Finding Text
Reference Number: 2022–008 Prior Year Finding: No Federal Agency: US Department of Agriculture (USDA) Pass-through Agency: Various Federal Program: The Food Distribution Cluster ALN Number: Various Compliance Requirement: Eligibility Type of Finding: Material Weakness, Material Non-compliance Criteria or specific requirement: In accordance with the Code of Federal Regulations a sub recipient must be either a public agency or a private entity possessing tax-exempt status under the Internal Revenue Code and must enter into a written agreement with the state agency, or with another recipient agency where permitted, binding it to perform the duties of a recipient agency (7 CFR sections 247.4, 247.7(a), 251.3(d), and 251.5(a)). Individual recipients must sign the Certificate of eligibility form (EFA-7), which is a self-declaration that they meet all the eligibility requirements to participate in in the program. Specifically, the participants are required to self-declare their household’s gross income is at or below the applicable TEFAP income guideline amount and they are prohibited from selling, bartering, or trading food received through this program. Condition: We made a total of 23 selections for the agreements signed with the sub-recipients (“Sub ERAs”), of which 4 Sub ERAs did not have signed agreements. To test the eligibility of individual recipients, we made a total of 60 selections of individuals who received food commodities from warehouses that maintained self-declaration forms. Of the 60 selections, there was no evidence that 14 of the individuals signed the self-declaration form. Additionally, the Division managed distribution sites that collectively distributed approximately $637,969 worth of food commodities that did not require or maintain self-declaration forms for the participants. Cause: Management was not aware that that the agreements with the sub recipients are required to be maintained and certain distributions sites were not aware of the grant requirements requiring individuals to self-certify their eligibility. Effect: Ineligible Sub-recipients or individual participants could receive grant funded food commodities, which can lead to the grantor withholding future funding. Questioned Costs: $637,969 Recommendation: We recommend management take steps to ensure sub-recipient agreements are retained and the distribution sites maintain sign-in sheets requiring participants to self-certify they meet the grant eligibility requirements. Views of responsible officials: See Corrective Action Plan.