Finding 1210876 (2025-001)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-04-30

AI Summary

  • Core Issue: The Organization followed the grant agreement but incurred costs that are not allowed under federal guidelines, leading to a material weakness.
  • Impacted Requirements: Compliance with the Uniform Guidance (2 CFR sections 200.303 and 200.401) regarding allowable costs and internal controls was not met.
  • Recommended Follow-Up: Management should review both the OMB Compliance Supplement and grant agreements for future federal awards to ensure all costs are allowable.

Finding Text

Finding Reference Number: 2025-001 Finding Type: Material Weakness Assistance Listing Number: 10.185 Program Title: Local Food for Schools Cooperative Agreement Program Federal Agency: U.S. Department of Agriculture Pass-Through Entity: Florida Department of Agriculture and Consumer Services Compliance Requirement: A/B – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria: The Uniform Guidance, 2 CFR section 200.303 requires the recipient and subrecipient of Federal funds to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Additionally, the Uniform Guidance, 2 CFR section 200.401, requires the recipient and subrecipient of federal funds to apply cost principles in determining allowable costs under Federal awards. Condition: During the audit, it was noted that the grant agreement between the Organization and the Florida Department of Agriculture and Consumer Services allowed for administrative funding; to be no more than 25% of total eligible food purchases. Per review of the Uniform Guidance, 2 CFR Part 200, Appendix XI (the “OMB Compliance Supplement”) for ALN 10.185, direct or indirect costs associated with developing or administering the program are not allowable. Cause: The grant agreement with the pass-through entity allowed costs that were not allowable per the OMB Compliance Supplement. The Organization was unaware that the costs were unallowed as they solely followed the guidance outlined in their signed grant agreement with the pass-through entity. Effect: Although the Organization was in compliance with their subrecipient grant agreement, they were not in compliance with the Uniform Guidance. Questioned Costs: $246,202 Recommendation: We recommend that management review the OMB Compliance Supplement in addition to the grant agreement for any future federal awards received to ensure compliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles. Views of Responsible Officials: See attached Corrective Action Plan.

Corrective Action Plan

The Florida School Nutrition Association, Inc. (FSNA) acknowledges the audit finding regarding the misalignment between the pass-through entity’s grant agreement and the OMB Compliance Supplement for ALN 10.185. While the Association operated in accordance with the terms of the executed agreement with the Florida Department of Agriculture and Consumer Services, it was subsequently determined that certain administrative costs permitted under that agreement were not allowable under the Uniform Guidance (2 CFR Part 200). Finding 2025-001: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Upon identification of this discrepancy, FSNA has taken immediate and decisive action: Program Termination & Strategic Shift: FSNA has formally concluded its participation in the Local Food for Schools Cooperative Agreement Program and has ceased all related activities. The Association has made the strategic decision not to pursue or engage in federal grant programs of this nature moving forward. This determination ensures alignment with the organization’s operational capacity and mitigates compliance risk associated with complex federal cost principles. Final Resolution: The identified material weakness has been addressed through the discontinuation of the applicable program, thereby removing the operational conditions under which the noncompliance occurred. Future Funding Consideration (If Applicable): While FSNA does not anticipate pursuing similar federal awards, the organization has established an internal standard that any future funding opportunities, if considered, will undergo a comprehensive compliance review to ensure alignment with the Uniform Guidance (2 CFR Part 200), the OMB Compliance Supplement, and all grantspecific terms and conditions. Record Retention: FSNA will maintain all financial and supporting documentation related to the FY25 audit period in accordance with applicable federal record retention requirements.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.185 LOCAL FOOD FOR SCHOOLS COOPERATIVE AGREEMENT PROGRAM $1.97M