Finding 124 (2023-001)

Significant Deficiency Repeat Finding
Requirement
P
Questioned Costs
-
Year
2023
Accepted
2023-10-05
Audit: 182
Organization: Regional Food Bank of Oklahoma (OK)
Auditor: Hogantaylor LLP

AI Summary

  • Core Issue: The Food Bank failed to get Board approval for procurement over $500,000, violating its own policy.
  • Impacted Requirements: This breaches 2 CFR § 200.303 on internal controls, risking non-compliance with federal regulations.
  • Recommended Follow-Up: Implement a procedure to ensure all purchases under the program receive proper Board approval.

Finding Text

Finding: Item 2023-001 – Procurement and Debarment Federal Program – Child and Adult Care Food Program ALN (CFDA) Numbers – 10.558 Agency Award Number – DC-55-811 Federal Award Year – June 30, 2023 Federal Agency – U.S. Department of Agriculture Pass-Through Entity – Oklahoma Dept. of Education Questioned Costs $ - Criteria: 2 CFR § 200.303, Internal Controls requires that a non-Federal entity establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Food Bank's procurement policy states: The CEO will not enter into any new contracts or purchase agreements or new commitments of any kind valued at or above $500,000 per year without Board review and approval. Condition/contex: The Food Bank did not obtain proper approval by the Board for procurement of the food products used for the Child and Adult Care Food Program based on the policy for acquiring goods and services. Cause: The Food Bank did not follow its procurement policy for Board review and approval of the purchase contract under the federal program. Effect: Without appropriate approvals, the Food Bank could obtain food products that are not needed or from vendors who are not approved under the program. Repeat finding: Finding is a repeat of finding 2022-001. Recommendation: The Food Bank should institute a procedure to ensure appropriate approval of all purchases under the program. View of responsible officials: Management's response is reported in "Management's Views and Corrective Action Plan" at the end of this report.

Corrective Action Plan

At the beginning of FY23, the following steps were initiated to ensure board review and approval of all contracts over an annual value of $500,000 per internal financial policy: - The CFO will flag all contracts in excess of the stated threshold and notify the CEO, Executive Assistant, and board Treasurer that an action of the board will be required. - A standing agenda item will be added for the board finance committee to discuss any notable contracts and potential board approval requirements at each meeting. To prevent the case in which a contract is overlooked due to multiple contracts requiring consideration at the same time, the organization will seek out an automated solution such as electronic workflows or contract lifecycle management software to be implemented in FY24 in combination with the previously established actions above.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 576566 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $1.62M
10.568 Emergency Food Assistance Program (administrative Costs) $1.30M
10.558 Child and Adult Care Food Program $1.00M
93.558 Temporary Assistance for Needy Families $454,027
10.559 Summer Food Service Program for Children $433,913
10.565 Commodity Supplemental Food Program $316,364
10.182 Local Food Purchase Assistance $311,423
14.218 Community Development Block Grants/entitlement Grants $90,527
10.187 Emergency Food Assistance Program - Commodity Credit Corporation (administrative Costs) $72,751
21.027 Coronavirus State and Local Fiscal Recovery Funds $20,000