Finding 2023-001: Eligibility
Finding Type: Significant Deficiency in Internal Controls over Compliance
Federal Program Title and AL Number: The Emergency Food Assistance Program (TEFAP) Commodity Credit Corporation Eligible Recipient Funds (10.187) and the Food Distribution Cluster (10.565, 10.568, 10.569).
Criteria: Per 7 CFR 251.5(c), a state agency may delegate to one or more eligible recipient agencies with which the state agency enters into an agreement the responsibility for the distribution of commodities and administrative funds. Per the State’s agreement with the Food Bank, the Food Bank shall submit household reports monthly.
Condition and context: As part of our eligibility testing, and in order to determine whether the onsite check-in forms were complete, we agreed the onsite check-in forms for our eligibility selections to the household distribution reports. For six out of the 38 statistically valid samples, the number of unduplicated households serviced on the check-in forms did not agree to the household distribution reports. This condition was noted for five out of 11 months selected for completeness.
Cause: The Food Bank did not have controls in place to ensure the accuracy of the Household Participation reports.
Effect: The number of eligible households that received food distributions was not accurately reported to the State.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Food Bank implement controls to ensure the accuracy of the Household Participation report.Management Response and Planned Corrective Action:
The Agency Relations Management team created a procedure to ensure all agency and program TEFAP household distribution reports are accurately entered into the CDSS reporting platform.
The TEFAP Specialist will run a CERES report by the 5th of every month showing all agencies and programs that received TEFAP the previous month. This report will be used as the checklist to ensure a TEFAP report is received and that the household information gets entered into the CDSS household reporting platform.
Once the TEFAP Specialist enters the reports into the CDSS platform, the Agency Relations Specialist will double-check the entered entries in the CDSS platform against the agency/program report to ensure accuracy before the CDSS portal is locked for the month.
In order to ensure the effectiveness of these procedures, the Agency Relations Supervisor will audit 25 reports randomly every month. The Agency Relations Supervisor will review the audit results with the Agency Relations Manager on a monthly basis.
For the Food Bank’s TEFAP direct to individuals programs, the Programs Coordinator will tally all TEFAP food recipients from the TEFAP sign-in sheets and complete the HHP TEFAP report form. Before submitting the TEFAP HHP report to the TEFAP Specialist, a different Programs Coordinator will double-check the total number of persons served from the TEFAP sign-in sheets and verify the HHP TEFAP report form is correct. After the second check is completed, the Programs Coordinator will send the monthly LARFB TEFAP reports via email to the TEFAP Specialist with a copy to the Programs Manager and Programs Director.
The Agency Relations Manager will oversee the processes completed by the Agency Relations Supervisor, TEFAP Specialist, and Agency Relations Specialist assigned to these procedural tasks.
The Programs Manager will oversee the work of the Programs Coordinators for the Food Bank’s direct to individuals programs. We will implement this corrective action on or before June 30, 2024.
Individuals responsible for corrective action:
Elizabeth Cervantes – Sr. Director of Product Acquisition and Agency Relations 323.974.0073 Hilda Ayala – Sr. Director of Programs & Policy 323.353.0114 Steven Meisberger – Chief Financial Officer 323.318.0319