FAC Explorer

Finding 529187 (2024-005)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-20
Audit: 347167
Organization: Oregon Food Bank, Inc. (OR)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: The Organization lacks a procurement policy that aligns with Federal regulations.
  • Impacted Requirements: Failure to maintain documented procedures for procurement transactions as required by 2 CFR §200.317 to 327.
  • Recommended Follow-up: Develop a compliant procurement policy and establish controls to ensure adherence, along with retaining documentation of procurement history.

Finding Text

Criteria – 2 CFR §200.317 to 327 – Procurement Standards. The recipient or subrecipient must maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in §200.317 through §200.327. Condition/context – The Organization did not have a procurement policy that complied with Federal regulations and did not retain documentation as to the significant history of procurements that would show compliance with the policy. We observed that the organization awarded contracts to vendors but did not have a procurement policy that matched Federal procurement standards. Questioned costs – None reported. Cause/effect – The Organization did not have policies or controls to ensure compliance with Federal regulations regarding procurements. Documentation as to the significant history of procurements, including from vendors, was not available to show compliance with procurement standards. Repeat finding – Yes, prior year finding 2023-001. Recommendation – The Organization should develop a procurement policy that matches Federal procurement standards and internal controls to ensure the policy is followed. The Organization should also retain documentation as to the significant history of procurements to show that the procurement policy was followed.

Corrective Action Plan

OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Corrective Action Plan: Oregon Food Bank finalized and implemented a procurement policy and a specific procurement policy for purchases made with federal funds, aligned with federal procurement standards and effective October 2024. Internal controls will be established to ensure adherence to the policy, and procedures will require retaining documentation of the procurement process to demonstrate compliance. These improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date is June 30, 2026.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment

Other Findings in this Audit

  • 529179 2024-003
    Material Weakness
  • 529180 2024-003
    Material Weakness
  • 529181 2024-003
    Material Weakness
  • 529182 2024-004
    Significant Deficiency
  • 529183 2024-004
    Significant Deficiency
  • 529184 2024-004
    Significant Deficiency
  • 529185 2024-004
    Significant Deficiency
  • 529186 2024-004
    Significant Deficiency
  • 529188 2024-005
    Significant Deficiency Repeat
  • 529189 2024-005
    Significant Deficiency Repeat
  • 529190 2024-005
    Significant Deficiency Repeat
  • 529191 2024-005
    Significant Deficiency Repeat
  • 1105621 2024-003
    Material Weakness
  • 1105622 2024-003
    Material Weakness
  • 1105623 2024-003
    Material Weakness
  • 1105624 2024-004
    Significant Deficiency
  • 1105625 2024-004
    Significant Deficiency
  • 1105626 2024-004
    Significant Deficiency
  • 1105627 2024-004
    Significant Deficiency
  • 1105628 2024-004
    Significant Deficiency
  • 1105629 2024-005
    Significant Deficiency Repeat
  • 1105630 2024-005
    Significant Deficiency Repeat
  • 1105631 2024-005
    Significant Deficiency Repeat
  • 1105632 2024-005
    Significant Deficiency Repeat
  • 1105633 2024-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $24.91M
10.568 Emergency Food Assistance Program (administrative Costs) $3.05M
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $2.44M
10.331 Gus Schumacher Nutrition Incentive Program $1.21M
10.187 The Emergency Food Assistance Program (tefap) Commodity Credit Corporation Eligible Recipient Funds $665,503
10.565 Commodity Supplemental Food Program $495,889
21.027 Coronavirus State and Local Fiscal Recovery Funds $177,939
97.024 Emergency Food and Shelter National Board Program $175,055
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $129,411
10.177 Regional Food System Partnerships $55,344