FAC Explorer

Finding 566887 (2024-002)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-06-24
Audit: 359751
Organization: Thurston County Food Bank (WA)
Auditor: Johnson Stone & Pagano P S

AI Summary

  • Core Issue: The Organization failed to conduct required site visits for subrecipient monitoring, violating federal compliance standards.
  • Impacted Requirements: Internal controls under 2 CFR 200.332(d) were not followed, risking unallowable costs being charged to federal funds.
  • Recommended Follow-up: The Organization should improve its monitoring processes and assign responsibilities to ensure compliance during grant periods.

Finding Text

2024-002 Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Criteria Internal controls and other compliance knowledge should provide adequate subrecipient monitoring under federal awards. Per 2 CFR 200.332(d), pass-through entities should "monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations and the terms and conditions of the subaward; and that subaward performance goals are achieved." This would include site monitoring visits during the grant's period of performance. Condition The Organization provided funds to subrecipients under its direct award from the Department of Treasury. Payments to subrecipients are made on a reimbursement basis. Context During our subrecipient monitoring testing, we noted one of the three subrecipients tested did not receive a site visit during the grant agreement period. Per our discussion with management, the Organization was unable to schedule a monitoring visit during the grant agreement period. The Organization was also unable to provide sufficient documentation that supported adequate monitoring activities were in place during the grant agreement period. Cause The error was caused by the Organization's negligence to conduct any monitoring activity during the grant agreement period. Effect Unallowable activities or cost principles could be charged to the Department of Treasury. Repeat Finding No.Auditor's Recommendation It is recommended that the Organization reevaluates its internal controls over subrecipient monitoring to ensure that proper monitoring is occurring during the grant agreement period. The Organization should also consider who is responsible for the monitoring activity, and if necessary, assign those responsibilities to an employee who has a more flexible schedule that can accommodate the scheduled monitoring visits.

Corrective Action Plan

Finding 2024-002: TCFB was negligent in monitoring sub-recipients during the grant agreement period. The Problem: During testing, the auditors noted that one of the three sub-recipients tested did not receive a site visit during the grant agreement period. Established standard Three programs require sub-agency monitoring visits. EFAP (3 sub-agencies) requires each sub-agency to be monitored on site once each biennium (2 year agreement period). TEFAP (40 sub-agencies) requires that a minimum of 10% of sub-agencies be monitored on site once each year. CSFP (3 sub-agencies) requires each agency to be monitored on site once every 2 years. Actions to be taken - While the EFAP requirement was used for the test above, this plan will include monitoring visits for all 3 programs. - An additional staff member will be added to the contract team who will be responsible for on-site monitoring visits once trained. - Plan out which agencies should be visited in which years. - Create a shared calendar that includes the time period visits should take place in, when to reach out to sub-agencies to schedule visits, who will conduct visits. Action assignments - The entire contract team will work together to create the calendar. - Contracts Manager and Commodities Coordinator will plan out which sub-agencies to visit, and when to visit them. - Contracts Manager and new team member will schedule and conduct the first 2 site reviews, after which the new team member will take the lead with support from the others. Timeline - The additional contract team member will be added July 1st, 2025, but will be available for planning meetings before then. - Ordered list of sub-agency visits will be completed by the end of May 2025. - Shared calendar will be fully completed by the end of June 2025. Verify implementation - The Contracts Manager will report progress of monitoring visits to CEO/ED quarterly.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 566871 2024-001
    Significant Deficiency
  • 566872 2024-001
    Significant Deficiency
  • 566873 2024-001
    Significant Deficiency
  • 566874 2024-001
    Significant Deficiency
  • 566875 2024-001
    Significant Deficiency
  • 566876 2024-001
    Significant Deficiency
  • 566877 2024-001
    Significant Deficiency
  • 566878 2024-001
    Significant Deficiency
  • 566879 2024-001
    Significant Deficiency
  • 566880 2024-001
    Significant Deficiency
  • 566881 2024-001
    Significant Deficiency
  • 566882 2024-001
    Significant Deficiency
  • 566883 2024-001
    Significant Deficiency
  • 566884 2024-001
    Significant Deficiency
  • 566885 2024-001
    Significant Deficiency
  • 566886 2024-001
    Significant Deficiency
  • 566888 2024-002
    Significant Deficiency
  • 566889 2024-002
    Significant Deficiency
  • 566890 2024-002
    Significant Deficiency
  • 566891 2024-002
    Significant Deficiency
  • 566892 2024-003
    Significant Deficiency
  • 566893 2024-003
    Significant Deficiency
  • 566894 2024-003
    Significant Deficiency
  • 566895 2024-003
    Significant Deficiency
  • 566896 2024-003
    Significant Deficiency
  • 1143313 2024-001
    Significant Deficiency
  • 1143314 2024-001
    Significant Deficiency
  • 1143315 2024-001
    Significant Deficiency
  • 1143316 2024-001
    Significant Deficiency
  • 1143317 2024-001
    Significant Deficiency
  • 1143318 2024-001
    Significant Deficiency
  • 1143319 2024-001
    Significant Deficiency
  • 1143320 2024-001
    Significant Deficiency
  • 1143321 2024-001
    Significant Deficiency
  • 1143322 2024-001
    Significant Deficiency
  • 1143323 2024-001
    Significant Deficiency
  • 1143324 2024-001
    Significant Deficiency
  • 1143325 2024-001
    Significant Deficiency
  • 1143326 2024-001
    Significant Deficiency
  • 1143327 2024-001
    Significant Deficiency
  • 1143328 2024-001
    Significant Deficiency
  • 1143329 2024-002
    Significant Deficiency
  • 1143330 2024-002
    Significant Deficiency
  • 1143331 2024-002
    Significant Deficiency
  • 1143332 2024-002
    Significant Deficiency
  • 1143333 2024-002
    Significant Deficiency
  • 1143334 2024-003
    Significant Deficiency
  • 1143335 2024-003
    Significant Deficiency
  • 1143336 2024-003
    Significant Deficiency
  • 1143337 2024-003
    Significant Deficiency
  • 1143338 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $4.01M
10.565 Commodity Supplemental Food Program $337,671
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $292,543
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $149,029
10.187 The Emergency Food Assistance Program (tefap) Commodity Credit Corporation Eligible Recipient Funds $111,038
21.027 Coronavirus State and Local Fiscal Recovery Funds $53,101
97.024 Emergency Food and Shelter National Board Program $15,000
14.218 Community Development Block Grants/entitlement Grants $8,125
10.568 Emergency Food Assistance Program (administrative Costs) $5,697