Finding 574024 (2024-004)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-08-20
Audit: 364615
Organization: The Food Trust (PA)

AI Summary

  • Core Issue: Lack of documentation showing that vendor suspension and debarment checks were performed before transactions, leading to a significant deficiency in internal controls.
  • Impacted Requirements: Non-compliance with 2 CFR Part 200, which mandates effective internal controls over federal awards to ensure proper vendor management.
  • Recommended Follow-up: Implement a formal process to document vendor verification before transactions, especially for amounts over $25,000, to mitigate compliance risks.

Finding Text

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 574021 2024-002
    Significant Deficiency Repeat
  • 574022 2024-004
    Significant Deficiency
  • 574023 2024-002
    Significant Deficiency Repeat
  • 574025 2024-002
    Significant Deficiency Repeat
  • 574026 2024-002
    Significant Deficiency Repeat
  • 574027 2024-002
    Significant Deficiency Repeat
  • 574028 2024-003
    Significant Deficiency Repeat
  • 574029 2024-003
    Significant Deficiency Repeat
  • 574030 2024-003
    Significant Deficiency Repeat
  • 1150463 2024-002
    Significant Deficiency Repeat
  • 1150464 2024-004
    Significant Deficiency
  • 1150465 2024-002
    Significant Deficiency Repeat
  • 1150466 2024-004
    Significant Deficiency
  • 1150467 2024-002
    Significant Deficiency Repeat
  • 1150468 2024-002
    Significant Deficiency Repeat
  • 1150469 2024-002
    Significant Deficiency Repeat
  • 1150470 2024-003
    Significant Deficiency Repeat
  • 1150471 2024-003
    Significant Deficiency Repeat
  • 1150472 2024-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $502,816
10.331 Gus Schumacher Nutrition Incentive Program $326,573
10.175 Farmers Market and Local Food Promotion Program $182,432
93.991 Preventive Health and Health Services Block Grant $150,000
10.225 Community Food Projects $71,155
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $65,012
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $37,834
10.531 State Agency: Farm to School Program Training and Curricula $15,797
21.027 Coronavirus State and Local Fiscal Recovery Funds $15,775
10.575 Farm to School Grant Program $11,085
10.170 Specialty Crop Block Grant Program - Farm Bill $2,138