Finding 584238 (2022-001)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2024-01-08
Audit: 10130
Organization: Golden Harvest Food Bank, Inc. (GA)

AI Summary

  • Core Issue: A significant deficiency in internal controls over compliance was identified, specifically regarding the eligibility of subrecipients for TEFAP products.
  • Impacted Requirements: Compliance with 7 CFR §251.3(d) and §251.5(a) was not met, as one agency lacked the necessary TEFAP agreement on file.
  • Recommended Follow-Up: Strengthen controls to verify eligibility, maintain documentation, and implement a checklist for each agency to ensure compliance during recertification and new subrecipient additions.

Finding Text

Finding 2022-001 Federal Agency: Department of Agriculture Federal Program: Food Distribution Cluster CFDA: #10.568, 10.569 Compliance Requirement: Eligibility for Subrecipients Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes – 2021-001 Criteria: 7 CFR §251.3(d) and §251.5(a) – Eligibility for Subrecipients Prior to making commodities available, eligible recipient agencies to which the state agency has delegated responsibility for the distribution of The Emergency Food Assistance Program (“TEFAP”) commodities must ensure that an organization applying for participation in the program meets the definition of an “eligible recipient agency”. An eligible recipient agency means an organization which is either public, or is private, possessing tax exempt status. Private organizations possessing tax exempt status must (i) be currently operating another federal program requiring tax-exempt status under the Internal Revenue Code (“IRC”), or (ii) possess documentation from the Internal Revenue Service (“IRS”) recognizing tax-exempt status under the IRC, or (iii) if not in possession of such documentation, be automatically tax exempt as “organized or operated exclusively for religious purposes” under the IRC. Condition: From a sample of twenty-five (25) agencies who distributed TEFAP products during the fiscal year, the following exception was noted: * One (1) agency did not have a FY21-22 TEFAP agreement on file. Question Costs: N/A Context: The Organization has a policy whereby an agency’s eligibility status is checked by either reviewing the IRS website to ensure an entity’s tax-exempt status, or obtaining documentation from an entity verifying the entity is automatically tax-exempt by being an organization organized or operated exclusively for religious purposes. The entity in question was noted as a church. Cause: Controls were not in place to ensure eligibility status is documented and filed with the subrecipient’s file prior to distribution. Effects: Ineligible subrecipients may receive TEFAP products. Recommendations: We recommend controls be strengthened to ensure eligibility status is confirmed and support is maintained verifying a subrecipient is eligible to received TEFAP products each year during recertification and when new subrecipients are added during the year. In order for a subrecipient to be eligible to receive TEFAP products, the subrecipient must be tagged as such in the inventory system. We recommend the Organization strengthen its internal controls to include maintaining a checklist to be included in each distributing agency’s file which includes the check for documentation supporting the agency’s eligibility including each required document. The forms should be reviewed to ensure proper verification was made and all contracts are signed and dated by both the agency and the Organization. A check could also be made that the agency was properly set up and eligible qualifiers checked in the inventory system. At the beginning of each fiscal year, a report should be reviewed of all agencies and their qualifiers. This should be checked against the agencies’ files to ensure 1) the removal of any qualifiers for which documentation has not been received, and 2) follow-up of agencies to obtain the necessary documents. This will ensure completeness, timeliness, and consistency among all agencies and all documents. Management’s Response: Management concurs with the finding.

Categories

Eligibility Subrecipient Monitoring Significant Deficiency Equipment & Real Property Management

Other Findings in this Audit

  • 7790 2022-001
    Significant Deficiency Repeat
  • 7791 2022-002
    Significant Deficiency Repeat
  • 7792 2022-003
    Significant Deficiency Repeat
  • 7793 2022-001
    Significant Deficiency Repeat
  • 7794 2022-002
    Significant Deficiency Repeat
  • 7795 2022-003
    Significant Deficiency Repeat
  • 7796 2022-001
    Significant Deficiency Repeat
  • 7797 2022-002
    Significant Deficiency Repeat
  • 7798 2022-003
    Significant Deficiency Repeat
  • 7799 2022-001
    Significant Deficiency Repeat
  • 7800 2022-002
    Significant Deficiency Repeat
  • 7801 2022-003
    Significant Deficiency Repeat
  • 584232 2022-001
    Significant Deficiency Repeat
  • 584233 2022-002
    Significant Deficiency Repeat
  • 584234 2022-003
    Significant Deficiency Repeat
  • 584235 2022-001
    Significant Deficiency Repeat
  • 584236 2022-002
    Significant Deficiency Repeat
  • 584237 2022-003
    Significant Deficiency Repeat
  • 584239 2022-002
    Significant Deficiency Repeat
  • 584240 2022-003
    Significant Deficiency Repeat
  • 584241 2022-001
    Significant Deficiency Repeat
  • 584242 2022-002
    Significant Deficiency Repeat
  • 584243 2022-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $4.72M
93.558 Temporary Assistance for Needy Families $599,720
10.568 Emergency Food Assistance Program (administrative Costs) $236,656
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $14,743
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $7,896