Finding 7497 (2022-002)

Significant Deficiency
Requirement
C
Questioned Costs
-
Year
2022
Accepted
2024-01-05
Audit: 9730
Organization: Food Export USA - Northeast (PA)

AI Summary

  • Core Issue: The Organization failed to follow internal controls for cash disbursements and claims approval, risking potential noncompliance.
  • Impacted Requirements: Compliance with 2 CFR Part 200 regarding cash disbursements and cash management is not being met.
  • Recommended Follow-up: Implement and adhere to documented internal controls to ensure proper review before cash disbursements and claims submissions.

Finding Text

Federal Agency: U.S. Department of Agriculture. Federal Program Name: Market Access Program and Agricultural Trade Promotion Program. Assistance Listing Number: 10.601 & 10.618. Federal Award Identification Number and Year: EUSAFEC MAP-2022. Award Period: January 1, 2022 through June 30, 2023. Type of Finding: Significant Deficiency in Internal Control over Compliance. Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of cash disbursements and cash management. The Organization should follow the internal controls designed to ensure compliance with those provisions. Condition: During our testing, we noted the Organization did not follow the adequate internal controls designed to ensure valid cash disbursements were approved prior to payment and claims were approved prior to submission. Questioned costs: None. Context: During our testing, it was noted that the Organization was not performing internal control procedures that are documented in its policies and procedures around cash disbursements for approval of payments and around claims submitted that did not have documented approval prior to submission to the federal government. Cause: The Organization was aware of the internal control procedures documented in its policies but did not follow the procedures. There was noted compensating controls around cash disbursements and cash management that were documented in our testing. Effect: The auditors noted no instances of noncompliance with the provisions of cash disbursements or claims submitted; however, the lack of internal controls over these compliance requirements provides an opportunity for noncompliance. Repeat Finding: The finding is not a repeat of a finding in the immediately prior year. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to cash disbursement payments and claims submitted. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

DEPARTMENT OF AGRICULTURE. Market Access Program and Agricultural Trade Promotion Program Assistance Listing Number: 10.601 & 10.618. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to cash disbursement payments and claims submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Food Export-Northeast, under the direction of the new Executive Director /CEO, has undergone a significant restructuring effective July 2023. This restructure has resulted in the installation of a Chief Financial Officer, reporting directly to the Executive Director/CEO. Similar “C-suite” positions now exist in Operations, Programs, and Communications. This has significantly increased the scope and ability for oversight and internal control. Internal policies and procedures are currently under review; any changes to policies and procedures will be made as needed/identified. Increased monitoring and enforcement of existing internal control measures has already resulted in improved completeness and accuracy of financial reporting. In September 2023, the Food Export staff met with FAS staff to review procedures and policies, including meetings with Management to review and evaluate controls. The feedback from those meetings will be incorporated into any updates on procedure. Names of the contact person(s) responsible for corrective action: Brendan Wilson, Food Export Executive Director/CEO; Michelle Rogowski, Chief Operating Officer, Laura England, Deputy Director/Chief Communications Officer; Robert Lowe, CPA, Chief Financial Officer; Teresa Miller, Chief Program and Partnership Officer. Planned completion date for corrective action plan: December 31, 2023. If the U.S. Department of Agriculture has questions regarding this plan, please call Laura England at (215) 599-9738 or contact via email at lengland@foodexport.org.

Categories

Allowable Costs / Cost Principles Cash Management Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 7498 2022-002
    Significant Deficiency
  • 583939 2022-002
    Significant Deficiency
  • 583940 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.601 Market Access Program $8.86M
10.618 Agricultural Trade Promotion Program $4.45M