Finding 7529 (2023-001)

Significant Deficiency
Requirement
B
Questioned Costs
-
Year
2023
Accepted
2024-01-05
Audit: 9830
Organization: Second Harvest Heartland (MN)

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance for the Commodity Supplemental Food Program.
  • Impacted Requirements: The failure to properly review and track CSFP box sign-out signatures violates 2 CFR 200.303, which mandates effective internal controls for managing federal awards.
  • Recommended Follow-Up: Implement a separate review of signature log cover sheets by an independent agent to ensure accuracy and compliance.

Finding Text

Information on the Federal Program: Assistance Listing Number 10.565—Commodity Supplemental Food Program, U.S. Department of Agriculture. Pass-Through Entities and Award Numbers: Minnesota Department of Health, award number 204642. Compliance Requirement: Allowable Costs. Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal entity to 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, including Activities Allowed or Unallowed, Allowable Costs and Cost Principles. Condition: Controls were not operating to ensure that CSFP box sign out signatures were properly reviewed and tracked against reported totals. Cause: One monthly signature log for a CSFP distribution site had fewer signatures on their box sign out sheet than were reported on the signature log cover sheet. These should never be different, as the log cover sheet should be a representation of the number of signatures in the sign out sheet. The site representative responsible for ensuring these amounts agree did not perform the designed control. Effect or Potential Effect: Unallowable costs or activities could be charged to the grant. Questioned Costs: None Context: The number of boxes distributed reported on the summary signature log did not agree to the supporting signature detail. Repeat Finding: No Recommendation: We recommend a separate review of signature log cover sheets be documented by an agent independent of the distribution site. Views of Responsible Officials: Agree and controls have been implemented.

Corrective Action Plan

Audit Finding: ALN: 10.656 Grant No.: 204642 Grant Period: Year ended September 30, 2023 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action: • Site Coordinator verifies what Site Partner reports as distributed numbers through counting signatures and confirms with distribution log from Site Partner. o Site Coordinator then writes number of signatures counted/verified, with their initials, on log cover printed from Site Distribution spreadsheet. • Then, another Site Coordinator recounts signatures and verifies that the signatures counted/verified match what is on the cover sheet, and initials cover sheet. Additionally, they will then verify that the signatures counted/verified match what is in the Side Distribution spreadsheet. • Paperwork is then filed by month. Monthly paperwork is reconciled by staff/volunteers who check that all components are included, and that all paperwork is accounted for. o Paperwork is then stored in warehouse once missing paperwork/missing components have been accounted for/documented [secondary verification]. Anticipated Completion Date: The updated monthly signature verification process will begin with the November 2022 set of site paperwork. The monthly paperwork reconciliation process was implemented with staff/volunteers in August 2023.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 7530 2023-002
    Significant Deficiency
  • 583971 2023-001
    Significant Deficiency
  • 583972 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.569 Emergency Food Assistance Program (food Commodities) $9.13M
10.565 Commodity Supplemental Food Program $4.97M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.10M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $699,842
10.568 Emergency Food Assistance Program (administrative Costs) $286,195
10.576 Senior Farmers Market Nutrition Program $5,972