Finding Text
Finding 2023-002: Special Tests and Provisions - Material Weakness in Internal Control Over Compliance
and Material Noncompliance for Eligibility
Federal Program: The Emergency Food Assistance Program (TEFAP) (Assistance Listing #10.569)
Federal Agency: U.S. Department of Agriculture
Award Year: 2022–2023
Criteria: Management is responsible for establishing and maintain an effective control over compliance. A strong
internal control system ensures that compliance requirements are met.
Condition: During audit procedures we noted the total number of food recipients during the reporting period July 1, 2022 to June 30, 2023 was 63,060, which was vouched to the Link2Feed website database. Management also tracks a separate spreadsheet the number of bags of food delivered to offsite locations where food recipients pick up a bag of food, which totaled 129,150, which is a difference of 66,090 food recipients not being tracked within the Link2Feed website.
Cause: Due to the COVID-19 pandemic, deliveries were being made via delivery services and directly to offsite locations with populations of food recipients that were not being tracked via Link2Feed by manual entry by management.
Effect: Failure to track recipients that received food distributions from the program is not compliant with the
TEFAP program and could cause ineligible food recipients to receive support from this program.
Context: Management did not implement effective internal controls over distributions of USDA Foods to food
recipients within the required method via the Link2Food website.
Questioned costs: $0
Repeat Finding: 2022-002
Recommendation: We recommend management to establish oversight controls to ensure compliance
requirements are met.
Views of responsible officials: Given the change in distribution approach, the large number of partner sites, and
partner site employee turnover, it was challenging to enforce compliance with the use of the Link2Feed website
by food recipients. In addition to strides made in FY23 towards correcting the documentation of recipients in Link2Feed, Brown Bag has continued to address it in FY24 by performing the following:
1) Build communication and relationships with the remaining sites still not documenting (16 of our current 77)
2) Issued emails and phone calls asking sites to update their records.
3) Making appointments and visiting all sites still not in compliance to make an in-person plea to comply.
4) As of November 1, issue written communications warning any remaining sites that food deliveries will cease at the end of the year for any remaining sites not in compliance. No exceptions. Participants will be invited to go to the closest open MBBP site in their area.
5) Management is actively trying to close the loop on the remaining MOU’s, including SAHA, which remains unsigned. Deliveries will cease to any sites not covered with an MOU at the end of the calendar year. No exceptions.