EIN: 231669589
UEI: JELCDUJ37PS9
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 19, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 19, 2026 (23 days from today).
What is a management decision? →During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2024. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: The organization had an issue with the internal tracking schedule resulting in the monitoring not being completed within the required two-year period. Effect: The Organization collected data and monitored participating agencies after year end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 003. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Food Commodities) Assistance Listing Number: 10.569 Pass-through Agency: Pennsylvania Department of Agriculture Pass-through Number: 5-07-39-217 Award Period: July 1, 2021 – September 30, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards require compliance with the provisions of eligibility. The Organization should have procedures and controls in place to ensure distributing agencies of The Emergency Food Assistance Program (TEFAP) are eligible to receive commodities for distribution to their participants. Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2024. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: The organization had an issue with the internal tracking schedule resulting in the monitoring not being completed within the required two-year period. Effect: The Organization collected data and monitored participating agencies after year end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 003. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Agriculture 2024-005 • Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2024. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2026.
2023-003
The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Questioned Costs: None. Context: Management does not have a timely process for determining the allocation of eligible expenses for the administrative revenue received for the distribution of commodities. Management was able to provide a reasonable allocation methodology which was used to create the program expenditure detail for the audit period, however, was provided significantly after year-end. Cause: The Organization experienced turnover within the finance department which resulted in no formal procedures in place for the allocation of allowable costs. Effect: If the Organization does not have timely proper allocation procedures, the Organization could potentially recognize revenue that is not appropriately substantiated with allowable costs and activities in compliance with program requirements. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 004. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) Assistance Listing Number: 10.568 and 10.565 Pass-through Agency: Hunger Free Pennsylvania (HFP); Pennsylvania Department of Agriculture (PDA); Lehigh County (LC); Northampton County (NC); Carbon County (CC) Pass-through Number: 5-07-39-217 (PDA) Award Period: August 5, 2021 – December 31, 2024 (HFP); October 1, 2021 – September 30, 2026 (PDA, LC, NC, CC) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: For both CSFP and TEFAP, a recipient agency must use its administrative funds for activities for the administration of the programs. Such activities include but are not limited to transporting and storing USDA Foods within the state or within a recipient agency’s service area, determining the eligibility of program applicants, publishing the times and locations of food distribution, and issuing USDA Foods to eligible persons (7 CFR sections 247.25 and 251.8(e)). Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Questioned Costs: None. Context: Management does not have a timely process for determining the allocation of eligible expenses for the administrative revenue received for the distribution of commodities. Management was able to provide a reasonable allocation methodology which was used to create the program expenditure detail for the audit period, however, was provided significantly after year-end. Cause: The Organization experienced turnover within the finance department which resulted in no formal procedures in place for the allocation of allowable costs. Effect: If the Organization does not have timely proper allocation procedures, the Organization could potentially recognize revenue that is not appropriately substantiated with allowable costs and activities in compliance with program requirements. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 004. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.568 and 10.565 Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respectiveidentifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2026.
2023-004
During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Questioned Costs: There were known questioned costs identified in the amount of $6,868. Context: During our testing of community service block grant costs recorded during the beginning of the approved period of performance (January 2024), we noted there were thirty five transactions tested charged to the federal program in January 2024 for salary and related payroll taxes which are portion was incurred prior to the start of the contract period. Based on the review of the supporting documentation, it was noted that the payroll period was 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. The total amount of the transactions was $6,868. Cause: The Organization recorded the transactions into the general ledger based on the payroll period ending date and invoice date rather than the date the transactions were incurred by the Organization. Effect: If the organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 006. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Service Block Grant Assistance Listing Number: 93.569 Pass-through Agency: Pennsylvania Department of Community and Economic Development Pass-Through Number: Contract #C000082084 Award Period: January 1, 2022 – December 31, 2027 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The Organization should have procedures and controls in place to ensure expenses are charged to a federal program within the approved period of performance. In addition, in accordance with 2 CFR Part 200.403, allowable costs should be determined in accordance with generally accepted accounting principles (GAAP), therefore payroll accruals should be appropriately reflected when recording program expenditures. Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Questioned Costs: There were known questioned costs identified in the amount of $6,868. Context: During our testing of community service block grant costs recorded during the beginning of the approved period of performance (January 2024), we noted there were thirty five transactions tested charged to the federal program in January 2024 for salary and related payroll taxes which are portion was incurred prior to the start of the contract period. Based on the review of the supporting documentation, it was noted that the payroll period was 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. The total amount of the transactions was $6,868. Cause: The Organization recorded the transactions into the general ledger based on the payroll period ending date and invoice date rather than the date the transactions were incurred by the Organization. Effect: If the organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2023- 006. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
U.S. Department of Health and Human Services • Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will strengthen internal controls over the recording of grant-related invoices and payroll expenditures by requiring expenses to be recorded based on the actual date services are incurred rather than invoice date or payroll period end date. Finance staff will be retrained on period-of-performance requirements for federal programs, and a secondary review will be implemented for all federal grant postings to verify proper timing prior to submission for reimbursement or drawdown. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.
2023-006
During our testing of performance and special reporting, we noted that the Organization did not maintain documentation evidencing review or approval of submitted reports. The reports tested did not include evidence demonstrating that an authorized individual reviewed and approved the performance and special reports prior to submission. Questioned Costs: No questioned costs have been identified. Context: This condition was identified during testing of performance and special reporting for the federal program. For all items selected, documentation of review or approval was not available. Cause: The Organization has not implemented formalized procedures requiring documented review and approval of performance and special reports prior to submission. Additionally, roles and responsibilities related to report preparation, review, and approval have not been clearly defined or enforced. Effect: Without documented evidence of review and approval by an authorized individual, the Organization cannot demonstrate that performance and special reports were appropriately reviewed prior to submission. This increases the risk that reports may contain errors, omissions, or unsupported information and limits assurance that reported performance results are reliable and compliant with applicable reporting requirements Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should implement formal internal controls over performance and special reporting by establishing documented procedures that require review and approval of all reports prior to submission. Management should define clear roles and responsibilities for report preparation and independent review, ensure that reviews are performed by an authorized individual, and maintain documentation evidencing review and approval, such as signatures, dates, or electronic approvals, to support compliance with performance reporting requirements. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services; U.S. Department of the Treasury Federal Program Name: Low-Income Home Energy Assistance; Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 93.568, 21.027 Pass-through Agency: Pennsylvania Department of Community and Economic Development (Liheap/SLFRF); PA CDFI (SBG/SBGII) Pass-Through Number: Contract #C000073877 (Liheap); Contract #C000084605 (SLFRF); Contract #C000082280 (SBG); Contract #C000086369 (SBGII) Award Period: October 1, 2020 – September 30, 2025 (Liheap); December 12, 2022 - December 31, 2026 (SLFRF); June 27, 2022 - December 31, 2026 (SBG); February 5, 2024 - June 30, 2026 (SBG) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The compliance requirement for performance reporting requires organizations to establish and maintain effective internal controls to ensure that reported performance information is accurate, complete, timely, and verifiable. This includes documented procedures, clearly defined roles and responsibilities, evidence of supervisory review and approval by authorized personnel, and retention of supporting documentation sufficient to substantiate reported performance results. Condition: During our testing of performance and special reporting, we noted that the Organization did not maintain documentation evidencing review or approval of submitted reports. The reports tested did not include evidence demonstrating that an authorized individual reviewed and approved the performance and special reports prior to submission. Questioned Costs: No questioned costs have been identified. Context: This condition was identified during testing of performance and special reporting for the federal program. For all items selected, documentation of review or approval was not available. Cause: The Organization has not implemented formalized procedures requiring documented review and approval of performance and special reports prior to submission. Additionally, roles and responsibilities related to report preparation, review, and approval have not been clearly defined or enforced. Effect: Without documented evidence of review and approval by an authorized individual, the Organization cannot demonstrate that performance and special reports were appropriately reviewed prior to submission. This increases the risk that reports may contain errors, omissions, or unsupported information and limits assurance that reported performance results are reliable and compliant with applicable reporting requirements Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should implement formal internal controls over performance and special reporting by establishing documented procedures that require review and approval of all reports prior to submission. Management should define clear roles and responsibilities for report preparation and independent review, ensure that reviews are performed by an authorized individual, and maintain documentation evidencing review and approval, such as signatures, dates, or electronic approvals, to support compliance with performance reporting requirements. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
U.S. Department of Health and Human Services U.S. Department of Treasury • Significant Deficiency in Internal Control over Compliance Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During our testing of performance and special reporting, we noted that the Organization did not maintain documentation evidencing review or approval of submitted reports. The reports tested did not include evidence demonstrating that an authorized individual reviewed and approved the performance and special reports prior to submission. Recommendation: The Organization should implement formal internal controls over performance and special reporting by establishing documented procedures that require review and approval of all reports prior to submission. Management should define clear roles and responsibilities for report preparation and independent review, ensure that reviews are performed by an authorized individual, and maintain documentation evidencing review and approval, such as signatures, dates, or electronic approvals, to support compliance with performance reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will implement formal internal controls over performance and special reporting by developing and documenting standardized procedures for the preparation, review, and approval of all required federal performance and special reports. These procedures will clearly define roles and responsibilities for report preparation and independent review, including identification of authorized individuals responsible for final approval. Evidence of review and approval—including signatures, dates, or electronic approval records—will be retained in the grant file to support compliance with reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2026.
During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Questioned Costs: None. Context: Ten reports were requested for audit testing and management was unable to provide three of the requested reports. Cause: The Organization experienced turnover within the finance department, which contributed to inadequate document retention and weaknesses in controls over the preparation and maintenance of required financial reports. Effect: Failure to maintain and provide required financial reports constitutes noncompliance with federal reporting and record retention requirements. The absence of key source documentation limits assurance that reported program activity is accurate and supported and increases the risk of misreporting or unsupported claims being submitted to the federal government. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-through Agency: Northampton County Pass-Through Number: N/A Award Period: May 18, 2022 - December 31, 2025; October 1, 2022 - December 31, 2025 May 18, 2023 - December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: Uniform Guidance requires recipients to prepare, submit, and retain accurate, complete, and timely financial reports for federal awards in accordance with 2 CFR §§ 200.327 and 200.328. Additionally, federal record retention requirements (2 CFR § 200.334) require organizations to maintain supporting documentation sufficient to substantiate reported program activity. Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Questioned Costs: None. Context: Ten reports were requested for audit testing and management was unable to provide three of the requested reports. Cause: The Organization experienced turnover within the finance department, which contributed to inadequate document retention and weaknesses in controls over the preparation and maintenance of required financial reports. Effect: Failure to maintain and provide required financial reports constitutes noncompliance with federal reporting and record retention requirements. The absence of key source documentation limits assurance that reported program activity is accurate and supported and increases the risk of misreporting or unsupported claims being submitted to the federal government. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
U.S. Department of Treasury • Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will require that all supporting documentation related to financial reporting—including reports, source data, approvals, and correspondence—be retained electronically within Sage Intacct using standardized attachment and naming conventions. Management will implement periodic monitoring procedures, including supervisory review and internal spot checks, to verify that reports are timely submitted and that documentation is properly retained in Sage Intacct in accordance with applicable federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.
During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Questioned Costs: None. Context: Procurement and suspension and debarment documentation was requested for audit testing, and management was unable to provide documentation supporting the procurement selections and vendor eligibility for the items tested. Cause: The Organization did not consistently maintain required procurement and suspension and debarment documentation. Contributing factors included turnover within the finance and administrative functions and the absence of formalized procedures to ensure documentation is retained and readily available for audit and monitoring purposes. Effect: The lack of procurement and suspension and debarment documentation constitutes noncompliance with federal procurement requirements. Without adequate documentation, the Organization cannot demonstrate that procurements were conducted in accordance with Uniform Guidance or that vendors were eligible to receive federal funds and increases the risk of improper or unsupported expenditures of federal funds. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award. Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-through Agency: Northampton County Pass-Through Number: N/A Award Period: May 18, 2022 - December 31, 2025; October 1, 2022 - December 31, 2025 May 18, 2023 - December 31, 2025 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: Uniform Guidance (2 CFR §§ 200.317–200.327) requires non‑federal entities to maintain written procurement procedures and documentation supporting procurement transactions to ensure compliance with applicable federal regulations. Additionally, entities must verify and document that vendors are not suspended or debarred from participation in federal programs prior to award, in accordance with 2 CFR § 200.214. Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Questioned Costs: None. Context: Procurement and suspension and debarment documentation was requested for audit testing, and management was unable to provide documentation supporting the procurement selections and vendor eligibility for the items tested. Cause: The Organization did not consistently maintain required procurement and suspension and debarment documentation. Contributing factors included turnover within the finance and administrative functions and the absence of formalized procedures to ensure documentation is retained and readily available for audit and monitoring purposes. Effect: The lack of procurement and suspension and debarment documentation constitutes noncompliance with federal procurement requirements. Without adequate documentation, the Organization cannot demonstrate that procurements were conducted in accordance with Uniform Guidance or that vendors were eligible to receive federal funds and increases the risk of improper or unsupported expenditures of federal funds. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award. Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries’ Corrective Action Plan.
Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of procurement and suspension and debarment requirements for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to provide documentation supporting the procurement selections tested. Additionally, documentation evidencing verification of vendor suspension and debarment status was not available for the selections reviewed. Recommendation: The Organization should strengthen internal controls over procurement and suspension and debarment compliance by establishing and enforcing written procedures requiring documentation of procurement methods, vendor selection, and verification of suspension and debarment status prior to award.Management should ensure that all required documentation is retained in accordance with federal record retention requirements and subject to supervisory review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization implemented internal controls over procurement and suspension and debarment compliance. Management will require documented verification of vendor eligibility through appropriate federal and state exclusion checks or signed certification, as applicable, before any procurement is finalized. All procurement-related documentation—including procurement method determinations, vendor selection support, debarment verification evidence, and required certifications—will be subject to supervisory review to ensure completeness and compliance with federal requirements. The Organization will retain all procurement and debarment documentation in the official procurement or contract file in accordance with federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2026.
FAC accepted this audit on May 19, 2025 — management decision was due November 19, 2025.
During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: The Organization had scheduling challenges with one of the agencies which resulted in a lapse in the timing of the monitoring to not be within the required two-year period. For the other agency there was documentation that could not be located. Effect: The Organization collected data and monitored participating agencies after year-end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Food Commodities) Assistance Listing Number: 10.569 Pass-through Agency: Pennsylvania Department of Agriculture Pass-through Number: 5-07-39-217 Award Period: July 1, 2021 – September 30, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of eligibility. The Organization should have procedures and controls in place to ensure distributing agencies of The Emergency Food Assistance Program (TEFAP) are eligible to receive commodities for distribution to their participants. Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: The Organization had scheduling challenges with one of the agencies which resulted in a lapse in the timing of the monitoring to not be within the required two-year period. For the other agency there was documentation that could not be located. Effect: The Organization collected data and monitored participating agencies after year-end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-003. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.
2022-003
The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Questioned Costs: None. Context: Management does not have a timely process for determining the allocation of eligible expenses for the administrative revenue received for the distribution of commodities. Management was able to provide a reasonable allocation methodology which was used to create the program expenditure detail for the audit period, however, was provided significantly after year-end. Cause: The Organization experienced turnover within the finance department which resulted in no formal procedures in place for the allocation of allowable costs. Effect: If the Organization does not have timely proper allocation procedures, the Organization could potentially recognize revenue that is not appropriately substantiated with allowable costs and activities in compliance with program requirements. Repeat Finding: No Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) Assistance Listing Number: 10.569 and 10.565 Pass-through Agency: Hunger Free Pennsylvania (HFP); Pennsylvania Department of Agriculture (PDA); Lehigh County (LC); Northampton County (NC); Carbon County (CC) Pass-through Number: 5-07-39-217 (PDA) Award Period: October 1, 2021 – June 30, 2023 (HFP); October 1, 2019 – September 30, 2023 (PDA) October 1, 2020 – September 30, 2021(LC, NC, CC); October 1, 2021 – September 30, 2022 (LC, NC, CC); October 1, 2022 – September 30, 2023 (LC, NC, CC) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: For both CSFP and TEFAP, a recipient agency must use its administrative funds for activities for the administration of the programs. Such activities include but are not limited to transporting and storing USDA Foods within the state or within a recipient agency’s service area, determining the eligibility of program applicants, publishing the times and locations of food distribution, and issuing USDA Foods to eligible persons (7 CFR sections 247.25 and 251.8(e)). Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Questioned Costs: None. Context: Management does not have a timely process for determining the allocation of eligible expenses for the administrative revenue received for the distribution of commodities. Management was able to provide a reasonable allocation methodology which was used to create the program expenditure detail for the audit period, however, was provided significantly after year-end. Cause: The Organization experienced turnover within the finance department which resulted in no formal procedures in place for the allocation of allowable costs. Effect: If the Organization does not have timely proper allocation procedures, the Organization could potentially recognize revenue that is not appropriately substantiated with allowable costs and activities in compliance with program requirements. Repeat Finding: No Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. CACLV has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2025.
During our testing, we noted there was a lack of supporting documentation and/or an approval for expenses charged to the federal programs. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: During the testing of the food distribution cluster programs, it was observed that there was a lack of supporting documentation for two out of forty transactions tested, and no approval documentation for four out of the forty transactions tested totaling $3,442. In the testing of the community service block grant, it was found that there was a lack of supporting documentation for one out of sixty transactions tested, and no approval documentation for fifteen out of the sixty transactions tested totaling $2,238.73. The respective payment documentation for two transactions was also unable to be located. In the testing of the community development block grant, it was noted that there was a lack of supporting documentation for three out of forty transactions tested, and no approval documentation for two out of the forty transactions tested totaling $15,902. The respective payment documentation for one transaction was also unable to be located. Cause: The Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Also, due to the turnover in the Organization, there was a lapse in the approval process surrounding credit card purchases. Effect: If the Organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: The Organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services; U.S. Department of Housing and Urban Development Federal Program Name: Commodity Supplemental Food Program (Administrative); The Emergency Food Assistance Program (Administrative); Community Service Block Grant; Community Development Block Grant Assistance Listing Number: 10.565; 10.568; 93.569; 14.218 Pass-through Agency: Hunger Free Pennsylvania (HFP); Pennsylvania Department of Agriculture (PDA); Lehigh County (LC); Northampton County (NC); Carbon County (CC); Pennsylvania Department of Community and Economic Development (DCED) Pass-Through Number(s): 5-07-39-217 (PDA); Contract #C000067069 (DCED); City of Allentown (CA) Contract #C000082084 (DCED) Award Period: October 1, 2021 – June 30, 2023 (HFP); October 1, 2019 – September 30, 2023 (PDA) October 1, 2020 – September 30, 2021(LC, NC, CC); October 1, 2021 – September 30, 2022 (LC, NC, CC); October 1, 2022 – September 30, 2023 (LC, NC, CC); April 1, 2020 – September 30, 2022 (DCED); January 1, 2021 – September 30, 2022 (DCED); January 1, 2022 – December 31, 2027 (DCED); July 1, 2020 - December 31, 2022 (NC); January 1, 2022 – December 31, 2023 (CA); January 1, 2022 - September 15, 2023 (LC); January 1, 2021 - December 31, 2022 (NC); January 1, 2021 - September, 2022 (NC) Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures and controls in place to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained, reviewed, and retained to support all transactions. Condition: During our testing, we noted there was a lack of supporting documentation and/or an approval for expenses charged to the federal programs. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: During the testing of the food distribution cluster programs, it was observed that there was a lack of supporting documentation for two out of forty transactions tested, and no approval documentation for four out of the forty transactions tested totaling $3,442. In the testing of the community service block grant, it was found that there was a lack of supporting documentation for one out of sixty transactions tested, and no approval documentation for fifteen out of the sixty transactions tested totaling $2,238.73. The respective payment documentation for two transactions was also unable to be located. In the testing of the community development block grant, it was noted that there was a lack of supporting documentation for three out of forty transactions tested, and no approval documentation for two out of the forty transactions tested totaling $15,902. The respective payment documentation for one transaction was also unable to be located. Cause: The Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Also, due to the turnover in the Organization, there was a lapse in the approval process surrounding credit card purchases. Effect: If the Organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-004. Recommendation: The Organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Agriculture U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative) – Assistance Listing No. 10.569 and 10.565 Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there was a lack of supporting documentation and/or an approval for expenses charged to the federal programs. Recommendation: The Organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a more robust contract compliance process. This process included internal audits which will include review of financial records. The organization has also developed a credit card policy which staff will be trained on before completion date. The organization also implemented a new credit card platform which allows for better tracking, approval and documentation of purchases. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.
2022-004
During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: During the review of community service block grant costs recorded at the beginning of the approved period of performance (January 2023), seventeen transactions charged to the federal program in January 2023 for salary and related payroll taxes were observed. A portion of these expenses was incurred before the start of the contract period, specifically covering the payroll period from 12/24/22 to 1/6/23, with the first eight days outside the approved period of performance. The total amount of these transactions was $11,606. Additionally, one transaction for facilities maintenance totaling $2,625 lacked supporting documentation. Furthermore, during testing of costs recorded towards the end of the period of performance (September 2022), there was one transaction for outside computer services amounting to $1,125, with the invoice indicating services performed in October 2022. During the testing of community development block grant costs recorded at the beginning of the approved period of performance (January 2023), seventeen transactions charged to the federal program in January 2023 for salary and related payroll taxes were noted, with a portion incurred prior to the start of the contract period. The total amount of these transactions was $1,079. Cause: The Organization recorded the transactions into the general ledger based on the payroll period ending date and invoice date rather than the date the transactions were incurred by the Organization. In addition, the Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: If the Organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-005. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Housing and Urban Development Federal Program Name: Community Service Block Grant; Community Development Block Grant Assistance Listing Number: 93.569; 14.218 Pass-through Agency: Pennsylvania Department of Community and Economic Development; City of Bethlehem (CB); Northampton County (NC) Pass-Through Number: Contract #C000067069; Contract #C000082084; B-22-MC-42-0003 (CB) Award Period: April 1, 2020 – September 30, 2022; January 1, 2022 – December 31, 2027; January 1, 2022 - December 31, 2023 (CB); July 1, 2020 - December 31, 2022 (NC) Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The Organization should have procedures and controls in place to ensure expenses are charged to a federal program within the approved period of performance. In addition, in accordance with 2 CFR Part 200.403, allowable costs should be determined in accordance with generally accepted accounting principles (GAAP), therefore payroll accruals should be appropriately reflected when recording program expenditures. Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: During the review of community service block grant costs recorded at the beginning of the approved period of performance (January 2023), seventeen transactions charged to the federal program in January 2023 for salary and related payroll taxes were observed. A portion of these expenses was incurred before the start of the contract period, specifically covering the payroll period from 12/24/22 to 1/6/23, with the first eight days outside the approved period of performance. The total amount of these transactions was $11,606. Additionally, one transaction for facilities maintenance totaling $2,625 lacked supporting documentation. Furthermore, during testing of costs recorded towards the end of the period of performance (September 2022), there was one transaction for outside computer services amounting to $1,125, with the invoice indicating services performed in October 2022. During the testing of community development block grant costs recorded at the beginning of the approved period of performance (January 2023), seventeen transactions charged to the federal program in January 2023 for salary and related payroll taxes were noted, with a portion incurred prior to the start of the contract period. The total amount of these transactions was $1,079. Cause: The Organization recorded the transactions into the general ledger based on the payroll period ending date and invoice date rather than the date the transactions were incurred by the Organization. In addition, the Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: If the Organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2022-005. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/24/22 - 1/6/23, which the first eight days were prior to the start of the period of performance. There was also one transaction selected for testing where no supporting documentation was able to be located and one transaction that was incurred after the period of performance for the program. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Organization expanded contract compliance to include financial contract compliance. The organization will also implement grant tracking and spend management modules in the accounting software to assist with monitoring expenses applied to contracts. A new process will also be implemented regarding payroll related expenses to ensure the correct period is used for federal expenditures. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.
2022-005
During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: The Organization did not have proper controls in place to ensure the salary and wages charged to the program were based on the records of the work performed. Cause: The Organization experienced turnover within the finance department causing a lack of a review of the salary allocations to the program. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential non-compliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Development Block Grant Assistance Listing Number: 14.218 Pass-through Agency: City of Allentown (CA); City of Bethlehem (CB); Northampton County (NC); Lehigh County (LC) Pass-Through Number: N/A Award Period: January 1, 2022 - December 31, 2024 (CA); January 1, 2022 - December 31, 2023 (CB); July 1, 2020 - December 31, 2022 (NC); January 1, 2020 - December 31, 2021 (LC); January 1, 2022 - September 15, 2023 (LC); January 1, 2021 - December 31, 2022 (NC); January 1, 2021 - September 15, 2022 (NC); April 1, 2023 - March 24, 2024 (NC) Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria: 3 CFR Part 200 Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Questioned Costs: No questioned costs above the $25,000 threshold have been identified. Context: The Organization did not have proper controls in place to ensure the salary and wages charged to the program were based on the records of the work performed. Cause: The Organization experienced turnover within the finance department causing a lack of a review of the salary allocations to the program. Effect: When an organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications, it can lead to a lack of transparency and accountability in recording and reporting personnel costs. This can result in inaccurate financial statements and potential non-compliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan
U.S. Department of Housing and Urban Development Material Weakness in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: During our testing, we noted that 21 out of 40 transactions tested exhibited a variance in the recalculation of wages charged to the program. This variance was identified when comparing the wages charged to the program with the time and effort documented on the timesheet for the respective programs. Recommendation: We recommend the time and effort documentation be regularly reviewed by appropriate personnel to ensure accuracy and completeness of personnel cost documentation is appropriately reported to the federal program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a new process for wages charged to a program to ensure accuracy. This will also be monitored regularly and tracked through the accounting software in the grant spend management module. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.
The Organization was unable to locate contract and/or contract extensions for federal funding awarded expended during the period. Questioned Costs: None. Context: The Organization was unable to locate one contract and two contract extension agreements for awards expended during the audit period. Cause: The Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: If the Organization is unable to provide contractual agreements related to federal awards, management may not be able to substantiate the allowability of costs incurred or activities performed with the funds expended. This could result in potential disallowances of costs and the need to return funds to the federal government. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation, such as contracts or agreements, is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Development Block Grant Assistance Listing Number: 14.218 Pass-through Agency: Northampton County (NC) Pass-Through Number: N/A Award Period: January 1, 2021 - December 31, 2022 (NC); January 1, 2021 - September 15, 2022 (NC); October 1, 2021 - September 30, 2022 (NC) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The Organization is responsible for maintaining all contracts and agreements for federal funding received to ensure compliance with requirements and ensuring costs are allowable, allocable, and reasonable under the terms of the federal award. Condition: The Organization was unable to locate contract and/or contract extensions for federal funding awarded expended during the period. Questioned Costs: None. Context: The Organization was unable to locate one contract and two contract extension agreements for awards expended during the audit period. Cause: The Organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Effect: If the Organization is unable to provide contractual agreements related to federal awards, management may not be able to substantiate the allowability of costs incurred or activities performed with the funds expended. This could result in potential disallowances of costs and the need to return funds to the federal government. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation, such as contracts or agreements, is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate contract and/or contract extensions for federal funding awarded expended during the period. Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation, such as contracts or agreements, is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a contract database and review process for all new and existing contracts. This process includes appropriate naming conventions across all platforms to ensure accuracy in records. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2024.
The Organization was unable to locate documentation related to performance and financial reporting. Questioned Costs: None. Context: The Organization could not find the performance reports for three contracts and the financial report for one contract in the federal program. Cause: Due to turnover in the finance department, reporting documentation was likely misfiled or not saved before submission to the funding agency. Effect: In the event that the Organization fails to provide documentation demonstrating that reports were correctly submitted to the federal awarding agency, management may be unable to verify compliance with the established requirements for federal funding. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Community Development Block Grant Assistance Listing Number: 14.218 Pass-through Agency: Lehigh County (LC); Northampton County (NC) Pass-Through Number: N/A Award Period: March 27, 2020 - September 30, 2023 (LC); January 1, 2021 - December 31, 2022 (NC); January 1, 2021 - September 15, 2022 (NC) Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: The Organization is responsible for maintaining comprehensive documentation to ensure compliance with all federal award reporting requirements. Condition: The Organization was unable to locate documentation related to performance and financial reporting. Questioned Costs: None. Context: The Organization could not find the performance reports for three contracts and the financial report for one contract in the federal program. Cause: Due to turnover in the finance department, reporting documentation was likely misfiled or not saved before submission to the funding agency. Effect: In the event that the Organization fails to provide documentation demonstrating that reports were correctly submitted to the federal awarding agency, management may be unable to verify compliance with the established requirements for federal funding. Repeat Finding: N/A: Not a repeat finding Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Housing and Urban Development Significant Deficiency in Internal Control over Compliance Community Development Block Grant – Assistance Listing No. 14.218 Condition: The Organization was unable to locate documentation related to performance and financial reporting. Recommendation: The Organization should review its internal controls and procedures to ensure all relevant documentation is reviewed and retained for all federal funds awarded. Implementing a standardized process for document retention and training staff on proper record-keeping practices can help mitigate this issue in the future. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization has developed a more robust contract compliance process which includes document retention and training. The organization recently reviewed and updated the document retention policy and trained staff responsible for record-keeping. The organization also began conducting internal audits to ensure documentation is reviewed and retained properly. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is December 31, 2024.
FAC accepted this audit on April 23, 2024 — management decision was due October 23, 2024.
During our testing, we identified there was no monitoring performed for 9 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2022. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: Due to Covid-19 changes in the ability to perform on-site monitoring, the Organization did not collect data from participating agencies on a timely basis during the year to establish eligibility of the recipients of food distributed. Effect: The Organization collected data and monitored participating agencies after year-end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: Yes Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture Federal Program Name: The Emergency Food Assistance Program (Food Commodities) Assistance Listing Number: 10.569 Pass-through Agency: Pennsylvania Department of Agriculture Pass-through Number: 5-07-39-217 Award Period: July 1, 2021 – June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of eligibility. The Organization should have procedures and controls in place to ensure distributing agencies of The Emergency Food Assistance Program (TEFAP) are eligible to receive commodities for distribution to their participants. Condition: During our testing, we identified there was no monitoring performed for 9 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2022. Questioned Costs: None. Context: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Cause: Due to Covid-19 changes in the ability to perform on-site monitoring, the Organization did not collect data from participating agencies on a timely basis during the year to establish eligibility of the recipients of food distributed. Effect: The Organization collected data and monitored participating agencies after year-end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Repeat Finding: Yes Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Food Distribution Cluster– Assistance Listing No. 10.569 During our testing, we identified there was no monitoring performed for 9 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2022. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Create a new folder checklist indicating all mandatory items that should be included in each agency folder for compliance. 2. Review all current documentation and assure each item has been properly placed in the appropriate folder. 3. Create a schedule to complete all outstanding monitoring. We are 10% complete to date. 4. Schedule 3-5 monitoring visits per week over the timeframe of January – March 2023. 5. File all monitoring reports in the appropriate folder. 6. Weekly Agency Relations check-ins scheduled beginning January 9th 2023. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.
2021-002
During our testing, we noted there was a lack of supporting documentation and approval for expenses charged to the federal program. Questioned Costs: None. Context: During our testing, we noted there was a lack of supporting documentation for four out of forty transactions tested charged to the federal program totaling $1,165. There were also seventeen out of the forty transactions tested that documentation of approval for the transaction was not present. Cause: The organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Also, due to the turnover in the organization, there was a lapse in the approval process surrounding credit card purchases. Effect: If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: Not a repeat finding. Recommendation: The organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Service Block Grant Assistance Listing Number: 93.569 Pass-through Agency: Pennsylvania Department of Community and Economic Development Pass-Through Number(s): Contract #C000067069 Contract #C000082084 Award Period: July 1, 2021 – June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of allowable costs and allowable activities. The Organization should have procedures and controls in place to ensure federal funds are only expended on allowable costs and allowable activities as dictated in the contract and budget of the program. Proper documentation should be maintained, reviewed, and retained to support all transactions. Condition: During our testing, we noted there was a lack of supporting documentation and approval for expenses charged to the federal program. Questioned Costs: None. Context: During our testing, we noted there was a lack of supporting documentation for four out of forty transactions tested charged to the federal program totaling $1,165. There were also seventeen out of the forty transactions tested that documentation of approval for the transaction was not present. Cause: The organization experienced turnover within the finance department and the missing supporting documentation was likely misfiled and therefore unable to be located. Also, due to the turnover in the organization, there was a lapse in the approval process surrounding credit card purchases. Effect: If the organization does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: Not a repeat finding. Recommendation: The organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Community Service Block Grant– Assistance Listing No. 93.569 During our testing, we noted there was a lack of supporting documentation for four out of forty transactions tested charged to the federal program totaling $1,165. There were also seventeen out of the forty transactions tested that documentation of approval for the transaction was not present. Recommendation: The organization should review its internal controls and procedures to ensure all supporting documentation is retained for federally funded purchases. Also, management should implement an approval control for purchases incurred on the Organizations credit cards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Organizations collaborating with federal agencies must adhere to specific guidelines to ensure financial documentation and compliance. In cases where expenses require further explanation or justification, it is imperative for the organization to promptly provide any necessary additional documentation, such as receipts or contracts, to substantiate these expenses. Moreover, if expenditures surpass the approved budget or funding limits, collaboration with the federal agency is essential to adjust these parameters accordingly. This may involve renegotiating the budget or seeking additional funding where necessary. It's also crucial to address any discrepancies between the approved period for project execution and the actual expenditure of funds, known as period of performance findings, as swiftly as possible. By providing explanations for any delays or discrepancies and taking corrective action as needed, organizations can avoid potential penalties or repayment obligations. Additionally, ensuring that invoices are accurately entered into the accounting software is vital for maintaining precise financial records. Therefore, reviewing and refining the process for entering invoices can help prevent errors and ensure that expenses are correctly allocated to the appropriate period. Overall, adhering to these guidelines promotes financial diligence and compliance, facilitating smooth collaboration with federal agencies and minimizing potential risks. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is October 1, 2023.
During our testing, we noted there were transactions charged to the federal program that were incurred prior to the beginning of the performance period. Questioned Costs: None. Context: During our testing of costs recorded during the beginning of the approved period of performance (January 2022), we noted there were two transactions charged to the federal program in January 2022 for utility costs. Based on the review of the supporting invoices costs were incurred prior to the beginning of the performance period in November and December 2021. The total amount of the transactions was $1,370.49. Cause: The organization recorded the transactions into the general ledger based on the invoice date rather than the date the services were provided by the vendor. Effect: If the organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: Not a repeat finding. Recommendation: The organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices into the accounting software to ensure the correct period is used. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Service Block Grant Assistance Listing Number: 93.569 Pass-through Agency: Pennsylvania Department of Community and Economic Development Pass-Through Number: Contract #C000067069 (2021 CSBG Expenditure Period 1/1/21 - 12/31/21) Award Period: July 1, 2021 – June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of period of performance. The Organization should have procedures and controls in place to ensure expenses are charged to a federal program within the approved period of performance. Condition: During our testing, we noted there were transactions charged to the federal program that were incurred prior to the beginning of the performance period. Questioned Costs: None. Context: During our testing of costs recorded during the beginning of the approved period of performance (January 2022), we noted there were two transactions charged to the federal program in January 2022 for utility costs. Based on the review of the supporting invoices costs were incurred prior to the beginning of the performance period in November and December 2021. The total amount of the transactions was $1,370.49. Cause: The organization recorded the transactions into the general ledger based on the invoice date rather than the date the services were provided by the vendor. Effect: If the organization includes expenses either incurred before the start date or after the end date of the approved period of performance, it could result in funds being required to be returned to the funding agency. Repeat Finding: Not a repeat finding. Recommendation: The organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices into the accounting software to ensure the correct period is used. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Community Service Block Grant– Assistance Listing No. 93.569 During our testing of costs recorded during the beginning of the approved period of performance (January 2022), we noted there were two transactions charged to the federal program in January 2022 for utility costs. Based on the review of the supporting invoices costs were incurred prior to the beginning of the performance period in November and December 2021. The total amount of the transactions was $1,370.49. Recommendation: The organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices into the accounting software to ensure the correct period is used. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Upon discovery of costs incurred prior to the approved performance period. The first step involves meticulously examining the documentation to verify the timing of the expenses and identify any ineligible costs. Following this, the organization will transparently communicate the issue with the funding agency, providing a detailed explanation of how the error occurred and expressing commitment to resolving it. Guidance will be sought from the funding agency on the appropriate steps to take, with a focus on reconciling the total amount of costs incurred before the performance period and adjusting the grant budget accordingly to exclude these expenses. If any funds were already disbursed for the ineligible costs, efforts will be made to reimburse the funding agency or adjust future disbursements as necessary. To prevent similar issues in the future, internal controls will be reviewed and strengthened, including implementing stricter procedures for expense approval and providing training to staff involved in grant management. Detailed documentation of all corrective actions taken will be maintained, and continuous monitoring of expenses and adherence to grant requirements will be conducted throughout the remainder of the performance period to mitigate any potential compliance risks. Through diligent implementation of this corrective action plan, the organization aims to address the issue effectively and prevent funds from being required to be returned to the funding agency. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2024.
During our testing of payroll transactions for the major federal programs, we were unable review the internal control of approved timesheets for any employees with payroll periods selected for testing prior to April 2, 2022. Questioned Costs: None identified. Context: During our testing of payroll transactions for the major federal programs tested, we were unable review approved timesheets for any employees with payroll periods tested prior to April 2, 2022. It was noted there were proper approvals in place for the transactions selected that were processed by the new payroll provider. Cause: The organization changed payroll providers on April 2, 2022 and no longer has access to pull time information from the old system as the provider purges all time keeping information after about 6 months. Effect: If the organization does not have adequate controls in place and documented could result in employees being funded with federal awards in which they did not actually perform work. Repeat Finding: Not a repeat finding. Recommendation: The Organization should ensure when there are changes in the Organization’s service providers, there are procedures in place to ensure all necessary documentation is retained to support the controls in place for federal spending. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
Show full finding ▾Hide full finding ▴Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services; U.S. Department of the Treasury Federal Program Name: The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative); Community Service Block Grant; Emergency Rental Assistance Program Assistance Listing Number: 10.565; 10.568; 93.569; 21.020 Pass-through Agency: Hunger Free Pennsylvania; Pennsylvania Department of Agriculture; Pennsylvania Department of Community and Economic Development; Lehigh County Pass-Through Number: 5-07-39-217; Contract #C000067069; Contract #C000082084 Award Period: July 1, 2021 – June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Other Matters Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards requires compliance with the provisions of allowable costs and allowable activities. The Organization should have documentation supporting the internal controls for the approval of personnel costs charged to federal programs for the time and effort employees spend working on the respective programs of the Organization. Condition: During our testing of payroll transactions for the major federal programs, we were unable review the internal control of approved timesheets for any employees with payroll periods selected for testing prior to April 2, 2022. Questioned Costs: None identified. Context: During our testing of payroll transactions for the major federal programs tested, we were unable review approved timesheets for any employees with payroll periods tested prior to April 2, 2022. It was noted there were proper approvals in place for the transactions selected that were processed by the new payroll provider. Cause: The organization changed payroll providers on April 2, 2022 and no longer has access to pull time information from the old system as the provider purges all time keeping information after about 6 months. Effect: If the organization does not have adequate controls in place and documented could result in employees being funded with federal awards in which they did not actually perform work. Repeat Finding: Not a repeat finding. Recommendation: The Organization should ensure when there are changes in the Organization’s service providers, there are procedures in place to ensure all necessary documentation is retained to support the controls in place for federal spending. View of Responsible Officials and Planned Corrective Action: Please refer to Community Action Committee of the Lehigh Valley, Inc. and subsidiaries’ Corrective Action Plan.
U.S. Department of Agriculture; U.S. Department of Health and Human Services; U.S. Department of the Treasury - Assistance Listing Numbers: 10.565; 10.568; 93.569; 21.020 During our testing of payroll transactions for the major federal programs tested, we were unable review approved timesheets for any employees with payroll periods tested prior to April 2, 2022. It was noted there were proper approvals in place for the transactions selected that were processed by the new payroll provider. Recommendation: The Organization should ensure when there are changes in the Organizations service providers, there are procedures in place to ensure all necessary documentation is retained to support the controls in place for federal spending. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: A comprehensive data migration plan must be developed, outlining steps to securely transfer data from the old system to the new one while safeguarding the integrity and confidentiality of sensitive information. During the transfer process, it is crucial to verify the completeness and accuracy of all transferred documentation through audits or spot-checks. Clear communication with employees about the transition, including any changes in payroll processes or documentation requirements, is essential to maintain transparency and trust. Training should be provided to relevant staff members on how to use the new payroll system and adhere to organizational policies for maintaining documentation. Compliance with regulatory requirements regarding document retention, data security, and privacy must be assured by the new payroll service provider. Regular audits of payroll processes and documentation should be conducted to ensure ongoing compliance and identify areas for improvement. Establishing secure storage and backup procedures for payroll documentation is paramount to ensure records remain accessible and protected from loss or unauthorized access. Periodic review and updates of procedures for document retention and payroll processing are necessary to adapt to changes in regulations, technology, or business practices. By following these steps, the organization can ensure a smooth transition between payroll service providers while maintaining the integrity and effectiveness of its controls and compliance efforts. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: The new Payroll provider, iSolve, was implemented on April 2, 2022.
FAC accepted this audit on September 13, 2022 — management decision was due March 13, 2023.
The Organization did not have proper internal controls in place to accurately report commodity inventory levels in the Organization?s inventory management system. Commodity receipts were not accurately or timely entered to the inventory management system to allow for proper and timely periodic reconciliation of commodity inventory quantities and proper valuation of the commodity inventory. Criteria: The Organization?s inventory management system internal controls should require timely data entry of all commodity receipts to allow for timely periodic reconciliation of inventory quantities and proper valuation of the commodity inventory. Cause: The timely data entry of commodity receipts into the inventory management system was not prioritized by the Organization which did not allow for proper periodic reconciliation of inventory quantities and inventory valuation and individuals tasked with using the inventory management system require additional training to properly capture inventory activity. Effect: Significant audit reconciliations and adjustments were required to properly report the commodity inventory and federal commodity activity in accordance with generally accepted accounting principles and federal financial reporting requirements. Questioned Costs: None. Recommendation: The Organization should prioritize the timely data entry of commodity receipts to the inventory management system to allow for periodic reconciliation of inventory quantities and valuation. Additionally, the Organization should provide additional training on the inventory management system to responsible personnel. This will allow for accurate and timely reporting of the Organization?s commodity inventory levels and activity for financial reporting purposes. View of Responsible Officials and Planned Corrective Action: The Organization agrees with the finding and plans to implement the recommended action.
Show full finding ▾Hide full finding ▴U.S. Department of Agriculture Passed through Lehigh, Northampton and Carbon counties from Commonwealth of Pennsylvania Program: Food Distribution Cluster- CFDA# 10.565, 10.568 & 10.569 Condition: The Organization did not have proper internal controls in place to accurately report commodity inventory levels in the Organization?s inventory management system. Commodity receipts were not accurately or timely entered to the inventory management system to allow for proper and timely periodic reconciliation of commodity inventory quantities and proper valuation of the commodity inventory. Criteria: The Organization?s inventory management system internal controls should require timely data entry of all commodity receipts to allow for timely periodic reconciliation of inventory quantities and proper valuation of the commodity inventory. Cause: The timely data entry of commodity receipts into the inventory management system was not prioritized by the Organization which did not allow for proper periodic reconciliation of inventory quantities and inventory valuation and individuals tasked with using the inventory management system require additional training to properly capture inventory activity. Effect: Significant audit reconciliations and adjustments were required to properly report the commodity inventory and federal commodity activity in accordance with generally accepted accounting principles and federal financial reporting requirements. Questioned Costs: None. Recommendation: The Organization should prioritize the timely data entry of commodity receipts to the inventory management system to allow for periodic reconciliation of inventory quantities and valuation. Additionally, the Organization should provide additional training on the inventory management system to responsible personnel. This will allow for accurate and timely reporting of the Organization?s commodity inventory levels and activity for financial reporting purposes. View of Responsible Officials and Planned Corrective Action: The Organization agrees with the finding and plans to implement the recommended action.
Finding 2021-002 ? Material Weakness Recommendation: The Organization should prioritize the timely data entry of commodity receipts to the inventory management system to allow for periodic reconciliation of inventory quantities and valuation. Additionally, the Organization should provide additional training on the inventory management system to responsible personnel. This will allow for accurate and timely reporting of the Organization?s commodity inventory levels and activity for financial reporting purposes. Corrective Action: CACLV agrees with the recommendation. The Food Bank Operations Manager has and continues to develop policies and procedures for inventory management at Second Harvest Food Bank. This includes continuing education and training on the inventory management system for any responsible personnel. The Senior Accountant will continue t to ensure accurate and timely reports of the commodity inventory levels.
The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Criteria: The Organization?s internal control should monitor the eligibility of recipients for food distributed during the fiscal year to participating agencies. Cause: Due to Covid-19 changes in the ability to perform on-site monitoring and employee turnover in supervisory positions of the program, the Organization did not collect data from participating agencies on a timely basis during the year to establish eligibility of the recipients of food distributed. Effect: The Organization collected data and monitored participating agencies after year end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Questioned Costs: None. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. d Corrective Action: The Organization agrees with the finding and to resume on-site monitoring and update regular monitoring activities
Show full finding ▾Hide full finding ▴U.S. Department of Agriculture Passed through Lehigh, Northampton and Carbon counties from Commonwealth of Pennsylvania Program: Food Distribution Cluster- CFDA# 10.565, 10.568 & 10.569 Condition: The Organization did not have proper internal controls in place to monitor the food distributed in a timely manner. Criteria: The Organization?s internal control should monitor the eligibility of recipients for food distributed during the fiscal year to participating agencies. Cause: Due to Covid-19 changes in the ability to perform on-site monitoring and employee turnover in supervisory positions of the program, the Organization did not collect data from participating agencies on a timely basis during the year to establish eligibility of the recipients of food distributed. Effect: The Organization collected data and monitored participating agencies after year end and without the ability to modify food distributions if any ineligible participants were discovered during the program year. No ineligible distributions were determined based on subsequent monitoring activities. Questioned Costs: None. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. d Corrective Action: The Organization agrees with the finding and to resume on-site monitoring and update regular monitoring activities
Finding 2021-003 ? Material Weakness Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Corrective Action: CACLV will monitor participating agencies to ensure food distributions are to eligible participants only. The Food Bank?s Agency Relations Coordinators will review the eligibility of the nonprofits affiliated with the Second Harvest Food Bank through monthly data collection reports. In April 2021, new agency relations staff began reviewing the eligibility of the nonprofits on a consistent monthly basis. The Food Bank?s Agency Relations staff also resumed onsite monitoring in August 2021 and ensure affiliated nonprofits are complying, which includes confirmation of obtaining eligibility determination from food recipients.
FAC accepted this audit on March 25, 2021 — management decision was due September 25, 2021.
The Organization distributed food to an ineligible participant agency under the Emergency Food Assistance Program. Criteria: Eligibility requirements for the program require that participating agencies have a program agreement on file with the Organization and maintain self-declaration forms for all individuals who receive the commodities at the participating agency. Cause: Controls related to food distribution at the Organization allowed federal commodities under the Emergency Food Assistance Program to be distributed to a participating agency without the proper eligibility for the program. Effect: One participating agency and its related agencies received federal commodities during the program year that they were ineligible to receive. Context: A sample of participating agencies was taken from the food distributed during the year ended June 30, 2020 for proper eligibility documentation. One agency was found that did not have the proper documentation to receive assistance under the program. Once discovered, all distributions to the agency and its related entities were compiled to determine the amount of the unallowed distributions. Questioned Costs: $57,605. Recommendation: The Organization should revise the control procedures that allowed the federal commodities to be distributed to an ineligible agency. Additional controls over the program should be implemented to be sure the proper eligibility documentation is on file before these food commodities are distributed. The Organization should contact their oversight agency for instructions on how to correct the questioned costs. View of Responsible Officials and Planned Corrective Action: The Organization agrees with the recommendation and has already revised the controls related to the program. The Organization will contact the United States Department of Agriculture contact to correct the questioned costs in this finding.
Show full finding ▾Hide full finding ▴Finding 2020-001 - Material Weakness U.S. Department of Agriculture Passed through Lehigh, Northampton and Carbon counties from Commonwealth of Pennsylvania Program: Food Distribution Cluster- CFDA# 10.565, 10.568 & 10.569 Condition: The Organization distributed food to an ineligible participant agency under the Emergency Food Assistance Program. Criteria: Eligibility requirements for the program require that participating agencies have a program agreement on file with the Organization and maintain self-declaration forms for all individuals who receive the commodities at the participating agency. Cause: Controls related to food distribution at the Organization allowed federal commodities under the Emergency Food Assistance Program to be distributed to a participating agency without the proper eligibility for the program. Effect: One participating agency and its related agencies received federal commodities during the program year that they were ineligible to receive. Context: A sample of participating agencies was taken from the food distributed during the year ended June 30, 2020 for proper eligibility documentation. One agency was found that did not have the proper documentation to receive assistance under the program. Once discovered, all distributions to the agency and its related entities were compiled to determine the amount of the unallowed distributions. Questioned Costs: $57,605. Recommendation: The Organization should revise the control procedures that allowed the federal commodities to be distributed to an ineligible agency. Additional controls over the program should be implemented to be sure the proper eligibility documentation is on file before these food commodities are distributed. The Organization should contact their oversight agency for instructions on how to correct the questioned costs. View of Responsible Officials and Planned Corrective Action: The Organization agrees with the recommendation and has already revised the controls related to the program. The Organization will contact the United States Department of Agriculture contact to correct the questioned costs in this finding.
Finding 2020-001, Material Weakness Recommendation The Orgru1izatio11 should revise the control procedures that allowed the federal commodities to be distributed to an ineligible agency. Additional controls over the program should be implemented to be sure the proper eligibility documentation is on file before these food commodities are distributed. The Organization should contact their oversight agency for instructions on how to correct the questioned costs. Corrective Action Tbe Community Action Committee of the Lehigh Valley, lnc., d/b/a Second Harvest Food Bank of Lehigh Valley and Northeast Peru1syJvania, proposes the following adjustments to correct tbe finding in our audit of the Temporary Emergency Fo0d Assistance Program for the fiscal year ending June 30 2020. CACLV wiU monitor the disbursement of federal commodities by implementing new and more aggressive controJs. When federal commodities are ordered by any nonprofit affiliated with the Second Harvest Food Bank for tbe purpose of distributing food assistance, the Food Bank's Agency Relations Coordinator will review the eligibility of the nonprofit. The Food Bank's Operations Manager will review the product and sign off on the agency's eligibility. Finally CACL V' s Fiscal Department will review all federal distributions each month. Additionally, the Second Harvest Food Bank will no longer offer federal product during its ''Free Friday" prnmotion to ensure that .ineligible organizations do not mistakenly receive the product. Although there were $57,605 in questioned costs, the Pennsylvanfa Department of Agriculture determined that the product was used for congregate feeding and was therefore an eligible use. No replacement product will need to be purchased nor will the Second Harvest Food Bank need to make monetary amends for the referenced costs. The Pennsylvania Department of Agriculture will meet with CACL V management and Second Harvest Food Bank staff to address this finding and provide proper training to review and reinforce the proper disbursal of federally funded product. We want to assure the Department that we take our stewardship of federal resources very seriously and fully intend to operate our program with no further incident.
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