THE FOOD TRUST

EIN: 232678383

UEI: K5QVXHA4R9G4

Data as of August 26, 2026

THE FOOD TRUST10 audit years11 findings6 repeat
10
Audit Years
11
Total Findings
6
Repeat Findings

FY 2024-09-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on August 20, 2025. 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 February 20, 2026 (187 days ago).

What is a management decision? →
2024-002
Cost Allowability
REPEAT

During our testing, we noted the organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the organization did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ time and effort charged to the grant.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 noncompliance with regulatory requirements. Repeat Finding: Yes - see finding 2023-002. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561; 10.331 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health; National Institute of Food and Agriculture; State of California, Department of Food and Agriculture Pass-through Number: S003654-COP; DFHS23SNA005; 2021-70034-34987; 2021-70034-35361; 22-1464-004-SF Award Period: October 1, 2023 - September 30, 2024; June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026; January 1, 2023 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 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 in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications. Condition: During our testing, we noted the organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the organization did not have approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees for the Food Insecurity Nutrition Incentive Grants Program. In addition, the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program it was identified there were eight employees tested that did not have time and effort documented for their time spent working on the New Jersey Corner store program. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employees’ time and effort charged to the grant.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 noncompliance with regulatory requirements. Repeat Finding: Yes - see finding 2023-002. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

During our testing, we noted the organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement processes and tools to ensure that all employee time and effort charged to federal grants is appropriately documented. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: The planned corrective action will be completed by October 2025.

Prior Finding References

2023-002

About Allowable Costs / Cost Principles →
2024-003
Cash Management
REPEAT

During our testing, we noted there was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2021-70034-34987; 2021-70034-35361 Award Period: June 15, 2021 - June 14, 2025; August 1, 2021 - July 31, 2026 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted there was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: Yes - see finding 2023-003. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

During our testing, we noted there was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement an electronic approval system, and draws will be completed within 30 days of month end. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: the planned corrective action will be completed by August 2025.

Prior Finding References

2023-003

About Cash Management →
2024-004
Procurement & Suspension/Debarment

During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University; New Jersey Department of Health Pass-through Number: S004968-COP-TFT; DFHS24SNA005 Award Period: October 1, 2023 - September 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria: 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements, section 200.303 requires that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. This includes verifying that vendors are not suspended or debarred before engaging in transactions. Condition: During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Questioned Costs: None Context: The absence of documentation confirming that vendors were screened for suspension or debarment before engaging in transactions represents a gap in internal control over compliance. This control measure is essential to adhere to Federal regulations and reduce the risk of conducting business with parties who are suspended or debarred. Cause: The Organization did not have a formal process in place to document the verification of suspension and debarment status prior to engaging with vendors. Effect: In the absence of documented evidence of vendor verification, there is an elevated risk that the Organization may engage in transactions with suspended or debarred parties. This situation could lead to noncompliance with Federal regulations and result in potential penalties. Repeat Finding: N/A – Not a repeat finding. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

During our testing, we found that the Organization provided documentation showing that the vendors used in the federal program were not listed as suspended or debarred according to the Sam.gov website, in line with their internal control procedures. However, there was no documentation indicating that the verification was performed prior to entering the transactions. Recommendation: The Organization should establish and enforce controls to verify that vendors are not suspended or debarred prior to entering any transactions and maintain this documentation. This measure ensures the integrity of the procurement process and mitigates risks associated with engaging disqualified vendors. In 2024, the threshold amount for suspension and debarment checks was $25,000. Transactions equal to or exceeding this amount required verification to confirm that the entity involved was not debarred or suspended. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement a process to screen vendors to ensure compliance with applicable regulations. Planned completion date for corrective action plan: the planned corrective action will be completed by August 2025. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance If the oversight agency has questions regarding this plan, please call Regine Metellus, Vice President of Finance at 215-575-0444 ext. 163.

About Procurement and Suspension and Debarment →

FY 2023-09-30

FAC accepted this audit on September 13, 2024 — management decision was due March 13, 2025.

2023-002
Cost Allowability
REPEAT

During our testing, we noted the organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the organization did not have an approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employee's time and effort charged to the grant. 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 noncompliance with regulatory requirements. Repeat Finding: Yes - see finding 2022-004. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

2023-002 Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria: 2 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 in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications. Condition: During our testing, we noted the organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the organization did not have an approval by a supervisor on time and effort certification for the actual time spent working on the program for seven employees. Cause: The organization did not have policies and procedures in place during the fiscal year to adequately document and certify employee's time and effort charged to the grant. 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 noncompliance with regulatory requirements. Repeat Finding: Yes - see finding 2022-004. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

The organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement processes and tools to ensure that all employee time and effort charged to federal grants is appropriately documented. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: The planned corrective action will be completed by October 2024.

Prior Finding References

2022-004

About Allowable Costs / Cost Principles →
2023-003
Cash Management
REPEAT

During our testing, we noted there was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: Yes - see finding 2022-005. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

2023-003 Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted there was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted there was no documentation of review or approval on the calculations for the draw of funding for the program. Cause: The organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: Yes - see finding 2022-005. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing an approval and a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

There was no documentation of review or approval on the calculation for the draw of funding for the program. In addition, draws are not performed in a timely manner after the expenditures are incurred. Recommendation: We recommend The Food Trust implement a clear approval process for the drawing of federal funding. In addition, it is important to establish a clear process and timeline for performing draws. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement an electronic approval system, and draws will be completed within 30 days of month end. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: The planned corrective action will be completed with the September 2024 month-end close.

Prior Finding References

2022-005

About Cash Management →
2023-004
Cost Allowability
REPEAT

During our testing, we noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $200 charged to the federal programs. Questioned Costs: None Context: During the testing, it was also noted management was unable to locate the supporting documentation for two transactions totaling $200. 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 does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: Yes - see finding 2022-002. Recommendation: We recommend The Food Trust review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

2023-004 Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Assistance Listing Number: 10.561 Pass-through Agency: The Pennsylvania State University Pass-through Number: S003654-COP-TFT Award Period: October 1, 2022 - September 30, 2023 Compliance Requirement Affected: Allowable Costs Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria: 2 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 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 and reviewed to support all transactions. Condition: During our testing, we noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $200 charged to the federal programs. Questioned Costs: None Context: During the testing, it was also noted management was unable to locate the supporting documentation for two transactions totaling $200. 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 does not retain proper supporting documentation for federal expenditures, it could result in funds being required to returned to the funding agency. Repeat Finding: Yes - see finding 2022-002. Recommendation: We recommend The Food Trust review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

There was a lack of documentation for the purchase of program supplies in the amount of $200 charged to federal programs. Recommendation: We recommend The Food Trust review its processes to ensure that all supporting documentation is maintained for federal purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will complete a review of its documentation by December 2024. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: The planned corrective action will be completed by December 31, 2024. If the oversight agency has questions regarding this plan, please call Regine Metellus, Vice President of Finance at 215-575-0444 ext. 163.

Prior Finding References

2022-002

About Allowable Costs / Cost Principles →

FY 2022-09-30

FAC accepted this audit on January 29, 2024 — management decision was due July 29, 2024.

2022-002
Cost Allowability
QUESTIONED COSTS

During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. 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: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. 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: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Full finding narrative

Federal Agency: U.S. Department of Agriculture Federal Program Name: State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.561 and 10331 Pass-through Agency: The Pennsylvania State University and National Institute of Food and Agriculture Pass-through Number: S001650-COP-TFT; 2019-70030-30412; 2020-70030-33186; 2021-70034-34987; 2021-70034-35361 Award Period: October 1, 2021 - September 30, 2022; September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023; June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance 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 in place to accurately record and report fringe benefits based on the actual expenses incurred by the organization and 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 and reviewed to support all transactions. Condition: During our testing, we noted the Organization charges benefits to the programs based on an allocation calculated at 25% of salaries, but the actual benefits incurred are 20% of total salaries, there is a discrepancy between the allocated amount and the actual amount. We also noted there was a lack of supporting documentation for the purchase of program supplies in the amount of $266 charged to the federal programs. Questioned Costs: The Organization allocated fringe benefits to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program more than the amount actually incurred by $99,699. The organization allocated fringe benefits to the Food Insecurity Nutrition Incentive Grants Program more than the amount actually incurred by $6,558.Context: During the review of the fringe benefits charged to the State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and the Food Insecurity Nutrition Incentive Grants Program, it was noted the amounts allocated for fringe benefits were in excess of the fringe incurred by the organization by $99,699 and $6,558, respectively. it was also noted management was unable to locate the supporting documentation for two transactions totaling $266. Cause: The Organization allocated fringe to the program based on the percentages included in the contract budget, as opposed to charging actual expenditures incurred to the grants. Management's internal controls did not prevent or detect the grants from being overcharged fringe benefits. 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: Allocated costs that are not appropriately budgeted and invoiced could result in inaccurate reporting and misrepresentation of the program's expenses. 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: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the Organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

DEPARTMENT OF AGRICULTURE 2022‐002 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program and Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.561 and 10.331 Recommendation: We recommend The Food Trust review the allocation process for fringe benefits to ensure amounts reflect a more accurate representation of the actual fringe benefits incurred by the organization. In addition, the Food Trust should review its practices to ensure all supporting documentation is retained for federal purchases. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization had no internal finance staff from October 2020 through July 2021. During that time, there was no review of the fringe benefits calculations. The new finance staff discovered this error and corrected the fringe benefits calculations starting in October 2022. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: This matter has been corrected and the updated rates have been in place for the entirety of fiscal year 2023.

About Allowable Costs / Cost Principles →
2022-003
Cost Allowability
QUESTIONED COSTS

The detail of the expenditures incurred for the program included a transaction for bad debt expense which is not an allowable cost per the program budgets. In addition, there was funding drawn down by the agency for this transaction. Questioned Costs: The Organization was reimbursed for $3,943 of unallowable costs. Context: During the review of program expenditure detail for the program, it was noted there was a transaction for bad debt expense that was not included in the budget as an allowable cost. Cause: The Organization had several key finance management positions turnover several times beginning in September 2019 through June 2021. There was an analysis performed by current management for this program which determined there was expenses incurred in prior years however not recognized as revenue until this reconciliation was performed in fiscal year 2022. This specific transaction was expensed in the year ended September 30, 2021. The charging to the federal program was an oversight by management.

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Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331Effect: The reconciliation of the program expenditures was not performed in a timely manner. This resulted in expenditures being charged to the program that were not allowable and funding may need to be returned to the pass-through agency. Repeat Finding: N/A: Not a repeat finding. Recommendation: Management should review its practices to ensure there are adequate review controls in place so only allowable costs are allocated to federal programs. In addition, the funding received for the questioned costs should be remitted back to the funder by the Organization. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan. Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412 Award Period: September 1, 2019 - August 31, 2022 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 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 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 and reviewed to support all transactions. Condition: The detail of the expenditures incurred for the program included a transaction for bad debt expense which is not an allowable cost per the program budgets. In addition, there was funding drawn down by the agency for this transaction. Questioned Costs: The Organization was reimbursed for $3,943 of unallowable costs. Context: During the review of program expenditure detail for the program, it was noted there was a transaction for bad debt expense that was not included in the budget as an allowable cost. Cause: The Organization had several key finance management positions turnover several times beginning in September 2019 through June 2021. There was an analysis performed by current management for this program which determined there was expenses incurred in prior years however not recognized as revenue until this reconciliation was performed in fiscal year 2022. This specific transaction was expensed in the year ended September 30, 2021. The charging to the federal program was an oversight by management.

Corrective Action Plan

DEPARTMENT OF AGRICULTURE 2022‐003 Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.331 Recommendation: Management should review its practices to ensure there are adequate review controls in place so only allowable costs are allocated to federal programs. In addition, the funding received for the questioned costs should be remitted back to the funder by the organization. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization had no internal finance staff from October 2020 through July 2021, and was not fully staffed until March 2023. Having adequate staffing levels within the department allows for the proper review of transactions and helps to prevent errors of this nature. When this error was identified, the Organization contacted the funder to initiate the return of funds. The Organization recently received instructions from the funder and is processing the refund of $4,696. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: The planned corrective action will be completed by December 2023.

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2022-004
Cost Allowability

During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. 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 noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Allowable Costs Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 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 in place to ensure adequate controls designed to ensure personnel costs are documented with time and effort certifications.Condition: During our testing, we noted the Organization does not have adequate controls designed to ensure personnel costs are documented with time and effort certifications. Questioned Costs: None Context: During our testing, it was noted the Organization is not completing time and effort certification for the actual time spent working on the program. Cause: The Organization did not have policies and procedures in place to adequately document and certify employee’s time and effort charged to the grant. 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 noncompliance with regulatory requirements. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

DEPARTMENT OF AGRICULTURE 2022-004 Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.331 Recommendation: We recommend The Food Trust establish and implement controls that require employees to document their time and effort spent on various activities. Time and effort certifications should be regularly reviewed and approved by appropriate personnel to ensure accuracy and completeness of personnel cost documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement processes and tools to ensure that all employee time and effort charged to federal grants is appropriately documented. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan:The planned corrective action will be completed by September 2024.

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2022-005
Cash Management

During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

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Federal Agency: U.S. Department of Agriculture Federal Program Name: Food Insecurity Nutrition Incentive Grants Program Assistance Listing Number: 10.331 Pass-through Agency: National Institute of Food and Agriculture Pass-through Number: 2019-70030-30412; 2020-70030-33186; 2021-70034-34987 2021-70034-35361 Award Period: September 1, 2019 - August 31, 2022; September 1, 2020 - August 31, 2023 June 15, 2021 - June 14, 2024; August 1, 2021 - July 31, 2024 Compliance Requirement Affected: Cash Management Type of Finding:  Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of cash management. The Organization should have procedures in place to ensure the draw down of federal funds in a timely manner and proper documentation of approval should be maintained to support the draw of funds. Condition: During our testing, we noted the same individual is both preparing and requesting the draw of funds for the program without any approval by another individual. In addition, draws are not performed in a timely manner after the expenditures are incurred. Questioned Costs: None Context: During our testing, it was noted the same individual is preparing and requesting the draw of funds for the program with no approval by another individual. Cause: The Organization had significant turnover within the finance department and was operating with insufficient resources to allocate responsibilities. Effect: We noted no instances of noncompliance with the provisions of allowable costs and activities; however, the lack of approval represents a lack of segregation of duties and can increase the risk of fraud or errors going undetected. In addition, when draws are not performed in a timely manner after the expenditures are incurred, it can lead to cash flow issues and potential disruptions in the program's operations. Timely draws are important to ensure that funds are available to cover expenses and maintain the program's financial stability. Repeat Finding: N/A: Not a repeat finding. Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the Organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Viewed of Responsible Officials and Planned Corrective Actions: Please refer to The Food Trust’s Corrective Action Plan.

Corrective Action Plan

DEPARTMENT OF AGRICULTURE 2022-005 Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.331 Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization had no internal finance staff from October 2020 through July 2021, and was not fully staffed until March 2023. Having adequate staffing levels within the department allows for the proper segregation of duties and internal controls. In addition, the department now has the capacity to perform these draws on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: This matter has been corrected since July 2023. If the oversight agency has questions regarding this plan, please call Regine Metellus, Vice President of Finance at 215‐575‐0444 ext. 163.

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FY 2019-09-30

FAC accepted this audit on December 23, 2020 — management decision was due June 23, 2021.

2019-001
Reporting
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2018-001

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