Feeding San Diego

Identification of federal program 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not obtain all signatures for dual signature process for the reception of food boxes and backpacks which would include the delivery driver signature and the receiver/site signature. Effect The occurrence of the delivery and reception of the backpacks is not documented which can lead to possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to reporting compliance requirement. Identification as a Repeat Finding Repeat finding. Recommendation The Organization create a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558 and 21.027 – Child and Adult Care Food Program (CACFP) and Child Care and Development Block Grant (ARPA) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not retain eligibility documentation for each site noting the control process. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect or Potential Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Eligibility. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials: Management agrees with the finding and observation.

Identification of federal programs 21.027 - Child Care and Development Block Grant (ARPA) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization was unable to provide support for backpacks, or food pantry boxes provided for certain sites throughout the year. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs Questioned costs totaled approximately $52,000; comprised of approximately $9,000 of known questioned costs and approximately $43,000 of likely questioned costs. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials: Management agrees with the finding and observation.

Identification of federal programs 10.558 – Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization could not provide support to evidence the number of supper meals or snacks distributed for certain sites throughout the year. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials: Management agrees with the finding and observation.

Identification of federal programs 21.027/10.558 - American Rescue Plan Act (ARPA) and Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not have adequate internal controls surrounding reception of food boxes, backpacks, supper meals, or snacks provided as some selections did not have supervisory review of support. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558 - Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization does not retain documentation of review of supper meals and snacks uploaded for reimbursement. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Cash Management, Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558 and 21.027 – Child and Adult Care Food Program (CACFP) and Child Care and Development Block Grant (ARPA) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not retain eligibility documentation for each site noting the control process. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect or Potential Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Eligibility. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558 – Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization could not provide support to evidence the number of supper meals or snacks distributed for certain sites throughout the year. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 21.027/10.558 - American Rescue Plan Act (ARPA) and Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not have adequate internal controls surrounding reception of food boxes, backpacks, supper meals, or snacks provided as some selections did not have supervisory review of support. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558 - Child and Adult Care Food Program (CACFP) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization does not retain documentation of review of supper meals and snacks uploaded for reimbursement. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Cash Management, Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the controls being implemented are documented. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 21.027- American Rescue Plan Act (ARPA) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not have did not have an adequate understanding of the requirements under the program agreement. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should put in place a formal process to ensure the agreement requirements are understood. Views of Responsible Officials Management agrees with the finding and observation.

Identification of federal programs 10.558/10.559 - Child and Adult Care Food Program (CACFP) and Summer Food Service Program for Children (SFSPC) Criteria or Specific Requirement Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition The Organization did not have adequate personnel with accounting experience as volunteers were allowed to keep track of the grants' tracking/accounting. Cause In the last couple of years due to the Organization receiving significant federal funding, documentation and implementation of processes were still in process. Effect Possibility of errors on the Schedule of Expenditures of Federal Awards. Questioned Costs None noted. Context The condition noted above was identified during the audit procedures related to Activities Allowed and Unallowed/Allowable Cost Principles/Reporting. Identification as a Repeat Finding Not a repeat finding. Recommendation The Organization should have personnel with adequate experience and background in accounting to maintain the records. Views of Responsible Officials Management agrees with the finding and observation.

Finding Number 2021-001 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-through number(s): 04127-SFSP-37 Award period: 2020 and 2021 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Cash Management ? Internal Control and Compliance Over Cash Management Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Pursuant to the August 2020 Compliance Supplement, Cash Management, for grants and cooperative agreements to nonfederal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Condition: During the single audit performed for the year ended June 30, 2020, it was noted the Organization did not have adequate internal control designed to ensure the reimbursement requests claimed to the grant agreed to the supporting document. Corrective actions to address this condition were not implemented during the year ended June 30, 2021. Cause: The Organization was not diligent in review of the supporting document. Effect or Potential Effect: Lack of internal control over this compliance requirement provides an opportunity for material noncompliance. Questioned Costs: Questioned costs were under $25,000. Identification as a Repeat Finding: Prior year finding 2020-001. Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place during the reimbursement process. Views of Responsible Officials: Management agrees with the finding and observation.

Finding Number 2021-002 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-through number(s): 04127-SFSP-37 Award period: 2020 and 2021 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency Procurement, Suspension, and Debarment ? Internal Control and Compliance Over Verification Against the System for Award Management (SAM) Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? included contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/ (click on Search Record, then click on Advanced ?Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During the single audit performed for the year ended June 30, 2020, it was noted the Organization did not have a policy in place to perform the verification check and the Organization did not verify the vendor against the SAM to ensure the vendor was not suspended or debarred from the federally-funded programs. Corrective actions to address this condition were not implemented during the year ended June 30, 2021. Cause: The Organization did not have formal policies in place to ensure the suspension and debarment review process over vendors that provide goods or services to the Organization was conducted prior to entering into contracts. Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contact awarded, the Organization could be contracting with vendors that are prohibited from working on federally funded projects. Questioned Costs: No questioned costs were noted. Identification as a Repeat Finding: Prior year finding 2020-002. Recommendation: We recommend the Organization develop policies and procedures to incorporate the suspension and debarment verification prior to awarding contracts into its existing procurement policies. Views of Responsible Officials: Management agrees with the finding and observation.

Finding Number 2021-003 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-through number(s): 04127-SFSP-37 Award period: 2020 and 2021 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Cash Management ? Internal Control and Compliance Over Cash Management Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Pursuant to the California Department of Education, Nutrition Services Division, Resource Management Unit, an Organization that is operating a Child Nutrition Program, should monitor and calculate (as applicable) its operating capital or cash reserves. The Organization is required to communicate any net cash resources to the California Department of Education. Condition: During our audit, we noted the Organization did not have adequate internal controls designed to accurately monitor its expenses incurred under the SFSP program. The Organization did not have adequate internal controls designed to compare the expenses incurred against the amounts reimbursed. The Organization did not have adequate internal controls designed to calculate the net cash resource balance as of June 30, 2021, which is required to be submitted to the California Department of Education. Cause: The Organization was not diligent in monitoring its net cash resource balances to ensure ongoing compliance with the limitations. Effect or Potential Effect: Lack of internal control over this compliance requirement provides an opportunity for material noncompliance. Questioned Costs: None. Identification as a Repeat Finding: N/A Recommendation: We recommend the Organization design controls to ensure timely and accurate tracking of net cash resource balances. Views of Responsible Officials: Management agrees with the finding and observation.

Finding Number 2021-004 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-through number(s): 04127-SFSP-37 Award period: 2020 and 2021 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Allowable Costs/Cost Principles ? Internal Control and Compliance Over Allowable Costs/Cost Principles Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Per Part 6 of the Compliance Supplement, controls need to be designed such that they would prevent or detect potential noncompliance. Management should implement control activities through policies. Condition: During our audit, we noted the Organization did not have documented policies regarding the specific process and controls in place surrounding the methodology utilized to allocate payroll costs to grants. Cause: Procedures used were not formally documented. Support of procedures performed were not maintained. Effect or Potential Effect: Lack of internal control over this compliance requirement provides an opportunity for material noncompliance. Questioned Costs: No questioned costs were noted. Identification as a Repeat Finding: N/A Recommendation: We recommend the Organization document policies regarding the process and controls in place to allocate payroll costs to grants. Views of Responsible Officials: Management agrees with the finding and observation.

Finding Number 2021-005 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-through number(s): 04127-SFSP-37 Award period: 2020 and 2021 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Reporting ? Internal Control and Compliance Over Reporting Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Per the United States Department of Agriculture Summer Food Service Program Administration Guide, each site must take a point-of-service meal count every day and the site supervisor must sign and date the meal count form. Condition: During our audit, we noted instances in which the meal count forms were not signed by the site supervisors. MHM noted that at some sites, one meal count form was used for two meals. Individual meal count forms should be used for each meal served. Cause: Sites were not properly trained on procedures to track and report meals. Effect or Potential Effect: Lack of internal control over this compliance requirement provides an opportunity for material noncompliance. Questioned Costs: No questioned costs were noted. Identification as a Repeat Finding: N/A Recommendation: We recommend the Organization train and monitor sites to ensure that they maintain program requirements. Views of Responsible Officials: Management agrees with the finding and observation.

2020-001 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-Through Number(s): 04127-SFSP-37 Award Period: 2019 and 2020 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency in Internal Control over Compliance Cash Management ? Internal Control and Compliance Over Cash Management Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Pursuant to the August 2020 Compliance Supplement, Cash Management, for grants and cooperative agreements to nonfederal entities that are paid on a reimbursement basis, supporting documentation shows that the costs for which reimbursement was requested were paid prior to the date of the reimbursement request. Condition: During our audit, we noted the Organization did not have adequate internal control designed to ensure the reimbursement requests claimed to the grant agreed to the supporting document. Cause: The Organization was not diligent in review of the supporting document. Effect or Potential Effect: Lack of internal control over this compliance requirement provides an opportunity for material noncompliance Questioned Costs: Questioned costs were under $25,000. Context: During our testing, we noted that the Organization under claimed the grantor in the amount of $8,029. Identification as a Repeat Finding, if Applicable: Not Applicable Recommendation: We recommend the Organization design controls to ensure an adequate review process is in place during the reimbursement process. Views of responsible officials: Management agrees the finding and observation.

2020-002 Federal agency: Department of Agriculture Federal program title: Summer Food Service Program for Children (SFSPC) CFDA number: 10.559 Pass-through entity: State of California Department of Education Nutrition Services Division Pass-Through Number(s): 04127-SFSP-37 Award Period: 2019 and 2020 Federal Award Number and Award Year: 04127-CACFP-37 Type of Finding: ? Significant Deficiency Procurement, Suspension, and Debarment ? Internal Control and Compliance Over Verification Against the System for Award Management (SAM) Criteria or Specific Requirement (including Statutory, Regulatory, or Other Citation): Nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/ (click on Search Record, then click on Advanced -Exclusions) (Note: The OMB guidance at 2 CFR part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our audit, we noted the Organization did not have a policy in place to perform the verification check and the Organization did not verify the vendor against the SAM to ensure the vendor was not suspended or debarred from federally-funded programs. Cause: The Organization did not have formal policies in place to ensure the suspension and debarment review process over vendors that provides goods or services to the Organization was conducted prior to enter into contracts.Effect or Potential Effect: Without verifying whether vendors are suspended or debarred from working on federally-funded projects prior to the contact awarded, the Organization could be contracting with vendors that are prohibited from working on federally funded projects. Questioned Costs: No questioned costs were noted. Context: See condition above for context of the finding. Identification as a Repeat Finding, if Applicable: Not Applicable Recommendation: We recommend the Organization develop policies and procedures to incorporate the suspension and debarment verification prior to awarding contracts into its existing procurement policies. Views of responsible officials: Management agrees the finding and observation.