EIN: 300396918
UEI: RHLUKEGHXGL5
Audit also covers EIN: 843906805 · unlinked EINs have no separate FAC filing
Audited by: Houldsworth, Russo & Company, P.C.
Oversight agency: 10 [Department of Agriculture]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 27, 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 August 27, 2026 (8 days ago).
What is a management decision? →FAC accepted this audit on November 22, 2024 — management decision was due May 22, 2025.
FAC accepted this audit on November 27, 2023 — management decision was due May 27, 2024.
Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete. Anticipated completion is November 6, 2023.
Show full finding ▾Hide full finding ▴Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete. Anticipated completion is November 6, 2023.
2023-001 Internal Control Systems Over Special Tests and Provisions (Accountability for USDA Foods) – U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.303(a), the auditee must maintain a system of internal controls to provide reasonable assurance that accurate and complete records are maintained with respect to the receipt, distribution, and inventory of USDA foods. Condition: Three Square’s internal controls, as designed, require an individual to verify that the weight of each product recorded in the inventory system is accurate. During inventory observation and testing audit procedures, twelve items were sampled. Of the twelve items, a discrepancy was discovered in the weight of one product when compared to the weight of the product recorded in the inventory system. Context: Of the twelve products selected for testing, the weight of one product was improperly recorded within Three Square’s inventory system. Cause: Internal controls over accountability for USDA foods were not operating effectively. Effect: Improper implementation of internal controls could result in improper tracking and reporting of costs of USDA foods. Recommendation: We recommend that management ensure that the system of internal controls over accountability for USDA foods is followed as designed. Views of Responsible Officials and Planned Corrective Actions: The weight of inventory is recorded within Three Square’s inventory management system as part of the receiving process. To ensure that all weight is properly recorded, Three Square will implement a verification process. Inventory control specialists, who are not part of the receiving process, will verify 10% of all items received weekly. This verification process will include independent weighing of items, and a review of the item description, quantity and dimensions recorded in the inventory management system. Any discrepancies will be reported to team leads to be rectified. Three Square is committed to ensuring that the system of internal controls is sufficient to ensure all records are accurate and complete.
FAC accepted this audit on November 28, 2022 — management decision was due May 28, 2023.
The Emergency Food Assistance Program (TEFAP) Agency Partner Services Agreement includes specific terms and conditions that an Agency Partner must agree to in order to be eligible to receive federal commodities. In accordance with 7 CFR 251.2, Three Square must obtain written agreements with Agency Partners before federal commodities are distributed. Of the 12 TEFAP Agency Partners selected for testing, management was unable to provide signed TEFAP Agency Partner Services Agreements for 4 entities. Context: Four Agency Partners received TEFAP commodities for which no evidence of eligibility was able to be produced by management. Effect: Improper determination and/or evidence of eligibility could result in Agency Partners who have not agreed to TEFAP-specific terms and conditions receiving distributions of federal commodities. Cause: The design and implementation of internal controls over eligibility was not effective. Recommendation: We recommend management design and implement a system whereby a fully executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution being made to an Agency Partner.
Show full finding ▾Hide full finding ▴Internal Controls Systems and Compliance Over Eligibility- U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR200.62(a)(3), the auditee must maintain a system of internal control to provide reasonable assurance that federal commodities are distributed to eligible recipients in accordance with the terms and conditions outlined in the federal award. Condition: The Emergency Food Assistance Program (TEFAP) Agency Partner Services Agreement includes specific terms and conditions that an Agency Partner must agree to in order to be eligible to receive federal commodities. In accordance with 7 CFR 251.2, Three Square must obtain written agreements with Agency Partners before federal commodities are distributed. Of the 12 TEFAP Agency Partners selected for testing, management was unable to provide signed TEFAP Agency Partner Services Agreements for 4 entities. Context: Four Agency Partners received TEFAP commodities for which no evidence of eligibility was able to be produced by management. Effect: Improper determination and/or evidence of eligibility could result in Agency Partners who have not agreed to TEFAP-specific terms and conditions receiving distributions of federal commodities. Cause: The design and implementation of internal controls over eligibility was not effective. Recommendation: We recommend management design and implement a system whereby a fully executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution being made to an Agency Partner.
Views of Responsible Officials and Planned Corrective Actions: During the pandemic, the TEFAP program was expanded using COVID-19 relief funds. Three Square had a misunderstanding in the classification of these supplemental commodities, and believed them to be part of COVlD-19 relief and as such did not necessitate an executed TEFAP Agency Partner Services Agreement. The four entities mentioned in the finding who received TEFAP commodities only received these supplemental COVlD-19 commodities. This finding was not pervasive throughout the organization, but rather isolated to a temporary program, which has now ended. To ensure effective internal controls, Three Square has designed a system to ensure an executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution to an Agency Partner. Moving forward, our agency services team will review all orders containing any federal commodity, regardless of the federal program. They will verify eligibility before approval is given to the warehouse to deliver the products.
During the year, Three Square distributed TEFAP commodities to 4 Agency Partners for which TEFAP Agency Partner Services Agreements were unable to be produced. Further, management was unable to produce evidence of compliance with warehousing accountability requirements for those Agency Partners improperly distributed to. Context: The TEFAP Agency Partner Services Agreement communicates to the Agency Partner specific requirements related to accountability for TEFAP commodities. Without a signed Agreement, the Agency Partner may be unaware of the federal compliance requirements related to these commodities which could result in noncompliant handling of USDA food product. Effect: Improper distribution of federal commodities could result in material noncompliance with the terms and conditions of the federal award. Cause: The design and implementation of internal controls over special tests and provisions (accountability for USDA foods) was not effective. Recommendation: We recommend management design and implement a system whereby a fully executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution being made to an Agency Partner.
Show full finding ▾Hide full finding ▴Internal Controls Systems and Compliance Over Special Tests and Provisions (Accountability for USDA Foods) - U.S. Department of Agriculture Food Distribution Cluster, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.62(c), the auditee must maintain a system of internal control to provide reasonable assurance that federal commodities are safeguarded against unauthorized disposition. Condition: During the year, Three Square distributed TEFAP commodities to 4 Agency Partners for which TEFAP Agency Partner Services Agreements were unable to be produced. Further, management was unable to produce evidence of compliance with warehousing accountability requirements for those Agency Partners improperly distributed to. Context: The TEFAP Agency Partner Services Agreement communicates to the Agency Partner specific requirements related to accountability for TEFAP commodities. Without a signed Agreement, the Agency Partner may be unaware of the federal compliance requirements related to these commodities which could result in noncompliant handling of USDA food product. Effect: Improper distribution of federal commodities could result in material noncompliance with the terms and conditions of the federal award. Cause: The design and implementation of internal controls over special tests and provisions (accountability for USDA foods) was not effective. Recommendation: We recommend management design and implement a system whereby a fully executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution being made to an Agency Partner.
Views of Responsible Officials and Planned Corrective Actions: During the pandemic, the TEFAP program was expanded using COVID-19 relief funds. Three Square had a misunderstanding in the classification of these supplemental commodities, and believed them to be part of COVID-19 relief and as such did not necessitate an executed TEFAP Agency Partner Services Agreement. The four entities mentioned in the finding who received TEFAP commodities only received these supplemental COVID-19 commodities. This finding was not pervasive throughout the organization, but rather isolated to a temporary program, which has now ended. To ensure effective internal controls, Three Square has designed a system to ensure an executed TEFAP Agency Partner Services Agreement is obtained prior to any TEFAP distribution to an Agency Partner. Moving forward, our agency services team will review all orders containing any federal commodity, regardless of the federal program. They will verify eligibility before approval is given to the warehouse to deliver the products.
FAC accepted this audit on November 15, 2021 — management decision was due May 15, 2022.
FAC accepted this audit on May 6, 2021 — management decision was due November 6, 2021.
Management was unable to provide evidence of review and approval by an authorized individual for certain federal expenditures. Context: Of the twenty-seven items selected for testing, two selections included fuel costs from a vendor purchased with federal funds. Management was unable to provide evidence of the review and approval by an authorized individual for these purchases. Cause: The implementation of internal controls over allowable costs was not effective. Effect: Improper implementation of internal controls could result in expenditures of federal awards on unallowable costs. Recommendation: We recommend that management implement a system of internal controls that includes maintaining evidence of review and approval of all federal expenditures by an individual familiar with the costs allowable in accordance with the terms and conditions outlined in the federal award. Views of Responsible Officials and Planned Corrective Actions: The fuel costs selected were reviewed, however, the Logistics Manager reviewing the charges failed to sign the invoice to indicate evidence of review. This oversight was due to employee turnover and training. The newly hired Logistics Manager has now been properly trained on evidence of review, and our new manager training now includes a discussion of evidence of review. We believe all charges to have been reviewed, just without the evidence to indicate such review had occurred. While we understand the necessity for this control finding, this is not indicative of our internal control environment as this finding was limited to one type of expense and one reviewer.
Show full finding ▾Hide full finding ▴Internal Control Systems Over Allowable Costs ? U.S. Department of Agriculture, Trade Mitigation Program Eligible Recipient Agency Operational Funds, CFDA #10.178, Passed Through the State of Nevada Department of Agriculture Criteria: In accordance with 2 CFR 200.62, the auditee must maintain a system of internal controls to provide reasonable assurance that federal funds expended by the auditee are allowable in accordance with the terms and conditions outlined in the federal award. Condition: Management was unable to provide evidence of review and approval by an authorized individual for certain federal expenditures. Context: Of the twenty-seven items selected for testing, two selections included fuel costs from a vendor purchased with federal funds. Management was unable to provide evidence of the review and approval by an authorized individual for these purchases. Cause: The implementation of internal controls over allowable costs was not effective. Effect: Improper implementation of internal controls could result in expenditures of federal awards on unallowable costs. Recommendation: We recommend that management implement a system of internal controls that includes maintaining evidence of review and approval of all federal expenditures by an individual familiar with the costs allowable in accordance with the terms and conditions outlined in the federal award. Views of Responsible Officials and Planned Corrective Actions: The fuel costs selected were reviewed, however, the Logistics Manager reviewing the charges failed to sign the invoice to indicate evidence of review. This oversight was due to employee turnover and training. The newly hired Logistics Manager has now been properly trained on evidence of review, and our new manager training now includes a discussion of evidence of review. We believe all charges to have been reviewed, just without the evidence to indicate such review had occurred. While we understand the necessity for this control finding, this is not indicative of our internal control environment as this finding was limited to one type of expense and one reviewer.
April 30, 2021 To Whom it May Concern: Re: Response to Findings and Questioned Costs - Major Federal Award Programs Audit #2020-01 Contact: Tifani Walker, CFO Email: twalker@threesquare.org Corrective plan has been implemented Views of Responsible Officials and Planned Corrective Actions: The fuel costs selected were reviewed, however, the Logistics Manager reviewing the charges failed to sign the invoice to indicate evidence of review. This oversight was due to employee turnover and training. The newly hired Logistics Manager has now been properly trained on evidence of review, and our new manager training now includes a discussion of evidence of review. We believe all charges to have been reviewed, just without the evidence to indicate such review had occurred. While we understand the necessity for this control finding, this is not indicative of our internal control environment as this finding was limited to one type of expense and one reviewer.
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
FAC accepted this audit on November 7, 2018 — management decision was due May 7, 2019.
FAC accepted this audit on November 28, 2017 — management decision was due May 28, 2018.
GSA_MIGRATION
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FAC accepted this audit on November 28, 2016 — management decision was due May 28, 2017.
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