Greater Cleveland Food BankNon-Profit

Reference Number: 2022-001 Internal Control over Compliance with Activities Allowed or Unallowable Federal Agency(ies): CFDA Number(s): Cluster (if applicable) and Program Name(s): Food Distribution Cluster: United States Department of Agriculture 10.569 Emergency Food Assistance Program (Food Commodities) United States Department of Agriculture 10.565 Commodity Supplemental Food Program 477 Cluster: United States Department of Health and Human Services 93.558 Temporary Assistance for Needy Families (TANF) Department of Treasury 21.019 COVID-19 - Coronavirus Relief Fund "Criteria or Specific Requirement:" The Code of Federal Regulations related to the Emergency Food Assistance Program 7 CFR part 251.10: Eligible recipient agencies must sign a receipt for program commodities which they receive under this part for distribution to households or for use in preparing meals, and records of all such receipts must be maintained. In addition, the Ohio Department of Job and Family Services Food Program Manual states: A Local Distributor must sign a receipt for program commodities, which they receive for distribution to households or for use in preparing meals. Context and Condition: We tested 40 sub-recipient agency invoices and noted all invoices tested were lacking a signed receipt for program commodities received. We also noted Greater Cleveland Food Bank's processes and procedures do not require recipient agencies to sign a receipt for program commodities. Questioned Costs: None noted Cause and Effect: Due to the impact of the COVID-19 pandemic, safety protocol was in place relating to in person contact relating to recipient agency signatures for receipt of program commodities. When the safety protocol was lifted, Greater Cleveland Food Bank did not resume the process of requiring recipient agencies sign a receipt for program commodities. Recommendation: We recommended the Greater Cleveland Food Bank review with all supervisors and employees handling food distributions to sub-recipient agencies the importance of compliance guidelines surrounding signature requirements acknowledging the sub-recipient agencies' receipt of program commodities.

Reference Number: 2022-002 Internal Control over Compliance with Reporting Federal Agency(ies): CFDA Number(s): Cluster (if applicable) and Program Name(s): 477 Cluster: United States Department of Health and Human Services 93.558 Temporary Assistance for Needy Families (TANF) "Criteria or Specific Requirement:" The subrecipient grant agreement between the Greater Cleveland Food Bank and the Ohio Association of Foodbanks states : the quarterly statistical summary report form of agencies, product pounds by source of food distributed, households served by type, individual served and service statistics by county must be submitted to the Ohio Association of Foodbanks within 45 days after the end of each quarter. Context and Condition: We tested all 4 quarterly statistical summary report forms submitted to the Ohio Association of Foodbanks for the year ended September 30, 2022 and 2 of the quarterly statistical summary report forms were submitted subsequent to 45 day deadline. Questioned Costs: None noted Cause and Effect: Policies and procedures were not appropriately adhered to in certain instances to ensure quarterly reporting was submitted in accordance with grant requirements. Recommendation: We recommended the Greater Cleveland Food Bank review with all supervisors and employees responsible for timely reporting to the Ohio Association of Foodbanks the importance of reporting compliance guidelines.

2021-003 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 United States Department of Agriculture Assistance Listing Number: 10.178 Assistance Listing Name: Trade Mitigation Program Eligible Recipient Agency Operational Funds Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0837 October 1, 2020 ? June 30, 2021 Criteria ? Under Code of Federal Regulation 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Further under the Uniform Guidance, if a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Condition ? During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Greater Cleveland Food Bank?s federal programs. The Greater Cleveland Food Bank used a full-time equivalent basis for the allocation of personnel costs to Federal programs, versus the actual hours worked for hourly employees. Accordingly, time and effort were not properly supported for hourly wage allocations. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $7,350 Context ? We tested a sample of 20 hourly individuals within the TEFAP program and 11 hourly individuals within the Trade Mitigation program. We found 20 exceptions within the TEFAP program and 11 exceptions within the Trade Mitigation program. The salary cost based on a flat number of hours per month rather than actual time resulted in an over reimbursement of $5,834 relating to TEFAP and $936 relating to Trade Mitigation. This is a condition identified per review of Greater Cleveland Food Bank?s compliance with specified requirements using a statistically valid sample. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that Greater Cleveland Food Bank develop a policy and procedure to ensure that all hours submitted for reimbursement are supported with timecards or appropriate allocation to demonstrate the level of effort. We further recommend that management review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 68 of this reporting package.

2021-004 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 United States Department of Agriculture Assistance Listing Number: 10.178 Assistance Listing Name: Trade Mitigation Program Eligible Recipient Agency Operational Funds Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0837 October 1, 2020 ? June 30, 2021 Criteria ? Under Code of Federal Regulation 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition ? During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Greater Cleveland Food Bank?s federal programs. The Greater Cleveland Food Bank did not adequately document hours worked for a number of employees. Accordingly, time and effort were not properly supported. Cause ? Greater Cleveland Food Bank has specific policies and procedures in place which require submission of timecards to support time charged across federal programs. In these cases, employees were not in compliance with such protocols, and therefore, supporting documentation was not maintained correctly to evidence hours worked relating to this program. Effect ? An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement and can be supported with timecards can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $6,567 Context ? The Food Bank did not routinely comply with their documented procedures to ensure all hours submitted for reimbursement are supported with timecards. We sampled 40 items for the TEFAP program and found 7 exceptions resulting in $2,072 of questioned costs. We sampled 20 items for the Trade Mitigation program and found 5 exceptions resulting in $4,495 of questioned costs. In addition, per review of the timecards we noted that no timecards were reviewed and signed off by a supervisor. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that Greater Cleveland Food Bank develop a policy and procedure to ensure that all hours submitted for reimbursement are supported with timecards or appropriate allocation to demonstrate the level of effort and those timecards to be reviewed by a supervisor. We further recommend that management review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 69 of this reporting package.

2021-005 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 Criteria ? Under Code of Federal Regulation 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Further under the Uniform Guidance, if a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Condition ? During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Greater Cleveland Food Bank?s federal programs. The Greater Cleveland Food Bank submitted reimbursement for employees that no longer worked at the Food Bank. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $34,824 Context ? We sampled 40 items for the TEFAP program and found 2 exceptions resulting in $3,896 of questioned costs. Upon further review of the total population of employee payroll charges that were charged to the program, we noted these same two employees were submitted for reimbursement after the date of their respective terminations from the Food Bank. One employee left the Food Bank in February of 2021, and his/her payroll was submitted for reimbursement for the remainder of the fiscal year, representing $13,077 of costs inappropriately charged. The second employee left the Food Bank in July 2021, and his/her payroll was submitted for reimbursement for the remainder of the fiscal year, representing $17,851 of costs inappropriately charged. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that Greater Cleveland Food Bank develop a policy and procedure to ensure that all hours submitted for reimbursement are supported with timecards or appropriate allocation to demonstrate the level of effort. We further recommend that management review its policies and procedures on a regular and ongoing basis related to the allocation methodology to ensure that its appropriate given changes in the program and workforce. Finally, we recommend that the personnel charged with submissions of reports to the government understand the nature and context of the information provide for submission, and test that data against independent sources (for example, test the employee labor allocation against the active employee roster that can be provided by Human Resources). Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 69 of this reporting package.

2021-006 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 Criteria ? Under Code of Federal Regulation 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Further under the Uniform Guidance, if a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, then the costs may be allocated or transferred to benefitted projects on any reasonable documented basis. Condition ? During our testing of allowable costs, we noted exceptions in the ability of management to support payroll incurred for the Greater Cleveland Food Bank?s federal programs. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that supporting documentation was maintained to evidence that costs were allowable and that an appropriate level of review and approval was completed prior to charging costs to a federal program. Effect ? An ineffective control system related to the charging of cost to federal programs in order to ensure that only hours worked relating to the programs is charged and requested for reimbursement can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? None Context ? We sampled 40 items for the TEFAP program and found 3 exceptions resulting in under reimbursement of $213. This is a condition identified per review of Greater Cleveland Food Bank?s compliance with specified requirements using a statistically valid sample. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Greater Cleveland Food Bank ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 69 of this reporting package.

2021-007 - Activities Allowed or Unallowed; Allowable Costs/Cost Principles Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 Criteria ? Under Code of Federal Regulation 200.403(g) states that for costs to be allowed under Federal awards, they must be adequately documented and there must be sufficient documentation. Condition ? During our testing of disbursements, we noted 3 of the 40 expenditures sampled included amounts that were past due from the prior months and therefore expenses were overallocated for the months tested. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that only disbursements incurred are requested for reimbursement to a federal program. Effect ? An ineffective control system related to the charging of cost to federal programs in order to ensure that allocated amounts are not greater than expenses incurred are charged and requested for reimbursement. Over allocation of expenses can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? $54,528 Context ? We originally tested a sample of 40 and found 3 exceptions resulting in $11,894 of questioned costs. Upon further review of the total population of expenditures that were charged to the program, we noted other expenses that were allocated to multiple programs, the sum of which greater than 100%, and other instances where the total amount of invoices included past due amounts and not solely charges for one month, resulting in an additional overallocation of expenses of $42,634. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Greater Cleveland Food Bank ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 70 of this reporting package.

2021-008 ? Cash Management Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 United States Department of Agriculture Assistance Listing Number: 10.178 Assistance Listing Name: Trade Mitigation Program Eligible Recipient Agency Operational Funds Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0837 October 1, 2020 ? June 30, 2021 Criteria ? ? 200.305 Federal payment. section (b) states that, " For Non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Specifically, under the Cooperative Agreement between the Greater Cleveland Food Bank and their subrecipient, the Food Bank is to remit payments made to subrecipient within 10 working days of receiving their TEFAP and Trade Mitigation reimbursements from the Ohio Department of Job and Family Services (ODJFS). Condition ? During our testing of payments made to subrecipients, we tested 6 transactions for the remittance of funds to subrecipient, noting 1 had not been remitted within 10 working days of receiving the Trade Mitigation reimbursements from ODJFS. Cause ? Greater Cleveland Food Bank is not in compliance with the provisions of CFR 200.305, in that, the Organization did not adhere to requirements to minimize the time elapsing between the transfer of funds and disbursement by the recipient. Effect ? Payments were made to subrecipient beyond the 10-working day window outlined in the Cooperative Agreement, and thus, payment periods were not minimized. Questioned Costs ? None Context ? We tested a sample of 4 months for TEFAP and 2 quarters for Trade Mitigation remittance to subrecipient to ensure that the 10-working day cutoff was being followed. One sample from Trade Mitigation was not remitted within the 10-working day window, totaling $7,377. Upon further review of the population provided by management, we noted there were an additional 4 exceptions relating to the TEFAP program. There were 4 months from TEFAP not remitted within the 10-working day window, totaling $62,073. Repeat Findings ? This is a repeat finding from prior year. This finding was reported as finding 2020-003 in the 2020 reporting package. Recommendation ? We recommend that the Greater Cleveland Food Bank develop policies and procedures to ensure that payments to subrecipients occurs within 10 working days of the Food Bank receiving their TEFAP and Trade Mitigation reimbursement from ODJFS. Views of Officials and Planned Corrective Actions ? The Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 70 of this reporting package.

2021-009 - Eligibility Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.558 Assistance Listing Name: 477 Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Association of Foodbanks G-2021-17-0120 July 1, 2019 - June 30, 2021 Ohio Association of Foodbanks G-2223-17-0382 July 1, 2021- June 30, 2023 Criteria ? Under the Ohio Agricultural Clearance Program agreement local distributors are defined as food pantries, soup kitchens, and homeless shelters and Supplemental Food Providers as defined as feeding programs, I.e. childcare, youth development, Meals on Wheels, after school programs, residential treatment/care facilities. Only eligible local distributors are to receive food commodities under the Ohio Agricultural Clearance Program. Condition ? During our testing, we noted an exception that an ineligible local distributor received food commodities. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that only eligible local distributors receive food commodities. Effect ? An ineffective control system related to ensuring only eligible local distributors were provided food commodities can lead to noncompliance with laws and regulations and loss of funding for the related program. Questioned Costs ? $5,957 Context ? The Food Bank did not routinely comply with their documented procedures to ensure only eligible local distributors receive food commodities under this program. We sampled 20 items for the Ohio Agricultural Clearance program and found 1 exception resulting in $5,957 of questioned costs. This is a condition identified per review of Greater Cleveland Food Bank?s compliance with specified requirements using a statistically valid sample. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Greater Cleveland Food Bank ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 70 of this reporting package.

2021-010 Internal Controls over Compliance with Procurement Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 United States Department of Agriculture Assistance Listing Number: 10.178 Assistance Listing Name: Trade Mitigation Program Eligible Recipient Agency Operational Funds Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0837 October 1, 2020 ? June 30, 2021 Criteria: In accordance with ?200.318(a), General Procurement Standards, the non-federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to applicable federal law and the standards identified in General Procurement Standards. In addition, ?200.318-326 of the Code of the CFR states that all procurement transactions must be conducted in a manner providing full and open competition. A non-Federal entity must have written policies and procedures on procurement, which should define required approvals for purchases and thresholds for each procurement method defined under ?200.320. Moreover, ?200.318(i) of the CFR states that a non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. ?200.333 of the CFR states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: Food Bank was not able to provide vendor selection documentation of the competitive bidding process associated with eight procurement transactions for the awards related to the Food Distribution Cluster assistance listing numbers 10.565,10.568, and 10.569 and four transactions associated with award G-2021-17-0837 related to the Trade Mitigation Program Eligible Recipient Agency Operational Funds assistance listing number 10.178. Due to lack of documentation of competitive bidding, there may be associated likely questioned costs related to this item; however, the amount of likely questioned costs could not be determined. Cause: Food Bank personnel did not adhere to Food Bank?s documented policies and procedures for ensuring complete documentation of the history of the procurement by having the requisitioner complete a Vendor Selection Form for purchases which cost between $3,500 and $10,000. Effect: Failure to maintain proper documentation for vendor selection process and failure to obtain vendor solicitation for procurements above small purchase acquisition threshold is noncompliance with Federal regulations and the Food Bank?s policy. Questioned Costs: While no known questioned costs were identified, likely questioned costs of $91,064 were noted within the finding above. Context: This is a condition based on testing of Food Bank?s compliance with specified requirements. The prevalence of these findings is detailed in the condition section above. The samples were selected using a non-statistical method. The total population for procurement testing was $505,883 and the 10 procurement transactions reviewed accounted for $91,064 of that population. The exceptions noted are related to 10 of the 124 procurement transactions and totaled $91,064 of the transactions tested. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management and those charged with governance continue to review and improve its internal controls over procurement to ensure compliance with the Food Bank?s procurement policy and Federal regulations. Views of Responsible Officials: Food Bank?s management agrees with the findings and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance and lapses in prescribed internal controls.

2021-011? Reporting Information on the Federal Program: United States Department of Agriculture Assistance Listing Number: 10.568/10.565/10.569 Assistance Listing Name: Food Distribution Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0814 November 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0153 July 1, 2021 ? September 30, 2021 Ohio Department of Job and Family Services G-2021-17-0805 October 1, 2020 ? June 30, 2021 Ohio Department of Job and Family Services G-2223-17-0168 July 1, 2021 ? September 30, 2021 United States Department of Agriculture Assistance Listing Number: 10.178 Assistance Listing Name: Trade Mitigation Program Eligible Recipient Agency Operational Funds Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Department of Job and Family Services G-2021-17-0837 October 1, 2020 ? June 30, 2021 United States Department of Health and Human Services Assistance Listing Number: 93.558 Assistance Listing Name: 477 Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Association of Foodbanks G-2021-17-0120 July 1, 2019 - June 30, 2021 Ohio Association of Foodbanks G-2223-17-0382 July 1, 2021- June 30, 2023 Criteria ? Pursuant to 7 CFR 247, 7 CFR 250, 7 CFR 251, FNS instruction 709-5 and the Ohio Department of Jobs and Family Services (ODJFS) Food Programs Manual and the Ohio Association of Food Bank Subrecipient Regional Agent agreement requires that: (a) Completion of local agency FNS Form ? 153 monthly reports that detail the food receipt, food distribution and recipient participation are due to ODJFS no later than the second Friday of the month that follows the month to which the report pertains. (b) Monthly reports that detail client participation at sites is due to ODJFS no later than 30 days from the end of the month to which the report pertains. (c) Provide an annual report FNS -191 ?Racial/Ethnic Group Participations? to ODJFS within reporting timelines as established by USDA/FNS and ODJFS (d) Monthly Statistical Report by Regional Agent within 30 days after the end of the prior month (e) Quarterly Statistical Summary Report form of agencies, pounds distributed and service statistics by county, within 45 days after the end of each quarter (f) Monthly Value of Food Distributed Report Form (g) Quarterly Value of Food Distributed Report Form Condition ? During our testing, we noted that these reports are not reviewed by a supervisor prior to submitting to ODJFS and Ohio Association of Food Banks. Uniform Guidance requires that recipients of federal awards have adequate procedures and controls in place to ensure information is accurate and complete prior to submitting to the Federal agency. Cause ? Policies and procedures were not appropriately adhered to in certain instances to ensure that monthly reporting is reviewed prior to submitting. Effect ? An ineffective control system related to the submission of monthly reporting can lead to noncompliance with law and regulations and possible loss of funding for the related program. Questioned Costs ? Not applicable Context ? See the condition section with regard to the items tested from the population. This is a condition identified per review of Greater Cleveland Food Bank?s compliance with specified requirements using a statistically valid sample. Repeat Finding ? This is not a repeat finding. Recommendation - We recommend that the Greater Cleveland Food Bank ensure its policies and procedures are followed on a consistent basis. Views of Responsible Officials and Planned Corrective Actions ? Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 71 of this reporting package.

2021-012 - Internal Control over Compliance and Compliance with Reporting (Preparation of the Schedule of Expenditures of Federal Awards) Information on the Federal Program: United States Department of Health and Human Services Assistance Listing Number: 93.558 Assistance Listing Name: 477 Cluster Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Association of Foodbanks G-2021-17-0120 July 1, 2019 - June 30, 2021 Ohio Association of Foodbanks G-2223-17-0382 July 1, 2021- June 30, 2023 United States Department of Health and Human Services Assistance Listing Number: 93.667 Assistance Listing Name: Social Services Block Grant Pass-through Awards under the Uniform Guidance Requirements: Pass-through Entity Award Number Award Period Ohio Association of Foodbanks G-2021-17-0120 July 1, 2019 - June 30, 2021 Ohio Association of Foodbanks G-2223-17-0382 July 1, 2021- June 30, 2023 Criteria: The Code of Federal Regulation (CFR) Section ?200.510(b) states in part: ?The auditee must also prepare a schedule of expenditures of Federal awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended as determined in accordance with CFR Section ?200.502 Basis for determining Federal awards expended.? The schedule must provide total Federal awards expended for each individual Federal program. In accordance with ?200.302 Financial Management, a non-federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in ?200.328 Financial Reporting and ?200.329 Monitoring and Reporting Program Performance. (3) Records that identify adequately the source and application of funds for federally funded activities. (4) Effective control over, and accountability for, all funds, property, and other assets. Condition: During the year ended September 30, 2021, the Food Bank experienced turnover in certain accounting and finance positions with the responsibility for reviewing the accuracy of the schedule of expenditures of federal awards (SEFA). As a result of these changes in staffing, the Food Bank management was unable to fully execute on its documented internal control policies regarding SEFA preparation. The SEFA review and approval process did not detect and correct the following errors that were identified during the audit procedures performed: During our major program grant population completeness procedures, we identified a federal award that was not included on the SEFA prepared by management. The SEFA, as presented in these financial statements has been adjusted to include award G-2021-17-0120 and G ? 2223-17-0382 in Assistance Listing Numbers 93.558 and 93.667. Cause: The internal controls established for the review and approval of the SEFA to ensure its completeness and accuracy did not operate as designed due to personnel changes in the accounting and finance department responsible for the SEFA. Effect: The SEFA provided for the audit was inaccurate for the reasons outlined in the condition section above. Failure to accurately report expenditures and programs on the SEFA result in audit adjustments. Questioned Costs: There are no questioned costs related to the items described above. Context: The conditions outlined above are based on our testing of the Food Bank?s major programs and our overall testing of the accuracy of the SEFA. The nature of this finding is detailed in the condition section above. Repeat Finding: This is not a repeat finding. Recommendation: We recommend management address the staffing considerations to ensure the documented policies and procedures can be performed as prescribed. This will ensure that Federal funds are reported accurately on the SEFA and that programs are reported under the correct CFDA number. Views of Responsible Officials: Food Bank?s management agrees with the finding and recommendations set forth within and has developed a corrective action plan to address the instances of noncompliance identified and lapses in prescribed internal controls.

SECTION III ? Federal Award Findings and Questioned Costs 2020-003 ? Cash Management Information on Federal Program ? 10.568, The Emergency Food Assistance Program (TEFAP) (Administrative Costs) and 10.178 Agricultural Marketing Service- Trade Mitigation Program Criteria ? ? 200.305 Federal payment. section (b) states that, " For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Specifically, under the Cooperative Agreement between the Greater Cleveland Food Bank and their two subrecipients, the Food Bank is to remit payments made to subrecipients within 10 working days of receiving their TEFAP and Trade Mitigation reimbursements from the Ohio Department of Job and Family Services (ODJFS). Condition ? During our testing of payments made to subrecipients, we tested 4 transactions for the remittance of funds to subrecipients, noting 4 had not been remitted within 10 working days of receiving the TEFAP and Trade Mitigation reimbursements from ODJFS. Cause ? Greater Cleveland Food Bank is not in compliance with the provisions of CFR 200.305, in that, policies and procedures were not maintained by the Organization, were not adhered to in order to minimize the time elapsing between the transfer of funds and disbursement by the recipient. Effect ? Payments were made to subrecipients beyond the 10 working day window outlined in the Cooperative Agreement, and thus, payment periods were not minimized. Questioned Costs ? $27,076; likely $44,777 Context ? We tested a sample of 2 months for TEFAP and 2 quarters for Trade Mitigation remittance to subrecipients to ensure that the 10 working day cutoff was being followed. In all samples selected funds were not remitted, totaling $27,076, within the 10 working day window. Repeat Findings ? This is not a repeat finding. Recommendation ? We recommend that the Greater Cleveland Food Bank develop a procedure to ensure that payments to subrecipients occurs within 10 working days of the Food Bank receiving their TEFAP and Trade Mitigation reimbursement from ODJFS. Views of Officials and Planned Corrective Actions ? The Greater Cleveland Food Bank concurs with the finding and the recommendation. The Food Bank?s corrective action plan is described in Managements Corrective Action Plan included at page 49 of this reporting package.

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