TOLEDO NORTHWESTERN OHIO FOOD BANK, INC.

2023-003 Written Financial Policies Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027; U.S. Department of Treasury Finding Type: Material Weakness and Material Noncompliance Condition: There were no formal, documented federal policies and procedures in place for December 31, 2023, as required by the Uniform Guidance. Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and conflict of interest policy) (§200.318); and 3) Allowability of costs charged to federal programs (§200.302 (7)). Cause: Documented federal policies and procedures were not created and implemented by the Organization. Effect: As the result of this condition, Toledo Northwestern Ohio Food Bank, Inc. did not fully comply with the Uniform Guidance applicable to the major federal program. Recommendation: We recommend that the Organization prepare the required written policies and procedures as soon as practical. Organization’s Response: The Organization concurs with the facts of this finding and is in the process of implementing documented federal policies and procedures.

Toledo Northwestern Ohio Food Bank, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2023 Organization Contact Person: James Caldwell, President/CEO The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Financial Statement Findings 2023-001 - Material Journal Entries Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2024 2023-002 - Timeliness of Bank Reconciliations Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2024 Federal Award Findings 2023-003 - Written Policies and Procedures Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Completion Date: May 14, 2025 2023-004 - Timeliness of Reporting Audited Financial Statements and Federal Awards Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2026

2022-003

2023-004 Timeliness of Reporting Audited Financial Statements and Federal Awards Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Coronavirus State and Local Fiscal Recovery Funds; ALN 21.027; U.S. Department of Treasury Finding Type: Material Weakness and Material Noncompliance Condition: The Organization’s data collection form and the reporting package for the year ended December 31, 2023, was not submitted to the Federal Audit Clearinghouse (FAC) within a timely manner. Criteria: Under the audit requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance), auditees are required to submit the data collection form and the reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Cause: The Organization did not have established controls in place to ensure timely submission to the Federal Audit Clearinghouse due to significant turnover in the finance department. Effect: The Organization did not meet the criteria for a low-risk auditee in the current year. Recommendation: The Organization should implement procedures and controls to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. Organization’s Response: The Organization concurs with the facts of this finding and is implementing procedures to prevent this in the future.

Toledo Northwestern Ohio Food Bank, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. Auditor: Maner Costerisan 2425 E. Grand River Avenue, Suite 1 Lansing, MI 48912 Audit Period: Year ended December 31, 2023 Organization Contact Person: James Caldwell, President/CEO The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Financial Statement Findings 2023-001 - Material Journal Entries Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2024 2023-002 - Timeliness of Bank Reconciliations Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2024 Federal Award Findings 2023-003 - Written Policies and Procedures Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Completion Date: May 14, 2025 2023-004 - Timeliness of Reporting Audited Financial Statements and Federal Awards Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2026

2022-004

Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Finding Type: Material Weakness and Material Noncompliance Condition: There were no formal, documented federal policies and procedures in place for December 31, 2022, as required by the Uniform Guidance. Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and conflict of interest policy) (§200.318); and 3) Allowability of costs charged to federal programs (§200.302 (7)). Cause: Documented federal policies and procedures were not created and implemented by the Organization. Effect: As the result of this condition, Toledo Northwestern Ohio Food Bank, Inc. did not fully comply with the Uniform Guidance applicable to the major federal program. Recommendation: We recommend that the Organization prepare the required written policies and procedures as soon as practical. Organization’s Response: The Organization concurs with the facts of this finding and is in the process of implementing documented federal policies and procedures.

Responsible Party: Director of Opertions and third-party accountant Action to be Taken: Management agrees with the finding, and we are in the process of implementing documented policies and procedures for future federal awards. Anticipated Completion Date: June 30, 2024

2021-003

Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Finding Type: Material Weakness and Material Noncompliance Condition: The Organization’s data collection form and the reporting package for the year ended December 31, 2022, was not submitted to the Federal Audit Clearinghouse (FAC) within a timely manner. Criteria: Under the audit requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance), auditees are required to submit the data collection form and the reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Cause: The Organization did not have established controls in place to ensure timely submission to the Federal Audit Clearinghouse due to significant turnover in the finance department. Effect: The Organization did not meet the criteria for a low-risk auditee in the current year. Recommendation: The Organization should implement procedures and controls to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. Organization’s Response: The Organization concurs with the facts of this finding and is implementing procedures to prevent this in the future.

Responsible Party: Director of Opertions and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy. Anticipated Completion Date: June 30, 2024

2021-004

Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Finding Type: Material Weakness and Material Noncompliance Condition: There were no formal, documented federal policies and procedures in place for December 31, 2021, as required by the Uniform Guidance. Criteria: The Uniform Guidance requires a non-federal entity that has expended federal awards for a grant awarded on or after December 26, 2014 to have written policies pertaining to various areas, including: 1) Payments (draws of federal funds and how to minimize the time elapsing between the receipt of federal funds and the disbursement to contractors/employees/subrecipients) (§200.302 (6)); 2) Procurement (including bidding and conflict of interest policy) (§200.318); and 3) Allowability of costs charged to federal programs (§200.302 (7)). Cause: Documented federal policies and procedures were not created and implemented by the Organization. Effect: As the result of this condition, Toledo Northwestern Ohio Food Bank, Inc. did not fully comply with the Uniform Guidance applicable to the major federal program. Recommendation: We recommend that the Organization prepare the required written policies and procedures as soon as practical. Organization’s Response: The Organization concurs with the

Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we are in the process of implementing documented policies and prodcedures for future federal awards.

Temporary Assistance for Needy Families; ALN 93.558; U.S. Department of Health and Human Services Finding Type: Material Weakness and Material Noncompliance Condition: The Organization’s data collection form and the reporting package for the year ended December 31, 2021, was not submitted to the Federal Audit Clearinghouse (FAC) within a timely manner. Criteria: Under the audit requirements of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirement for Federal Awards (Uniform Guidance), auditees are required to submit the data collection form and the reporting package to the FAC within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the end of the audit period. Cause: The Organization did not have established controls in place to ensure timely submission to the Federal Audit Clearinghouse due to significant turnover in the finance department. Effect: The Organization did not meet the criteria for a low-risk auditee in the current year. Recommendation: The Organization should implement procedures and controls to effectively monitor the status of the submission of the data collection form and the reporting package to ensure that the required information is submitted in a timely manner. Organization’s Response: The Organization concurs with the facts of this finding and is implementing procedures to prevent this in the future.

Responsible Party: Director of Operations and third-party accountant Action to be Taken: Management agrees with the finding, and we have implemented such a policy Anticipated Completion Date: June 30, 2024

Finding 2019-001 Internal Control Process ? Adjustments to reconciled accounts Condition: During the performance of our audit procedures, we noted management had not adjusted all significant accounts balances to reflect reconciled year end balances. Without the year end balances for audit not adjusted to reconciled balances, it was identified that internal control policies and procedures did not prevent, or detect and correct, material misstatements of the financial statements submitted for audit. Criteria: Policies and procedures for reconciliation of accounts and adjusted to related accounting records will facilitate annual and interim financial statements that are materially correct. Cause: Policies and procedures have been established for reconciliation of accounts and adjustments to related accounting records. However, over the audit period, there were several transitions in the Director of Finance position. With these transitions, certain adjustments were not performed prior to audit. Effect: Because of the unadjusted balances to significant accounts within accounting records prior to audit, there were a significant amount of audit year end adjustments. The adjustments are a reflection of the weakness in the internal control process to provide materially correct financial statements on an interim and annual basis. Views of Responsible Officials and Planned Corrective Actions: Toledo Northwestern Ohio Food Bank, Inc. agrees with the finding and the recommended procedures have been implemented.

Views of Responsible Officials and Planned Corrective Actions: Toledo Northwestern Ohio Food Bank, Inc. agrees with the finding and the recommended procedures have been implemented.