Tri-State Food Bank, Inc.

SECTION II ? FINANCIAL STATEMENT FINDINGS None for the year ended June 30, 2022. SECTION III ? MAJOR FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING OF NONCOMPLIANCE: Finding No.: 2022-001 Subrecipient Eligibility Federal Program Name: Food Distribution Cluster CFDA Numbers: 10.565, 10.568, 10.569 Federal Agency: U.S. Department of Agriculture Information on Federal Program: The objective of the Food Distribution Cluster is to strengthen the nutrition safety net through the provision of U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. Included in the cluster are the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP). Criteria or Specific Requirement: The Organization must enter into written agreements with their subrecipient agencies that includes certain information, including references to 7 CFR section 247.4 and must also include a statement that recipient agencies are responsible for certain losses. Condition: During the testing of thirty seven subrecipient agency agreements, we noted 6 that did not have all required information. Questioned Costs: N/A Context: Of 75 agencies receiving commodities, KCPAG tested 37. There were four Kentucky agreements that were missing a reference to 7 CFR section 247.4 and two Illinois agreements that were missing a statement that the subrecipient agency was responsible for certain losses. Effect: The Organization is not in compliance with applicable regulations. Cause: The Organization used a simplified contract for CSFP that did not have the required information. Identification as a repeat finding, if applicable: N/A Recommendation: We recommend that the Organization update all agreements to include all required information and references.

Corrective Action Plan Finding No.: 2022-001 Subrecipient Eligibility Federal Program Name: Food Distribution Cluster CFDA Numbers: 10.565, 10.568, 10.569 Federal Agency: U.S. Department of Agriculture Requirement: The Organization must enter into written agreements with their subrecipient agencies that includes certain information, including references to 7 CFR section 247.4 and a statement that subrecipient agencies are responsible for certain losses. Finding: During the testing of 37 subrecipient agency agreements, we noted 6 that did not have all required information. Questioned Costs: N/A Systemic or Isolated: This instance of noncompliance is systemic with regard to CSFP subrecipient agreements in Kentucky and Illinois. Effect of Finding: The Organization is not in compliance with applicable regulations. Recommendation: We recommend that the Organization update all agreements to include all required information and references. Corrective Action Plan: Management will immediately update all Illinois CSFP contracts with the required language that references 7 CFR section 247.4 and send the updated contracts to all participating Illinois sites for signature and return to Tri-State Food Bank. Contact Person Responsible for Corrective Action: Glenn Roberts, Executive Director Anticipated Completion Date: January 31, 2022

SECTION II ? FINANCIAL STATEMENT FINDINGS None for the year ended June 30, 2021. SECTION III ? MAJOR FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FINDING OF NONCOMPLIANCE: Finding No.: 2021-001 Subrecipient Eligibility Federal Program Name: Food Distribution Cluster CFDA Numbers: 10.565, 10.568, 10.569 Federal Agency: U.S. Department of Agriculture Information on Federal Program: The objective of the Food Distribution Cluster is to strengthen the nutrition safety net through the provision of U.S. Department of Agriculture (USDA)-donated foods (USDA Foods) to low-income persons. Included in the cluster are the Commodity Supplemental Food Program (CSFP) and the Emergency Food Assistance Program (TEFAP). Criteria or Specific Requirement: The Organization must enter into written agreements with their subrecipient agencies that includes certain information, including references to 7 CFR section 247.4. Condition: During the testing of eight subrecipient agency agreements, we noted 3 that did not have all required information. Questioned Costs: N/A Context: Of 76 agencies receiving commodities, KCPAG tested 8. There were 3 agreements that were missing a reference to 7 CFR section 247.4. Effect: The Organization is not in compliance with applicable regulations. Cause: The Organization used a simplified contract for CSFP that did not have the required information. Identification as a repeat finding, if applicable: N/A Recommendation: We recommend that the Organization update all agreements to include all required information and references. Views of Responsible Officials:

Corrective Action Plan Finding No.: 2021-001 Subrecipient Eligibility Federal Program Name: Food Distribution Cluster CFDA Numbers: 10.565, 10.568, 10.569 Federal Agency: U.S. Department of Agriculture Requirement: The Organization must enter into written agreements with their subrecipient agencies that includes certain information, including references to 7 CFR section 247.4. Finding: During the testing of 8 subrecipient agency agreements, we noted 3 that did not have all required information. Questioned Costs: N/A Systemic of Isolated: This instance of noncompliance is systemic with regard to CSFB subrecipient agreements. Effect of Finding: The Organization is not in compliance with applicable regulations. Recommendation: We recommend that the Organization update all agreements to include all required information and references. Corrective Action Plan: Contact Person Responsible for Corrective Action: Glenn Roberts, Executive Director Anticipated Completion Date:

Finding No.: 2019-001 Subrecipient Compliance ? Civil Rights Training Federal Program Name: Emergency Food Assistance Program (Food Commodities) CFDA Number: 10.569 Federal Agency: U.S. Department of Agriculture Information on the Federal Program: ? 10.569 ? To strengthen the nutrition safety net through the provision of U.S. Department of Agriculture (USDA) ? donated foods to low-income persons. Criteria or Specific Requirement: The Organization, along with the USDA, requires subrecipient agencies to complete annual civil rights training. Condition: During the testing of monitoring of subrecipients we noted that 28 subrecipients did not have completed civil rights training in their file for the current fiscal year. Questioned Costs: N/A Context: We tested 40 subrecipients and noted 28 that had not completed civil rights training for the current fiscal year. Effect: The Organization was not in compliance with requirements in relation to having all subrecipients complete the annual civil rights training. Cause: The Organization did send out training information to all agencies but failed to follow up in making sure all agencies had completed the training and turned in their completed information. Identification as a repeat finding, if applicable: N/A Recommendation: The Organization should verify that all subrecipient agencies have completed the required training annually. Views of Responsible Officials: Management is aware of the requirement to have all subrecipient agencies complete the annual civil rights training. Corrective Actions: Management will ensure that all subrecipient agencies will complete the required annual civil rights training by taking the following measures: Tri-State Food Bank will organize and host an annual agency conference in which agency representatives will receive the required civil rights training; for those representatives who, for whatever reason, are unable to attend the aforementioned agency conference, management will provide training either remotely or in person to the individual agency; management has restructured job assignments and has transferred the role of USDA Coordinator (who is responsible for agency training) to the Bookkeeper who has past experience in this role.

Finding No.: 2019-001 Subrecipient Compliance ? Civil Rights Training Federal Program Name: Emergency Food Assistance Program (Food Commodities) CFDA Number: 10.569 Federal Agency: U.S. Department of Agriculture Requirement: The Organization, along with the USDA, requires subrecipient agencies to complete annual civil rights training. Finding: During the testing of monitoring of subrecipients we noted that 28 subrecipients did not have completed civil rights training in their file for the current fiscal year. Questioned Costs: N/A Systemic or Isolated: This instance of noncompliance is systemic. Effect of Finding: The Organization was not in compliance with requirements in relation to having all subrecipients complete the annual civil rights training. Recommendation: The Organization should verify that all subrecipient agencies have completed the required training annually. Corrective Action Plan: Management will ensure that all subrecipient agencies will complete the required annual civil rights training by taking the following measures: Tri-State Food Bank will organize and host an annual agency conference in which agency representatives will receive the required civil rights training; for those representatives who, for whatever reason, are unable to attend the aforementioned agency conference, management will provide training either remotely or in person to the individual agency; management has restructured job assignments and has transferred the role of USDA Coordinator (who is responsible for agency training) to the Bookkeeper who has past experience in this role. Contact Person Responsible for Corrective Action: Glenn Roberts, Executive Director Anticipated Completion Date: Immediately

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2016-001

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