Midwest Food Bank NFP

2023-001: Procurement Requirements Criteria: The Organization is required to establish a procurement policy in accordance with Uniform Guidance requirements, as specified in the compliance supplement. Condition: For one of the 40 items tested, we noted one food purchase expense did not have the documentation as required by the procurement policy. Based on inquiry with management, the procurement policy was not consistently followed for purchases surrounding food. Questioned costs: $51,200 Cause and Effect: By not maintaining documentation as required by the procurement policy, the Organization could expense funds that are not in accordance with the procurement policies established by Uniform Guidance Recommendation: We recommend the Organization provide training to staff on the requirements of the procurement policy. Auditee Response: The Organization will provide additional communication and training to staff on the requirements of the procurement policy

2022-001: Procurement Requirements Criteria: The Organization is required to establish a procurement policy in accordance with Uniform Guidance requirements, as specified in the compliance supplement. Condition: The Organization did not establish a procurement policy in accordance with Uniform Guidance 2 CFR 200.318 ? 200.327, as required for the major program. The Organization developed and implemented a policy during 2022 but it was not in effect for the whole organization for the entire year. Questioned costs: None Cause and Effect: By not having an updated procurement policy the Organization could expense funds that are not in accordance with the procurement policies established by Uniform Guidance Recommendation: We recommend the Organization establish a procurement policy based on the requirements noted in 2 CFR 200.318-200.327. Auditee Response: The Organization established and implemented a procurement policy in accordance with Uniform Guidance requirements during the year in 2022.

2022-002: Reporting Requirements Criteria: The Organization is required to submit various reports as listed in each grant agreement for the major program. The Organization submitted three reports after the reporting deadline. Condition: The Organization did not timely file all reports in accordance with reporting requirements listed in each grant. Questioned costs: None Cause and Effect: By not filing all reports timely, the Organization could face repercussions from the grantors. Recommendation: We recommend the Organization establish processes to evaluate and track reporting requirements for each grant to ensure required reports are filed timely. Auditee Response: The Organization inadvertently missed the reporting deadline due to misinterpreting the reporting requirements. The Organization intends to more closely identify and track reporting deadlines.

Federal Program Name and Year: Department of U.S. Treasury, Coronavirus Relief Fund ? 2020, CFDA No.: 21.019, Passed Through: Lee County, FL Criteria and Condition: Per Federal Compliance Requirements, Coronavirus Relief Fund monies received by recipients and sub-recipients should be used on necessary expenditures incurred due to the public health emergency with respect to Coronavirus Disease 2019 (COVID?19) and on costs that were not accounted for in the Organization's most recently approved budget as of March 27, 2020. The Organization requested reimbursement for expenditures budgeted prior to March 27, 2020. Context: As a sub-recipient, the Organization received Coronavirus Relief Fund monies (CFDA #21.019) through Lee County, Florida (County) on a reimbursement basis with approval of appropriateness given by the County. The County?s reimbursement basis did not follow the Federal Compliance Requirements of the Coronavirus Relief Fund. Effect and questioned costs: The Organization was reimbursed with Federal monies for costs of supplies and services totaling $78,127, with $50,000 accounting for one debt repayment, that were budgeted and/or expected in normal operations of the Organization. These types of expenses were not appropriate based on the Federal Compliance Requirements. Cause: Program employees were unaware of the compliance requirement. Also, due to the speed and unusual nature of the grant there was a lack of guidance available when funds were released. Recommendation: We recommend the Organization monitor all grants received and if a Federal program to review the applicable Federal Compliance Requirements. Views of responsible officials and Planned Corrective Actions: The Federal Compliance Requirements for the Coronavirus Relief Fund monies were approved by the county the funds originated at the time of disbursement. The compliance requirements lacked specific guidance as to what could be reimbursed. Dana Williamsen, Accounting Director, will be reviewing each grant documentation to identify if Midwest Food Bank is a "sub-recipient" of funds that would be subject to a Federal Program's Compliance Requirements and review the Federal Compliance Supplement for the specific programs with an anticipated start date of May 2021.