PARTNERS IN NUTRITION

EIN: 474302258

UEI: C6ATHHFBAE88

Data as of August 24, 2026

PARTNERS IN NUTRITION6 audit years16 findings2 repeat
6
Audit Years
16
Total Findings
2
Repeat Findings

FY 2022-09-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 11, 2023. 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 January 11, 2024 (956 days ago).

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2022-002
Subrecipient Monitoring
MATERIAL WEAKNESS

FINDING REFERENCE NUMBER 2022-002 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted the following issues during testing of compliance requirements: 1. There was one instance out of forty CACFP claims tested in which the Organization failed to collect all invoices and receipts from the subrecipient site, resulting in the spreadsheet tracking the subrecipient sites? allowable food and non-food expenditures being incomplete. In addition, there was one instance out of forty CACFP claims tested in which the spreadsheet tracking the subrecipient sites? expenditures was corrupted and could not be opened. By failing to track food costs, the Organization was unable to verify whether the nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. 2. There were two instances out of forty CACFP claims tested in which the Organization could not locate the monitoring visit forms. 3. There was one instance out of forty CACFP claims tested in which the Organization retained a 10% administrative fee despite the Sponsor Agreement indicating a 15% admin fee. The error resulted in the subrecipient site being over-reimbursed by $282. 4. There were two instances out of forty CACFP claims tested in which the subrecipients? Site Information Form was incomplete. The forms were missing contact names and dates of birth, hours of operation, licensed capacity, average daily attendance, meal times, and whether the food is prepared by the site or obtained from a vendor. Criteria or Specific Requirement 1. In regard to the first issue noted above, CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. 2. In regard to the second issue noted above, CACFP sponsors are required to retain subrecipient site monitoring forms to support that monitoring visits were performed throughout the year. 3. In regard to the third issue noted above, the Organization is to retain an administrative fee for the percentage stated within the Sponsor Agreement. 4. In regard to the fourth issue noted above, CACFP sponsors are required to retain information regarding the subrecipient sites? operations to ensure that the sites are eligible to participate in the CACFP and the information required to effectively perform subrecipient monitoring procedures is on file. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause During fiscal 2021, and continuing into fiscal 2022, the Organization experienced significant growth in the number of subrecipients under its sponsorship and the number of claims processed, largely due to the impacts of the COVID-19 pandemic. As a result, the systems of controls in place were inadequate to meet demands for services. There was a lack of staffing to handle administrative and program responsibilities, as well as a lack of oversight to identify errors and gaps in documentation. Recommendation The Organization should expand staffing to better manage caseloads and meet the demands of administrative and program responsibilities. In addition, the Organization should implement a quality control function to ensure that processes in place are operating effectively. Lastly, the Organization should perform checks of documentation periodically to ensure that no documentation is missing, or if there is a lack of documentation, that it is addressed and corrected timely.

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Full finding narrative

FINDING REFERENCE NUMBER 2022-002 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted the following issues during testing of compliance requirements: 1. There was one instance out of forty CACFP claims tested in which the Organization failed to collect all invoices and receipts from the subrecipient site, resulting in the spreadsheet tracking the subrecipient sites? allowable food and non-food expenditures being incomplete. In addition, there was one instance out of forty CACFP claims tested in which the spreadsheet tracking the subrecipient sites? expenditures was corrupted and could not be opened. By failing to track food costs, the Organization was unable to verify whether the nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. 2. There were two instances out of forty CACFP claims tested in which the Organization could not locate the monitoring visit forms. 3. There was one instance out of forty CACFP claims tested in which the Organization retained a 10% administrative fee despite the Sponsor Agreement indicating a 15% admin fee. The error resulted in the subrecipient site being over-reimbursed by $282. 4. There were two instances out of forty CACFP claims tested in which the subrecipients? Site Information Form was incomplete. The forms were missing contact names and dates of birth, hours of operation, licensed capacity, average daily attendance, meal times, and whether the food is prepared by the site or obtained from a vendor. Criteria or Specific Requirement 1. In regard to the first issue noted above, CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. 2. In regard to the second issue noted above, CACFP sponsors are required to retain subrecipient site monitoring forms to support that monitoring visits were performed throughout the year. 3. In regard to the third issue noted above, the Organization is to retain an administrative fee for the percentage stated within the Sponsor Agreement. 4. In regard to the fourth issue noted above, CACFP sponsors are required to retain information regarding the subrecipient sites? operations to ensure that the sites are eligible to participate in the CACFP and the information required to effectively perform subrecipient monitoring procedures is on file. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause During fiscal 2021, and continuing into fiscal 2022, the Organization experienced significant growth in the number of subrecipients under its sponsorship and the number of claims processed, largely due to the impacts of the COVID-19 pandemic. As a result, the systems of controls in place were inadequate to meet demands for services. There was a lack of staffing to handle administrative and program responsibilities, as well as a lack of oversight to identify errors and gaps in documentation. Recommendation The Organization should expand staffing to better manage caseloads and meet the demands of administrative and program responsibilities. In addition, the Organization should implement a quality control function to ensure that processes in place are operating effectively. Lastly, the Organization should perform checks of documentation periodically to ensure that no documentation is missing, or if there is a lack of documentation, that it is addressed and corrected timely.

Corrective Action Plan

In October 2021, the Organization created a full-time staff position whose primary responsibilities were to collect, review, and track invoices and receipts. The individual was instructed to use the Journal Ledger Spreadsheet provided by MDE. However, the spreadsheet does not include a cross-check to verify that the receipts and invoices entered into the spreadsheet have associated images or scans of receipts. The Organization will begin utilizing the My Food Program software to enter invoices and receipts to track the nonprofit food service. The software will be configured to require the upload of a photo or scan of the actual receipt or invoice in order to create the expense, thus guaranteeing that documentation of the expense exists and is appropriately maintained. This procedure will also resolve any issues with corrupted files as the reports can be generated from the cloud-based software. The Organization abruptly ceased operations in January 2022. It is our understanding that sponsored sites must prove that they expended all program funds on approved program-related expenses, but are not required to do so in the month the funds were received. In other words, sponsored sites would have had all of fiscal year 2022 to document the expenditures of all funds received in fiscal year 2022. It is reasonable to assume that sites with an excessive balance in their food service account would have been able to document appropriate expenditures if given sufficient time. The Organization is confident that the systems in place in fiscal year 2022 would have allowed the Organization to monitor the appropriate use of excessive nonprofit food service program balances in future periods; most notably through the Organization?s policies and procedures contained in the Management Plan and approved by MDE. The Organization holds future claims if the balance in the food service account exceeds a three-month average of expenditures. Monitoring forms were completed on paper during fiscal year 2022. Staff were instructed to scan and save an electronic copy of the monitoring form on the Organization?s cloud-based storage system. In some cases, staff failed to save an electronic copy and the only verification of the monitoring visit is contained in paper files that are currently in off-site storage. The Organization believes that staff adhered to the monitoring requirements, despite the documentation of those visits not being readily available. Going forward, all monitoring staff will be required to complete site visits electronically using the My Food Program software. The software will store the monitoring form electronically on the cloud, inclusive of sponsor and site staff signatures with date-time stamps. There are also comprehensive monitor tracking reports available to assist with monitoring frequency compliance. In the event of a loss of internet service, the monitors will be required to complete the visit on paper and upload a copy to the My Food Program software. The Organization agrees that the retained administrative fee should reflect the administrative fee percentage stated in the Sponsor Agreement. However, the Organization would like to note that the USDA Guidance for Management Plans & Budgets states that, ?A sponsoring organization may retain a portion of the reimbursement for costs associated with administering the CACFP. It may retain up to 15 percent of the total CACFP reimbursement received, or the actual net administrative costs incurred, whichever is less.? Further in the same document, it states, ?There is a concern that sponsoring organizations of centers may spend more on administrative costs than on food. The state agency?s review should investigate how reimbursements are disbursed and whether the food service is supported appropriately.? The Organization would like to emphasize that additional funds, in a miniscule amount, were spent on operating costs, such as food, and it did not retain additional administrative funds. The Organization?s policy in fiscal year 2022 was to track the administrative fee percentage in the claims tracking spreadsheet in lieu of referencing a signed agreement each month. This is supported by the Organization?s disbursement allocation policy, which is included in the fiscal year 2022 Management Plan and approved by MDE. In fiscal 2022, the claims staff would alter the administrative fee percentage upon the written direction of the Executive Director or Director of Operations based on their verbal or written interactions with the site. Going forward, claims staff will not be allowed to change the administrative fee percentage in the claims tracking spreadsheet unless a revised Sponsor Agreement is signed. The Site Information Form was used as a supplement to other operational information about the site. This form is not a federal requirement, nor a form provided by or required by the state agency. During fiscal year 2022, the processing time for the approval of site applications by the state agency was beyond the normal thirty business days. Therefore, sites interested in participating under the sponsorship of the Organization would often complete the Site Information Form as early as possible so that the Organization could submit the site application with MDE. Oftentimes, at the time the Site Information Form was completed, the site may not have finalized site operating times and meal times. The Organization maintained a complete record of all required site information at all times. Contact names and dates of birth of responsible individuals at the sites were documented in the Google sheet used to track information during the intake appointment. In addition, the hours of operation and licensed capacity were maintained in My Food Program software. Lastly, the sites? food preparation methods were also documented on the Google sheet with site information. Catering contracts with vended meal providers are maintained on-file as they are required to be uploaded to the state agency with the site application. Going forward, the Organization will no longer use the Site Information Form or the Google sheet to track required site information. Instead, all data to ensure that the sites are eligible to participate in the CACFP, and the information required to effectively perform subrecipient monitoring procedures, will be retained in the My Food Program software.

About Subrecipient Monitoring →

FY 2021-09-30

FAC accepted this audit on January 31, 2023 — management decision was due July 31, 2023.

2021-002
Subrecipient Monitoring
MATERIAL WEAKNESS

FINDING REFERENCE NUMBER 2021-002 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted the following issues during testing of compliance requirements: 1. There was one instance out of forty CACFP claims tested in which the incorrect cash in lieu amount was documented in the claims spreadsheet. This resulted in an incorrect calculation of the administrative fee to be retained by the Organization and the subrecipient site was underpaid by $30. 2. There were three instances out of forty CACFP claims tested in which the Organization failed to collect all invoices and receipts from the subrecipient site, resulting in the spreadsheet tracking the subrecipient sites? allowable food and non-food expenditures being incomplete. In addition, there were two instances out of forty CACFP claims tested in which the spreadsheet tracking the subrecipient sites? expenditures could not be located. By failing to track food costs, the Organization was unable to verify whether the nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. 3. There was one instance out of forty CACFP claims tested in which the Organization could not locate the subrecipient site?s menu with substitutions. 4. There were three instances out of forty CACFP claims tested in which the Organization could not locate the monitoring visit forms. 5. There were two instances out of forty CACFP claims tested in which the Organization could not provide the Sponsor Agreement. Criteria or Specific Requirement 1. In regard to the first issue noted above, the amount to be reimbursed to subrecipients should be the amount of the claim, less cash in lieu meals, less the administrative fee outlined in the Sponsor Agreement to be retained by the Organization. 2. In regard to the second issue noted above, CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. 3. In regard to the third issue noted above, CACFP sponsors are required to retain subrecipient site menus and substitutions to ensure that meal requirements have been met. 4. In regard to the fourth issue noted above, CACFP sponsors are required to retain subrecipient site monitoring forms to support that monitoring visits were performed throughout the year. 5. In regard to the fifth issue noted above, CACFP sponsors are required to retain Sponsor Agreements for subrecipient sites to ensure that the sites are eligible to participate in the CACFP. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause During fiscal 2021, the Organization experienced significant growth in the number of subrecipients under their sponsorship and the number of claims processed, largely due to the impacts of the COVID-19 pandemic. As a result, systems of controls in place were inadequate to meet demands for services. There was a lack of staffing to handle administrative and program responsibilities, as well as a lack of oversight to identify errors and gaps in documentation. In addition, the COVID-19 pandemic made it more difficult to perform detailed site visits whereby all meals were appropriately accounted for, creating exposure of billings in excess of meal served. Recommendation The Organization should expand staffing to better manage caseloads and meet the demands of administrative and program responsibilities. In addition, the Organization should implement a quality control function to ensure that processes in place are operating effectively. Lastly, the Organization should perform checks of documentation periodically to ensure that no documentation is missing, or if there is a lack of documentation, that it is addressed and corrected timely. Views of Responsible Officials and Corrective Action Plan The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. Our Claims Staff will review the payment information from CLiCS each Monday and ensure that the amount in My Food Program matches the true payment amount. Once that is confirmed, they will save that information and it will generate the bill for the vendor or site that the claim is linked to. The Interim Executive Director or Director of Operations will then run a report that will show the open bills and remit payment based off that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization or paying the incorrect amount. Claims for reimbursement will not be processed without receiving all required documentation to validate the claim. This includes, but is not limited to, meal counts, attendance, menus with substitutions, and receipts. Receipts will be reviewed against the menu and recorded on the expense tracker spreadsheet. Once the receipts are recorded and the claim is processed, Claims Support will record the amount of reimbursement provided to each site in the expense tracker spreadsheet. Claims Support will notify the appropriate agency funded if there is excess funding and the balance of unspent funds that the site has. Site Support will follow up with the program to discuss the reason for the excess funding and how it will be corrected. ?Excess Funding? would be considered 3 months? worth of expenses. If a program gets to a point where they have ?excess funding,? we will not process a claim until the money is spent down to acceptable levels. The Organization will decrease the case load for each Site Support to ensure the demands of the administrative and program requirements are met for all sites. Each Site Support will be responsible for completing a monthly file review for each site assigned to their case load. This will be completed by using a Site Folder Checklist that includes a list of all required documentation. The Director of Operations will complete a review of all site folders quarterly to ensure all required documentation has been collected.

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Full finding narrative

FINDING REFERENCE NUMBER 2021-002 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted the following issues during testing of compliance requirements: 1. There was one instance out of forty CACFP claims tested in which the incorrect cash in lieu amount was documented in the claims spreadsheet. This resulted in an incorrect calculation of the administrative fee to be retained by the Organization and the subrecipient site was underpaid by $30. 2. There were three instances out of forty CACFP claims tested in which the Organization failed to collect all invoices and receipts from the subrecipient site, resulting in the spreadsheet tracking the subrecipient sites? allowable food and non-food expenditures being incomplete. In addition, there were two instances out of forty CACFP claims tested in which the spreadsheet tracking the subrecipient sites? expenditures could not be located. By failing to track food costs, the Organization was unable to verify whether the nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. 3. There was one instance out of forty CACFP claims tested in which the Organization could not locate the subrecipient site?s menu with substitutions. 4. There were three instances out of forty CACFP claims tested in which the Organization could not locate the monitoring visit forms. 5. There were two instances out of forty CACFP claims tested in which the Organization could not provide the Sponsor Agreement. Criteria or Specific Requirement 1. In regard to the first issue noted above, the amount to be reimbursed to subrecipients should be the amount of the claim, less cash in lieu meals, less the administrative fee outlined in the Sponsor Agreement to be retained by the Organization. 2. In regard to the second issue noted above, CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. 3. In regard to the third issue noted above, CACFP sponsors are required to retain subrecipient site menus and substitutions to ensure that meal requirements have been met. 4. In regard to the fourth issue noted above, CACFP sponsors are required to retain subrecipient site monitoring forms to support that monitoring visits were performed throughout the year. 5. In regard to the fifth issue noted above, CACFP sponsors are required to retain Sponsor Agreements for subrecipient sites to ensure that the sites are eligible to participate in the CACFP. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause During fiscal 2021, the Organization experienced significant growth in the number of subrecipients under their sponsorship and the number of claims processed, largely due to the impacts of the COVID-19 pandemic. As a result, systems of controls in place were inadequate to meet demands for services. There was a lack of staffing to handle administrative and program responsibilities, as well as a lack of oversight to identify errors and gaps in documentation. In addition, the COVID-19 pandemic made it more difficult to perform detailed site visits whereby all meals were appropriately accounted for, creating exposure of billings in excess of meal served. Recommendation The Organization should expand staffing to better manage caseloads and meet the demands of administrative and program responsibilities. In addition, the Organization should implement a quality control function to ensure that processes in place are operating effectively. Lastly, the Organization should perform checks of documentation periodically to ensure that no documentation is missing, or if there is a lack of documentation, that it is addressed and corrected timely. Views of Responsible Officials and Corrective Action Plan The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. Our Claims Staff will review the payment information from CLiCS each Monday and ensure that the amount in My Food Program matches the true payment amount. Once that is confirmed, they will save that information and it will generate the bill for the vendor or site that the claim is linked to. The Interim Executive Director or Director of Operations will then run a report that will show the open bills and remit payment based off that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization or paying the incorrect amount. Claims for reimbursement will not be processed without receiving all required documentation to validate the claim. This includes, but is not limited to, meal counts, attendance, menus with substitutions, and receipts. Receipts will be reviewed against the menu and recorded on the expense tracker spreadsheet. Once the receipts are recorded and the claim is processed, Claims Support will record the amount of reimbursement provided to each site in the expense tracker spreadsheet. Claims Support will notify the appropriate agency funded if there is excess funding and the balance of unspent funds that the site has. Site Support will follow up with the program to discuss the reason for the excess funding and how it will be corrected. ?Excess Funding? would be considered 3 months? worth of expenses. If a program gets to a point where they have ?excess funding,? we will not process a claim until the money is spent down to acceptable levels. The Organization will decrease the case load for each Site Support to ensure the demands of the administrative and program requirements are met for all sites. Each Site Support will be responsible for completing a monthly file review for each site assigned to their case load. This will be completed by using a Site Folder Checklist that includes a list of all required documentation. The Director of Operations will complete a review of all site folders quarterly to ensure all required documentation has been collected.

Corrective Action Plan

The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. Our Claims Staff will review the payment information from CLiCS each Monday and ensure that the amount in My Food Program matches the true payment amount. Once that is confirmed, they will save that information and it will generate the bill for the vendor or site that the claim is linked to. The Interim Executive Director or Director of Operations will then run a report that will show the open bills and remit payment based off that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization or paying the incorrect amount. Claims for reimbursement will not be processed without receiving all required documentation to validate the claim. This includes, but is not limited to, meal counts, attendance, menus with substitutions, and receipts. Receipts will be reviewed against the menu and recorded on the expense tracker spreadsheet. Once the receipts are recorded and the claim is processed, Claims Support will record the amount of reimbursement provided to each site in the expense tracker spreadsheet. Claims Support will notify the appropriate agency funded if there is excess funding and the balance of unspent funds that the site has. Site Support will follow up with the program to discuss the reason for the excess funding and how it will be corrected. ?Excess Funding? would be considered 3 months? worth of expenses. If a program gets to a point where they have ?excess funding,? we will not process a claim until the money is spent down to acceptable levels. The Organization will decrease the case load for each Site Support to ensure the demands of the administrative and program requirements are met for all sites. Each Site Support will be responsible for completing a monthly file review for each site assigned to their case load. This will be completed by using a Site Folder Checklist that includes a list of all required documentation. The Director of Operations will complete a review of all site folders quarterly to ensure all required documentation has been collected.

About Subrecipient Monitoring →
2021-003
Subrecipient Monitoring
MATERIAL WEAKNESS

FINDING REFERENCE NUMBER 2021-003 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted one instance out of forty CACFP claims tested in which the meal counts provided by the program site that were reimbursed on the selected claim were significantly higher than expected when compared to the available roster for the program site. Criteria or Specific Requirement CACFP sponsors are required to obtain attendance reports and program rosters to ensure that meal counts appear to be reasonable before processing the claim. Questioned Costs Total questioned costs are unknown. Refer to explanation under ?Cause? below. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause The Organization?s inability to provide a roster to corroborate meal counts is a result of a lack of internal controls surrounding claim and meal count review. Recommendation The Organization should implement an effective system of controls whereby meal counts are compared against student rosters prior to approval and reimbursement to ensure meal counts are reasonable prior to issuing claim reimbursements. Views of Responsible Officials and Corrective Action Plan The Organization will have all sites? meal counts and attendances entered into My Food Program. Within this software, there are checks and balances that would not allow more meal counts to be claimed than the number of participants in attendance.

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Full finding narrative

FINDING REFERENCE NUMBER 2021-003 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted one instance out of forty CACFP claims tested in which the meal counts provided by the program site that were reimbursed on the selected claim were significantly higher than expected when compared to the available roster for the program site. Criteria or Specific Requirement CACFP sponsors are required to obtain attendance reports and program rosters to ensure that meal counts appear to be reasonable before processing the claim. Questioned Costs Total questioned costs are unknown. Refer to explanation under ?Cause? below. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause The Organization?s inability to provide a roster to corroborate meal counts is a result of a lack of internal controls surrounding claim and meal count review. Recommendation The Organization should implement an effective system of controls whereby meal counts are compared against student rosters prior to approval and reimbursement to ensure meal counts are reasonable prior to issuing claim reimbursements. Views of Responsible Officials and Corrective Action Plan The Organization will have all sites? meal counts and attendances entered into My Food Program. Within this software, there are checks and balances that would not allow more meal counts to be claimed than the number of participants in attendance.

Corrective Action Plan

The Organization will have all sites? meal counts and attendances entered into My Food Program. Within this software, there are checks and balances that would not allow more meal counts to be claimed than the number of participants in attendance.

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FY 2020-09-30

FAC accepted this audit on August 26, 2022 — management decision was due February 26, 2023.

2020-002
Reporting

FINDING REFERENCE NUMBER 2020-002 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Reporting TYPE OF FINDING Noncompliance and Significant Deficiency in Internal Control Statement of Condition The Uniform Guidance Report for the year ended September 30, 2020 was submitted during August 2022, which was several months after its due date. Criteria or Specific Requirement The Uniform Guidance Report is normally due nine months after the Organization?s fiscal year end. In addition, the Federal Audit Clearinghouse filing is normally due thirty days after the receipt of the auditor?s report or nine months after the end of the fiscal year ? whichever comes first. A special sixmonth extension past the normal due dates was granted due to the COVID-19 pandemic, extending the submission due date for the year ended September 30, 2020, to December 31, 2021. Questioned Costs Not applicable. Effect The Organization did not comply with the reporting requirements established by the Federal Agency. Cause The Uniform Guidance audit for the year ended September 30, 2020 was delayed due to the withdrawal of the previous auditors due to investigations by the Minnesota Department of Education (?MDE?). Recommendation The Organization should closely monitor compliance with reporting requirements established by the Federal Agency. Views of Responsible Officials and Corrective Action Plan The Organization will begin procuring audit firms on September 1st of each fiscal year. The goal is to have a signed engagement letter by September 30th to ensure compliance with federal reporting requirements. The Organization will check in with the audit firm monthly to confirm that deadlines will be met.

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Full finding narrative

FINDING REFERENCE NUMBER 2020-002 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Reporting TYPE OF FINDING Noncompliance and Significant Deficiency in Internal Control Statement of Condition The Uniform Guidance Report for the year ended September 30, 2020 was submitted during August 2022, which was several months after its due date. Criteria or Specific Requirement The Uniform Guidance Report is normally due nine months after the Organization?s fiscal year end. In addition, the Federal Audit Clearinghouse filing is normally due thirty days after the receipt of the auditor?s report or nine months after the end of the fiscal year ? whichever comes first. A special sixmonth extension past the normal due dates was granted due to the COVID-19 pandemic, extending the submission due date for the year ended September 30, 2020, to December 31, 2021. Questioned Costs Not applicable. Effect The Organization did not comply with the reporting requirements established by the Federal Agency. Cause The Uniform Guidance audit for the year ended September 30, 2020 was delayed due to the withdrawal of the previous auditors due to investigations by the Minnesota Department of Education (?MDE?). Recommendation The Organization should closely monitor compliance with reporting requirements established by the Federal Agency. Views of Responsible Officials and Corrective Action Plan The Organization will begin procuring audit firms on September 1st of each fiscal year. The goal is to have a signed engagement letter by September 30th to ensure compliance with federal reporting requirements. The Organization will check in with the audit firm monthly to confirm that deadlines will be met.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-002 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Reporting TYPE OF FINDING Noncompliance and Significant Deficiency in Internal Control The Organization will begin procuring audit firms on September 1st of each fiscal year. The goal is to have a signed engagement letter by September 30th to ensure compliance with federal reporting requirements. The Organization will check in with the audit firm monthly to confirm that deadlines will be met.

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2020-003
Subrecipient Monitoring
MATERIAL WEAKNESS

FINDING REFERENCE NUMBER 2020-003 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted thirteen instances out of forty CACFP claims tested in which the spreadsheet tracking subrecipient sites? allowable food and non-food expenditures and CACFP reimbursements could not be provided. In addition, by failing to track food costs, the Organization was unable to verify whether nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. Furthermore, the auditor noted seventeen instances out of forty CACFP claims tested in which receipts to substantiate site expenditures on allowable food and non-food purchases could not be provided. Criteria or Specific Requirement CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. Questioned Costs Not applicable. Refer to explanation under ?Cause? below. Effect The Organization was unable to provide evidence that spending was monitored at the subrecipient level, and therefore could not support that adequate internal controls exist in this area to comply with the subrecipient monitoring requirements established by the Federal Agency, resulting in material noncompliance. Cause The Organization?s inability to provide spreadsheets tracking subrecipients? expenditures and CACFP reimbursements, as well as the inability to provide receipts to substantiate site expenditures on allowable food and non-food purchases, is a result of a loss of data experienced when the Organization switched its cloud-based document storage system. In addition, the Organization did not develop adequate controls to identify whether excessive nonprofit food service site program balances existed or take corrective action to monitor the use of excessive nonprofit food service program balances by subrecipients.Recommendation In response to the loss of data relating to the spreadsheets and receipts that were unable to be provided, the Organization should implement controls to ensure that data is backed up onto a server, or a dedicated place on the cloud, in order to protect against the loss of data. In response to the noncompliance in determining excessive nonprofit food service program balances, the Organization should maintain schedules of allowable expenditures and reimbursements and establish controls to regularly monitor whether subrecipients are generating excessive nonprofit food service program balances. Communication should take place with CACFP should any excess funds be generated by the program so that a corrective action plan can be developed. Furthermore, excessive nonprofit food service program balances generated each year should be monitored in conjunction with the applicable corrective action plan to ensure that such excessive nonprofit food service program balances have been appropriately utilized. Views of Responsible Officials and Corrective Action Plan The Organization is using Coordinated Business Systems as an IT consultant. Data is backed up on the cloud in order to protect against the loss of data. The Organization?s Claims Staff records all allowable food program expenses on the spreadsheet provided by MDE on a monthly basis. After all expenses are recorded, the claim is processed, and the reimbursement amount is recorded. The Claims Staff notifies the appropriate Site Support employee if there is excess funding received by the site year-to-date. Site Support employees follow up with the program to discuss the reason for the excess funding and how it will be corrected.

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FINDING REFERENCE NUMBER 2020-003 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control Statement of Condition The auditor noted thirteen instances out of forty CACFP claims tested in which the spreadsheet tracking subrecipient sites? allowable food and non-food expenditures and CACFP reimbursements could not be provided. In addition, by failing to track food costs, the Organization was unable to verify whether nonprofit service program sites generated an excessive nonprofit food service program balance or take corrective action to monitor the appropriate use of such excessive nonprofit food service program balances in future periods. Furthermore, the auditor noted seventeen instances out of forty CACFP claims tested in which receipts to substantiate site expenditures on allowable food and non-food purchases could not be provided. Criteria or Specific Requirement CACFP sponsors are required to maintain data in order to determine if a nonprofit food service program site is generating an excessive nonprofit food service program balance defined as a profit exceeding three months? average program operating expenses. Questioned Costs Not applicable. Refer to explanation under ?Cause? below. Effect The Organization was unable to provide evidence that spending was monitored at the subrecipient level, and therefore could not support that adequate internal controls exist in this area to comply with the subrecipient monitoring requirements established by the Federal Agency, resulting in material noncompliance. Cause The Organization?s inability to provide spreadsheets tracking subrecipients? expenditures and CACFP reimbursements, as well as the inability to provide receipts to substantiate site expenditures on allowable food and non-food purchases, is a result of a loss of data experienced when the Organization switched its cloud-based document storage system. In addition, the Organization did not develop adequate controls to identify whether excessive nonprofit food service site program balances existed or take corrective action to monitor the use of excessive nonprofit food service program balances by subrecipients.Recommendation In response to the loss of data relating to the spreadsheets and receipts that were unable to be provided, the Organization should implement controls to ensure that data is backed up onto a server, or a dedicated place on the cloud, in order to protect against the loss of data. In response to the noncompliance in determining excessive nonprofit food service program balances, the Organization should maintain schedules of allowable expenditures and reimbursements and establish controls to regularly monitor whether subrecipients are generating excessive nonprofit food service program balances. Communication should take place with CACFP should any excess funds be generated by the program so that a corrective action plan can be developed. Furthermore, excessive nonprofit food service program balances generated each year should be monitored in conjunction with the applicable corrective action plan to ensure that such excessive nonprofit food service program balances have been appropriately utilized. Views of Responsible Officials and Corrective Action Plan The Organization is using Coordinated Business Systems as an IT consultant. Data is backed up on the cloud in order to protect against the loss of data. The Organization?s Claims Staff records all allowable food program expenses on the spreadsheet provided by MDE on a monthly basis. After all expenses are recorded, the claim is processed, and the reimbursement amount is recorded. The Claims Staff notifies the appropriate Site Support employee if there is excess funding received by the site year-to-date. Site Support employees follow up with the program to discuss the reason for the excess funding and how it will be corrected.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-003 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Material Noncompliance and Material Weakness in Internal Control The Organization is using Coordinated Business Systems as an IT consultant. Data is backed up on the cloud in order to protect against the loss of data. The Organization?s Claims Staff records all allowable food program expenses on the spreadsheet provided by MDE on a monthly basis. After all expenses are recorded, the claim is processed, and the reimbursement amount is recorded. The Claims Staff notifies the appropriate Site Support employee if there is excess funding received by the site year-to-date. Site Support employees follow up with the program to discuss the reason for the excess funding and how it will be corrected.

About Subrecipient Monitoring →
2020-004
Cash Management
QUESTIONED COSTS

FINDING REFERENCE NUMBER 2020-004 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted one instance in which the Organization erroneously paid a SFSP vendor for a CACFP claim that should have been a reimbursement to a subrecipient. Criteria or Specific Requirement Sponsors are required to reimburse subrecipients within five days of the claim funds being received from the MDE. Questioned Costs $1,593 Effect The Organization should have paid the subrecipient site a reimbursement of $27,561. Instead, the Organization paid the SFSP vendor $27,561. Since the subrecipient site owed the SFSP vendor $25,968 for meals purchased, the SFSP vendor applied the payment received to the subrecipient site?s balance owed. As a result, the Organization underpaid the subrecipient site by $1,593 and did not comply with cash management requirements established by the Federal Agency. Cause The Organization erroneously paid the vendor rather than reimbursing the subrecipient because the Organization had recently transitioned out of the SFSP contract period, during which vendors are paid directly, and into the CACFP contract period, during which subrecipients are reimbursed. Recommendation The Organization should implement procedures and controls to ensure that the payments are made to the correct payees based on the types of program claims processed. Views of Responsible Officials and Corrective Action Plan The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. The Organization?s Claims Director will review the payment information from the Cyber-Linked Interactive Child Nutrition System (?CLiCS?) software program each Monday and ensure that the amount in My Food Program matches the true payment amount. Once confirmed, the Claims Director will save that information and it will generate the bill for the vendor or site whom that claim is linked to. The Executive Director or Director of Operations will then run a report that will show them the open bills and remit payment based off of that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization.

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FINDING REFERENCE NUMBER 2020-004 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted one instance in which the Organization erroneously paid a SFSP vendor for a CACFP claim that should have been a reimbursement to a subrecipient. Criteria or Specific Requirement Sponsors are required to reimburse subrecipients within five days of the claim funds being received from the MDE. Questioned Costs $1,593 Effect The Organization should have paid the subrecipient site a reimbursement of $27,561. Instead, the Organization paid the SFSP vendor $27,561. Since the subrecipient site owed the SFSP vendor $25,968 for meals purchased, the SFSP vendor applied the payment received to the subrecipient site?s balance owed. As a result, the Organization underpaid the subrecipient site by $1,593 and did not comply with cash management requirements established by the Federal Agency. Cause The Organization erroneously paid the vendor rather than reimbursing the subrecipient because the Organization had recently transitioned out of the SFSP contract period, during which vendors are paid directly, and into the CACFP contract period, during which subrecipients are reimbursed. Recommendation The Organization should implement procedures and controls to ensure that the payments are made to the correct payees based on the types of program claims processed. Views of Responsible Officials and Corrective Action Plan The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. The Organization?s Claims Director will review the payment information from the Cyber-Linked Interactive Child Nutrition System (?CLiCS?) software program each Monday and ensure that the amount in My Food Program matches the true payment amount. Once confirmed, the Claims Director will save that information and it will generate the bill for the vendor or site whom that claim is linked to. The Executive Director or Director of Operations will then run a report that will show them the open bills and remit payment based off of that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-004 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency The Organization will begin utilizing My Food Program and its Claims Payment feature. This feature allows each claim to be linked to a vendor or site in QuickBooks and will create a bill for the appropriate vendor or site. The Organization?s Claims Director will review the payment information from the Cyber-Linked Interactive Child Nutrition System (?CLiCS?) software program each Monday and ensure that the amount in My Food Program matches the true payment amount. Once confirmed, the Claims Director will save that information and it will generate the bill for the vendor or site whom that claim is linked to. The Executive Director or Director of Operations will then run a report that will show them the open bills and remit payment based off of that report. Because of how the site is linked to QuickBooks, it will remove the possibility of paying the incorrect organization.

About Cash Management →
2020-005
Cash Management

FINDING REFERENCE NUMBER 2020-005 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted one instance in which the Organization retained an administrative fee that differed from the administrative fee documented in the Sponsor Agreement between the Organization and the subrecipient. In addition, the auditor noted six discrepancies in two payment spreadsheets out of fifty payment spreadsheets tested in which subrecipient reimbursement amounts and administrative fee amounts to be retained by the Organization were incorrectly calculated. Criteria or Specific Requirement The administrative fee noted in the Sponsor Agreement should agree to the administrative fee retained by the Organization when processing the reimbursement to the subrecipients. In addition, the amount to be reimbursed to subrecipients should be the amount of the claim, less cash in lieu meals, less the administrative fee, outlined in the Sponsor Agreement, to be retained by the Organization. Questioned Costs Not applicable. Effect Regarding the first instance noted, the Organization ultimately retained the correct administrative fee, despite the re-negotiated administrative fee failing to be appropriately documented in the Sponsor Agreement. In the second instance noted, the Organization underpaid the subrecipient by $10,024, resulting in the Organization not complying with the cash management requirements established by the Federal Agency. Cause The Organization re-negotiated the administrative fee percentage in the Sponsor Agreement with the site subsequent to the initial signing of the agreement. However, the date that the re-negotiated fee percentage went into effect was not clearly documented. The Organization maintains spreadsheets to track batch claims submitted to the MDE for multiple subrecipient sites for certain time periods. The spreadsheets include the sites to be reimbursed, and the respective claim amounts, cash in lieu amounts, dollar amounts of the administrative fee to be retained by the Organization, and the net amounts to be reimbursed to the subrecipients. The spreadsheet includes formulas to determine the administrative fee portion and the reimbursement portion. For the six instances noted, the amounts in the spreadsheet were erroneously hardcoded as opposed to calculated by formula. Recommendation A new Sponsor Agreement should be signed when there are amendments to the agreement and the effective date of the agreement should be clearly documented. In addition, the Organization should review payment spreadsheets for formula errors before the reimbursements are processed. Views of Responsible Officials and Corrective Action Plan The Organization is currently in the process of updating all sponsor agreements with our programs. The updated Sponsor Agreements will clearly document the agreed upon administrative fee percentage. The Organization will begin utilizing My Food Program and its Claims Payment feature. The My Food Program feature allows users to enter the claiming percentage at ten or fifteen percent based upon the Sponsor Agreement. This feature will replace the Claims Spreadsheet and will remove the possibility of any spreadsheet errors.

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Full finding narrative

FINDING REFERENCE NUMBER 2020-005 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted one instance in which the Organization retained an administrative fee that differed from the administrative fee documented in the Sponsor Agreement between the Organization and the subrecipient. In addition, the auditor noted six discrepancies in two payment spreadsheets out of fifty payment spreadsheets tested in which subrecipient reimbursement amounts and administrative fee amounts to be retained by the Organization were incorrectly calculated. Criteria or Specific Requirement The administrative fee noted in the Sponsor Agreement should agree to the administrative fee retained by the Organization when processing the reimbursement to the subrecipients. In addition, the amount to be reimbursed to subrecipients should be the amount of the claim, less cash in lieu meals, less the administrative fee, outlined in the Sponsor Agreement, to be retained by the Organization. Questioned Costs Not applicable. Effect Regarding the first instance noted, the Organization ultimately retained the correct administrative fee, despite the re-negotiated administrative fee failing to be appropriately documented in the Sponsor Agreement. In the second instance noted, the Organization underpaid the subrecipient by $10,024, resulting in the Organization not complying with the cash management requirements established by the Federal Agency. Cause The Organization re-negotiated the administrative fee percentage in the Sponsor Agreement with the site subsequent to the initial signing of the agreement. However, the date that the re-negotiated fee percentage went into effect was not clearly documented. The Organization maintains spreadsheets to track batch claims submitted to the MDE for multiple subrecipient sites for certain time periods. The spreadsheets include the sites to be reimbursed, and the respective claim amounts, cash in lieu amounts, dollar amounts of the administrative fee to be retained by the Organization, and the net amounts to be reimbursed to the subrecipients. The spreadsheet includes formulas to determine the administrative fee portion and the reimbursement portion. For the six instances noted, the amounts in the spreadsheet were erroneously hardcoded as opposed to calculated by formula. Recommendation A new Sponsor Agreement should be signed when there are amendments to the agreement and the effective date of the agreement should be clearly documented. In addition, the Organization should review payment spreadsheets for formula errors before the reimbursements are processed. Views of Responsible Officials and Corrective Action Plan The Organization is currently in the process of updating all sponsor agreements with our programs. The updated Sponsor Agreements will clearly document the agreed upon administrative fee percentage. The Organization will begin utilizing My Food Program and its Claims Payment feature. The My Food Program feature allows users to enter the claiming percentage at ten or fifteen percent based upon the Sponsor Agreement. This feature will replace the Claims Spreadsheet and will remove the possibility of any spreadsheet errors.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-005 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency The Organization is currently in the process of updating all sponsor agreements with our programs. The updated Sponsor Agreements will clearly document the agreed upon administrative fee percentage. The Organization will begin utilizing My Food Program and its Claims Payment feature. The My Food Program feature allows users to enter the claiming percentage at ten or fifteen percent based upon the Sponsor Agreement. This feature will replace the Claims Spreadsheet and will remove the possibility of any spreadsheet errors.

About Cash Management →
2020-006
Cash Management

FINDING REFERENCE NUMBER 2020-006 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted that federal funds received in excess of funds expended were not communicated to MDE. Criteria or Specific Requirement For CACFP, the Organization was allowed to retain three months of excess federal funds received, which were restricted for future use in a Child Nutrition Program, with the remainder subject to recoupment by MDE. For SFSP, the Organization was allowed to retain all excess funds received, which were also restricted for future use in a Child Nutrition Program. Questioned Costs Not applicable. Effect The Organization did not comply with the cash management requirements established by the Federal Agency. Cause The Organization failed to track and report excess federal funds received to MDE. Recommendation The Organization should track federal funds received in excess of funds expended on a cumulative basis and communicate the excess to MDE at least annually. Views of Responsible Officials and Corrective Action Plan In connection with the response to Finding Reference Number 2020-002, The Organization will be checking in with our audit firm monthly to confirm that compliance with federal reporting requirements will be met. When the audit is completed in a timely manner, The Organization will be able to communicate any excess funding to MDE. The Organization will then work with MDE to determine if the excess funding should be remitted back or how it can be spent down appropriately.

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FINDING REFERENCE NUMBER 2020-006 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition The auditor noted that federal funds received in excess of funds expended were not communicated to MDE. Criteria or Specific Requirement For CACFP, the Organization was allowed to retain three months of excess federal funds received, which were restricted for future use in a Child Nutrition Program, with the remainder subject to recoupment by MDE. For SFSP, the Organization was allowed to retain all excess funds received, which were also restricted for future use in a Child Nutrition Program. Questioned Costs Not applicable. Effect The Organization did not comply with the cash management requirements established by the Federal Agency. Cause The Organization failed to track and report excess federal funds received to MDE. Recommendation The Organization should track federal funds received in excess of funds expended on a cumulative basis and communicate the excess to MDE at least annually. Views of Responsible Officials and Corrective Action Plan In connection with the response to Finding Reference Number 2020-002, The Organization will be checking in with our audit firm monthly to confirm that compliance with federal reporting requirements will be met. When the audit is completed in a timely manner, The Organization will be able to communicate any excess funding to MDE. The Organization will then work with MDE to determine if the excess funding should be remitted back or how it can be spent down appropriately.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-006 FEDERAL PROGRAM Child and Adult Care Food Program and Summer Food Service Program COMPLIANCE REQUIREMENT Cash Management TYPE OF FINDING Noncompliance and Internal Control Deficiency In connection with the response to Finding Reference Number 2020-002, The Organization will be checking in with our audit firm monthly to confirm that compliance with federal reporting requirements will be met. When the audit is completed in a timely manner, The Organization will be able to communicate any excess funding to MDE. The Organization will then work with MDE to determine if the excess funding should be remitted back or how it can be spent down appropriately.

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2020-007
Subrecipient Monitoring

FINDING REFERENCE NUMBER 2020-007 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition During the audit procedures, the auditor noted that there was one instance out of forty CACFP claims selected in which training forms for a site could not be provided and the site monitoring form indicated that the training logs on file at the site was expired. In addition, the auditor noted fourteen instances out of forty CACFP claims tested in which the Organization could not provide signed training logs. However, the Organization was able to confirm that training logs were reviewed during site visits as noted in the sites? monitoring forms. Criteria or Specific Requirement CACFP sponsors are required to ensure that sites are completing CACFP training at least once a year. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause The Organization failed to track expirations of site trainings and site monitors failed to maintain documentation of training logs. Recommendation The Organization should maintain copies of signed training logs and keep track of expirations of trainings to ensure that subrecipients are receiving CACFP training at least annually. Views of Responsible Officials and Corrective Action Plan Trainings dates will be documented in My Food Program as training logs are received. If no training log is received for a site, the My Food Program dashboard will alert the program and Organization staff that training is not completed. The Claims Director will notify Site Support employees monthly if there are expired or missing trainings. Claims will not get processed for any site with expired or missing training logs.

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FINDING REFERENCE NUMBER 2020-007 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Noncompliance and Internal Control Deficiency Statement of Condition During the audit procedures, the auditor noted that there was one instance out of forty CACFP claims selected in which training forms for a site could not be provided and the site monitoring form indicated that the training logs on file at the site was expired. In addition, the auditor noted fourteen instances out of forty CACFP claims tested in which the Organization could not provide signed training logs. However, the Organization was able to confirm that training logs were reviewed during site visits as noted in the sites? monitoring forms. Criteria or Specific Requirement CACFP sponsors are required to ensure that sites are completing CACFP training at least once a year. Questioned Costs Not applicable. Effect The Organization did not comply with the subrecipient monitoring requirements established by the Federal Agency. Cause The Organization failed to track expirations of site trainings and site monitors failed to maintain documentation of training logs. Recommendation The Organization should maintain copies of signed training logs and keep track of expirations of trainings to ensure that subrecipients are receiving CACFP training at least annually. Views of Responsible Officials and Corrective Action Plan Trainings dates will be documented in My Food Program as training logs are received. If no training log is received for a site, the My Food Program dashboard will alert the program and Organization staff that training is not completed. The Claims Director will notify Site Support employees monthly if there are expired or missing trainings. Claims will not get processed for any site with expired or missing training logs.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-007 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Subrecipient Monitoring TYPE OF FINDING Noncompliance and Internal Control Deficiency Trainings dates will be documented in My Food Program as training logs are received. If no training log is received for a site, the My Food Program dashboard will alert the program and Organization staff that training is not completed. The Claims Director will notify Site Support employees monthly if there are expired or missing trainings. Claims will not get processed for any site with expired or missing training logs.

About Subrecipient Monitoring →
2020-008
Procurement & Suspension/Debarment

FINDING REFERENCE NUMBER 2020-008 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Procurement and Suspension and Debarment TYPE OF FINDING Noncompliance Statement of Condition The auditor noted that the Organization reviewed the names of responsible individuals at the subrecipient sites against the National Disqualification List upon signing of the Sponsor Agreement to ensure that responsible individuals were not debarred or suspended from participating in CACFP. However, the Organization did not review the list regularly after that point to ensure subrecipients were not subsequently added to the list. In addition, the Organization did not formally document the review of the National Disqualification List, including who performed the review with a proper sign off and date. Criteria or Specific Requirement The National Disqualification List should be reviewed upon the annual renewal of the contract between the Organization and the subrecipient. Questioned Costs Not applicable. Effect The Organization did not comply with the suspension and debarment requirements established by the Federal Agency. Cause The Organization did not comply with the suspension and debarment requirements due to a misunderstanding of program requirements. Recommendation The Organization should review the names of responsible individuals at the subrecipient sites against the National Disqualification List at least annually. In addition, the Organization should formally document who performed the review and when. Views of Responsible Officials and Corrective Action Plan Every fiscal year, each program will be required to complete an updated Site Information form. Using the information provided, the names will be checked against the National Disqualified List. Additionally, if there are any key staff changes throughout the year, a new Site Information form will be completed, and the updated information will be checked against the National Disqualified List. The review of the National Disqualified List will be documented in My Food Program under the Staff tab in the Notes section. It will include the date the review was performed and the signature of who completed the review.

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FINDING REFERENCE NUMBER 2020-008 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Procurement and Suspension and Debarment TYPE OF FINDING Noncompliance Statement of Condition The auditor noted that the Organization reviewed the names of responsible individuals at the subrecipient sites against the National Disqualification List upon signing of the Sponsor Agreement to ensure that responsible individuals were not debarred or suspended from participating in CACFP. However, the Organization did not review the list regularly after that point to ensure subrecipients were not subsequently added to the list. In addition, the Organization did not formally document the review of the National Disqualification List, including who performed the review with a proper sign off and date. Criteria or Specific Requirement The National Disqualification List should be reviewed upon the annual renewal of the contract between the Organization and the subrecipient. Questioned Costs Not applicable. Effect The Organization did not comply with the suspension and debarment requirements established by the Federal Agency. Cause The Organization did not comply with the suspension and debarment requirements due to a misunderstanding of program requirements. Recommendation The Organization should review the names of responsible individuals at the subrecipient sites against the National Disqualification List at least annually. In addition, the Organization should formally document who performed the review and when. Views of Responsible Officials and Corrective Action Plan Every fiscal year, each program will be required to complete an updated Site Information form. Using the information provided, the names will be checked against the National Disqualified List. Additionally, if there are any key staff changes throughout the year, a new Site Information form will be completed, and the updated information will be checked against the National Disqualified List. The review of the National Disqualified List will be documented in My Food Program under the Staff tab in the Notes section. It will include the date the review was performed and the signature of who completed the review.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-008 FEDERAL PROGRAM Child and Adult Care Food Program COMPLIANCE REQUIREMENT Procurement and Suspension and Debarment TYPE OF FINDING Noncompliance Every fiscal year, each program will be required to complete an updated Site Information form. Using the information provided, the names will be checked against the National Disqualified List. Additionally, if there are any key staff changes throughout the year, a new Site Information form will be completed, and the updated information will be checked against the National Disqualified List. The review of the National Disqualified List will be documented in My Food Program under the Staff tab in the Notes section. It will include the date the review was performed and the signature of who completed the review.

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2020-009
Eligibility

FINDING REFERENCE NUMBER 2020-009 FEDERAL PROGRAM Summer Food Service Program COMPLIANCE REQUIREMENT Eligibility TYPE OF FINDING Noncompliance Statement of Condition The auditor noted one instance out of thirteen SFSP vendors tested in which the Organization could not provide a copy of the food and beverage license and food manager certificate for a SFSP vendor. Criteria or Specific Requirement Documentation of vendor eligibility of Summer Food Service Program vendors must be documented and maintained. Questioned Costs Not applicable. Refer to explanation under ?Cause? below. Effect The Organization did not comply with the eligibility requirements established by the Federal Agency. Cause The Organization?s inability to provide the requested documents is due to documentation being lost during a conversion to a new data storage software. Recommendation The Organization should implement controls to ensure that data is backed up onto a server in order to protect against the loss of data. Views of Responsible Officials and Corrective Action Plan The Organization is using Coordinated Business Systems as an IT consultant. The Organization?s data is backed up on the cloud in order to protect against the loss of data. The Organization is also in the process of completing a folder audit to ensure that all paper documents are saved in the corresponding electronic file.

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FINDING REFERENCE NUMBER 2020-009 FEDERAL PROGRAM Summer Food Service Program COMPLIANCE REQUIREMENT Eligibility TYPE OF FINDING Noncompliance Statement of Condition The auditor noted one instance out of thirteen SFSP vendors tested in which the Organization could not provide a copy of the food and beverage license and food manager certificate for a SFSP vendor. Criteria or Specific Requirement Documentation of vendor eligibility of Summer Food Service Program vendors must be documented and maintained. Questioned Costs Not applicable. Refer to explanation under ?Cause? below. Effect The Organization did not comply with the eligibility requirements established by the Federal Agency. Cause The Organization?s inability to provide the requested documents is due to documentation being lost during a conversion to a new data storage software. Recommendation The Organization should implement controls to ensure that data is backed up onto a server in order to protect against the loss of data. Views of Responsible Officials and Corrective Action Plan The Organization is using Coordinated Business Systems as an IT consultant. The Organization?s data is backed up on the cloud in order to protect against the loss of data. The Organization is also in the process of completing a folder audit to ensure that all paper documents are saved in the corresponding electronic file.

Corrective Action Plan

FINDING REFERENCE NUMBER 2020-009 FEDERAL PROGRAM Summer Food Service Program COMPLIANCE REQUIREMENT Eligibility TYPE OF FINDING Noncompliance The Organization is using Coordinated Business Systems as an IT consultant. The Organization?s data is backed up on the cloud in order to protect against the loss of data. The Organization is also in the process of completing a folder audit to ensure that all paper documents are saved in the corresponding electronic file.

About Eligibility →

FY 2019-09-30

FAC accepted this audit on December 27, 2020 — management decision was due June 27, 2021.

2019-001
Cost Allowability
MATERIAL WEAKNESSREPEAT

Condition and Perspective Information: The Organization did not have supporting timesheets for all four tested months of 2019 payroll periods and some timesheets were missing or did not agree to salary cost allocations worksheets used to record the underlying transactions. The Organization used allocations that were not supported by actual results. Criteria: Allowable payroll costs are to be supported by detailed payroll records and allocations are supported by actual results. Cause: The previous accountant was not always properly ensuring the timesheets agreed to the salary cost allocations. Estimates were made in some cases that the accountant believed to be fair estimates of actual results. Effect: Noncompliance with Allowable Cost criteria. Questioned Costs: Unknown. Repeated Finding: Yes. Recommendation: The Organization should maintain adequate support of payroll charges and base allocations on actual results. Views of responsible officials of the auditee: There is no disagreement with the audit finding. Summary of Corrective Action Plan: Since discovering that the previous accountant was not appropriately following the procedures that were adopted in the previous year?s finding, the Organization is taking immediate steps to verify that all timesheets agree to cost allocation worksheets and those worksheets are used to charge costs to the program.

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Full finding narrative

Condition and Perspective Information: The Organization did not have supporting timesheets for all four tested months of 2019 payroll periods and some timesheets were missing or did not agree to salary cost allocations worksheets used to record the underlying transactions. The Organization used allocations that were not supported by actual results. Criteria: Allowable payroll costs are to be supported by detailed payroll records and allocations are supported by actual results. Cause: The previous accountant was not always properly ensuring the timesheets agreed to the salary cost allocations. Estimates were made in some cases that the accountant believed to be fair estimates of actual results. Effect: Noncompliance with Allowable Cost criteria. Questioned Costs: Unknown. Repeated Finding: Yes. Recommendation: The Organization should maintain adequate support of payroll charges and base allocations on actual results. Views of responsible officials of the auditee: There is no disagreement with the audit finding. Summary of Corrective Action Plan: Since discovering that the previous accountant was not appropriately following the procedures that were adopted in the previous year?s finding, the Organization is taking immediate steps to verify that all timesheets agree to cost allocation worksheets and those worksheets are used to charge costs to the program.

Corrective Action Plan

Name of Contact Person Responsible for Corrective Action: Kara Lomen, Executive Director Corrective Action Planned: The Organization is taking immediate steps to verify that all timesheets agree to cost allocation worksheets and those worksheets are used to charge costs to the program. Anticipated Completion Date: These procedures will be implemented immediately.

Prior Finding References

2018-001

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FY 2018-12-31

FAC accepted this audit on April 9, 2019 — management decision was due October 9, 2019.

2018-001
Cost Allowability
MATERIAL WEAKNESSREPEAT

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

Prior Finding References

2017-001

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2018-002
Eligibility
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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FY 2017-09-30

FAC accepted this audit on August 21, 2018 — management decision was due February 21, 2019.

2017-001
Cost Allowability
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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2017-002
Reporting
MATERIAL WEAKNESS

GSA_MIGRATION

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GSA_MIGRATION

Corrective Action Plan

GSA_MIGRATION

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