EIN: 742122979
UEI: MNH2R27KRAX4
Data as of August 22, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 29, 2022. 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 March 29, 2023 (1243 days ago).
What is a management decision? →To ensure compliance with the latter part of the criteria noted above (i.e., ?and must enter into a written agreement?) the policy and control procedures of the Food Bank require each entity sign an application which serves as the written agreement. The application must be signed by a representative of the subrecipient entity and be reviewed by the Food Bank?s supervisory personnel. Control procedures also require the completion of an Agency Audit File Checklist that is also reviewed by the Food Bank?s supervisory personnel. The results from our procedures over the required applications revealed that one application was not signed by the subrecipient. We also noted that four Agency Audit File Checklist?s were completed several months subsequent to the completion of the application process for the subrecipient. Cause: Control procedures in place did not function as designed or failed to ensure accurate, timely and complete records, which support the Food Bank?s compliance with the criteria above, were maintained and available for the period under audit. Effect: Not maintaining accurate and complete records increases the risk that subrecipient entities receiving food commodities do not meet eligibility requirements. Questioned costs: None known. Context: Context 17-application?s selected for review: ? 1 application was not signed by the subrecipient Context over 17 Agency Audit File Checklists selected for review: ? 4 checklists were reviewed and dated over four months subsequent to the last completed application date. Repeat finding: Yes Recommendation: We recommend management review and revise control procedures in place to ensure they are functioning as designed. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-002?Eligibility (Subrecipients) Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2020, 2021 Type of Finding: Significant Deficiency Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect om each of its federal programs. Per 7 CFR sections 247.4, 247.7(a), 251.3(d), and 251.5(a), the Food Bank must ensure a recipient agency must be either a public agency or a private entity possessing tax-exempt status under the Internal Revenue Code and must enter into a written agreement with the state agency, or with another recipient agency where permitted, binding it to perform the duties of a recipient agency. Condition: To ensure compliance with the latter part of the criteria noted above (i.e., ?and must enter into a written agreement?) the policy and control procedures of the Food Bank require each entity sign an application which serves as the written agreement. The application must be signed by a representative of the subrecipient entity and be reviewed by the Food Bank?s supervisory personnel. Control procedures also require the completion of an Agency Audit File Checklist that is also reviewed by the Food Bank?s supervisory personnel. The results from our procedures over the required applications revealed that one application was not signed by the subrecipient. We also noted that four Agency Audit File Checklist?s were completed several months subsequent to the completion of the application process for the subrecipient. Cause: Control procedures in place did not function as designed or failed to ensure accurate, timely and complete records, which support the Food Bank?s compliance with the criteria above, were maintained and available for the period under audit. Effect: Not maintaining accurate and complete records increases the risk that subrecipient entities receiving food commodities do not meet eligibility requirements. Questioned costs: None known. Context: Context 17-application?s selected for review: ? 1 application was not signed by the subrecipient Context over 17 Agency Audit File Checklists selected for review: ? 4 checklists were reviewed and dated over four months subsequent to the last completed application date. Repeat finding: Yes Recommendation: We recommend management review and revise control procedures in place to ensure they are functioning as designed. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action ? In accordance with 2 CFR 200.303, the Food Bank has evaluated and implemented a compliance process that ensures client eligibility is verified and deemed eligible to receive benefits. The compliance coordinator is responsible to accepting and reviewing each application with specific attention to client?s date of birth, income, household size, and verification signature. Individual(s) Responsible ?? Melanie McGuire, Chief Programs Officer, Erica Gonzales, Director of Food for Today Anticipated Date of Completion ? December 31, 2022
2020-003
We selected seventeen subrecipients that received subawards during the fiscal year and noted the Food Bank did not retain documentation to support that suspension and debarment was verified for two of the subrecipients. In addition, we noted three instances in which the Food Bank obtained suspension and debarment documentation, however it was subsequent to year-end. Cause: Control procedures did not function as designed and thus the suspension and debarment support was not performed timely or retained. Effect: Not performing the suspension and debarment process increases the risk of noncompliance with rules and regulations and increases the risk that a subrecipient may be suspended and debarred. Questioned costs: None known. Context: We selected seventeen subrecipients and noted five did not have support that suspension and debarment was verified during the fiscal year before the transactions was completed. Of the five, three had suspension and debarment verified subsequent to year-end. Repeat finding: Yes Recommendation: We recommend management implement controls procedures that require verification, before a transaction is complete, that subrecipients are not suspended or debarred. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-003? Procurement, Suspension and Debarment Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2020, 2021 Type of Finding: Significant Deficiency and Noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transactions, regardless of amount, and meet certain other criteria as specified in 2 CFR section 180.220. Condition: We selected seventeen subrecipients that received subawards during the fiscal year and noted the Food Bank did not retain documentation to support that suspension and debarment was verified for two of the subrecipients. In addition, we noted three instances in which the Food Bank obtained suspension and debarment documentation, however it was subsequent to year-end. Cause: Control procedures did not function as designed and thus the suspension and debarment support was not performed timely or retained. Effect: Not performing the suspension and debarment process increases the risk of noncompliance with rules and regulations and increases the risk that a subrecipient may be suspended and debarred. Questioned costs: None known. Context: We selected seventeen subrecipients and noted five did not have support that suspension and debarment was verified during the fiscal year before the transactions was completed. Of the five, three had suspension and debarment verified subsequent to year-end. Repeat finding: Yes Recommendation: We recommend management implement controls procedures that require verification, before a transaction is complete, that subrecipients are not suspended or debarred. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action ? The SAFB will re-train staff on how to utilize SAM to verify suspension and debarment status. Training will focus on each aspect of the audit checklist implemented by the compliance team. Individual(s) Responsible ?? Melanie McGuire, Chief Programs Officer, Erica Gonzales, Director of Food for Today Anticipated Date of Completion ? December 31, 2022
2020-005
We selected twenty-five individuals and determined one individual?s income exceeded the 130% poverty guidelines and therefore was ineligible to participate in the CSFP. Cause: Control procedures did not function as designed in the application process. Effect: Not reviewing the application in comparison to the 130% federal poverty guidelines increased the risk that an applicant would not be eligible to participate in the program. Questioned costs: None known. Context: We selected twenty-five participants and noted one was not eligible to participate in the program. Repeat finding: No Recommendation: We recommend management implement an process that requires and ensures each applicant is eligible to receive benefits. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-004?Eligibility (Individuals) Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2021 Type of Finding: Significant Deficiency and Noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. In order to participate in the Commodity Supplemental Food Program (CSFP), applicants must be at least 130% of federal poverty guidelines and elderly. Condition: We selected twenty-five individuals and determined one individual?s income exceeded the 130% poverty guidelines and therefore was ineligible to participate in the CSFP. Cause: Control procedures did not function as designed in the application process. Effect: Not reviewing the application in comparison to the 130% federal poverty guidelines increased the risk that an applicant would not be eligible to participate in the program. Questioned costs: None known. Context: We selected twenty-five participants and noted one was not eligible to participate in the program. Repeat finding: No Recommendation: We recommend management implement an process that requires and ensures each applicant is eligible to receive benefits. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action ? In accordance with 2 CFR 200.303, the Food Bank has evaluated and implemented a compliance process that ensures client eligibility is verified and deemed eligible to receive benefits. The compliance coordinator is responsible to accepting and reviewing each application with specific attention to client?s date of birth, income, household size, and verification signature. Individual(s) Responsible ?? Melanie McGuire, Chief Programs Officer, Erica Gonzales, Director of Food for Today Anticipated Date of Completion ? December 31, 2022
We selected sixty mobile distribution participants and noted one individual was ineligible to participate in the program, one individual did not provide income information in order to determine if participant was eligible and fifty-one selections did not have adequate support of review and approvals as required by the control. Cause: Control procedures in place did not function as designed to ensure accurate and complete records were reviewed and maintained. Effect: Not maintaining accurate and complete records increases the risk that an individual receiving food commodities does not meet eligibility requirements. Questioned costs: None known. Context: We selected sixty participants and noted one individual was improperly deemed to be eligible to receive USDA benefits, one individual had no income to support eligibility and fifty-one individuals did not have adequate support of review an approval for eligibility. Repeat finding: Yes Recommendation: We recommend management develop a process which requires and ensures accurate and complete records of food distribution and eligibility determinations be maintained and readily available. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-005?Eligibility (Individuals) Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2020, 2021 Type of Finding: Material Weakness and Noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Per 7 CFR 251.5 (b), the Food Bank must ensure eligibility of households receiving USDA Foods is met by using criteria established by the Texas Department of Agriculture. Uniform Guidance 7 CFR 250.19 requires that distributing agencies must maintain accurate and complete records with respect to the distribution of USDA foods. In order to participate in the mobile distribution, applicants must be at least 185% of federal poverty guidelines. Condition: We selected sixty mobile distribution participants and noted one individual was ineligible to participate in the program, one individual did not provide income information in order to determine if participant was eligible and fifty-one selections did not have adequate support of review and approvals as required by the control. Cause: Control procedures in place did not function as designed to ensure accurate and complete records were reviewed and maintained. Effect: Not maintaining accurate and complete records increases the risk that an individual receiving food commodities does not meet eligibility requirements. Questioned costs: None known. Context: We selected sixty participants and noted one individual was improperly deemed to be eligible to receive USDA benefits, one individual had no income to support eligibility and fifty-one individuals did not have adequate support of review an approval for eligibility. Repeat finding: Yes Recommendation: We recommend management develop a process which requires and ensures accurate and complete records of food distribution and eligibility determinations be maintained and readily available. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action ? In accordance with 2 CFR 200.303, the Food Bank has evaluated and implemented a compliance process that ensures client eligibility is verified and deemed eligible to receive benefits. The compliance coordinator is responsible to accepting and reviewing each application with specific attention to client?s date of birth, income, household size, and verification signature. Individual(s) Responsible ?? Melanie McGuire, Chief Programs Officer, Erica Gonzales, Director of Food for Today Anticipated Date of Completion ? December 31, 2022
2020-002
During our testing, we noted the Food Bank did not obtain informal price or rate quotations for one small purchase. In addition, the Food Bank provided support for the reasonableness of the price for a micro-purchase, however, there?s no formal process in place to document the Food Bank?s rationale for micro-purchases. Cause: Control procedures did not function as designed and thus compliance with procurement requirements was not followed and/or properly documented. Effect: Not performing or documenting the procurement process required increases the risk of noncompliance with rules and regulations described in the criteria above. Questioned costs: None known Context: We selected two transactions to test micro-purchases and two transactions to test small purchases and noted there was no informal price or rate quotations obtained for one small purchase and noted there?s no formal process in place to document the Food Bank?s rationale for micro-purchases. Repeat finding: Yes Recommendation: We recommend management review, revise, and test current control procedures and make any necessary changes to ensure compliance with criteria above. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2021-006? Procurement SNAP Cluster Assistance Listing No.10.561 Federal Award Number: 529-16-0002-00001 Federal Award Year: 2020, 2021 Type of Finding: Material Weakness and Noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: During our testing, we noted the Food Bank did not obtain informal price or rate quotations for one small purchase. In addition, the Food Bank provided support for the reasonableness of the price for a micro-purchase, however, there?s no formal process in place to document the Food Bank?s rationale for micro-purchases. Cause: Control procedures did not function as designed and thus compliance with procurement requirements was not followed and/or properly documented. Effect: Not performing or documenting the procurement process required increases the risk of noncompliance with rules and regulations described in the criteria above. Questioned costs: None known Context: We selected two transactions to test micro-purchases and two transactions to test small purchases and noted there was no informal price or rate quotations obtained for one small purchase and noted there?s no formal process in place to document the Food Bank?s rationale for micro-purchases. Repeat finding: Yes Recommendation: We recommend management review, revise, and test current control procedures and make any necessary changes to ensure compliance with criteria above. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - The Food Bank will create a log of all micro purchases related to federal funds that clearly identifies the steps taken prior to procuring the goods and/or services. The procurement manager will identify the appropriate staff and coordinate a re-training of the process. The steps taken may be documented as emergency purchases, informal price comparison, product shortage, etc. Individual(s) Responsible ? George Cox, Procurement Manager ? Natalie Rendon, Procurement Analyst Anticipated Date of Completion ? November 30, 2022
2020-006
FAC accepted this audit on June 29, 2021 — management decision was due December 29, 2021.
The Food Bank did not maintain adequate records to support individual eligibility. Cause: Control procedures in place did not function as designed to ensure accurate and complete records were maintained throughout the year. These records are necessary to demonstrate the Food Bank complied with the criteria described above. Effect: Not maintaining accurate and complete records increases the risk that an individual receiving food commodities does not meet eligibility requirements. Questioned costs: $167,348 (total from the three sites where support was not available) Context: The Food Bank maintains a listing of agencies and dates in which mobile pantry food commodities are distributed. We selected a total of nine agencies and noted three did not have support for the individuals that received mobile pantry food commodities during the date selected and therefore no samples were tested from these sites. We could only select thirty-six (of the required sample size of 40) individuals to test from sites where a population was available; based on this sample, we noted one individual was improperly deemed to be eligible to receive USDA benefits. For the three-sites where support was not available, we could not test to determine if the Food Bank was in compliance with the criteria noted above. Repeat finding: No Recommendation: We recommend management develop a process which requires and ensures accurate and complete records of food distribution and eligibility determinations be maintained and readily available. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-002?Eligibility (Individuals) Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2019, 2020 Type of Finding: Material weakness and material instance of noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Per 7 CFR 251.5 (b), the Food Bank must ensure eligibility of households receiving USDA Foods is met by using criteria established by the Texas Department of Agriculture. Uniform Guidance 7 CFR 250.19 requires that distributing agencies must maintain accurate and complete records with respect to the distribution of USDA foods. Condition: The Food Bank did not maintain adequate records to support individual eligibility. Cause: Control procedures in place did not function as designed to ensure accurate and complete records were maintained throughout the year. These records are necessary to demonstrate the Food Bank complied with the criteria described above. Effect: Not maintaining accurate and complete records increases the risk that an individual receiving food commodities does not meet eligibility requirements. Questioned costs: $167,348 (total from the three sites where support was not available) Context: The Food Bank maintains a listing of agencies and dates in which mobile pantry food commodities are distributed. We selected a total of nine agencies and noted three did not have support for the individuals that received mobile pantry food commodities during the date selected and therefore no samples were tested from these sites. We could only select thirty-six (of the required sample size of 40) individuals to test from sites where a population was available; based on this sample, we noted one individual was improperly deemed to be eligible to receive USDA benefits. For the three-sites where support was not available, we could not test to determine if the Food Bank was in compliance with the criteria noted above. Repeat finding: No Recommendation: We recommend management develop a process which requires and ensures accurate and complete records of food distribution and eligibility determinations be maintained and readily available. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - The Community Partner team continues to complete site visits and as part of the site visit will review the intakes and provide feedback as necessary along with follow up deadline dates if the partner is missing or needs to provide information. The community partner team conducts annual site visits for all agencies, despite being a TEFAP site or not. Per Feeding America guidelines, partner site visits are to be conducted every two years; however, to ensure accuracy and maintaining quality communication with partners, site visits are conducted annually. SAFB is now utilizing Fresh Trak, so for any individual whose information has been captured in Qualtrics, if their profile is incomplete will be checked and completed using FreshTrak prior to receipt of food. This information also allows for the data insights team to analyze and assess areas of need or improvement where food insecurity is not yet addressed.We reported to TDA will only be using H1555. We are constructing a process that if a modified form is desired by a partner agency, that they will need to submit to SAFB for approval prior to usage. This also pertains to our pop-up market partners that have monthly reporting and documentation to provide after a distribution. Agencies must return COVID rosters and/or intakes to SAFB within 3 days of distribution. If not received, there is the potential for these distributions to be temporary paused. This is also explained in the Pop-Up Market MOU. Community Partner team has implemented ongoing monthly calls were a variety of topics are discussed to ensure compliance. Team has addressed client intakes in October 2020, December 2020, and then again in April 2020 and provided a document with guidance on how to complete the intakes. After each call for partners who were not able to participate in live virtual call, the training slides and any additional documents are emailed out to the partners. Individual(s) Responsible- Melanie McGuire, CPO- Jessica Molinar, Compliance Manager Anticipated Date of Completion- 6/30/2021
To ensure compliance with the latter part of the criteria noted above (i.e., ?and must enter into a written agreement?) the policy and control procedures of the Food Bank require each entity sign an application which serves as the written agreement. The application must be signed by a representative of the subrecipient entity and be reviewed by the Food Bank?s supervisory personnel. Control procedures also require the completion of an Agency Audit File Checklist that is also reviewed by the Food Bank?s supervisory personnel. The results from our procedures over the required applications revealed that application was either not available, was incomplete, or was not dated within the audit period. We also noted the Agency Audit File Checklist was either not signed off appropriately, or was dated outside the audit period. Cause: Control procedures in place did not function as designed or failed to ensure accurate and complete records, which support the Food Bank?s compliance with the criteria above, were maintained and available for the period under audit. Effect: Not maintaining accurate and complete records increases the risk that subrecipient entities receiving food commodities do not meet eligibility requirements. Questioned costs: None known. Context: Context over 60-applications selected for review: ? 7 applications could not be located ? 6 applications were incomplete ? 12 applications obtained were dated subsequent to June 30, 2020. There were no applications available that applied to the period under audit. Context over 25 Agency Audit File Checklist selected for review: ? 1 checklist was not signed off by the Food Bank supervisory personnel. ? 8 checklists were dated subsequent to June 30, 2020. There were no checklists available that applied to the period under audit. ? 5 checklists were dated 2018 or prior. Management completed checklist subsequent to year-end. Repeat finding: No Recommendation: We recommend management review and revise control procedures in place to ensure they are functioning as designed. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-003?Eligibility (Subrecipients) Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2019, 2020 Type of Finding: Material weakness and material instance of noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect om each of its federal programs. Per 7 CFR sections 247.4, 247.7(a), 251.3(d), and 251.5(a), the Food Bank must ensure a recipient agency must be either a public agency or a private entity possessing tax-exempt status under the Internal Revenue Code and must enter into a written agreement with the state agency, or with another recipient agency where permitted, binding it to perform the duties of a recipient agency. Condition: To ensure compliance with the latter part of the criteria noted above (i.e., ?and must enter into a written agreement?) the policy and control procedures of the Food Bank require each entity sign an application which serves as the written agreement. The application must be signed by a representative of the subrecipient entity and be reviewed by the Food Bank?s supervisory personnel. Control procedures also require the completion of an Agency Audit File Checklist that is also reviewed by the Food Bank?s supervisory personnel. The results from our procedures over the required applications revealed that application was either not available, was incomplete, or was not dated within the audit period. We also noted the Agency Audit File Checklist was either not signed off appropriately, or was dated outside the audit period. Cause: Control procedures in place did not function as designed or failed to ensure accurate and complete records, which support the Food Bank?s compliance with the criteria above, were maintained and available for the period under audit. Effect: Not maintaining accurate and complete records increases the risk that subrecipient entities receiving food commodities do not meet eligibility requirements. Questioned costs: None known. Context: Context over 60-applications selected for review: ? 7 applications could not be located ? 6 applications were incomplete ? 12 applications obtained were dated subsequent to June 30, 2020. There were no applications available that applied to the period under audit. Context over 25 Agency Audit File Checklist selected for review: ? 1 checklist was not signed off by the Food Bank supervisory personnel. ? 8 checklists were dated subsequent to June 30, 2020. There were no checklists available that applied to the period under audit. ? 5 checklists were dated 2018 or prior. Management completed checklist subsequent to year-end. Repeat finding: No Recommendation: We recommend management review and revise control procedures in place to ensure they are functioning as designed. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - All active partners do now have a signed SAFB application. Community Partner Manager does review each SAFB application and only signs once approved. If an application is incomplete, Manager returns to partner until application is fully completed. The Community Partner team utilizes the Audit checklist in order to ensure the completeness of a partner's file. The staff filling out the dates on the audit checklist is different than the staff member who is signing off with date filed as this ensures multiple staff are reviewing the file to ensure compliance. Community Partner Manager does review and provides written feedback upon each file submission. The Community Partner Manager provides feedback to the assigned coordinator in the case that items are still pending, corrections are needed, or file is complete.Partners who do not complete the requirements for the application and/or their re-certification will be sent reminder emails. After 3 attempts to obtain necessary documents the account is placed on inactive status. Community Partner and Distribution Assistant Manager notifies Client Services to temporarily remove the agency from the list of active agencies so not potential clients in need would be referred while a partner is on inactive status. Individual(s) Responsible- Melanie McGuire, CPO- Jessica Molinar,Compliance Manager Anticipated Date of Completion- 6/30/2021
During our testing of monthly reimbursement requests, we noted two requests were submitted more than 60 days after the claim month had ended. Cause: The Food Bank does not appear to have a process in place and/or current controls failed to detect in a timely manner that reimbursement requests were not processed within the required 60-day period. Effect: Failure to submit timely reimbursement requests could result in claims not being accepted. Questioned costs: None known. Context: Two out of twelve tested were not submitted for reimbursement within 60 days after the claim month had ended. Repeat finding: No Recommendation: We recommend management implement procedures to ensure reimbursement requests are processed timely. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-004?Cash Management Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2019, 2020 Type of Finding: Significant deficiency Criteria: Per the Commodity Supplemental Food Program (CSFP) Handbook Section 3100, the Food Bank must maintain a financial management system that provides accurate, current and complete disclosure of the financials status of CSFP operation. This system must ensure monthly reimbursement claims and adjusted claims are received by the Texas Department of Agriculture in TX-Unified Nutrition Program System (UNPS) in a timely manner. The Texas Department of Agriculture recommends no later than 60 days after the claim month has ended. Condition: During our testing of monthly reimbursement requests, we noted two requests were submitted more than 60 days after the claim month had ended. Cause: The Food Bank does not appear to have a process in place and/or current controls failed to detect in a timely manner that reimbursement requests were not processed within the required 60-day period. Effect: Failure to submit timely reimbursement requests could result in claims not being accepted. Questioned costs: None known. Context: Two out of twelve tested were not submitted for reimbursement within 60 days after the claim month had ended. Repeat finding: No Recommendation: We recommend management implement procedures to ensure reimbursement requests are processed timely. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - The Food Bank will utilize a check list to identify each contract, the staff responsible and due date. The controller will monitor on a monthly basis and provide status updates to the CFO. Individual(s) Responsible- Kevin Brown, CFO- Amanda Jaime, Controller, Delilah Castro, Government Contract Accountant Anticipated Date of Completion- 6/30/2021
We selected sixty subrecipients that received subawards and noted that during the fiscal year, the Food Bank did not retain documentation to support that suspension and debarment was verified for the subrecipient. Subsequent to year-end, management obtained and provided us with records to support the subrecipient was not suspended or debarred. Cause: Control procedures did not function as designed and thus the suspension and debarment process was not followed during the fiscal year. Effect: Not performing the suspension and debarment process increases the risk of noncompliance with rules and regulations and increases the risk that a subrecipient may be suspended and debarred. Questioned costs: None known. Context: We selected sixty subrecipients and noted none had support that suspension and debarment was verified during the fiscal year before the transactions was completed. Repeat finding: No Recommendation: We recommend management implement controls procedures that require verification, before a transaction is complete, that subrecipients are not suspended or debarred. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-005? Procurement, Suspension and Debarment Passed-Through Texas Department of Agriculture Food Distribution Cluster Assistance Listing No.10.565, 10.568, 10.569 Federal Award Number: CE01530 Federal Award Year: 2019, 2020 Type of Finding: Material weakness Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transactions, regardless of amount, and meet certain other criteria as specified in 2 CFR section 180.220. Condition: We selected sixty subrecipients that received subawards and noted that during the fiscal year, the Food Bank did not retain documentation to support that suspension and debarment was verified for the subrecipient. Subsequent to year-end, management obtained and provided us with records to support the subrecipient was not suspended or debarred. Cause: Control procedures did not function as designed and thus the suspension and debarment process was not followed during the fiscal year. Effect: Not performing the suspension and debarment process increases the risk of noncompliance with rules and regulations and increases the risk that a subrecipient may be suspended and debarred. Questioned costs: None known. Context: We selected sixty subrecipients and noted none had support that suspension and debarment was verified during the fiscal year before the transactions was completed. Repeat finding: No Recommendation: We recommend management implement controls procedures that require verification, before a transaction is complete, that subrecipients are not suspended or debarred. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - SAM search was added to our audit checklist immediately upon feedback from audit. All files moving forward will have a SAM search results document for current year. Individual(s) Responsible- Melanie McGuire, CPO- Jessica Molinar, Compliance Manager Anticipated Date of Completion- 6/30/2021
Procurement process was not performed for the SNAP Cluster during the year. Cause: Control procedures did not function as designed and thus compliance with procurement requirements was not followed. Effect: Not performing the procurement process increases the risk of noncompliance with rules and regulations and increases the risk that a vendor may be suspended and debarred. Questioned costs: None known Context: We selected 18 transactions to test micro-purchases, 1 transaction to test small purchases and 1 transaction to test sealed bid method (greater than or equal to $50,000) and noted there was no support for procurement for any of these transaction methods. In addition, we noted there was no support that suspension and debarment was verified for the vendor selected for the sealed bid method. We also noted the procurement policies and procedures related to federal programs was specific to the Summer Food Service Program, versus specific to the overall procurement process for federal grants as required. Repeat finding: No Recommendation: We recommend management review, revise, and test current control procedures and make any necessary changes to ensure compliance with compliance criteria above. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2020-006? Procurement and Suspension and Debarment SNAP Cluster Assistance Listing No.10.561 Federal Award Number: 529-16-0002-00001 Federal Award Year: 2019, 2020 Type of Finding: Material weakness and material instance of noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. A non-federal entity must use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(a) and (b). Micro-purchases may be awarded without soliciting competitive quotations if the non-federal entity considers the price to be reasonable (2 CFR section 200.320(a). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR section 200.320(b). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for good and services awarded under non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition: Procurement process was not performed for the SNAP Cluster during the year. Cause: Control procedures did not function as designed and thus compliance with procurement requirements was not followed. Effect: Not performing the procurement process increases the risk of noncompliance with rules and regulations and increases the risk that a vendor may be suspended and debarred. Questioned costs: None known Context: We selected 18 transactions to test micro-purchases, 1 transaction to test small purchases and 1 transaction to test sealed bid method (greater than or equal to $50,000) and noted there was no support for procurement for any of these transaction methods. In addition, we noted there was no support that suspension and debarment was verified for the vendor selected for the sealed bid method. We also noted the procurement policies and procedures related to federal programs was specific to the Summer Food Service Program, versus specific to the overall procurement process for federal grants as required. Repeat finding: No Recommendation: We recommend management review, revise, and test current control procedures and make any necessary changes to ensure compliance with compliance criteria above. View of responsible officials: Management concurs with the finding. See corrective action plan.
Corrective Action - The Food Bank is reassigning the procurement manager to the accounting and administrative team. This change should allow for additional oversight and increase federal procurement knowledge by way of additional formal and informal training opportunities. Individual(s) Responsible- Kevin Brown, CFO-George Cox, Procurement Manager Anticipated Date of Completion- 6/30/2021
FAC accepted this audit on January 14, 2020 — management decision was due July 14, 2020.
The Food Bank adopted a new reimbursement methodology on May 2019 that was implemented retroactively through October 1, 2018, which required a substantial amount of effort on behalf of the Food Bank. This effort extended through audit fieldwork; thus, the engagement team tested cash management compliance procedures within days of the Food Bank completing and submitting the revised drawdown requests based on the new methodology. We noted there was evidence of review and approval on the four reimbursement requests tested. Although proper reviews were noted, one of the four drawdowns tested included a reimbursement in the amount of $102,181.95; however, per review of the support, we noted the reimbursement request should have been $78,738.59, which resulted in the Food Bank requesting an additional $23,443.36 in error. The Food Bank submitted a revision within a couple of business days of the engagement team notifying management. Cause: Incorrect amount from supporting documentation was inadvertently selected for reimbursement. Effect: The amount requested for reimbursement was incorrect. Questioned costs: Known questioned costs do not exceed $25,000. Context: One of the four drawdown requests included an additional $23,443.36 for reimbursement in error. Recommendation: We recommend management review existing control procedures to ensure they mitigate the risk of inaccurately submitting reimbursement requests. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-001?Cash Management Texas Department of Agriculture Food Distribution Cluster CFDA No.10.565, 10.568, 10.178, 10.569 Federal Award Number: CE01530 Federal Award Year: 2018, 2019 Type of Finding: Significant Deficiency and Noncompliance Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Per 2 CFR 200.305(b)(3)), program costs must be paid by non-federal entity funds before submitting a payment request, i.e., the non-federal entity must disburse funds for program purposes before requesting payment from the federal awarding agency or pass-through entity. Condition: The Food Bank adopted a new reimbursement methodology on May 2019 that was implemented retroactively through October 1, 2018, which required a substantial amount of effort on behalf of the Food Bank. This effort extended through audit fieldwork; thus, the engagement team tested cash management compliance procedures within days of the Food Bank completing and submitting the revised drawdown requests based on the new methodology. We noted there was evidence of review and approval on the four reimbursement requests tested. Although proper reviews were noted, one of the four drawdowns tested included a reimbursement in the amount of $102,181.95; however, per review of the support, we noted the reimbursement request should have been $78,738.59, which resulted in the Food Bank requesting an additional $23,443.36 in error. The Food Bank submitted a revision within a couple of business days of the engagement team notifying management. Cause: Incorrect amount from supporting documentation was inadvertently selected for reimbursement. Effect: The amount requested for reimbursement was incorrect. Questioned costs: Known questioned costs do not exceed $25,000. Context: One of the four drawdown requests included an additional $23,443.36 for reimbursement in error. Recommendation: We recommend management review existing control procedures to ensure they mitigate the risk of inaccurately submitting reimbursement requests. View of responsible officials: Management concurs with the finding. See corrective action plan.
Identifying Number: 2019-001 ? Cash Management Finding: The Food Bank adopted a new reimbursement methodology on May 2019 that was implemented retroactively through October 1, 2018, which required a substantial amount of effort on behalf of the Food Bank. This effort extended through audit fieldwork, thus the engagement team tested cash management compliance procedures within days of the Food Bank completing and submitting the revised draw down requests based on the new methodology. We noted there was evidence of review and approval on the four reimbursement requests tested. Although proper reviews were noted, one of the four drawdowns tested included a reimbursement in the amount of $102,181.95, however, per review of the support, we noted the reimbursement request should have been $78,738.59, which resulted in the Food Bank requesting an additional $23,443.36 in error. The Food Bank submitted a revision within a couple of business days of the engagement team notifying management. Individual(s) responsible for corrective action plan: Kevin Brown, CFO and Amanda Jaime, Controller. Anticipated Completion Date: June 30, 2020 Corrective Action Taken or Planned: Management will closely monitor the current controls to assess if additional measures need to be implemented.
During our testing of eligibility for the mobile pantry, we noted three vouchers and four site envelopes did not have evidence of review and approval. Although evidence of review and approval was not noted, our testing indicated there was no noncompliance noted. Cause: Control procedures did not function as designed which allowed for eligibility determination to be approved without the vouchers and site envelopes containing evidence of review and approval. Effect: Not performing a formal review and approval of eligibility increases the risk that an individual will be approved when they may not meet eligibility requirements. Questioned costs: None. Context: Three vouchers and four site envelopes out of 40 tested did not have evidence of review and approval. Recommendation: We recommend management enhance the review and approval process over making eligibility determinations. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-002?Eligibility Texas Department of Agriculture Food Distribution Cluster CFDA No.10.565, 10.568, 10.178, 10.569 Federal Award Number: CE01530 Federal Award Year: 2018, 2019 Type of Finding: Significant Deficiency Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Condition: During our testing of eligibility for the mobile pantry, we noted three vouchers and four site envelopes did not have evidence of review and approval. Although evidence of review and approval was not noted, our testing indicated there was no noncompliance noted. Cause: Control procedures did not function as designed which allowed for eligibility determination to be approved without the vouchers and site envelopes containing evidence of review and approval. Effect: Not performing a formal review and approval of eligibility increases the risk that an individual will be approved when they may not meet eligibility requirements. Questioned costs: None. Context: Three vouchers and four site envelopes out of 40 tested did not have evidence of review and approval. Recommendation: We recommend management enhance the review and approval process over making eligibility determinations. View of responsible officials: Management concurs with the finding. See corrective action plan.
Identifying Number: 2019-002 ? Eligibility Finding: During testing of eligibility for mobile pantry, it was noted three vouchers and four site envelopes did not have evidence of review and approval. Although evidence of review and approval was noted, testing indicated there was not non-compliance noted. Individual responsible for corrective action plan: Jessica Molinar, Compliance and Capability Manager Anticipated Completion Date: September 30, 2020 Corrective Action Taken or Planned: Though the testing indicated that no non-compliance occurred, we acknowledge the necessity to ensure reviews and approvals. In our commitment to ensure each entity has thoroughly completed their eligibility determination, San Antonio Food Bank has adopted a ?10 Folder System? to safeguard our review and approval process. San Antonio Food Bank implemented new training in November 2019 for all new partners which included the ?10 Folder System?. However, due to our substantial partnership size the training for all existing partnerships will begin with a soft roll-out January 2020. The trainings will be offered monthly and be a part of our annual conferences. All partnerships will have the training completed no later than September 30, 2020. The ?10 Folder System? will ensure each subrecipient partner file is complete and available to be reviewed by San Antonio Food Bank compliance staff during their annual monitoring inspection. All compliance staff will complete annual training on the 10-folder system to ensure their understanding of requirements and ability to review, monitor, and provide feedback and/or corrective action if needed. The folder will include: 1. Agreement ? current, signed agreement with the San Antonio Food Bank 2. Administrative Reviews ? San Antonio Food Bank reviews, must include most current review which must have been completed no more than 24 months prior 3. Approved Applications ? current, signed, approved applications for all clients who receive food, updated at annually 4. Ineligible/Denied Applications ? all applications that have been denied receipt of food 5. Distribution List ? approved, signed distribution list, by all clients that received food 6. Income Guidelines ? current income guidelines, updated every year in July 7. Distribution Rates ? amount of food given to clients, determined by the number of people in household 8. Food Bank Invoices ? documentation of food received from Food Bank, signed, and dated 9. Temperature Logs ? must record temperature of all coolers and freezers and keep history of this documentation in this folder, if applicable. 10. Correspondence ? any miscellaneous information received from San Antonio Food Bank The Compliance and Capability Manager will audit 10% of Compliance Coordinator?s visits monthly with follow up to agency gathering information regarding the effectiveness of communication provided and that all issues or concerns were addressed. Additionally, Compliance and Capability Manager will complete 10% of annual monitoring site visits to ensure review and approval processes are being adhered too.
During our testing of subrecipient monitoring, we noted one subrecipient that was not monitored in a year. The last monitoring visit occurred in March 2018. It is the Food Bank?s policy to perform a monitoring visit at least once a year on a calendar-year basis. Cause: Control procedures did not function as designed which allowed for a subrecipient to not have a monitoring site visit performed in a year in accordance with the Food Bank?s policies and procedures. Effect: Not performing a formal monitoring visit increases the risk that a subrecipient may not be meeting subrecipient contract requirements. Questioned costs: None. Context: One subrecipient out of 25 tested did not have a monitoring site visit in a year. Recommendation: We recommend management review policies and procedures related to performing subrecipient monitoring site visits to ensure sites with a history of problems be reviewed on an annual basis and other sites with no issues can have site visits on a periodic basis. View of responsible officials: Management concurs with the finding. See corrective action plan.
Show full finding ▾Hide full finding ▴Finding 2019-003?Subrecipient Monitoring Texas Department of Agriculture Food Distribution Cluster CFDA No.10.565, 10.568, 10.178, 10.569 Federal Award Number: CE01530 Federal Award Year: 2018, 2019 Type of Finding: Significant Deficiency Criteria: Per 2 CFR 200.303, the Food Bank must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and the provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Condition: During our testing of subrecipient monitoring, we noted one subrecipient that was not monitored in a year. The last monitoring visit occurred in March 2018. It is the Food Bank?s policy to perform a monitoring visit at least once a year on a calendar-year basis. Cause: Control procedures did not function as designed which allowed for a subrecipient to not have a monitoring site visit performed in a year in accordance with the Food Bank?s policies and procedures. Effect: Not performing a formal monitoring visit increases the risk that a subrecipient may not be meeting subrecipient contract requirements. Questioned costs: None. Context: One subrecipient out of 25 tested did not have a monitoring site visit in a year. Recommendation: We recommend management review policies and procedures related to performing subrecipient monitoring site visits to ensure sites with a history of problems be reviewed on an annual basis and other sites with no issues can have site visits on a periodic basis. View of responsible officials: Management concurs with the finding. See corrective action plan.
Identifying Number: 2019-003 ? Subrecipient Monitoring Finding: During testing of subrecipient monitoring it was noted one subrecipient was not monitored in a year. The last monitoring visit occurred in March 2018. It is the Food Bank?s policy to perform a monitoring visit at least once a year on a calendar year basis. Individual responsible for corrective action plan: Jessica Molinar, Compliance and Capability Manager Anticipated Completion Date: January 2022 Corrective Action Taken or Planned: As a growing organization we are actively seeking to bring on new subrecipient partners. Though our rapid growth demonstrates San Antonio Food Bank?s dedication and commitment to meet the demand to reach additional partners, the audit has helped highlight the need to maintain focus on monitoring/compliance. We fully understand the purpose of completing monitoring site visits is to ensure compliance. As a result, we have dedicated staff to complete an internal audit, all files will be audited prior to their annual monitoring site inspection. At the moment we have approximately over 500 active partners. As previously noted in above finding, San Antonio Food Bank has recently adopted a 10-file system which will help ensure each annual monitoring inspection is completed thoroughly. Due to the size of subrecipients partners, San Antonio Food Bank will be dividing all subrecipients into one of three tiers: High Priority, Medium Priority, and Low Priority. Agencies will be placed into the appropriate category based on the following factors: date of last monitoring visit, history of grievances/concerns, and size of families serviced. Each month Compliance staff will complete at minimum 8% of total number of active subrecipients and annually the Compliance and Capability Manager will complete 10% of monitoring inspections visits. Our outlined percentage is strategic two-fold to ensure within the next 24 months all agencies have a current monitoring inspection and additionally ensure our staff have dedicated time it may take to support subrecipients achieve compliance. All monitoring inspections which require a corrective action plan, will receive an additional visit within 30 days of inspection and one additional visit within 6 months thereafter to ensure compliance is being maintained.
FAC accepted this audit on November 30, 2017 — management decision was due May 30, 2018.
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