EIN: 760338721
UEI: YHGHJ7VZK3G7
Audited by: WATHEN, DESHONG & JUNCKER LLP
Oversight agency: 10 [Department of Agriculture]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on July 9, 2026. 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 9, 2027 (128 days from today).
What is a management decision? →FAC accepted this audit on June 17, 2025 — management decision was due December 17, 2025.
2024‐001 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance – Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CFR 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture’s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), specifically, competitive bidding for purchases over the SAT threshold. Cause: The Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CFR 200 was not conducted until after the Organization entered into the contract with the vendor. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2024 that were not in compliance with state and federal requirements. Repeat Finding: See prior year finding 2023-001. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2024‐001 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance – Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CFR 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture’s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), specifically, competitive bidding for purchases over the SAT threshold. Cause: The Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CFR 200 was not conducted until after the Organization entered into the contract with the vendor. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2024 that were not in compliance with state and federal requirements. Repeat Finding: See prior year finding 2023-001. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2024-001-TEFAP- Rach and Resiliency Grant {ALN 10.568) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance - Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200) Criteria - The Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CFR 200 procurement requirements. Conditions and Context : The Food Bank did not follow Texas Department of Agriculture's or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over thee simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.) specifically , competitive bidding for purchases over the SAT threshold. Repeat Finding: 2023-001 Recommendation : Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirement should be followed. CORRECTIVE ACTIONS : All Director level Management will go to the Houston Food Bank for training on RFA's, advertisement, sealed bid process, and federal guideline procurement procedures by September 2025. This training will be documented and placed in each personnel file. ALL purchases being made for reimbursement through Federal funding or being handled through a pass through process with grantor will be reviewed and signed off for approval by the President/CEO and the CFO of the Southeast Texas Food Bank. The President/CEO will ensure that proper bids and process have been taken and reviewed following the required guidelines set forth by the Food Bank policy updated May 2024, Federal guidelines, and/or grantor guidelines. The more restrictive policy either Food Bank, Federal entity, or grantor will be followed prior to purchase. If in the event that RFA's were sent out to three or more vendors with no response by deadline, these will be documented as such.
2023-001
2024‐002 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control – Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2024 did not include proper monitoring of the program policies and procedures. Cause: The Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CFR 200 was not conducted until after the Organization entered into the contract with the vendor. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Repeat Finding: See prior year finding 2023-002. Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2024‐002 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control – Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2024 did not include proper monitoring of the program policies and procedures. Cause: The Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CFR 200 was not conducted until after the Organization entered into the contract with the vendor. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Repeat Finding: See prior year finding 2023-002. Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2024-002 – TEFAP Reach and Resiliency Grant (ALN 10.568) United States Department of Agriculture , Passed through the Texas Department of Agriculture Internal Control – Monitoring Criteria : Monitoring should be such that there is an assurance that controls are being performed in a timely manner. Condition and Context :The policies and procedures in place during 2024 did not include proper monitoring of the program policies and procedures. Repeat finding : 2023-002 Recommendation : Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding CORRECTIVE ACTIONS : ALL purchases being made for federal and state funding will be reviewed by the President/CEO and the CFO of the Southeast Texas Food Bank for proper monitoring and compliance of procurement policies. The President/CEO will sign off for approval prior to purchasing.
2023-002
FAC accepted this audit on September 25, 2024 — management decision was due March 25, 2025.
2023‐001 – COVID‐19 Coronavirus State and Local Recovery Funds – Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance – Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture’s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchase threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2023 that were not in compliance with state and federal requirements. Repeat Finding: See prior year finding 2022-001. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2023‐001 – COVID‐19 Coronavirus State and Local Recovery Funds – Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance – Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture’s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchase threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2023 that were not in compliance with state and federal requirements. Repeat Finding: See prior year finding 2022-001. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2023-001- Coronavirus State and Local Recovery Funds - Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance - Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Condition and Context : The Food Bank did not follow Texas Department of Agriculture's or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchases threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Recommendation : Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive requirements should be followed. CORRECTIVE ACTIONS: ALL purchases being made for reimbursement through Federal funding or being handled through a pass through process with a grantor will be reviewed and signed off for approval prior to purchase by the President and CEO of the Southeast Texas Food Bank. The President and CEO will ensure that proper bids have been taken and reviewed following the required guidelines set forth by the Food Bank policy updated May 2024, Federal guidelines, and/or grantor guidelines. The more restrictive policy either Food Bank, Federal entity, or grantor will be followed prior to purchase. All ARPA expenditures were solicited prior to 2022 by previous management and no records exist for bid processes. It was also noted that the CSFP boxes were not handled through policy and procedure for small purchases. As of June 2024, there have been three bids acquired for the next years box order.
2022-001
2023‐002 – COVID‐19 Coronavirus State and Local Recovery Funds – Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control – Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2023 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CRF 200 was not conducted. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Repeat Finding: See prior year finding 2022-002. Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2023‐002 – COVID‐19 Coronavirus State and Local Recovery Funds – Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control – Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2023 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CRF 200 was not conducted. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Repeat Finding: See prior year finding 2022-002. Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2023 – 002 – Coronavirus State and Local Recovery Funds – Food Bank Capacity Grant (ARPA) (ALN ‐21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control – Monitoring Condition and Context: The policies and procedures in place during 2023 did include proper monitoring of the program policies and procedures. Recommendations: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. CORRECTIVE ACTION PLAN : ALL purchases being made for federal and state funding will be reviewed by the President and CEO for proper monitoring and compliance of procurement policies. The President and CEO will sign off for approval prior to purchasing. ALL Purchases being made for grantors with procurement requirements will be reviewed by the President and CEO prior to purchase for approval for monitoring for procurement compliance. To Note : all prior ARPA grant purchases were made and ordered prior to 2022 by previous leadership.
2022-002
FAC accepted this audit on September 27, 2023 — management decision was due March 27, 2024.
2022-001 ? Coronavirus State and Local Recovery Funds ? Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance ? Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture?s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchase threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2022 that were not in compliance with state and federal requirements. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-001 ? Coronavirus State and Local Recovery Funds ? Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance ? Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to adhere to procurement guidelines reflected in the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank did not follow Texas Department of Agriculture?s or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement, sealed bids, etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchase threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2022 that were not in compliance with state and federal requirements. Recommendation: Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive procurement requirements should be followed. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2022-001- Coronavirus State and Local Recovery Funds - Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Compliance - Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Condition and Context : The Food Bank did not follow Texas Department of Agriculture's or the 2 CFR 200 required Methods of Procurement. Deviations include lack of adherence to required Formal Procurement Methods for purchases over the simplified acquisition threshold (SAT) (advertisement sealed bids , etc.), competitive bidding for purchases over the SAT threshold, unavailable supporting documents demonstrating compliance with Small Purchase Procedures for purchases over the micro purchases threshold and under the SAT, and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Recommendation : Management should take steps to ensure that the Food Bank identifies, assigns responsibility, and adheres to procurement requirements for federal funding. If procurement requirements for a pass through entity and grantor differ, the more restrictive requirements should be followed. CORRECTIVE ACTIONS : ALL purchases being made for reimbursement through Federal funding or being handled through a pass through process with a grantor will be reviewed and signed off for approval prior to purchase by the President and CEO of the Southeast Texas Food Bank. T he President and CEO will ensure that proper bids have been taken and reviewed following the required guidelines set forth by the Food Bank policy dated September 2022, Federal guidelines, and/or grantor guidelines. The more restrictive policy either Food Bank, Federal entity, or grantor will be followed prior to purchase.
2022-002 ? Coronavirus State and Local Recovery Funds ? Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2022 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CRF 200 was not conducted. Section III ? Federal Award Findings (Continued) Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2022-002 ? Coronavirus State and Local Recovery Funds ? Food Bank Capacity Grant (ARPA) (ALN 21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2022 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of compliance with 2 CRF 200 was not conducted. Section III ? Federal Award Findings (Continued) Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis Recommendation: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2022 - 002 - Coronavirus State and Local Recovery Funds - Food Bank Capacity Grant (ARPA) (ALN -21.027) United States Department of Agriculture, Passed through the Texas Department of Agriculture. Internal Control - Monitoring - Condition and Context: The policies and procedures in pace during 2022 did not include proper monitoring of the program policies and procedures. Recommendations: Management should consider implementation of a contemporaneous monitoring process over procurement with federal and state funding. CORRECTIVE ACTION PLAN : ALL purchases being made for federal and state funding will be reviewed by the President and CEO for proper monitoring and compliance of procurement policies. T he President and CEO will sign off for approval prior to purchasing. ALL Purchases being made for grantors with procurement requirements will be reviewed by the President and CEO prior to purchase for approval for monitoring for procurement compliance.
FAC accepted this audit on September 27, 2022 — management decision was due March 27, 2023.
2021-001 ? The Emergency Food Assistance Programs (CFDA/ALN 10.569, 10.568 and 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture Compliance ? Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to use documented procurement procedures which reflect the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank?s written procurement plan does not align with the Texas Department of Agriculture?s Emergency Food Assistance Handbook or the 2 CFR 200 Methods of procurement to be followed. Deviations include purchase threshold classifications and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2021 that were not in compliance with state and federal requirements. Recommendation: Management should modify the written procurement procedures to follow the more restrictive of state or federal procurement requirements. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-001 ? The Emergency Food Assistance Programs (CFDA/ALN 10.569, 10.568 and 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture Compliance ? Office of Management and Budget Guidance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal Regulations (CFR) Part 200 Procurement Standards (2 CFR 200). Criteria: The Southeast Texas Food Bank is required to use documented procurement procedures which reflect the applicable state and federal regulations and conform to 2 CRF 200 procurement requirements. Condition and Context: The Food Bank?s written procurement plan does not align with the Texas Department of Agriculture?s Emergency Food Assistance Handbook or the 2 CFR 200 Methods of procurement to be followed. Deviations include purchase threshold classifications and formal procurement requirements and other instances of noncompliance that do not rise to the level of a finding. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities, procurement policies and procedures applicable to compliance with 2 CRF 200 was not conducted. Effect: The entity did not follow state and federal procurement requirements, consequently, purchases were made during 2021 that were not in compliance with state and federal requirements. Recommendation: Management should modify the written procurement procedures to follow the more restrictive of state or federal procurement requirements. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
The Emergency Food Assistance Programs (CFDA/ ALN 10.569, 10.568 and 10.565) United States Department of Agriculture , Passed through the Texas Department of Agriculture Compliance - Office of Management and Budget Compliance for Grants and Agreements Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 Code Federal regulations (CFR) Part 200 Procurement Standards (2 CFR 200) Corrective Action Plan : The Southeast Texas Food Bank Management Staff will review current Procurement policies and make written recommendations to its Board of Directors for more alignment with the Texas Department of Agriculture's Emergency Food Assistance Handbook for current Procurement Policies and Procedures as the more restrictive procurement policy. The intent will be to align the procurement thresholds for purchase classifications and formal procurement requirements for which there are deviations and/or non-compliance. This will allow us to follow state and federal procurement requirements for future purchases. Anticipated Completion date of review process by Food Bank Management to the Board of Directors: October 31, 2022 Anticipated Completion of Board review and Approval : December 31, 2022 Responsible Party : Harvey Zernial - President/CEO, Jimmy Sparks - Chief Administration Officer
2021-002 ? The Emergency Food Assistance Programs (CFDA/ALN 10.569, 10.568 and 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2021 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of Program Compliance with the Emergency Food Assistance Programs and compliance with 2 CRF 200 was not conducted. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the TEFAP and CSFP programs. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2021-002 ? The Emergency Food Assistance Programs (CFDA/ALN 10.569, 10.568 and 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Context: The policies and procedures in place during 2021 did not include proper monitoring of the program policies and procedures. Cause: Southeast Texas Food Bank experienced turnover in key management positions. Sufficient training and transition of responsibilities related to the monitoring of Program Compliance with the Emergency Food Assistance Programs and compliance with 2 CRF 200 was not conducted. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance including procurement and other instances of noncompliance that do not rise to the level of a finding were not recognized and corrected on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the TEFAP and CSFP programs. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
The Emergency Food Assistance Program (CFDA/ ALN 10.569, 10.568 and 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture Internal Control - Monitoring The Southeast Texas Food Bank management staff will monitor all programming at least once per month (12 times per year) for compliance in Program policies and procedures. These monitors will be documented and follow up training and/or counsel will be provided. The Southeast Texas Food Bank will create Standard Operating Procedures (S.O.P.'s) Handbooks for all Programs for training purposes in times of turnover. Food Bank Management will train and sign off on all training for new hires with documented training logs to be placed in the personnel files of each new employee. Anticipated Completion Date for monitoring all Programs : September 31, 2022 Anticipated Completion Date for creating Standard Operating Procedure Handbooks for all Programs : December 31. 2022 Responsible Party : Harvey Zernial, President/CEO, Jimmy Sparks, Chief Administration Officer, Rachel Crowder, Director of Programs
2020-002
FAC accepted this audit on October 19, 2021 — management decision was due April 19, 2022.
Compliance ? Special Testing Criteria: CSFP provides a package of USDA Foods to low-income elderly adults. Accurate and complete records must be maintained with respect to the receipt, distribution/use, and inventory of USDA Foods, including end products. Condition and Context: Distributions of CSFP commodities at 7 locations were tested. Of the 7 CSFP distribution sites tested (which represented 2,955 individual distributions) unreconciled differences between the total number of boxes distributed per inventory records and the total number of boxes distributed per CSFP tracking software Link2Feed existed at all sites. Detailed records supporting distributions to individual recipients selected for testing were not available for examination. Cause: Southeast Texas Food Bank experienced turnover in the CSFP coordinator position. The individual in this position did not adhere to the existing policies and procedures regarding documentation of the distribution process for the CSFP commodities. Effect: Lack of documentation of compliance and performance (detailed record of distributions and reconciliation of inventory amounts distributed per inventory records compared to amounts per Link2Feed) exposes the Southeast Texas Food Bank, Inc. to a risk that the Texas Department of Agriculture will assert that CSFP commodities were not distributed in compliance with requirements of the grant. Recommendation: Management should consider implementing additional procedures to address reconciliation and documentation of the distribution process. Management should also consider establishing a formal training policy for new employees who are directly involved in grant administration. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴Compliance ? Special Testing Criteria: CSFP provides a package of USDA Foods to low-income elderly adults. Accurate and complete records must be maintained with respect to the receipt, distribution/use, and inventory of USDA Foods, including end products. Condition and Context: Distributions of CSFP commodities at 7 locations were tested. Of the 7 CSFP distribution sites tested (which represented 2,955 individual distributions) unreconciled differences between the total number of boxes distributed per inventory records and the total number of boxes distributed per CSFP tracking software Link2Feed existed at all sites. Detailed records supporting distributions to individual recipients selected for testing were not available for examination. Cause: Southeast Texas Food Bank experienced turnover in the CSFP coordinator position. The individual in this position did not adhere to the existing policies and procedures regarding documentation of the distribution process for the CSFP commodities. Effect: Lack of documentation of compliance and performance (detailed record of distributions and reconciliation of inventory amounts distributed per inventory records compared to amounts per Link2Feed) exposes the Southeast Texas Food Bank, Inc. to a risk that the Texas Department of Agriculture will assert that CSFP commodities were not distributed in compliance with requirements of the grant. Recommendation: Management should consider implementing additional procedures to address reconciliation and documentation of the distribution process. Management should also consider establishing a formal training policy for new employees who are directly involved in grant administration. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Although we have shown improvements over 2019 results and audit findings, we realize through the 2020 audit process that enough reconciliation work and processes were not put in place to fully correct previous findings. These next recommended corrective action steps will be put in place effective 7-1-2021. The Southeast Texas Food Bank Senior Program Specialist will run Link2Feed weekly kit issuance reports by individual site verifying every CSFP site distribution numbers upon entry in to Link2Feed. One copy of the kit issuance report will go to the Director of Operations for reconciliation with Primarius inventory entry. The invoice in Primarius will be generated from numbers verified by the Senior Program Specialist on the Operations Load Sheet and entered into Link2Feed. An additional copy will be kept with the Senior Program Specialist for filing with a monthly file for all CSFP sites that month for reconciliation with the monthly spreadsheet and all Primarius invoices. If the kit issuance report does not match the Primarius entry, immediate investigative actions will be taken by the Director of Operations and the Director of Programs to research and identify such discrepancies. The Director of Operations will now enter all CSFP sites individually instead of by County. This will help both the Program staff and the Operations staff to easily reconcile weekly and timely by site. Now both Primarius and Link2Feed will have individual site entry. This will also allow for better audit processes for both an external and internal audit. To further enhance inventory reconciliation, Senior Program Specialist will review the loaded CSFP truck inventory by day to have a beginning Inventory and an ending inventory upon return. This will also be a reconciliation with the boxes distributed in that day. Senior Program Specialist will keep a copy of operation load sheets and sign off on said inventory for CSFP. This copy will accompany the monthly files with the kit issuance reports and invoices kept by the Senior Program Specialist.
2019-001
Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Cause: The policies and procedures in place during 2020 did not include proper monitoring of the program policies and procedures. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance were not recognized on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the CSFP distributions. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Cause: The policies and procedures in place during 2020 did not include proper monitoring of the program policies and procedures. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance were not recognized on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the CSFP distributions. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
The Southeast Texas Food Bank has added a Senior Program Coordinator. This Senior Program Coordinator will travel with the Senior Program Specialist on 4 CSFP distribution sites monthly for monitoring of the program policies and procedures at the distribution sites. The Senior Program Coordinator will also review all weekly kit issuance reports and operation load sheets for weekly sign off (signature). Any findings of discrepancies of policy and procedure by the Senior Program Coordinator will be reported immediately to the Director of Programs in written form for filing. The Director of Programs will travel to 2 CSFP distribution sites monthly for monitoring of the CSFP policies and procedures for both the Senior Program Coordinator and the Senior Program Specialist. The Director of Programs will sign off (signature) on the kit issuance reports for those site distribution monitors. Any discrepancies will be noted in written form and filed.
2019-002
FAC accepted this audit on September 14, 2020 — management decision was due March 14, 2021.
2019-001 ? Commodity Supplemental Food Program (CSFP), (CFDA 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture, Contract No. 806780706 Compliance ? Special Testing Criteria: CSFP provides a package of USDA Foods to low-income elderly adults. Accurate and complete records must be maintained with respect to the receipt, distribution/use, and inventory of USDA Foods, including end products. Condition and Context: Distributions of CSFP commodities at 5 locations were tested. Of the 5 CSFP distribution sites tested (which represented 720 individual distributions) unreconciled differences between the total number of boxes distributed per inventory records and the total number of boxes distributed per CSFP tracking software Link2Feed existed at all sites. Detailed records supporting distributions to individual recipients selected for testing were not available for examination. Cause: In 2019 the Southeast Texas Food Bank experienced turnover in the CSFP coordinator position. The individual in this position did not adhere to the existing policies and procedures regarding documentation of the distribution process for the CSFP commodities. Effect: Lack of documentation of compliance and performance (detailed record of distributions and reconciliation of inventory amounts distributed per inventory records compared to amounts per Link2Feed) exposes the Southeast Texas Food Bank, Inc. to a risk that the Texas Department of Agriculture will assert that CSFP commodities were not distributed in compliance with requirements of the grant. Recommendation: Management should consider implementing additional procedures to address reconciliation and documentation of the distribution process. Management should also consider establishing a formal training policy for new employees who are directly involved in grant administration. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2019-001 ? Commodity Supplemental Food Program (CSFP), (CFDA 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture, Contract No. 806780706 Compliance ? Special Testing Criteria: CSFP provides a package of USDA Foods to low-income elderly adults. Accurate and complete records must be maintained with respect to the receipt, distribution/use, and inventory of USDA Foods, including end products. Condition and Context: Distributions of CSFP commodities at 5 locations were tested. Of the 5 CSFP distribution sites tested (which represented 720 individual distributions) unreconciled differences between the total number of boxes distributed per inventory records and the total number of boxes distributed per CSFP tracking software Link2Feed existed at all sites. Detailed records supporting distributions to individual recipients selected for testing were not available for examination. Cause: In 2019 the Southeast Texas Food Bank experienced turnover in the CSFP coordinator position. The individual in this position did not adhere to the existing policies and procedures regarding documentation of the distribution process for the CSFP commodities. Effect: Lack of documentation of compliance and performance (detailed record of distributions and reconciliation of inventory amounts distributed per inventory records compared to amounts per Link2Feed) exposes the Southeast Texas Food Bank, Inc. to a risk that the Texas Department of Agriculture will assert that CSFP commodities were not distributed in compliance with requirements of the grant. Recommendation: Management should consider implementing additional procedures to address reconciliation and documentation of the distribution process. Management should also consider establishing a formal training policy for new employees who are directly involved in grant administration. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2019-001 - Compliance - Commodity Supplemental Food Program (CFDA 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture, Contract No, 80678O706 Corrective Action Plan: Management will establish processes, procedures, and additional controls addressing, but not limited to, the reconciliation and documentation of CSFP distribution process. Management will also implement a formal training program addressing specific grant compliance requirements for all new employees involved with the administration of Federal Grants. Anticipated Completion Date: October 3L,2020
2019-002 ? Commodity Supplemental Food Program (CFDA 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture, Contract No. 806780706 Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Cause: The policies and procedures in place during 2019 did not include proper monitoring of the program policies and procedures. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance were not recognized on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the CSFP distributions. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
Show full finding ▾Hide full finding ▴2019-002 ? Commodity Supplemental Food Program (CFDA 10.565) United States Department of Agriculture, Passed through the Texas Department of Agriculture, Contract No. 806780706 Internal Control ? Monitoring Criteria: Monitoring should be such that there is an assurance that control activities are being performed in a timely manner. Condition and Cause: The policies and procedures in place during 2019 did not include proper monitoring of the program policies and procedures. Effect: As a result of this lack of monitoring, deficiencies in Program Compliance were not recognized on a timely basis. Recommendation: Management should consider implementation of a contemporaneous monitoring process over the CSFP distributions. View of Responsible Party: Management concurs with recommendation. See corrective action plan.
2O19-0O2 - Monitoring Corrective Action Plan: Management will implement a contemporaneous monitoring process to include monthly review of documented compliance with specific program requirements. Anticipated Completion Date: October 31,2020 Responsible Party: Daniel Maher, President/CEO; Harvey Zernial, Director of Programs; Donald Stagg, Director of Operations; Shannon Beathard, CSFP Coordinator.
FAC accepted this audit on August 27, 2019 — management decision was due February 27, 2020.
FAC accepted this audit on August 21, 2018 — management decision was due February 21, 2019.
FAC accepted this audit on September 20, 2017 — management decision was due March 20, 2018.
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