New Vision FoundationNon-Profit

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 Pass-Through Agency: Feeding Our Future Award Period: February 2021 – December 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Adverse Opinion) Criteria or specific requirement: 7 CFR 226.17a(c) states that at-risk afterschool snacks and/or at-risk afterschool meals are reimbursable only if served to children who are participating in an approved afterschool care program. Condition: Siblings of children participating in an approved afterschool care program received meals that were reimbursed under the program through a weekly meal delivery. The siblings were not participating in an approved afterschool care program. There had been a waiver from USDA to serve all children, regardless of participation in an approved afterschool care program, but it expired on June 30, 2020. Management was not aware the waiver had expired and indicated that the sponsoring organization encouraged the continued enrollment of all children throughout 2021. Questioned costs: Known questioned costs from the sample tested for the 25 ineligible children in that month totaled $2,731. Context: We tested 40 enrollment forms, and noted that out of 40 children selected for testing, 25 were not participating or enrolled in an approved after school care program. Additionally, we noted that on the enrollment forms, siblings were enrolled in the program as young as one year old, and entire sibling groups were enrolled despite not participating in or being enrolled in an approved after school care program. Additionally, none of the home meal delivery authorization forms were signed providing consent for meal delivery and release of information. Cause: Management has indicated that their sponsor organization, Feeding Our Future, told them they were required to sign up all children if requested. Management was not aware that forms were required to be signed or that the waiver from USDA had expired. Effect: Meals and snacks were reimbursed to the Organization from federal funds related to children that were not eligible. Recommendation: We recommend the Organization attend training, review federal requirements, and fully understand the eligibility requirements of children they can serve if they apply for funding with this program again. Views of responsible officials: This program was initiated during the height of COVID, when guidelines on both state and federal levels were changing rapidly. Management provided auditors with documentation for participation in the meal program. Documentation included participant names that were printed and/or written in cursive as is customary for the served population. The printed names were not considered signatures and rejected by the auditors. Management attended all trainings provided by the sponsor organization and followed all of the program sponsor guidelines. See the Corrective Action Plan for further details.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 Pass-Through Agency: Feeding Our Future Award Period: February 2021 – December 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Adverse Opinion) Criteria or specific requirement: 2 CFR section 200.303(a) requires that nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. MDE also issued At-Risk Afterschool Care Centers Guidance for School Year 2021-22 which indicated that CACFP at-risk meals can only be claimed for reimbursement on days when an afterschool program is provided. As an example, the guidance indicated that a 7-day meals bundle would not be an allowable use of the flexibilities if the afterschool care program is only provided for 2 days a week. Additionally, in that same memo, MDE indicated that it was expected that USDA expects that CACFR operators follow the lead of schools to discontinue use of noncongregate meal waivers once it is safe for children to return to school in each community. Condition: The Organization purchased meals from a vendor that delivered meals to homes of participating children. There was not documentation of delivery of meals, such as delivery logs, schedule of deliveries, etc. to support the number of meals actually delivered, but rather an invoice showing the total meal number. Meals on the provided invoices included seven day meal bundles which were also not allowed under the program guidance as the afterschool programs were not provided all seven days. In addition, the site application submitted by the sponsor organization indicated that meals were served on site, when they were not. Schools resumed in-person learning in September of 2021, but noncongregate meals were provided by the Organization from September-December of 2021 instead of on-site congregate meals. Questioned costs: Reimbursed meals for 2021 totaled $2,736,462, which did not contain evidence of delivery of meals by the vendor. Context: Between February-December of 2021, the Organization was reimbursed by its sponsor organization for approximately 574,000 meals, totaling $2,736,462, which consisted of seven day meal bundles delivered by the vendor. There was no supporting documentation related to delivery of meals by the vendor, other than a weekly invoice indicating the number of meals. The contract with the vendor also did not specify delivery arrangements, pricing, or other relevant details. Meal bundles containing seven days of a supper/snack were provided which was also not allowed. Cause: The Organization’s management indicated it was not told by the sponsor organization to maintain documentation supporting delivery of meals; management also indicated they did not receive guidance from their sponsor on seven day meal bundles not being allowed, or discontinuance of noncongregate meals in the fall of 2021. Effect: A lack of sufficient documentation exists related to the delivery of meals. Meals and snacks were reimbursed to the Organization from federal funds related to meals and snacks provided on days that were not allowable. Recommendation: We recommend the Organization attend training, review federal requirements, and fully understand the documentation and meal requirements of the program if they apply for funding with this program again. Views of responsible officials: This program was initiated during the height of COVID, when guidelines on both state and federal levels were changing rapidly. Management provided auditors with documentation for participation in the meal program. Documentation included participant names that were printed and/or written in cursive as is customary for the served population. The printed names were not considered signatures and rejected by the auditors. Management attended all trainings provided by the sponsor organization and followed all of the program sponsor guidelines. See the Corrective Action Plan for further details.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 Pass-Through Agency: Feeding Our Future Award Period: February 2021 – December 2021 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Adverse Opinion) Criteria or specific requirement: Nonfederal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations. Under these procurement standards, there must be written standards of conduct for employees involved in contracting, procurement transactions must be conducted in a manner providing full and open competition, and certain methods must be followed for soliciting bids or pricing. Additionally, under 2 CFR Part 180, which implements Executive Orders 12549 and 12689, nonfederal entities are prohibited from contracting with parties that are suspended or debarred and must follow certain procedures to verify that an entity is not suspended or debarred when it enters into a contract. Condition: The Organization does not have a procurement policy which complies with procurement requirements noted above. The organization did not have documentation supporting the selection of the vendors used for the program. Procurements did not provide full and open competition. There were not procedures to verify that an entity was not debarred, suspended, or otherwise excluded. Additionally, contracts did not contain required elements, such as pricing, type of meals, delivery, and schedule. The contract utilized for the largest vendor was very brief and did not follow the template contract that the State of Minnesota recommends. Questioned costs: Unknown Context: There were three vendors utilized for food purchases in the following amounts: (1) $2,276,877; (2) $325,801; and (3) $254,843. For all three vendors, no procurement or suspension and debarment procedures were performed. Cause: The Organization was not aware it was required to perform procurement or suspension and debarment procedures. Management indicated the contracting processes used were approved by its sponsor organization. Effect: It is unclear if the Organization received competitive pricing for its federal grant purchases. The auditors verified that vendors were not listed as suspended or debarred. Recommendation: We recommend the Organization familiarize itself with the procurement regulations prior to entering into any future federal grants and review state and federal guidance. Views of responsible officials: This program was initiated during the height of COVID, when guidelines on both state and federal levels were changing rapidly. Management provided auditors with documentation about vendors that had been approved by the sponsor organization. Management attended all trainings provided by the sponsor organization and followed all of the program sponsor guidelines. See the Corrective Action Plan for further details.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Child and Adult Care Food Program Assistance Listing Number: 10.558 Pass-Through Agency: Feeding Our Future Award Period: February 2021 – December 2021 Type of Finding: • Material Weakness in Internal Control over Compliance Criteria or specific requirement: 2 CFR section 200.303(a) requires that nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal Statutes, regulations, and the terms and conditions of the Federal award. Condition: Each month, the Organization provided a packet to the sponsor organization, Feeding Our Future, which contained detailed meal count sheets with names and ages of children receiving meals and days received, Clicker Reports summarizing the meal counts, and invoices from the vendor. Meal count sheets in many cases were not specifically labeled as to the month they related to, but management indicated they were part of the monthly submission. In our review of the packets we noted numerous discrepancies between the meal count sheets and Clicker reports. Meal count sheets for the year were higher than Clicker reports by approximately 43,000 meals. Questioned costs: None Context: We tested all monthly submissions for the St. Paul site from March-June and all monthly submissions for the St. Paul and St. Cloud sites from September-December, noting variances every month. Cause: Management indicated that discrepancies between meal count sheets and Clicker reports were due to items returned to the vendor by families. There was no documentation of returned items, and reports were adjusted based on phone conversations with the vendor. Effect: Clicker reports submitted for reimbursement are not in agreement with supporting documentation. There are no questioned costs related to this, since the Clicker reports were used for reimbursement and were lower than the meal count sheets. UpRecommendation: We recommend the Organization retain clear documentation of meal count sheets, including labeling of the particular month they relate to. We also recommend the Organization reconcile the meal count sheets with the clicker reports, and retain specific documentation as to the variances. Views of responsible officials: This program was initiated during the height of COVID, when guidelines on both state and federal levels were changing rapidly. Management provided auditors with documentation that had been approved by the sponsor organization. Management performed all activities requested by the sponsor organization and followed all the program sponsor guidelines. See the Corrective Action Plan for further details.