Lutheran Social Services of Nevada

Criteria: In accordance with 2 CFR 200.303, a non-federal entity must maintain an effective system of internal controls over compliance for federal awards that provides reasonable assurance that the non-federal entity is managing the award in compliance with federal statutes, regulations, and the terms and condition of the federal award. Condition: During our audit, we discovered that management had not implemented an effective system of internal controls over compliance related to the federal award. Specifically, food commodities received under the federal award were not warehoused and tracked in accordance with award terms, and management was unable to produce a listing of participants who received distributions of federal food commodities. Cause: The majority of federal awards received by the Organization are cash reimbursement grants. The food commodities received by the Organization under the federal award program are not usual or routine and, as a result, the internal controls over compliance with federal award programs were not appropriately designed. Effect: Management was unable to substantiate compliance with warehousing requirements. Further, management was unable to determine whether only eligible individuals/households received federal food commodities as allowable under the federal award. Perspective Information: The deficiencies noted appear to be indicative of a systemic issue related to the internal controls over compliance related to noncash federal award programs (e.g., food commodities). Questioned Costs: Unable to be determined. Repeat Finding: No Recommendation: We recommend the Organization design and implement and effective system of internal controls over compliance for all federal award programs. This system should include consideration for those noncash federal awards that may need to be considered. View of Responsible Officials: The Organization will design and implement a system of effective internal controls over compliance that will take into consideration all federal award program, to include noncash awards.

Lutheran Social Services of Nevada (LSSN) acknowledges the findings from the audit conducted on the year ending June 30, 2020. LSSN is taking the necessary steps to ensure compliance according to the guidelines stated during the audit. The following actions are in the process of implementation at the transcribing of this corrective action plan. In accordance with 2 CPR 200.511 (c), we have prepared a corrective action plan for the audit finding including in the audit report. 2020-001: Corrective Action Plan ? To ensure internal controls over compliance is met, LSSN has designated a team member as the Strategic Programming and Partnership Director. This position will ensure compliance to program rules and regulations in relation to the grants LSSN receive from the multiple grantors. ? To ensure the proper accountability and distribution of The Emergency Food Assistance Program items, LSSN will designate/identify those items on the shelves and refrigerated areas to have visible identification of the items in relation to donated items received by LSSN. ? LSSN will strongly implement and follow the guidelines for qualifying individuals and families for the services provided. The appropriate paperwork will be completed (with COVID-19 acceptable guidelines being approved for use) for each household that receives service. ? Upon conclusion of a month, LSSN will conduct inventory and spot audit of client information to ensure compliance is met for The Emergency Food Assistance Program. Proper documentation of noncash awards will be review by the Strategic Programming and Partnership Director for adherence to grant regulations. ? LSSN will track and record any findings from the monthly audits and correct the issues in a timely manner. LSSN's goal with the plan above will ensure that the information provided during and audit is accurate with proof of accountability for items from The Emergency Food Assistance Program. This process will also have oversight provided by the Assistant Executive Director.