Neighborhood Food Environments Program Grant Compliance

Fresh produce in a shopping cart.

Objective

To determine whether the Denver Department of Public Health and Environment is complying with expenditure requirements under the state grant-funded Neighborhood Food Environments Program and whether the department properly reported grant expenditures to the grant governing authority and sufficiently monitored grant subrecipients.

Background

The Neighborhood Food Environments Program is intended to advance policy changes that increase targeted neighborhoods’ access to healthy food. The city receives its grant funding from the state and partners with Jefferson County Public Health and the Tri-County Health Department to address food environment-related policies and practices from a regional approach.

Why this matters

Noncompliance with state grant documentation and oversight requirements jeopardizes both the city’s future state funding for the Neighborhood Food Environments Program and its goal of increasing Denver residents’ equitable access to healthy and affordable foods.

Findings

Finding 1 -  Selected Expense Transactions Appear Eligible for Neighborhood Food Environments Program Grant Funding but Some Lack Complete Supporting Documentation

Ten — or 37% — of 27 expenses we tested were missing some form of documentation required by the state. Seven of those were missing travel-related documentation.

Finding 2 - The Denver Department of Public Health and Environment Did Not Sufficiently Monitor Subrecipients’ Expenditures

The department does not have formal processes for reviewing invoices on a detailed level, which led to subrecipients not maintaining sufficient documentation for grant expenditures in accordance with grant requirements. We could not determine eligibility for one grant expenditure because of the lack of documentation.

In addition, the department never completed the city’s required worksheet to determine the subrecipient statuses of Jefferson County Public Health and the Tri-County Health Department.

Recommendations

1.1 Develop Mileage Policy – The Denver Department of Public Health and Environment should develop and implement a policy and procedure for mileage related to the Neighborhood Food Environments Program. The policy and procedure should meet the state’s travel documentation requirements laid out in the invoice documentation checklist. The department should also include Fiscal Accountability Rule 10.7 in this new policy.

Agency Response: Agree, Implementation Date – January 31, 2022

1.2 Develop Documentation Requirements  – The Denver Department of Public Health and Environment should develop and implement policies and procedures for documentation requirements based on the guidance provided by the state’s invoice documentation checklist and the agreement for the state grant that pays for the Neighborhood Food Environments Program.

Agency Response: Agree, Implementation Date – June 30, 2022 

1.3 Develop Documentation Retention Training –  The Denver Department of Public Health and Environment should develop and conduct a training to teach new grant staff about documentation requirements for the Neighborhood Food Environments Program.

 Agency Response: Agree, Implementation Date – June 30, 2022 

1.4 Develop Grant Gift Card Policy  –  The Denver Department of Public Health and Environment should develop and implement a specific policy and procedure for gift cards that meet the state’s requirements as listed in the agreement for the state grant that pays for the Neighborhood Food Environments Program.

Agency Response: Agree, Implementation Date –  January 31, 2022

2.1 Develop Subrecipient Review Process  –  The Denver Department of Public Health and Environment should develop and implement procedures for a formal review of subrecipient invoices on a detailed level — such as a monthly spot-check procedure — to ensure the Neighborhood Food Environments Program meets state documentation requirements.

Agency Response: Agree, Implementation Date –  June 30, 2022 

2.2 Develop Grant-Specific Training – The Denver Department of Public Health and Environment should develop and implement procedures to ensure staff in the Neighborhood Food Environments Program are periodically and consistently trained on required subrecipient monitoring.

Agency Response: Agree, Implementation Date –  June 30, 2022 

2.3 Define Other Departments’ Subrecipient Monitoring Responsibilities – The Denver Department of Public Health and Environment should develop and implement policies and procedures on the roles and responsibilities of city agencies that are integral to administering the Neighborhood Food Environments Program, including the Department of Finance. Policies and procedures for the Department of Finance should include processes for monitoring subrecipients’ indirect rates.

Agency Response: Agree, Implementation Date –  June 30, 2022 

2.4 Complete Required Worksheet – The Denver Department of Public Health and Environment should complete the “Subrecipient vs. Contractor” worksheet — as required by Fiscal Accountability Rule 9.2 — to determine whether Jefferson County Public Health and the Tri-County Health Department are subrecipients of the Neighborhood Food Environments Program. The department should then retain the documentation of its decision.

Agency Response: Agree, Implementation Date –  June 30, 2022 

Auditor's Letter

January 20, 2022

The objective of our audit of the Neighborhood Food Environments Program — funded by a state grant from the Colorado Department of Public Health and Environment and administered by the Denver Department of Public Health and Environment — was to determine the city’s compliance with state grant regulations. I am pleased to present the results of this audit.

The audit did not identify unallowed grant expenditures. However, some documentation did not comply with grant regulations. Furthermore, the Denver Department of Public Health and Environment has an unreliable process for monitoring subrecipients, which led to some documentation not meeting grant requirements. We also found the department has not completed the city’s worksheet for determining whether Jefferson County Public Health and the Tri-County Health Department were subrecipients of grant funding.

By implementing recommendations for stronger controls over grant-required documentation and subrecipient monitoring, the Denver Department of Public Health and Environment will be better equipped to ensure the city complies with grant requirements.

This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, “General Powers and Duties of Auditor.” We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

We extend our appreciation to the personnel in the Denver Department of Public Health and Environment and the Department of Finance who assisted and cooperated with us during the audit. For any questions, please feel free to contact me at 720-913-5000.

Denver Auditor,

Auditor's Signature
Timothy O'Brien, CPA

Follow-up report

A follow-up report is forthcoming. 


Timothy O'Brien Official Headshot

AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor


Denver Auditor´s Office

201 W. Colfax Ave. #705 Denver, CO 80202
Emailauditor@denvergov.org
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