Transcript OVERVIEW OF THE CHILD NUTRITION PROGRAMS (CNP)

SUBGRANTEE
MONITORING &
OVERSIGHT IN THE CHILD
NUTRITION PROGRAMS
(CNP)
School Nutrition Association
USDA/State Agency Conference
Nashville, Tennessee
November 27, 2007
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
TOPICS TO BE COVERED
• Importance of Monitoring &
Oversight
• State Agency’s Arsenal of
Monitoring Tools
• Summary of Monitoring
Accountability Issues
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
IMPORTANCE OF MONITORING &
OVERSIGHT
• BACKGROUND: WHY STATE
AGENCY OVERSIGHT IS
NEEDED
– Program benefits delivered at
subgrantee level.
– Results in obligation of Federal
funds ($12 billion in FFY 2006).
– States disburse Federal funds
to numerous entities.
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
IMPORTANCE OF MONITORING &
OVERSIGHT
• Federal CNP funds pass
through many hands:
– 101,000 schools & RCCIs under
21,000 SFAs
– 20,000 CACFP child and adult
day care center sponsors
– 49,000 child and adult day care
centers (sponsored and
independent)
– 152,000 FDCHs under 1,000
FDCH sponsors
– 30,000 SFSP feeding sites
under 3,700 sponsors
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
IMPORTANCE OF MONITORING &
OVERSIGHT
• Many opportunities for
error and irregularities
• Need to keep all those
subgrantees out of trouble
• Subgrantee monitoring by
State agency our first line
of defense
• Arsenal of State agency
monitoring tools
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
A STATE AGENCY’S ARSENAL
OF MONITORING TOOLS
– Screening
– Training & Technical
Assistance
– Data Analysis
– A-133 Audits
– Administrative
Reviews
– Agreed-Upon
Procedures (AUP)
Engagements
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• SCREENING:
– Gathering information
to determine:
• Eligibility for CNP Subgrant
– Example: to determine that
NSLP/SBP applicant is a
“school”
• Future Monitoring Needs
– Example: other sources of
Federal funding
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• TRAINING &
TECHNICAL
ASSISTANCE
– Required by
regulation
– Instruct
subgrantees on
program
requirements
– Never ending job
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• DATA ANALYSIS
– Regulations require analysis of
subgrantees’ claims for reimbursement.
– NSLP Regulations require one specific edit
check: Free & reduced price meals claimed vs.
number of children determined income eligible in
October times days of operation times an
attendance factor.
– We suggest additional edit checks, such as:
• Total meals claimed vs. enrollment or average daily
attendance
• Types of meals claimed vs. types approved in
subgrant agreement
• Etc.
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• A-133 AUDITS:
– State agency must:
• Identify subgrantees subject to
A-133 audits
• Make sure they get required
audit coverage
• Follow-up on audit results
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• A-133 AUDIT ISSUES:
– Identifying subgrantees subject to A133
– CACFP for-profit institutions
• Not under A-133
– CACFP 1-1/2 Percent Audit Funds
• Audits of institutions
• Other program integrity costs after
audit requirements met
– CNP in audit planning and reporting
• CN Cluster and CACFP
• Treatment of commodity assistance
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
ADMINISTRATIVE
REVIEWS
–
–
–
–
Site visits by State agency staff
Required by regulation
Differ from audits
Complement to audits:
• “Real time”
• Cover compliance requirements
not tested by auditors
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF
MONITORING TOOLS
• AGREED-UPON PROCEDURES:
–
–
–
–
Authorized by A-133/Part 3052
Only for subgrantees not subject to A-133
Scope set by A-133
State agency must arrange and pay for
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
SUMMARY OF MONITORING ISSUES
• Identify subgrants to
subgrantees by
program & CFDA
• Screen applicants for
subgrants
• Provide training &
technical assistance
• Analyze claims before
paying
• Make required
administrative reviews
• Make other on-site
visits as needed
• Identify subgrantees
subject to A-133
• Make sure subgrantees
get required audits
• Use agreed-upon
procedures correctly
• Follow-up on results of
audits, reviews, etc.
• Establish and collect
claims
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
CONCLUSION
• NEED STRONG SUBGRANTEE MONITORING
PROGRAM
• TO GET MORE INFORMATION
• QUESTIONS & ANSWERS