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ARRA Monitoring Training

ARRA Monitoring Training. Iowa WIC Compliance May 3, 2010. Vendor Monitoring. Before Approval After Approval Electronic On-site Routine Compliance Buys Inventory Audits. Before Approval. Review Application – paper form Confirm information Food Supplier, other State and Federal.

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ARRA Monitoring Training

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  1. ARRA Monitoring Training Iowa WIC Compliance May 3, 2010

  2. Vendor Monitoring • Before Approval • After Approval • Electronic • On-site • Routine • Compliance Buys • Inventory Audits

  3. Before Approval • Review Application – paper form • Confirm information • Food Supplier, other State and Federal

  4. Monitoring • Electronic • Monitor activities • Inventory Audit • Actual Count • On-Site

  5. Agency Monitoring • On-site agency reviews • Office visit • Clinic visit • Administrative visit • Financial review

  6. Agency Office Visit • Completed by nutrition consultant • Every 2 years, opposite of administrative visit • Review of programs related to service delivery and outreach • Audit clinic service records

  7. Agency Clinic Visit • Monitor quality of services • Evaluate adequacy • Completed by nutrition consultant • Yearly

  8. Administrative Visit • Review of administrative and personnel policies • Compliance with civil rights • Evaluation of: • Property management • Fiscal control measures • Documentation of expenditures • Completed by program planner • Every 2 years, opposite of office visit and financial review

  9. Financial Review • Completed by internal auditor • Every 2 years, opposite of administrative visit • Review recent audit findings, purchasing and inventory controls • Evaluate: • Fiscal policies • Fiscal control measures • Expenditures and documentation

  10. Routine Store Monitoring Routine - store notified at time of visit • Required by Federal or Program Guidelines • WIC requires 5% of all authorized vendors • Selection Criteria

  11. Compliance Monitoring • Compliance – Covert -- store not notified until close of investigation. • Required by Federal or Program Guidelines • WIC requires 5% of all authorized vendors • Selection Criteria

  12. Documentation • Complete Records • Paper and Electronic • Record buy/purchase • Disposal of products

  13. Disposal of Product • Documentation of disposal • Description of product • Quantity • Value • Date and Time of disposal • Person delivering and person accepting product • Signed – Dated document

  14. Sanctions – Vendor and Participant • Violation (point or fine system) • Disqualification • Reciprocal Agreements – other agencies • Civil Money Penalty • Formula for calculation • Establish sanctions and be consistent

  15. Other Compliance Methods • Staff conflict of interest • Separation of duties • Fraud and abuse data collection • Comment cards • General conditions posted to IDPH website

  16. Deviations - Indicators • Deviations • Program Guidelines – Federal / State • Required monitoring • Indicators • Complaints • Reciprocal Agreements • Frequency

  17. Encourage Compliance • Establish Rapport • Believability • Be Consistent • Follow-through • Reciprocal Agreements • Network with other agencies/states

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