Audits/Reviews

1. Audits/Reviews 2013 Summer Food Service Program March 19, 2013

2. Reviews Part II, Chapter 6 - Pages 94-95

3. A-133 Audit • Governmental or non-profit entity that expends $500,000 or more in Federal awards during its fiscal year period and receives funding from more than one type of Federal program • Must submit an organization-wide A-133 audit • Sponsor that expends $500,000 or more and has only one Federal program • May submit a program specific audit

4. A-133 Audit - Report • Should be submitted as part of the application process • Due to the State Department of Education within 30 days after issuance of report or no later than 9 months after the end of the fiscal year • Must identify Federal awards by CFDA number in the required Schedule of Expenditures of Federal Awards (SEFA) • CFDA number for Summer Food Service Program for Children is 10.559

5. A-133 Audit – Review Process • Audit is reviewed by State Agency (SA) staff for compliance. • Corrective action plan is requested for findings or questionable costs. • If required, Sponsor must submit corrective action plan to participate in SFSP. • Sponsor cannot participate or receive final reimbursement without an A-133 audit.

6. Administrative Review – Selection Process

7. Adminstrative Review - Purpose Unannounced reviews to ensure: • Financial operations are conducted properly • Financial statement/reports are correct • Expenditures of program funds comply with applicable laws and regulations • Internal procedures meet the objectives of federally assisted programs

8. Administrative Review

9. Administrative Review Records needed: • SFSP Application • Documentation of training and monitoring • Inventory records, meal production records and menus • Documentation of reimbursement for all program costs • Meal benefit eligibility forms, if applicable • Daily meal count records and the Sponsor’s consolidation count • Documentation of racial and ethnic data • Documentation of media release

10. Administrative Review - Sponsor Review Program Costs – Operating and Administrative • Review receipts, invoices, payroll documents, mileage reports, and canceled checks • Review checking account and/or fund statements and reports • Determine if costs are allowable, allocated correctly, and reasonable

11. Administrative Review - Sponsor Review • Monitoring • Pre-Operational Visit – Required for new and problem sites • First Week Visit – Can be waived for experienced sponsors with experienced site staff • Four Week Visit – Required for all sites • Training • ALL site personnel must be trained before taking on responsibilities • Adequate documentation must be available for review to include topic, date and name of attendees

12. Administrative Review – Sponsor / Site Review • Meal Count Records • Daily tally sheet for open sites • Weekly roster for enrolled children – closed enrolled and camps • Documentation of counts for first meals, second meals, test meals, excess meals, and adult meals • Consolidate Weekly and Monthly Meal Count Records

13. Administrative Review - Site Review

14. Adminstrative Review - Site Review • Counting and Claiming Meals • Cannot Claim Reimbursement for Meals Served: • To any child who is not enrolled at the site (closed enrolled) • To ineligible participants at camp • In excess of the approved level of meal service (CAP) • In excess of the two meals per day (or 3 meals a day for migrant and camp programs) • Outside the approved meal service times • At unapproved locations • In the temperature danger zone

15. Adminstrative Review - Site Review • Counting and Claiming Meals, continue • Cannot Claim Reimbursement for: • Meal types not approved by the SA • Meal pattern requirements not followed

16. Administrative Review – Findings • Review/Audit with deficiencies must submit a corrective action plan • Failure to submit a corrective action plan could result in termination

17. Review/Audit – Serious Deficiency Serious Deficiency (SD) can occur during • Application Review • A-133 Audit Review • Administrative Review Two critical factors: Frequency and Severity • Severity • Negligence • Fraud • Frequency: How often does the error/problem occur? • Isolated error • Systemic problem

18. Review/Audit – Serious Deficiency Serious Deficiency (SD) • Fully describe the SDs • Outcome of corrective action • Corrective action deadline • Identify the Responsible Principals (RP) / Responsible Individuals(RI) • Sponsor is determined SD • Persons who caused the SD are RP/RIs

19. Review/Audit – Serious Deficiency SD includes, but not limited to: • Noncompliance with application bid procedures and contract requirements of Federal CNP • Submission of false information to the SA • Failure to return to the SA advance payments which exceeded reimbursement • Program Violations • Noncompliance with the meal service time restrictions • Failure to maintain adequate records

20. Review/Audit – Serious Deficiency • Program Violations • Failure to adjust meal orders to conform with changing participation • Simultaneous service of greater than one meal to any child • Claiming of meals not served to children • Service of meals that do not meet program requirements • Excessive instances of off site consumption • Continued use of FSMC in violation of health codes • Any other violation of program requirements

21. Review/Audit – Serious Deficiency SD Process • Sponsor declared SD • Opportunity for corrective action • Incomplete corrective action • Termination of agreement by SA • Disqualification is primary consequence of termination – Placement of RP/RIs on State DQ List • Appeal of Termination and Disqualification

22. Review/Audit – Serious Deficiency • Appeal of Termination and Disqualification • Sponsors may continue to operate the program and maintain adequate documentation during an appeal of termination • Program payments will not continue during appeal • Voluntary termination = Disqualification • Two Possibilities • Sponsor wins – retroactive reimbursement for meals • SA wins – reimbursement will not be paid

23. Carolyn Rhodes Phone : (334) 242-8224 Email: crhodes@alsde.edu