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SUBGRANTEE MONITORING & OVERSIGHT IN 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.

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SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP)

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  1. SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP) School Nutrition Association USDA/State Agency Conference Nashville, Tennessee November 27, 2007

  2. 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

  3. 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.

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

  9. 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.

  10. 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

  11. Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)STATE AGENCY’s ARSENAL OF MONITORING TOOLS • A-133 AUDIT ISSUES: • Identifying subgrantees subject to A-133 • 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

  12. 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

  13. 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

  14. 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)SUMMARY OF MONITORING ISSUES

  15. Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)CONCLUSION • NEED STRONG SUBGRANTEE MONITORING PROGRAM • TO GET MORE INFORMATION • QUESTIONS & ANSWERS

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