190 likes | 300 Views
15% Cap. Why the Cap is Necessary. Center reimbursement covers admin. & operating costs (like school meal rates) More $ kept for admin = less $ for meals “ Retained ” means the amount of money the sponsor keeps for its admin. costs
E N D
Why the Cap is Necessary • Center reimbursement covers admin. & operating costs (like school meal rates) • More $ kept for admin = less $ for meals • “Retained” means the amount of money the sponsor keeps for its admin. costs • Audits/reviews found 25-30% approved with even more retained • 15% consistent with school meal program admin costs
What the Interim Rule Does Applies cap to: Approved budget estimate Actual retention during the year
Objective of the Interim Rule 15% 85%
Cap Applies to All Types of Sponsored Centers • Nonprofit sponsors • For-profit sponsors • Public sponsors • Sponsors of unaffiliated centers • Sponsors of affiliated centers
Administrative Costs Planning Organizing Managing Operating Costs Food costs Food service labor Food service supplies Administrative & Operating Costs
Center Sponsor Administrative Costs • Claims preparation • F/RP eligibility determinations • Monitoring • Training Must conform to 796-2
Suggestion or Goal? The cap is not a: Suggestion Goal Guarantee Floor (minimum)
Mandate The cap is a: Ceiling (maximum) Applies to all administrative costs at the sponsor and sponsored center level
Sponsored Center Administrative Costs Included in the cap because: • Law limits the amount of CACFP funds retained for administrative costs - not who pays the costs • Not including sponsored center admin. costs = incentive to shift costs to evade cap
How the Cap Works: Budgets Sponsor must report all admin. costs on budget • Including all sponsored center administrative costs • SAs must revise application budget documents for center sponsors to capture all admin. costs
How the Cap Works: Monthly Retention Three factors: • Amount of reimbursement actually earned • Annual limit of 15 percent • Cannot exceed monthly allowable costs
How the Cap Works:Sponsor Responsibilities Sponsors must: • Monitor monthly retention on year-to-date basis • Monitor actual vs. projected reimbursement earnings • Adjust retention to stay within “cap”
Retention Question Question: Is a sponsor prohibited from retaining more than 15% in a month? Answer: No. Sponsors can vary recovery of monthly amounts, but cannot retain more than 15% for the year.
Example 1:ABC Center Sponsor Retention October (1st month budget year) Reimbursement ($13,200) earned X 15%: $ 1,980 Actual admin costs & retention: $ 4,486 Approved budget = $ 22,500 Actual expenses - $ 4,486 Available for remainder of year = $ 18,014
Key Considerations • Sponsors & SA must track actual admin. costs • Time major expenditures throughout the year
Mistakes, Errors & Misconduct Problem: Sponsor retains more than approved Resolution: ID causes, require corrective action • Restore funds to sponsored centers or CNP Account • Improve fiscal procedures • Escalate SA oversight Serious deficiency when appropriate
Recap State agencies: • Apply 15% cap to budgets • Monitor retention practices of sponsors Center sponsors: • Prepare budgets that reflect 15% cap • Establish internal controls to ensure proper retention • Maintain records to demonstrate compliance