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Institution Eligibility. Goals of Eligibility Requirements. New institutions: Meet program requirements Fully capable of operating  Existing institutions: Application renewal as a tool to evaluate performance. Eligibility Requirements Before and After ARPA.

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Institution Eligibility

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Institution eligibility

Institution Eligibility

Goals of eligibility requirements

Goals of Eligibility Requirements

  • New institutions:

    • Meet program requirements

    • Fully capable of operating

  •  Existing institutions:

    • Application renewal as a tool to evaluate performance

Eligibility requirements before and after arpa

Eligibility Requirements Before and After ARPA

  • Before - institutions responsible for management of effective food service

  • Before - SA determined institution’s capability

  • After - new eligibility requirements based on OIG audits and other reviews

Review of terminology

Review of Terminology

  • Institution signs agreement with SA

    • Independent centers

    • Sponsors

  • Facility is a home or a sponsored center

Outside employment

Outside Employment

“The policy must restrict other employment by employees that interferes with an employee’s performance of program-related duties and responsibilities….”

Outside employment1

Outside Employment

  • Cannot interfere with program duties

  • Cannot be a real/apparent conflict of interest

Past performance

Past Performance

Should the SA become a Private Investigator?




  • All info true and correct

  • Past performance

    • Publicly funded programs

    • Criminal conviction

Publicly funded programs

Publicly Funded Programs

  • List Federal, State or local programs in past 7 years

  • Indicate if institution or principals declared ineligible

  • Or show that restored to full participation

  • SA follow up on information

Criminal convictions

Criminal Convictions

  • Convictions during past 7 years

  • Criminal convictions only

    • Consult State legal council if in doubt

  • Include both institution and principals

National disqualified list

National Disqualified List

  • SA’s check: institutions, principals and facilities 

  • Institutions check: principals

  • Sponsors check: facilities and principals

  • Abbreviated appeal

Name address and dob

Name, Address and DOB

  • Executive Director and Chairman of Board on an institution application

Name address and dob con t

Name, Address and DOB (con’t)

  • Issue #1: Similar or identical names?

    As more names added to the list…..

    = Need for Date of Birth to be included

Name address and dob con t1

Name, Address and DOB (con’t)

  • Issue #2: Refusal to provide information?

    • For Institutions = Not a complete application

Why performance standards

Why Performance Standards?

  • Viability, Capability and Accountability (VCA)

  • Use as evaluation tool

  • No more checklists

  • Compare application content to performance standards

Standard 1 financial viability and financial management

Standard 1: Financial Viability and Financial Management

  • Institution is financially viable

  • Institution will make proper expenditures

    • Nonprofit food service funds only for allowable costs

    • Nonprofit food service funds restricted

  • All employees with FM responsibility are aware of procedures

How to document compliance

How to Document Compliance

  • Institutions—budget and management plan

How much detail

How Much Detail?

“too little” “too much”

Financial viability

Financial Viability

  • Resources

  • Program reimbursements

    • Grants and loans

    • Donations

    • Other Federal funds if permitted

    • For-profit subsidiary

Financial viability recap

Financial Viability: Recap

  • All resources

  • Assets/liabilities

  • Budget/proper expenditures

  • Size/nature of program

  • History

Performance standard 2 administrative capability

Performance Standard 2: Administrative Capability

  • Adequate, qualified staff

  • For sponsors:

    • Policies and procedures

    • Job descriptions

    • Budget/management plan

    • Staffing standards for monitoring

Performance standard 3 internal controls for accountability

Performance Standard 3: Internal Controls for Accountability

  • Board of Directors (nonprofits)

  • Financial management system with written controls (all institutions)

  • Recordkeeping system (all institutions)

Responsibilities of boards of directors

Responsibilities of Boards of Directors

  • Determining institution’s mission and purpose

  • Ensuring compliance with regulatory requirements

  • Selection and evaluation of the Executive Director

  • Regular training on Program

More accountability controls

More Accountability Controls

  • Factors to be looked at for ALL institutions:

    • Financial controls ensuring proper use of funds and detect improper activities

    • Records documenting compliance with financial rules

Accountability controls for sponsors

Accountability Controls for Sponsors

  • Sponsor staff & facility training

  • Monitoring

  • Compliance with admin cost limits

  • Facility compliance with meal pattern, other requirements

If performance standards not met

If Performance Standards Not Met

  • Must deny application

  • Provide opportunity for appeal

Summary of vca

Summary of VCA

  • Viable, capable and accountable

  • Evaluate against standards

  • Deny if fail to demonstrate

Institution eligibility1

Institution Eligibility

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