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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

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
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


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.


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


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


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


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


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


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.


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


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


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


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


Subgrantee monitoring oversight in the child nutrition programs cnp summary of monitoring issues

Identify subgrants to subgrantees by program & CFDA Programs (CNP)

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


Subgrantee monitoring oversight in the child nutrition programs cnp conclusion
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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