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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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Presentation Transcript
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