FDPIR Management Evaluations Tammy Larma Lead Program Specialist Midwest Regional Office-Chicago, IL

Goal Purpose of the ME Process Timeline What to expect Common Findings

Differences Several factors might result in slight variations in the ME process between ITOs. Size of the FDPIR program Multiple distribution sites or warehouses, participants served Accessibility to ITO Drive time Lodging Funding Staffing Program needs

Similarities National Management Evaluation Guidance FDPIR Management Evaluation Module http://www.fns.usda.gov/fdpir-management-evaluation-module

New Program Integrity and Monitoring Branch Monitor MEs for trends: Need for additional training Technical assistance Change or develop policies or procedures

Purpose of the ME Ensure compliance with Federal Regulations and other guidance materials. Identify needs for technical assistance Share best practices

Format Most MEs are conducted on-site with a desk review of some documents and/or case files prior to the on-site portion. There can also be follow-up conference calls or site visits as needed. Some MEs may be conducted as “focused” MEs and consist of a desk review of case files or other documentation.

Timeline > 30 days before on-site review: On-site review Notify State Agency/ITO of ME Requested documents/questionnaire due to RO On-site review Typically 1-5 days 60 days after on-site review or exit conference: Report due to SA/ITO 60 days after ITO/SA receives ME report: SA/ITO’s initial corrective action response due to RO

Timeline continued… Corrective Action negotiation continues until RO accepts Corrective Action Plan (CAP) When CAP is accepted, RO must also verify that the actions have taken place. ME will remain open/in progress until corrective actions have been verified. RO sends closure letter

Process: Pre-site Review Negotiate schedule for review Send official notification letter Request any documents needed for pre-site review, which may include: Case Files Plan of Operation Self-Assessment Questionnaire Equipment List

Process: On-Site Review Reviewers use the FDPIR ME modules and program’s Plan of Operation to guide the review Entrance Conference Interview: Program director Financial/grants management staff Other staff as needed (i.e.: warehouse, certifiers) Inspect: Condition of the warehouse Temperature logs Food storage organization

Process – On-Site Review continued… Review and verify: Case files (claims, fair hearings, denied cases) Equipment list Training materials and other records Other administrative procedures and documents Observe (when possible): Distribution (including Tailgate, if applicable) Certification appointments Inventory procedures Exit Conference Discussion on potential findings and observations

How to Prepare The best way to prepare for an ME is to complete an annual self-assessment and ongoing monitoring of your program Use the FNS FDPIR ME module to anticipate what reviewers look for and request: http://www.fns.usda.gov/fdpir-management-evaluation-module

Tips Invite all interested parties to the entrance conference Share any cultural tips or etiquette that you want reviewers to know Have documents organized and ready for review Hold a brief meeting to introduce reviewers to help put your staff at ease Be prepared to share best practices and ideas

ME Report – What to Expect Executive summary Noteworthy initiatives: May include best practices that exceed regulatory requirements. Findings: Identification of non-compliance with program regulations, policies, and procedures. Required Corrective Actions: Actions that must be taken to change or improve operational effectiveness and correct non-compliance.

ME Report - What to Expect continued… Observations: Identification of a weakness involving management practices or unregulated activity. Suggestions: Actions that address observations made in the ME- may not be required under the regulations but should be taken to improve program operations and management.

Common ME Findings – Plan of Operations The Plan of Operation must be in compliance with FNS regulations. The program must be in compliance with its Plan of Operation. Not up-to-date with FNS policies that have changed Does not reflect current program operations

Common ME Findings - Staffing There are limitations to the type of staff who may perform certification functions. Volunteers used inappropriately Staff who work on multiple programs or non-FDPIR activities do not correctly allocate time for budget purposes

Common ME Findings – Records and Reports Late reports Records not kept for required 3 year time period/inaccessible Equipment list not kept or missing required information

Common ME Findings – Inventory Control Outdated product in inventory FNS-152 reports show frequent losses and gains Food losses not adequately tracked Excessive or inadequate inventory

Common ME Findings - Warehousing Warehouse must be clean, temperature-controlled, and protect against the elements, infestation, and theft. USDA Foods were improperly stored with no space separation; with non-food items; or with non-USDA Foods Temperature logs were not being kept Sanitation/health inspections of the warehouse are not up-to-date

Common ME Findings - Eligibility Case files do not contain adequate documentation Income deductions are applied incorrectly Two-year certification periods incorrectly assigned Common errors in case files Conversion factors or earned income deduction incorrectly applied or not used when necessary Application and Notice of Decision do not contain required information

Common ME Findings – Nutrition Education & Outreach Public notification system (e.g., brochures, bulletins, leaflets, letters, newspapers, etc.) to inform potentially eligible persons, is not effective/inadequate No records of nutrition education activities held at the ITO warehouse/tailgates for FDPIR recipients Nutrition Education funds spent on inappropriate items

Common ME Findings – Civil Rights Non-discrimination statement is incorrect or missing on program forms All staff do not complete annual CR training/No records of CR training by staff

Common ME Findings - Training Programs must have a continuing training program for all staff, including volunteers. Program does not assess training needs / staff do not receive training on all required elements / No records of training conducted.

Common ME Findings – Program Monitoring Programs must monitor and review their operations and local agency operations at least annually. Annual self-monitoring review is not conducted Annual self-monitoring review does not include all required elements

Questions ?