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SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP) School Nutrition Association USDA/State Agency Conference Nashville, Tennessee.

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Presentation on theme: "SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP) School Nutrition Association USDA/State Agency Conference Nashville, Tennessee."— Presentation transcript:

1 SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP) School Nutrition Association USDA/State Agency Conference Nashville, Tennessee November 27, 2007

2 Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) TOPICS TO BE COVERED Importance of Monitoring & OversightImportance of Monitoring & Oversight State Agency’s Arsenal of Monitoring ToolsState Agency’s Arsenal of Monitoring Tools Summary of Monitoring Accountability IssuesSummary of Monitoring Accountability Issues

3 IMPORTANCE OF MONITORING & OVERSIGHT Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) IMPORTANCE OF MONITORING & OVERSIGHT BACKGROUND: WHY STATE AGENCY OVERSIGHT IS NEEDEDBACKGROUND: 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.

4 IMPORTANCE OF MONITORING & OVERSIGHT 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

5 IMPORTANCE OF MONITORING & OVERSIGHT 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

6 A STATE AGENCY’S ARSENAL OF 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

7 STATE AGENCY’s ARSENAL OF MONITORING TOOLS 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

8 STATE AGENCY’s ARSENAL OF MONITORING TOOLS Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) STATE AGENCY’s ARSENAL OF MONITORING TOOLS TRAINING & TECHNICAL ASSISTANCETRAINING & TECHNICAL ASSISTANCE –Required by regulation –Instruct subgrantees on program requirements –Never ending job

9 STATE AGENCY’s ARSENAL OF MONITORING TOOLS Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) STATE AGENCY’s ARSENAL OF MONITORING TOOLS DATA ANALYSISDATA 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.

10 STATE AGENCY’s ARSENAL OF MONITORING TOOLS Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) STATE AGENCY’s ARSENAL OF MONITORING TOOLS A-133 AUDITS:A-133 AUDITS: –State agency must: Identify subgrantees subject to A-133 auditsIdentify subgrantees subject to A-133 audits Make sure they get required audit coverageMake sure they get required audit coverage Follow-up on audit resultsFollow-up on audit results

11 STATE AGENCY’s ARSENAL OF MONITORING TOOLS 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

12 STATE AGENCY’s ARSENAL OF MONITORING TOOLS 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

13 STATE AGENCY’s ARSENAL OF MONITORING TOOLS Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) STATE AGENCY’s ARSENAL OF MONITORING TOOLS AGREED-UPON PROCEDURES: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

14 SUMMARY OF MONITORING ISSUES Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) SUMMARY OF MONITORING ISSUES Identify subgrants to subgrantees by program & CFDAIdentify subgrants to subgrantees by program & CFDA Screen applicants for subgrantsScreen applicants for subgrants Provide training & technical assistanceProvide training & technical assistance Analyze claims before payingAnalyze claims before paying Make required administrative reviewsMake required administrative reviews Make other on-site visits as neededMake other on-site visits as needed Identify subgrantees subject to A-133Identify subgrantees subject to A-133 Make sure subgrantees get required auditsMake sure subgrantees get required audits Use agreed-upon procedures correctlyUse agreed-upon procedures correctly Follow-up on results of audits, reviews, etc.Follow-up on results of audits, reviews, etc. Establish and collect claimsEstablish and collect claims

15 CONCLUSION Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP) CONCLUSION NEED STRONG SUBGRANTEE MONITORING PROGRAMNEED STRONG SUBGRANTEE MONITORING PROGRAM TO GET MORE INFORMATIONTO GET MORE INFORMATION QUESTIONS & ANSWERSQUESTIONS & ANSWERS


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