SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP)

SUBGRANTEE SUBGRANTEE MONITORING & MONITORING &

OVERSIGHT IN THE CHILD OVERSIGHT IN THE CHILD NUTRITION PROGRAMS NUTRITION PROGRAMS

(CNP)(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• Importance of Monitoring & Importance of Monitoring &

Oversight Oversight

• State Agency’s Arsenal of State Agency’s Arsenal of Monitoring ToolsMonitoring Tools

• Summary of Monitoring Summary of Monitoring Accountability IssuesAccountability Issues


IMPORTANCE OF MONITORING & IMPORTANCE OF MONITORING & OVERSIGHTOVERSIGHT

• BACKGROUND: WHY STATE BACKGROUND: WHY STATE AGENCY OVERSIGHT IS AGENCY OVERSIGHT IS NEEDEDNEEDED

– Program benefits delivered at Program benefits delivered at subgrantee level.subgrantee level.

– Results in obligation of Federal Results in obligation of Federal funds ($12 billion in FFY 2006).funds ($12 billion in FFY 2006).

– States disburse Federal funds States disburse Federal funds to numerous entities.to numerous entities.



• 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



• 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


A STATE AGENCY’S ARSENAL A STATE AGENCY’S ARSENAL OF MONITORING TOOLSOF MONITORING TOOLS

– Screening– Training & Technical

Assistance– Data Analysis– A-133 Audits– Administrative

Reviews– Agreed-Upon

Procedures (AUP) Engagements


STATE AGENCY’s ARSENAL OF STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING 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



• TRAINING & TRAINING & TECHNICAL TECHNICAL ASSISTANCEASSISTANCE– Required by

regulation– Instruct

subgrantees on program requirements

– Never ending job



• 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.



•A-133 AUDITS:A-133 AUDITS:– State agency must:State agency must:

• Identify subgrantees subject to A-133 Identify subgrantees subject to A-133 auditsaudits

• Make sure they get required audit Make sure they get required audit coveragecoverage

• Follow-up on audit resultsFollow-up on audit results



• 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



ADMINISTRATIVE ADMINISTRATIVE REVIEWSREVIEWS– Site visits by State agency staff– Required by regulation– Differ from audits– Complement to audits:

• “Real time”• Cover compliance requirements not

tested by auditors



• AGREED-UPON PROCEDURES:AGREED-UPON PROCEDURES:– Authorized by A-133/Part 3052Authorized by A-133/Part 3052– Only for subgrantees not subject to A-133Only for subgrantees not subject to A-133– Scope set by A-133Scope set by A-133– State agency must arrange and pay forState agency must arrange and pay for


SUMMARY OF MONITORING ISSUESSUMMARY OF MONITORING ISSUES• Identify subgrants to Identify subgrants to

subgrantees by subgrantees by program & CFDAprogram & CFDA

• Screen applicants for Screen applicants for subgrantssubgrants

• Provide training & Provide training & technical assistancetechnical assistance

• Analyze claims before Analyze claims before payingpaying

• Make required Make required administrative reviewsadministrative reviews

• Make other on-site Make other on-site visits as needed visits as needed

• Identify subgrantees Identify subgrantees subject to A-133subject to A-133

• Make sure subgrantees Make sure subgrantees get required auditsget required audits

• Use agreed-upon Use agreed-upon procedures correctlyprocedures correctly

• Follow-up on results of Follow-up on results of audits, reviews, etc.audits, reviews, etc.

• Establish and collect Establish and collect claimsclaims


CONCLUSIONCONCLUSION

• NEED STRONG SUBGRANTEE MONITORING NEED STRONG SUBGRANTEE MONITORING PROGRAMPROGRAM

• TO GET MORE INFORMATIONTO GET MORE INFORMATION• QUESTIONS & ANSWERSQUESTIONS & ANSWERS

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SUBGRANTEE MONITORING & OVERSIGHT IN THE CHILD NUTRITION PROGRAMS (CNP)