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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
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.
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
IMPORTANCE OF MONITORING & IMPORTANCE OF MONITORING & OVERSIGHTOVERSIGHT
• 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 & IMPORTANCE OF MONITORING & OVERSIGHTOVERSIGHT
• 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 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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING TOOLS
• TRAINING & TRAINING & TECHNICAL TECHNICAL ASSISTANCEASSISTANCE– 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 STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING 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.
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING TOOLS
•A-133 AUDITS:A-133 AUDITS:
– State agency must:State agency must:
• Identify subgrantees subject to A-Identify subgrantees subject to A-133 audits133 audits
• Make sure they get required audit Make sure they get required audit coveragecoverage
• Follow-up on audit resultsFollow-up on audit results
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING 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 STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING TOOLS
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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
STATE AGENCY’s ARSENAL OF STATE AGENCY’s ARSENAL OF MONITORING TOOLSMONITORING TOOLS
• 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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
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
Subgrantee Monitoring & Oversight in the Child Nutrition Programs (CNP)
CONCLUSIONCONCLUSION
• NEED STRONG SUBGRANTEE MONITORING NEED STRONG SUBGRANTEE MONITORING PROGRAMPROGRAM
• TO GET MORE INFORMATIONTO GET MORE INFORMATION• QUESTIONS & ANSWERSQUESTIONS & ANSWERS