Presentation is loading. Please wait.

Presentation is loading. Please wait.

Investigating Allegations of Noncompliance and/or Misuse of Funds in the CACFP & SFSP How the Investigation Affects the Administrative Hearing 2012 CACFP.

Similar presentations


Presentation on theme: "Investigating Allegations of Noncompliance and/or Misuse of Funds in the CACFP & SFSP How the Investigation Affects the Administrative Hearing 2012 CACFP."— Presentation transcript:

1 Investigating Allegations of Noncompliance and/or Misuse of Funds in the CACFP & SFSP How the Investigation Affects the Administrative Hearing 2012 CACFP National Professional Association Conference- Austin Texas

2 MH Miles Company, CPA PC Full service CPA firm Corporate Office in Decatur, GA Satellite office in Richmond, VA MHM Financial Services - Washington DC 2012 CACFP National Professional Association Conference- Austin Texas

3 Specialize in Compliance FEDERAL Nutrition Transportation Equal Opportunity/ Civil Rights STATE Prekindergarten 2012 CACFP National Professional Association Conference- Austin Texas

4 CACFP & SFSP Nutrition – CACFP & SFSP State Agencies State Agencies – Complaint Investigations – Fraud Investigations – Agreed-upon Procedure Reviews – Staff Augmentation – Policy & Procedure Development – Internal/External Audit Services – Budget Reviews – VCA Analysis 2012 CACFP National Professional Association Conference- Austin Texas

5 CACFP & SFSP Nutrition – CACFP & SFSP Sponsors Sponsors – OMB Circular A-133 audits – Management Studies – Programmatic Audits – Compliance Monitoring – Management Plan Evaluation – Policy & Procedure Development – Accounting System Set-up 2012 CACFP National Professional Association Conference- Austin Texas

6 Objectives Documenting the Complaint/Allegation Assessing the allegation(s) Planning the engagement Fieldwork Techniques for Investigating Common Schemes Reporting Affects on the Administrative Hearing Process 2012 CACFP National Professional Association Conference- Austin Texas

7 Looking at the Big Picture 2012 CACFP National Professional Association Conference- Austin Texas

8 Who files Complaints? Whistleblowers 2012 CACFP National Professional Association Conference- Austin Texas

9 WHISTLEBLOWERS Program Beneficiaries Parents/Guardians Caregivers Employees Agency Sub-recipients General Public Vendors 2012 CACFP National Professional Association Conference- Austin Texas

10 Documenting the Complaint/Allegation 2012 CACFP National Professional Association Conference- Austin Texas

11 Documentation Process Capture Pertinent Information Who received the complaint Date Received How the complaint was received – Written Email Letter – Recorded Voicemail – Live Telephone call Interview in person Does complainant want to remain anonymous? 2012 CACFP National Professional Association Conference- Austin Texas

12 Documentation Process Documenting the actual complaint Written or Recorded – Verbatim Live / complainant doesn’t want to be anonymous – Verbatim – Clarity 2012 CACFP National Professional Association Conference- Austin Texas

13 Helpful Words & Phrases 2012 CACFP National Professional Association Conference- Austin Texas

14 Organizing the Information What is being communicated What is actually being said? Supporting documentation available? Keep the complainant on track Side bar thoughts What they didn’t say….. What other areas are impacted? Follow-up questions 2012 CACFP National Professional Association Conference- Austin Texas

15 Documentation Process Compiling the information – Assign a tracking number – Categorizing the Complaint 2012 CACFP National Professional Association Conference- Austin Texas

16 Documentation Process C 2012-06178-01 - A 2012 CACFP National Professional Association Conference- Austin Texas Complaint Year Identifying Number Sequence in the year Complaint Category

17 Assessing the Allegation(s) Group allegation(s) in bite size subcategories 1 st on face value then by noncompliance Additional Observations Committee for feedback Next Steps 2012 CACFP National Professional Association Conference- Austin Texas

18 USDA OIG Complaint Hotline Categories Participant Fraud Waste Management Employee Misconduct Bribery Reprisal Health & Safety Opinion & Information 2012 CACFP National Professional Association Conference- Austin Texas National intake-point for reports from both employees and the general public of suspected incidents of fraud, waste, mismanagement, and abuse in USDA programs and operations.

19 FY2010 – FY2011 USDA-OIG Semiannual Report to Congress FY2010 1st HalfFY2010 2nd HalfFY2011 1st HalfFY2011 2nd Half Participant Fraud 780 1,090 931 969 Waste Management 108 165 207 259 Employee Misconduct 183 204 177 172 Bribery 1 1 3 - Reprisal 1 2 2 4 Health & Safety 25 51 41 31 Opinion & Information 127 198 131 116 Total Complaints 1,225 1,711 1,492 1,551 2012 CACFP National Professional Association Conference- Austin Texas

20

21 Planning the Engagement Investigation Review Plan Review Tools Staffing Considerations Scope – Determine Necessary Documents – Develop Interview List Fieldwork- Action Plan Timeline 2012 CACFP National Professional Association Conference- Austin Texas

22 Review Tools Review Reports & Management Plan Interviews Observations Program Documentation Independent Research Supplies 2012 CACFP National Professional Association Conference- Austin Texas

23 Staffing Considerations Specific Experience Independent Coverage & Resources 2012 CACFP National Professional Association Conference- Austin Texas

24 Scope & Timeline Clear & Concise Regulatory Compliance Subject to Change Documentation for Review Interview List Develop an initial timeline 2012 CACFP National Professional Association Conference- Austin Texas

25 Action Plan Start Big Drill Down 2012 CACFP National Professional Association Conference- Austin Texas

26 Fieldwork Entrance Conference Document Request Tour 2012 CACFP National Professional Association Conference- Austin Texas

27 Interviews & Observations Interview Methodology: Telephone Interview – Quick – No Travel – Record Ability to record (State) Less intimidating In-person Interview – Observe reactions to questions Questionnaire 2012 CACFP National Professional Association Conference- Austin Texas

28 Interview Objectives Gather information related to the allegations Identify possible “leads” to support/refute allegations 2012 CACFP National Professional Association Conference- Austin Texas

29 Interview Techniques Develop an Interview Plan Start with easy questions – Build rapport – Relax Identify relationships Be prepared Private/Confidential Choose your words wisely 2012 CACFP National Professional Association Conference- Austin Texas

30 Interview Techniques Observe body language Pose open & close ended questions LISTEN – What is said – What is not said Take Notes- not dictation Show documentation where applicable 2012 CACFP National Professional Association Conference- Austin Texas

31 Red Flags Information changes No eye contact Long pauses 2012 CACFP National Professional Association Conference- Austin Texas

32 Document Analysis Techniques Horizontal & Vertical Analysis of Information Signatures Dates & Times Transactions Formatting Verifying item codes 2012 CACFP National Professional Association Conference- Austin Texas

33 Techniques for Common Program Schemes Inflated Meal Counts Assess knowledge of sponsored facilities Confirm affiliated/unaffiliated sites Flux analysis of meals by type/site Observe behavior 2012 CACFP National Professional Association Conference- Austin Texas

34 Techniques for Common Program Schemes Inflated Meal Counts Open Sites- #of meals delivered = # of meals served 100% Simultaneous Reviews (open site & central kitchen) Arrive early & engage participants Observe behavior Test Leftover meal practice 2012 CACFP National Professional Association Conference- Austin Texas

35 Techniques for Common Program Schemes Falsified labor documentation – Review standardized forms by individual – Record transaction number by vendor/date/total – Be familiar with other programs Duplication of Costs – Record transaction number by vendor/date/total – Be familiar with other programs Other Unallowable Costs – Cost of Ownership between organizations under common control 2012 CACFP National Professional Association Conference- Austin Texas

36 Reporting Status Reports Draft Report Final Report – Findings of noncompliance – Recommendations for oversight 2012 CACFP National Professional Association Conference- Austin Texas

37 Administrative Hearing Methodology and Results are relied upon to determine how to move forward Notes and emails related to investigation may be requested Weakest Evidence is anything than can be contradicted Anyone who has touched the investigation is a potential witness 2012 CACFP National Professional Association Conference- Austin Texas

38 Ideal Witness Education/Training/ Experience in the area Knowledge of the investigation Testified in other cases & courts have relied on information presented 13 Tips 2012 CACFP National Professional Association Conference- Austin Texas

39

40 Questions Cherese Myree, CFE Vice President, MH Miles Company, CPA PC (404) 633-4555 cmyree@mhm-cpa.com 2012 CACFP National Professional Association Conference- Austin Texas

41 Thank You! 2012 CACFP National Professional Association Conference- Austin Texas


Download ppt "Investigating Allegations of Noncompliance and/or Misuse of Funds in the CACFP & SFSP How the Investigation Affects the Administrative Hearing 2012 CACFP."

Similar presentations


Ads by Google