FDPIR Management Evaluations Purpose Process Common Findings NAFDPIR 2015

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

Purpose  Ensure compliance with Federal regulations and other guidance materials  Identify needs for technical assistance  Take back best practices to share

Format Most MEs are conducted on-site, with a desk review of some documents and/or case files prior to the on-site portion of the review Some MEs may be conducted as “focused” MEs and consist of an off-site review of case files or other documentation.

Timeline  > 30 days before on-site review: - Notify State Agency/ITO of ME - Requested documents/questionnaire due to RO  On-site review - Typically 3-5 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 (cont.)  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: Before the On-Site Review Negotiate schedule for review Send official notification letter Request any documents needed for pre-on-site review, which may include: - Plan of Operation - Case Files - Self-Assessment - Questionnaire

Process: During the On-Site 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 - Accessibility

Process: During the On-Site Review (cont.) Review: - Case files - Equipment list - Training materials and logs Observe (when possible): - Tailgate distribution - 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: evaluation-module 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, or procedures.  Required Corrective Actions: Actions that must be taken to change or improve operational effectiveness and correct non-compliance.

ME Report – What to Expect (cont.)  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 Operation 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 & 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

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

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

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

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

PROGRAM MONITORING & SELF-ASSESSMENT NAFDPIR 2015

Program Monitoring  Program Monitoring  Conducting an Annual Review / Self-Assessment  Annual and Periodic Case File Review

Annual Review – Requirements Programs are required to conduct an annual self assessment that includes:  Certification  Determination of food preferences  Distribution  Civil Rights compliance  Fair hearing procedures  Warehousing and inventory  Timeliness and accuracy of reports  Training

Annual Review – Tools & Documentation Programs should develop their own tools for self assessment and/or share tools that other FDPIRs have developed. The completed annual review, plus the corrective action plan, must be documented.

Discussion on Annual Review When do you do it? / How often? Who does it? What tools do you use? What common issues do you find? What corrective actions do you take?

Annual & Ongoing Case File Review Case file review must be a part of your annual review. Additionally, periodic case file reviews are a best practice to ensure program integrity and to identify staff training needs.

Discussion on Case File Review When do you do it? / How often? Who does it? What tools do you use? What common issues do you find? What corrective actions do you take?