2013 Summer Food Service Program March 19, 2013

Reviews Part II, Chapter 6 - Pages 94-95

A-133 Audit Governmental or non-profit entity that expends $500,000 or more in Federal awards during its fiscal year period and receives funding from more than one type of Federal program Must submit an organization-wide A-133 audit Sponsor that expends $500,000 or more and has only one Federal program May submit a program specific audit

A-133 Audit - Report Should be submitted as part of the application process Due to the State Department of Education within 30 days after issuance of report or no later than 9 months after the end of the fiscal year Must identify Federal awards by CFDA number in the required Schedule of Expenditures of Federal Awards (SEFA) CFDA number for Summer Food Service Program for Children is

A-133 Audit – Review Process Audit is reviewed by State Agency (SA) staff for compliance. Corrective action plan is requested for findings or questionable costs. If required, Sponsor must submit corrective action plan to participate in SFSP. Sponsor cannot participate or receive final reimbursement without an A-133 audit.

Administrative Review – Selection Process Sponsors reviewed every three years Sponsors in the first year of operation Sponsors with 20 or more sites One-half of total program reimbursements for prior year Review 10 percent of sites

Adminstrative Review - Purpose Unannounced reviews to ensure: Financial operations are conducted properly Financial statement/reports are correct Expenditures of program funds comply with applicable laws and regulations Internal procedures meet the objectives of federally assisted programs

Administrative Review Sponsor ReviewSite Review

Administrative Review Records needed:  SFSP Application  Documentation of training and monitoring  Inventory records, meal production records and menus  Documentation of reimbursement for all program costs  Meal benefit eligibility forms, if applicable  Daily meal count records and the Sponsor’s consolidation count  Documentation of racial and ethnic data  Documentation of media release

Administrative Review - Sponsor Review Program Costs – Operating and Administrative Review receipts, invoices, payroll documents, mileage reports, and canceled checks Review checking account and/or fund statements and reports Determine if costs are allowable, allocated correctly, and reasonable

Administrative Review - Sponsor Review Monitoring Pre-Operational Visit – Required for new and problem sites First Week Visit – Can be waived for experienced sponsors with experienced site staff Four Week Visit – Required for all sites Training ALL site personnel must be trained before taking on responsibilities Adequate documentation must be available for review to include topic, date and name of attendees

Administrative Review – Sponsor / Site Review Meal Count Records Daily tally sheet for open sites Weekly roster for enrolled children – closed enrolled and camps Documentation of counts for first meals, second meals, test meals, excess meals, and adult meals Consolidate Weekly and Monthly Meal Count Records

Administrative Review - Site Review Meal service Preparation and Delivery of meals Review of site records (delivery receipts, production records, meal counts, payroll records) Sanitation and Safety Display of the “…And Justice for All” poster Other aspects of Program compliance, as needed

Counting and Claiming Meals Cannot Claim Reimbursement for Meals Served: To any child who is not enrolled at the site (closed enrolled) To ineligible participants at camp In excess of the approved level of meal service (CAP) In excess of the two meals per day (or 3 meals a day for migrant and camp programs) Outside the approved meal service times At unapproved locations In the temperature danger zone Adminstrative Review - Site Review

Counting and Claiming Meals, continue Cannot Claim Reimbursement for: Meal types not approved by the SA Meal pattern requirements not followed Adminstrative Review - Site Review

Administrative Review – Findings Review/Audit with deficiencies must submit a corrective action plan Failure to submit a corrective action plan could result in termination

Review/Audit – Serious Deficiency Serious Deficiency (SD) can occur during  Application Review  A-133 Audit Review  Administrative Review Two critical factors: Frequency and Severity Severity Negligence Fraud Frequency: How often does the error/problem occur? Isolated error Systemic problem

Review/Audit – Serious Deficiency Serious Deficiency (SD) Fully describe the SDs Outcome of corrective action Corrective action deadline Identify the Responsible Principals (RP) / Responsible Individuals(RI) Sponsor is determined SD Persons who caused the SD are RP/RIs

Review/Audit – Serious Deficiency SD includes, but not limited to: 1) Noncompliance with application bid procedures and contract requirements of Federal CNP 2) Submission of false information to the SA 3) Failure to return to the SA advance payments which exceeded reimbursement 4) Program Violations a) Noncompliance with the meal service time restrictions b) Failure to maintain adequate records

Review/Audit – Serious Deficiency 4) Program Violations c) Failure to adjust meal orders to conform with changing participation d) Simultaneous service of greater than one meal to any child e) Claiming of meals not served to children f) Service of meals that do not meet program requirements g) Excessive instances of off site consumption h) Continued use of FSMC in violation of health codes i) Any other violation of program requirements

Review/Audit – Serious Deficiency SD Process Sponsor declared SD Opportunity for corrective action Incomplete corrective action Termination of agreement by SA Disqualification is primary consequence of termination – Placement of RP/RIs on State DQ List Appeal of Termination and Disqualification

Review/Audit – Serious Deficiency Appeal of Termination and Disqualification Sponsors may continue to operate the program and maintain adequate documentation during an appeal of termination Program payments will not continue during appeal Voluntary termination = Disqualification Two Possibilities Sponsor wins – retroactive reimbursement for meals SA wins – reimbursement will not be paid

Carolyn Rhodes Phone : (334)