1. FDPIR Management Evaluations
Tammy Larma
Lead Program Specialist
Midwest Regional Office-Chicago, IL

2. Goal
Purpose of the ME
Process
Timeline
What to expect
Common Findings

3. Differences
Several factors might result in slight variations in the ME process between ITOs.
Size of the FDPIR program
Multiple distribution sites or warehouses, participants served
Accessibility to ITO
Drive time
Lodging
Funding
Staffing
Program needs

4. Similarities National Management Evaluation Guidance
FDPIR Management Evaluation Module

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

6. Purpose of the ME
Ensure compliance with Federal Regulations and other guidance materials.
Identify needs for technical assistance
Share best practices

7. Format
Most MEs are conducted on-site with a desk review of some documents and/or case files prior to the on-site portion.
There can also be follow-up conference calls or site visits as needed.
Some MEs may be conducted as “focused” MEs and consist of a desk review of case files or other documentation.

8. Timeline > 30 days before on-site review: On-site review
Notify State Agency/ITO of ME
Requested documents/questionnaire due to RO
On-site review
Typically 1-5 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

9. Timeline continued…
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

10. Process: Pre-site Review
Negotiate schedule for review
Send official notification letter
Request any documents needed for pre-site review, which may include:
Case Files
Plan of Operation
Self-Assessment
Questionnaire
Equipment List

11. Process: On-Site Review
Reviewers use the FDPIR ME modules and program’s Plan of Operation to guide the 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

12. Process – On-Site Review continued…
Review and verify:
Case files (claims, fair hearings, denied cases)
Equipment list
Training materials and other records
Other administrative procedures and documents
Observe (when possible):
Distribution (including Tailgate, if applicable)
Certification appointments
Inventory procedures
Exit Conference
Discussion on potential findings and observations

13. 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:

15. 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

16. 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, and procedures.
Required Corrective Actions: Actions that must be taken to change or improve operational effectiveness and correct non-compliance.

17. ME Report - What to Expect continued…
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.

18. Common ME Findings – Plan of Operations
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

19. 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

20. Common ME Findings – Records and Reports
Late reports
Records not kept for required 3 year time period/inaccessible
Equipment list not kept or missing required information

21. Common ME Findings – Inventory Control
Outdated product in inventory
FNS-152 reports show frequent losses and gains
Food losses not adequately tracked
Excessive or inadequate inventory

22. 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

23. 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
Application and Notice of Decision do not contain required information

24. 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

25. Common ME Findings – Civil Rights
Non-discrimination statement is incorrect or missing on program forms
All staff do not complete annual CR training/No records of CR training by staff

26. 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 / No records of training conducted.

27. 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

28. Questions ?