Audits/Reviews2013 Summer Food Service Program

March 19, 2013

Reviews

Part II, Chapter 6 - Pages 94-95

A133 Audit

Administrative Review

A-133 AuditGovernmental 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 programMust submit an organization-wide A-133

auditSponsor that expends $500,000 or more and

has only one Federal programMay submit a program specific audit

A-133 Audit - ReportShould be submitted as part of the

application processDue 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 10.559

A-133 Audit – Review ProcessAudit 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 ProcessSponsors

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 - PurposeUnannounced reviews to ensure: Financial operations are conducted properlyFinancial statement/reports are correctExpenditures of program funds comply with

applicable laws and regulationsInternal procedures meet the objectives of

federally assisted programs

Administrative Review

Sponsor Review

Site Review

Administrative ReviewRecords needed:SFSP ApplicationDocumentation of training and monitoring Inventory records, meal production records and menusDocumentation of reimbursement for all program costsMeal benefit eligibility forms, if applicableDaily meal count records and the Sponsor’s consolidation countDocumentation of racial and ethnic data Documentation of media release

Administrative Review - Sponsor ReviewProgram Costs – Operating and AdministrativeReview receipts, invoices, payroll documents, mileage reports,

and canceled checksReview checking account and/or fund statements and reportsDetermine if costs are allowable, allocated correctly, and

reasonable

Administrative Review - Sponsor ReviewMonitoring

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 sitesTraining

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 ReviewMeal Count Records

Daily tally sheet for open sitesWeekly roster for enrolled children – closed

enrolled and campsDocumentation 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 – FindingsReview/Audit with deficiencies must submit a

corrective action planFailure to submit a corrective action plan

could result in termination

Review/Audit – Serious DeficiencySerious Deficiency (SD) can occur during Application Review A-133 Audit Review Administrative Review

Two critical factors: Frequency and SeveritySeverity

NegligenceFraud

Frequency: How often does the error/problem occur?Isolated errorSystemic problem

Review/Audit – Serious DeficiencySerious 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 DeficiencySD includes, but not limited to:1) Noncompliance with application bid

procedures and contract requirements of Federal CNP

2) Submission of false information to the SA3) Failure to return to the SA advance

payments which exceeded reimbursement4) Program Violations

a) Noncompliance with the meal service time restrictions

b) Failure to maintain adequate records

Review/Audit – Serious Deficiency4) 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 childrenf) Service of meals that do not meet program

requirementsg) Excessive instances of off site consumption h) Continued use of FSMC in violation of health

codesi) Any other violation of program requirements

Review/Audit – Serious DeficiencySD ProcessSponsor declared SDOpportunity for corrective action

Incomplete corrective actionTermination 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 DeficiencyAppeal 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 appealVoluntary termination = Disqualification

Two Possibilities Sponsor wins – retroactive reimbursement for meals SA wins – reimbursement will not be paid

Carolyn RhodesPhone : (334) 242-

8224Email:

crhodes@alsde.edu