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Institution Eligibility

Institution Eligibility. Goals of Eligibility Requirements. New institutions: Meet program requirements Fully capable of operating  Existing institutions: Application renewal as a tool to evaluate performance. Eligibility Requirements Before and After ARPA.

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Institution Eligibility

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  1. Institution Eligibility

  2. Goals of Eligibility Requirements • New institutions: • Meet program requirements • Fully capable of operating •  Existing institutions: • Application renewal as a tool to evaluate performance

  3. Eligibility Requirements Before and After ARPA • Before - institutions responsible for management of effective food service • Before - SA determined institution’s capability • After - new eligibility requirements based on OIG audits and other reviews

  4. Review of Terminology • Institution signs agreement with SA • Independent centers • Sponsors • Facility is a home or a sponsored center

  5. Outside Employment “The policy must restrict other employment by employees that interferes with an employee’s performance of program-related duties and responsibilities….”

  6. Outside Employment • Cannot interfere with program duties • Cannot be a real/apparent conflict of interest

  7. Past Performance Should the SA become a Private Investigator? “NO!!”

  8. Certifications • All info true and correct • Past performance • Publicly funded programs • Criminal conviction

  9. Publicly Funded Programs • List Federal, State or local programs in past 7 years • Indicate if institution or principals declared ineligible • Or show that restored to full participation • SA follow up on information

  10. Criminal Convictions • Convictions during past 7 years • Criminal convictions only • Consult State legal council if in doubt • Include both institution and principals

  11. National Disqualified List • SA’s check: institutions, principals and facilities  • Institutions check: principals • Sponsors check: facilities and principals • Abbreviated appeal

  12. Name, Address and DOB • Executive Director and Chairman of Board on an institution application

  13. Name, Address and DOB (con’t) • Issue #1: Similar or identical names? As more names added to the list….. = Need for Date of Birth to be included

  14. Name, Address and DOB (con’t) • Issue #2: Refusal to provide information? • For Institutions = Not a complete application

  15. Why Performance Standards? • Viability, Capability and Accountability (VCA) • Use as evaluation tool • No more checklists • Compare application content to performance standards

  16. Standard 1: Financial Viability and Financial Management • Institution is financially viable • Institution will make proper expenditures • Nonprofit food service funds only for allowable costs • Nonprofit food service funds restricted • All employees with FM responsibility are aware of procedures

  17. How to Document Compliance • Institutions—budget and management plan

  18. How Much Detail? “too little” “too much”

  19. Financial Viability • Resources • Program reimbursements • Grants and loans • Donations • Other Federal funds if permitted • For-profit subsidiary

  20. Financial Viability: Recap • All resources • Assets/liabilities • Budget/proper expenditures • Size/nature of program • History

  21. Performance Standard 2: Administrative Capability • Adequate, qualified staff • For sponsors: • Policies and procedures • Job descriptions • Budget/management plan • Staffing standards for monitoring

  22. Performance Standard 3: Internal Controls for Accountability • Board of Directors (nonprofits) • Financial management system with written controls (all institutions) • Recordkeeping system (all institutions)

  23. Responsibilities of Boards of Directors • Determining institution’s mission and purpose • Ensuring compliance with regulatory requirements • Selection and evaluation of the Executive Director • Regular training on Program

  24. More Accountability Controls • Factors to be looked at for ALL institutions: • Financial controls ensuring proper use of funds and detect improper activities • Records documenting compliance with financial rules

  25. Accountability Controls for Sponsors • Sponsor staff & facility training • Monitoring • Compliance with admin cost limits • Facility compliance with meal pattern, other requirements

  26. If Performance Standards Not Met • Must deny application • Provide opportunity for appeal

  27. Summary of VCA • Viable, capable and accountable • Evaluate against standards • Deny if fail to demonstrate

  28. Institution Eligibility

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