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This guide outlines the eligibility requirements for institutions participating in food service programs, distinguishing between new institutions and existing ones. It details the performance evaluation tools and standards used to assess institutional capability and accountability. Key components include management responsibilities, compliance with financial management regulations, documentation of past performance, and regulations regarding outside employment. It emphasizes the importance of adhering to eligibility criteria set by regulatory agencies to maintain participation in publicly funded programs.
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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 • 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
Review of Terminology • Institution signs agreement with SA • Independent centers • Sponsors • Facility is a home or a sponsored center
Outside Employment “The policy must restrict other employment by employees that interferes with an employee’s performance of program-related duties and responsibilities….”
Outside Employment • Cannot interfere with program duties • Cannot be a real/apparent conflict of interest
Past Performance Should the SA become a Private Investigator? “NO!!”
Certifications • All info true and correct • Past performance • Publicly funded programs • Criminal conviction
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
Criminal Convictions • Convictions during past 7 years • Criminal convictions only • Consult State legal council if in doubt • Include both institution and principals
National Disqualified List • SA’s check: institutions, principals and facilities • Institutions check: principals • Sponsors check: facilities and principals • Abbreviated appeal
Name, Address and DOB • Executive Director and Chairman of Board on an institution application
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
Name, Address and DOB (con’t) • Issue #2: Refusal to provide information? • For Institutions = Not a complete application
Why Performance Standards? • Viability, Capability and Accountability (VCA) • Use as evaluation tool • No more checklists • Compare application content to performance standards
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
How to Document Compliance • Institutions—budget and management plan
How Much Detail? “too little” “too much”
Financial Viability • Resources • Program reimbursements • Grants and loans • Donations • Other Federal funds if permitted • For-profit subsidiary
Financial Viability: Recap • All resources • Assets/liabilities • Budget/proper expenditures • Size/nature of program • History
Performance Standard 2: Administrative Capability • Adequate, qualified staff • For sponsors: • Policies and procedures • Job descriptions • Budget/management plan • Staffing standards for monitoring
Performance Standard 3: Internal Controls for Accountability • Board of Directors (nonprofits) • Financial management system with written controls (all institutions) • Recordkeeping system (all institutions)
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
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
Accountability Controls for Sponsors • Sponsor staff & facility training • Monitoring • Compliance with admin cost limits • Facility compliance with meal pattern, other requirements
If Performance Standards Not Met • Must deny application • Provide opportunity for appeal
Summary of VCA • Viable, capable and accountable • Evaluate against standards • Deny if fail to demonstrate