In this section, we will discuss the monitoring requirements for the At-risk Afterschool Meal Program. First, we will discuss the monitoring requirements the State Agency must fulfill. This will help explain why we come out for program reviews and why with larger sponsors, with multiple sites, we visit more than one site. As a state agency, we are required to conduct various compliance assessments and activities. The first is a pre-approval visit to make sure things are getting off to a good start—or at least all the necessary parts and pieces are present, in order to start off on the right track. Once you have been operating for at least a month or two, we will come and perform a more comprehensive review. We refer to this review as an Administrative Review or AR. Reviews can be announced or unannounced. The majority of our reviews will be announced, and you will know when we are coming well in advance, so you will have plenty of time to get prepared. Our office is however, required to do 15% of our reviews completely unannounced. When we conduct reviews we will take a comprehensive look at all of your program documentation. You will receive a list of documents with your review letter prior to an announced review that will help you to prepare.
During the onsite portion of program reviews, our staff will learn a lot more about your unique operation and will be better able to provide one-on-one training. We refer to this type of training as technical assistance. We don’t just come out to look for mistakes, but also for exceptional practices that we can pass along to other sponsors as well. We are interested in the positive aspects of your operation. After your first year, we will conduct at least one administrative review within a three year period. Keep in mind, you may be reviewed at the end of one three-year cycle and the beginning of the next, but over the course of 6 years it is likely you will only have two Administrative Reviews. Our office uses a risk analysis worksheet to decide on the frequency and type of reviews. Larger organizations that receive more funding will be considered higher risk. High risk does not necessarily mean that your are more likely to be non-compliant. However, compliance with your prior review is weighted heavily as a risk factor. Please also keep in mind that there are other agencies that can conduct program reviews besides our office. Staff from the USDA regional or national office may also come and conduct reviews. There can also be inspectors from other state or federal entities that can conduct investigations or audits, although these are rare.
Now, lets talk about the types of monitoring visit you will need to complete. As part of the site application process, your administrative or monitoring staff must complete a pre-approval visit/review, unless this requirement is waived by the state agency. Waivers can be granted to sites already participating on other federal child nutrition programs. Once approved on the program, monitoring staff will need to complete site monitoring visits at each site that operates the program. Let's look at the site monitoring requirements.
Each year sponsors must: annually review each facility three times per year, at least two of the reviews must be unannounced, at least one unannounced review must include observation of a meal service, at least one review must be during each new facility’s first four weeks of operations, and no more than 6 months may elapse between reviews. Year round sites participating on both the CACFP and SFSP or SSO, may count the monitoring visit made during the summer toward the annual requirement. Our office has a form, on the form and resources tab of the USBE CNP At-risk Afterschool Meals website, that should be used to document monitoring. Please use this form or have your form approved by our office prior to use. If you choose to make your own form it must cover all of the relevant topics our form would cover.
When creating your monitoring schedule, be sure to make your visits unpredictable by varying your timing. Staff should not be able to predict when you will come and perform an unannounced review. Be sure to fill out monitoring forms completely and follow up on any non-compliance identified with a written corrective action plan of what the site will do to bring their practices into compliance. Follow up on prior non-compliance at the next review in order to determine if the corrective action plan was effective. For sponsors of multiple sites a monitoring visit tracking sheet can be a valuable tool in making sure no visits are missed and that issues are followed up on. Also, keep in mind that the staff conducting the food service at their own site cannot complete the monitoring form. Our office is happy to help work with you on making the most of the monitoring process. Conducting good self monitoring is the best way to avoid non-compliance findings when our office comes to conduct our program reviews.
As you become an experienced program sponsor, there will be a lot of questions that come up. The USDA also frequently modifies or provides additional guidance and clarification on program rules. It is important to understand not only the basic regulations but also to keep up to date on program changes. Keep in mind, there are no free passes on program compliance regardless of the circumstances. If staff turns over and a new person comes without experience, it is the organization’s responsibility to ensure that person is trained on program requirements. It is best to review and ensure compliance prior to submitting a claim for reimbursement. Because the meal programs are always changing, it is very important that we have a current email address in CNPweb for the individual over the food program at your facility. It’s also very important that the individual checks this email and reads through the information that we send. You’ll receive both memos and bulletins from our office. Bulletins are new or updated regulations. Memos are clarifications or reminders. They’re both very important. Please read through and understand the correspondence that you receive from our office.
Another great resource is the USDA At-risk handbook. This has information specific to the At-risk Meals programs and is written in language that is much easier to read and understand than how it is laid out in regulation. There is also a policy index that is a handy reference at the back of the handbook. Keep in mind, this policy reference is only as up-to-date as the last time the handbook was published. For the most up-to-date policy information, be sure to visit the USDA CACFP Policy Page. There is a link to this page from the Policy tab of the CACFP and At-risk meal program pages of the USBE CNP website. Effective monitoring starts with knowing the program requirements.
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