In October 2021, the Organization created a full-time staff position whose primary responsibilities were to collect, review, and track invoices and receipts. The individual was instructed to use the Journal Ledger Spreadsheet provided by MDE. However, the spreadsheet does not include a cross-check t...
In October 2021, the Organization created a full-time staff position whose primary responsibilities were to collect, review, and track invoices and receipts. The individual was instructed to use the Journal Ledger Spreadsheet provided by MDE. However, the spreadsheet does not include a cross-check to verify that the receipts and invoices entered into the spreadsheet have associated images or scans of receipts. The Organization will begin utilizing the My Food Program software to enter invoices and receipts to track the nonprofit food service. The software will be configured to require the upload of a photo or scan of the actual receipt or invoice in order to create the expense, thus guaranteeing that documentation of the expense exists and is appropriately maintained. This procedure will also resolve any issues with corrupted files as the reports can be generated from the cloud-based software. The Organization abruptly ceased operations in January 2022. It is our understanding that sponsored sites must prove that they expended all program funds on approved program-related expenses, but are not required to do so in the month the funds were received. In other words, sponsored sites would have had all of fiscal year 2022 to document the expenditures of all funds received in fiscal year 2022. It is reasonable to assume that sites with an excessive balance in their food service account would have been able to document appropriate expenditures if given sufficient time. The Organization is confident that the systems in place in fiscal year 2022 would have allowed the Organization to monitor the appropriate use of excessive nonprofit food service program balances in future periods; most notably through the Organization?s policies and procedures contained in the Management Plan and approved by MDE. The Organization holds future claims if the balance in the food service account exceeds a three-month average of expenditures. Monitoring forms were completed on paper during fiscal year 2022. Staff were instructed to scan and save an electronic copy of the monitoring form on the Organization?s cloud-based storage system. In some cases, staff failed to save an electronic copy and the only verification of the monitoring visit is contained in paper files that are currently in off-site storage. The Organization believes that staff adhered to the monitoring requirements, despite the documentation of those visits not being readily available. Going forward, all monitoring staff will be required to complete site visits electronically using the My Food Program software. The software will store the monitoring form electronically on the cloud, inclusive of sponsor and site staff signatures with date-time stamps. There are also comprehensive monitor tracking reports available to assist with monitoring frequency compliance. In the event of a loss of internet service, the monitors will be required to complete the visit on paper and upload a copy to the My Food Program software. The Organization agrees that the retained administrative fee should reflect the administrative fee percentage stated in the Sponsor Agreement. However, the Organization would like to note that the USDA Guidance for Management Plans & Budgets states that, ?A sponsoring organization may retain a portion of the reimbursement for costs associated with administering the CACFP. It may retain up to 15 percent of the total CACFP reimbursement received, or the actual net administrative costs incurred, whichever is less.? Further in the same document, it states, ?There is a concern that sponsoring organizations of centers may spend more on administrative costs than on food. The state agency?s review should investigate how reimbursements are disbursed and whether the food service is supported appropriately.? The Organization would like to emphasize that additional funds, in a miniscule amount, were spent on operating costs, such as food, and it did not retain additional administrative funds. The Organization?s policy in fiscal year 2022 was to track the administrative fee percentage in the claims tracking spreadsheet in lieu of referencing a signed agreement each month. This is supported by the Organization?s disbursement allocation policy, which is included in the fiscal year 2022 Management Plan and approved by MDE. In fiscal 2022, the claims staff would alter the administrative fee percentage upon the written direction of the Executive Director or Director of Operations based on their verbal or written interactions with the site. Going forward, claims staff will not be allowed to change the administrative fee percentage in the claims tracking spreadsheet unless a revised Sponsor Agreement is signed. The Site Information Form was used as a supplement to other operational information about the site. This form is not a federal requirement, nor a form provided by or required by the state agency. During fiscal year 2022, the processing time for the approval of site applications by the state agency was beyond the normal thirty business days. Therefore, sites interested in participating under the sponsorship of the Organization would often complete the Site Information Form as early as possible so that the Organization could submit the site application with MDE. Oftentimes, at the time the Site Information Form was completed, the site may not have finalized site operating times and meal times. The Organization maintained a complete record of all required site information at all times. Contact names and dates of birth of responsible individuals at the sites were documented in the Google sheet used to track information during the intake appointment. In addition, the hours of operation and licensed capacity were maintained in My Food Program software. Lastly, the sites? food preparation methods were also documented on the Google sheet with site information. Catering contracts with vended meal providers are maintained on-file as they are required to be uploaded to the state agency with the site application. Going forward, the Organization will no longer use the Site Information Form or the Google sheet to track required site information. Instead, all data to ensure that the sites are eligible to participate in the CACFP, and the information required to effectively perform subrecipient monitoring procedures, will be retained in the My Food Program software.