Finding Text
Criteria: Sponsoring organizations participating in the CACFP are required to monitor the facilities under their sponsorship in accordance with CACFP program requirements and the applicable federal and state administering agency rules. Monitoring visits are intended to provide oversight of participating facilities, verify compliance with program requirements, and support the allowability of meals claimed for reimbursement. For CACFP sponsoring organizations, required monitoring generally includes periodic reviews of each sponsored facility. At least one required monitoring visit must include observation of a meal service, as applicable under program requirements. The meal observation is a key control for verifying that reimbursable meals are served in accordance with the CACFP meal pattern, attendance, meal count, and program operating requirements. Condition: During our testing over subrecipient monitoring, we noted one instance where the Organization did not perform a meal observation across three site visits for one of the centers during a 12-month period. Cause: The condition appears to have resulted from insufficient controls over scheduling, performing, and documenting required CACFP monitoring visits. Specifically, the sponsoring organization did not have an effective process to ensure that monitoring staff: • Identified which visits were required to include a meal observation; • Scheduled visits to coincide with an approved meal service time; • Completed all required monitoring elements during the visit; and • Reviewed monitoring documentation for completeness before closing the visit. Effect: Failure to perform the required meal observation reduces the sponsoring organization’s ability to verify that meals claimed for reimbursement were served in compliance with CACFP requirements. Without a meal observation, the sponsor may not identify noncompliance related to meal counts, attendance, meal pattern requirements, approved meal service times, or other operational requirements affecting the allowability of CACFP claims. Questioned Costs: None Recommendation: We recommend that the sponsoring organization strengthen its CACFP monitoring procedures to ensure all required meal observations are performed and documented. At a minimum, management should: • Implement a monitoring schedule control that identifies which facility visits must include a meal observation and the applicable meal service time. • Require advance planning by monitoring staff to ensure visits occur during an approved meal service when a meal observation is required. • Revise monitoring forms or electronic checklists to require completion of meal observation fields before a monitoring visit can be closed. • Perform supervisory review of monitoring documentation to verify that required visit elements, including meal observations, are completed and supported. • Train monitoring staff on CACFP sponsor monitoring requirements, including when meal observations are required and how they should be documented. • Perform a retrospective review of monitoring visits during the audit period to determine whether additional required meal observations were missed. • Calculate and resolve questioned costs, if applicable, in coordination with the state administering agency, based on the affected meal service, claim period, and applicable reimbursement rates. Management Response: BBCF acknowledges this specific exception and the associated weakness in controls for scheduling and verifying required monitoring elements. The finding alone does not establish that other sponsored centers lacked required observations.