Performance Standards Child and Adult Care Food Program Administration Spring 2019

Agenda

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• Define Performance Standards • Financial Viability • Administrative Capability • Program Accountability

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A participating institution must be financially viable

The institution must be capable of administering the CACFP

Participating institutions must have internal controls and other management systems in place to guarantee fiscal accountability and other CACFP operational requirements

Financial Viability and Management

Administrative Capability

Program Accountability

Performance Standards

7 CFR §226.6(b)(2)(vii)(A-C)

PresenterPresentation NotesThere are three Performance Standards in the CACFP: Financial Viability and Management, Administrative Capability, and Program Accountability

Financial Viability and ManagementThere should be adequate resources to sustain the program during any interruption. The institution should be able to document its finances and the submitted budget should contain costs that are necessary, reasonable, allowable, and documented.

Administrative CapabilityAdequate and qualified staff Program administrators Oversight of dutiesWritten program policies and proceduresAssigned Program responsibilities and duties Ensure compliance with civil rights requirements (FNS 113-1)

Program Accountability Recordkeeping Meal service and other operational requirementsFood preparation Menus that meet the meal patternsStaff training Edit checksSponsoring organizations, must document in management plan there is adequate and regular training of sponsoring organization staff and sponsored facilities

Financial Viability and Management

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• Financial Viability and Financial Management – FNS Instruction 796-2, rev. 4 “Financial Management in the Child and

Adult Care Food Program” – 2 CFR part 200, subpart D – USDA implementing regulations 2 CFR part 400 and part 415

• Description of Need and Recruitment • Fiscal Resources and Financial History • Budget

– Necessary – Reasonable – Allowable

Performance Standard 1: Financial Viability

7 CFR §226.6(b)(2)(vii)(A)

PresenterPresentation NotesExpanded Part A: Demonstrated ability to generate sufficient income and possession of sufficient resources to meet the institution’s total operating obligations, debt commitments, and to maintain sufficient contingency funds.

Expanded Part B: Must be evidenced in the institution’s official books and records; must also demonstrate financial management (the included activity is about financial tracking, which is one way to demonstrate financial management; overlaps with Program Accountability – fiscal integrity).

Expanded Part C: Financial management policies and procedures, both documented and in practice, ensure the implementation of the appropriate fiscal activities and are communicated to staff with financial management responsibilities.

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• Sufficient revenue – Diversify streams of revenue – Fundraising – Grants – Other unrestricted funds

• Ensure solvency…A healthy business!

Financial Viability

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• Administrative Costs – Labor (*monitoring, program administration, etc.) – Rent/lease expenses – Telecommunications – Travel costs – Materials and supplies – Printing and postage – Purchased services – Professional Organization activities

• Multi-State Sponsoring Organizations must establish a cost allocation plan – Approved by MARO and cognizant State Agency

*Sponsors of centers and family day care homes

Financial Tracking

PresenterPresentation NotesOne key element of financial viability and management is financial tracking. The process of tracking federal funds (CACFP reimbursement) is also a standard that must be met under Performance Standard #3: Program Accountability (ensuring funds are segregated and spent only on creditable items approved in the budget).

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• Purpose: o All CACFP creditable food, non-food, and labor costs will be

totaled each month on the “CACFP Reimbursement and Expense Tracking” log and compared to the monthly Claim for Reimbursement total dollar amount to validate a non-profit CACFP program.

o Items charged to CACFP that are found on receipts and invoices will be supported by the dated, daily menus.

Financial Tracking

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• Documents and Records: o All receipts and/or documentation for creditable food, non-food

items, supplies, and labor costs associated with the Child and Adult Food Program.

- Operational: food and non-food receipts; FSMC invoices *You may choose: Only CACFP food and non-food items will be purchased and documented on original receipts or invoices. OR Receipts or invoices that include non-creditable CACFP expenses will be marked so that the non- creditable items are not included in the amount documented as a CACFP related expense. - Administrative: supplies - Labor: time & attendance logs for food service and/or

administrative labor.

Financial Tracking

PresenterPresentation NotesAll receipts and/or documentation for creditable food, non-food items, supplies, and labor costs associated with the Child and Adult Care Food Program will be maintained by the month to validate a non-profit food program. -Operational: food and non-food receipts (pitchers, cups, serving utensils, etc.) *Only CACFP food and non-food items will be purchased and documented on original receipts or invoices. OR Receipts or invoices that include non-creditable CACFP expenses will be marked so that the non- creditable items are not included in the amount documented as a CACFP related expense; FSMC invoices.- Administrative: supplies- Labor: food service (cook); administrative (meal count reconciliation, IES determinations, etc.)

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Financial Tracking: Food

PresenterPresentation NotesFood: Food Service Management Company Invoice

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Financial Tracking: Food

PresenterPresentation NotesFood: Grocery store receipt

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Financial Tracking: Non-Food

PresenterPresentation NotesNon-food: Home supply store receipt*In this example, the organization co-mingled the purchase with some personal items, so they elected to deduct the items from the total cost.

Administrative supplies: Office supply store receipt

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Financial Tracking: Labor

PresenterPresentation NotesFood labor: CACFP Time and Attendance log for Cora Snead

Administrative labor: CACFP Time and Attendance log for Michael Tremble

Documentation Requirements. Payroll records. At a minimum, a record for each employee containing: (a) Employee name; (b) Employee identification number; (c) Rate of pay; (d) Hours worked; (e) Benefits earned; (f) Any reductions or increases to the employee’s base compensation, i.e., overtime pay, incentive award, etc.; (g) Gross pay; (h) Net pay; (i) Date of payment to employee; (j) Method of payment, i.e., check, cash, EFT; and (k) Verification that the employee has been paid, i.e., canceled checks or EFT deposit verification. For cash payments, an original signature certifying receipt of payment is required.

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Financial Tracking: Reimbursement

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Financial Tracking Summary

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• Best Practice: o No more than 10% reimbursement surplus in a claim month. o Reinvest the surplus in your food program within 3 months. Nutrition Initiatives: HTA Wellness Guidelines Increase Quality: more fresh, local, or seasonal produce Program Upgrades: new serving equipment Nutrition Education: curriculum, garden, kitchen

classroom, etc. - Document a long-term savings goal (large kitchen

equipment, substantial program upgrades, etc.)

Financial Tracking: Excess Reimbursement

Administrative Capability

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• Administrative Capability – Adequate and qualified staff – Written policies and procedures that assign Program responsibilities and

duties, and ensure compliance with civil rights requirements – Staff sufficient to meet ratio of monitors to facilities

• Equivalent of one (1) full-time staff person for each 50 to 150 day care homes (Sponsors of family day care homes)

• Equivalent of one (1) full-time staff person for each 25 to 150 centers (Sponsors of centers)

Performance Standard 2: Administrative Capability

7 CFR §226.6(b)(2)(vii)(B)

PresenterPresentation NotesThe renewing institution must be administratively capable. Appropriate and effective management practices must be in effect to ensure that the Program operates in accordance with this part.

This session will focus on institution staff and sponsored facility training, which overlaps with Performance Standard #3: Program Accountability – adequate and regular trainings.

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“Mary’s Kids” has a volunteer whose main responsibility is

center administrative duties.

Civil Rights

Scenario #1

PresenterPresentation NotesAre you required to train volunteers? Which trainings are required?*

*Best practice is to train volunteers on all CACFP administrative/operation areas.

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“Milly Rockers” hired a new assistant director who is responsible for determining income eligibility of participants,

as well as purchasing food and non-food items for the program.

Enrollment/Income Eligibility Statements

Income Eligibility Classifications Meal Pattern Requirements

Itemized Receipts Time and Attendance

Civil Rights

Scenario #2

PresenterPresentation NotesWhich trainings are required for this new assistant director?

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“Jordan’s Playground” hired a new teacher during the holiday break with Child and Adult Care Food Program experience.

Meal Pattern Requirements Daily Attendance Record Meal Count Procedures

Civil Rights

Scenario #3

PresenterPresentation NotesAre you required to train new staff? When should you train them? What trainings are required?

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“Mary’s Kids” has a parent volunteer who chaperones

field trips.

Civil Rights

Scenario #1

*Sponsors of centers and family day care homes

PresenterPresentation NotesAre you required to train volunteers?

This scenario is specific to sponsors of centers and family day care homes.

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“Roll Bounce” sponsoring organization was informed

Mike (provider) will be on extended medical leave for 3 weeks. Mike has hired a long-term substitute.

Conduct training on CACFP duties and responsibilities Civil Rights

Scenario #2

*Sponsors of centers and family day care homes

PresenterPresentation NotesWhat must the sponsoring organization do to on board this long-term substitute?

This scenario is specific to sponsors of centers and family day care homes.

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The sponsoring organization, “Roll Bounce”, was notified that Casey (provider) has hired a new aide. The aide has previous

experience with CACFP from her last job.

Yes, it is the responsibility of the Sponsoring organization to provide the required training for all new employees,

regardless if they have previous CACFP experience and training.

Scenario #3

*Sponsors of centers and family day care homes

PresenterPresentation NotesIs the sponsoring organization required to train new staff if they have previous Program experience and training?

This scenario is specific to sponsors of centers and family day care homes.

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Identifying Key Staff

Front line or staff positions who are responsible

for one or more areas of the CACFP.

Owners/Presidents/Board of Directors

Executive Directors Center Directors

Support and Administrative Staff Teachers/Aides/Volunteers

Food Service Staff

PresenterPresentation NotesKey staff are any persons responsible for or have oversight of one or more of the Program areas. The institution’s Authorized Representative (AR) signs an Annual Information Certification certifying its responsibility to train all staff on their duties as well as Civil Rights. If this AR leaves the Program, what will happen?

Authorized Representatives may be the Corporate Official/Owner, President of the Board of Directors, Executive Director, Military Commander

Official Designees- Financial Manager, Operational Specialist, Center Directors

Authorized Signer- Center Directors, Teachers

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Identifying Key Staff

Staff positions at either the sponsor and/or site level who are responsible for one or more areas of the CACFP.

Sponsor Level:

Executive Director/Owner Financial Manager

Support Staff Monitors

Site Level:

Center Director/Home Providers

Owner Teachers/Aides/Volunteers

PresenterPresentation NotesKey staff are any persons responsible for or have oversight of one or more of the Program areas. The institution’s Authorized Representative (AR) signs an Annual Information Certification certifying its responsibility to train all staff on their duties as well as Civil Rights. If the AR leaves the Program, what will happen?

Authorized Representatives may be the Corporate Official/Owner, President of the Board of Directors, Executive Director, Military CommanderOfficial Designees- Financial Manager, Operational Specialist, Center Directors Authorized Signer- Center Directors, Teachers

*This is specific to sponsors of centers and family day care homes

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Responsibility for:

• Administration and/or operations of the CACFP • Maintenance of Program records

• Compliance with other CACFP requirements • Monitoring*

*Sponsors of centers and family day care home

Train Key Staff

PresenterPresentation NotesSponsoring organizations must annually provide training on CACFP topics to front line and “key staff” from all sponsored sites. It is highly recommended that you implement a policy and procedure for sites to provide updated information on staff turnover.

Compliance with other CACFP requirements relate to annual trainings.

Site Level (Daily):

Recording attendance Prepare meals or collect delivery tickets Verify that each meal meets the CACFP meal pattern requirements Record any and all menu changes Serve meals Record the number of reimbursable meals served Record the number of meals served to staff or volunteers

Sponsor Level (Monthly): Create or update the menu as needed Prepare and submit the claim for reimbursement File the invoices, receipts, menus, attendance, and meal count records for the previous month

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Frequency & Timing of Training

Current Staff

Annually

New Staff

Upon Employment

Prior to being assigned CACFP

duties

Timing

Annually/Monthly

PresenterPresentation NotesCurrent staff must be formally trained on an annual basis, which is at least once during the organization’s defined program year.

New staff must be formally trained upon employment and prior to being held responsible for CACFP operations and duties. This applies to all volunteers as well.

Institutions need to determine and use established program year for training. What is your organization’s program year? (i.e. CACFP fiscal year, calendar year, etc.)

What is the timing of your training; one annual 2 hour CACFP training, monthly trainings during staff meetings/professional development, every 6mths, etc.?

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Required Trainings

Meal Pattern Requirements Menus

Meal Count Procedures

Daily Attendance Records

Itemized Receipts Claims Completion Procedures Training

Requirements Monitoring

Requirements*

Enrollment/Income Eligibility

Statements

Income Eligibility Classification

Time & Attendance Logs

Record Keeping Procedures

Civil Rights

PresenterPresentation NotesMeal Pattern Requirements- Knowledgeable of portion sizes, meal components, and creditable/non-creditable food items

Menus- Menu substitutions and ensuring all required meal components are served to make a reimbursable meal

Meal Count Procedures- Point of service

Daily Attendance Records- What is your organization’s policy and procedure for recording daily attendance?

Itemized Receipts- Best practice is to keep Program purchases separate and not co-mingle accounts

Claims Completion Procedures- If you are using an electronic system, it is recommended that you have a policy and procedure of how to capture and enter the data.

Training Requirements- Program trainings upon employment and annually

Monitoring Requirements- Sponsoring organizations are responsible for reviewing their affiliated and unaffiliated sites* This is specific to sponsors of centers and family day care homes.

Enrollment/Income Eligibility Statements- Maintain accurate IES forms for completion and accuracy, updating enrollment form as needed

Income Eligibility Classification- Accurately determining and verifying eligibility classifications

Time & Attendance Logs- Staff must correctly submit time and attendance for all work associated with Program operations.

Record Keeping Procedures- Maintaining Program files and records

Civil Rights- Anyone with direct contact with parents or children are required to attend Civil Rights training, at a minimum.

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• Training date(s) and location(s)

• CACFP topics presented at each

session

• Agenda and training materials/resources

• Names of staff members who

attended

Training Documentation

Training Documentation Form CACFP Institution Name: Date of Training Session:

Time of Training Session:

Location of Training Session:

Name and Job Title/Position of Trainer:

Topics Discussed: (Check all topics discussed during the training session)

Meal Pattern Requirements Itemized Receipts

Menus Time & Attendance Logs

Meal Count Procedures Training Requirements

Enrollment/Income Eligibility Statements Monitoring Requirements

Income Eligibility Classifications Claim Completion Procedures

Record Keeping Procedures Daily Attendance Records

Civil Rights

Other

Attendee Sign-In:

Name Position Title

PresenterPresentation NotesAll CACFP staff trainings, including materials and resources used must be documented and maintained with Program files. The staff documentation form should be completed for every training. This training documentation form is located in program resources on the OSSE website.

The required information includes:

Training date(s) and location(s)Program topics covered during each session Agendas and training materials/resourcesNames, titles, and signatures of every staff member who attended the training

Individuals listed in the management plan, must specifically attend Program training annually and their signatures and titles must be recorded.

If it is not on paper, it did not happen.

The Child and Adult Care Food Program

Training Documentation Form

CACFP Institution Name:

Date of Training Session:

Time of Training Session:

Location of Training Session:

Name and Job Title/Position of Trainer:

Topics Discussed:

(Check all topics discussed during the training session)

Meal Pattern Requirements

Itemized Receipts

Menus

Time & Attendance Logs

Meal Count Procedures

Training Requirements

Enrollment/Income Eligibility Statements

Monitoring Requirements

Income Eligibility Classifications

Claim Completion Procedures

Record Keeping Procedures

Daily Attendance Records

Civil Rights

Other

Attendee Sign-In:

Name

Position Title

06/2015 CACFP Training Documentation Form

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Training Resources

PresenterPresentation NotesThe OSSE website offers access to several training resources. Other useful training resources are USDA memos, Team Nutrition posters, and CACFP Halftime: Thirty on Thursdays Training Webinars. Additional training materials are your organization’s employee handbook, internal standard operating procedures (SOPs), and materials specific to your organization are great training tools as well.

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Whose Job is It Anyway?

1. Who is the Authorized Representative at your institution? 2. Who plans the menu and ensures it meets the meal pattern requirements? 3. Who submits the monthly claim for reimbursement? 4. Who determines the reimbursement category of each Income Eligibility

Statements (IES), based on the information reported by the parent/guardian?

5. Who is responsible for attending Orchard and/or annual training? 6. Who vets your application for completion and accuracy prior to submission?

Take Away Tidbits

PresenterPresentation NotesThe individual who is assumes ultimate fiscal and administrative responsibility for the program; named the responsible principal when declared seriously deficient. Titles include Executive Director, Center Director, Owner, Military commander, or President of the Board of Directors.This individual must be employed or contracted by the institution, i.e., the cook, food service manager, Center director. If your institution has a FSMC, it is still ultimately the responsibility of institution to ensure all menus are compliant with the meal pattern.This individual may have the title financial manager, operations specialist, Center director, or owner. This individual may have the title admission coordinator, compliance manager/associate, Center director, deputy director.This individual may have the title Center director, program manager, food service coordinator, nutrition specialist, owner, or Military commander. In the Orchard application, this person is listed as the primary contact, official designee, authorized signer, and/or Authorized representative. The Authorized Representative.

Program Accountability

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• Program Accountability – Governing Board of Directors – Fiscal Accountability – Recordkeeping – Adequate and regular training – Ensuring sponsored facility compliance – Accurately classify day care homes as tier I or tier II – Retaining appropriate administrative funds – Meal service and other operational requirements

Performance Standard 3: Program Accountability

7 CFR §226.6(b)(2)(vii)(C)

PresenterPresentation NotesThe renewing institution must have internal controls and other management systems in effect to ensure fiscal accountability and to ensure that the Program operates in accordance with the requirements of this part.

(i)Fiscal integrity and accountability for all funds and property received, held, and disbursed;(ii) The integrity and accountability of all expenses incurred;(iii) That claims are processed accurately, and in a timely manner;(iv) That funds and property are properly safeguarded and used, and expenses incurred, for authorized Program purposes; and(v) That a system of safeguards and controls is in place to prevent and detect improper financial activities by employees;

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• A system of checks and balances that provide assurance that policies and procedures work as designed.

• Critical for effective business management. • Proactive and strategic approach to managing the CACFP. • Key elements are Control Activities.

Internal Controls

PresenterPresentation NotesFederal regulations:The GAO Green Book outlines internal control standards through five (5) internal control components and seventeen (17) principles.2 CFR 200.3032 CFR 200.627 CFR 226.6(b)

GAO Green Book - five elements of internal controlsControl environment: tone at the topRisk Assessment: risks to maintaining complianceControl Activities: policies, Standard Operating Procedures, verification checksInformation and Communication: reliable reportingMonitoring: evaluate controls and update

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Internal Controls

Policies “What”

• Regulations, rules, and laws for administering the CACFP

Procedures “How”

• Step-by-step process to follow the rules

Verification “Check”

• Activities performed to verify that established procedures are followed

PresenterPresentation NotesControl activities are standard operating procedures.

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• SOPs standardize operations. – Reduces miscommunication; increases uniformity. – Simplifies monitoring and edit checks; ensures compliance. – Achieves efficiency and high-quality output.

• SOPs allow leadership and management to turn their attention to program improvement initiatives. – Less time spent on micromanaging, double checking work,

and running down work assignments. • Ensures consistency and continuity.

– SOPs ensure that information is shared across and between staff and units.

• They are living documents that can be modified, as needed.

What are the Benefits?

PresenterPresentation NotesA lack of SOPs lead to findings. During an Administrative Review, the SA monitors for documentation and procedure.Standardized operations reduces miscommunication (everyone knows what’s expected and how to do it); increases uniformity (the task will always be done the same way); simplifies monitoring and edit checks; ensures compliance; achieves efficiency and high-quality output (streamlines and schedules time to complete tasks).Once drafted and implemented, SOPs allow leadership and management to turn their attention to program improvement initiatives; less time spent on micromanaging, double checking work, and running down work assignments.Ensure consistency and continuity. Child care community suffers from high staff turnover. SOPs ensure that information is shared across and between staff and units. The information doesn’t live in a silo, where only one person knows how to execute a particular duty.They are living documents that can be modified as needed (when regulations change, when staff changes, when procedures are simplified, when technology is introduced, etc.).

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Activity

1) Each pair receives a Policy. Each pair will develop Procedures and Verification steps for the procedures developed.

2) Develop Procedures that include step-by-step instructions to support the policy.

3) Develop Verification steps that act as an edit check for the procedures. 4) Finish the Procedures and Verification steps before the sound of the

buzzer!

PresenterPresentation NotesThink about two-step verification for password protected accounts and devices…Layered checks that ensure accuracy and identify errors.

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• Consider your audience. • Consider your knowledge. • Collaborate! Interview the personnel involved in

the process on how they execute tasks. • Have the SOP reviewed by those who actually

do the procedure. • Conduct training.

– REMINDER! Be sure to document training. • Make on going adjustments.

Best Practices!

PresenterPresentation NotesEnsure staff and sponsored facilities are trained on all policies and procedures. Recordkeeping is key! Obtain signatures for trainings; email receipt for memos; etc.

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ADDRESS:

POC:

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OSSE 1050 First Street NE WDC 20002

Crishna Hill, CACFP Specialist Crishna.hill@dc.gov (202) 727-4742

mailto:Crishna.hill@dc.gov

Slide Number 1AgendaPerformance StandardsSlide Number 4Performance Standard 1: Financial ViabilityFinancial ViabilityFinancial TrackingFinancial TrackingFinancial TrackingFinancial Tracking: FoodFinancial Tracking: FoodFinancial Tracking: Non-FoodFinancial Tracking: LaborFinancial Tracking: ReimbursementFinancial Tracking SummaryFinancial Tracking: Excess ReimbursementSlide Number 17Performance Standard 2: Administrative CapabilityScenario #1Scenario #2Scenario #3Scenario #1 Scenario #2Scenario #3Identifying Key StaffIdentifying Key StaffTrain Key Staff Frequency & Timing of Training Required Trainings Training Documentation Training ResourcesTake Away TidbitsSlide Number 33Performance Standard 3: Program AccountabilityInternal ControlsInternal ControlsWhat are the Benefits?ActivityBest Practices!Slide Number 40