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The Oregon Department of Education Child Nutrition Programs (ODE CNP) is providing updates to the administrative review procedures for the Child and Adult Care Food Program (CACFP), effective as of Fiscal Year (FY) 2024. These updates are a result of USDA guidance and an internal review of practices and regulations.
All Sponsor Updates
The below updates apply to all CACFP sponsors.
Underclaims Found During a Review
An underclaim is an error found by ODE CNP, during review of records, that would result in an increase in reimbursement.
This year, ODE CNP received guidance from USDA concerning our application of underclaims found during administrative reviews. Previously when an underclaim was determined by ODE CNP, whether this was through a meal counting error or an inaccurate One Month Enrollment Roster, ODE CNP would reimburse for the underclaim, or apply the number of underclaimed meals to the total overclaim for the sponsor’s review, lessening the total funds owed.
Based on USDA’s guidance this practice is not in line with regulation and ODE CNP has been inaccurately providing reimbursement and/or applying underclaims.
Effective immediately, ODE CNP will no longer take underclaims into account during administrative reviews. If the review is conducted prior to the claim due date, 60 days following the end of the claim month, the sponsor will have the ability to revise the claim to match the ODE CNP verified claim. If the claim due date has passed, sponsors may choose to use a one-time exception, to have an upward claim adjustment. One-time exceptions are available by program once every 36 months. For more information on the one-time exception process, please see Chapter 6, of the CACFP Policy and Procedure Manual.
One Month Enrollment Roster Adjustments
During a review, ODE CNP will verify One Month Enrollment Rosters based on the sponsors supporting documentation. If an OMER revision is required based on ODE CNP’s verification, the following will occur:
- A revised OMER that increases reimbursement to the sponsor will be applied to the next claim following the end of the appeal period. ODE CNP will not revise the OMER on previous claims.
- A revised OMER that decreases reimbursement to the sponsor will be included in the Fiscal Action Tool and may be recovered by ODE CNP if the total downward claim adjustment from the review is $600 or more. if the total fiscal action for a review is $600 or more, ODE CNP verified numbers will be applied from the test month forward, whereas if it is under the total disregard of $600, the revised OMER numbers will be applied to the next claim following the end of the appeal period.
Verification of Previous Corrective Action Implementation
During review, ODE CNP will now verify that findings from previous reviews have been corrected and the sponsor’s accepted corrective action plan has been implemented. While ODE CNP did have a process to review this previously, it was an informal review. Under USDA’s guidance, specific questions have been added to the CACFP Administrative Review tool to formally verify that the corrections have taken place, and the sponsor’s submitted policies are being followed. Please ensure policies and procedures are current and up to date. We recognize that policies and procedures may have changed since the organizations last administrative review, it is important to provide specialist with a copy of the most current policy and/or procedure.
Exit Conferences
ODE CNP will be moving to virtual exit conferences to be conducted within 10 calendar days of the end of the active review period. An active review period may conclude at the end of the onsite review, or there may be additional items that are reviewed as a desk review. The assigned Child Nutrition Specialist will work with the sponsor to determine a time that works best for all who will attend the exit conference. On occasion, when time allows, an exit conference may be conducted on-site, at the agreement of the sponsor and specialist.
During the on-site portion of the review, specialists will continue to meet with the Food Program Coordinator, each day, to inform them of the status of the review.
CACFP Appeal Procedure – Issuance Timeline
Previously, ODE CNP provided the CACFP appeal procedure at the end of the review process after corrective action had been accepted. This timeline increased potential delays in reimbursement payments and lengthened the time a review remained open.
After careful consideration, ODE CNP will issue the appeal procedure during the exit conference, when informing the sponsor of any adverse action being taken. This change aligns the appeal timeline across the CACFP and Summer Food Service Programs (SFSP), as well as lessens the potential for delays in reimbursement and the time of the review.
The ODE CNP CACFP Appeal Procedure remains the same and can be found on the ODE CNP public webpage. The appeal procedure includes a list of adverse actions that sponsors may appeal, as well as the process and timeline in which an appeal must be received.
School Food Authority (SFA) Specific Updates
The following administrative review updates are specific to SFA Sponsors only.
Administrative Review Scheduling
When schedules allow, ODE CNP may reach out to an SFA that is scheduled to receive both a School Nutrition Program Administrative Review (SNPAR) and a CACFP Administrative Review in the same year, to determine if the sponsor would like to have the reviews conducted at the same time. SFA’s may choose to accept or decline this offer. If the offer is declined, your assigned CACFP Child Nutrition Specialist will work with you to determine a different time frame, within the year, to schedule the review.
Verification of Financial Management Implementation
On February 8, 2021, ODE CNP issued guidance to our sponsors detailing the requirement that all CACFP sponsors must have written management controls in place that ensure fiscal integrity of program funds, accountability of all expenses, the use of program funds only for authorized Program purposes, safeguards to prevent improper financial activities, and measures to ensure CACFP administrative costs do not exceed the regulatory limits. Since the issuance of this memo, ODE CNP has reviewed SFA’s written financial management policy and procedures. Beginning this review year, Child Nutrition Specialists will now verify that SFA’s are implementing their policies and procedures as written, and will review documentation to support the receipt and expenditure of CACFP funds for the test month.
If you have any questions or concerns, please contact your assigned Child Nutrition Specialist.
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