Monitoring The Corrective Action Process Monitoring Elements of

Monitoring & The Corrective Action Process

Monitoring Elements of monitoring requirements: • • • 2 Types of Monitoring Visits Frequency Announced & Unannounced Reviews Timing Scheduling Follow-up

Monitoring Types: Frequency & Timing Monitoring visits – Pre-approval • Visit includes training, ensuring ability of VCA, prior to claiming – New facilities/homes • Visit within first four weeks of operations – Annual reviews • Three times per year – Two unannounced – At least one unannounced meal observation Timing – Irregularity – Fiscal year or calendar year (specify) 3

Monitoring: High-Need Facilities/Homes • Review Averaging – A tool to assist struggling facilities/homes – Visit high-need facilities/homes more than three times a year • Fully compliant facilities/homes visited reviewed less than three times – All visits are still less than six months apart – Must still conduct average of three visits of all facilities/homes in a review year – Must still conduct average of two unannounced reviews of all facilities/homes that year – Must receive approved justification for review averaging • Submit monitoring schedule • Submit justification for using review averaging 4

Monitoring Form Elements – Total operations overview • Record Maintenance/Recordkeeping • Financial Management • Health & Safety • Civil Rights 5

Five-Day Reconciliation

Five-Day Reconciliation • Five-day Reconciliation – USDA allows for aggregate reconciliation • If need to determine a source of error, use by-name reconciliation – Monitor may choose to reconcile meal counts with: • Attendance • Sign-in sheets • Enrollment forms - Top portion of IES – Using enrollment forms to collect weekdays children are present can be arduous; therefore the SA advises sponsors to use this method for by-name reconciliation – For sponsors of facilities: • Number of children reviewed – At least 10 percent of enrolled children per facility – Minimum 5 children (facilities with 50 or less children) – Random Sample 7

Five-Day Reconciliation • Reviewing a center that operates M – F and captures children by attendance/sign-in sheets Date (m/d/yr) Day 1 Day 2 Day 3 Day 4 Day 5 5/1/18 4/30/18 4/27/18 4/26/18 4/25/18 Attendance/Sign-In/ Enrollment Totals Meal Count Totals Breakfast 5 6 4 4 6 5 6 4 AM Snack Lunch PM Snack 6 6 5 6 4 4 6 5 6 4 Supper Evening Snack • What are two problems you see here? (1) 5/1/18: Lunch count higher than attendance total Attendance could’ve been taken inaccurately or meal count done incorrectly (2) The subsequent four days show the exact same count across all meal types and attendance. Block claiming? 8

Five-Day Reconciliation • Five-day Reconciliation Enrollment Child’s Name Day(s) Time Day 1 Day 2 Taylor M-F 8 am – 5 pm Kamilah M-F 8 am – 5 pm x Jesus M-F 8 am – 5 pm Josh M-F Aniyah M-F Day 4 Day 5 x x x 8 am – 5 pm x x x 8 am – 5 pm x x 3 4 5 4 4 Enrollment Totals Date Day 1 Day 2 Day 3 Day 4 Day 5 9 Breakfast 3 4 5 5 3 Attendance Day 3 AM Snack 3 4 5 5 4 Lunch 3 4 5 5 4 PM Snack 0 0 0 Supper 0 0 0 Evening Snack 0 0 0

Corrective Action Process 10

Corrective Action: A training tool • Summary of Technical Assistance or Findings List any problems that were noted during the visit and any related technical assistance or corrective actions that were initiated to correct the problems. Review Item Meal service/ observation Brief Description • James was given water at lunch and no milk. • Mc. Kenzie drank almond milk from home with lunch. • Both children were counted on the lunch meal count. • The facility/home has no Medical Substitution forms on file. Corrective Action CA Due Date Which ones can be corrected on-site with TA? Staff could’ve been instructed to give James milk (if no allergy). Mc. Kenzie could have been removed from the lunch meal count and not claimed. 11

Corrective Action: A training tool • Summary of Technical Assistance - List the problem and what technical assistance was given on-site - Have the individual receiving technical assistance sign and put their job title - Make sure that the area which TA was given is emphasized in the next monitoring visit - Best practice: collect follow-up documentation if needed • Summary of Corrective Action - Address issues early before the problem grows - Collect follow-up documentation or schedule a follow-up visit to ensure implementation of CAP done 12

What’s Technical Assistance vs Corrective Action • Questions to ask – Is it systemic? – Was it a one-time occurrence? • Can it be fixed on-site? – Is there reason to collect follow-up documentation for the issue? Small groups: What would make these technical assistance or findings? What TA training or corrective action would be given? (1) Incorrect milk being served (2) Delivery tickets not being signed (3) Food temperatures not taken upon arrival on day of visit (4) Substitution not recorded on menu for entire day (5) Sponsors with cash agreements: facilities are not tracking surplus of reimbursement 13

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