AAA Operations Policy #9: AAA Monitoring of Service Providers

This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.

Authority Reference	45 CFR Part 75 Subpart D – Performance and Financial Monitoring and Reporting 45 CFR Part 75 Subpart D – Subrecipient Monitoring and Management Thompson Publishing – “Techniques for Monitoring Federal Subawards” Circ. A-133 OGM 08-06 Pre-Award Risk Assessment OGM 08-10 Policy on Grant Monitoring
Operating Category	AAA Operations

Policy

1. The AAA shall conduct ongoing monitoring and assessment of service providers under the Area Plan to ensure that funds are expended in keeping with the purposes for which they were awarded.

2. Although the level of oversight required for each service provider will vary according to the dollar value of the service provider’s contract or grant agreement and according to the outcome of the service provider’s pre-award risk assessment, AAAs must perform at least a minimum amount of monitoring as described in this policy.

A. AAAs must conduct an in person on-site monitoring visit to each service provider with a grant or contract agreement of $50,001 or more before the end of the grant or contract period. This dollar value applies to the initial contract period as well as any extension amendments. In extraordinary circumstances, such as a pandemic or another significant unanticipated situation of extended duration, AAAs may conduct monitoring visits virtually.

The monitoring visits described in this section 2(A) are intended to be with the service provider’s management team and are separate from and in addition to nutrition site visits described below. The purpose of monitoring visits is to review and ensure progress with objectives in the grant or contract, to address any problems or issues before the end of the grant or contract period, and to build rapport between the AAA and the service provider. An effective grant monitoring visit may cover topics including but not limited to statutory compliance, challenges faced by the service provider, new requirements, program outcomes, service provider policies and procedures, and training and technical assistance needs. Provided the AAA otherwise meets the minimum requirements of this policy, the AAA may determine what additional topics to cover during the annual monitoring visit.

During the on-site monitoring visit, AAAs must pull a sample of at least 20 records from the provider’s PeerPlace data and document the following:

· i. Does the client have a current NAPIS form on file (meaning has it been completed in the past year)?

· ii. Does the number of units received by the client for the past three months raise any concerns? (For example, has the client received a number of meals that seems unlikely for the time period?)

B. AAAs must also conduct a financial reconciliation of service providers’ expenditures at least once on grants or contracts of $50,001 or more before final payment is made. A financial reconciliation involves reconciling a grantee’s request for payment for a given period with valid supporting documentation for that request and occurs before a final payment is made. Examples of valid supporting documentation include purchase orders, receipts, bank statements, and payroll records. AAAs must maintain documentation used for financial reconciliation for six years.

3. AAA monitoring practices for all service providers, regardless of the amount of their grant or contract, must include the following:

A. Review of half year narrative reports submitted by each service provider;

B. Monthly or quarterly review of expenditures submitted by each service provider commensurate with the time period expenditure data are submitted (for example, if the service provider submits expenditure data monthly, the AAA must review the data monthly);

C. Monthly review of data entered into PeerPlace, including monitoring number of units provided;

4. AAAs shall also conduct site visits to at least one third of its congregate and home-delivered meal sites (or twenty sites, whichever is less) each year. For purposes of counting, each visit counts as one visit regardless of the number of types of services or number of additional sites a central site supports.

A. In addition, AAAs shall make unannounced spot-check site visits to congregate and home-delivered meal sites as needed as part of its monitoring responsibility.

B. In addition to the annual criteria for visiting 1/3 or at least 20 of its congregate and home-delivered meal service providers, the AAA must ensure a different set of sites are visited each year. The AAA must also ensure each meal site receives a site visit at least every three years.

C. When a congregate site receives a monitoring visit, the AAA must check the following:

· i. That the on-site kitchen is preparing a meal in accordance with the health and safety standards of the Nutrition Policy;

· ii. That the site has a menu plan that meets the standards outlined in the Nutrition Policy;

· iii. That voluntary contributions are being solicited for the meal, that they are stored in a secure manner if a meal participant makes a cash voluntary contribution, and that any non-eligible participants in the meal pay the advertised cost of the meal.

D. When a home-delivered meal site receives a monitoring visit, the AAA must check the following:

· i. That the site at which the meal was prepared cooked the meal in accordance with health and safety standards described in the Nutrition Policy (or, alternatively, if the meal being delivered is a frozen meal, that any meals currently being prepared at the service provider’s central food preparation site meets health and safety standards);

· ii. A NAPIS form has been completed for the individual(s) receiving the meal.

· iii. That the meal has been transported using an insulated bag as required in the Nutrition Policy.

Procedures

1. AAAs must develop plans, procedures, and templates for monitoring visits and follow up summary reports so that each service provider receiving a site visit goes through a standard monitoring process.

2. By March 1 of each year, AAAs must identify which grants require a monitoring visit and which grants require a financial reconciliation, where the monitoring visits and financial reconciliations will take place, and the position titles for which AAA employees will participate. This monitoring plan must be submitted to MBA.

3. AAAs must work with service providers to schedule monitoring visits (unless an unannounced spot check is being conducted for a nutrition provider), giving service providers adequate notice and preparation time. AAAs should advise service providers on how to prepare for the monitoring visit and financial reconciliation, the format for the visit and which service provider staff members should be involved in the visit.

4. AAAs should review all financial and progress reports that have been submitted prior to the on-site visit.

5. When AAAs are on site for the monitoring visit, they should document activities carried out and any findings from the visit. AAAs must maintain documentation about the site visit in the grant file.

6. AAAs must provide each service provider with a follow up summary report from their site visit within 14 business days. The summary report must include any areas where changes or improvements are required, including whether any corrective action plans are required.