SFSP Best Practices for Meal Claim Verification and Ensuring Properly Payable Claims

This memorandum offers state agencies best practices for using appropriate documentation to validate claims for reimbursement for self-preparation (self-prep) sites and ensuring claims are properly payable in the Summer Food Service Program (SFSP). An audit by the USDA Office of Inspector General (OIG), Consolidated Report of FNS and Selected State Agencies’ Controls over SFSP, Audit Report 27601-0005-41, disclosed that states need additional guidance on establishing methods and procedures for ensuring the accuracy of sponsor program payments by verifying appropriate record keeping for sponsors with self-prep sites. State agencies must establish and maintain procedures to validate the sponsors’ meal claims utilizing a record review process that includes, at a minimum, per 7 CFR 225.7(e)(6)(i), reconciling delivery receipts, daily meal counts from sites, and the sponsors’ claim consolidation spreadsheets against the meals claimed for reimbursement by the sponsors for periods under review. State agencies must also ensure that claims submitted for reimbursement are properly payable, which means that the sponsor’s records justify all costs and meals claimed. Corrective action must adequately address any issues related to claiming issues and other areas of noncompliance.

Background

Simplified cost accounting procedures allow SFSP sponsors to claim reimbursement for eligible meals using “meals times rates” (i.e., the number of meals served times the per meal rate equals the total amount of reimbursement). Sponsors are not required to report their costs to the state agency but are required to maintain documentation indicating that reimbursements were spent on allowable child nutrition program costs. This documentation must be available for state agency review or audit purposes. Regulations also require the state agency to develop and utilize a records review process to validate sponsors’ meal claims.

This guidance offers best practices to complement regulations at 7 CFR 225.7(e)(6) regarding meal claim validation and updated guidance on simplified cost accounting procedures in SFSP 05-2017 Summer Food Service Program Questions and Answers, Dec, 1, 2016 and SFSP 01-2008, Nationwide Expansion of Summer Food Service Program Simplified Cost Accounting Procedures, Jan. 2, 2008. FNS shares these best practices for states seeking additional guidance regarding appropriate documentation that can be used for reconciling claims for reimbursement for self-prep sites and can be applied to vended sites as well. Sponsors should be aware of the types of important documentation needed to facilitate meal claim validation by state agencies as well as ensure records are made available to the state agency to support all claims for reimbursement, per 7 CFR 225.9(d)(5). All documentation related to the sponsors’ meal claims should be maintained so that state agencies can periodically verify previous determinations assessed by state agency reviewers.

FNS appreciates the effort of state agencies and local program operators working to meet the nutritional needs of children during the summer months. State agencies are reminded to distribute this memorandum to program operators. Program operators should direct any questions concerning this guidance to their respective state agency. State agencies with questions should contact the appropriate FNS regional office.

Jessica Saracino
Director
Program Monitoring and Operational Support Division
Child Nutrition Programs
 

Attachment

• Best Practices for Meal Claim Verification of Self-Preparation Sites in the Summer Food Service Program