On-site/Off-site Monitoring Guidance (SFSP)

Why it Matters

Virtual monitoring waivers have provided flexibilities that have been crucial to the continued, successful, monitoring of CACFP programs. As the waivers are ending, State agencies and sponsoring organizations must prepare to conduct all monitoring visits onsite. USDA’s guidance allows state agencies and sponsoring organizations to conduct some monitoring requirements off-site, however all three visits must be conducted on-site for meal counts. 

On-site/Off-site Monitoring Guidance Summer Food Service Program (SFSP)

In response to State agencies and sponsoring organizations implementing innovative solutions to conduct off-site reviews and provide oversight of the SFSP throughout the public health emergency, FNS has developed the following guidance for conducting off-site monitoring. The review must take place at the institution or facility’s location, though portions may be conducted at the State or sponsoring organization’s office, informally known as the ‘desk review’ or ‘desk audit’ portion. There may be a combination of reviews conducted to complete the Program review. For instance, the State agency monitor may evaluate the institution’s single audit, budget, and training attendance via desk review and conduct the balance of the evaluation of the institution’s Program on-site. Please note that these on-site and off-site strategies apply to both congregate and non-congregate meal service options.

Tips for Best Practices

1. Plan ahead and communicate.
2. Develop a standard process.
3. Consider feasibility of a hybrid approach.
   • Obtain documents through a secure platform to ensure personally identifiable information is secure.
   • Conduct the exit interview can be conducted via video conferencing as an off-site approach.
4. Develop checklists and tools to ensure operators are aware of on-site and off-site review requirements and documentation submission procedures.
   • Request additional information as needed to resolve issues found in the off-site
     portion.
5. Document any off-site elements of the review and interviews.
6. Practice using a file sharing platform among staff before conducting a review.
7. Evaluate your established review standard procedures and make modifications to reflect latest learned strategies.

SFSP State Agency Review Content

Review Element and Regulations	Procedures to be Conducted On-site	Procedures with Option to be Conducted Off-site
Food Service Management Company Registration (7 CFR 225.6(k))		Request and obtain a copy of the registration document. May evaluate the registration document as part of a desk audit.
Monitoring of food service management company procurements (7 CFR 225.6(l))	Visits conducted to inspect facilities are to be conducted on-site.	Evaluate copies of State or local health certifications, contracts, books, and records pertaining to the sponsor’s food service operation as part of a desk audit.
Meal Ordering (7 CFR 225.6(l)(2)(iv))		Evaluate invoices, delivery receipts, and meal counts as part of a desk audit.
Pre-approval Visits (7 CFR 225.7(d))	Pre-approval visits must be conducted on-site.
Review of Sponsor and Site Reviews (7 CFR 225.7(e))	Reviews must be conducted on-site.
Meal Claim Validation (7 CFR 225.7(e)(6))		Request and obtain copies of meal counts, delivery receipts, and or production records. Conduct reconciliation as part of a desk audit.
Follow up Reviews (7 CFR 225.7(f))	Visits conducted to inspect facilities are to occur on-site.	Request and obtain copies of written corrective action and supporting documentation, for example, a corrected menu for a meal pattern violation.
Records (7 CFR 225.7(h))		Request a sample of records to cover the scope of the last three years plus the current year (dated invoices, training, mileage log, etc.).
Meal Preparation Facility Reviews (7 CFR 225.7(i))	Visits conducted to inspect facilities are to occur on-site.
Corrective Action (7 CFR 225.7(k))	Conduct a follow-up visit or in some other manner verify that the specified corrective action has been taken.	Conduct a follow-up visit or in some other manner verify that the specified corrective action has been taken.
Other Facility Inspections and Meal Quality Tests (7 CFR 225.7(l))	Visits conducted to inspect facilities are to occur on-site.
Financial Management (7 CFR 225.7(m))		Request and obtain documentation of the net cash resources of the nonprofit food service account. Evaluate these records as part of a desk audit.
Training and Monitoring (7 CFR 225.7(j))	The reviewer must ensure that at least one person who has received SFSP training is present at each meal service.	Request and obtain copies of dated training materials and agendas and attendee sign in sheets. If training is conducted virtually, obtain dated confirmation. Request and obtain copies of site review forms, schedules, and tracking logs.
Sponsor Site Visit (7 CFR 225.7(o))		Request and obtain documentation of site visits and review forms for sites that had operational problems in the year prior.
Notification to the Community (7 CFR 225.15(e))		Request and obtain the media release and marketing materials for the Program.

SFSP Sponsor Review Content

Review Element	Procedures to be Conducted On-site	Procedures with Option to be Conducted Off-site
Meal Ordering (7 CFR 225.15(b))		Request records of participation from sites, review approved levels of meal service, and keep records of meal ordering adjustments.
Records and claims (7 CFR 225.15(c))		Sponsors must maintain records to cover the scope of the last three years plus the current year (dated invoices, training, mileage log, meal counts, etc.).
Food Service Operations (7 CFR 225.15(d)(3))	Visits conducted to verify food service operations are to occur on-site.
Meal Service (7 CFR 225.15(d)) (7 CFR 225.16(b))	Visits conducted to verify meal service operations are to occur on-site. At least one full meal service must be observed.
Training and monitoring (7 CFR 225.15(d)(1))	The reviewer must ensure that each site has present at each meal service at least one person who has received SFSP training.	Request and obtain copies of dated training materials and agendas and attendee sign in sheets. If training is conducted virtually, obtain dated confirmation.
Training and monitoring (7 CFR 225.15(d)(2)) (7 CFR 225.15(d)(3))	The sponsor must visit each of their sites, including a full review of food service operations during the first four weeks of Program operations.
Food Service Management Companies (7 CFR 225.15 (m))	Visits conducted to inspect facilities are to be conducted on-site to ensure the operator is in conformity with its agreement with the State agency and contract with the sponsor.	Sponsors must maintain records including but not limited to bids, contracts, site visits and reviews, etc.
Meal Preparation (7 CFR 225.16(a))	Visits conducted to verify meal preparations operations are to occur on-site.
Meal Pattern Requirements (7 CFR 225.16(d))	Requirement: Validate meal items/components and quantities, complete meals, and meal signage on day of review onsite.	Request and obtain copies of menus. Evaluate menus for compliance with meal pattern requirements.
Civil Rights Compliance – FNS INSTRUCTION 113-1 Civil Rights Compliance and Enforcement – Nutrition Programs and Activities	Visits conducted to verify civil rights compliance are to occur on-site to ensure compliance requirements are routinely implemented and the “And Justice for All” poster is displayed.	Request civil rights training logs and attendee sign in sheets. If training is conducted virtually, obtain dated confirmation. Verify that civil rights data submitted for the eligible population is from a credible source (U.S. Census data).

 

To read the full guidance, read On-site/Off-site Monitoring Guidance Summer Food Service Program (SFSP) (SFSP-06-2023).