|DATE:||September 1, 2010|
|SUBJECT:||Supplemental Nutrition Assistance Program (SNAP) - Fiscal Year (FY) 2011 Target Areas for Management Evaluations (MEs)|
The Food and Nutrition Service (FNS) has identified critical program areas to be monitored for the successful operation of SNAP nationwide. The designated FY 2011 national target areas for management evaluation (ME) reviews are listed below. In addition, FNS has identified other program areas that should be reviewed on an at-risk basis, but at least once every six years. We encourage the regional offices (RO) to consider the specific operations of each state agency in determining whether other program areas should be reviewed.
FY 2011 National Target Areas
1. Program Access - to include on-line application processing and call centers
2. State ME Systems
3. Quality Control
Other Review Areas
1. Recipient Claims Management
3. Nutrition Education
4. Employment and Training
5. Electronic Benefit Transfer
ME Reviews of Target and Other Areas
At a minimum, ROs must perform a review of program access at the state agency level, of the state's ME system, and of the state's quality control (QC) system. These MEs must be performed in accordance with the approved schedule or on a more frequent basis if there is an identified risk. ROs have the flexibility to review the other areas on an at-risk basis but at a minimum every 6 years. This includes nutrition education which ROs were previously required to review every two years. Payment accuracy may be reviewed on an as-needed basis. In determining risk, the RO should take into consideration how long it has been since an area has been reviewed, if there were any deficiencies identified at that time, and if there has been any recent changes to the program area. The RO does not need to include the reason a program area was not reviewed in the ME review report that is sent to state agencies.
Except where local level site visits are required (state ME systems and nutrition education), review of a target or other program area may be conducted off-site if data is available at the RO to ensure an adequate review. When determining whether or not to perform an on-site review, the RO should refer to the ME review guides that have recently been developed and consider changes that put the state agency at risk for compliance problems such as recent staffing cuts, personnel changes, reduced budgets, policy changes.
ROs should use the standardized ME review guides that have recently been developed to review the specified program areas. More information concerning the review guide for quality control will be forthcoming.
ROs are still required to perform four local level program access reviews (PAR) per year. A full local level PAR using the review guide can be substituted for the required local level ME review. A shadow or follow-up review of a state's ME can be used as a PAR when the shadow review is augmented to meet the PAR guidelines or the follow-up review's focus is on program access and the PAR guide is used.
State Agency Responsibilities
The regulations at 7 CFR 275.8 provide that states shall review the national target areas specified by FNS. Considering that states are stressed due to reduced resources, FNS has determined that states should focus their reviews on program access and review the other areas on an at-risk basis. This gives states the flexibility to put resources where the risks are greatest and to conduct more effective reviews.
The regulations at 7 CFR 275.9(b) provide that state agencies develop a plan prior to each ME review. Under the regulations at 275.5(b)(2) each project area must be reviewed at least every 3-years. Allowing state agencies to submit a plan that covers the 3-year review cycle and provide updates annually is consistent with the regulations.
If reviewers at the RO are not familiar with a target or other area the RO may need to train reviewers to conduct the review or assign the review to other staff within the RO who have the expertise. For example, financial management staff may monitor and review the financial area of a target, information technology staff may monitor and review an automated function, or civil rights staff may review an overlapping client services target. It does not matter which staff conduct the review as long as the target and other areas are covered so problems are identified and corrected.
Reports of FNS Regional Office Review Activity
As described below, the ROs are required to submit information on their review activity.
Review ScheduleThe RO schedule of review visits to states, including review type and coverage is due by Jan. 1, 2011. Please include program access reviews (PARs) to local offices in this schedule and indicate what areas will not be reviewed in each state, if known. Please provide this information to Moira Johnston, Chief Program Design Branch and Connie Slough, Special Assistant, Associate Administrator's Office for Program Service and Support.
RO Summary of Review ActivitiesROs can enter the summary of each review conducted into the ME tool that can be accessed through the Partner Web. If an RO chooses to upload its end of the year summary as an attachment instead of entering the information into the tool, the attached reporting format should be used. ROs should remember to enter the summary of each local PAR conducted. Please contact Tim McCrosson at firstname.lastname@example.org for access to the tool. Summaries of review activities are due Nov. 30, 2011.
We appreciate the effort made by you, your staff, and your state agency partners to ensure the integrity of and improve access to SNAP.
Supplemental Nutrition Assistance Program
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.