HomeMy WebLinkAboutexhibit1aFLORIDA DEPARTMENT OF
HEA LT
Bureau of Child Nutrition Programs
Child Care Food Program
FY 2004-2005 CONTRACT
ATTACHMENT 1
This attachment incorporates those serious deficiencies found in 7 CFR Part 226 and provides
examples of non-compliance with program requirements. Contractors who commit or engage in
any serious deficiencies, including but not limited to those incorporated herein, shall be subject to
termination and disqualification from the Child Care Food Program (CCFP).
1. Submission of false information to the Department
• Failure to disclose ineligible officers, directors, key employees
• Listing fictitious employees/officers/board members on an application
• Claiming tax-exempt status when denied, rescinded, etc.
• Submitting the iRS tax-exempt determination letter of a different or defunct organization
• Concealing a conviction for any activity occurring during the previous seven years that
indicates a lack of business integrity
• Falsification of documentation
2. Permitting an individual on the National Disqualified List to serve in a principal
capacity with the contractor or at a site sponsored by the contractor
3. Failure to operate the CCFP in conformance with performance standards established
in 7 CFR section 226.6(b)(18), regarding financial viability and financial management,
administrative capability, and program accountability
• Failure to ensure provision of adequate financial resources for daily program operations
• Failure to maintain adequate funds to withstand temporary interruptions in program payments
and/or fiscal claims against the contractor
• Failure to maintain an adequate number and type of qualified staff to ensure proper CCFP
operations
• Failure to establish and implement internal controls and other systems to ensure fiscal
accountability
• Failure of the Board of Directors to provide adequate program oversight
4. Failure to maintain adequate records
• Failure to maintain appropriate records to document compliance with CCFP requirements
including budgets, approved budget amendments, and when applicable, management plans
and records pertaining to facility operations
• Consistently missing/incomplete records during different reviews, complaint investigations,
agreed -upon -procedures reviews, or audits '
• Missing/incomplete/incorrect invoices, receipts, canceled checks, inventories resulting in
false/inflated/unsubstantiated claimed costs
• Cost records not maintained according to generally accepted accounting principles resulting
in false/inflated/unsubstantiated claimed costs
5. Failure to adjust meal orders to conform to variations in the number of participants
• Inflated meal counts, meals claimed regularly equals the number of meals ordered/planned
or the number of participants on the center roster
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Child Care Food Program Contract
Attachment 1, Page 3
12. Claiming reimbursement for meals served by a proprietary child care center during a
calendar month in which the center does not meet Title XX eligibility requirements, or
Free and Reduced eligibility requirements, as applicable
13. Failure by a sponsoring organization to properly classify individuals or homes in the
correct reimbursement category
14. Failure of a sponsoring organization to properly exercise its oversight responsibilities
• Failure to adequately monitor
• Failure to require full, permanent, and systemic corrective actions
• Failure to impose sanctions on centers, sites, or day care home providers when serious
deficiencies are identified
• Failure to follow suspension, termination, disqualification and appeal procedures
15. The fact that the contractor or any of its principals have been declared ineligible to
participate in a publicly funded program due to violating that program's requirements
16. Conviction of the contractor or any of its principals for any activity that occurred
during the past seven years and that indicates a lack of business integrity
17. The following acts or omissions are also serious deficiencies
• Failure to make records associated with the CCFP available upon request at a reasonable
time and place
• Failure to maintain current licensure requirements
• Misuse of CCFP funds
• Serious mismanagement (e.g. failure to monitor properly)
• Failure to obtain a required audit
• Failure to notify the Department of change in IRS status
• Violations of IRS regulations
• Failure to remit periodic payments (required by statute or regulation) to regulatory agencies
(e.g. employee withholding for income taxes, social security, unemployment compensation)
• Failure to implement corrective action(s)within required timeframes
• Failure to follow-up/require and maintain corrective action for facility review findings
• Creating fictitious records
• Failure to make required repayment of program funds to the Department
• Failure to comply with state incorporation requirements
• Paying employees salaries based on the number of homes/centers recruited; paying
recruitment bounties or bonuses
• Failure to attend training required by the Department
• Failure to make payment(s) to subcontractor(s) for program services rendered
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