All Recovery Act programs will be assessed for risk and to ensure that appropriate internal controls are in place throughout the entire funding cycle. These assessments will be done consistent with the statutory requirements of the Federal Managers' Financial Integrity Act and the Improper Payments Information Act, as well as OMB’s Circular A-123 “Management’s Responsibility for Internal Control.”
Congregate Nutrition Services is a long-established program with a proven track record of delivering results. Internal control assessments conducted under the Federal Managers' Financial Integrity Act have consistently found AoA mandatory grants programs (including Congregate Nutrition Services) to be low risk and to have a sound internal control structure. Financial statement and other programmatic audits have not identified any significant deficiencies in OAA nutrition programs and there are no uncorrected weaknesses or deficiencies associated with these activities. Primary recipients are State governments that have their own established control structures and State audits of these programs under Circular A-133 have not generated significant systemic findings.
Congregate Nutrition Services also has an established system for collecting and validating financial data and program data on both outputs, such as numbers of meals and individuals served, as well as client outcomes, such as ability to remain independent and in the community. AoA data collection systems and controls have been assessed by external entities, including the Office of Management and Budget, which found that the program had both credible and effective performance data and strong financial management systems in place.
In addition to routine performance measurement activities, AoA conducts in-depth program evaluations on a 10-year basis. The Recovery Act has coincided with the evaluation cycle for Congregate Nutrition Services. An evaluation design contract has been completed and a contract to conduct the evaluation is under development. AoA’s comprehensive evaluation framework assesses all levels of the Aging Network (State and Local) as well as program participant outcomes and impacts. The current design for this evaluation includes three interconnected studies: cost, process and client outcome. The cost study will examine the use of multiple funding streams for congregate meals and will be amended to include the Recovery Act. AoA’s data collection systems, including evaluation, provide a robust assessment of program efficiency and effectiveness. The results of the evaluation will be posted on the AoA website in FY 2012.
To ensure that recipients understand and can meet the objectives, outcomes and accountability expectations associated with the provision of Recovery Act funds to OAA nutrition programs, AoA will provide additional technical assistance to States, along with enhanced monitoring and reporting as required under the Act. On March 18, 2009, AoA posted to its website Frequently-Asked Questions about the implementation of the Recovery Act, and the agency participated in conference calls with State officials on March 30, 2009 and April 23, 2009 to answer questions. AoA will also utilize existing technical assistance mechanisms, such as State Planning Grant Projects, the Area Agency Capacity Assessment Grant Project, and the State Unit Regional Program Analysis Forum Project. These projects provide ongoing support of communication and technical assistance needs of AoA and its OAA grantees, and will enhance assurances of full program compliance for Recovery Act funding. AoA will not use Recovery Act funds to provide technical assistance under these existing mechanisms.