This op-ed was authored by Vander Weele Group Outreach Manager Jillian Helding.
The COVID-19 pandemic brought with it a host of changes in the grants world – new streams of funding, new regulations concerning its use, and some major revisions of the Uniform Guidance.
Tucked away in the section on Sub-recipient Monitoring are two changes that we’ve discussed at length at the Vander Weele Group: the removal of mandates to provide Technical Assistance and to conduct on-site monitoring reviews.
If you’ve kept up with the news in the last year, you’ve likely seen the steadily increasing number of cases of COVID relief fraud coming to light, often to the tune of millions of dollars. Some of these thefts were made possible by extreme staffing shortages and the sudden influx of funding to organizations and agencies that, in some cases, was more than their annual budget. Some, however, slipped through the cracks, due possibly in part to the relaxed monitoring standards that became the norm starting in 2020.
While it’s completely understandable that monitoring visits were cancelled due to site closures and the risks of close contact, it had consequences. One story that comes to mind is the massive scheme involving the theft of $250 million from the Federal Child Nutrition Program in Minnesota. During the pandemic, the USDA waived some of the standard requirements for participation in the Federal Child Nutrition Program, including allowing off-site food distribution to children outside of educational programs. Coupled with the cessation of on-site monitoring visits, this created a perfect storm that allegedly allowed Feeding Our Future, a non-profit and sponsor of the program, to obtain, misappropriate, and launder millions of dollars intended to provide meals to hungry children.
“As part of the charged scheme, Feeding Our Future employees recruited individuals and entities to open Federal Child Nutrition Program sites throughout the state of Minnesota. These sites, created and operated by the defendants and others, fraudulently claimed to be serving meals to thousands of children a day within just days or weeks of being formed. The defendants created dozens of shell companies to enroll in the program as Federal Child Nutrition Program sites. The defendants also created shell companies to receive and launder the proceeds of their fraudulent scheme.
To carry out the scheme, the defendants also created and submitted false documentation. They submitted fraudulent meal count sheets purporting to document the number of children and meals served at each site. The defendants submitted false invoices purporting to document the purchase of food to be served to children at the sites. The defendants also submitted fake attendance rosters purporting to list the names and ages of the children receiving meals at the sites each day. These rosters were fabricated and created using fake names. For example, one roster was created using names from a website called “www.listofrandomnames.com.” Because the program only reimbursed for meals served to children, other defendants used an Excel formula to insert a random age between seven and 17 into the age column of the rosters.
When MDE attempted to perform necessary oversight regarding the number of sites and amount of claims being submitted, [Executive Director Aimee] Bock and Feeding Our Future gave false assurances that they were monitoring the sites under its sponsorship and that the sites were serving the meals as claimed. When MDE employees pressed Bock for clarification, Bock accused MDE of discrimination and unfairly scrutinizing Feeding Our Future’s sites. When MDE denied Feeding Our Future site applications, Bock and Feeding Our Future filed a lawsuit accusing MDE of denying the site applications due to discrimination in violation of the Minnesota Human Rights Act.”
Setting aside, for the moment, the fact that the scheme was certainly enabled by allowing the organization administering the program to conduct its own monitoring activities (a topic we covered last November in Segregating Grants Monitoring from Management Protects Program Integrity), it’s clear that a number of the claims Feeding Our Future made could have been easily debunked by sending monitors out to their alleged sites. It begs the question: how much of the fraud we’ve seen in the last three years might have been prevented this way? How many millions of taxpayer dollars might have been saved by simply having eyes on-site?
This isn’t to say that remote monitoring doesn’t have an important role to play in grants oversight. Quite the opposite, in fact. Program monitors at the Vander Weele Group developed expert processes and tools for completing desk reviews during the pandemic, which allowed us to continue monitoring activities that might otherwise have been suspended. In some ways, it streamlined and sped up the monitoring process. It allowed us to offer our services to organizations we can’t easily visit or whose risk profile didn’t necessitate in-person reviews.
Perhaps most surprisingly, the switch to remote monitoring offered us valuable new insights into how data collection practices can impact the accuracy and quality of monitoring. During the pandemic, our Prevention Initiative monitoring team--who monitor home visiting services in Illinois--conducted compliance monitoring 100% remotely by requesting all documents be uploaded to a secure server. This led to improved practices and more efficient monitoring, both during the pandemic and today. The assessment of home visitors with the Home Visit Rating Scale (HOVRS-3) is typically conducted using virtual observations. Home visitors record their interactions during visits with families and upload them to the same secure server used for documentation review. This approach, which is far less intrusive than having a monitor in the room, allows us to gain a more realistic view of how providers and families naturally interact in the home environment. It also allows for more thorough, thoughtful monitoring reviews since footage can be reviewed multiple times if necessary.
Vander Weele Group President and CEO Maribeth Vander Weele says, “I don’t think every situation requires on-site visits. In our work on the East Coast, for example, they are predicated upon anomalies being found in desk reviews. When conducted properly, desk reviews can be very effective. That said, it’s important to have different tools in your toolbox to meet different needs. There are absolutely times I’ve wanted to go out and visit a school I had concerns about. I also believe that on-site interviews allow for two-way conversations that provide critical insight into how a program is working. If I could wave a magic wand, desk reviews would be part of an escalated series of reviews that would grow in intensity as problems are found.”