2015 1

Scope of the Administrative ReviewA Look at the National School Lunch Program’s

Administrative Review Process

2015 2

Let’s Meet the Review Team!

2015 3

A New Look for the Review:Off-Site and On-Site

Off-Site Assessment Tool• Determine whether or

not SFA meets program requirements.

• Provide technical assistance.

On-Site Assessment Tool• Determine whether or not

SFA meets program requirements.

• Provide technical assistance.

• Assess fiscal action, if applicable to recover improperly paid funds.

2015 4

Online Web-Based AR Compliance System: CNIPS• All AR question sets,

documentation, findings, technical assistance and corrective action are housed within the system.

2015 5

Online Web-Based Compliance System Support

• A user manual is provided for SFAs.

• The manual can be found on the SCN Administrative Review webpage.

• The intention of this manual is to provide step by step instructions on how to use the compliance section of CNIPS.

2015 6

Review Frequency and Schedule

• Review Frequency• SFA must be reviewed every 3 years• Cycle began on July 1, 2013

• Review Period• Most recent month claim submitted

• Must include > 10 operating days• Week of Review

• Menu review during Review Period (5 days)• Must have at least 3 consecutive days, RCCI’s have 7)

• Day of Review• On-site review

2015 7

Minimum Number of Review Sites in each SFA

2015 8

Follow-Up Visits When Necessary

• Follow-Up visits will occur to determine corrective action compliance.

• Timeline• After documented corrective action occurs.• Early in the following school year.

• Scope• Only addresses areas of the review in which serious

violations were noted on the previous review.

2015 9

Pre-Visit Procedures• The Administrative Review

Information Packet will be sent to you.

• This packet includes a checklist of necessary items for the Offsite and Onsite portion of the review.

• Be sure to prepare and gather all necessary materials to have them ready for the Review Team.

2015 10

Pertinent Dates and Information• Your packet will

include important dates and information regarding the review.

2015 11

Pre-Visit Procedures: Available Guidance

• Consultant will provide SFA with AR training materials and guidance.

• SCN developed a website for SFAs off-site and on-site portions.

• Consultants will be in constant communication during this portion of the review for explanations and to provide technical assistance if necessary.

http://education.ky.gov/federal/SCN/Pages/Glossary-of-Terms-and-Resource-

Materials.aspx

2015 12

Areas of ReviewCRITICAL AREAS OF REVIEW GENERAL AREAS OF REVIEW

Meal Access & Reimburseme

nt

Meal Pattern & Nutritional

Quality

Resource Management

General Program

Compliance

Other State/Federal

Program Reviews

Certification & Benefit Issuance

Meal Components & Quantities

Risk Assessment Civil Rights Afterschool Care Snack Program

Verification Offer vs. Serve Nonprofit School Food Service Account

Food Safety Fresh Fruit and Vegetable Program

Meal Counting & Claiming

Dietary Specs & Nutrient Analysis

Paid Lunch Equity Local Wellness Policy

Seamless Summer Option

Revenue from Non-Program Foods

Competitive Foods Special Milk Program

Indirect Costs WaterLevel One CertificationOn-Site Monitoring

Performance

Standard 1Performance

Standard 2

2015 13

Let’s Take a Look at the Main Areas of Review

2015 14

1. Meal Access & Reimbursement

Certification & Benefit IssuanceVerification

Meal Counting & Claiming

2015 15

Performance Standard 1• This occurs when there is an error associated with the

following:

All free, reduced-price, and paid meals claimed for reimbursement are served only to children

eligible for free, reduced-price, and paid meals, respectively; and are counted, recorded,

consolidated and reported through a system which consistently yields correct claims.

2015 16

Meal Access & Reimbursement:Certification & Benefit Issuance

• SFA answer Questions #100-#122

• SFA sends benefit issuance information to SCN

• SCN reviews a statistical sample of eligible students

• SFA sends additional information if necessary

• Section shortened for CEP districts

Off-Site

• Review of denied applications• Review of eligibility

notification lettersOn-Site

2015 17

Meal Access & Reimbursement:Certification & Benefit IssuanceCommon Findings- Incomplete Applications- Miscategorized Applications- Issues relating to disclosure

2015 18

Meal Access & Reimbursement:Verification

N/AOff-Site

• Review a sample of verified applications & supporting documents

• Review to ensure correct changes were made in the POS if necessary

On-Site

2015 19

Meal Access & Reimbursement:VerificationCommon Findings

• Incorrect letters due to missing information.• Incorrect conversion of income (incorrectly converted to

annual).• No POS documentation if status changed.

2015 20

Meal Access & Reimbursement:Meal Counting and Claiming

• SFA Answers questions #300- 312

• Ensure claim for review month is submitted

Off-Site

• Provide daily and monthly meal counts for the review month

• Provide edit checks for the review month

On-Site

2015 21

Meal Access & Reimbursement:Meal Counting and ClaimingCommon Findings

• Missing or inaccurate edit checks

2015 22

Community Eligibility Provision Districts (Full and Partial)

Full Districts• This section of the review

will be abbreviated for CEP districts.

• ISP (from April 1st) information will be validated.

• Randomly selected students will be checked on the DC list to validate status.

Partial Districts• This section will be

utilized to review non-CEP sites.

• An abbreviated review will occur of your CEP sites.

2015 23

Documentation: ISP

2015 24

2. Meal Pattern and Nutritional Quality

Meal Components & QuantitiesOffer vs. Serve

Dietary Specifications & Nutrient Analysis

2015 25

Performance Standard 2• SFAs must:

• Offer students the required meal components in the required quantities.

• Allow students to select required meal components on all reimbursable meal service lines.

• Record/claim only those meals that contain required components in required quantities.

Reimbursable lunches must meet the meal requirements in 210.10, as applicable tothe age/grade group reviewed. Reimbursable breakfasts must meet the meal requirements in 220.8 and 220.23, as applicable to the age/grade group reviewed.

2015 26

Meal Pattern & Nutritional Quality:Review Process

• SCN will complete the off-site Meal Compliance Risk Assessment Tool with assistance from the SFA

• Submits menus via inTeam• Menu production records• Menu component crediting,

recipes, labels, etc., when requested

Off-Site

• Breakfast/Lunch meal preparation observation

• Breakfast/Lunch meal service observation

• Validate and follow-up on the off-site review

On-Site

2015 27

If SFA has more than one site…

• If the SFA has more than one site, an assessment will be conducted to determine which school site is at the highest risk for non-compliance. That site is referred to as the TARGET SITE.

• All other sites will be considered Non-Target sites.Review menu for quantities, components as well as dietary specifications

Target Review menu

for quantities and components

Non-Targe

t

2015 28

Meal Pattern and Nutritional Quality:Off-Site Documents

• All menu documents are needed for:

• Each menu & age/grade group

• Each reviewed site• Week of Review- during

Review Period• Day of an On-Site Review• Breakfast• Lunch

• Menu documents:• Menus• Refrigerator Menus• Menu production records• Standardized Recipes• Crediting information

• Nutrition labels• Child Nutrition Labels• Manufacturer’s Statements

2015 29

Menu Compliance Team• SFAs will be contacted by

the SCN Menu Compliance team.

• The Menu Compliance team will assist the SFA with menu and documentation submission.

Meet the TeamElli PaceSandy WagnerBrenda Zahn

2015 30

To Analyze or Not To Analyze?• SCN will review submitted menus utilizing the InTeam

menu compliance software.• If Dietary Specifications Assessment Tool (DSAT)

deems site is high risk, a nutrient analysis will be conducted.

• SCN will offer Administrative Review Meal Compliance Workshops for all SFAs.

• Workshops will focus on Production Records, Crediting and Menu Planning.

2015 31

Meal Pattern & Nutritional Quality:On-Site

On-Site Documentation• Menu Production Records

• Day of Review• Each Site Reviewed• Breakfast and Lunch• Refrigerator Menus

(month of on-site review)

On-Site Meal Observation• All reimbursable meal lines offer

all required components.• Breakfast in the classroom, Grab ‘n

Go, etc.• Observe a % of meals served in

each line.• Determine if meals contain

components and quantities for specific age/grade.

• Ensure students have access to, and know how to select, a reimbursable meal.

2015 32

On Site Meal Observation• Ensure Offer vs. Serve is implemented correctly:

• Adequate food is offered on all reimbursable meal lines.• Signage is posted on the service line.• Students are selecting enough components/items to make a

reimbursable meal.• Food service staff are accurately judging quantities on self-

serve bars.• Food service staff at the POS are trained and can recognize

a reimbursable meal.

2015 33

Common Findings• Inadequate quantities of components offered.• Calculation errors when determining meal component

contributions- crediting.• Offer vs. Serve not implemented correctly.• Trans fats in food products.• Incorrect portion sizes.• Incomplete or incorrect production records.• No standardized recipes.

2015 34

3. Resource Management

Maintenance of the non-profit school food servicePaid Lunch Equity

Revenue from non-programs foodsIndirect Costs

2015 35

Resource ManagementReview Process

Answer Questions

#700-712 in CNIPS

Off-Site

Review activities

dependent on results of off-site responses

On-Site

2015 36

Off-Site Questions• Ensure the overall financial health of the SFA’s

nonprofit school food service account.• Completed off-site with assistance from reviewer if

necessary.• Questions include the following topics:

• SFA enrollment• Previous financial findings on previous reviews• Maintenance of the nonprofit food service account• Paid Lunch Equity• Non-Program foods• Indirect Costs

2015 37

Resource Management Risk Indicator Tool

• SCN will conduct a risk assessment on the SFA via the off-site responses.

• If SFA demonstrates a high risk for non-compliance with resource management, SCN will conduct a comprehensive resource management review of the SFA.

2015 38

4. General Program Compliance

Civil RightsFood Safety

Local Wellness PolicyCompetitive Foods

WaterSFA On-Site MonitoringLevel One CertificationSBP & SFSP Outreach

2015 39

Civil Rights

• SFA answers questions #800- 807

• SFA provides current non-discrimination statement

• Annual Civil Rights training documented

• Copy of the public release• SFA’s Civil Rights Complaints

procedure• SFAs accommodating special

dietary needs procedures

Off-Site

• Validate off-site questions/documents

• And Justice For All Poster compliance

• Prevention of overt identification

On-Site

2015 40

Food Safety

N/AOff-Site

- SCN conducts kitchen and food service area walkthroughs- Review of food safety plan- Two food safety Inspection reports- Temperature logs

On-Site

2015 41

Local Wellness Policy

• SFA answers #1000-1006 in CNIPS

• Review of current Local School Wellness Policy

• Review of Public Notification, updates and assessment of policy

Off-Site

Reviewer may conduct or complete off-site portions

On-Site

2015 42

Competitive Foods

Answer questions #1100-1102

Off-Site

- Observation of foods and beverages sold on school campus- List of all foods/beverages sold on campus & sample documentation*

On-Site

2015 43

* Competitive Foods Sold in a District

• All competitive foods sold in the district to students must be in compliance with Smart Snacks guidance.

• To ensure compliance, the SFA will be asked to provide documentation:

• product packaging (front and back),• assessment documentation showing compliance using the

Alliance for a Healthier Generation’s Smart Snacks Calculator.

• You will need to work with your district administration in obtaining this information.

2015 44

Water

N/AOff-Site

Meal Service Observation

On-Site

2015 45

SFA On-Site Monitoring

Answer question #900 in CNIPS

Off-Site

Review of site

monitoring forms

On-Site

2015 46

Level One Certification/Professional Standards (coming soon!)

Review Level One Training

DocumentationOff-Site

Completion of Review of Level

One training documentation if

necessary

On-Site

2015 47

SBP and SFSP Outreach

Reviewer will review outreach documentation

Off-Site

Reviewer will review outreach documentation to ensure it is

ongoing

On-Site

2015 48

Other Federal Programs• Reviewers will also monitor documentation for the

following programs if being operated by the SFA• After School Snack Program (tally sheets or other

documentation)• Seamless Summer Option• Fresh Fruit and Vegetable Program• Special Milk

2015 49

Post Review

Administrative Review Exit ConferenceAdministrative Review Report

Corrective Action Plan DocumentsFiscal Action/Claim Revisions

2015 50

Agreed Upon Corrective Action Plans

• All CAP information will be maintained within CNIPS.• SCN will identify how the SFA will resolve the finding

and ensure future compliance.• Findings must be corrected system-wide.• May need to supply additional documentation to SCN.

2015 51

Training and Support Materials

• SCN is always here to support you!

• A one-stop shop webpage exists to answer your AR questions.

• PLEASE take the time to familiarize yourself with available resources.

http://education.ky.gov/federal/SCN/Pages/Administrative-Review.aspx

2015 52

Questions?

Thank you for your time!

2015 53

The U.S Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov .Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish).

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