Administrative Review Summary and Corrective Actions SFA ...Joannie Miller Shone Fry, Director of Food Services 12/7/2016 East Alton-Wood River Community High School District 14 The

Administrative Review Summary and Corrective Actions

SFA Name: East Alton-Wood River Community High School District 14

Administrative Review Conducted on: 12/7/2016

SFA Contact Name and Title: Shone Fry, Director of Food Services

CNR Reviewer: Joannie Miller

The purpose of this spreadsheet is to inform you of the results of the Administrative Review that was conducted on December 7, 2016; an exit conference summarizing the findings took place on December 7, 2016.

The Administrative Review is a comprehensive evaluation of the Local Education Agency’s (LEA’s) National School Lunch Program (NSLP) and School Breakfast Program (SBP). The AR consists of two performance standards. While findings were identified, the two performance standards reviewed were found to be

satisfactory. During the Administrative Review, compliance with the new meal pattern requirements is also evaluated, at this time there are no menu findings that warrant the termination of the performance based

reimbursement.

This summary includes a comprehensive list of the technical assistance that was provided throughout the

review as well as all findings that require a written response from the SFA. All items listed in the Corrective

Action Plan must be submitted in writing to CN Resource, by Friday, March 3, 2017. Please complete the chart, an electronic version or a hand written response will be acceptable. If any additional responses are needed, please respond on district letterhead. Failure to submit the required materials by the due date may

result in the withholding of claims. Should corrective actions not be submitted, a follow-up review may take place to ensure all required corrective actions were completed and implemented system-wide as appropriate.

Any potential fiscal action will be calculated once the corrective action responses have been received and

approved.

I appreciate the courtesies extended by you and your personnel during the review. If you have questions or need assistance concerning the school food service program, please call our office. Please respond to the AR Corrective Action Document by March 3, 2017.

Thank you,

Administrative Review Summary and Corrective Actions

SFA Name:

Administrative Review Conducted on:

SFA Contact Name and title:

CNR Reviewer:

The Director of Technology was very helpful in all aspects of the review and should be commended for his

dedication to the program and the FS staff.

Menu Review- Additional technical assistance was provided in an email to the SFA with the menu review

results. Suggestions were provided to bring the menus into compliance.

Menu Review- Please ensure that all processed menu items have an accompanying CN Statement or Product Formulation Statement to clearly define the contributions of grains and meat/meat alternates towards the menu. These statements must be from the manufacturer and not just included in school notes or a school recipe. For example, upon request for documentation for items such as French Toast or Little Caesar’s Pizza,

a recipe was provided, but no official documentation from the manufacturer. Upon second request, this information was provided

At the beginning of the Verification process, when the confirmation reviews are on going, any errors that may be discovered from the initial determination should be corrected immediately, according to regulations in the Eligibility Manual, and verified accordingly with the appropriate notification to the parents.

Joannie Miller

Shone Fry, Director of Food Services

12/7/2016

East Alton-Wood River Community High School District 14

The FSD demonstrated a strong effort to follow and to be informed of all USDA and IL rules and regulations.

Her dedication to the program should be commended as this is an awesome responsibility.

Other areas of Technical Assistance (NOT requiring Corrective Action)

Commendations & Suggestions

Suggestions and recommendations were accepted with plans for implementation.

All employees were very professional and the cafeteria line staff had great interaction with the students.

The food service director (FSD) and staff were very cooperative and friendly. She initiated some of the corrections on the same day of the review.

The kitchen and cafeteria were clean and organized. Posters were displayed throughout the cafeteria for student education and conducive to students eating well.

The FSD documented all of her Smart Snacks utilizing the Smart Snack calculator.

With the high percentage of Free and Reduced in the SFA, reviewing the Community Eligibility Provision (CEP) might be a good option. This would potentially allow more students to take advantage of your school meals and reduce administrative labor as it relates to the Free and Reduced process.

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SFA Name:

Administrative Review Conducted on:

Sites Selected for Review:

Due Date for Corrective Action Plan:

East Alton-Wood River Community High School District 14

220.8(c) Meal pattern for school breakfasts. A school must offer the food components and quantities required in the breakfast meal pattern established. K-12: 1 oz. equivalent of grains daily.

Please provide a detailed response to each finding in the spaces provided.

12/7/2016

East Alton-Wood River Cons. High School District 14

Wednesday, February 1, 2017

Friday, March 3, 2017

Technical Assistance Provided

The Code of Federal Regulations citation number or alternate resource citation

A summary of the regulation / requirement

Suggested guidance for the SFA in order to achieve compliance

The following pages address the findings that were identified during your Administrative Review. For

each finding you will be presented with the following:

SFA area for reply to state how, when and

by whom corrections will be made

The finding, and details specific to the SFA regarding the finding

Date Corrective Action Plan was provided to SFA:

Finding #1 Meal Components and Quantities, Week of Review

For the week of menu review, the 9-12 breakfast menu did not meet the minimum daily requirement of 1 ounce equivalent grain. A grain was provided, however not all grains were whole grain-rich and creditable towards the meal pattern.

Regulation / Citation and Summary

During the review, the portion sizes required by the meal patterns were discussed with the SFA. The

SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. The SFA should review all menus to

ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/

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SFA must ensure that all meals counted for reimbursement meet the weekly requirements as well as

the daily requirements for grains required for the specific grade group. The SFA should review all menus to ensure that at least the minimum daily and weekly requirement is planned for the specific

grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include how to determine the total number of weekly servings if there are multiple menu items each day. The USDA FNS website can be used for training

materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/

220.8(c) Meal pattern for school breakfasts. A school must offer the food components and quantities required in the breakfast meal pattern established. 9-12: minimum 9 oz. equivalents of grain weekly.


For the week of menu review, the 9-12 breakfast menu did not meet the minimum weekly requirement

of 9 ounce equivalent grain.

SFA Suggested Guidance for Compliance




To come into compliance with meal pattern requirements, the SFA must provide a written plan that

will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional

menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

SFA Response

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SFA Response

For the menu review week, the 9-12 breakfast menu did not meet the 100% Whole Grain Rich requirement. Not all grains provided were Whole Grain Rich.

220.8(c)(2)(iv) Grains component. (A) Enriched and whole grains. All grains must be made with enriched and whole grain meal or flour, in accordance with the most recent FNS guidance on grains.

Whole grain-rich products must contain at least 50 percent whole grains and the remaining grains in the product must be enriched. Effective July 1, 2013 (SY 2013-2014), schools may substitute meats/meat alternates for grains, after the daily grains requirement is met, to meet the weekly grains

requirement. One ounce equivalent of meat/meat alternate is equivalent to one ounce equivalent of grains.




During the review requirements for the meal pattern were reviewed with the SFA. All grains provided as part of the reimbursable meal must be Whole Grain Rich. To be considered Whole Grain Rich the

item it must be comprised of at least 50% whole grain ingredients. An easy way to determine if a pre-purchased item is whole grain is to look at the ingredient list. If the first ingredient is whole grain, it is

a Whole Grain Rich product. If the first ingredient is water, but the second is a whole grain it is also a Whole Grain Rich product. If the SFA is using a recipe as long as the whole grain ingredient is the

largest by weight of all of the grain ingredients combined it is a Whole Grain Rich product. For additional information on whole grains visit the USDA FNS website. http://healthymeals.nal.usda.gov/menu-planning/whole-grains


To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus

will be reviewed to ensure that all weekly requirements for grains and meat/meat alternates are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will

be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

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220.8(c) Meal pattern for school breakfasts. A school must offer the food components and quantities

required in the breakfast meal pattern established. K-12: No more than 50% of the fruit or juice offering may be in the form of juice.

For the week of menu review, the 9-12 breakfast menu did not meet the requirement of no more than 50% of the fruit or vegetable offerings may be in the form of juice.


To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance with the Whole Grain Rich requirements. The plan

should include; a statement that only Whole Grain Rich grain products will be used as part of the reimbursable meal, a statement that all labels/recipes/manufacturer statements will be kept on file to document the Whole Grain Rich compliance, and a statement that additional menu training will be provided to SFA staff. Provide the outline for the training and the dates that the training(s) will be completed. In the plan include the name(s) and title(s) of the SFA representative(s) that will oversee

this area and ensure future compliance. In addition to the plan please submit a revised menu from the week of review that clearly identifies the products that have been changed to bring the menu into compliance, submit any needed supporting documentation such as labels, recipes, and/or manufacturer statements.

SFA Response

During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement may contain no more than 50% of the fruit or vegetable offerings in the form of juice. The SFA should also provide additional training to the

kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a

certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/



To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount

for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will

be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any

needed documentation to support the changes such as labels, recipes, production records, etc.

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SFA Response


For the week of menu review, the 9-12 lunch menu did not meet the minimum daily requirement of 2 ounce equivalent meat/meat alternate. A meat/meat alternate was provided, however the minimum

required portion size was not met.


During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. The SFA should review all menus to

ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The

training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance

on the meal pattern. http://healthymeals.nal.usda.gov/


210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: 9-12: 2 oz. equivalent meat/meat alternate.



will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually

reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will

oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

SFA Response


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For the week of menu review, the 9-12 lunch menu did not meet the minimum daily requirement of 2

ounce equivalent grain. A grain was provided, however the minimum required portion size was not met and not all grains offered were whole grain-rich and creditable towards the meal pattern.


For the week of menu review, the 9-12 lunch menu did not meet the minimum weekly requirement of 10 ounce equivalent meat/meat alternate.


During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement meet the weekly requirements as well as the daily requirements for meat/meat alternates required for the specific grade group. The SFA should review all menus to ensure that at least the minimum daily and weekly requirement is planned for the

specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include how to determine the total number of weekly servings if there are multiple menu items each day. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/

210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: 9-12: minimum of 10 oz. equivalent of meat/meat alternate per week.



will be reviewed to ensure that all weekly requirements for meat/meat alternates are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu

items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be

completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the

corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.


SFA Response


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210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: 9-12: 2 oz. equivalent daily grain.

SFA Response


For the week of menu review, the 9-12 lunch menu did not meet the minimum weekly requirement of 10 ounce equivalent grain.



To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount

for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually

reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will

oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any

needed documentation to support the changes such as labels, recipes, production records, etc.

During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the

minimum portion size required for the specific grade group. The SFA should review all menus to ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance

on the meal pattern. http://healthymeals.nal.usda.gov/

During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement meet the weekly requirements as well as

the daily requirements for grains required for the specific grade group. The SFA should review all menus to ensure that at least the minimum daily and weekly requirement is planned for the specific

grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include how to determine the total number of weekly servings if there are multiple menu items each day. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/


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For the week of menu review, the 9-12 lunch menu did not meet the 100% Whole Grain Rich requirement for grains. Not all grains provided were Whole Grain Rich.


During the review requirements for the meal pattern were reviewed with the SFA. All grains provided

as part of the reimbursable meal must be Whole Grain Rich. To be considered Whole Grain Rich the item it must be comprised of at least 50% whole grain ingredients. An easy way to determine if a pre-

purchased item is whole grain is to look at the ingredient list. If the first ingredient is whole grain, it is a Whole Grain Rich product. If the first ingredient is water, but the second is a whole grain it is also a Whole Grain Rich product. If the SFA is using a recipe as long as the whole grain ingredient is the

largest by weight of all of the grain ingredients combined it is a Whole Grain Rich product. For additional information on whole grains visit the USDA FNS website. http://healthymeals.nal.usda.gov/menu-planning/whole-grains


220.8(c)(2)(iv) Grains component. (A) Enriched and whole grains. All grains must be made with

enriched and whole grain meal or flour, in accordance with the most recent FNS guidance on grains. Whole grain-rich products must contain at least 50 percent whole grains and the remaining grains in the product must be enriched. Effective July 1, 2013 (SY 2013-2014), schools may substitute

meats/meat alternates for grains, after the daily grains requirement is met, to meet the weekly grains requirement. One ounce equivalent of meat/meat alternate is equivalent to one ounce equivalent of grains.

To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all weekly requirements for grains are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is

insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were

made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: 9-12: minimum of 10 oz. equivalent of grains per week.



SFA Response

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210.10(c)(iii) Vegetables component. Vegetable offerings at lunch over the course of the week must include the vegetable subgroups, as defined in this section in the quantities specified in the meal

pattern in paragraph (c) of this section: K-12: 1/2 C bean/peas/legumes.


To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance with the Whole Grain Rich requirements. The plan

should include; a statement that only Whole Grain Rich grain products will be used as part of the reimbursable meal, a statement that all labels/recipes/manufacturer statements will be kept on file to document the Whole Grain Rich compliance, and a statement that additional menu training will be provided to SFA staff. Provide the outline for the training and the dates that the training(s) will be completed. In the plan include the name(s) and title(s) of the SFA representative(s) that will oversee

this area and ensure future compliance. In addition to the plan please submit a revised menu from the week of review that clearly identifies the products that have been changed to bring the menu into compliance, submit any needed supporting documentation such as labels, recipes, and/or manufacturer statements.




SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. This includes meeting the weekly

requirements for the vegetables sub-groups. Over the course of the standard school week the SFA must at a minimum meet the required servings for each sub-group. The SFA should review all menus

to ensure that at least the minimum serving for each sub-group is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not

available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/


For the week of menu review, the 9-12 lunch menu did not meet the minimum weekly requirement of

1/2 cup beans/legumes vegetable subgroup.

SFA Response

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For the week of menu review, the 9-12 lunch menu did not meet the minimum weekly requirement of

1/2 cup starchy vegetable subgroup.

SFA Response

During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the

minimum portion size required for the specific grade group. This includes meeting the weekly

requirements for the vegetables sub-groups. Over the course of the standard school week the SFA must at a minimum meet the required servings for each sub-group. The SFA should review all menus to ensure that at least the minimum serving for each sub-group is planned for the specific grade group.

The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not

available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/



210.10(c)(iii) Vegetables component. Vegetable offerings at lunch over the course of the week must include the vegetable subgroups, as defined in this section in the quantities specified in the meal

pattern in paragraph (c) of this section: K-12: 1/2 C starchy.


will be reviewed to ensure that all weekly requirements for grains are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition

please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

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To bring this area into compliance the SFA must submit a written assurance that includes; a statement that labels (nutrient labels, ingredients labels, CN labels and manufacturer statements) will be maintained for all menu items, a process for maintaining labels, and a statement that additional training will be provided to the SFA staff, include the training outline and the dates that the trainings

will be held. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance.


will be reviewed to ensure that all weekly requirements for grains are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition

please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide any needed documentation to support the changes such as labels, recipes, production records, etc.

SFA Response

Finding #12 Meal Components and Quantities

The SFA is not maintaining Child Nutrition labels or Product Formulation Statements for processed

menu items.


During the menu review, CN labels and Product Formulation Statements were discussed with the SFA. The SFA must ensure that this documentation is being maintained in order to document an item's

compliance with the meal pattern. The SFA should have a folder or a binder to keep labels for all menu

items, that way they are easy to find and can be referenced when determining menu compliance.


210.7(d)(2)School food authorities certified to earn performance-based cash assistance must maintain documentation of compliance, including production and menu records, and other records, as specified

by FNS. School food authorities must make appropriate records available to State agencies upon request.

SFA Response

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During the review, making determinations based on the stated frequency was discussed with the SFA.

When determining eligibility, the SFA may not annualize income unless income sources are listed at

different frequencies. If there are multiple income sources with more than one frequency, the LEA must annualize, that is, calculate all income as for an entire year, by multiplying: Weekly income by 52; or Bi-weekly income (received every two weeks) by 26; or Semi-monthly income (received twice a month) by 24; or Monthly income by 12.



Finding #14

245.6(c)(4) Calculating income. The local educational agency must use the income information

provided by the household on the application to calculate the household's total current income. Eligibility Manual, Chapter 3: If there is only one source of income, or if all sources are received in the same frequency, the LEA totals all sources and compares the total to the IEGs.


To come into compliance with the requirements for determining applications, the SFA must provide an assurance that staff administering the free and reduced lunch program understand these

requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. Applications found to be incorrectly determined during the review must be

corrected, and the corrected application and date of the correction must be submitted. If the SFA is unable to correct the error because of missing/incomplete information from the household, after allowing the household an adequate amount of time to respond, the SFA must send a letter of adverse

action and advise the date that this letter was sent.

245.6(c)(4) Calculating income. The local educational agency must use the income information

provided by the household on the application to calculate the household's total current income. When a household submits an application containing complete documentation, as defined in §245.2, and the

household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in §245.2, the children in that household must be approved for free or reduced price benefits, as applicable.

During the review, determining applications was discussed with the SFA. When determining eligibility, the SFA must ensure that the household has listed the amounts, source, and frequency of current income for each household member; otherwise, the application is incomplete. For more information, see the Eligibility Manual for School Meals, Chapter 3. When determining the total household income the SFA must use all income provided on the application.


Finding #13 Certification and Benefit Issuance

Not all selected applications were approved correctly. The SFA did not calculate the income and

household size correctly.

SFA Response

The SFA annualized income when it should have been determined at its stated frequency.


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Finding #16 Verification

245.6(c)(4) Calculating income. The local educational agency must use the income information provided by the household on the application to calculate the household's total current income.

Eligibility Manual, Chapter 3: If there is only one source of income, or if all sources are received in the

same frequency, the LEA totals all sources and compares the total to the IEGs.

Finding #15


To come into compliance with the requirements for determining applications, the SFA must provide written assurance that the SFA will determine applications based on the frequency of pay provided on the application when only one frequency is listed and that the SFA will use the correct conversions factors when multiple pay frequencies are provided to determine the annual income.

SFA Response

The SFA did not update the benefit issuance document accurately and in a timely manner for students

who had updated information.



SFA Response

During the review, updating the benefit issuance document timely was discussed with the SFA. The SFA must update the benefit issuance document accurately and in a timely manner for students who are new, transferred, or withdrawn, or who have updated information. Increases in benefits must

occur within 3 operating days. Decreases in benefits must occur within 10 calendar days.

Eligibility Manual, Chapter 3: The LEA must provide benefits promptly. Eligible children may receive

benefits immediately and the LEA may assume consent, if refusal has not been received within a

certain number of days, as determined by the LEA. When a child transfers to another school within the LEA, the date of the transfer must be noted on the application and the point of service must be

updated.


To come into compliance with the requirements for updating the benefit issuance document, the SFA

must provide a written statement that the SFA understands the requirements and that moving forward all changes in eligibility will be reflected on the benefit issuance document. The statement should also include the process that will be implemented to ensure that the benefit issuance document is kept up

to date and accurate. The name and title of the SFA representative that will oversee compliance should also be provided. Eligibility statuses found to be incorrectly listed during the review must be corrected, and the date of the correction must be submitted.

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SFA Response


The households were not notified within 10 operating days of the approval of their application.

245.6( c)(6(i) Notice of approval -Income applications. The local educational agency must notify the

household of the children's eligibility and provide the eligible children the benefits to which they are entitled within 10 operating days of receiving the application from the household.


To come into compliance with the requirement for approving and notifying the households within 10 days, the SFA must submit an assurance that this will be completed and a plan to ensure future compliance. Submit the assurance and the plan.

245.6a(f)(7) Eligibility changes. Based on the verification activities, the local educational agency shall make appropriate modifications to the eligibility determinations made initially. 245.6a(j) Adverse action. If verification activities fail to confirm eligibility for free or reduced price benefits or should the household fail to cooperate with verification efforts, the school or local educational agency shall reduce or terminate benefits, as applicable, as follows: Ten days advance notification shall be provided

to households that are to receive a reduction or termination of benefits, prior to the actual reduction or termination. The first day of the 10 day advance notice period shall be the day the notice is sent.


To come into compliance with the requirements for updating eligibility that has changed due to verification, the SFA must provide an assurance that staff conducting verification understand these

requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. Also, please provide evidence that the appropriate student status(es) has/have

now been updated, as well as the date that they were changed.

SFA Response

During the review, updating eligibility that changed due to verification was discussed with the SFA. The SFA must decrease benefits changing because of verification no later than 10 operating days from

the final decision and the date the letter of adverse action is sent.


During the review, notifying the households within 10 days of approving their application was discussed with the SFA.


The SFA did not decrease benefits within the 10 operating days from the final decision and date letter of adverse action is sent to the household, during the Verification process.

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Joannie Miller Date: 12/7/2016

Date:

If you have any questions, feel free to contact CN Resource at your convenience. Thank you.

CN Resource

To come into compliance with the requirements for updating benefit issuance documents, the SFA

must provide an assurance that staff administering the free and reduced lunch program understand these requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. Eligibility statuses found to be incorrectly listed during the review must be

corrected, and the date of the correction must be submitted.

SFA Response


The SFA did not update benefit issuance documents accurately upon receipt of Direct Certification updates.


During the review, updating benefit issuance documents was discussed with the SFA. The SFA must update benefit issuance documents accurately upon receipt of Direct Certification updates, as soon as

possible but no later than three operating days after the date the local educational agency receives the direct certification documentation.


245.6(b)(6)(ii )Once the appropriate official has provided the direct certification documentation to the

local educational agency, the child must have free benefits made available as soon as possible but no later than three operating days after the date the local educational agency receives the direct

certification documentation.


P.O. Box 31060

Mesa, AZ 85275

866-941-6368

[email protected]

Administrative Review Team

Signature of Reviewer:

Signature of SFA Representative:

mailto:[email protected]






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Please insert your detailed responses, save, print, sign, scan and upload the signed copy to cnrsupport.com by the due date indicated. Thank you.

Documents

Administrative Review Summary and Corrective Actions SFA ...Joannie Miller Shone Fry, Director of Food Services 12/7/2016 East Alton-Wood River Community High School District 14 The