Coordinated Review Effort (CRE) 2013-14Distance Learning November 7, 2013Karen Franklin, SNS

CRE 2013-14•83 school district reviews planned •98 schools within those districts being

reviewed•Reviewing breakfast and lunch•Nutrient Analysis for BOTH breakfast

and lunch will be for the week of the review (not previous week)

CRE 2013-14Announcement Letter

• Mailed to superintendent and copied to the child nutrition director • Sent at least 30 days prior to the review dates• Includes list of items needed for review• Includes list of items needed for weighted nutrient

analysis• Includes instructions for information needed to be sent

to the area specialist along with the date the information is due

CRE 2013-14USDA Review Criteria

• Elementary schools (defined as grades K-8 by USDA) that have 97% of the free eligible students eating lunch each day

• Secondary schools (defined as grades 9-12 by USDA) that have 77% of the free eligible students eating lunch each day

• Combination schools (any combination of K-8 with 9-12) that have 87% of the free eligible students eating lunch each day• Many ‘high schools’ in Arkansas are 7-12 schools which

would be considered a combination school by USDA regulations

CRE 2013-14State Review Criteria

• Low participation schools• Provision 2 base year• Findings from previous reviews, on-site visits or claims

review process• Daily meal counts appear questionable• Identical or similar claiming patterns• Large changes in free meal counts• Manager or school never reviewed by state• New or unusual accountability system• Director or Superintendent request

CRE 2013-14Site Selection Process

• Fax or email claim along with all daily records or monthly reports to area specialist by date specified on CRE announcement letter• Daily records/monthly reports must show each type of

meal, by category served at each school (as listed on the Schedule A) for the month of the claim• Daily records/monthly reports must also show the free

and reduced eligibles for each school (adjusted as needed throughout the month). This is Edit Check 1 and very important part of this record keeping.

CRE 2013-14Entrance Conference

• State Agency personnel• Superintendent• Child Nutrition Director• Other personnel as determined to be needed by

the superintendent or child nutrition director (for example: determining officials, verifying officials)

CRE 2013-14Entrance Conference

• Purpose of the review• Description of the review process and scope of

review• Procedures for findings communications during

the review (including technical assistance and corrective action)• Set date and time of exit conference

CRE 2013-14Review Location – Place to Work

• Private place to work – confidential information• Close to or easy access to determining official

and all eligibility determination documents• Table space to spread out

CRE 2013-14While the CRE covers many, many aspects of the child nutrition program there are two areas that can cause fiscal action (meaning money would have to be returned )

CRE 2013-14Fiscal Action PS 1

• Certification (application approval)• Issuing benefits (rosters, class lists, checklists,

tickets)• Meal counts and claiming

Fiscal Action PS 2• Meal component errors

CRE 2013-14Performance Standard 1 (PS1)

• Certification/Counting/Claiming – All free, reduced price and paid breakfasts and lunches claimed for reimbursement are served only to children eligible for free, reduced price and paid meals, respectively; and counted, recorded, consolidated and reported through a system which consistently yields correct claims.

CRE 2013-14

Performance Standard 1 (PS1)• Every student receiving free or reduced meals

must have a source document (application, name on DC list, etc.)• Count by category at point of service must be

accurate• Consolidation of meal counts for claims must be

accurate

CRE 2013-14Performance Standard 2 (PS2)

• Components – Breakfasts and Lunches claimed for reimbursement within the school food authority contain food items/components as required by program regulations.

CRE 2013-14

Performance Standard 2 (PS2)• Every meal claimed must meet all meal pattern

requirements and have appropriate documentation• Components (meat/meat alternate, red/orange

vegetable, etc.)• Contributions (how the item served contributes to

meal pattern)• Dietary specifications (calories, saturated fat, trans fat,

etc.)

CRE 2013-14Review Period Claim for Reimbursement

• The month of the most recent claim for reimbursement that has been filed with state agency (must be at least 10 days)• We must confirm ALL ASPECTS of the claim – source

documents for everything on the claim form• Revenues• Expenses• Eligibles• Meals claimed by type and category• Unpaid bills, funds due to program, etc.• Inventory

Source Documents/RostersSource Documents

• Approved F/R meal application• Student name on direct certification list• Student name listed as “other students

in household with direct certification students” (list, on duplicate app, etc.)

Source Documents/Rosters

• Student name on other source categorically eligible lists• Homeless•Migrant• Runaway• Head Start• Even Start• Foster

Source Documents/RostersRosters

• Point of Sale Roster • APSCN/eSchool Roster• Child Nutrition Master Roster

• Any student listed as F/R must have source document• All rosters must match eligibility status for each student’s

source document• 100% of students on rosters for the schools reviewed will

have source document review

Scope of Review• Free & Reduced Price Meal Eligibility

Process• Child Nutrition Master Roster• APSCN or e-School plus Roster with meal

status• Point of Service (POS) Roster or paper

method

Scope of Review• Verification: Narrative Description &

Verification Collection Report• Civil Rights Compliance• Reporting & Record Keeping

Responsibilities• Breakfast & Lunch Program; participation

(average daily participation in programs)

Scope of Review• Use & Storage of Commodities; warehouse

inspection (if applicable)• Food Safety Plan (HACCP Plan including

Standard Operating Procedures (SOPs))• Sanitation/Copy of the two (2) most recent

health inspection forms (most recent inspection posted in publicly visible area?)

Scope of Review• Current Wellness Committee Members,

Wellness Policy, ACSIP Plan• Please review Commissioner’s Memo FIN-

14-037 Wellness Committee Responsibilities – especially the “Wellness Committee Responsibilities Documentation Form”

Scope of Review• Competitive Foods (State & Federal

Standards)• Nutrition & Physical Activity Standards

(Copy of Pouring Rights/Beverage Contracts)• REMINDER – USDA has issued rules for “All

Foods on Campus” which are effective July 1, 2014 – BE PREPARED

Scope of Review• Quality of Food• Time to Eat• Cafeteria Atmosphere/Supervision• Facilities/Equipment

Scope of Review• After School Snack Program (if applicable)• Seamless Summer Program (if applicable)• Fresh Fruit and Vegetable Program (FFVP)

(if applicable)• Pre-School Programs (if applicable)

Nutrient Analysis• Sheila is going to talk to you a little about the

weighted nutrient analysis as compared to the simplified nutrient analysis • The nutrient analysis will be performed for BOTH

breakfast and lunch• The nutrient analysis will be for the WEEK of the

on-site portion of our review• Based on completed production records – may

have to mail the end of the weeks production records to us after the review

Nutrient AnalysisDocumentation needed for nutrient analysis• Menus served, including serving size and menu

contribution• Completed production records• Recipes to support the daily menu and

production record• Nutrient fact labels and CN labels or Product

Formulation Statements to support each recipe used in production of menus

Nutrient AnalysisMenus and Production Records

• Include all menu items served on all lines open for service• Indicate the meal, day, Offer vs. Serve, varied portions,

choices and grade levels• USDA, ADE or local recipe number on production record• The meal pattern contribution for each menu item• All condiments, extras, milk, etc., other beverages• If the menus have been analyzed using one of the approved

USDA nutrient analysis programs, print the menu analysis and production record for review

Nutrient AnalysisStandardized Recipes

• Recipes are needed for each menu item served during the review week. If USDA or ADE recipes are used exactly as printed, indicate the recipe number on the production record. If any changes have been made to the recipe or if it is a local district recipe, include ingredients (type or measure), serving size or preparation techniques or indicate the changes to the original recipe. Print recipes that have been entered on a nutrient analysis program and have a copy available. • REMINDER - the Vegetable and Fruit contribution on

USDA and ADE recipes may have changed. VERIFY!!!

Nutrient AnalysisStandardized Recipes

• Recipe name• Ingredients• Exact weight/measure for each ingredient listed• Directions/instructions for production• Serving size, indicate portion size served if varied

portions are served for grade levels.• Yield – number servings recipe makes• Variations and other notes for success• Marketing guide as needed• Pan size, as needed• Meal pattern contribution

Nutrient AnalysisProduct/Nutrient Information

• Provide printed product/nutrient information sheets for all menu items served during the review week, including USDA Donated Foods. • In addition, provide copies of current Child

Nutrition (CN) product labels for products served to students. • In order for a CN label to be used it must be

currently approved by USDA and MUST be listed on the USDA CN Label website at: http://www.fns.usda.gov/cnd/cnlabeling/labels.pdf

Nutrient AnalysisProduct/Nutrient Information

• If a combination product is purchased that does not have a CN label then a Product Formulation Statement from the manufacturer is required to document meal pattern contribution. • Product/nutrient information is needed on all

prepared entrees, salad dressings, seasoning mixes, prepared desserts, soup and gravy bases, etc.

Nutrient AnalysisProduct/nutrient analysis information should

include the following:• Product name• Manufacturer name• Meal component contribution• CN Label (if applicable)• Product Formulation Statement (if applicable)• Serving size• Calories per serving• Grams of Saturated Fat per serving• Grams of Trans Fat per serving• Milligrams of Sodium per serving

Nutrient Analysis• The information for the Nutrient Analysis will be

taken back to our office and the area specialist will use nutrient analysis software to analyze the menus served • If the area specialist does not have all the

information needed they will be contacting you for the information needed. Please respond quickly!!• Nutrient Analysis findings letter will be sent to

superintendent and child nutrition director

Review Activities• During the review any non-compliance issues will be

addressed with technical assistance at the time of the review

• If non-compliance issues cannot be corrected at the time of the review further technical assistance visits may be necessary

• ALL items addressed through technical assistance during the review process MUST be addressed in the exit conference with the superintendent and MUST be addressed in the CRE results letter • We are no longer allowed to just get it fixed and go on – we

are required by USDA to document everything in the review findings letter – SORRY!!!

Post Review

• Exit conference• Benefit issuance findings• Review results letter• Weighted nutrient analysis• Nutrient analysis findings letter• Corrective action requirements• Corrective action plan from district

Exit Conference• Exit conference at the end of the review is required by

USDA• Should include state agency personnel, superintendent,

child nutrition director, other personnel as needed (for example if there are benefit issuance problems the determining official may be required to attend the exit conference)

• Will provide a preliminary assessment of the violations observed, the extent of the violations and a preliminary assessment of action needed to correct the violations. Discuss and define appropriate deadlines for completion of the Corrective Action (CA), provided the deadline(s) result in the completion of CA on a timely basis.

Exit Conference• We will discuss which school(s) had findings

and/or violations, and cite the causes and magnitude of deficiencies. • We will address the numbers and types of errors

that were discovered, • We will provide a copy of the completed

CERTIFICATION AND BENEFIT ISSUANCE ERROR WORKSHEET(s), for use in identifying the eligibility certification, benefit issuance errors, and updating eligibility errors.

Post Review• After every review, the State agency must

provide written notification of the review findings to the SFAs Superintendent (or equivalent in a non-public SFA) or authorized representative – within 30 days of review. • The written notification must include the review

findings, the required CAs, the deadlines for completion of the CA, and the potential Fiscal Action.

Post Review• If review findings initiate or terminate the SFA’s

receipt of the performance-based reimbursement (six cents), the State agency must notify the SFA at the exit conference. • If findings result in the performance-based

reimbursement being terminated, the State agency must provide corrective action and technical assistance and ensure the SFA understands steps that must be taken to reinstate the performance-based reimbursement.

Corrective Action (CA)• Corrective actions are those actions that are

taken by a SFA to correct any degree of violation in the Critical and General Areas of Review. Additionally, if during the course of the review, a Program violation is identified that is outside the scope of AR, CA would also be required. • SFA may provide input on CA approaches that

will achieve the desired result• SA may offer technical assistance for deficiencies

cited

Corrective Action (CA)• CA establishes the extent of the fiscal action taken, it

is important the SFA implements CA in a timely manner. • Explain that withholding of payments will result if CA

is not taken• Explain how FA will be calculated. At the State

agency’s option, a potential claim amount may be discussed

Corrective Action (CA)• The State agency must provide a preliminary

assessment of the actions needed to correct the violations. This assessment should be based on discussions of CAs and TA at the SFA/school levels • Problems identified must be corrected system-

wide. Therefore, effective CA must be taken by the SFA in all schools and Programs, not just those reviewed.

Corrective Action (CA)• Documentation of CA is required for any degree of

violation in either the Critical or General Areas that are identified during an review. Documented CA should also include any program violations identified outside the scope of a CRE • Unless documented CA is provided at the time of the

review, the SFA must send written notification to the State agency certifying that the CA required for each violation has been completed, and notify the State agency of the dates of completion. • The State agency will make the determination as to when

a problem is satisfactorily corrected.

CA Timeframes• The State agency must establish appropriate

timeframes for the SFA for each problem requiring CA• State agency must receive the documented CA plan

by the established deadline – READ the review results letter carefully!!!• In the past the CA deadline was not as critical as the

new requirement. Please pay close attention to this and follow the required timelines.

CRE 2013-14• Meet the corrective action plan deadline (if

applicable) – again read the review findings letter carefully.• May receive a separate letter for the nutrient

analysis findings which may or may not result in additional corrective action not discussed in exit conference. Read the review results letter carefully. If you have any questions or problems call the area specialist.

Follow Up Review• When the follow-up review is required it is

primarily the responsibility of the State agency, it may be conducted by either the State agency or FNS. • All SFAs found to have exceeded the review

threshold(s) are subject to a follow-up review.

CRE 2013-14• Part of the Healthy Hunger Free Kids Act of 2010 will

require that review findings be posted at the cafeteria and the findings be made available to the public. At this time USDA has not published the rules and guidance on this issue yet, so there is not a this moment a method of handling this requirement.• Keep in mind that this will happen, probably sometime

during this new three year review cycle. It may happen that a year or two from now USDA publishes the rule and guidance and requires that all findings beginning with this school year be made available.

CRE 2013-14• Read the announcement letter carefully. If you

have any questions or problems call the area specialist.• Send pre-review documentation by the date

established in the announcement letter.• Read the review results letter carefully. If you

have any questions or problems call the area specialist.

CRE 2013-14• We have several new staff members now and others coming

still during this school year.• Do not be surprised if you have more than one person show

up to do the review as all the new staff members will be in training this school year.

• The Southwest Regional Office of USDA (in Dallas) has requested (as usual) our review schedule so that they can determine which reviews they will accompany us. In the past they have let us know ahead of time if they will be with us on a review; if they continue this practice then we will let you know they are coming on the review.

CRE 2013-14• Based on new federal requirements for state

agencies we are required to document every thing we do on a review (including technical assistance) and cover it with the exit conference and the review findings letter.• While this may seem like we are ‘out to get you’

that is definitely not the case.We are required to follow federal regulations, just like you are. • Please don’t take it personally!

Questions?

Ask them now!!!