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Detailed information for each area covered in this review may be found on the DPI website at
http://fns.dpi.wi.gov/
1
The New AR: Performance Standards
2Critical Areas
Performance Standard 1Performance Standard 2
General AreasResource ManagementGeneral Program Compliance
Regulatory Authority for the Administrative Review can be found in 7CFR 210, 220 and 245, The Richard B. Russell National School Lunch Act, the Child Nutrition Act of 1966, Section 201 of the Healthy, Hunger-Free Kids Act of 2010 and Public Law 11-296.
Review Period3
Most recent month for which a claim was submitted
Must include > 10 operating daysSpecial Circumstances
Reviews early in school yearYear round, multi-track, & provision schoolsMay require approval or special procedures
New Administrative Review Structure
4
Section 1 Section 2 Section 3
Access & Reimbursement
•Eligibility Determination
•Benefit Issuance
•Direct Certification
•Verification
•Meal Counting, Claiming and Reimbursement
Nutritional Quality/Meal Pattern
•Meal Components
•Offer versus Serve
•Dietary Specifications and Nutrient Analysis
Resource Management
•Resource Management
•Nonprofit School Food Service Account
•Paid Lunch Equity
•Revenue from Non-program Foods
•Indirect Costs
•USDA foods
Section 4 Section 5
General Program Compliance
•Civil Rights
•SFA On-site Monitoring
•Local Wellness Policy
•Competitive Foods
•School Env. Report Card
•Water
•Food Safety
•SBP & SSO Outreach
Other Federal Program Reviews
•Afterschool Care Snack Program
•Seamless Summer Option
•Fresh Fruit and Vegetable Program
•Special Milk Program
Review Frequency & Schedule5
Review FrequencySFA must be reviewed every 3 years
Cycle begins July 1, 2013
AR Schedule for 2013-14 SYSchools scheduled in 2012-13 will be reviewed in 13/14
CESA 2 , CESA 8, and Lower half of CESA 4
Schools that did not certify in 2012-13 will be subject to review in 2013-14
A list of SFAs that will be reviewed in 2013-14 can be found on the DPI website at http://fns.dpi.wi.gov/fns_ar
School Site Selection6
If more than one school is listed on Schedule A of your on-line contract, you will need to complete a site selection form
Complete the form using claim information for the month of October 2013
> School Name
> Number of serving days
> Number of free eligible
> Number of free lunches claimed
Minimum Number of Review Sites
7
Review all sites (except RCCI) with free ADP of 100 students and free participation factor of > 100%.
All meal patterns must be represented for schools which are NOT $.06 Certified
Number of Sites in the School Food Authority
Minimum Number of Sites to Review for NSLP
Number of Sites in the School Food Authority
Minimum Number of Sites to Review for NSLP
1 to 5 .................................................1 6 to 10................................................2 11 to 20..............................................3 21 to 40..............................................4
41 to 60............................................6 61 to 80............................................8 81 to 100........................................10 101 or More....................................12*
* 12 plus 5 percent of the number of sites over 100. Fractions must be rounded to the nearest whole number.
BENEFIT ISSUANCEELIGIBILITY DETERMINATION
DIRECT CERTIFICATIONVERIFICATION
MEAL COUNTING & CLAIMING
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Access and Reimbursement
Access and Reimbursement Overview
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The New Administrative Review Process 10
School Food Authority (SFA)School Food Authority (SFA)
Certification of Eligibility Benefit Issuance
Eligibility Determination
Direct Certification
Verification
Meal Counting and Claiming Site-level Review
SFA-level Review
11
Access and Reimbursement
12
Access and Reimbursement
CERTIFICATION AND BENEFIT ISSUANCE
Eligibility and Benefit Issuance13
Information requested: How student was certified for benefits Who is Hearing Official Back-up system School Calendar for school start date and
approval timelines F/RP meal application materials sent to
household How is Direct Certification conducted http://fns.dpi.wi.gov/fns_fincou1#manual
Direct Certification (DC)14
Name(s) of the individual(s) responsible for processing the DC listings and issuing benefits to eligible students.
A copy of the letter used by the SFA to notify households of their direct certification eligibility.
A description of the SFA’s procedures for extending DC eligibility to all children in the Foodshare or W-2 household
Eligibility15
Other items that will be assessed: Conversion factors and income guidelines How SFA handles carryover of previous school
year’s eligibility (up to 30 Operating Days) Length of time for application approval How SFA updates eligibility changes Method used to notify households of student’s
eligibility determination Who has access to benefits issuance
documents Applications include all required elements
Benefit Issuance16
F/RP meal applications to be reviewed All applications in SFA (must be reviewed if less than
100 students certified for F/RP meal benefits)Statistical Sampling for SFAs with 100 or more
students certified for F/RP meal benefitsSFA-wide Benefit Issuance List requirements:
Name/Benefit Status for all F/RP eligible students Generated from Point of Service used in each
school No Duplicate Names School Name, Certification Method, Certification
Date, Total number of eligible students Do Not Group by Free and Reduced eligibility
status May be any day during the review period
Review minimum of 10 denied applications
Notification of denial Reason Appeal Rights and
Instructions Family may reapply
17
Reviewing Denied Applications
Common Findings18
Reimbursement claimed for student meals when no approved application is on file
F/R apps not processed within 10 operating days of receipt
Data entry error results in incorrect eligibility status Income Application missing required informationIncorrect number recorded as case numberSFA did not use Direct Certification for students who
receive Foodshare or W-2.One student is receiving free DC benefits but siblings are
notConfidential eligibility information is released for
unauthorized purposes or without prior consentStudent eligibility status is not updated in (POS) or roster
Corrective Action19
Required for Findings/ErrorsMust be applied SFA-system wide
Formal response required from SFA
Fiscal Action20
Reasons Fiscal Action is taken? Applications missing information Incorrect categorization of eligibility Benefit Issuance Errors Failure to update verified applications
How far back is fiscal action taken? Can be back to the original date of
eligibility
VERIFICATION
21
Access and Reimbursement
Verification Collection Report (FNS 742 Report)
Questions
Verification Collection Report (FNS 742 Report)
Questions
Accuracy of Verification:
Sample Size
Reporting
fns.dpi.wi.gov/files/fns/pdf/gm_sp_38_2013
22
Verification
Verification 23
Verification Official and Confirming Official
Description of SFA Verification Process
Participation in Training
Electronic System
Determining Compliance 24
Verification Requirements
Number of Verified Applications Calculated Correct Sample Size Verified Correct Number of Applications for
Sample Size If applicable, replaced applications accurately Notification letters meet FNS requirements Household follow-up attempts were made Notice of adverse action met FNS requirements Timeliness of eligibility status changes Completed the verification process by November
15
Common Verification Errors25
Verification process did not begin on October 1Verification process did not end by November 15Verification did not take place at allVerification Collection Report not submitted by February
1An application was pulled for Direct Cert. studentSFA uses an incorrect verification method.The sample pool does not round upNo follow-up attempt to collect verification informationFollow-up attempt not documentedNo replacement application selected for withdrawn
studentThe software not updated
MEAL COUNTING & CLAIMING
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Access and Reimbursement
Counting, Claiming, and reimbursement
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Meal counting and claiming system accurate by category
Meals counted, consolidated, and recorded correctly
Accuracy of meals claimed and reported for reimbursement
Electronic vs. Manual
Standard Counting Procedures
Point of Service Back-up SystemTraining
28
Meal Counting and Claiming
Meal Counting and Claiming29
Provide an accurate count taken at the point of service daily
number of reimbursable meals served
by categorywithout overt
identification
Meal Counting and Claiming30
Complete edit checks for potential over-claims
Federally required Conducted on a daily
basis at the school/site level
Conducted on a monthly basis at the SFA level
Resolve discrepancies before filing claim for reimbursement
Meal Counting and Claiming31
Site Level ● Prevention of Overt
Identification● Accurate Count by
Category● Overrides● Validate the meal
count by type● Fiscal Action
Validating Counting & Claiming
Meal Counting and Claiming32
Site Level● Meal count comparison
to review period● Meal count comparison
to free and reduced-price students
● Meal count comparison to attendance adjusted eligible
● School meal counts vs. SFA claim for reimbursement
Common Findings33
Each service line does not provide an accurate count by eligibility category at the Point of Sale (POS).
Meal counts incorrectly consolidated or not done daily.
There are questionable patterns in the meal counts.
Effective edit checks are not conducted as federally required.
Systemic Systemic Non-Systemic Non-Systemic
34
Errors
SystemicSystemic Non-SystemicNon-Systemic
Errors will result in fiscal action
CA is requiredFollow up from
SA may be required for the CAP
Errors may result in fiscal action
CA may be required
35
Meal Counting and Claiming Errors
Fiscal Action Errors36
Meal Count Combining Errors
Fiscal Action for difference between incorrect and correct meals
Counting Errors Meal counts do
not equal number of meals served to eligible students
Meal counts exceed number of eligible students by category
Second and/or ineligible meals were counted
USDA Non-discrimination Statement37
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 [email protected]. 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). USDA is an equal opportunity provider and employer
