Preparing for an Administrative Review

Lindsay Healy, RD, SNSCN ResourceJune 4th, 2014

The Administrative Review (AR) is the new USDA review process. This AR replaces both the old CRE and the SMI.

The AR was introduced with the Healthy Hunger Free Kids Act of 2010. The 2013-2014 school year was the first year that it was implemented.

Moving forward it is important to forget the ways of the CRE and SMI and embrace the changes! There are many similarities however, it is a different review and it is important to make sure everyone is aware and comfortable with the new review process.

Administrative Reviews will be completed on a 3 year cycle.

This increases our opportunity to visit schools and

offer technical assistance. Having more frequent

reviews will hopefully bring a decrease in review

findings and create more effective child nutrition

programs in the schools.

There are 4 main focus areas of the AR:

Performance Standard 1: This focuses on meal eligibility

and counting and claiming.

Performance Standard 2: This standard focuses on the

meal quality; menu components, serving sizes and

nutritional quality.

Resource Management Comprehensive Review: This is a

part of the review that takes an in-depth look at the

financial aspects of the program.

General Areas: This includes, food safety, civil rights,

wellness policy, etc.

The Healthy Hunger Free Kids Act also brought along major changes to the meal patterns for breakfast and lunch.

The AR reviews the new pattern through an in-depth menu review that is completed prior to the on-site visit as well as meal observation on the review day.

What is the Administrative Review?

Step 1: Notification of ReviewThe state agency will send a notification to all of the SFAs that are selected for review in SY 2014-2015. They will receive a letter letting them know that they will be contacted to schedule the review.

Step 2: Scheduling the ReviewDetermining the site(s) for review:

• The number of sites selected for review is based on the number of participating schools within the SFA.

• There are USDA criteria that is used when selecting the specific sites.

• The length of the on-site review will be based on the number of sites that must be reviewed and the number of meal applications that will need to be reviewed.

Step 3: Pre-Review Procedures

Selecting the site for a targeted menu review:• Meal compliance assessment procedures

Additional Pre-review documents:• Off-Site Assessment • Dietary Specification Assessment Tool (targeted menu site

only)• Menu Documentation Review

Off-Site Assessment When completing the Off-Site Assessment:• Work as a team

• Answer the questions completely

• Be as accurate as possible

• Call and ask if there is a question you don’t understand

• Submit it by the due date

• Submit all the requested supporting documents

Dietary Specification Assessment

• Only needed for the site that is selected for the Targeted Menu Review. (the reviewer will let you know what site this is)

• The reviewer will tell you if you need to complete breakfast and lunch or lunch only.

• Read each statement carefully.

• Answer each statement honestly.

Menu Documentation Review

Week of Menu ReviewA single week from the review month will be selected for the

menu documentation review. The reviewer will work with the SFA to determine the week.

What Menus are Reviewed?All unique menus that will be observed at the review site(s)

must be submitted for menu review.

What Menu Documentation Needs to be Submitted? Production Records, Menus, Standardized Recipes, Labels, CN

labels

Step 4: On-site Review

SFA Level:• Applications• Verification• Claims• Resource Management*• Civil Rights• Wellness Policy• Food Safety Plan• Record Keeping• SBP and SFSP outreach• FSMC*

Site Level:• Point of service• Meal components• OVS• Kitchen walk through • Civil rights • On-site monitoring• Competitive Foods • Water• Food safety • Record Keeping

Certification and Benefit IssuanceBenefit Issuance list from all sites participating within the SFA

• Total number of eligible students in the SFA• Identify which students were selected for Verification• List must come from the point of service• No duplicates• List of students eligible for free and reduced meals (do not

include paid students). For each student the list must provide:• student’s name, • school name, • benefit status, • method of certification, • date of certification

Eligibility Documentation

• Reviewer will determine which applications will be reviewed.• Applications will be reviewed district wide, not just selected sites.• A percentage of denied applications will also be reviewed.

SFA must provide:• Certification Document (application, direct certification,

eligibility list)• Verification documents (if applicable)• Notification of benefits• Any follow-up documentation and/or communications with

the household

Income Applications MUST include:

Names of all household members

All household member’s income and frequency

Indication of no income for those that have none

Signature of adult household member

Last 4 digits of Social Security Number

*Must be approved using the correct USDA Income Eligibility Guidelines

Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Families (TANF) or Food Distribution Program on

Indian Reservations (FDPIR) Applications MUST include:

Case Number

Signature of adult household member

Foster Students MUST:

Have an approved application on file OR

Have approved documentation from the County indicating their foster status

Categorically Eligible Students MUST:

Be on an approved and complete list (Homeless, Migrant, Runaway, Head Start)

Be on the Direct Certification Report

Students Extended Eligibility through the Direct Certification Report MUST:

Be documented on the Direct Certification Report or on a separate document.

The documentation must include the date they were added, and the student that they reside with that is listed on the Direct Certification Report.

VerificationAll Verified applications will be reviewed

• Initial application• Notifications sent to households• Verification documents submitted by households• Notification of results of Verification

• Reviewer will complete a detailed review of 10% of verified applications

• Summary of Verification Efforts• This is the report that the SFA is required to maintain each

year, but is NOT required to submit to the State.

Claim for Reimbursement and POS

Claiming documents from all sites within the SFA will be reviewed

• Review month claim from each site• Edit check from review month for each site• Consolidated claim for review month

Point of Service (POS)

Does the system avoid overt identification?Does it provide an accurate meal count?How are meals consolidated at the end of service?How does the POS ensure that students are not claimed more than once?

Meal Compliance

Production Records: Are the records complete?Were all components served each day?Were the correct portions served for each component?

Production Record Requirements

• Food components

• Recipe or food product used

• Planned/projected number of portions and serving size

for each age/grade group

• Planned/projected number of portions and serving size

for adults

• Total amount of food prepared

• Actual number of servings for each item served

• Actual number of non-reimbursable meals served (adult

or a la carte)

• Leftovers and substitutions

Meal Preparation Observation

During meal preparation are:

Standardized Recipes used?

Are correct measuring tools used?

Are proper food safety practices followed?

Meal Service

Was each component available to all students?

Were portion sizes accurate?

Two varieties of milk

Were reimbursable meals selected?

Offer vs. serve implemented correctly (if applicable)

Is there proper signage that identifies a reimbursable

meal?

Resource Management

AuditsNon-Profit School Food Service Account

Paid Lunch EquityRevenue from Non-Program Foods

Indirect CostsUSDA Foods

Paid Lunch Equity Toolhttp://www.fns.usda.gov/paid-lunch-equity-school-year-2014-2015-calculations-and-tool

Non-Program Foods Revenue Toolhttp://www.fns.usda.gov/cnd/governance/policy2006-2011.htm

Civil Rights• The SFA's public release

• Description of the SFA's procedures for receiving and handling a Civil Rights complaint

• Information on the number and description of complaints alleging discrimination in the current and prior school year

• Date, agenda and attendees of the recent Civil Rights training for the SFA staff

• Need and availability of translation services

• Description of the SFA's procedures for collecting racial/ethnic data

• The non-discrimination statement used on all program materials

• "And Justice For All" poster

On-Site Monitoring

*Important: On-site monitoring is only required if the SFA has more than 1 building that participates in the NSLP and/or SBP.

Documents to Review:Current year on-site review forms

http://www.fns.usda.gov/cnd/governance/Policy-Memos/2011/SP14-2011_os.pdf

Wellness Policy At a minimum the Wellness Policy must include:1. Goals for Nutrition Education2. Goals for Physical Activity3. Goals for other school based activities to promote wellness4. Nutritional guidelines for all food sold on campus5. Goals for Nutrition Promotion

*The wellness policy should be developed by a team that includes, teachers, food service staff, parents, administration and students

NEW with Reauthorization:6. SFAs are required to make the Wellness Policy public 7. SFAs must periodically measure the implementation of the policy8. The SFA must designate one or more school officials to ensure

compliance with the wellness policy

You need to be able to answer: How is the Public informed?When and how is the policy reviewed and updated?

Who is involved with the policy?How can stakeholders participate?

Competitive Foods & A la Carte

1. Ensure that there is no sale of competitive foods and that foods of minimal nutritional value are not available during meal service in the serving or dining area.

2. All food sales must be incompliance with the new guidance for the 2014-2015 school year.

3. Have copies of the nutrition labels of all foods sold within the school during the school day available for review.

WaterThe Healthy Hunger Free Kids Act requires that potable water be made available to all program participants free of charge during both breakfast and lunch service.

While observing breakfast and lunch you must ensure that free water is available for consumption by program participants.

Schools can provide water in a variety of ways:• Water pitchers and cups on tables• A water fountain• Water dispenser with cups in the cafeteria

Food SafetyFood Safety Inspections• Copy of the most recent food safety inspection must be

posted at each site in a prominent location• The SFA needs to provide documentation of the two most

recent inspections

Temperature Logs• For the cooler(s), Freezer(s) and Store room• For all food that required cooking to an established internal

temperature• For food that needs to be maintained below 41

Food Safety PlanCopy should have already been submitted with off-site assessment, but each site should have a copy maintained on site.

Complete a Kitchen Review:

• Food stored off the floor

• Temperature logs for storage areas

• 3 compartment sink

• Proper storage procedures

• Recent inspection is posted in a visible location

• Proper hygiene

• Cross contamination risks

• Food Preparation area and cooking utensils are clean

• No obvious evidence of a pest problem

Record Keeping

As you review other areas, you should be evaluating that the appropriate reporting and record keeping requirements are in compliance.

Page 166-167 of the Administrative Review manual list the common reports and records that the SFA must have on file.

Other Programs

Afterschool Snack Program (ASSP): Ensure that production records are maintained and all snack items offered are creditable.

Fresh Fruit and Vegetable Program (FFVP): Have documentation of products served and detailed claims for reimbursement.

Special Milk Program (SMP): Pricing Policy, counting and claiming procedures, milk service procedures and records.

Seamless Summer Option (SSO): Meal counting and claiming practices, menu planning, and meal service.

Step 5: Administrative Review Report

The reviewer must provide the SFA with written notification of the review findings:

• Superintendent or authorized representative

• Commendations

• Review findings

• Corrective Action Plan

• Potential for Fiscal Action

• Right to an appeal

How can I have a Great Review?

Team work:Get everyone involvedProvide in house trainingsDon’t leave it up to just one person

Organization:Determine the best way to present all the requested materialsBinders, folders, paperclips, hanging files, etc.

Over prepare!!Double, triple check everything Read all of the guidance and resources that are available

This seems overwhelming…

• Start early

• Ask questions

• Submit requested information by requested dates

• Be responsive

• Use your team to get prepared

• Don’t wait until the morning of the review

• Stay up-to-date on trainings

Use the Review tools

• All of the administrative Review forms are on the USDA website

• Do an in house review using the tools

• Make sure you understand the questions and you are in compliance

Administrative Review Tools:http://www.fns.usda.gov/cnd/guidanceadminreview.htm

Questions??