The NEW Administrative Review

This institution is an equal opportunity provider

It takes a lot of courage to release the familiar and seemingly secure, to embrace the new. But there is no real security in what is no longer meaningful. There is more security in the adventurous and exciting, for in movement there is life, and in change there is power- Alan Cohen

The Healthy, Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process: Consolidate the Administrative Review Processes Incorporate school breakfast, the new meal pattern and

dietary specification, and the 6-cent performance based reimbursement

Implement a 3-year review cycle Provide for offsite monitoring approaches Provide effective training and ongoing technical

assistance

Administrative Review Goals

New processes uses tools and forms designed to be: Modular Efficient Flexible Effective Collaborative

Revamped Resources

Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit

Additional Off-Site Monitoring Tools Include: Meal Compliance Risk Assessment Tool Dietary Specifications Assessment Tool Resource Management Risk Indicator Tool

Off Site Assessment Tools

Maximizing Resources

Review Period Most recent month claim submitted, Must

include 10 or more operating days 2013 Reviews

Postponed Reviews from 2012 Those schools not 6 Cents Certified

Special circumstances Reviews early in school year Year round, multi-track, and Provision schools

3 Year Review Cycle

Just because everything is different doesn’t mean that everything has changed.- Irene Peter

New Administrative Review Areas

Notify Superintendent and Food Service Director

Initiate Off-site Assessment Tools Review SFA Documentation Obtain pre-visit information Select NSLP sites for review

Pre-Visit Procedures

Entrance Conference On-Site Review Exit Conference

On-Site Review Procedures

Certification Household Applications and Direct Certification

7 CFR 245.6 for process Benefit Issuance

Roster and Medium of Exchange 7 CFR 210.7 (c)(1)(ii); 245.6 (a)(4); 245.6 (c)(3)(iii); 245.6

(c)(6)(iii) Verification Meal Counting and Claiming

School level review

Entire School Food Authority

Complete Off-Site Assessment Tool Step 1: Obtain Benefit Issuance Document

Must always use the list used by the Point of Service

Must be a day during the review period Step 2: Select Student Certifications for Review Step 3: Obtain Certification Documents

Off-Site Review Phase

Step 2: Selecting Student Certifications for Review

Step 1: Validate SFA’s procedures as described on the Off-Site Assessment Tool

Step 2: Validate Student Certifications Examine Household Application OR find student on DC

List Step 3: Validate Benefit Issuance Document

Make sure no Overt Identification Validate POS

Step 4: Review Denied Applications Reviewed at least 10 denied applications

On-Site Assessment Phase

If you have always done it that way, it is probably wrong.- Charles Kettering

Accuracy of Verification Applications Verified correctly Sample Size determined correctly Confirmation reviews done as necessary Direct Verification done properly Letter sent to household met FNS requirements Correct documentation received from family and

determined correctly Notice of adverse action met FNS requirements

Verification

Review scheduled for: Validation Review

Prior to completion of Verification Summary Report (FNS742)

*Previous year Verification Summary Report*Previous year’s verified applications

Timeframe that falls BEFORE the Verification Summary Report for the current school year has been submitted BUT after the SFA completed Verification

*Previous Year’s FNS742*Validate the number of applications from the previous school year*Review current year’s verified applications for accuracy

After the Verification Summary Report is completed

*Use current year’s applications and FNS742

Verification Review Documents

Verification Review

Validate Off-Site Assessment Tool Validate the Counting and Claiming Process

Electronic versus Manual Prevention of Overt Identification Point of Service Alternative Points of Service Back-up System Training Consolidation and Reimbursement

Record Errors

Meal Counting and Claiming

Reviewer will assess whether the school: Offers students the required meal components

in the required quantities Gives students access to select required meal

components on all reimbursable meal service lines; and

Records for reimbursement only meals that contain required components in required quantities

Meal Components and Quantities

At Least two varieties of fluid milk at breakfast and lunch Fat Free, Flavored or unflavored Low fat, unflavored

Milk Requirements

Schools must offer vegetables from five vegetable subgroups over the course of a week: Dark Green Red/Orange Beans/peas Starchy Other

Vegetable Subgroup Requirements

Starting July 1, 2013 in NSLP and SBP ½ grains offered over the week must be whole

grain-rich Starting July 1, 2014

All grains offered over the week must be whole grain-rich

Whole Grain-Rich Requirements

Review breakfast and lunch documentation to assess meal pattern compliance Menus/production records 6 Cents reimbursement documentation

Week must be 3-7 consecutive days Missing meal components/insufficient

quantities: expand documentation review to (at least) entire review period

Documentation Review

Production Records By meal service line and age/grade group served Support claims Document what was served and leftovers Food is creditable for portions served Document that daily and weekly meal component

requirements are met Identify if seconds are offered regularly

Pre-Visit Documentation Review

Ensure all reimbursable meal lines offer all required components

Make sure standardized recipes are used and followed

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

Ensure there is a milk variety available to all students

“Like” substitutions strongly encouraged

On-Site Review

The State agency will monitor whether: School is offering enough food on all reimbursable meal

service 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; and Food service staff at the POS are trained and can

recognize a reimbursable meal If they make a child go back for more food when the child has

a reimbursable meal, that is now a OVS violation

Offer Versus Serve

Lunch Must take 3 of 5 components Fruits and Vegetables are 2 separate food components Must take at least ½ cup serving of fruit or vegetable component

Food Component is one of the five food groups for a reimbursable meal

Breakfast 4 food items for OVS versus 3 items for non-OVS Must include the three breakfast components (Fruit (or vegetable

substitute), Grain, and Milk) Food Item is a specific food offered within the five food components

After School Snack

Offer versus Serve

School BreakfastOVS

Must Offer 4 Breakfast Items that include the 3 Breakfast Components:

Fruit (or Vegetable SubstituteGrainMilk

Student may decline:1 Item

Student Must Take:At Least 3 items

One component must be fruit or vegetable (SY 2014-15)

School LunchOVS

Must offer 5 Lunch Components:Fruit

VegetableGrain

Meat/Meat AlternateMilk

Student may decline:2 Items

Student Must TakeAt Least 3 components

One component must be fruit or vegetable

OVS: Breakfast and Lunch

We will be asking you 26 questions to assess your practices and determine if you are a Low Risk or High Risk

We will request and review a weeks worth of menu documentation from the targeted menu review site prior to coming on-site Breakfast & Lunch Menu Corresponding Production Records Corresponding Standardized Recipes

If High Risk will have to complete on-site Dietary specifications Assessment tool and a Nutrient Analysis Nutrition Facts Labels and Manufacturer Specification Sheets will be

requested for all food to complete a nutrient analysis

Dietary Specifications

Possible Findings: Missing Meal Components Insufficient quantities of Fruits/Vegetables Implementation Staff Training Signage

Technical Assistance & Corrective Action

Must review at least 1 school 0-5 schools selected that operate FFVP –

Review 1 6-10 schools selected that operate the FFVP –

Review 2 11-20 schools selected that operate the FFVP –

Review 3 Must review the invoices, timesheets,

purchase orders, etc. submitted for the FFVP claim

FFVP Meal Service observation

Review FFVP

Reviewer will determine if SFA retains final administrative and management responsibility for meeting all afterschool snack requirements

Assess compliance in the following areas: Eligibility Accountability/Meal Counting and Claiming Meal Pattern/Production Records Monitoring General Areas

Review Afterschool Snack Program

General Areas of Review Written Food Safety (HACCP) plan Food Safety Inspections posted in a publicly

visible location Temperatures Monitored Request for two inspections Recordkeeping Storage

Food Safety

Have an “…And Justice for All” poster displayed in a prominent location

Program materials have the correct statement included

Civil Rights policy and procedure Documentation for staff training

Civil Rights

FNS Memo SP42-2011 Copy of the Local School Wellness Policy How does the public know about the Local School Wellness Policy?

Periodic review and update How are stakeholders made aware of their ability to participate Goals for Nutrition Education, physical activity, school based

activities Nutrition promotion goals Designated LWP oversight official Nutrition guidelines Plan for Measuring implementation How does the public know about the results of the most recent

assessment on implementation of LWP?

Local School Wellness Policy

Maintenance of the Nonprofit School Food Service Account

Indirect Costs Paid Lunch Equity Revenue from Non-Program Foods USDA Foods

Resource Management

Nonprofit School Food Service Account Did you conduct a year-end review of revenues and

expenses? Did you have expenses in excess of revenues? If you had a surplus – was this amount moved out of your

account? Net Cash Resources

Less than 3 month operating balance Allowable Costs

Restrict the use of program funds to expenses that meet the requirements of 2 CFR 225 and are reasonable, necessary, and otherwise allowable.

Maintenance of the Nonprofit School Food Service Account

Review the SFA’s most recent full year statement of revenues and expenses

Determine whether selected expenses are allowable

Ensure accurate and sufficient support documents are maintained for allowable costs Select a sample of at least 10% of the SFA’s

expenses to test compliance and allowability

Review

WE will check your PLE calculations and amount you determined to increase prices to make sure prices were increased, and if not, make sure that there is a corresponding move of money from non Federal sources (i.e. the General Fund) to Food Service to make up for not increasing prices.

PLE

Non-Program foods – Foods and beverages sold in a participating school that are purchased using funds from the nonprofit food service account

Includes: A la carte items Adult meals Vending machine food purchased with food service

funds Fundraisers Catered and vended meals

Non-Program Foods Revenue

Does the SFA use the USDA Revenue from Non-program Foods Tool to calculate its non-program food costs and non-program food revenue?

Non-Program Foods Revenue

FNS Instruction 782-5 Rev. 1 Adult meal prices should include the value of any USDA

entitlement and bonus donated foods used to prepare the meal

Lunch Reimbursement Rate $2.88 Commodity Rate $.2275 Tax at 6% Total Lunch Adult Price $3.27-$3.29 depending on lunch

rate Total Breakfast Adult Rate $1.60-$1.91

Adult Meal Prices

Ensure SFAs are correctly determining if their costs are allowable, allocable and appropriately charged as a direct or indirect cost.

Indirect costs are determined on an annual basis at the Department Of Education and are valid for one year. Direct costs – incurred specifically for a program or

other cost objective; clearly identifiable Indirect Costs – Incurred for the benefit of multiple

programs, functions, or other cost objectives; not readily identifiable

Indirect Costs

The reviewer should determine if the SFA is conducting an annual reconciliation to ensure that a purchasing agent of FSMC has credited the SFA for the value of all USDA foods received.

Must also review invoices to make sure all rebates, discounts and credits are properly given back to the SFA

Food Service Management Company

Have at most 30 days to correct. Some corrective action must occur

immediately

Corrective Action

Regulatory Authority Authority for Withholding Payments as a

result of Administrative Review (7 CFR 210.18 (l))

Authority for Withholding payments (7 CFR 210.24)

Withholding Payments

SFA has failed to submit documented Corrective Action by the specified due date

SA finds Corrective Action was not completed

SFA continues to have the same problems with the same cause

Payments are withheld until the SA determines that Corrective Action was properly implemented by the SFA

When???

Applications missing information Miscategorization of Certification Benefit Issuance Errors Failure to update verified applications

Fiscal Action

Missing Meal Components Immediate fiscal action required

Vegetable Subgroup & Milk Type Fiscal Action required for repeat violations

Quantities & Whole Grain Rich Fiscal action discretionary for repeat violations

Fiscal Action

2013-14 SFA’s to be reviewed

Sugar Salem SD

Never doubt that a small group of committed people can change the world. Indeed, it is the only thing that ever has.- Margaret Mead

Thank you