Breakout session from NSNA conference, NDA Production Records

1. agri.nv.gov
Legislative Update
Catrina Peters MS, RD
School Nutrition Services Manager

2. agri.nv.gov
NDA Legislative Update
• Federal legislative changes
• State legislative changes

3. agri.nv.gov
NDA Legislative Update--Federal
• The past 7 years have been
exciting!

4. agri.nv.gov
NDA Legislative Update--Federal
• What does the future hold?
• New Secretary of Agriculture
– Sonny Perdue
– Previous Governor of Georgia
– Supportive of School Nutrition
• Lots of positions still unfilled

5. agri.nv.gov
NDA Legislative Update--Federal
• Meal Pattern “flexibility”
– May 1 press release
• Sodium
• Flavored milk
• Whole grains

6. agri.nv.gov
NDA Legislative Update--Federal
• Previously instated flexibility
– Hold at sodium target 1
– Whole grain pasta waiver
• Newly stated flexibility—approved
waiver required
– 1% Flavored Milk
– Whole grains—all types, not just pasta

7. agri.nv.gov
NDA Legislative Update--Federal
• How do I pursue a waiver?
– NDA will be distributing a memo and
waiver template shortly
• Waiver request must be submitted
demonstrating:
– Financial hardship (participation/cost)
– Limited product availability
– Unacceptable product quality
– Poor student acceptability

8. agri.nv.gov
NDA Legislative Update--Federal
• Can I just serve non-whole grain
items now?
– No, you need an approved waiver
– Otherwise, must still meet meal pattern
requirements
• Will further flexibility be allowed?

9. agri.nv.gov
NDA Legislative Update--Federal
• Will there be other changes?
• Current requirements such as professional
standards, PLE and meal pattern
requirements are written into federal
regulation
• Changing them requires an act of
congress (literally)

10. agri.nv.gov
NDA Legislative Update--State
• Last legislative session
– SB 503 “Breakfast After the Bell”
– School Nutrition rose to challenge
– Huge participation gains
– $2 million in general funds to
school breakfast programs
• Resulted in $8 million in additional
federal reimbursement for SY 15/16
• National leader in breakfast
participation increase

11. agri.nv.gov
NDA Legislative Update--State
• Last legislative session
– Required reporting for lunch and
breakfast participation
– Gender, race and ethnicity
– Report on NDE “report card”
– Special provisions made this
challenging but data is currently being
reported by NDE

12. agri.nv.gov
NDA Legislative Update--State
• Last legislative session

13. agri.nv.gov
NDA Legislative Update--State
• This legislative session
– SB 3
• slight changes to breakfast after the bell
– Free and Reduced breakfast participation must
be maintained in 17/18 compared to 16/17
benchmark participation level
• If participation level is not maintained, a corrective
action plan may be required to be submitted
– Letters have been distributed to Superintendent,
Food Service Directors and Principals
• Pre-k expansion
– Much discussed but no bill was passed

14. agri.nv.gov
NDA Legislative Update--State
• Medicaid expansion
– Bill passed, was vetoed by Governor
Sandoval
• Private and Charter Schools
– ESA (voucher program) was not funded
– $20 million was approved to be put towards
scholarship program for private and charter
schools
– Achievement School District was much
discussed but no bill was passed requiring
changes

15. agri.nv.gov
Administrative Review:
Common Deficiencies
Edward Coleman
Quality Assurance Specialist
June 26, 2017

16. agri.nv.gov
Administrative Review: Common Deficiencies
Presentation Outline
Performance Standard 1
• Applications
• Non- Discrimination Statements
• Verification
• Counting and Claiming
Performance Standard 2
• Production Records
• Whole Grain Rich Items
Other Areas
• Civil Rights
• Professional Standards
• Water
• Food Safety
Other Programs
• Afterschool Snack

17. agri.nv.gov
Common Terminology
Benefit Issuance: the link in the accountability system
between the eligibility determination and the benefit
delivery
Eligibility/Certification: the process used to
determine a student’s for free or reduced price meals
Point of Service: the point in the food service
operation where a determination can accurately be
made that a reimbursable meal has been served to an
eligible child
Verification: confirmation of eligibility for free and
reduced price benefits under NSLP or SBP

18. agri.nv.gov
Performance Standard 1
All free, reduced- price, and paid meals claimed for reimbursement are served only
to children eligible for free, reduced- price, and paid meals respectively, and are
counted, recorded, consolidated, and reported through a system that consistently
yields correct claims.
In Summary;
• Performance Standard 1 covers meal certification and the benefits
issuance process.

19. agri.nv.gov
Certifying Applications
Four types of applications as noted in the Eligibility Manual for School
Meals page 62;
• Income Based Applications
• Assistance Program Applications
• Other Source Categorically Eligible Applications
• Applications for Foster Children
https://www.fns.usda.gov/sites/default/files/cn/EligibilityManualFinal.pdf

20. agri.nv.gov
Incomplete Applications
Incomplete applications cannot be processed for meal benefits and must
be completed by the family prior to processing the application.

21. agri.nv.gov
Income Applications
To be considered complete an Income Application must have the
following information;
• Names of all household members
• Amount, source, and frequency of current income for each
household member
• Signature of an adult household member
• Last 4 digits of the Social Security Number of an adult household
member or an indication of no adult household member having a
Social Security Number.

22. agri.nv.gov
Income Applications: Income Conversions
If a household has multiple incomes with differing frequencies all
incomes for the household must be annualized.
Income Conversion Factors;
• Weekly Income: multiply x 52
• Bi- weekly Income: multiply x 26
• Bi- Monthly Income: multiply x 24
• Monthly Income: multiply by 12

23. agri.nv.gov
Assistance Program Applications
These are applications of households with individuals that receive
assistance from an assistance program in the State of Nevada.
Acceptable Assistance Programs
• SNAP
• TANF
• FDPIR

24. agri.nv.gov
Assistance Program Applications
To be considered complete, Assistance Program Application must
have the following information;
• Names of the children for whom the application is made
• SNAP, TANF, FDPIR case number or identifier for household
member
• Signature of the adult household member completing the
application.
– If a valid case number is entered, the last 4 digits of the social security
number or the box for no SS# can be skipped as indicated on the USDA NSLP
meal benefit application prototype

25. agri.nv.gov
Assistance Program Applications: Case Numbers
In Nevada, all case numbers are 9 digits.
Exception: Some SNAP case numbers may have the following
format: 000-34-5678 or 000-00-6789
Note: Eligibility extends to all children in the household whether
they are listed on the application or not.

26. agri.nv.gov
Assistance Program Applications vs. Direct
Certification (DC)
Direct Certification is a process of establishing a child's categorical
eligibility for benefits by obtaining documentation directly from the
State or local SNAP, TANF, or FDPIR office that the children's
households are receiving those benefits.
An assistance program application is an application for free or
reduced meal benefits that is submitted by a family that has their
assistance program case number on it.

27. agri.nv.gov
Other Source Categorical Eligibility Applications
Other Source Categorically Eligible Applications are applications for
children with outside circumstances that would qualify them for free
meals.
Outside Circumstances
• Homeless
• Migrant
• Runaway

28. agri.nv.gov
Other Source Categorical Eligibility Applications
To be considered complete, Other Source Categorically Eligible
Applications must have the following information:
• Names of children for whom the application is made
• Indication of the child’s categorically eligible status
• Signature of an adult household member

29. agri.nv.gov
Other Source Categorical Eligibility Applications
Determining Eligibility;
• Other Source Categorical Eligibility must be
determined on a per child basis.
• There must be supporting documentation;
1. An appropriate program official must confirm the
status of each child either through direct contact with
the agency or by a list of names provided to the
agency prior to providing benefits.

30. agri.nv.gov
RCCIs and Documenting Eligibility
RCCI’s have 2 options;
• They can maintain an Eligibility Documentation Sheet
OR
• RCCI’s can complete free and reduced applications for all residents.

31. agri.nv.gov
Eligibility Documentation Sheets
The Eligibility Documentation Sheet should have the following;
• Childs Name
• Documentation of the Childs Income
• Childs Date of Birth
• Date of Admission to the facility
• Expected Release date from the Facility
• Facility Officials signature
• Facility Officials title and contact information

32. agri.nv.gov
USDA Non- Discrimination Statement
All program materials and supporting platforms must have the most
current version of the USDA non-discrimination statement.
Includes
• Documents, pamphlets, brochures and websites for public
information, public education, or public dissemination.

33. agri.nv.gov
USDA Non- Discrimination Statement
The shorter USDA non- discrimination statement may be used when
the size of the material is too small to include the full statement.
• “USDA is an equal opportunity provider, employer, and lender.”
• “This institution is an equal opportunity provider.”
Full Statement Information
• https://www.fns.usda.gov/fns-nondiscrimination-statement

34. agri.nv.gov
Verification
Verification is confirmation of eligibility for free and reduced priced
meals based on applications only.
Verification must include confirmation of either;
• Income Eligibility
• That the child or a member of the household receives SNAP, TANF,
or FDPIR benefits
• That the child is other source categorically eligible
https://www.fns.usda.gov/sites/default/files/cn/EligibilityManualFinal.
pdf

35. agri.nv.gov
Verification
Verification Process
• Verification must be completed no later than November 15 of the
current school year.
• SFAs must make at least one follow up attempt with households
that do not submit information to complete verification process.
Any changes resulting from verification should by correctly applied to
the requisite child(ren).

36. agri.nv.gov
Counting and Claiming
Meals for reimbursement may only by counted when they are served
to the child at the point of service.
Pre- counts, pull counts, counts based on occupancy, counts based on
what is left over after a meal service, counts that do not occur at the
point of service, and counts where a proper reimbursable meal is not
verified by a staff member are ineligible according to the federal
regulations governing counting and claiming in the FNS programs

37. agri.nv.gov
Counting and Claiming: Consolidating
the Claim
The daily consolidation of meal counts from the site level should reflect
what was counted at the site level.
Infinite Campus: We are aware that this program has issues consolidating
counts. It is your responsibility to ensure that all counts submitted for
claims are accurate.
Infinite Campus: Problem Areas to be aware of;
• The Monthly Transaction Summary Report may produce incorrect totals
Work Around Solution:
• The Daily or Monthly Edit Check Report or the daily transaction report
should be used to consolidate totals.

38. agri.nv.gov
• The National School Lunch Program meal pattern is the
foundation of federal school nutrition programs, and sponsors of
the program must ensure that they are offering reimbursable
meals for breakfast and lunch according to regulations (7 CFR
210.10 and 220.80). Schools operating NSLP and/or the SBP
must prepare, offer, and serve meals to students that meet the
meal pattern requirements for the appropriate age/grade groups
on all reimbursable meal service lines.
In Summary,
Performance Standard 2 establishes that meals
claimed for reimbursement contain the appropriate meal
components and quantities for the SBP and NSLP.
Performance Standard 2

39. agri.nv.gov
The most common areas in Performance Standard II
• Production Records- missing units of measure,
not completed daily, not noting how much was
pulled
• Whole Grain Rich Items- check labels and
vendor orders to be sure its WGR. Must say
“Whole” on the nutrition label and not “Enriched”
Common Deficiencies

40. agri.nv.gov
Comprehensive
Resource Management

41. agri.nv.gov
• The intent and scope of the CRM is to apply a
systemic approach to ensuring the overall
financial health of a School Food Authorities'
(SFA’s) nonprofit school food service.
• This review has up to four areas it can focus on
based on the Resource Management Risk
Indicator Tool.
Comprehensive Resource Management (CRM)

42. agri.nv.gov
Recently the CRM changed
To get a CRM before the change, you had to flag
in three of the four areas on the tool and you
would receive a CRM in ALL areas.
NOW
You receive a focused CRM in each individual
area that you flag in on the tool. If you flag on
three areas, you receive a CRM for all areas.
Comprehensive Resource Management

43. agri.nv.gov
In general if your transfers into the
program from non- federal sources
exceeds the annual cost of adult
meals, this should be documented and
no further action is needed.
If you do not know how to calculate
the cost of adult meals contact me and
I will provide technical assistance.
RCCI’s and Adult Meals

44. agri.nv.gov
General Areas

45. agri.nv.gov
Civil Rights
To be compliant with Civil Rights requirements you must have the
following;
• An annual Civil Rights Log
• Staff who interact with program participants must receive annual
USDA civil rights training
• The “And Justice for All Poster” must be visible in the serving area
to program participants

46. agri.nv.gov
Documentation that will be requested for review;
• USDA Trainer Tracker or your own training tracking
documentation
• Supporting documentation for all completed trainings
for the school year (July 1- June 30)
Professional Standards

47. agri.nv.gov
The training tracker must contain the following
information if you choose to create your own document;
• Key Areas
• Training Topics and Learning Objectives with proper
codes
• Training date and length
https://www.fns.usda.gov/school-meals/professional-
standards
Professional Standards

48. agri.nv.gov
Water
Free non-potable water must be made available to program
participants during the meal services.
• Note: The water requirement for breakfast only applies when
breakfast is served in the cafeteria.

49. agri.nv.gov
Food Safety
The HAACP Manual
• Must contain all necessary and current SOP’s for the type of meal service
you provide
• Must have an accurate table of contents
• Must be available to onsite staff
The Institute for Child Nutrition(ICN) is a great resource for standard SOP’s
but you should tailor the documents you download to meet the needs of
each site.
For example, if your sites do not use salad bars, it is not necessary to have
the SOP for cross contamination at salad bars.

50. agri.nv.gov
Food Safety Specific Issues
• Dropped Food: you should have an SOP or procedure covering
how dropped food will be handled for a tray or an individual item
such as the child’s milk or an apple.
• Sanitizer levels: These should be at the appropriate levels for
proper sanitation.
• Temperature Logs: These should be filled out daily by staff to
ensure proper storage of food.

51. agri.nv.gov
Afterschool Snack
It must be monitored two times per year;
• Once within the first four weeks of program operation
• One more time some time after the first but before the end of the
year

52. agri.nv.gov
Afterschool Snack
Counting and Claiming
• Snacks may only be counted when served to the child at the point
of service.
• Snacks may not be counted on weekends or holidays.
• There must be an educational component that accompanies the
snack.

53. agri.nv.gov
Resources
Applications
• Eligibility Manual for School Meals
• https://www.fns.usda.gov/sites/default/files/cn/EligibilityManu
alFinal.pdf
• Nevada Department of Agriculture Applications Webinar
• https://www.youtube.com/watch?v=GsiR5AHA0GA
USDA Non- Discrimination Information
• https://www.fns.usda.gov/fns-nondiscrimination-statement
Professional Standards Resources
• https://www.fns.usda.gov/school-meals/professional-standards

54. agri.nv.gov
Questions?