NSNA Breakout Session Administrative Review 6.22.15
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NSNA Breakout Session Administrative Review 6.22.15. Presentation covers Administrative Review Timeline, Performance Standards, Resource Management, General Program Compliance, Other Federal Programs, and Fiscal Action
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NSNA Breakout Session Administrative Review 6.22.15
- 1. Administrative Review JUNE 2015 PRESENTER: EDWARD COLEMAN
- 2. Presentation Outline The Administrative Review Administrative Review Time line Performance Standard 1- Meal Counting and Claiming Performance Standard 2- Meal Pattern and Nutritional Quality Resource Management General Program Compliance Other Federal Programs Fiscal Action
- 3. Administrative Review Timeline Pre Review- occurs four to six weeks prior to the onsite review 1. Notice of Administrative Review Letter 2. Off Site Assessment 3. Resource Management Risk Indicator Tool 4. Dietary Specifications Analysis 5. Site Selection Worksheet (to be completed by each SFA)
- 4. Documents for the Pre Review Certification Worksheets for those schools that are $0.06 Certified Benefits Issuance Document 1. Must include the school the student is enrolled in, the method of certification and the date of certification Menu, production records, recipes, and CN labels Nutrient Analysis if available Copies of the Public Release, Civil Rights Policy, Policy for recording Racial and Ethnic Data , Wellness Policy, Health Inspections, Onsite Reviews (if done after February 1 or as available)
- 6. Administrative Review Onsite Review Onsite Assessment can last from a day to weeks 1. Counting and claiming system 2. Applications- Verified and at least 10 Denied Applications 3. Claim validation 4. Meal Components and Quantities 5. Offer vs Serve 6. Nutrient Analysis 7. General Areas: Civil Rights, Water, On Site Monitoring, School Wellness, Food Safety, Reporting and Record Keeping 8. Other Federal Programs: Special Milk Program, After School Snack, Fresh Fruit and Vegetable
- 7. Documents for the Onsite Review These documents should be gathered for review in a central location 1. The applications for free and reduced priced meals and any required supporting documentation 2. The direct certification lists 3. The denied applications 4. The verified applications 5. Consolidated count reports for the month of review
- 8. Post Review The exit conference 1. Will lay out a general overview of the major findings of the Administrative Review onsite assessment Within 30 days of the exit conference a formal letter will be sent detailing all of the findings and proposing a list of corrective actions. The corrective actions letter will give you a time frame to complete and submit all of the required corrective actions.
- 9. Performance Standard 1 Meal Counting and Claiming
- 10. Purpose The Purpose of Performance Standard 1 is to ensure that all free, reduced priced, 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.
- 11. Meal Access and Reimbursement Certification and Benefit Issuance Verification Meal Counting and Claiming
- 12. Certification and Benefits Issuance Assess certification documentation- applications, DC lists, etc. Application review includes; time frames, required information, income computations, and accurate benefits levels. 10 denied applications for benefits from the current school year. Supporting documentation for specific cases; homeless and migrant youth
- 13. Verification Validates the Verification Process 1. Including timeframes for applications in the verification process 2. Required statements in letters (approval and denial letters for benefits)
- 14. Meal Counting and Claiming Verify that reimbursable meals are correctly counted, consolidated, and recorded School Level 1. Determine site level procedures 2. Observe meal service at the point of service 3. Signage indicating what is a Reimbursable Meal is present 4. Review meal counts for day of review SFA Level 1. Determine meal consolidation procedure 2. Review meal count claims for the review period
- 16. Performance Standard 2 Meal Pattern and Nutritional Quality
- 17. Purpose The meal pattern is the foundation of the federal school nutrition programs. To qualify as reimbursable, all meals served must meet the meal requirements for the age/grade group being reviewed. In addition, meal service lines must meet the daily and weekly meal pattern requirements for the age/grade group served.
- 18. Meal Pattern Meal Components and Quantities Offer vs. Serve Dietary Specifications and Nutrient Analysis
- 19. Meal Components and Quantities Documentation that will be reviewed onsite 1. Menus 2. Productions Records 3. Standardized recipes 4. CN Labels 5. Nutrition Fact Labels
- 20. Offer vs Serve Signage identifies reimbursable meal Staff are trained and can recognize a reimbursable meal at breakfast and at lunch Mandatory at the High School Level
- 21. Dietary Specification and Nutrient Analysis Validates the findings of the dietary specification tool from the offsite assessment Observe meal preparation procedures Review food storage procedures on the day of review Check labels
- 23. Purpose The intent of a Comprehensive Resource Management review is to ensure compliance with the program regulations of NSLP in regards to resource management. Comprehensive Management Resource reviews are triggered when the answers provided by school districts to the comprehensive resource management tool classify that school district as high risk. The resource management risk assessment tool aims to assess through the use of known indicators situations that may result in noncompliance.
- 24. Comprehensive Resource Management Resource Management Risk Indicator Tool; used to forecast and/or assess through the use of known indicators, situations that may result in noncompliance. 1. Consists of 7 areas, with some areas having multiple questions 2. The tool assesses the answers given and determines if a comprehensive resource management review is necessary.
- 25. Comprehensive Resource Management Review Cover the following areas; 1. Non- profit School Food Service Account- ensuring the SFA is maintaining and using its nonprofit food service account according to regulatory requirements 2. Paid Lunch Equity- Evaluate the prices the SFA charges for paid lunches in relation to the federal paid and free reimbursement rates. 3. Revenue from non- program foods- Assess whether the revenue from the sales of non program foods generate at least the same proportion of revenues as expenditures for the purchase of the non program foods. 4. Indirect Costs- evaluate the charges to the nonprofit school food service account including allowable direct and indirect costs.
- 27. General Program Compliance Civil Rights Local Wellness Policy Competitive Food Services Water Food Safety Reporting and Record Keeping SBP and SSO Outreach
- 28. Civil Rights “And Justice for All” posters are visible Determine if denied applications are disproportionately submitted by a protected group Documentation of civil rights training Program materials contain the proper non discrimination statement Observe the meal service to ensure all children are receiving benefits equally without discrimination
- 29. Civil Rights Policy The Civil Rights Policy is a policy that is specific to the food and nutrition programs at your school. 1. It should include a log of civil rights complaints by school year for the food programs 2. It should have a system set up for participants in these programs to lodge a civil rights complaint locally and it should explain what that process looks like at each phase of the process from start to finish. 3. Finally it should have a mechanism for the participants to file a complaint directly to the USDA, bypassing the local system entirely.
- 30. Food Safety Includes 1. Up to date food safety manual with an accurate table of contents 2. Food safety inspection documentation (2 per year) 3. Temperature and Sanitation Logs 4. Storage- proper storage techniques (FIFO) 5. Special Diet Accommodation form
- 31. Local School Wellness Policy The SFA must have a wellness policy and documentation of stakeholder input to the development, implementation and evaluation of the policy Documentation of public notification of updates to the policy Must be compliant with the State of Nevada School Wellness Policy Guidelines http://nutrition.nv.gov/Programs/Wellness/
- 32. Reporting and Recordkeeping This general area is evaluated to see if the SFA has maintained all of the required records for the required 3 years plus current year time frame. The documentation can include but is not limited to the following; 1. Agreements and free and reduced policy statements 2. Approved and denied free and reduced price meal applications 3. Claims for reimbursement and their supporting documentation 4. Documentation of edit checks 5. Menu and food production records
- 33. SBP and SFSP Outreach The SFA is required to inform eligible families of the availability of breakfasts offered under the School Breakfast Program (SBP). This is to verify that at the beginning of the year you send the initial notification and then in addition to see if you sent the required follow up notifications informing the families that school breakfast is offered.
- 35. Other Federal Programs These programs are assessed for compliance with their governing regulations 1. Afterschool Snack Program 2. Fresh Fruit and Vegetable Program 3. Special Milk Program
- 36. Fiscal Actions Fiscal Action is the recovery of overpayment through direct assessment or offset of future claims, disallowance of over claims as reflected in unpaid claims for reimbursement, submission of a revised claim for reimbursement, and correction of records to ensure that unfiled claims for reimbursement are corrected when filed. 1. Performance Standard 1 violations 2. Performance Standard 2 violations 3. Egregious or Recurring Infractions
- 37. Questions?
Editor's Notes
- Notice of Administrative Review Letter: It will request documentation and ask for times and dates to do an hour phone conference to go over the offsite assessment tool. The Resource Management Risk Assessment tool must be completed 4 weeks before the onsite review is conducted. If it is not, the Comprehensive Resource Management Review becomes mandatory.
- The Applications should be ordered in some reasonable system, alphabetical, or what have you. Site Level Staff during the onsite portion of the Administrative Review; We will be observing you as you run the lines, count and claim children at the POS, and portion and serve the food. We also will from time to time ask questions such as what is a reimbursable meal during this lunch service or for you to measure a serving of some item being served to ensure that it is the proper quantity for the age/grade group being served. We will be looking for you to put into action the policies and procedures that are created at the administrative level.
- The required information on the applications is dependent on the basis for applying; receipt of certain benefits, or household size, and income. Categorical Edibility: the assistance programs SNAP, TANF, FDPIR Name of the children for whom the application is made SNAP, TANF, or FDPIR case number for the children or for any adult household member listed on the application Signature of an adult household member Other Source Categorical Eligibility; migrant, runaway, homeless children Name of the children for whom the application is made Indication of the child’s categorical eligibility status Signature of adult household member The required supporting documentation is primarily for Homeless and Migrant children. This documentation should have the following information at the minimum: The Childs Name (or a list of names of participating children) Effective date(s) and the signature of the school districts homeless liaison or other appropriate officials.
- Electronic systems for counting and claiming are systems like Nutri- Kids. Paper rosters systems require us to take a closer look at the process as paper systems are more prone to errors.
- There should be a standardized recipe on site for every item that is served to children in these programs. When we are onsite we will review these at that time.
- Reimbursable meal at Breakfast Guidelines: 4 Items must be offered. The children may choose 3 and 1 of those chosen has to be the ½ cup of fruit/vegetables. For lunch 5 item must be offered and the children can
- The Comprehensive Resource Management Review is focused on the administrative level and may include Fiscal Staff from the school district.
- The approved Civil Rights Training can be found on the CNP website. You may also choose to use your own training program. IN these cases, you are required to provide copies of the training in addition to the other documentation covered under Civil Rights. Program Materials: Non Discrimination Statement, Information Letter/ Public Release
- The Civil Rights Policy is only specific to the National food program; NSLP, SBP, FFVP, SMP, After School Snack. It requires a log be kept even if you have not had any recent complaints. The log must be kept for each school year.
- There must be a food safety manual at each site.
- Best Practice: At the beginning of the school year, you inform the public of your participation in the SBP. Most do this through the public release or information letter. The Summer Food Program is done exactly opposite. At the end of the year you notify the public of your participation in this program. You would let them know where the sites are and any community partners you may be working with as well.
- After School Snack has federal requirements. The first is that there has to be an accurate counting and claiming system in place. Second the are specific snacks in specific quantities that may be served and finally there must be an education component. For the count system there has to be count sheets of some sort. You must have a published menu as well as keep production records for this. Finally this program must be monitored twice per year. The first time has to be within the first 4 weeks of the beginning of the program for that school year. The second time can be anytime before the end of that same school year. Fresh Fruit and Vegetable: all of the documentation to justify costs must be kept and will be reviewed if you offer this program. In addition, this program operates under the by American provision. Fruits that can be found domestically must be purchased domestically. If a domestic source cant be found then it can be bought internationally but the vendor must provide documentation supporting this. We will also be looking to see that it is offered to all students that are eligible. SMP- We look for a counting and claiming system and documentation supporting the monthly claims. This documentation includes, daily attendance sheets, count sheets for the peiod of review, and receipts from purchasing milk.
- Performance Standard 1 violations focus on counting systems and eligibility determinations. The basic counting system is that the child is counted at the POS when he has a reimbursable meal. If you do not have an accurate counting system in place it could trigger fiscal action or recoupment. If you have no applications or systems in place to make sure that the correct benefit level is being assigned to each child, it could trigger fiscal action or recoupment. Under Performance Standard 2 things like completely missing components or non compliance with the vegetable sub groups can cause fiscal action or recoupment.