Administrative ReviewJUNE 2015

PRESENTER: EDWARD COLEMAN

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

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)

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)

Certification Worksheet

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

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

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.

Performance Standard 1

Meal Counting and Claiming

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.

Meal Access and Reimbursement

Certification and Benefit Issuance

Verification

Meal Counting and Claiming

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

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)

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

Performance Standard 2

Meal Pattern and Nutritional Quality

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.

Meal Pattern

Meal Components and Quantities

Offer vs. Serve

Dietary Specifications and Nutrient Analysis

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

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

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

Comprehensive Resource Management

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.

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.

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.

General Program Compliance

General Program Compliance

Civil Rights

Local Wellness Policy

Competitive Food Services

Water

Food Safety

Reporting and Record Keeping

SBP and SSO Outreach

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

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.

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

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/

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

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.

Other Federal Programs

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

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

Questions?