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The new administrative review

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

Administrative review goals
Administrative Review Goals 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

  • 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

Revamped resources
Revamped Resources 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

  • New processes uses tools and forms designed to be:

    • Modular

    • Efficient

    • Flexible

    • Effective

    • Collaborative

Off site assessment tools
Off Site Assessment Tools 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

  • 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

Maximizing resources
Maximizing Resources 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

3 year review cycle
3 Year Review Cycle 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

  • 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

New administrative review areas
New Administrative Review Areas everything has changed.

Pre visit procedures
Pre-Visit Procedures everything has changed.

Notify Superintendent and Food Service Director

Initiate Off-site Assessment Tools

Review SFA Documentation

Obtain pre-visit information

Select NSLP sites for review

On site review procedures
On-Site Review Procedures everything has changed.

Entrance Conference

On-Site Review

Exit Conference

Entire school food authority
Entire School Food Authority everything has changed.

  • 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

Off site review phase
Off-Site Review Phase everything has changed.

  • 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

On site assessment phase
On-Site Assessment Phase everything has changed.

  • 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

If you have always done it that way, it is probably wrong. everything has changed.

  • Charles Kettering

Verification everything has changed.

  • 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 documents
Verification Review Documents everything has changed.

Verification review
Verification Review everything has changed.

Meal counting and claiming
Meal Counting and Claiming everything has changed.

  • 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 components and quantities
Meal Components and Quantities everything has changed.

  • 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

Milk requirements
Milk Requirements everything has changed.

  • At Least two varieties of fluid milk at breakfast and lunch

    • Fat Free, Flavored or unflavored

    • Low fat, unflavored

Vegetable subgroup requirements
Vegetable Subgroup Requirements everything has changed.

  • Schools must offer vegetables from five vegetable subgroups over the course of a week:

    • Dark Green

    • Red/Orange

    • Beans/peas

    • Starchy

    • Other

Whole grain rich requirements
Whole Grain-Rich Requirements everything has changed.

  • 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

Documentation review
Documentation Review everything has changed.

  • 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

Pre visit documentation review
Pre-Visit Documentation Review everything has changed.

  • 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

On site review
On-Site Review everything has changed.

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

Offer versus serve
Offer Versus Serve everything has changed.

  • 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 serve1
Offer versus Serve everything has changed.

  • 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

Ovs breakfast and lunch
OVS: Breakfast and Lunch everything has changed.

Dietary specifications
Dietary Specifications everything has changed.

  • 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

Technical assistance corrective action
Technical Assistance & Corrective Action everything has changed.

  • Possible Findings:

    • Missing Meal Components

    • Insufficient quantities of Fruits/Vegetables

    • Implementation

    • Staff Training

    • Signage

Review ffvp
Review FFVP everything has changed.

  • 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 afterschool snack program
Review Afterschool Snack Program everything has changed.

  • 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

Food safety
Food Safety everything has changed.

  • 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

Civil rights
Civil Rights everything has changed.

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

Local school wellness policy
Local School Wellness Policy everything has changed.

  • 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?

Resource management
Resource Management everything has changed.

Maintenance of the Nonprofit School Food Service Account

Indirect Costs

Paid Lunch Equity

Revenue from Non-Program Foods

USDA Foods

Maintenance of the nonprofit school food service account
Maintenance of the Nonprofit School Food Service Account everything has changed.

  • 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.

Review everything has changed.

  • 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

PLE everything has changed.

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.

Non program foods revenue
Non-Program Foods Revenue everything has changed.

  • 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 revenue1
Non-Program Foods Revenue everything has changed.

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

Adult meal prices
Adult Meal Prices everything has changed.

  • 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

Indirect costs
Indirect Costs everything has changed.

  • 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

Food service management company
Food Service Management Company everything has changed.

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

Corrective action
Corrective Action everything has changed.

Have at most 30 days to correct.

Some corrective action must occur immediately

Withholding payments
Withholding Payments everything has changed.

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)

When??? everything has changed.

  • 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

Fiscal action
Fiscal Action everything has changed.

Applications missing information

Miscategorization of Certification

Benefit Issuance Errors

Failure to update verified applications

Fiscal action1
Fiscal Action everything has changed.

  • 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

2013 14 sfa s to be reviewed
2013-14 SFA’s to be reviewed everything has changed.

Sugar Salem SD

Thank you
Thank you everything has changed.

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

- Margaret Mead