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New Administrative Review Process – What to Expect?. July 2013. Reinvention Goals. The Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process Consolidate the Administrative Review process

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Presentation Transcript
reinvention goals
Reinvention Goals
  • The Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process
    • Consolidate the Administrative Review process
    • Incorporate school breakfast, the new meal pattern, and dietary specifications, and the 6-cent performance-based reimbursement
    • Implement a 3-yr review cycle
    • Provide for offsite monitoring approaches
    • Provide effective training and ongoing technical assistance


revamped resources
Revamped Resources
  • New process uses tools and forms designed to be:
    • Modular
    • Efficient
    • Flexible
    • Effective
    • Collaborative


off site components
Off-Site Components
  • Advantages
    • Flexibility
    • Use of specialized staff
    • Reduced staff time
  • Off-site monitoring tools
    • Off-site Assessment Tool (SFA and SA)
    • Compliance Risk Assessment Tool (SA)
    • Dietary Specifications Assessment Tool (SA)
    • Resource Management Risk Indicator Tool (SA)


off site assessment tool
Off-Site Assessment Tool
  • Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit
  • Feedback from USDA testing:
    • Tool encourages SA and SFA to work collaboratively and helps shift the process toward the goal of combining compliance/monitoring with technical assistance
    • SFA has more time to provide information to the SA, and also will better understand why they are providing that information
    • SA has more time to review documents thoroughly, conduct reviews more consistently, and provide ongoing technical assistance to the SFA


off site monitoring tools
Off-Site Monitoring Tools
  • Meal Compliance Risk Assessment Tool
    • Targets error-prone areas of the new meal pattern
    • Determines which site is selected for an in-depth menu review
  • Dietary Specifications Assessment Tool
    • Assesses food service practices to determine risk for not meeting the Dietary Specifications
  • Resource Management Risk Indicator Tool
    • Identifies whether S


performance standards
Performance Standards
  • Critical Areas
    • Performance Standard 1
      • Certification and Benefit Issuance
      • Meal Counting and Claiming
    • Performance Standard 2
      • Meal Components & Quantities
  • General Areas
    • Resource Management
    • General Program Compliance
      • Verification


review period
Review Period
  • Most recent month claim submitted, must include > 10 operating days
  • Period of On-Site review
  • Special Circumstances
    • Reviews early in the school year
    • Year-round, multi-track & provision schools
    • May require FNS approval or special procedures


pre visit procedures
Pre-Visit Procedures
  • Notify superintendent and food service director
  • Initiate Off-Site Assessment Tool
  • Review SFA documentation
  • Obtain pre-visit information
  • Select NSLP sites for review


on site review procedures
On-site Review Procedures
  • Entrance Conference
  • On-site Review
  • Exit Conference


review frequency schedule
Review Frequency & Schedule
  • Review Frequency
    • SFA must be reviewed every 3 years
    • Cycle begins July 1, 2013
  • Review Schedule
    • SA discretion
    • Postponed reviews
    • Non-compliant SFAs


data for site selection
Data for Site Selection
  • Site name
  • Site type
  • Number of serving days
  • Number of eligible for free meals
  • Number of free meals claimed


minimum number of review sites
Minimum Number of Review Sites

Review all sites (except RCCI) with free ADP of 100 and free participation factor of ≥100%


criteria for additional sites
Criteria for Additional Sites
  • Additional NSLP sites:
    • Elementary sites with ≥ 100 free ADP and ≥ 97% free participation
    • Combination sites with ≥ 100 free ADP and ≥ 87% free participation
    • Secondary sites with ≥ 100 free ADP and ≥ 77% free participation
  • State Agency Criteria


additional site selection requirements
Additional Site Selection Requirements
  • Dietary Specifications and Nutrient Analysis
    • Meal Compliance Risk Assessment Tool
  • School Breakfast Program
    • 50% of select3ed NSLP sites
  • Other Federal Program Reviews
    • Varies based on regulations
  • Resource Management
    • Offsite Assessment Tool


access and reimbursement
Certification & Benefit Issuance


Meal Counting and Claiming

Access and Reimbursement


off site assessment
Off-site Assessment
  • Certification and Benefit Issuance
    • Question set 100s
  • Verification
    • Question set 200s
  • Meal Counting and Claiming
    • Question set 300s


on site assessment
On-site Assessment
  • Certification and Benefit Issuance
    • Validate SFA’s Procedures from off-site assessment tool
    • Validate Student Certifications: Validate Benefit Issuance Document
    • Review Denied Applications
  • Verification
    • Determine compliance with Verification requirements
  • Meal counting and Claiming
    • Validate off-site assessment tool
    • Validate the counting and claiming process
    • Record errors


fiscal action
Fiscal Action
  • Certification and Benefit Issuance. Why is Fiscal Action taken?
    • Applications missing information
    • Miscategorization of certification
    • Benefit Issuance Errors
    • Failure to update verified applications
  • Verification
    • No fiscal action taken
  • Meal Counting and Claiming
    • Innacurate meal counting or claiming
      • Counting errors include: meal counts to not equal number of meals served to eligible students, second meals were counted, meal counts exceed number of eligible students by category


meal pattern nutritional quality
Meal Components & Quantities

Offer vs. Serve

Dietary Specifications & Nutrient Analysis

Meal Pattern & Nutritional Quality


why do we review meal components quantities
Why do we review Meal Components & Quantities
  • Support Learning & Educational Achievement
    • Provide students with well-balanced meals
    • Combat childhood hunger
  • Nutrition Education
    • Teach students components of a well-balanced meal, variety
  • Stewardship of Federal $
    • Ensure that meals reimbursed with Federal $$ contain required components
  • 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 quantities
Meal Components & Quantities
  • Assess meal pattern compliance
    • Milk, Vegetable subgroups, whole grain rich requirements, etc
  • Review breakfast and lunch documentation for compliance
    • Menus/production records
    • Performance-based reimbursement documentation (USDA worksheets)
  • 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
  • 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 meal service observation
On-site Meal Service Observation
  • Prior to Meal Service
    • Will ensure all reimbursable meal lines offer all required components
    • Will observe meal preparation
  • During the Meal Service
    • Will observe % of meal service for each line
    • Will determine if meal contain components & quantities for age/grade group
    • Will ensure students have access to, and know how to select a reimbursable meal


offer vs serve
Offer vs. Serve

The CDE OSN 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; and
  • 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.


ovs pre visit documentation review
OVS: Pre-visit: Documentation Review
  • Review OVS Policy
  • Optional OVS Edit Check

Total # of Food Components or Food Items

Total # of Meals served


ovs on site prior to meal service
OVS: On-site: Prior to Meal Service

CDE OSN Determines whether:

  • Staff training has been conducted
  • Staff understands what constitutes a reimbursable meal;
  • Staff understands the number of required meal components/food items for a reimbursable meal;
  • Staff properly distinguish reimbursable meals from a la carte purchases; and,
  • Signage has been posted explaining OVS to students


ovs on site meal service observation
OVS: On-site: Meal Service Observation

CDE OSN Determines whether:

  • Meals selected by students contain a minimum of 3 food components (NSLP) or food items (SBP) as the students exit the meal service line;
  • Each reimbursable meal contains at least ½ cup of fruits or vegetables;
  • Food service staff are accurately judging quantities when the school utilizes service stations, theme bars, and/or self-serve bars;
  • Students understand OVS; and
  • Food service staff/cashiers understand OVS


dietary specifications nutrient analysis overview
Dietary Specifications & Nutrient Analysis - Overview
  • Determine if SFA is serving reimbursable meals according to Dietary Specifications
    • Calories
    • Saturated Fat
    • Sodium
    • Trans Fat
  • Determine if a one week weighted nutrient analysis is required for each USDA established age/grade group and menu type offered at a lunch and breakfast for one site in the SFA


resource management
Maintenance of the nonprofit school food service account

Revenue from non-program foods

Indirect costs

USDA Foods

Resource Management


off site assessment tool1
Off-site Assessment Tool

Resource Management: Question set 700s

  • Maintenance of Nonprofit School Food Service Account
    • Questions 702 – 706
  • Paid Lunch Equity (PLE)
    • Questions 707 – 710
  • Revenue from Non-program Foods
    • Questions 711 – 712
  • Indirect Costs
    • Questions713 – 714
  • USDA Foods
    • Questions 715 - 717
resource management risk indicator tool
Resource Management Risk Indicator Tool
  • State Agency conducts a risk assessment based on off-site assessment tool
  • 1-2 risk indicators  Technical Assistance and Corrective Action
  • 3 + risk indicators  USDA Comprehensive Review
    • All Resource Management monitoring areas
    • State agencies to consult with State USDA foods staff


general program compliance
Civil Rights

Local Wellness Policy

Food Safety

General Program Compliance


off site assessment tool section v
Off-site Assessment Tool: Section V
  • Civil Rights
    • Question set 800s
  • SFA On-site Monitoring
    • Question set 900s
  • Local School Wellness Policy
    • Question set 1000s
  • School Breakfast and Summer Food Service Program Outreach
    • Question set 1600s
food safety
Food Safety
  • General areas of review
    • Written food safety plan
    • Food safety inspections
    • Recordkeeping
    • Storage
  • State Agency to determine if regulatory requirements are being met
  • Corrective Action
    • Each area assessed at the site level
    • If all schools compliant, SFA compliant
    • Corrective action prescribed as necessary


local wellness policy
Local Wellness Policy
  • HHFKA added new provisions
    • Changed content requirements
    • Required certain actions
  • LWP portion of administrative review changed to address HHFKA and FNS Memo SP 42-2011
    • Deficiencies handled through TA only
      • No final rule
      • Limited implementation guidance
    • Assess progress and provide implementation suggestions
    • No LWP = Corrective Action
  • Complete Off-site Assessment tool questions


off site assessment tool section vi
Off-site Assessment Tool: Section VI
  • Other Federal Programs
    • Indication of any additional federal programs that will be examined during the review
      • Afterschool Snack Program
      • Seamless Summer Option
      • Fresh Fruit and Vegetable Program
      • Special Milk Program
ffvp review
FFVP Review
  • Three components to the FFVP review process
    • Establishing the FFVP review sample size (CDE)
    • Claim validation
      • One month’s claim is validated per site
      • Any month can be selected
      • Check status of administrative costs
    • FFVP meal service observation
      • Occurs at each FFVP site
  • Fiscal Action must be used to recover any payments in whole or in part, that is inconsistent with FFVP requirements


afterschool snack program evaluating compliance
Afterschool Snack Program: Evaluating Compliance
  • 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


post review procedures
Post Review Procedures
  • Administrative Review Exit Conference
  • Administrative Review Report (i.e., Notification Letter of Review Results
  • Documented Corrective Action