The Administrative Review Process

1. The Administrative Review Process • Resource Management • General Program Compliance • Other Federal Programs • Post Review Procedures http://fns.dpi.wi.gov

2. Resource Management MAINTENANCE OF NON-PROFIT CHILD NUTRITION ACCOUNT PAID LUNCH EQUITY REVENUE FROM NON-PROGRAM FOODS INDIRECT COSTS USDA FOODS

3. Resource Management: 5 Areas 1. Maintenance of the non-profit Child Nutrition Account 2. Indirect Costs 3. Paid Lunch Equity 4. Revenue from Non-program Foods 5. USDA Foods

4. Resource Management Maintenance of the Non-Profit Child Nutrition Account

5. Important Facts • Non-profit status does not require that the SFA operate at a break-even or loss • The SA must ensure that SFAs observe the regulatory limitations on the use of non-profit Child Nutrition revenue • Identify revenue excess or shortfall

6. Components of the Non-Profit Child Nutrition Account • Net Cash Resources - Not to exceed 3 month’s operating expense - Surplus funds cannot be transferred from the non-profit food service account to support other operations - Adult meals may not be subsidized by non-profit funds • Allowable costs - For authorized purposes (food , labor, purchased services, equipment, supplies, etc.) - reasonable and necessary - appropriately allocated and documented - represent activity and function for operation of food service program

7. Classification of Food Service-Specific Allowable and Unallowable costs

8. Resource Management Paid Lunch Equity

9. Paid Lunch Equity Review • Included in the Healthy, Hunger-Free Kids Act (Section 205). • Intent of PLE: To ensure that SFAs charge paid lunch prices sufficient to cover the costs of paid meals or otherwise provide enough funds to support paid meal costs. • PLE tool is used (located on DPI website) fns.dpi.wi.gov/files/fns/xls/ple_tool_rev.xls

10. Paid Lunch Equity – Corrective Action Corrective action examples • Incorrect PLE Tool calculations • Utilizing unallowable non-Federal sources of revenue • SFA didn’t increase its paid lunch price(s), if required

11. Resource Management Revenue from Non-Program Foods

12. Revenue from Non-program Foods • “Non-program foods” - Foods and beverages sold in a participating school that are purchased using funds from the nonprofit Child Nutrition account. • Includes a la carte items, extra milk, adult meals, items purchased with nonprofit Child Nutrition account funds for vending machines, fundraisers, school stores and for catered and vended meals. • Adult meal prices should include the value of any USDA entitlement and bonus donated foods used to prepare the meal.

13. Resource Management Indirect Costs

14. Review of Indirect Cost • Ensure SFAs are correctly determining if their costs are allowable, allocable and appropriately charged as a direct cost. • Wisconsin does not allow the annual assigned indirect cost rate to be applied to Food Service (For public schools this is Fund 50)

15. Resource Management USDA Foods

16. Review of USDA Foods • USDA Foods requirements: Included under Section 14 of the NSLA, 7 CFR 210.14(d), 7 CFR 250, FD instructions/policy memoranda. • Monitoring intent: Ensure that SFAs have adequate policies and procedures in place to safeguard and fully utilize USDA foods.

17. Review of USDA Foods During the review, the State Agency will: • Determine sample size of records to review • Validate records to ensure rebates, discounts and credits are accounted for • Talk with SFA staff about its crediting process to assess its effectiveness • Review the SFA’s procurement of end products containing USDA foods • Ensure that SFA conducts an annual reconciliation

18. General Program Compliance Civil Rights On-site reviews Local wellness policy Competitive Foods Water Food safety SBO and SSO Outreach Procurement

19. General Program Compliance Civil rights

20. CIVIL RIGHTS Protected categories for Child Nutrition Programs are race, color, national origin, age, sex, or disability.

21. Civil Rights All Children must receive equal benefits without discrimination at each school during each meal service Supporting Documentation • Program materials must contain the correct non-discrimination statement – reviewed on next slide • Public Release • Civil Rights complaint procedures • Annual Civil Rights training for staff • Racial/Ethnic data collection (Form PI-1441) • Special Dietary Needs procedures • And Justice for All posters displayed

22. USDA Non-discrimination Statement The U.S Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department.  (Not all prohibited bases will apply to all programs and/or employment activities.) If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish). USDA is an equal opportunity provider and employer

23. Civil Rights Compliance Worksheet Civil Rights Self Evaluation Worksheet -Form Pl-1441 - which collects racial or ethic datais required to be: • Completed for each school site in the SFA • Kept on file at Central Office • Complete by October 31st each year (dpi.wi.gov/files/forms/doc/f1441.doc)

24. General Program Compliance SFA On-Site Review and Self Assessment

25. SFA On-Site Review/Self Assessment All SFAs are required to monitor their CN programs if they have more than one school building • SFAs must conduct an annual On-Site monitoring review for every approved Child Nutrition site, no later than February 1stof the current school year. To determine if monitoring was conducted by SFA, SA will request: • Copy of the SFA’s On-Site Review or Self Assessments • Written documentation of follow-up SFA reviews • Written documentation to verify Corrective Action has occurred for any findings in the initial SFA review

26. General Program Compliance Local Wellness Policy

27. Local Wellness Policy • Each SFA participating in the National School Lunch Program and School Breakfast Program must establish a LWP • SFAs determine the specific policies appropriate for the schools under their jurisdiction provided that those policies address all the required elements specified in the HHFKA • SA will review for content only not quality

28. LWP Assessment Must include, at a minimum: • Goals for nutrition education, physical activity, promotion of the policy, and other school based activities that promote student wellness • Nutrition guidelines to promote student health and reduce childhood obesity • Team to develop wellness policy must include: - Parents, students, representatives of the SFA, school board, school administrators, the publicPhysical education teachers, and school health professionals -collaborate beyond the development of LWP to include the implementation with periodic review and updates

29. General Program Compliance Competitive Foods

30. Competitive Foods Foods sold or offered to students in competition with the CN Program… Includes: • A la Carte items • Vending machines • School Stores • Fund-raisers • Student sales • Other food or beverage sales or activities

31. Competitive Foods School districts that participate in the NSLP and SBP: • SFAs must PROHIBIT the sale of foods or beverages of minimal nutritional value, i.e. soft drinks, gum and hard candies during designated meal periods.

32. Competitive Foods The review of Competitive Foods will determine: • If food/beverage sales that are occurring during the school day are conducted by the CN program, and; • If all monies collected from the sale of such foods/beverages are returned to the non-profit Child Nutrition program, and; • If Foods of Minimal Nutritional Value are being sold by the CN program.

33. General Program Compliance Water

34. Water Availability During School Lunch • Schools participating in NSLP and SBP if breakfast is served in the cafeteria • Potable water available to all students at no charge • In the area where meals are served during meal service • Must be available without restriction in all locations where meals are served • Is not considered a part of reimbursable meal (please refer to interim final rule 78 CFR 39068)

35. General Program Compliance Food Safety & HACCP

36. Food Safety Review Includes: Written food safety (HACCP) plan, food safety inspections, recordkeeping, and storage practices • Written food safety (HACCP) plan and forms must be in place and accessible and must cover all facilities that store, prepare or serve food for FNS programs. (HACCP Plan templates and checklists are available on DPI website) • Two food safety inspections per school year with most recent posted in a publicly visible location • Each area is assessed at the site level (please refer to memo SP-37-2013 for more information on HACCP as it relates to HHFKA)

37. General Program Compliance SBP Outreach

38. SBP Outreach Requirements Schools mustinform eligible families of the availability of reimbursable Breakfast in SBP and send reminders multiple times throughout the SY • SFAs must inform families of the availability of SBP just prior to or at the beginning of the SY in F/RP packets. (Refer to Memo SP40-2011) • SFAs may provide reminders through public address system, developing or disseminating printed or electronic material. (For example info could be posted on school’s website). • Document Outreach activities

39. General Program Compliance Procurement

40. Competition Full,Free and Open Competition is required for ALLpurchases made with Child Nutrition funds…

41. Procurement Methods Purchasing Threshold: • Formal (Large Purchases) • $150,000 – Federal • Local Thresholds • Informal (Small Purchases)

42. Procurement Methods • Request for Quote (RFQ) also known as an informal request for prices or small purchase • Invitation for Bid (IFB) also known as formal competitive sealed bid • Request for Proposal (RFP) also known as formal competitive negotiation • Non-Competitive Negotiation may be formal or informal

43. Bid Specifications • Clearly written, detailed product specifications (approved brand or equal) • Quantity • Quality • Packaging • Pricing (unit and extended) • Substitutions and/or derivations

44. Procurement – Corrective Action • Procurement activities are assessed primarily at the SFA level for compliance • Improper or unallowable expenditures will require a Corrective Action Plan (for more information on procurement go to: http://dpi.wi.gov/files/sped/pdf/grt-disc-procurement-guide.pdf)

45. Other Federal Program Reviews After school snack program Fresh Fruit & vegetable program

46. Evaluating ASSP Compliance • SFA retains final administrative and management responsibility for all ASSP requirements. • Assess compliance in the following areas: • Eligibility • Accountability/Meal Counting and Claiming • Meal Pattern/Production Records • Monitoring • General Areas • Self-Reviews Completed? 1st – during first 4 weeks of operation 2nd – prior to end of SY

47. Review of Snack Service • Reimbursable Snack contains Required Components and Adequate Serving Size • Only One Snack per Child is Claimed • Snacks are Served at the Appropriate Time • Counting/Claiming is accurate

48. What does an FFVP review include? • Three components to the FFVP review process • Review of a pre-established number of FFVP sites • Claim validation • FFVP meal service observation

49. FFVP Claim Validation • One month’s claim is validated per site • Any month can be selected • Check status of administrative costs • Costs claimed for reimbursement vs. site’s cost documentation • Invoices, timesheets, purchase orders, etc. • Observations measured to ensure FFVP funds used for allowable purposes • Fiscal Action MUST be used to recover any payment in whole or in part, that is inconsistent with FFVP requirements.

50. Post Review