Child Nutrition Programs 101

1. Child Nutrition Programs 101 CSNA Fall Conference 2012

2. Objectives • To provide an overview of the Federal Child Nutrition Programs & their administration and structure • To create an understanding of what is expected of those operating the Child Nutrition Programs • To answer questions about the operation of the Child Nutrition Programs

3. USDAOrganizationalChart

4. President of the United States, Barack Obama Secretary of Agriculture, Thomas J. Vilsack Deputy Secretary Under Secretary for Natural Resources and Environment Six Directors, i.e. , Inspector General Under Secretary for Farm and Foreign Agricultural Services Under Secretary for Rural Development Under Secretary for Research, Education and Economics Under Secretary for Food Safety Under Secretary for Marketing and Regulatory Reforms Under Secretary for Food, Nutrition, and Consumer Services, Dr. Janey Thornton

5. FNS Regional Offices Mountain Plains Region MidwestRegion NortheastRegion WesternRegion Mid AtlanticRegion SoutheastRegion SouthwestRegion

6. Administrative Flow FNS Headquarters Alexandria, VA FNS Regions State Agencies School Food Authorities Schools

7. State of Colorado and School Nutrition Programs • Administered by Colorado Dept of Education (CDE) Office of School Nutrition (OSN) • CDE OSN administers school district and charter school SFAs and RCCIs • School Food Authority: a governing body responsible for one or more schools and has the legal authority to operate the Program

8. Office of School Nutrition (OSN) Provides oversight and management of Colorado School Nutrition Programs SUCH AS: • Pay reimbursement/manage claims • Provide technical assistance and training • Review the operation of all public school, charter school, and RCCI SFAs

9. School Nutrition Programs

10. Big Picture: How We Work

11. Regulatory Process

12. Regulatory Process • Regulations change because: • A law is passed amending the NSLA • Other updates - i.e., meal pattern changes • Proposed Rule - published for comments, not to be implemented • Evaluate comments - read/consider comments • Final or Interim Regulation – implemented (comments taken on Interim Regulation) • Notices – announce routine updates

13. 210The National School Lunch Program Regulations

14. http://www.fns.usda.gov/cnd/governance/regulations.htm

15. National School Lunch Program - Agreement

16. Non-profit Food Service MAINTAIN A NON-PROFIT SCHOOL FOOD SERVICE AND OBSERVE THE LIMITATIONS…ON FOOD SERVICE REVENUES IN SEC. 210.14(A) AND LIMITATIONS ON COMPETITIVE FOOD SERVICE AS SET FORTH IN 210.11(B) • Food Service Funds may be used only for program expenses or program improvements • Accounting procedures must accurately record all revenues and expenditures in the Child Nutrition Program (Fund 51)

17. Limit Cash Resources LIMIT NET CASH RESOURCES TO 3 MONTHS’ AVERAGE OPERATING EXPENSES, OR HIGHER IF APPROVED BY STATE • If over 3 months operating expenses: • Consider food quality • Other improvements • State can lower reimbursements

18. Financial Viability: Break Even

19. Paid Lunch Equity (PLE) • Sufficient funds must go to the food service account for paid lunches • Involves pricing of ala carte, adult meals, and paid student lunches • Compliant if current paid student lunch price is >$2.51 OR if nonfederal funds are provided • PLE Lunch Pricing Tool located at CDE Website

20. Non-Program Food Revenue • Percentage of revenues of non-program foods (a la cart, beverages, etc.) • Must be at least equal to the % of the cost of that food • Must stay in the non-profit food service account • Track non-program food revenue separately from all other revenue items

21. Procurement (Purchasing) ALL PURCHASES IN SCHOOL NUTRITION PROGRAMS MUST FOLLOW USDA REQUIREMENT FOR “FREE AND OPEN COMPETITION” • Small purchase procedures depend on the size of the purchase • Federal limit of $100,000 requires a formal bid process • District small purchase threshold requires formal bid process • Include a “Buy American” clause in all bids

22. Free or Reduced Price Lunches Serve lunches free or at a reduced price to all children who are determined eligible under 7 CFR 245 --determining eligibility for free and reduced price meals • This is to ensure that schools provide for children from qualifying households. • It also requires that the same meals be made available to all children.

23. Meal Service Serve lunches, during the lunch period, which meet the minimum requirements prescribed in § 210.10 • The lunch period is between 10:00 a.m. - 2:00 p.m. • § 210.10 describes the minimum nutrition requirements that must be met by the lunches

24. Point of Service Counts • Count meals where you can accurately determine: • If the meal meets nutritional requirements • The eligibility status of the child Count the number of free, reduced price, and paid reimbursable meals served to eligible children at the point of service, or through another system approved by the state

25. Nondiscrimination Comply with requirements of the Department’s regulations regarding nondiscrimination • 7 CFR parts 15, 15a and 15b • FNS 113 – 6 (replaced by FNS 113-1) • SFA will not discriminate on the basis of race, color, national origin, sex, age, or disability

26. Civil Rights Requirements • Public Release • “And Justice For All …” poster • Special Needs/ Special Diets • Annual training

27. Public Release • Required to submit to local media - but not required to pay • Prototype in the F&R Packet • Keep copies: where, when, and what is sent • Send to: • Community/grassroots organizations • Local employers reducing hours or planning layoffs, etc.

28. “And Justice for All” All schools must display the most current “And Justice for All” poster: • In each school • In a location that is easily visible to students and the public in the food service area

29. Special Dietary Needs Disability: Meal accommodations are required for children with disabilities at no additional charge when documented by a licensed physician Non-disability: Substitutions may be made but are not required for children who are medically certified as having a special medical or dietary need with a note on file from a recognized medical authority Information on CDE Nutrition Website

30. Civil Rights Training All staff involved in all levels of the administration of FNS programs must receive training in order to understand civil rights laws, regulations, procedures, and directives to assist them in performing good customer service and avoiding complaints. • Required annually for “front line” school staff and supervisors • Training will be verified during reviews • Questions should be directed to the CDE OSN

31. Overt Identification Make no discrimination against any child because of his or her eligibility for free or reduced price meals in accordance with the approved policy statement • SFA will not overtly identify students based upon their eligibility status

32. Food Distribution and Donated Goods Enter into an agreement to receive donated foods as required by 7 CFR 250 • Part 250 • Food Distribution Regulations Accept and use, as much as possible, foods donated by the Department • Encourage the domestic consumption of agricultural products Food Distribution Programs

33. Maintain Facilities • Maintain necessary facilities for storing, preparing, and serving food • Sec.210.13(c) • Ensures proper maintenance of facilities to safeguard against theft, spoilage, or other loss

34. Sanitation and Health • Maintain proper sanitation and health standards in conformance with all applicable state and local laws and regulations • Comply with the food safety inspection requirement of sec. 210.13(b); • Obtain two food safety inspections per year • Develop food safety program/HACCP

35. Retain Eligibility Records Retain each household’s application for free and reduced price meals • Keep applications & Direct Certification match reports for at least 3 years + current • Complete Direct Certification at least 3 times per school year • Distribute meal benefit applications • Notify parents of student eligibility • Conduct Verification

36. Make Records Available • Records are available for audit or review at a reasonable time and place Upon request, make all accounts and records pertaining to school food service available to the state and FNS Keep records for at least 3 years + current

37. Claim Reimbursement • SFA official takes responsibility for accurate claims Claim reimbursement at assigned rates. The SFA official signing the claim is responsible for review and analysis for accuracy. Failure may result in withholding, suspension, or termination

38. 210.8 Claims for Reimbursement • On-site visit - counting & claiming before Feb 1 (if more than 1 serving site in the SFA) • Claims review process • Edit checks: AF x the number eligible, F/R/P • Follow-up - fix the problems • Recordkeeping – keepclaims at least 3 years + current • File claims monthly

39. OSN Online Claim System - Applications • Each year before claims can be entered, the claim system must be set up by SFAs (site and sponsor applications and required forms) • Afterschool Care Snack Program - apply using the claim system • Special Milk Program - apply using the claim system • CDE OSN will approve the application packet once everything in the claim system is correct and the following have been completed: • Annual Free and Reduced Training • Direct Certification • Paid Lunch Equity Tool

40. OSN Online Claim System - Claims • Once the application packet is approved, claims can be entered on a site basis • Claim system is currently comprised of Lunch (including the PK-2 Reduced Lunch Program), Breakfast (including Start Smart), Afterschool Snack, & Special Milk • Claims are due 60 days after the end of the claim month • The OSN makes payments twice per month

41. OSN Online Claim System – Further Information • System will eventually also include Food Safety Inspection Reports, Certification, Fresh Fruit & Vegetable Program, Summer Food Service Program, Direct Certification, Verification, Administrative Reviews - for a "one-stop shop" for reporting to the OSN • Critical Information is posted at http://www.cde.state.co.us/cdenutritran/nutriprogramrenewal.htm • Link to claim system • Renewal Overview (for beginning of the year requirements) • Simplified Step-by-Step Instructions for Applying • How-to Steps to Upload Forms in the System • Steps for Revising Online Applications • Claiming Instructions For questions, please contact Jennifer at otey_j@cde.state.co.us

42. A Brief Overview of NSLP Nutrition Standards

43. Participating schools must follow the nutritional guidelines set forth by USDA Meals patterns follow the Dietary Guidelines for Americans Nutrition Standards

44. Food-Based Menu Planning 5components 1) Fruit 2) Vegetables 3) Grains 4) Meat/Meat Alternates (Protein) 5) Milk (Dairy)

45. Breakfast *Meal patterns changing for school year 2013 – 2014*

46. Offer at least one serving each Lunch

47. Competitive foods are those foods sold in competition with the reimbursable meal during lunch periods Part 210 prohibits the sale of Foods of Minimal Nutritional Value infood service areas during thelunch period Specific list of foods Found in Appendix Bof 7 CFR 210 Competitive Foods

48. Milk and Substitutes Non-disability: Milk substitutes (Ex: soy milk) may NOT be counted in a reimbursable meal if they do not meet the USDA Nutrient Standards, including fat content. SFA NOT required to provide for non-disability reasons Disability: Physician statement must identify substitution. SFA MUST provide substitute at no cost to the student.

49. OVS - General Rules • Students need to take at least 3 components • One must be ½ cup Fruit or Vegetable • Required in high school lunch • Optional K-8 • Optional for all grade levels for breakfast

50. Production Records • Required for program compliance • CDE reviews adequate food is prepared • Management tool • How much to plan? • What should staff prepare? How much? • Evaluation tool • Trends: Popular? Tried it 20x? Forget it? • Throwing away food and money?