New Administrative Review Process – What to Expect?

1. New Administrative Review Process – What to Expect? July 2013

2. 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 2

3. Revamped Resources • New process uses tools and forms designed to be: • Modular • Efficient • Flexible • Effective • Collaborative 3

4. Maximizing Resources 4

5. The “New” Process 5

6. 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) 6

7. 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 7

8. 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 9

9. 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 10

10. 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 11

11. 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 12

12. On-site Review Procedures • Entrance Conference • On-site Review • Exit Conference 13

13. 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 14

14. Data for Site Selection • Site name • Site type • Number of serving days • Number of eligible for free meals • Number of free meals claimed 15

15. Minimum Number of Review Sites Review all sites (except RCCI) with free ADP of 100 and free participation factor of ≥100% 16

16. 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 17

17. 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 18

18. New Administrative Review Structure 19

19. Certification & Benefit Issuance Verification Meal Counting and Claiming Access and Reimbursement 20

20. Why Review? 21

21. Off-site Assessment • Certification and Benefit Issuance • Question set 100s • Verification • Question set 200s • Meal Counting and Claiming • Question set 300s 22

22. 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 23

23. 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 24

24. Meal Components & Quantities Offer vs. Serve Dietary Specifications & Nutrient Analysis Meal Pattern & Nutritional Quality 25

25. 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

26. Overview • 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 27

27. 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 28

28. 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 29

29. 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 30

30. 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. 31

31. OVS: Pre-visit: Documentation Review • Review OVS Policy • Optional OVS Edit Check Total # of Food Components or Food Items Total # of Meals served 32

32. 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 33

33. 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 34

34. 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 35

35. Maintenance of the nonprofit school food service account Revenue from non-program foods Indirect costs USDA Foods Resource Management 36

36. 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

37. 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 38

38. Civil Rights Local Wellness Policy Food Safety General Program Compliance 39

39. 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

40. 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 41

41. Civil Rights – Scope of Review 42

42. 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 43

43. Fresh Fruit and Vegetable Program Afterschool Snack Program General Program Reviews

44. 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

45. 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 46

46. 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 47

47. Post Review Activities 48

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