370 likes | 381 Views
The New Administrative Review Process for Child Nutrition Progr ams. Detailed information for each area covered in this review may be found on the DPI website at http://fns.dpi.wi.gov/. The New AR: Performance Standards. Critical Areas Performance Standard 1 Performance Standard 2
E N D
The New Administrative Review Process for Child Nutrition Programs Detailed information for each area covered in this review may be found on the DPI website at http://fns.dpi.wi.gov/
The New AR: Performance Standards • Critical Areas • Performance Standard 1 • Performance Standard 2 • General Areas • Resource Management • General Program Compliance Regulatory Authority for the Administrative Review can be found in 7CFR 210, 220 and 245, The Richard B. Russell National School Lunch Act, the Child Nutrition Act of 1966, Section 201 of the Healthy, Hunger-Free Kids Act of 2010 and Public Law 11-296.
Review Period • Most recent month for which a claim was submitted • Must include >10 operating days • Special Circumstances • Reviews early in school year • Year round, multi-track, & provision schools • May require approval or special procedures
Review Frequency & Schedule • Review Frequency • SFA must be reviewed every 3 years • Cycle begins July 1, 2013 • AR Schedule for 2013-14 SY • Schools scheduled in 2012-13 will be reviewed in 13/14 CESA 2 , CESA 8, and Lower half of CESA 4 • Schools that did not certify in 2012-13 will be subject to review in 2013-14 • A list of SFAs that will be reviewed in 2013-14 can be found on the DPI website at http://fns.dpi.wi.gov/fns_ar
School Site Selection • If more than one school is listed on Schedule A of your on-line contract, you will need to complete a site selection form • Complete the form using claim information for the month of October 2013 > School Name > Number of serving days > Number of free eligible > Number of free lunches claimed
Minimum Number of Review Sites Review all sites (except RCCI) with free ADP of 100 students and free participation factor of > 100%. All meal patterns must be represented for schools which are NOT $.06 Certified
Access and Reimbursement Benefit issuance Eligibility determination Direct certification Verification Meal Counting & claiming
Access and Reimbursement School Food Authority (SFA) • Certification of Eligibility • Benefit Issuance • Eligibility Determination • Direct Certification • Verification • Meal Counting and Claiming • Site-level Review • SFA-level Review
Access and Reimbursement CERTIFICATION AND BENEFIT ISSUANCE
Eligibility and Benefit Issuance Information requested: • How student was certified for benefits • Who is Hearing Official • Back-up system • School Calendar for school start date and approval timelines • F/RP meal application materials sent to household • How is Direct Certification conducted http://fns.dpi.wi.gov/fns_fincou1#manual
Direct Certification (DC) • Name(s) of the individual(s) responsible for processing the DC listings and issuing benefits to eligible students. • A copy of the letter used by the SFA to notify households of their direct certification eligibility. • A description of the SFA’s procedures for extending DC eligibility to all children in the Foodshare or W-2 household
Eligibility • Other items that will be assessed: • Conversion factors and income guidelines • How SFA handles carryover of previous school year’s eligibility (up to 30 Operating Days) • Length of time for application approval • How SFA updates eligibility changes • Method used to notify households of student’s eligibility determination • Who has access to benefits issuance documents • Applications include all required elements
Benefit Issuance F/RP meal applications to be reviewed • All applications in SFA (must be reviewed if less than 100 students certified for F/RP meal benefits) • Statistical Sampling for SFAs with 100 or more students certified for F/RP meal benefits • SFA-wide Benefit Issuance List requirements: • Name/Benefit Status for all F/RP eligible students • Generated from Point of Service used in each school • No Duplicate Names • School Name, Certification Method, Certification Date, Total number of eligible students • Do Not Group by Free and Reduced eligibility status • May be any day during the review period
Reviewing Denied Applications • Review minimum of 10 denied applications • Notification of denial • Reason • Appeal Rights and Instructions • Family may reapply
Common Findings • Reimbursement claimed for student meals when no approved application is on file • F/R apps not processed within 10 operating days of receipt • Data entry error results in incorrect eligibility status • Income Application missing required information • Incorrect number recorded as case number • SFA did not use Direct Certification for students who receive Foodshare or W-2. • One student is receiving free DC benefits but siblings are not • Confidential eligibility information is released for unauthorized purposes or without prior consent • Student eligibility status is not updated in (POS) or roster
Corrective Action • Required for Findings/Errors • Must be applied SFA-system wide • Formal response required from SFA
Fiscal Action • Reasons Fiscal Action is taken? • Applications missing information • Incorrect categorization of eligibility • Benefit Issuance Errors • Failure to update verified applications • How far back is fiscal action taken? • Can be back to the original date of eligibility
Access and Reimbursement VERIFICATION
Verification Verification Collection Report (FNS 742 Report) Questions • Accuracy of Verification: • Sample Size • Reporting fns.dpi.wi.gov/files/fns/pdf/gm_sp_38_2013
Verification • Verification Official and Confirming Official • Description of SFA Verification Process • Participation in Training • Electronic System
Determining Compliance Verification Requirements • Number of Verified Applications • Calculated Correct Sample Size • Verified Correct Number of Applications for Sample Size • If applicable, replaced applications accurately • Notification letters meet FNS requirements • Household follow-up attempts were made • Notice of adverse action met FNS requirements • Timeliness of eligibility status changes • Completed the verification process by November 15
Common Verification Errors • Verification process did not begin on October 1 • Verification process did not end by November 15 • Verification did not take place at all • Verification Collection Report not submitted by February 1 • An application was pulled for Direct Cert. student • SFA uses an incorrect verification method. • The sample pool does not round up • No follow-up attempt to collect verification information • Follow-up attempt not documented • No replacement application selected for withdrawn student • The software not updated
Access and Reimbursement Meal Counting & Claiming
Counting, Claiming, and reimbursement • Meal counting and claiming system accurate by category • Meals counted, consolidated, and recorded correctly • Accuracy of meals claimed and reported for reimbursement
Meal Counting and Claiming • Electronic vs. Manual • Standard Counting Procedures • Point of Service • Back-up System • Training
Meal Counting and Claiming • Provide an accurate count taken at the point of service daily • number of reimbursable meals served • by category • without overt identification
Meal Counting and Claiming Complete edit checks for potential over-claims • Federally required • Conducted on a daily basis at the school/site level • Conducted on a monthly basis at the SFA level • Resolve discrepancies before filing claim for reimbursement
Validating Counting & Claiming Meal Counting and Claiming Site Level • Prevention of Overt Identification • Accurate Count by Category • Overrides • Validate the meal count by type • Fiscal Action
Meal Counting and Claiming SiteLevel • Meal count comparison to review period • Meal count comparison to free and reduced-price students • Meal count comparison to attendance adjusted eligible • School meal counts vs. SFA claim for reimbursement
Common Findings • Each service line does not provide an accurate count by eligibility category at the Point of Sale (POS). • Meal counts incorrectly consolidated or not done daily. • There are questionable patterns in the meal counts. • Effective edit checks are not conducted as federally required.
Errors Systemic Non-Systemic
Meal Counting and Claiming Errors Systemic Non-Systemic • Errors will result in fiscal action • CA is required • Follow up from SA may be required for the CAP • Errors may result in fiscal action • CA may be required
Fiscal Action Errors • Meal Count Combining Errors • Fiscal Action for difference between incorrect and correct meals • Counting Errors • Meal counts do not equal number of meals served to eligible students • Meal counts exceed number of eligible students by category • Second and/or ineligible meals were counted
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