Coordinated Review Effort (CRE) 2014-15

1. Coordinated Review Effort (CRE) 2014-15 Distance Learning October 2, 2014 Karen Franklin, SNS

2. Before we get started on CRE… • USDA revised the Eligibility Manual for School Meals – FIN-15-020 • Flexibility in Determination Dates – if the SFA is using the flexibility in determination dates as discussed in the August distance learning and in the above memo • SFA MUST complete and submit the form • MUST apply the date of application as the determination date for ALL if using this flexibility

4. CRE 2014-15 • 88 school district reviews planned • 119 schools within those districts being reviewed • Review and observe both breakfast and lunch • Weighted Nutrient Analysis for BOTH breakfast and lunch will be for the week of the review (not previous week)

5. Announcement Letter • Mailed to superintendent and copied to the child nutrition director • Sent at least 30 days prior to the review dates • Includes list of items needed for review • Includes list of items needed for weighted nutrient analysis

6. AnnouncementLetter • Includes instructions for information needed to be sent to the area specialist along with the date the information is due • Please pay attention to these dates and send the information required by the due date • If cannot send the information by the due date contact your Area Specialist

7. Prior to Review School District Website • Child Nutrition Information on website? • Menus posted? • Do they include non-discrimination (shortened) • USDA non-discrimination statement posted? • Charge policy? • Student handbook information about child nutrition

8. Prior to Review • Area Specialist will review the most recent audit posted on Arkansas Legislative Audits website – if any CN findings will follow up as part of review • Findings from last CRE/Nutrient Analysis • Findings letter from ADE/CNU • Corrective Action Plan from SFA

9. Prior to Review • Financials: • Claims issues • Claims filed on time • Claims accurate when filed • Year to Date Financial Statement • Average Daily Participation in breakfast and lunch • Loans to program vs loan repayments • Financial standing at end of last SY (in red or black) • % of expenses on food/labor/other

10. Prior to Review • Renewal Agreement • Schedule A accurate • Meal Count and Collection Report accurate • CN contact – are determining officials, etc. accurate • Paid Lunch Equity • Documentation • Meet USDA requirements • Paid lunch prices submitted to SA accurate • If using non-federal funds is there an audit trail

11. Prior to Review – Send to Area Specialist • Completed Claim for Reimbursement • Daily records (or other POS report) for each school for all meals • Number of F/R eligibles • Number of F/R/P meals served each day of month • Number of adult meals served each day of month • Edit Check 1 – no days where more meals were served in a category than students eligible in that category

12. Prior to Review • Based on the documentation sent to Area Specialist • Confirm daily records added correctly • Confirm Edit Check 1 met • Confirm # meals claimed match daily records • Confirm consolidation of daily records = number meals claimed in each category

13. Prior to Review • Anything “jumps out” as questionable. For example: • ADA and ADM not completed for Pre-K and daily records indicate Pre-K meals claimed • Nothing listed for unpaid bills, ending inventory and/or funds due to program • Adult meals served are questionable (serving 30 free adults per day when have 5 adults on CN staff)

14. Prior to Review • Are there ‘patterns’ to number of meals being claimed; for ex: exact same number for both breakfast and lunch meals each day • Are the numbers reported as F/R eligible close to the numbers reported as eligible for the Cycle 2 report (won’t be equal, but will be close)

15. Prior to Review • You may get a call or an email from your Area Specialist after they receive the claim form and the daily records • Please get the information they are requesting to them as soon as possible

16. Prior to Review • After the Area Specialist receives the daily records and claim form, then the “site selection” can be made • Probably will not tell the SFA which schools have been selected prior to the Entrance Conference • Site Selection based on USDA criteria

17. Site Selection Criteria • USDA Criteria for site selection for review is based on the average number of free eligible students that each lunch each day. • Different percentage criteria for different grade groups

18. Site Selection Criteria For ex: School XYZ Elem (K-5) has 200 free eligible students, 20 serving days and served 3800 free lunches during the month of review • 200 (Free elig) x 20 (# serving days) = 4000 possible free meals if every free student ate lunch every day • 3800 (actual free meals served) / 4000 (possible free meals served) = .95 or 95% of free students ate each day • Formula = Total free lunches served divided by (Free Elig x number serving days) gives percentage of free eligibles eating per day

19. Site Selection Criteria • Elementary schools (defined as grades K-8 by USDA) that have 97% of the free eligible students eating lunch each day • Secondary schools (defined as grades 9-12 by USDA) that have 77% of the free eligible students eating lunch each day • Combination schools (any combination of K-8 with 9-12) that have 87% of the free eligible students eating lunch each day • Many ‘high schools’ in Arkansas are 7-12 schools which would be considered a combination school by USDA regulations

20. Site Selection Criteria State Review Criteria • Low participation schools • Provision 2 base year • Community Eligibility first year • Findings from previous reviews, on-site visits or claims review process • Daily meal counts appear questionable • Identical or similar claiming patterns • Large changes in free meal counts • Manager or school never reviewed by state • New or unusual accountability system • Director or Superintendent request

21. Entrance Conference Time and location set prior to arrival on-site to include: • State Agency personnel • Superintendent • Child Nutrition Director • Other personnel as determined to be needed by the superintendent or child nutrition director (for example: determining officials, verifying officials)

22. Entrance Conference • Purpose of the review • Description of the review process and scope of review • Procedures for findings communications during the review (including technical assistance and corrective action) • Set date and time of exit conference

23. Review Location(Place to Work) • State Agency personnel need: • Private place to work – confidential information • Close to or easy access to determining official and all eligibility determination documents • Table space to spread out and work

24. CRE 2014-15 While the CRE covers many, many aspects of the child nutrition program there are two areas that can cause fiscal action (meaning money would have to be returned )

25. CRE 2014-15 Fiscal Action PS 1 • Certification (benefit issuance documentation and approval) • Issuing benefits (rosters, class lists, checklists, tickets) • Meal counts and claiming (how point of sale counts are determined and consolidated) Fiscal Action PS 2 • Meal component errors – not meeting meal pattern for all reimbursable meals

26. Performance Standard 1 (PS1) • Certification/Counting/Claiming – All free, reduced price and paid breakfasts and lunches claimed for reimbursement are served only to children eligible for free, reduced price and paid meals, respectively; and counted, recorded, consolidated and reported through a system which consistently yields correct claims.

27. Performance Standard 1 (PS1) • Every student receiving free or reduced meals must have a source document (application, name on DC list, student living in HH on DC list with audit trail, etc.) • Count by category at point of service must be accurate • Consolidation of meal counts for claims must be accurate

28. Performance Standard 2 (PS2) • Components – Breakfasts and Lunches claimed for reimbursement contain food items/components as required by program regulations. • Offer vs. Serve • Properly implemented • Correct signage • Cashiers and staff recognize reimbursable breakfast and lunch meals

29. Performance Standard 2 (PS2) • Every meal claimed must meet all meal pattern requirements and have appropriate documentation • Components (meat/meat alternate, red/orange vegetable, etc.) • Contributions (how the item served contributes to meal pattern) • Dietary specifications (calories, saturated fat, trans fat, etc.)

30. Review Period The Review Period is the month of the most recent claim for reimbursement that has been filed with state agency (must be at least 10 serving days on the claim) For example: • CRE Visit is November 18-20; • review period will be October (most recent claim submitted to ADE); • Daily Records/monthly reports will be for October meals claimed • CRE Visit is December 3-5; • review period will be November if November claim is filed – will be October if November claim is not filed yet

31. Claim for Reimbursement • We must confirm ALL ASPECTS of the claim – source documents for everything on the claim form • Revenues (federal, student, adult, a la carte, contract income, loans to programs, etc.) • Expenses (food, labor, other, loan repayments) • Eligibles (number of free and reduced eligible at each school) • Meals claimed by type and category (breakfast, lunch; free, reduced, paid) • Unpaid bills, funds due to program, etc. • Inventory

32. Claim for Reimbursement • Make sure you have the correct APSCN reports to back up all the financial information on the claim form. • This is not a piece of scratch paper!! • Prior to submitting the Claim for Reimbursement, please READ the Instructions for how to complete the Claim for Reimbursement (on our forms page) • Even if you have completed the claim for years • Especially if you are new to the claim process

33. Source Documents/Rosters • Source Documents • Approved F/R meal application • Student name on direct certification list • Student name listed as “other students in household with direct certification students” (list, on duplicate app, etc.)

34. Source Documents • Direct Certification • Portal accessed by SFA • DC Letters sent to HHs • Perform all DC matches during school year (Arkansas did four matches last year – will do four matches this year also) • Extended DC categorical eligibility to all students living in the same household with students on DC list • Audit trail to find those “other students in HH”

35. Source Documents • Income applications • All persons listed in Part 1 are also listed in Part 3 of application • All persons listed on application have an income listed or an indication of “no income” – this includes students! • Signed by adult HH member • Includes last four digits of SS# or indication of no SS# • Eligibility determination made correctly (math) • Signed or initialed and dated by Determining official

36. Source Documents • Incomplete applications: remember that any application that does not have all the required information is considered incomplete and cannot be approved. If cannot get information from household then the application must be denied for being incomplete and the students are paid.

37. Source Documents • Supplemental Nutrition Assistance Program (SNAP) applications • Correct SNAP number or SNAP identifier • Not the 16 digit EBT card number • Application signed by adult HH member • All students determined free • No need to have part 3 of application completed • Signed or initialed and dated by Determining official

38. Source Documents/Rosters • Student name on other source categorically eligible lists (signed and dated) • Homeless • Migrant • Runaway • Head Start • Even Start • Foster

39. Source Documents/Lists • The categorically eligible lists must include: • Students names • Date of the list • Signature of the person responsible for the list as designated on the Renewal Agreement on the CN Contact Page (for example: homeless liaison)

40. Source Documents/Rosters • Reminder: Foreign Exchange Students eligibility is based on the household they reside with; they are not considered homeless; they are not automatically eligible – must have an application or source document for them to receive free or reduced price meals.

41. Source Documents • Free & Reduced Price Meal Eligibility Process • All four pages of application provided to HHs • Source documentation • Applications correctly determined • Direct Certification • Other Categorical Lists

42. Source Documents/Rosters • Point of Service (POS) Roster • e-School Plus Roster with meal benefit status • Child Nutrition Master Roster with meal benefit status (if different from POS Roster)

43. Source Documents • Any student listed as F/R must have source document • All rosters must match eligibility status for each student’s source document • Eligibility determination must be same on all rosters • 100% of students on rosters for the schools reviewed will have source document review

44. Scope of Review • Edit Check 2 • Attendance Adjusted Eligibles comparison to number of meals served daily • Form on the forms page of our website • Must be done BY SCHOOL for EACH MONTH • Are they any days that more F/R meals were served than F/R attendance adjusted eligibles indicate? If so, must have notations as to why this happened

45. Scope of Review • Verification (most recent) • Narrative Description of Verification selection and follow up activities • Verification Collection Report • Verification documentation – • copies of verification documentation (pay stubs, etc.) • letters to HH • status change completions • COMPLETED Verification Tracker form for each application verified

46. Scope of Review • Example of Verification Narrative: On October 1, 2014 there were 298 approved meal applications. 3% of 298 = 8.94 or 9 applications. All 298 approved applications were placed face down on table and CN Secretary randomly chose 9 applications. Confirmation official confirmed the 9 apps were approved correctly. First letters of notification were sent to HH on October 2nd.

47. Scope of Review • Verification • Correct number verified (3%, no more, no less) • Sample pool correctly identified (approved income apps, error prone, SNAP apps, etc.) • Verified applications chosen correctly • Confirmation review of all applications chosen for verification – documented!

48. Scope of Review • Verification • Correct documentation from households • Read the letters sent to HH regarding verification • Only accept documentation that is part of the “acceptable documentation list” • Bank statements are not acceptable documentation of anything involving verification • Must keep copies of verification documentation from households (legislative audit also looks at these)

49. Scope of Review • Verification • Did SFA make correct determination based on documentation submitted by HH • Keep good notes as to determinations were made • Math records • Discussions with HH members

50. Scope of Review • Verification • Changes in eligibility correctly documented and completed • All verification activities completed November 15 • Considered complete when letter is sent to HH indicating change in status or that there is no change in status • Verification summary report submitted to ADE by December 15