The NEW Administrative Review

1. The NEW Administrative Review This institution is an equal opportunity provider

2. It takes a lot of courage to release the familiar and seemingly secure, to embrace the new. But there is no real security in what is no longer meaningful. There is more security in the adventurous and exciting, for in movement there is life, and in change there is power - Alan Cohen

3. Administrative Review Goals • The Healthy, Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process: • Consolidate the Administrative Review Processes • Incorporate school breakfast, the new meal pattern and dietary specification, and the 6-cent performance based reimbursement • Implement a 3-year review cycle • Provide for offsite monitoring approaches • Provide effective training and ongoing technical assistance

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

5. Off Site Assessment Tools • Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit • Additional Off-Site Monitoring Tools Include: • Meal Compliance Risk Assessment Tool • Dietary Specifications Assessment Tool • Resource Management Risk Indicator Tool

6. Maximizing Resources

7. 3 Year Review Cycle • Review Period • Most recent month claim submitted, Must include 10 or more operating days • 2013 Reviews • Postponed Reviews from 2012 • Those schools not 6 Cents Certified • Special circumstances • Reviews early in school year • Year round, multi-track, and Provision schools

8. Just because everything is different doesn’t mean that everything has changed. • Irene Peter

9. New Administrative Review Areas

10. Pre-Visit Procedures Notify Superintendent and Food Service Director Initiate Off-site Assessment Tools Review SFA Documentation Obtain pre-visit information Select NSLP sites for review

11. On-Site Review Procedures Entrance Conference On-Site Review Exit Conference

12. Entire School Food Authority • Certification • Household Applications and Direct Certification • 7 CFR 245.6 for process • Benefit Issuance • Roster and Medium of Exchange • 7 CFR 210.7 (c)(1)(ii); 245.6 (a)(4); 245.6 (c)(3)(iii); 245.6 (c)(6)(iii) • Verification • Meal Counting and Claiming • School level review

13. Off-Site Review Phase • Complete Off-Site Assessment Tool • Step 1: Obtain Benefit Issuance Document • Must always use the list used by the Point of Service • Must be a day during the review period • Step 2: Select Student Certifications for Review • Step 3: Obtain Certification Documents

14. Step 2: Selecting Student Certifications for Review

15. On-Site Assessment Phase • Step 1: Validate SFA’s procedures as described on the Off-Site Assessment Tool • Step 2: Validate Student Certifications • Examine Household Application OR find student on DC List • Step 3: Validate Benefit Issuance Document • Make sure no Overt Identification • Validate POS • Step 4: Review Denied Applications • Reviewed at least 10 denied applications

16. If you have always done it that way, it is probably wrong. • Charles Kettering

17. Verification • Accuracy of Verification • Applications Verified correctly • Sample Size determined correctly • Confirmation reviews done as necessary • Direct Verification done properly • Letter sent to household met FNS requirements • Correct documentation received from family and determined correctly • Notice of adverse action met FNS requirements

18. Verification Review Documents

19. Verification Review

20. Meal Counting and Claiming • Validate Off-Site Assessment Tool • Validate the Counting and Claiming Process • Electronic versus Manual • Prevention of Overt Identification • Point of Service • Alternative Points of Service • Back-up System • Training • Consolidation and Reimbursement • Record Errors

21. Meal Components and Quantities • 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

23. Milk Requirements • At Least two varieties of fluid milk at breakfast and lunch • Fat Free, Flavored or unflavored • Low fat, unflavored

24. Vegetable Subgroup Requirements • Schools must offer vegetables from five vegetable subgroups over the course of a week: • Dark Green • Red/Orange • Beans/peas • Starchy • Other

25. Whole Grain-Rich Requirements • Starting July 1, 2013 in NSLP and SBP • ½ grains offered over the week must be whole grain-rich • Starting July 1, 2014 • All grains offered over the week must be whole grain-rich

26. Documentation Review • Review breakfast and lunch documentation to assess meal pattern compliance • Menus/production records • 6 Cents reimbursement documentation • Week must be 3-7 consecutive days • Missing meal components/insufficient quantities: expand documentation review to (at least) entire review period

27. 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

28. On-Site Review Ensure all reimbursable meal lines offer all required components Make sure standardized recipes are used and followed Ensure students have access to, and know how to select a reimbursable meal Ensure there is a milk variety available to all students “Like” substitutions strongly encouraged

29. Offer Versus Serve • The State agency 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; • 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 • If they make a child go back for more food when the child has a reimbursable meal, that is now a OVS violation

30. Offer versus Serve • Lunch • Must take 3 of 5 components • Fruits and Vegetables are 2 separate food components • Must take at least ½ cup serving of fruit or vegetable component • Food Component is one of the five food groups for a reimbursable meal • Breakfast • 4 food items for OVS versus 3 items for non-OVS • Must include the three breakfast components (Fruit (or vegetable substitute), Grain, and Milk) • Food Item is a specific food offered within the five food components • After School Snack

31. OVS: Breakfast and Lunch

32. Dietary Specifications • We will be asking you 26 questions to assess your practices and determine if you are a Low Risk or High Risk • We will request and review a weeks worth of menu documentation from the targeted menu review site prior to coming on-site • Breakfast & Lunch Menu • Corresponding Production Records • Corresponding Standardized Recipes • If High Risk will have to complete on-site Dietary specifications Assessment tool and a Nutrient Analysis • Nutrition Facts Labels and Manufacturer Specification Sheets will be requested for all food to complete a nutrient analysis

33. Technical Assistance & Corrective Action • Possible Findings: • Missing Meal Components • Insufficient quantities of Fruits/Vegetables • Implementation • Staff Training • Signage

34. Review FFVP • Must review at least 1 school • 0-5 schools selected that operate FFVP – Review 1 • 6-10 schools selected that operate the FFVP – Review 2 • 11-20 schools selected that operate the FFVP – Review 3 • Must review the invoices, timesheets, purchase orders, etc. submitted for the FFVP claim • FFVP Meal Service observation

35. Review Afterschool Snack Program • 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

36. Food Safety • General Areas of Review • Written Food Safety (HACCP) plan • Food Safety Inspections posted in a publicly visible location • Temperatures Monitored • Request for two inspections • Recordkeeping • Storage

37. Civil Rights Have an “…And Justice for All” poster displayed in a prominent location Program materials have the correct statement included Civil Rights policy and procedure Documentation for staff training

38. Local School Wellness Policy • FNS Memo SP42-2011 • Copy of the Local School Wellness Policy • How does the public know about the Local School Wellness Policy? • Periodic review and update • How are stakeholders made aware of their ability to participate • Goals for Nutrition Education, physical activity, school based activities • Nutrition promotion goals • Designated LWP oversight official • Nutrition guidelines • Plan for Measuring implementation • How does the public know about the results of the most recent assessment on implementation of LWP?

39. Resource Management Maintenance of the Nonprofit School Food Service Account Indirect Costs Paid Lunch Equity Revenue from Non-Program Foods USDA Foods

40. Maintenance of the Nonprofit School Food Service Account • Nonprofit School Food Service Account • Did you conduct a year-end review of revenues and expenses? • Did you have expenses in excess of revenues? • If you had a surplus – was this amount moved out of your account? • Net Cash Resources • Less than 3 month operating balance • Allowable Costs • Restrict the use of program funds to expenses that meet the requirements of 2 CFR 225 and are reasonable, necessary, and otherwise allowable.

41. Review • Review the SFA’s most recent full year statement of revenues and expenses • Determine whether selected expenses are allowable • Ensure accurate and sufficient support documents are maintained for allowable costs • Select a sample of at least 10% of the SFA’s expenses to test compliance and allowability

42. PLE WE will check your PLE calculations and amount you determined to increase prices to make sure prices were increased, and if not, make sure that there is a corresponding move of money from non Federal sources (i.e. the General Fund) to Food Service to make up for not increasing prices.

43. Non-Program Foods Revenue • Non-Program foods – Foods and beverages sold in a participating school that are purchased using funds from the nonprofit food service account • Includes: • A la carte items • Adult meals • Vending machine food purchased with food service funds • Fundraisers • Catered and vended meals

44. Non-Program Foods Revenue Does the SFA use the USDA Revenue from Non-program Foods Tool to calculate its non-program food costs and non-program food revenue?

45. Adult Meal Prices • FNS Instruction 782-5 Rev. 1 • Adult meal prices should include the value of any USDA entitlement and bonus donated foods used to prepare the meal • Lunch Reimbursement Rate $2.88 • Commodity Rate $.2275 • Tax at 6% • Total Lunch Adult Price $3.27-$3.29 depending on lunch rate • Total Breakfast Adult Rate $1.60-$1.91

46. Indirect Costs • Ensure SFAs are correctly determining if their costs are allowable, allocable and appropriately charged as a direct or indirect cost. • Indirect costs are determined on an annual basis at the Department Of Education and are valid for one year. • Direct costs – incurred specifically for a program or other cost objective; clearly identifiable • Indirect Costs – Incurred for the benefit of multiple programs, functions, or other cost objectives; not readily identifiable

47. Food Service Management Company The reviewer should determine if the SFA is conducting an annual reconciliation to ensure that a purchasing agent of FSMC has credited the SFA for the value of all USDA foods received. Must also review invoices to make sure all rebates, discounts and credits are properly given back to the SFA

48. Corrective Action Have at most 30 days to correct. Some corrective action must occur immediately

49. Withholding Payments Regulatory Authority Authority for Withholding Payments as a result of Administrative Review (7 CFR 210.18 (l)) Authority for Withholding payments (7 CFR 210.24)

50. When??? • SFA has failed to submit documented Corrective Action by the specified due date • SA finds Corrective Action was not completed • SFA continues to have the same problems with the same cause • Payments are withheld until the SA determines that Corrective Action was properly implemented by the SFA