CRE-SMI Overview

1. CRE-SMI Overview Please turn on your speakers or headphones!

2. What is CRE-SMI? • CRE/SMI: Two different reviews • CRE=Coordinated Review Effort • Performance Standard 1-Meal Counting and Claiming/Eligibility • Performance Standard 2- Meal Components • General Review Areas • State Agency (ODE) Specific Areas • SMI=School Meals Initiative • Comprehensive nutritional review of School Food Authority’s (SFA) selected menu planning option

3. CRE review cycle and schedule • SFA’s must be reviewed at least once every 5 year cycle. • SFA’s are notified in August that they will be reviewed. • Confirmation letter sent at least 30 days prior to review. Hint: Always be prepared!

4. Review Period and Number of Sites to be Reviewed • CRE includes: • Day of review (the day we are on-site) • Review period • Review period= most recent month for which a claim for reimbursement was submitted. • When selecting school(s) to be reviewed, ODE must use USDA required procedures.

5. School selection cont. • School Selection Worksheet. • Schools w/free ADP of 100 or more and 100% or more free participation must be reviewed. • Additional schools that must be reviewed: • Elementary schools (pre-K, K-8) w/free ADP of 100 or more and 97% free participation. • Combination schools (K-12, 7-9, 7-12, etc.) w/free ADP of 100 or more and 87% free participation. • Secondary schools (9-12) w/free ADP of 100 or more and 77% free participation. • If none of these criteria are met, then optional criteria can be used.

6. Program areas to be reviewed • Performance Standard 1= Meal Counting and Claiming/Eligibility • Performance Standard 2= Meal Components • General Areas= Wide variety of subjects and ODE specific subjects

7. The Review Process • CRE announcement letter sent to SFA in August. • ODE will contact SFA to set exact date for review. • Second CRE announcement letter sent to SFA approximately 30 days before review date. • ODE reviewers will conduct entrance conference with the superintendent and/or their designee(s). ODE reviewers may review breakfast service prior to the entrance conference. • ODE reviewers will conduct an exit conference with the superintendent and/or their designee(s) to discuss the review findings. ODE reviewers will issue a Document of Administrative Findings (DAF) outlining the Corrective Action required by the SFA. • The SFA has 30 days to adequately respond to all findings noted in the DAF. Should the DAF be incomplete or past due, the SFA’s claims will be placed on “HOLD” until all review findings are corrected. • If there are no findings or the DAF has been adequately addressed, ODE will issue a closure letter for the review.

8. The First Review • Breakfast and Lunch will be reviewed. • What will ODE reviewers be looking at: • Applications/Benefit Issuance Process • Applications should be sorted by review school and Benefits Issuance Document. • 100 Percent of applications will be reviewed (ODE retains right to review less). • Temporary and denied applications. • Approved eligible student counts vs. reviewer’s count. • Applications will be checked for correct approval on income and family size. • Determine if questionable applications were researched before a determination was made.

9. The First Review Cont. • Direct Certification (DC) • Official ODE downloaded DC list. • DC list updated regularly? • Predetermined Eligibility letter for DC sent to households? • Are siblings of directly certified students included in the eligibility benefits following new USDA guidelines? • Is DC list only used for first 30 operating days of the school year? • Head Start Documentation • Are Head Start students enrolled in the school district in an academic program? • Is a statement of low income provided by an authorized Head Start employee? OR • A list of income eligible Head Start students. • Is the list new for each school year? • Was predetermined eligibility letter sent to households?

10. The First Review Cont. • Even Start Program Documentation • Approved Even Start application, or • Statement of enrollment in Even Start; or a list of children in Even Start must be on file. • Confirmation of pre-kindergarten status. • Re-certify each year. • Runaway Youth Documentation • To document a child’s runaway status and eligibility for free meal benefits, the school must obtain a list with each child’s name and the signature of the local runaway coordinator. • Homeless Youth Documentation • To document a child’s homeless status and eligibility for free meal benefits, the school must obtain a list with each child’s name and the signature of the local homeless coordinator.

11. The First Review Cont. • Migrant Youth Documentation • To document a child’s migrant status and eligibility for free meal benefits, the school must obtain a list with each child’s name and the signature of the local migrant coordinator. • Master List/Roster • Is there a listing of all students and their approved categories by school? • The list/roster should include: • Child’s name • Approved status • Date approved • Date noting a change must be on roster or application • School master list will be compared to all F/R applications, DC list, runaway, homeless, migrant, Head Start/Even Start. • Denied (paid) applications will be checked for correct approval and student’s status will be checked on roster to make sure student is receiving proper benefits.

12. The First Review Cont. • Documentation of any Changes • Any change on the master list/roster or the application must be initialed and dated by the person making the change. • Verification Process • Is the correct sample size based on October 1 count of applications? • Is the district summary sheet completed? • Did the district document by application? • Was verification completed by November 15? • Were an adequate number of applications selected? • Were required income and SSN documentation obtained? • Is the Verification Record completed? • Were correct letters sent to households • Were changes to the master list/roster made if verification results changed eligibility? • Meal Count/Collection Procedures • Is the counting, recording, and claiming of the number of meals served to students by category accurate? • Is there adequate documentation to support the claim? • Is the medium of exchange used correctly? No overt identification? Is the collection procedure observed the same as approved by ODE? • Is there equal access for all students?

13. The First Review Cont. • Point-of-Service Count • Is the system used providing an accurate point-of service count of reimbursable meals served (one per eligible student per day) by category (free, reduced and paid) each day without overtly identifying students’ eligibility? • Consolidation of Claims • Are the edit checks conducted to prevent claiming more students than in attendance? • Are edit checks performed daily (compare each school’s daily claim against the number of students approved for free and reduced-price lunches, the school’s average daily attendance and the school’s enrollment? • Are on site reviews completely annually for an SFA with more than one feeding site?

14. The First Review Cont. • Menu Requirements for all meal patterns • Are all required components/food items available in correct portion sizes on reimbursable meal serving lines on day of review? • Are all items offered before the point-of-service count? • Are food production records complete and adequate to support claims? • Do the Month of Review menus meet meal pattern requirements? • Are CN labels available for food based menus, product data sheets for Nutrient Standard menus? • General Record Keeping Policies • Are records kept for 3 years plus current operating year? • Are approved applications (date approved, level of benefits, signature or initials of reviewing official) kept? • Is supporting information, such as dates of transfers, withdraws and changes in eligibility, maintained?

15. The First Review Cont. • Records to maintain daily • Is the daily record of Reimbursable Meals maintained? • Is the daily record of Income updated? • Are food production records completed by the end of each day? • Is the system that notes transfers, withdrawals, etc. updated as needed? • Are edit checks conducted daily? • Records to maintain monthly • Is the consolidation of school meal counts by category correct? • Is the reimbursement claim submitted electronically via CNPweb no later than 60 days following the completion of the claim month?

16. The First Review Cont. • Financial Records • Are financial records, purchasing procedures, and meal pricing available for review? • Is the fund balance from last year carried forward (positive or negative)? • Is the net cash balance less than three months’ operating expenditures? • Is all interest posted to Child Nutrition Program account? • Does payroll account for only Child Nutrition personnel? • Are meals priced as a unit? • Do reduced-price charges exceed maximum allowed? (40 cents for lunch and 30 cents for breakfast, public schools must have zero charge for reduced-price breakfasts due to Oregon law) • Are adult meals prices at least the free reimbursement rate plus commodity entitlement rate? • Is there a bidding process in place? Is district purchasing awarded items? • Are state matching funds deposited in the CN account?

17. The First Review Cont. • Policy Statement • Is the district following all attachments to their free/reduced policy statement? • Civil Rights • Are disabled children receiving accommodations for feeding? • Nondiscrimination poster posted? • Is the nondiscrimination statement printed on correspondence? • How is the district handling complaints of discrimination? • Is the district providing/using foreign language translation applications, if needed? • Is there separation by race, color, national origin, sex, age or disability in the eating periods, seating arrangements, serving lines or eating areas? • Is there overt identification?

18. The First Review Cont. • Procurement Process • Do you know what the Federal procurement regulations are? If not review 7 CFR 3016. • Do you know what your local small bid threshold is? If not are you using Oregon small bid threshold of $5,000? • If you are purchasing below the small bid threshold are you obtaining at least 3 quotes? • If you are purchasing above small bid threshold are you using an Invitation for Bid or Request for Proposal? • Are all purchases being procured competitively with no restrictive requirements? • Is the Buy American provision being followed? • Is child nutrition required to purchase off an exclusive school beverage contract?

19. The First Review Cont. • Competitive Foods • Does the SFA have a board policy allowing foods to be sold in competition with school meals? • Foods of Minimal Nutritional Value • Is serving/purchasing of Foods of Minimal Nutritional Value (FMNV) in foodservice area or with CNP funds observed?

20. The First Review Cont. • Provision 2 Base Year • Is there a notification document to parent/guardian on file including media release? • Meals being provided at no charge to students? • Meals being counted and claimed by eligibility category of student? • All other eligibility rules still apply. • Provision 2 Non-Base Year • Is documentation of public announcement regarding Provision 2 on file? • Meals being provided at no charge to students? • Is the percentage of free/reduced/paid established in the base year being applied to monthly count correctly? • Are base year free/reduced applications still available for review?

21. The First Review Cont. • Food Service Management Company Operations (if applicable) • Is the contract being followed? • Is the SFA monitoring the management company operations? • SFA employee completing yearly on-site reviews? • Is SFA filing monthly claim for reimbursement, establishing meal pricing, and retaining signature authority? • Is SFA monitoring free/reduced applications and verification process if management company is completing? Is this agreement in contract? • Does the SFA have an advisory board composed of parents, teachers, and students to assist in menu planning? Documentation of attendance on file? • Is FSMC following all applicable rules regarding commodities and rebates?

22. The First Review Cont. • After School Snacks (if applicable) • Documentation of education or enrichment activity • Attendance records • Snack Production Records • Roster/tally sheet of daily count of snack • Two afterschool on-site reviews per year • Fresh Fruit and Vegetable Program (if applicable) • Invoices and time and effort document Month of Review FFVP claim • Adequate amount of produce to serve the enrolled number of students in the school • Sponsor/school is serving a variety of fruits and vegetables • Sponsor/school following the Implementation Plan • Sponsor/school completing two yearly self-reviews

23. The First Review Cont. • Commodities • Is the district storing foods properly: • Off floor, away from walls? • Cleaning supplies stored separately? • Old, excessive or damaged commodities utilized or removed? • Annual Commodity Storage Evaluation completed? • Health Inspections/Food Safety • Has the school been inspected twice within the last 12 months? Most recent inspection posted? • Have violations been addressed, if noted on inspection? • Is HAACP food safety plan available at every production, serving site in SFA?

24. Follow-up Review • Review Threshold • Review threshold or degree of error in a critical area of review is exceeded and triggers a follow-up review • Review Findings classified as either: • Non-systemic • Unusual factors contributed to the error • Systemic • An error is built into a system and would likely re-occur if no changes to system. • Clerical • Means the error may or may not be non-systemic or systemic.

25. Fiscal Action • If an over-claim is noted during a review, fiscal action could occur= we take money back! • ODE has option to disregard any over-claim of $600 or less per program. • Month of review claim (and possibly others) will be adjusted by ODE. • Eligibility errors normally go back to beginning of month of review to date of correction. Reviewer retains discretion. • Meal counting/meal component errors normally go back to the beginning of the school year to date of correction. Reviewer retains discretion. • ODE has discretion to go into previous fiscal years depending on severity of the situation.

26. Lack of Response or Documented Administrative Findings (DAF) Plan Past due • No response • Claims put on hold until DAF received • Response past due • Claims put on hold until DAF received • Appeals Procedure • Available when fiscal action is assessed. • Cannot appeal findings.

27. Scope and Timeline for Follow-up Review • If Follow-up review has been triggered: • Problem areas addressed • All other Child Nutrition Programs reviewed • Follow-up review must be conducted before December 31 of the following year. • If a second follow-up review is required, ODE can place a “HOLD” on program funds. • Eliminate possibility for follow-up reviews • Program termination?

28. School Meals Initiative (SMI) Comprehensive evaluation of districts lunch menu to ensure compliance with the Dietary Guidelines for Americans.

29. Required Nutrient Levels

30. What must sponsors do? Traditional Food Based Menu Planning (TFBP) • After the on-site visit by ODE during the week of review, you will send us: • Printed Menu • Production Records for SMI week of review • Standardized recipes used • Nutrition Fact Labels for non-single food items. • Condiment recording form

31. What must sponsors do? Nutrient Standard Menu Planning (NSMP) • Prior to the on-site visit by ODE, you will send us: • Printed Menu for SMI week of review • Menu spreadsheet detail report using portion values • Recipe audit report • Nutrition facts labels for products used • Data entry for local ingredients • During on-site visit, ODE will evaluate: • Production Records are being completed • Adjustments made to servings planned from production records • Data entry for local ingredients • Portion sizes used in analysis are the same as on-site day of review • Use of standardized recipes in analysis and production • Verify ingredients used in analysis and those used in production • After on-site visit, you will send ODE: • Completed production records for the week of review

32. Compliance or Corrective Action • Whether on NSMP or TFBP, if any of the 8 required Federal nutrient levels are inadequate, a improvement plan will be issued. • If any of the 3 recommended state nutrient levels are inadequate, a improvement plan will only be necessary if at least 1 federal nutrient level is inadequate. • If you meet all requirements you will receive a congratulations letter.

33. Lack of response or Corrective Action Plan Past Due • No response to information requested • Claims put on hold until information received • Corrective Action past due • Claims put on hold until corrective action received

34. The whole point of the CRE-SMI review is to ensure that money is being spent appropriately and you are providing nutritious meals to children that meet Federal requirements. We are here to help. If you need any assistance in the operation of your child nutrition program, please call or e-mail your assigned child nutrition specialist.