1annual training 2015. 2 check sfa compliance with regulations provide technical assistance ensures...

Annual Training 2015 1

Scope of the Administrative ReviewA Look at the National School Lunch Program’s

Administrative Review Process

Annual Director’s Training, Spring 2015


ObjectivesBy the end of this presentation, you will:- Have a clear understanding of the Administrative

Review Process.- Understand areas of review and the implications of

findings based on those areas.- Understand common findings associated with the

Review process.- Increase awareness of resources that are available

from SCN to assist sponsors with the review.


The Administrative Review- Why?

Check SFA

Compliance with

Regulations

Provide Technical Assistanc

e

Ensures

Program

Integrity

Objectives of the Review

• Determine whether or not SFA meets program requirements.

• Provide technical assistance.

• Assess fiscal action, if applicable to recover improperly paid funds.


A New Look for the Review:Off-Site and On-Site

Off-Site Assessment Tool



On-Site Assessment Tool



• Assess fiscal action, if applicable to recover improperly paid funds.


Online Web-Based AR Compliance System: CNIPS• All AR question sets,

documentation, findings, technical assistance and corrective action are housed within the system.


Online Web-Based Compliance System Support

• A user manual is provided for SFAs.

• The manual can be found on the SCN Administrative Review webpage.

• The intention of this manual is to provide step by step instructions on how to use the compliance section of CNIPS.


Review Frequency and Schedule

• Review Frequency• SFA must be reviewed every 3 years• Cycle began on July 1, 2013

• Review Period• Most recent month claim submitted

• Must include > 10 operating days

• Week of Review• Menu review during Review Period (5 days)

• Must have at least 3 consecutive days, RCCI’s have 7)

• Day of Review• On-site review


Minimum Number of Review Sites in each SFA


Follow-Up Visits When Necessary

• Follow-Up visits will occur to determine corrective action compliance.

• Timeline• After documented corrective action occurs.• Early in the following school year.

• Scope• Only addresses areas of the review in which serious

violations were noted on the previous review.


Areas of ReviewCRITICAL AREAS OF REVIEW GENERAL AREAS OF REVIEW

Meal Access & Reimburseme

nt

Meal Pattern & Nutritional

Quality

Resource Management

General Program

Compliance

Other State/Federal

Program Reviews

Certification & Benefit Issuance

Meal Components & Quantities

Risk Assessment Civil Rights Afterschool Care Snack Program

Verification Offer vs. Serve Nonprofit School Food Service Account

Food Safety Fresh Fruit and Vegetable Program

Meal Counting & Claiming

Dietary Specs & Nutrient Analysis

Paid Lunch Equity Local Wellness Policy

Seamless Summer Option

Revenue from Non-Program Foods

Competitive Foods Special Milk Program

Indirect Costs WaterLevel One Certification

On-Site Monitoring

Perform

ance

Standard 1Perfo

rmance

Standard 2


Pre-Visit Procedures• SCN Review Consultants will notify the SFA and

schedule the review. They will also:• Obtain pre-visit information• Notify key SFA staff (Director, Business Manager,

Superintendent)• Intro letter will be sent containing instructions

• SCN will initiate the Off-site Assessment tool in CNIPS.• Consultants will Review/Evaluate SFA Documentation.• SCN and SFA must complete the Resource

Management portion 4 weeks prior to the review day.


Pre-Visit Procedures• Consultant will provide SFA

with AR training materials and guidance.

• SCN developed a website for SFAs off-site and on-site portions.

• Consultants will be in constant communication during this portion of the review for explanations and to provide technical assistance if necessary.

http://education.ky.gov/federal/SCN/Pages/Glossary-of-Terms-and-Resource-

Materials.aspx


Let’s Meet the Review Team!

Steve Justice, Section SupervisorSteve Abbott, ConsultantFaith Corbin, Consultant

Alan Curtsinger, ConsultantDiana Drury, Consultant

Brent Mason, CoordinatorAli McCreary, Consultant

Cindy McIntosh, Consultant


Let’s Take a Look at the Main Areas of Review


1. Meal Access & Reimbursement

Certification & Benefit IssuanceVerification

Meal Counting & Claiming


Performance Standard 1• This occurs when there is an error associated with the

following:

All free, reduced-price, and paid meals claimed for reimbursement are served only to children

eligible for free, reduced-price, and paid meals, respectively; and are counted, recorded,

consolidated and reported through a system which consistently yields correct claims.


Meal Access & Reimbursement:Certification & Benefit Issuance

• SFA answer Questions #100-#122

• SFA sends benefit issuance information to SCN

• SCN reviews a statistical sample of eligible students

• SFA sends additional information if necessary

• Section shortened for CEP districts

Off-Site

• Review of denied applications

• Review of eligibility notification letters

On-Site


Meal Access & Reimbursement:Certification & Benefit IssuanceCommon Findings- Incomplete Applications- Miscategorized Applications- Issues relating to disclosure


Meal Access & Reimbursement:Verification

N/AOff-Site

• Review a sample of verified applications & supporting documents

• Review to ensure correct changes were made in the POS if necessary

On-Site


Meal Access & Reimbursement:VerificationCommon Findings

• Incorrect letters due to missing information.• Incorrect conversion of income (incorrectly converted to

annual).• No POS documentation if status changed.


Meal Access & Reimbursement:Meal Counting and Claiming

• SFA Answers questions #300- 312

• Ensure claim for review month is submitted

Off-Site

• Provide daily and monthly meal counts for the review month

• Provide edit checks for the review month

On-Site


Meal Access & Reimbursement:Meal Counting and ClaimingCommon Findings

• Missing or inaccurate edit checks


Community Eligibility Provision Districts (Full and Partial)

Full Districts

• This section of the review will be abbreviated for CEP districts.

• ISP (from April 1st) information will be validated.

• Randomly selected students will be checked on the DC list to validate status.

Partial Districts

• This section will be utilized to review non-CEP sites.

• An abbreviated review will occur of your CEP sites.


Documentation: ISP


2. Meal Pattern and Nutritional Quality

Meal Components & QuantitiesOffer vs. Serve

Dietary Specifications & Nutrient Analysis


Performance Standard 2• SFAs must:

• Offer students the required meal components in the required quantities.

• Allow students to select required meal components on all reimbursable meal service lines.

• Record/claim only those meals that contain required components in required quantities.

Reimbursable lunches must meet the meal requirements in 210.10, as applicable tothe age/grade group reviewed. Reimbursable breakfasts must meet the meal requirements in 220.8 and 220.23, as applicable to the age/grade group reviewed.


Meal Pattern & Nutritional Quality:Review Process

• Submits menus via inTeam

• Menu production records

• Menu component crediting information

• Recipes, labels, etc.• SCN will complete

the off-site Meal Compliance Risk Assessment Tool with assistance from the SFA

Off-Site

• Breakfast/Lunch meal preparation observation

• Breakfast/Lunch meal service observation

• Validate and follow-up on the off-site review

On-Site


If SFA has more than one site…

• If the SFA has more than one site, an assessment will be conducted to determine which school site is at the highest risk for non-compliance. That site is referred to as the TARGET SITE.

• All other sites will be considered Non-Target sites.

Review menu and documentation for quantities, components as well as dietary specifications

Target Review menu and

documentation for quantities and components

Non-Targe

t


Meal Pattern and Nutritional Quality:Off-Site Documents Needed

• All menu documents are needed for:

• Each menu & age/grade group

• Each reviewed site• Week of Review- during

Review Period• Day of an On-Site Review• Breakfast• Lunch

• Menu documents:• Menus• Refrigerator Menus• Menu production records• Standardized Recipes• Crediting information

• Nutrition labels• Child Nutrition Labels• Manufacturer’s Statements


Menu Compliance Team• SFAs will be contacted by

the SCN Menu Compliance team.

• The Menu Compliance team will assist the SFA with menu and documentation submission.

Meet the TeamRachel BeachElli PaceSandy WagnerBrenda Zahn


To Analyze or Not To Analyze?• SCN will review submitted menus and documentation

utilizing the InTeam menu compliance software.• If SCN finds significant issues (missing meal

components or other high risk assessment factors) a nutrient analysis will be conducted.

• SCN will offer Administrative Review Meal Compliance Workshops for all SFAs.

• Workshops will focus on how to use InTeam software.


Meal Pattern & Nutritional Quality:On-Site

On-Site Documentation• Menu Production Records

• Day of Review• Each Site Reviewed• Breakfast and Lunch• Refrigerator Menus

(month of on-site review)

On-Site Meal Observation• All reimbursable meal lines offer

all required components.• Breakfast in the classroom, Grab ‘n

Go, etc.

• Observe a % of meals served in each line.

• Determine if meals contain components and quantities for specific age/grade.

• Ensure students have access to, and know how to select, a reimbursable meal.


On Site Meal Observation• Ensure Offer vs. Serve is implemented correctly:

• Adequate food is offered on all reimbursable meal 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.• Food service staff at the POS are trained and can recognize

a reimbursable meal.


Common Findings• Inadequate quantities of components offered.• Calculation errors when determining meal component

contributions- crediting.• Offer vs. Serve not implemented correctly.• Trans fats in food products.• Incorrect portion sizes.• Incomplete or incorrect production records.• No standardized recipes.


3. Resource Management

Maintenance of the non-profit school food servicePaid Lunch Equity

Revenue from non-programs foodsIndirect Costs


Resource ManagementReview Process

Answer Questions #700-712 in CNIPS

Off-Site

Review activities dependen

t on results of off-site

responses

On-Site


Off-Site Questions• Ensure the overall financial health of the SFA’s

nonprofit school food service account.• Completed off-site with assistance from reviewer if

necessary.• Questions include the following topics:

• SFA enrollment• Previous financial findings on previous reviews• Maintenance of the nonprofit food service account• Paid Lunch Equity• Non-Program foods• Indirect Costs


Resource Management Risk Indicator Tool

• SCN will conduct a risk assessment on the SFA via the off-site responses.

• If SFA demonstrates a high risk for non-compliance with resource management, SCN will conduct a comprehensive resource management review of the SFA.


4. General Program Compliance

Civil RightsFood Safety

Local Wellness PolicyCompetitive Foods

WaterSFA On-Site MonitoringLevel One CertificationSBP & SFSP Outreach


Civil Rights

• SFA answers questions #800- 807

• SFA provides current non-discrimination statement

• Annual Civil Rights training documented

• Copy of the public release

• SFA’s Civil Rights Complaints procedure

• SFAs accommodating special dietary needs procedures

Off-Site

• Validate off-site questions/documents

• And Justice For All Poster compliance

• Prevention of overt identification

On-Site


Food Safety

N/AOff-Site

- SCN conducts kitchen and food service area walkthroughs- Review of food safety plan- Two food safety Inspection reports- Temperature logs

On-Site


Local Wellness Policy

• SFA answers #1000-1006 in CNIPS

• Review of current Local School Wellness Policy

• Review of Public Notification, updates and assessment of policy

Off-Site

Reviewer may conduct or

complete off-site portions

On-Site


Competitive Foods

Answer questions

#1100-1102

Off-Site

- Observation of foods and beverages sold on school campus- List of all foods/beverages sold on campus & sample documentation*

On-Site


* Competitive Foods Sold in a District

• All competitive foods sold in the district to students must be in compliance with Smart Snacks guidance.

• To ensure compliance, the SFA will be asked to provide documentation:

• product packaging (front and back),• assessment documentation showing compliance using the

Alliance for a Healthier Generation’s Smart Snacks Calculator.

• You will need to work with your district administration in obtaining this information.


Water

N/AOff-Site

Meal Service

Observation

On-Site


SFA On-Site Monitoring

Answer question #900 in CNIPS

Off-Site

Review of site

monitoring forms

On-Site


Level One Certification

Review Level One Training Documentati

on

Off-Site

Completion of Review of Level One training

documentation if

necessary

On-Site


SBP and SFSP Outreach

Reviewer will review outreach

documentation

Off-Site

Reviewer will review outreach

documentation to

ensure it is ongoing

On-Site


Other Federal Programs• Reviewers will also monitor documentation for the

following programs if being operated by the SFA• After School Snack Program (tally sheets or other

documentation)• Seamless Summer Option• Fresh Fruit and Vegetable Program• Special Milk


Post Review

Administrative Review Exit ConferenceAdministrative Review Report

Corrective Action Plan DocumentsFiscal Action/Claim Revisions


Corrective Action Plans• All CAP information will be maintained within CNIPS.• SCN will identify how the SFA will resolve the finding

and ensure future compliance.• Findings must be corrected system-wide.• May need to supply additional documentation to SCN.


Training and Support Materials

• SCN is always here to support you!

• A one-stop shop webpage exists to answer your AR questions.

• PLEASE take the time to familiarize yourself with available resources.

http://education.ky.gov/federal/SCN/Pages/Administrative-Review.aspx


Questions?

Thank you for your time!

1annual training 2015. 2 check sfa compliance with regulations provide technical assistance ensures...

Documents

annual training

review month

vegetable program meal

meal requirements

monthly meal

cep districts offsite

program integrity

check sfa compliance