school meal administrative review reinvention...

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School Meal Administrative Review Reinvention Team

School Nutrition AssociationJuly 2013

Presentation Overview2

Background – Why a New Review Process? SMARRT Activities Details of New Administrative Review –

How Does it Differ from the CRE?How Does it Differ from the CRE? Questions

Team Lead:Lynn Rodgers

Lauren Russell (PA MARO)

Loren LaCorte

Heather Hopwood( bbi Ni i)

Lynn Rodgers‐Kuperman

(PA ‐MARO)

Jamie McMillian (NY ‐ NERO)

Sarah Edwards(NC ‐ SERO)

(Debbie Nigri)

Eric Lai

SMARRTMembers

State Agency Advisors

Headquater Staff

( )

Karen Campbell (KS ‐MPRO)

Melanie Brummeler(MI ‐MWRO)

Susan WeeksRegional

Office Staff

(MI MWRO)

Sharon Welborn(TX ‐ SWRO)

Heidi Dupuis(OR ‐WRO)

MARO

•Mark Durma•John Gallagher

NERO

•Emily Desrosiers•Susan Gentile

SERO

•Donnie Lewis•Sean Monahan

MPRO

•Penny Burke•Katrina Klatt

MWRO

•Maged Hanafi•Eleanor Thompson

SWRO

•Brenda Hildebrand•Sandy Moody

WRO

•Marisa Cheung•Tim Thole

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Team Structure4

3 Subgroups to Review Details of Program Material: Access to School Meals & Reimbursement (PS1) Meal Pattern and Nutritional Quality (PS2) Meal Pattern and Nutritional Quality (PS2) School Environment (General Areas)

4 S b t Add O hi N d 4 Subgroups to Address Overarching Needs: Organization and Process Forms Testing Training

Administrative Review Testing

Why test the process?

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◦ Test the theories behind the new approach

◦ Gather feedback from SFAs/LEAS, State Agency staff, and team membersand team members

◦ Allow testing to inform the new process and materials

◦ Examine the new flow and enhance materials as needed

Testing Results

SAs and SFAs preferred using an off-site pre-visit process

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p g p pto make better use of time spent on-site

Statistical sampling method reduced time spent reviewing li ibilit d t i ti d i t i d t eligibility determinations and maintained accurate error

percentages (e.g., one test sample had no error compared to only one application in

the review of all applications)

Dietary Specifications Assessment Tool’s determination of compliance was supported when compared to an actual compliance was supported when compared to an actual nutrient analysis (i.e., tool indicated low risk, nutrient analysis supported compliance)

Testing Results

The new process makes the review more of a

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The new process makes the review more of a team effort — the SA reviewers and the SFA working together — and reduces the “gotcha” g g gaspect of the review.

The SFA not only has more time to provide information to the SA, but also will better understand why they are providing that information.

Administrative Review: SY 2013-2014

School year 2013-14: State Agencies have options

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y 3 4 g p New process in its entirety (requires a waiver) Current process (i.e., CRE + nutrient analysis)

New Administrative Review Training & GuidanceS d i l ll S id h i Started in early 2013 to allow SAs to consider the new review process before committing to one of the two options

Review Frequency & Schedule

Re ie Frequenc

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Review FrequencySFA must be reviewed every 3 years

Cycle begins July 1 2013Cycle begins July 1, 2013

Base Year: Special provision options

Review ScheduleSA discretion

Postponed reviews

Non-compliant SFAs

Follow-Up Reviews No Longer Required10

Performance Standard Thresholds Eliminated 3 year review cycle = more frequent contact Ensure corrective action is implementedp

Collaborative Compliance

New Administrative Review Structure

Meal Access & Reimbursement

NutritionalQuality & Meal

Resource Management

General Program

Other Federal

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• Certification & Benefit Issuance

Q yPattern

• Meal Components &

g

• Risk Assessment

gCompliance

• Civil Rights

• SFA On-site

Program Reviews

• After-school

• Verification

pQuantities

• Offer versus S

• Nonprofit School Food Service Account

• SFA On-site Monitoring

• Local Wellness Policy

Snacks

• Seamless Summer

• Meal Counting & Claiming

Serve

• Dietary Specs & Nutrient

Account

• Paid Lunch Equity

• Revenue

• Competitive Foods

• Water

F d S f t

Option

• Fresh Fruit & Vegetable & Nutrient

Analysis from Non-program Foods

• Indirect

• Food Safety

• SBP & SSO Outreach

gProgram

• Special Milk Indirect

Costs

• USDA foods

Program

Performance Standards12

Critical AreasPerformance Standard 1

Performance Standard 2

General AreasResource Management

General Program Compliance

h d lOther Federal Program Reviews

Maximizing Resources

CRE ApproachCRE Approach New ApproachNew Approach

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pppp pppp

Primarily conducted on-site Process structured to be conducted off-site and on-site:conducted off site and on site:

• Off-site Assessment Tool

• Risk Assessment Tools

New Approach allows for:New Approach allows for:

• Office staff assistance• Application of risk indicators• Better balanced workload and preparation• More on-site technical assistance

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Off-site Components

Advantages: Flexibility Flexibility Use of specialized staff Reduced staff time

Off-site monitoring tools: Off-Site Assessment Tool Compliance Risk Assessment

Tool Dietary Specifications Dietary Specifications

Assessment Tool Resource Management Risk

I di T lIndicator Tool

Off-site Assessment Tool15

The Off-site Assessment and Risk Assessment Tools allow for:

Collection of information through a series of questions and, in some instances, documentation

Flexibility for review at various times of the year

When applicable, allows the SA to identify sites potentially at-risk of noncompliance with federal requirements and target them accordingly for reviewg y

Off-site Assessment Tool

Includes questions on a number of monitoring areas

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Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit Feedback from testing: Tool encourages SA and SFA to work collaboratively and helps shift the process toward the goal of combining shift the process toward the goal of combining compliance/monitoring with technical assistance

SFA has more time to provide information to the SA, and also ill b tt d t d h th idi th t i f tiwill better understand why they are providing that information

SA has more time to review documents thoroughly, conduct reviews more consistently, and provide ongoing technical

i h SFAassistance to the SFA

Additional Off-site Monitoring Tools17

Meal Compliance Risk Assessment Toolp Targets error-prone areas of the new meal pattern Determines which site is selected for an in-depth menu review

Dietary Specifications Assessment Tool Assesses food service practices to determine risk for not p

meeting the Dietary Specifications

Resource Management Risk Indicator Tool Resource Management Risk Indicator Tool Identifies whether SFAs need an on-site Resource

Management Comprehensive Review




Resource Management

General Program

Other Federal

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• Certification & Benefit I

Q yPattern


g

• Risk Assessment

gCompliance

• Civil Rights

• SFA On-site

Program Reviews

• After-school Issuance

• Verification

pQuantities

• Offer versus S




Snacks

• Seamless Summer

• Meal Counting& Claiming

Serve


Account


• Revenue


• Water

F d S f t

Option



• Indirect

• Food Safety


gProgram


Costs

• USDA foods

Program

Access and Reimbursement Overview 19

Certification & Benefit Issuance

Administrative


Meal C ti d Review Counting and

Claiming

General Areas Verification

Overview of Access & Reimbursement

CRE Approach

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pp◦ Certification, Benefit Issuance and Verification

examined at selected sites only

◦ Verification process also examined at SFA level

◦ Two samples are used to examine Certification and Benefit Issuance

◦ Review almost entirely conducted on-site

Overview of Access & Reimbursement

New Approach

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Process Based Approach• System evaluation (off-site assessment)• System validation (on-site)

S i SFA idScope is now SFA-wide• Certification and Benefit Issuance errors are applied across the

SFA instead of by site• Verification will be reviewed at the SFA level; SA will review a Verification will be reviewed at the SFA level; SA will review a

random sample of verified applicationsStreamlined process

• Certifications will be used to examine BI list• Verification will be examined as part of the certification review

No changes to the Meal Counting and Claiming approach (except for adding breakfast review)adding breakfast review)




Resource Management

General Program

Other Federal

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Q yPattern

• Meal Components

g

• Risk Assessment

gCompliance

• Civil Rights

• SFA On-site

Program Reviews

• After-school

• Verification

p& Quantities

• Offer versus S




Snacks

• Seamless Summer


Serve

• Dietary Specs &

Account


• Revenue


• Water

F d S f t

Option

• Fresh Fruit & Vegetable Specs &

Nutrient Analysis

from Non-program Foods

• Indirect

• Food Safety


gProgram


Costs

• USDA foods

Program

Nutritional Quality & Meal Pattern Overview23

P f

Critical Areas

Performance Standard 1 Dietary

Specifications & Nutrient

Administrative Review

Areas


Analysis

Meal Components &

General Areas

Components & Quantities

Offer versus Offer versus Serve

Meal Pattern & Nutritional QualityNew Tools & Checklist

Meal Compliance Risk Assessment Tool ti

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9 questions Targets error-prone areas of the new meal pattern Determines which site is selected for an in-depth menu review

Dietary Specifications Assessment Tool 26 questions

A f d i i d i i k f i h Assesses food service practices to determine risk for meeting the Dietary Specifications High Risk – a nutrient analysis is required Low Risk a nutrient analysis may not be required Low Risk – a nutrient analysis may not be required

Nutrient Analysis & Validation Checklist Checklist of items needed to accurately conduct or validate a Checklist of items needed to accurately conduct or validate a

nutrient analysis

Overview of Nutritional Quality & Meal Pattern

CRE/SMI Approach

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CRE/SMI Approach◦ Meal components and quantities assessed at all

reviewed sites:• Menu/production record review • Meal observation◦ Evaluate Offer vs. Serve implementation◦ Nutrient analysis required for each menu type

at one site

Overview of Nutritional Quality & Meal Pattern

New Approach:

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New Approach:• Meal components and quantities assessed at all

reviewed siteso Menu/production record reviewo Meal observation

• Evaluate Offer vs Serve implementation• Evaluate Offer vs. Serve implementationo Ensure reimbursable meals contain > ½ cup of

fruits or vegetables• Nutrient analysis for each menu type only required

at high-risk sites




Resource Management

General Program

Other Federal

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Q yPattern


g

• Risk Assessment

gCompliance

• Civil Rights

• SFA On-site

Program Reviews

• After-school

• Verification

pQuantities

• Offer versus S



• Local Wellness P li

Snacks

• Seamless Summer


Serve


Account• Paid Lunch

Equity• Revenue

Policy


• Water

Option



• Indirect

Water

• Food Safety


gProgram


Costs• USDA foods

Program

Resource Management Overview28

f Performance Standard 1



G l A Resource General Areas Resource Management

Overview of Resource Management

CRE Approach

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CRE Approacho Resource Management is NOT included in the CRE

although State Agencies are required to review a SFA’s fi i l d ifinancial processes and practices.

o Some states have developed their own review questions and include them as part of the CRE; other states may and include them as part of the CRE; other states may review financial information as part of the annual SA-SFA agreement.

Overview of Resource Management

New Approach

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pp• Includes a resource management section, streamlining

the review process in this areaRequires SFA to submit information via the Off site • Requires SFA to submit information via the Off-site Assessment Tool to the SA at least 4 weeks prior to on-site review

k d l• A Resource Management Risk Indicator Tool assesses information provided in the Off-site Assessment Tool to determine if potential risk for noncompliance exists

• If three or more risk indicators are triggered by the Risk Indicator Tool, the SFA will have an on-site Resource Management comprehensive review. g p




Resource Management

General Program

Other Federal

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Q yPattern


g

• Risk Assessment

gCompliance

• Civil Rights• SFA On-site

Program Reviews

• After-

• Verification

pQuantities

• Offer versus S



• Local Wellness P li

school Snacks

• Seamless • Meal Counting &

ClaimingServe


Account


• Revenue

Policy• Competitive

Foods• Water

Summer Option

• Fresh & Nutrient Analysis from Non-

program Foods

• Indirect Costs

Water• Food Safety• SBP & SSO

Outreach

Fruit & Vegetable Program

Indirect Costs

• USDA foods• Special

Milk Program

General Program Compliance/Other Federal Programs Overview

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f Performance Standard 1



General Program Compliance

G l A Other Federal General Areas Other Federal Programs

General Program Compliance/Other Federal Programs OverviewPrograms Overview

CRE Approach – General Program Compliance:

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CRE Approach General Program Compliance: o Monitored on-site during the course of review ORo Not part of the CRE process

CRE Approach – Other Federal ProgramsAfterschool Snacks and Special Milk Program reviews o Afterschool Snacks and Special Milk Program reviews only required during a FOLLOW-UP review

o FFVP not included in CREi b i d d i b fo One SSO site must be reviewed during summer before

or after the SY in which the SFA’s administrative review occurs.

General Program Compliance/Other Federal Programs Overview

New Approach – General Program Compliance:

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• Mix of off-site and on-site responsibilities• Some exclusively off-site/Some exclusively on-site• Some reviews with a combination of both

New Approach – Other Federal Programs• Afterschool Snack Program – documentation review only

d i i iti l i / ff it it / b ti during initial review/off-site or onsite/observation optional

• Seamless Summer Program – unchangedF h F it d V t bl P t f i iti l • Fresh Fruit and Vegetable Program – part of initial admin review/site selection procedures/claim validation (off-site) & program observation (day of review)

• Special Milk Program unchanged• Special Milk Program - unchanged

Corrective Action Procedures35

Corrective A i

Immediate CA Reported at Exit Conference

CA Noted on SA Report to SFA

No further action required

ActionAbsent

Immediate CAReported at

Exit ConferenceCA Requested

on SA Report to SFA

SFA details Corrective

Action Plan

Questions?36

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