Preparing for an Administrative Review

Report
Preparing for an Administrative
Review
Lindsay Healy, RD, SNS
CN Resource
June 4th, 2014
What is the Administrative Review?
The Administrative Review (AR) is the new USDA review
process. This AR replaces both the old CRE and the SMI.
The AR was introduced with the Healthy Hunger Free
Kids Act of 2010. The 2013-2014 school year was the first
year that it was implemented.
Moving forward it is important to forget the ways of the
CRE and SMI and embrace the changes! There are many
similarities however, it is a different review and it is
important to make sure everyone is aware and
comfortable with the new review process.
Step 1: Notification of Review
The state agency will send a notification to all of the SFAs that are
selected for review in SY 2014-2015. They will receive a letter
letting them know that they will be contacted to schedule the
review.
Step 2: Scheduling the Review
Determining the site(s) for review:
• The number of sites selected for review is based on the
number of participating schools within the SFA.
• There are USDA criteria that is used when selecting the
specific sites.
• The length of the on-site review will be based on the number
of sites that must be reviewed and the number of meal
applications that will need to be reviewed.
Step 3: Pre-Review Procedures
Selecting the site for a targeted menu review:
• Meal compliance assessment procedures
Additional Pre-review documents:
• Off-Site Assessment
• Dietary Specification Assessment Tool (targeted menu site
only)
• Menu Documentation Review
Off-Site Assessment
When completing the Off-Site
Assessment:
• Work as a team
• Answer the questions completely
• Be as accurate as possible
• Call and ask if there is a question you
don’t understand
• Submit it by the due date
• Submit all the requested supporting
documents
Dietary Specification Assessment
• Only needed for the site that is selected for the Targeted Menu
Review. (the reviewer will let you know what site this is)
• The reviewer will tell you if you need to complete breakfast
and lunch or lunch only.
• Read each statement carefully.
• Answer each statement honestly.
Menu Documentation Review
Week of Menu Review
A single week from the review month will be selected for the
menu documentation review. The reviewer will work with the
SFA to determine the week.
What Menus are Reviewed?
All unique menus that will be observed at the review site(s)
must be submitted for menu review.
What Menu Documentation Needs to be Submitted?
Production Records, Menus, Standardized Recipes, Labels, CN
labels
Step 4: On-site Review
SFA Level:
• Applications
• Verification
• Claims
• Resource Management*
• Civil Rights
• Wellness Policy
• Food Safety Plan
• Record Keeping
• SBP and SFSP outreach
• FSMC*
Site Level:
• Point of service
• Meal components
• OVS
• Kitchen walk through
• Civil rights
• On-site monitoring
• Competitive Foods
• Water
• Food safety
• Record Keeping
Certification and Benefit Issuance
Eligibility
Benefit Issuance
list
from Eligible
allDocumentation
sites Students
participating
within the SFA
Categorically
MUST:
Students Extended
IncomeFoster
Eligibility
Applications
Students
through
MUST
MUST:
theinclude:
Direct Certification
••Supplemental
Total
number
of
eligible
students
in the SFA
Nutrition
Assistance
Report
Program
(SNAP)
orreviewed.
Temporary
Reviewer
will
determine
whichMUST:
applications
will be
•• Assistance
Identify
students
were selected
for Verification
Names
ofwhich
all
forhousehold
Families
(TANF)
members
or
Food
Distribution
Program

Be
on an
approved
complete
list (Homeless,
Migrant,
Applications
will
beand
reviewed
district
wide,
not just
selected on

Have
Indian
an approved
Reservations
application
(FDPIR)
file OR
MUST include:
Head
sites.
• Runaway,
List
must
come Start)
from
the
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ofApplications
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All

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documented
the Direct
income
Certification
and frequency
Report
or on a
•• Be
A
of on
denied
applications
will also
be reviewed.
Nopercentage
duplicatesmember’s
Case

separate
Have
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Be
onNumber
thedocument.
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Certification Report
• List of students eligible for free and reduced meals (do not
Indication
status
of no income for those that have none
SFAfoster
must
provide:
include
paid
students).
For
each
student
listwere
mustadded,
provide:
Signature

The
documentation
of adult
household
must
include
member
the datethe
they
and
• Certification
Document
(application,
direct
certification,
• student’s
name,
Signature
the eligibility
student
of that
adult
household
reside with
member
that is listed on the Direct
list)they
• schoolReport.
name,
Certification
• Verification documents (if applicable)
Last 4• digits
ofstatus,
Social Security Number
benefit
• Notification of benefits
• method
of certification,
•
Any
follow-up
and/or
with
*Must be approveddocumentation
using the correct
USDAcommunications
Income Eligibility
• date
of certification
the
household
Guidelines
Verification
All Verified applications will be reviewed
•
•
•
•
Initial application
Notifications sent to households
Verification documents submitted by households
Notification of results of Verification
• Reviewer will complete a detailed review of 10% of verified
applications
• Summary of Verification Efforts
• This is the report that the SFA is required to maintain each
year, but is NOT required to submit to the State.
Claim for Reimbursement and POS
Claiming documents from all sites within the SFA will be
reviewed
• Review month claim from each site
• Edit check from review month for each site
• Consolidated claim for review month
Point of Service (POS)
Does the system avoid overt identification?
Does it provide an accurate meal count?
How are meals consolidated at the end of service?
How does the POS ensure that students are not claimed
more than once?
Meal Compliance
Resource Management
Audits
Non-Profit School Food Service Account
Paid Lunch Equity
Revenue from Non-Program Foods
Indirect Costs
USDA Foods
Paid Lunch Equity Tool
http://www.fns.usda.gov/paid-lunch-equity-school-year-20142015-calculations-and-tool
Non-Program Foods Revenue Tool
http://www.fns.usda.gov/cnd/governance/policy2006-2011.htm
Civil Rights
• The SFA's public release
• Description of the SFA's procedures for receiving and
handling a Civil Rights complaint
• Information on the number and description of complaints
alleging discrimination in the current and prior school year
• Date, agenda and attendees of the recent Civil Rights training
for the SFA staff
• Need and availability of translation services
• Description of the SFA's procedures for collecting
racial/ethnic data
• The non-discrimination statement used on all program
materials
• "And Justice For All" poster
On-Site Monitoring
*Important: On-site monitoring is only required if the SFA
has more than 1 building that participates in the NSLP
and/or SBP.
Documents to Review:
Current year on-site review forms
http://www.fns.usda.gov/cnd/governance/PolicyMemos/2011/SP14-2011_os.pdf
Wellness Policy
At a minimum the Wellness Policy must include:
1. Goals for Nutrition Education
2. Goals for Physical Activity
3. Goals for other school based activities to promote wellness
4. Nutritional guidelines for all food sold on campus
5. Goals for Nutrition Promotion
*The wellness policy should be developed by a team that includes,
teachers, food service staff, parents, administration and students
NEW with Reauthorization:
1. SFAs are required to make the Wellness Policy public
2. SFAs must periodically measure the implementation of the policy
3. The SFA must designate one or more school officials to ensure
compliance with the wellness policy
Competitive Foods & A la Carte
1. Ensure that there is no sale of competitive foods and that
foods of minimal nutritional value are not available during
meal service in the serving or dining area.
2. All food sales must be incompliance with the new
guidance for the 2014-2015 school year.
3. Have copies of the nutrition labels of all foods sold within
the school during the school day available for review.
Water
The Healthy Hunger Free Kids Act requires that potable water
be made available to all program participants free of charge
during both breakfast and lunch service.
While observing breakfast and lunch you must ensure that free
water is available for consumption by program participants.
Schools can provide water in a variety of ways:
• Water pitchers and cups on tables
• A water fountain
• Water dispenser with cups in the cafeteria
Food Safety
Food Safety Inspections
•Copy of the most recent food safety inspection must be
posted at each site in a prominent location
• The SFA needs to provide documentation of the two most
recent inspections
Temperature Logs
•For the cooler(s), Freezer(s) and Store room
•For all food that required cooking to an established internal
temperature
•For food that needs to be maintained below 41
Food Safety Plan
Copy should have already been submitted with off-site
assessment, but each site should have a copy maintained on
site.
Record Keeping
As you review other areas, you should be evaluating that the
appropriate reporting and record keeping requirements are
in compliance.
Page 166-167 of the Administrative Review manual list the
common reports and records that the SFA must have on file.
Other Programs
Afterschool Snack Program (ASSP): Ensure that production
records are maintained and all snack items offered are
creditable.
Fresh Fruit and Vegetable Program (FFVP): Have
documentation of products served and detailed claims for
reimbursement.
Special Milk Program (SMP): Pricing Policy, counting and
claiming procedures, milk service procedures and records.
Seamless Summer Option (SSO): Meal counting and claiming
practices, menu planning, and meal service.
Step 5: Administrative Review Report
The reviewer must provide the SFA with written notification
of the review findings:
• Superintendent or authorized representative
• Commendations
• Review findings
• Corrective Action Plan
• Potential for Fiscal Action
• Right to an appeal
How can I have a Great Review?
Team work:
Get everyone involved
Provide in house trainings
Don’t leave it up to just one person
Organization:
Determine the best way to present all the requested materials
Binders, folders, paperclips, hanging files, etc.
Over prepare!!
Double, triple check everything
Read all of the guidance and resources that are available
This seems overwhelming…
• Start early
• Ask questions
• Submit requested information by requested dates
• Be responsive
• Use your team to get prepared
• Don’t wait until the morning of the review
• Stay up-to-date on trainings
Use the Review tools
• All of the administrative Review forms are on the USDA
website
• Do an in house review using the tools
• Make sure you understand the questions and you are in
compliance
Administrative Review Tools:
http://www.fns.usda.gov/cnd/guidanceadminreview.htm
Questions??

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