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The NEW Administrative Review

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1 The NEW Administrative Review
Hello everyone and welcome to the video training module on the New Administrative Review. During this webinar, I will be going over the New Administrative Review process that is taking the place of the CRE and SMI starting this coming school year. 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 Remember, new does not always equal scary, it is just different. The Review process is now more meaningful and hopefully more helpful for your program. In change there is power!

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 The review process has been changed to include both off-site and on-site components. The State agency will also be reviewing breakfast, after school snack, and the fresh fruit and vegetable program in addition to the lunch program. It is likely that the State agency will now spend significantly longer periods of time on-site during a review.

4 Revamped Resources New processes uses tools and forms designed to be:
Modular Efficient Flexible Effective Collaborative The new review comes with new tools and forms that are designed to be modular, efficient, flexile, effective, and collaborative. We will go over some of these tools and forms on the next few slides.

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 The Off-site assessment tool will be filled out prior to the on-site portion of the Administrative Review. This assessment includes questions on a number of monitoring areas and will be filled out as a collaborative effort between the State agency and the SFA. There are additional off-site monitoring tools that will help the State agency to determine the risk factors present at the SFA. Meal Compliance Tool targets error-prone areas of the new meal pattern and determines which site is selected for an in-depth menu review. The Dietary Specifications Tool assesses food service practices to determine risk for not meeting the dietary specifications. The Resource Management Risk Indicator tool identifies whether SFAs need an on-site Resource Management Comprehensive Review.

6 Maximizing Resources Also as part of the off-site assessment we will be asking for some of the documents up front, such as the Benefit Issuance List from all schools in advance. You can see from this slide that the new review process is focusing on maximizing resources at the State agency level in order to provide more targeted technical assistance to the SFA.

7 3 Year Review Cycle Review Period 2013 Reviews Special circumstances
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 Reviews will now be conducted every three years. The review period is the most recent month claim submitted and must include 10 or more operating days. This coming school year the SFAs who will be reviewed include any reviews that were postponed this past year and SFAs who were not certified for the additional reimbursement. I will be letting you know which SFA is getting a review at the end of this presentation. We also have to review provision schools a little differently.

8 Just because everything is different doesn’t mean that everything has changed.
Irene Peter Some parts of the review process are the same and some are different….

9 New Administrative Review Areas
A lot of these areas are what we reviewed in the past. (Enter – Enter) We have added more Financial areas, Wellness Policy (Enter) and All Meal Programs (Enter)

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 To begin with, we will send a letter or notification to the Food Service Director and Superintendent notifying them when the review will take place. This will start the process of us gathering the off-site documentation needed for the Off-Site Assessment tools. Using this information, we will select schools to be reviewed and determine which applications (from all schools) to be pulled. We will also be doing some of the review process at our office so we can give you more focused TA while we are with you on-site.

11 On-Site Review Procedures
Entrance Conference On-Site Review Exit Conference The onsite review procedures are the same as before, however, since we will be reviewing more meals, we will be onsite longer. If your review was one day in the past, it might be two days now. For larger districts we may actually be there fewer days because we do not have to review as many applications.

12 Entire School Food Authority
Certification Household Applications and Direct Certification 7 CFR for process Benefit Issuance Roster and Medium of Exchange 7 CFR (c)(1)(ii); (a)(4); (c)(3)(iii); (c)(6)(iii) Verification Meal Counting and Claiming School level review The scope of the review is now at the SFA level. Prior to the review we will ask for the Certification and Benefit Issuance Documents. The State Agency will look at all names (Free and Reduced) and take a statistical sample to pull the names prior to review. WE are looking at the entire SFA in order to ensure program integrity and to make sure that the SFA complies with all program regulations.

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 We will ask for the Benefit Issuance List used from the Point of Service and we will want a list by school and by name, which lists each student’s status (free, reduced or paid)

14 Step 2: Selecting Student Certifications for Review
This is how we will be selecting applications. If you are a school with 700 applications, we need to look at 50%, or 350 applications. We will take your list and using a random number generator, will look at every other application in the list. If your school has 4,800 students, we will look at 580 applications.

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 During the offsite assessment we will be asking you your procedures for approving applications, then when we come on-site we will be verifying that what was said is what is being followed.

16 If you have always done it that way, it is probably wrong.
Charles Kettering You may want to ask your staff how they are doing things to make sure that your procedures are being followed correctly.

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 We will also be looking at your verification files, but which year we look at depends on when we come and review you.

18 Verification Review Documents
Review scheduled for: Validation Review Prior to completion of Verification Summary Report (FNS742) *Previous year Verification Summary Report *Previous year’s verified applications Timeframe that falls BEFORE the Verification Summary Report for the current school year has been submitted BUT after the SFA completed Verification *Previous Year’s FNS742 *Validate the number of applications from the previous school year *Review current year’s verified applications for accuracy After the Verification Summary Report is completed *Use current year’s applications and FNS742 If you have not completed Verification by the time of your review, we look at last year’s verification file. If you are done with verification, but have not submitted your report, we will look at both this year and last year. If you are done with Verification and have submitted your report on-line, then we look at this year’s verification file.

19 Verification Review This is how many applications we have to review. If you have 5 verified applications, we will only have to review 3 of them.

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 All of the information that was provided on the off-site assessment tool will be validated on-site. We will make sure that there is no overt identification of children at the point of service. This means that if the children have a F, R, or P by their name, or if the amount owed shows on the screen, a student could figure out another student’s eligibility status and this counts as overt identification. If only the cashier can see the screen, then there is no overt identification. We will ask about your backup system. The cashier should have a list if the power were to suddenly go off, and we will check it. How have you trained your staff and in what? We will be looking at an agenda with sign-in sheet.

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 We will also observe the staff making the meal. Are they following the standardized recipe? If the recipe does not call for salt, are they adding it in anyway? Are they recording information on the production records? Including what is done with leftovers and seconds? This information does make a difference.

22 Will also make sure you follow the appropriate meal pattern for each age/grade grouping and do not have Trans Fat in any of your products or in your storeroom.

23 Milk Requirements At Least two varieties of fluid milk at breakfast and lunch Fat Free, Flavored or unflavored Low fat, unflavored Are you offering two varieties of milk at breakfast and lunch? Make sure your staff is not requiring any food group that they should not be. They cannot require that a student take milk, that is offer versus serve error now.

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 Make sure all trays have the required amount of fruit or vegetable on them before the adult at the end of the line.

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 We will look at your products and recipes to make sure they are 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 We will make sure that your menus are in compliance with all aspects of the 6 cents reimbursement (if you receive it) or make sure they qualify for the additional six cents if you were not certified for the performance-based reimbursement this past year.

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 We will require that production records containing all of the information on the slide be sent to our office prior to the review.

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 Also during the onsite review we will ensure that all reimbursable meal lines offer all required components, we will make sure standardized recipes are used and followed, we will ensure students have access to and know how to select a reimbursable meal, and ensure that a variety of milk is available to all students.

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 We will ask staff if they know what constitutes a reimbursable meal and make sure each tray contains at least the required amounts of fruits or vegetables. We want to see the signage for the meals at the front of the line. It does not have to be the What’s for Lunch sign, any sign that lists the meal will work, but it has to be present. We will observe students in the line and note if they are being told something different on the day of review. We generally know if things are done differently while we are on site. We will also make sure the staff/cashiers understand offer vs. serve and do not make a child go back for more food/milk.

30 Offer versus Serve Lunch Breakfast After School Snack
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 We must observe both breakfast and lunch at the site. If you have After School Snack and/or the FFVP, we have to observe these programs even if they are not at the school we selected.

31 OVS: Breakfast and Lunch
School Breakfast OVS Must Offer 4 Breakfast Items that include the 3 Breakfast Components: Fruit (or Vegetable Substitute Grain Milk Student may decline: 1 Item Student Must Take: At Least 3 items One component must be fruit or vegetable (SY ) School Lunch Must offer 5 Lunch Components: Fruit Vegetable Meat/Meat Alternate 2 Items Student Must Take At Least 3 components One component must be fruit or vegetable We must also check alternate meal service locations such as breakfast in the classroom and breakfast in the hallway.

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 The site must be in compliance with the meal pattern for both lunch and breakfast Are production records completed accurately? Are properly standardized recipes credible, utilized and maintained? Are nutrition Facts labels available for all products? If a SFA is Low Risk – the SA will observe meal preperation, food storage, evaluate menus, production records, recipes, and other documentation which supports the meals served. For Low Risk SFAs No Nutrient Analysis is required. If what we observe does not support your Low Risk Status we have to move you to High Risk If a SFA is High Risk – the SA will conduct a weighted Nutrient Analysis based on Meals Offered for each age/grade group at breakfast and lunch Seconds served every day counts in the nutrient analysis and can make your calories higher than the required range.

33 Technical Assistance & Corrective Action
Possible Findings: Missing Meal Components Insufficient quantities of Fruits/Vegetables Implementation Staff Training Signage If any of the above findings are noted, we will provide technical assistance and will document it in a Corrective Action Plan.

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 Remember, even if the school selected does not offer the FFVP, we still have to observe at least one site that does operates the program.

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 We will also review the after school snack program. We are going to see if the person doing the afterschool snack has been trained, if you have reviewed them per regulations, if they are counting the children correctly, etc.

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 General areas of review will be observed at each site. Is a copy of the health inspection report at each site and is it available and accessible? Are principles to avoid cross contamination observed at each site? The reviewer can ask for temperature logs for any date up to six months prior to the on-site visit. Has the sponsor sent the request for two health inspections and have they been completed? Is there a HACCP Plan at each site and does it follow regulations?

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 Civil Rights requirements are the same as before. You must have an “And Justice for All” poster displayed in a prominent location, program material must have the correct non-discrimination statement included, you must have a civil rights policy and procedure, and it must be documented that your staff was trained on civil rights.

38 Local School Wellness Policy
FNS Memo SP 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? We will check your wellness policy – remember at renewal when we ask the last time it was reviewed? If you recorded 2006, that would be a problem. The rules have changed and more frequent updating is necessary. Also, is the wellness policy posted on your website?

39 Resource Management Maintenance of the Nonprofit School Food Service Account Indirect Costs Paid Lunch Equity Revenue from Non-Program Foods USDA Foods The Resource management part of the review will include some items that were not reviewed before. The State agency will ask for a years worth of revenue and expenses to make sure you are being credited/charged correctly. We will also ask if the district charges for Indirect Costs. We will check the PLE tool that you submitted during renewal and make sure that your prices reflect what you entered on the PLE. We will look at whether you keep track of revenue from non-program foods using the USDA tool. We will also determine whether you utilize USDA foods to the maximum extent practicable. I will go over these in depth in the next few slides

40 Maintenance of the 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. Nonprofit status does not require that the SFA operate at a break-even or loss. The state agency must ensure that SFAs observe the regulatory limitations on the use of nonprofit school food service revenue. We will identify revenue in excess or shortfall. W will also test actual expenses for compliance with allowable cost requirements based on the financials you sent before the review. We will identify and correct unallowable costs and ensure costs are adequately documented and are treated consistently.

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 We will select a sample of at least 10% of the SFAs expenses to test compliance and allowability. So if you have 100,000 in expenses = we would check 10% of them $40,000 in food – we will check $4,000 $50,000 in labor – we will check $5,000 $10,000 other = we will check $1,000 We will also ensure costs are reasonable and necessary for program functions. Review actual invoices and receipts as necessary Identify unallowable costs

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. WE will check your PLE calculations and the 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, such as the General Fund, to Food Service to make up for not increasing prices. Any payments provided by parents is NOT considered a non-federal source. These payments must go to food service in support of the meals. Make sure that Adult payments are not included in the calculations.

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 Non-Program foods are foods and beverages sold in a participating school that are purchased using funds from the nonprofit food service account In other words – ANYTHING you purchase from the food service account to sell to anyone other than a reimbursable meal for a child. The intent is that with the exception of reimbursable meals, all foods sold must generate revenue at least equal to the cost of such foods.

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? If you don’t use the USDA Revenue from Non-programs Foods tool to calculate non-program food costs and revenue, and you sell a la carte foods, you are considered a risk for noncompliance with federal requirements. This will automatically give you one risk factor point.

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 Adult meal prices should include the value of any USDA entitlement and bonus donated foods used to prepare the meal. Do your Adult meal prices fall within these guidelines?

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 The State agency will ensure SFAs are correctly determining if their costs are allowable, allocable, and appropriately charged as a direct or indirect cost. Examples of Direct Costs include wages and salaries of food service, the cost of food purchased, and food service supplies and equipment. Indirect Costs include Payroll services, human resources, workers compensation, electricity, gas, and trash (unless you have a separate meter or dedicated dumpster) We also must determine if costs are treated consistently within the SFA. The SFA cannot charge Food Service indirect if they do not charge other federal programs an indirect rate. If you never see your income and expenses, you will now, and so will we. We also must see the source documents for any of these charges that hit your account. If there are charges that should not be there, we will require the General Fund to replace the money.

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 Just because a SFA is contracting with a FSMC, it does not absolve them of their monitoring duties. When we come to do the review we will 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. We will 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 We will give you something at the end of the review telling you what you must correct. If you miss that deadline, we must assess fiscal action as if the problem occurred during the entire year. This may be a large hit to your bottom line….

49 Withholding Payments Regulatory Authority
Authority for Withholding Payments as a result of Administrative Review (7 CFR (l)) Authority for Withholding payments (7 CFR ) We will also stop paying you until you correct the problem. And we will make sure the problem stays corrected in future reviews.

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 The state agency can withhold payments if the SFA has failed to submit documented Corrective Action by the specified due date, if The SA finds Corrective Action was not completed, or if the SFA continues to have the same problems with the same cause. Payments are withheld until the State agency determines that Corrective Action was properly implemented by the SFA

51 Fiscal Action Applications missing information
Miscategorization of Certification Benefit Issuance Errors Failure to update verified applications If applications are missing information, we find miscategorization of certification, benefit issuance errors, or failure to update verified applications, we will take fiscal action. Remember to fix these issues immediately. When we leave your district, it does not mean everything is done. Make sure you follow up with corrective action.

52 Fiscal Action Missing Meal Components Vegetable Subgroup & Milk Type
Immediate fiscal action required Vegetable Subgroup & Milk Type Fiscal Action required for repeat violations Quantities & Whole Grain Rich Fiscal action discretionary for repeat violations Fiscal action will be assessed for missing meal components. Fiscal action is required for repeat violations of vegetable subgroup and milk type. Fiscal Action is discretionary for repeat violations of quantities and whole grain-rich issues. For Meal Components and Quantities, A REPEAT VIOLATION includes: Any finding at the SFA level, meaning that a subsequent similar problem at a different site within a SFA was found in a follow-up or subsequent Administrative Review. Any findings at a follow-up review or subsequent administrative review A repeat violation of any of the same meal component requirements (milk type, vegetable subgroup, or whole grain rich) or quantities. FOR EXAMPLE: red/orange vegetables not offered at the initial administrative review. At the next review leafy green vegetables are not offered. This would be a REPEAT vegetable subgroup finding

53 SFA’s to be reviewed These are the SFA’s will be reviewed in the school year. There are 66 SFA’s with 82 sites. 22 in the Eastern part of the state; 18 in the SW portion of the state; 11 in the Twin Falls region and 14 up North. When we send you the review letter, please do not call immediately to reschedule. We are not fortunate enough to have that latitude to be able to move things around as much. We may also start reviewing in October this year. Sugar Salem SD

54 Thank you Never doubt that a small group of committed people can change the world. Indeed, it is the only thing that ever has. - Margaret Mead If you have any questions or concerns regarding the new Administrative Review process, please do not hesitate to call the Idaho State Department of Education Child Nutrition Programs. Thank you for participating in the webinar, I hope you have found it informative.

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