1. Wyoming Department of Education June 2013 Terry Walling ~ Tamra Jackson

2. Reinvention Goals The Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process Consolidate the Administrative Review process Incorporate school breakfast, the new meal pattern, and dietary specifications, and the 6-cent performance-based reimbursement Wyoming Department of Education 2

3. Reinvention Goals Implement a 3-yr review cycle Provide for offsite monitoring approaches Provide effective training and ongoing technical assistance Wyoming Department of Education3 I run six-to-eight miles a day, plus weights and aerobics in the lunch hour. I also lie a lot, which keeps me thin.I run six-to-eight miles a day, plus weights and aerobics in the lunch hour. I also lie a lot, which keeps me thin. Hugh LaurieHugh Laurie

4. Revamped Resources New process uses tools and forms designed to be: Modular Efficient Flexible Effective Collaborative Wyoming Department of Education 4

5. Maximizing Resources Wyoming Department of Education 5 CRE ApproachNew Approach Primarily Conducted On- Site Process structured to be conducted off-site and on-site: Off-site Assessment Tool Risk Assessment Tools New Approach allows for: Office staff assistance Application of risk indicators Better balanced workload and preparation More on-site technical assistance

6. The “New” Process On-Site Review Validation Questions Off-Site Assessment Tool Evaluation Questions Wyoming Department of Education 6

7. Off-Site Components Advantages Flexibility Use of specialized staff Reduced staff time Off-site monitoring tools Off-site Assessment Tool (SFA and SA) Compliance Risk Assessment Tool (SA) Dietary Specifications Assessment Tool (SA) Resource Management Risk Indicator Tool (SA) Wyoming Department of Education 7

8. Off-Site Assessment Tool Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit Feedback from USDA testing: Tool encourages SA and SFA to work collaboratively and helps 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 will better understand why they are providing that information SA has more time to review documents thoroughly, conduct reviews more consistently, and provide ongoing technical assistance to the SFA Wyoming Department of Education 8

9. Off-Site Assessment Tool Review a section of the Off-Site Assessment Tool with the class Walk them through some questions and discuss/give examples of how they might answer the question. Note the ordering of the questions Wyoming Department of Education 9

10. Off-Site Monitoring Tools Meal Compliance Risk Assessment Tool 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 meeting the Dietary Specifications Resource Management Risk Indicator Tool Identifies whether the SFA should receive a comprehensive resource management review Wyoming Department of Education 10

11. Performance Standards Critical Areas Performance Standard 1 Certification and Benefit Issuance Meal Counting and Claiming Performance Standard 2 Meal Components & Quantities Wyoming Department of Education 11

12. Performance Standards General Areas Resource Management General Program Compliance Verification Wyoming Department of Education12

13. Review Period Most recent month claim submitted, must include > 10 operating days Period of On-Site review Special Circumstances Reviews early in the school year Year-round, multi-track & provision schools May require FNS approval or special procedures Wyoming Department of Education 13

14. Pre-Visit Procedures Notify superintendent and food service director Initiate Off-Site Assessment Tool Review SFA documentation Obtain pre-visit information Select NSLP sites for review Wyoming Department of Education 14

15. On-site Review Procedures Entrance Conference On-site Review Exit Conference Wyoming Department of Education 15

16. Review Frequency & Schedule Review Frequency SFA must be reviewed every 3 years Cycle begins July 1, 2013 Review Schedule SA discretion Postponed reviews Non-compliant SFAs Wyoming Department of Education 16

17. Data for Site Selection Site name Site type Number of serving days Number of eligible for free meals Number of free meals claimed Wyoming Department of Education 17

18. Minimum Number of Review Sites # of Sites in the SFA Minimum # of Sites to Review for NSLP # Sites in SFAMinimum # of Sites to Review for NSLP 1 to 5141 to 606 6 to 10261 to 808 11 to 20381 to 10010 21 to 404101 or More12* * 12 plus 5 percent of the number of sites over 100. Fractions must be rounded to the nearest whole number Wyoming Department of Education 18 Review all sites (except RCCI) with free ADP of 100 and free participation factor of ≥100%

19. Criteria for Additional Sites Additional NSLP sites: Elementary sites with ≥ 100 free ADP and ≥ 97% free participation Combination sites with ≥ 100 free ADP and ≥ 87% free participation Secondary sites with ≥ 100 free ADP and ≥ 77% free participation State Agency Criteria Wyoming Department of Education 19

20. Additional Site Selection Requirements Dietary Specifications and Nutrient Analysis Meal Compliance Risk Assessment Tool School Breakfast Program 50% of selected NSLP sites Other Federal Program Reviews Varies based on regulations Resource Management Offsite Assessment Tool Wyoming Department of Education 20

21. Wyoming Department of Education 21 Meal Access & Reimbursement Nutritional Quality & Meal Pattern Resource Management General Program Compliance Other Federal Program Reviews Certification & Benefit Issuance Dietary Specs & Nutrient Analysis Risk Assessment Civil RightsAfter-school Snacks VerificationMeal Components & Quantities Nonprofit School Food Service Account SFA On-site Monitoring Seamless Summer Option Meal Counting & Claiming Offer versus Serve Revenue from Non-program foods Local Wellness Policy Fresh Fruit & Vegetable Program Paid Lunch Equity Competitive Foods Special Milk Program Water Food Safety SBP & SSO Outreach New Administrative Review Structure

22. Certification & Benefit Issuance Verification Meal Counting and Claiming Wyoming Department of Education 22

23. Why Review? Ensuring Program Integrity SFA Compliance with Regulations Wyoming Department of Education 23

24. Off-site Assessment Certification and Benefit Issuance Question set 100s Verification Question set 200s Meal Counting and Claiming Question set 300s Wyoming Department of Education 24

25. On-site Assessment Certification and Benefit Issuance Validate SFA’s Procedures from off-site assessment tool Validate Student Certifications: Validate Benefit Issuance Document Review Denied Applications Verification Determine compliance with Verification requirements Meal counting and Claiming Validate off-site assessment tool Validate the counting and claiming process Record errors Wyoming Department of Education 25

26. Fiscal Action Certification and Benefit Issuance. Why is Fiscal Action taken?  Applications missing information  Mis-categorization of certification  Benefit Issuance Errors  Failure to update verified applications Verification No fiscal action taken Meal Counting and Claiming Inaccurate meal counting or claiming Counting errors include: meal counts to not equal number of meals served to eligible students, second meals were counted, meal counts exceed number of eligible students by category Wyoming Department of Education 26

27. Meal Components & Quantities Offer vs. Serve Dietary Specifications & Nutrient Analysis Wyoming Department of Education 27

28. Why do we review Meal Components & Quantities Support Learning & Educational Achievement Provide students with well-balanced meals Combat childhood hunger Nutrition Education Teach students components of a well-balanced meal, variety Stewardship of Federal $ Ensure that meals reimbursed with Federal $$ contain required components Wyoming Department of Education28

29. Overview 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 Wyoming Department of Education 29

30. Meal Components & Quantities Assess meal pattern compliance Milk, Vegetable subgroups, whole grain rich requirements, etc Review breakfast and lunch documentation for compliance Menus/production records Performance-based reimbursement documentation (USDA worksheets) Week must be 3-7 consecutive days Missing meal components/insufficient quantities: expand documentation review to (at least) entire review period Wyoming Department of Education 30

31. 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 Wyoming Department of Education 31

32. On-site Meal Service Observation Prior to Meal Service Will ensure all reimbursable meal lines offer all required components Will observe meal preparation During the Meal Service Will observe % of meal service for each line Will determine if meal contain components & quantities for age/grade group Will ensure students have access to, and know how to select a reimbursable meal Wyoming Department of Education 32

33. Offer vs. Serve The WDE Child Nutrition Programs 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; and 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. Wyoming Department of Education 33

34. OVS: Pre-visit: Documentation Review Review OVS Policy Optional OVS Edit Check Total # of Food Components or Food Items Total # of Meals served Wyoming Department of Education 34

35. OVS: On-site: Prior to Meal Service WDE CNP Determines whether: Staff training has been conducted Staff understands what constitutes a reimbursable meal; Staff understands the number of required meal components/food items for a reimbursable meal; Staff properly distinguish reimbursable meals from a la carte purchases; and, Signage has been posted explaining OVS to students Wyoming Department of Education 35

36. OVS: On-site: Meal Service Observation WDE CNP Determines whether: Meals selected by students contain a minimum of 3 food components (NSLP) or food items (SBP) as the students exit the meal service line; Each reimbursable meal contains at least ½ cup of fruits or vegetables; Food service staff are accurately judging quantities when the school utilizes service stations, theme bars, and/or self-serve bars; Students understand OVS; and Food service staff/cashiers understand OVS Wyoming Department of Education 36

37. Dietary Specifications & Nutrient Analysis - Overview Determine if SFA is serving reimbursable meals according to Dietary Specifications Calories Saturated Fat Sodium Trans Fat Determine if a one week weighted nutrient analysis is required for each USDA established age/grade group and menu type offered at a lunch and breakfast for one site in the SFA Wyoming Department of Education 37

38. Maintenance of the nonprofit school food service account Revenue from non-program foods Indirect costs USDA Foods Wyoming Department of Education 38

39. Off-site Assessment Tool Resource Management: Question set 700s Maintenance of Nonprofit School Food Service Account Questions 702 – 706 Paid Lunch Equity (PLE) Questions 707 – 710 Revenue from Non-program Foods Questions 711 – 712 Indirect Costs Questions713 – 714 USDA Foods Questions 715 - 717 Wyoming Department of Education39

40. Resource Management Risk Indicator Tool State Agency conducts a risk assessment based on off-site assessment tool 1-2 risk indicators  Technical Assistance and Corrective Action 3 + risk indicators  USDA Comprehensive Review All Resource Management monitoring areas State agencies to consult with State USDA foods staff Wyoming Department of Education 40

41. Civil Rights Local Wellness Policy Food Safety Wyoming Department of Education 41

42. Off-site Assessment Tool: Section V Civil Rights Question set 800s SFA On-site Monitoring Question set 900s Local School Wellness Policy Question set 1000s School Breakfast and Summer Food Service Program Outreach Question set 1600s Wyoming Department of Education42

43. Food Safety General areas of review Written food safety plan Food safety inspections Recordkeeping Storage State Agency to determine if regulatory requirements are being met Corrective Action Each area assessed at the site level If all schools compliant, SFA compliant Corrective action prescribed as necessary Wyoming Department of Education 43

44. Civil Rights – Scope of Review Off-site Assessment SA obtains SFA responses to the Off-site Tool If necessary, clarification provided If noncompliant, the SA provides TA and if necessary, prescribes corrective action On-site Assessment If necessary, validate CA on-site if non-compliance is detected by Off-Site Assessment Tool Ensure the USDA “And Justice for All” Poster is displayed in a prominent location and visible to program students During meal observation on day of review, determine if all program students had equal access to the program without discrimination Ensure program materials contain correct non-discrimination statement Determine if denied applications are disproportionately submitted by minority households Wyoming Department of Education 44

45. Local Wellness Policy HHFKA added new provisions Changed content requirements Required certain actions LWP portion of administrative review changed to address HHFKA and FNS Memo SP 42-2011 Deficiencies handled through TA only No final rule Limited implementation guidance Assess progress and provide implementation suggestions No LWP = Corrective Action Complete Off-site Assessment tool questions Wyoming Department of Education 45

46. Fresh Fruit and Vegetable Program Afterschool Snack Program Wyoming Department of Education46

47. Off-site Assessment Tool: Section VI Other Federal Programs Indication of any additional federal programs that will be examined during the review Afterschool Snack Program Fresh Fruit and Vegetable Program Special Milk Program Wyoming Department of Education47

48. FFVP Review Three components to the FFVP review process Establishing the FFVP review sample size (WDE) Claim validation One month’s claim is validated per site Any month can be selected Check status of administrative costs FFVP meal service observation Occurs at each FFVP site Fiscal Action must be used to recover any payments in whole or in part, that is inconsistent with FFVP requirements Wyoming Department of Education 48

49. Afterschool Snack Program: Evaluating Compliance 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 Wyoming Department of Education 49

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51. Post Review Procedures Administrative Review Exit Conference Administrative Review Report (i.e., Notification Letter of Review Results Documented Corrective Action Wyoming Department of Education51 Intent/Scope Corrective Action Plan Documented Corrective Action Fiscal Action Review Findings Corrective Action/CAP Timeframes Fiscal Action Intent/Scope Documented CA/Written Notification Timeframes

52. Wyoming Department of Education52 Thank You!! Questions?