1. An Overview of Time, Effort, and Resources Needs in the implementation of Public Law 108-265 The Child Nutrition and WIC Reauthorization Act of 2004

2. What’s Different This Time? Many changes directed by The Child Nutrition and Reauthorization Act of 2004 are systemic. Food Services Directors, Business Managers, Superintendents and other district operations need to be informed and involved in the planning and implementation.

3. Areas of Work  Direct Certification  Application Process  Categorical Eligibility  Verification Process  Food Safety  Wellness Policy  Nutrition Requirements  Use of Technology

4. Direct Certification Section 104. Mandatory Direct Certification for Food Stamps Households –2006 >25,000 students –2007 >10,000 students –2008 All Continuing effort to improve our direct certification system in Arizona. Clarification of household eligibility. Taking advantage of the process to reduce applications.

5. Application Process Section 105. Prohibits requiring separate applications for each child in the household. Effective July 1. 2005 Will Require Time, Effort and Resources for Schools Not Currently Using Household Applications. -Distribution of applications. -Record storage area. -Dissemination of eligibility information. -Affects practices of resending applications home by individual student.

6. Application Process Section 106. Eligibility is for the school year + 30 days unless new application filed. New application not required if income changes. Effective July 1, 2004. Applications and letters need revised for 04-05 if new printing needed. Applications and letters for 05-06 must be in compliance.

7. Application Process Section 104. –To extent practicable, in language parent or guardian can understand. –Applications can be made available via the internet and electronic signature accepted. Definition and practice of Meaningful Access aspects. Design capabilities and determine information management process.

8. Categorical Eligibility Section 107. Automatic Free Meal Eligibility for Runaway, Homeless, and Migrant Youth. –Income Application is not required –ADE guidance: CN #04-05 CN #27-05 Impacts –E-rate –Title 1 –Individual School’s Eligibility for Programs Coordination within the district –Record keeping: Food Services Department District (Student Record System) –Informing

9. Verification Process Section 105. Review by someone other than approved application prior to verification notification. Toll free number. Local okay if no charges incurred by parent. Coordination of staff. District long distance or in state local calling charges.

10. Verification Process Timeline change –Base is on applications on file October 1 (previously October 31) –Completed by November 15 (previously December 15 – can request extension to December 15) May change staff allocation of time because applications for new school for those who did not yet apply often peak at this time.

11. Verification Process Sample Size –Same number of the lesser of 3% of all approved applications or 3,000 applications. –MUST be from “error-prone” group Error Prone is defined in the Eligibility Guidance for School Meals. It is within $100 of allowable monthly income and $1200 of allowable annual income.

12. Verification Process Alternative Sample Size Qualification SY2004-05 results impacts SY05-05 qualifying Non-response rate in previous year is less than 20%, or For 20,000+ enrollment, a non- response rate for the previous year was 10% less than preceding year. –May do 3% random or 1% error-prone and ½% categorical eligible. This year counted. Food Services Directors notified by telephone call at end of November. Alternative sample size can significantly reduce the verification burden.

13. Food Safety Section 111. Food Safety Inspections -2 per year required -Local or state agency can increase the requirement -Post in public place and provide copy on request. -State to audit Health Department Inspections through 2009. Effective July 1, 2005 Procedure Development for posting and providing copies. Reporting obligations related to the audit of Health Department Inspections

14. Food Safety Section 111. Food Safety Program to be implemented that complies with the HACCP system established by the Secretary of Agriculture Effective July 1, 2005 No guidance has come forward to this date. Implementation is likely to require time, effort and resources. Adjunct Consideration: Arizona Food Code 2000 requires within 10 years of adoption of the Code, equipment used for holding potentially hazardous food cold must be upgraded or replaced to maintain 41°F. (3-510.16)

15. Local Wellness Policy Section 204. Requires school districts to create a wellness policy by July 2006. Specifies who must be involved in the development. Specifies areas that must be included This is less than 1-1/2 school years at this date to have policy adoption. Goals for nutrition education and physical activity Nutrition guidelines for all foods sold on campus. Nutrition guidelines for school meals will not be less restrictive than federal policy Effectiveness measurement

16. Nutrition Requirements Section 102. Removes the whole milk requirement from the NSLP. Requires a variety of fat content milk be offered. Allows flavored and lactose free milk. Changes in procurement documents Causes changes in weighted nutrient analysis. Can result in reduced % calories from fat

17. Nutrition Requirements Section 102. Districts at their discretion may allow milk substitutes based on a parent’s request if substitute is nutritionally equivalent to milk. Any increased cost is at the school food authority’s expense.

18. Nutrition Requirements Section 102. Bars restricting the sale or marketing of milk at any time or place on the school campus. Effective July 1, 2005 Section 103. Requires USDA to issue guidance and regulations to increase consumption of foods as recommended in the Dietary Guidelines Review and revise contracts Menu development Food Cost

19. Use of Technology ADE must include in its State plan submittal to USDA a description of how technology and information management systems will be used to improve program integrity by: -monitoring the nutrient content of meals -training in use of technology and IMS -use electronic data to establish benchmarks to monitor program integrity, participation, and financial data. New processes

20. Resources Arizona Department of Education Student Health and Nutrition Programs -www.ade.az.gov -Your Child Nutrition Program Specialist -Official Guidance Memos USDA Food and Nutrition Service -Memos to State Agencies and Child Nutrition Programs School Nutrition Association -www.asfsa.org Arizona School Food Service Association