Onsite Monitor Reviews SBP & NSLP Learning Code: 3310 Meal Counting, Claiming and Managing Funds Kentucky Department of Education School and Community Nutrition September 2016

What is an On-Site Monitor Review? The on-site monitor is an evaluation of the breakfast and lunch counting and claiming procedures at each school. The purpose of this monitoring requirement is to ensure that any issues with meal counting and claiming are identified and corrected.

When are you required to conduct an On-Site Monitoring Review? Sponsors with more than one site are required to conduct a review, each school year, prior to February 1st. Both breakfast and lunch meals require an onsite monitoring review. BEST PRACTICE SUGGESTION: It is recommended to conduct the review early in the year to catch any potential issues.

Who should conduct the onsite Review? Reviews must be conducted by an individual that does not typically work at the reviewed site. Familiar with the meal counting and claiming procedures specific to each school. Understand meal counting and claiming requirements.

How are the onsite reviews conducted? Onsite review form - available on SCN’s website on the forms page. Reviewer must be present throughout the entire meal service and evaluate the procedures used to obtain the days meal counts. Only one monitor review each day per reviewer can be conducted.

Onsite Review Form Provide a response to all questions. Don’t leave anything blank. Be sure to evaluate all meal counting processes that are counted for claiming, not just the meals counted by your electronic POS in your cafeteria.

What to do if problems are identified If any questions are answered with a “NO” a corrective action plan is mandatory. Determine the appropriate corrective action to address the problem (document on form) and the timeframe in which to complete. A follow up review is required to be conducted within 45 days to determine that the corrective action is implemented and has adequately addressed the problem. *Corrective action is not a penalization, it is a way to ensure that your program is in compliance.

Let’s Take a Look At The Questions 1. Is the method used for counting reimbursable meals in compliance with the approved “point of service” requirement. (Meal counts must be taken at the location where complete meals are served to children.) Determine if the methods used to count meals are counting reimbursable meals by category through a point of service. Evaluate all locations where meal counts are taken including classrooms and other alternate locations.

The following is a list of UNACCEPTABLE meal count practices 1. Meal counts taken at the beginning of the service line 2. “backed out” systems that subtract one number from the total meal counts to get another number 3. Cash “backed out”- dividing total cash received by the meal price to determine meals sold 4. Tray or plate counts (counting the trays before being served and see how many are leftover at the end of the service) 5. Meals not checked for all components (meals not checked to see if they meet the meal pattern requirements) 6. Morning/classroom counts (taking counts in the classroom before students are served) 7. Attendance records (using attendance records instead of point of service to determine reimbursement count)

2. Is the point of service meal count used to determine the school’s claim for reimbursement? Determine if the meal counts obtained through the points of service are correctly recorded on the end of the day report and if the meal count totals on the reports are the number of meals that are claimed for reimbursement. (No further consolidating, etc.)

3. Is the person responsible for monitoring meals correctly identifying reimbursable meals for the menu planning option selected by the SFA? OVS is properly implemented for the grades indicated on site application. Ensure cashiers are only counting meals that meet what is planned to be a reimbursable by the menu planner. Example, may plan a non-whole grain rich item to be an “other” and not count towards the bread/grain requirement for that meal service.

4. Is the school correctly implementing policies handling the following (as applicable): Incomplete meals? Second meals? Lost, stolen, misused, forgotten or destroyed tickets, tokens, IDs, PINs? Visiting student meals? A la carte? Field Trips? Student Worker Meals? Charged and/or prepaid meals? Offer vs Serve? Adult and non-student meals (and identifying program vs. Nonprogram)? The reviewer should read the school’s meal counting and claiming procedure to ensure that all processes are being followed as written.

5. Is there a method of identifying non-reimbursable meals (i. e 5. Is there a method of identifying non-reimbursable meals (i.e. not meeting meal pattern requirements, seconds, adult meals, etc.) distinguishing them from reimbursable meals? Determine if there is a method of identifying non-reimbursable meals (i.e. meals not meeting the meal pattern requirements, seconds, adult meals, a la carte items, etc.) which are not included in the reimbursable meal count. Those identified as non-reimbursable meals should not be included in the reimbursable meal count and claimed for reimbursement.

6. Is someone trained as a backup for the monitor and the meal counter? Determine if the school has multiple staff properly trained to monitor and count meals by category (free, reduced price, and paid). This is required in case a substitute is needed.

7. Are there procedures for meal counting and claiming when the primary counting and claiming system is not available and do staff know when and how to implement it? Determine if there is a back-up system in place if the main meal counting and claiming system is unavailable. Make sure the staff is fully trained in the utilization of the system.

8. Are daily counts correctly totaled and recorded? Determine if the meal count reports submitted for reimbursement are accurate. The reviewer should make sure the individual school meal counts, by category recorded for claiming a daily, weekly, or monthly basis are accurate. The counts by category should be reported in a way that can be easily read, edited, and consolidated into an accurate monthly claim for reimbursement. Counts should be auditable. All source documentation maintained.

9. If claims are aggregated, are the meal counts correctly totaled and consolidated? Determine if the monthly claim figures for each school matches the monthly claim figures on file at the sponsor level. Evaluate if the daily meal counts correctly total to the monthly number of meal counts claimed for this school site.

10. Are internal controls (edits, monitoring, etc 10. Are internal controls (edits, monitoring, etc.) established to ensure that daily counts do not exceed the number of students eligible or in attendance and that an accurate claim for reimbursement is made? Record today’s meal count by category and compare to the number of students eligible by category. Record the number of students approved by category on the day of review and the number of meals claimed by category in the space provided. Review previous reports to ensure that student total edit checks were conducted.

11. Does the system prevent overt identification of children receiving free or reduced price meals? While observing the meal services, determine if it is possible to determine a child's eligibility status. Observe the screens of electronic POS systems, review rosters used, etc.

Examples of Overt Identification 1. Unacceptable coding system (using P, F, and R to identify students); 2. Availability of tickets/tokens only available to specific categories such as paid students only); 3. All cash line (specific lines for categories such as a line for paid students only); 4. Visual or vocal ID (others can see or hear if a child is paid, free, or reduced); or 5. Serving lines limited (free or reduced kids are unable to go through certain lines such as a premium meal line)

12. Is a current eligibility list kept up-to-date and used by the meal count system to provide an accurate daily count of reimbursable meals by category (free, reduced price, paid)? Evaluate whether or not rosters and changes in eligibility status are kept current on a daily basis. *Question is not applicable to CEP schools and RCCI’s with only residential children.

13. If applicable to 7 CFR 210.8(a)(3), are edit checks completed and documented which compare the daily counts of free, reduced price and paid lunches against the product of the number of children currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor (and any discrepancies accounted for)? Review edit check documentation for previous meal services – for each meal, explanation when meal counts are higher than anticipated. Observe school staff conduct an edit check on the day of review to ensure that it is completed correctly. *Question is not applicable to CEP schools and RCCI’s with only residential children.

Don’t Forget to sign and date the Form! The review form must be signed by both the reviewer and the manager of the site reviewed.

Best Practice Tips 1. Plan to spend the some time at the site! 2. Watch other programs as well such as Afterschool Snack.

Record Keeping Requirements All records and documentation should be kept on file for three years plus the current year including any corrective action related documentation and follow up reviews.

Resources and Questions? The USDA Meal Counting and Claiming Handbook is available on SCN’s website on the guidance and resource page. Direct any questions to your approving consultant. Thank you!

USDA Non-Discrimination Statement: In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.  Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits.  Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339.  Additionally, program information may be made available in languages other than English. To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; (2)  fax: (202) 690-7442; or (3)  email: program.intake@usda.gov. This institution is an equal opportunity provider