Administrative Reviews at the District Level Quache Spencer | Compliance Director | Office of School Nutrition

Objectives Introduction/overview Changes to the 2017-18 review process What is the administrative review (AR) process? Before the review The week of review After the review Responding to corrective actions Frequent findings Questions

Changes in the 2017-18 ARs Final rule (81-FR 50170): Administrative Reviews in School Nutrition Programs Resource management—risk flags Procurement reviews

What are ARs? A comprehensive evaluation by state agencies (SAs) of school food authorities (SFAs) participating in the National School Lunch Program (NSLP) and School Breakfast Program (SBP), and includes both critical and general areas of review.

What is the AR process? Before the review Notification Site selection Contact from lead reviewer Completion of off- site module The week of the review Review begins Entrance meeting District review Site reviews Exit meeting After the review Begin working on corrective action documents (CADs) Receive the letter of finding and review summary Complete CADs by agreed upon deadline Approve CADs and close review

Dos and Don’ts Do: allow yourself plenty of time to prepare for the AR; include proper staff; contact the lead reviewer and the compliance director with AR questions; complete the 700 Module off–site at least four weeks before the review; organize documentation; and be present the week of review.

Dos and Don’ts (Cont’d.) wait until last minute to prepare; force reviewers to “dig” for information that should readily available; and plan meetings and overbook yourself the week of the review.

Frequent Findings

After the Review Procedures: Documentation: Begin working on CADs Receive the letter of finding and review summary Complete CADs by agreed upon deadline Approve CADs and close review Documentation: Documentation needed to respond to findings Pictures Fliers Letters Menus Signage Corrective actions must have already happened The beginning of the corrective action phase Documentation is determined by findings Lead reviewer will discuss with you what documentation is expected for findings Documentation should be uploaded inside of the actual finding There must be documentation for each finding

Responding to Corrective Action Will start on the compliance section of the module Scroll down and click on the Corrective action documents

Responding to Corrective Action (Cont’d.)

Responding to Corrective Action (Cont’d.) When you open that link you will find all of your findings that require corrective action When you click on the finding itself, you will see where the reviewer documented your finding and the required corrective action Here is where the SFA responds. Here is where you upload your documentation; just like any other attachment, you click on the link, browse for your document and and upload it

Responding to Corrective Action (Cont’d.) Let’s look at a response and what it may look like Talk through the document and what makes it a good response

Responding to Corrective Action (Cont’d.)

Responding to Corrective Action (Cont’d.) The staff will receive training. The training topics will cover: Introduction to school nutrition Providing safe food Forms of contamination The safe food handler Acceptable response? Why or why not? No—Future actions are not acceptable; actions should have already taken place. So let’s see if we can spot a well written response

Responding to Corrective Action (Cont’d.) Since our administrative review, we have included the latest civil rights short statement on all correspondence and documentation. Please find attached copies of our May calendar menu and our revised notification letter. Acceptable response? Why or why not? Yes—The response is in past tense and indicates that there are attachments to demonstrate compliance.

Responding to Corrective Action (Cont’d.) We were unaware of the requirement. We will do better on our next review. Acceptable response? Why or why not? No—Offers no documentation of corrective action.

Questions?

Quache Spencer Compliance Director Office of School Nutrition Quache Quache Spencer Compliance Director Office of School Nutrition Quache.Spencer@tn.gov (615) 532-4740

Mission Statement Develop extraordinary school nutrition professionals and provide strategies to increase consumption of healthy school meals.

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