Kentucky Administrative Review Training

Reinvention 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 specifications, and the 6-cent performance-based reimbursement Implement a 3-year review cycle Provide for off-site monitoring approaches Provide effective training and ongoing technical assistance

New Administrative Review Areas Meal Access and Reimbursement Meal Pattern and Nutritional Quality Resource Management General Program Compliance Other Federal Program Reviews Certification and Benefit Issuance Verification Meal Counting and Claiming Meal Components and Quantities Offer vs Serve Dietary Specifications and Nutrient Analysis Risk Assessment Nonprofit School Food Service Account Paid Lunch Equity Revenue from Non-Program Foods Indirect Costs USDA Foods Civil Rights SFA On-site Monitoring Local Wellness Policy Competitive Water Food Safety SBP and SFSP Outreach Afterschool Snack Program (ASCP) Seamless Summer Option (SSO) Fresh Fruit and Vegetable Program Special Milk

Administrative Review Areas Meal Access and Reimbursement Meal Pattern and Nutritional Quality Resource Management General Program Compliance Other Federal Programs

Administrative Review Steps 1.Letter to Superintendent and School Nutrition Director (SND) 2.School Selection form completed by State Agency (SA) 3.Off-Site Assessment Tool completed by SFA and SA NEW 4.Review schools are selected by SA

Other Site Selection Factors Based on results of: Meal Compliance Risk Assessment Tool (NEW) Resource Management Off-Site Assessment Tool (NEW) Other Federal Programs that are in use, such as Fresh Fruit & Vegetable Program (FFVP), Seamless Summer Option (SSO), etc.

Other Site Selection Factors (cont.) Breakfast Review o ½ of all breakfast o Minimum of 1

Section II: Meal Access and Reimbursement Certification and benefit issuance Verification Meal counting and claiming

Certification and Benefit Issuance SFA provides benefit issuance documents (used at POS) system-wide, for free and reduced price eligible students (NEW) SA selects: o Statistical sample based on the number of eligible students in the SFA (NEW) or o 100% of students on system-wide benefit issuance documents (NEW)

Certification and Benefit Issuance (cont.) SA validates based on: o Free and reduced documentation applications, DC list, homeless list, migrant list, extended eligible student documentation, etc Validation will include at least 10 denied applications

Certification and Benefit Issuance Review Process SFA provides benefit issuance lists for all free and reduced eligible students in district SA reviewer selects sample of free/reduced eligible students from benefit issuance lists SA reviewer validates accuracy of certification for sampled students SA reviewers assesses certification documents – applications, DC lists, etc.

Verification Off-Site Assessment Tool A most recent 742 report will be reviewed by SA On-Site Assessment Tool SA will validate verification process o Including dates o Number selected o Required statements in letters

Meal Counting and Claiming System(s) in use for the SBP and NSLP must provide accurate counts of reimbursable meals, by category. Reimbursable meals are correctly counted, consolidated and recorded at each school and at the SFA Counting and claiming system yields an accurate Claim for Reimbursement

Meal Counting and Claiming On-Site Assessment Tool, School Level Determine site level procedures Observe meal service Review meal counts for review month and day of review On-Site Assessment Tool, SFA Level Determine meal consolidation procedure Review meal count consolidation for all schools in SFA for accuracy

Section III: Meal Pattern and Nutritional Quality Meal components and quantities Offer vs Serve Dietary specifications and nutrient analysis

Meal Components & Quantities

Review Documentations Targeted Menu Review o Menus o Production Records o Standardized Recipes o CN Labels o Nutrition Fact Labels Off-Site Review Period o Menus o Production Records o Standardized Recipes o CN Labels o Nutrition Fact Labels

Offer vs. Serve

Offer vs. Serve Monitoring Adequate amount of food Signage identifies reimbursable meal Students select reimbursable meals Staff are trained and can recognize a reimbursable meal

Dietary Specification and Nutrient Analysis

Off-Site Procedures for Selected Sites Menu certification worksheet(s) submission in InTeam for selected sites (components and pattern) – Not required to complete the Simplified Nutrient Assessment portion of Menu Planning Tool Menu Risk Assessment Tool (assess risk)

Off-site Review Procedures for Targeted Menu Review

4 Options to Assess Dietary Specifications Option 1 Complete Dietary Specifications Assessment Tool (risk- based approach) Option 2 Validate Existing Nutrient Analysis Option 3 Conduct Nutrient Analysis Option 4 SA Proposed Process using Approved 6 Cents Cert. Tool

Section IV: Resource Management Risk Assessment completed by SA Non-profit School Food Service Account Paid Lunch Equity Revenue from Non-program Foods Indirect Costs USDA Foods

Review Approach 1-2 Risk Indicators3-7 Risk Indicators Corrective action and/or technical assistance for the area(s) where risk was identified Resource Management Comprehensive Review

Section V: General Program Compliance Civil Rights SFA On-site monitoring Local Wellness Policy Competitive Foods Water Food Safety SBP and SFSP Outreach

Off-site: Civil Rights Information on the number and description of complaints alleging discrimination in FNS programs for the current and prior school year. Procedures in place for accommodating students with special dietary needs Documentation of civil rights training for staff who interact with program applicants or participants How the SFA collects racial/ethnic data and the frequency for collecting the data. Non-discrimination statement SFA’s public release Information on services for Limited English Proficient households Procedures for receiving and processing complaints alleging discrimination within FNS programs

On-Site: Civil Rights “And Justice for All” poster placed in visible location Children are receiving equal benefits without discrimination at each school during each meal service reviewed Program materials contain the correct non- discrimination statement Determine if denied applications are disproportionately submitted by minority households If applicable, the SA validates corrective action for noncompliance identified through the Off-site Assessment Tool

Local Wellness Policy Submitted off-site Areas of Review o Each site must have a policy or documentation of stakeholder input to the development, implementation and evaluation or review of policy o Documentation of public notification of updates to policy and implementation to policy o Review for minimum required goals for nutrition, physical activity, etc. o Review procedure for LWP assessment and evaluation as well as public notification of ongoing process. o Documentation of oversight person or persons More information to come

Food Safety Includes: o Written food safety plan o Food safety inspections o Record-keeping o Storage Food Safety Inspections o Assessed at each site o Two food safety inspections per school year o Posted in a publicly visible location

Section VI: Other Federal Program Reviews Afterschool Snack Program Seamless Summer Option Fresh Fruit and Vegetable Program