Counting, Claiming and CEP – The 3 C’s 4/15/2017 SNT Pre review Workshops 2014 Counting, Claiming and CEP – The 3 C’s Correctly counting and claiming procedures are critical for the success of your school nutrition program. The new CEP option is one way of streamlining the administrative paperwork and reducing the amount of paperwork required for participation. However it is equally important that you are able to submit accurate claims regardless of the program and systems that you have in place. This breakout will offer guidance for successfully managing the counting, claiming and if you are participating the Community eligibility option of USDA’s child nutrition programs. Welcome to the 3 C’s …

MEAL COUNTING Eligibility Documentation Collection Procedures 4/15/2017 MEAL COUNTING Eligibility Documentation Collection Procedures Point of Service Meal Counts Meal counting is the most important step for accurate claiming. The steps involved include eligibility documentation, the SFA’s collection procedures and the all important point of service meal counts. Let’s look at each in detail.

ELIGIBILITY DOCUMENTATION 4/15/2017 You must have documentation supporting the eligibility of each student receiving free and reduced priced meals. Free/reduced price meal household application Direct certification list Public schools only – certified list of homeless, migrant, foster or runaway There are several ways that students may be determined eligible for meal benefits. They include …

COLLECTION PROCEDURES 4/15/2017 COLLECTION PROCEDURES Steps Receiving payments for meals from students Issuing and collecting the medium of exchange Policy for handling meal charges and unpaid accounts Medium of exchange: Cash Ticket Token ID Name Number List the steps involved explain that each must be handled in a specific manner Discuss the mediums of exchange – each acts as money for the student when they purchase their meal.

Collection Procedures 4/15/2017 Collection Procedures Overt Identification: Eligibility must never be publicized or used in such a way that students’ eligibility may be recognized by other students or staff. Must be prevented during issuing and collecting of the medium of exchange. USDA and DPI take this very seriously. When we audit schools we must ensure that students receiving meal benefits are not identified in any way.

Overt Identification… What do you think? When the reviewer visits your school he/she observes the following: A. The computer, visible to students, shows how much a student is charged for meals. If students or faculty or others are able to see how much a student is charged for lunch this is overt ID. B. Student check lists used by the teacher have free students highlighted in yellow and reduced students highlighted in green for easy identification. This would be considered overt ID. USDA requires that only those who have a direct need to know have access to the information. C. A student comes up to the reviewer during the onsite visit and says loudly “I get free meals” This is called “self disclosure” and the school is not held responsible.

Point of Service Meal Count Systems Electronic Debit Bar Codes Personal identification numbers (PIN) Tickets Check-off List Discuss when you can deny a meal because of no money. Folder – Financial Q&A – Question 3 talks about bad debt and the fact that it cannot be charged to foodservice account. Question 1 talks about donations earmarked to help with student accounts. Let them know that this Q&A was also printed in the SNT Spring Newsletter, and can hold up a copy. Take a little time to discuss their meal charging policies (or lack of). – Can let them know that this is a question on the new AR assessment.

Point of Service (POS) The point where it can be determined that a student has received a reimbursable meal, after having been offered all of the required components. (end of line)

Alternate to the Point of Service Meal count is taken at the beginning of the line, with another adult at the end of the line monitoring the student’s tray to ensure that they have a reimbursable meal. The system must be able to verify that students receive a reimbursable meal. Non reimbursable meals must be subtracted from the day’s meal count. The online contract will specify the POS Point out that on-line contract should reflect their meal accountability system including whether meal counts are taken at the end or beginning of the line. Have them look at their SFA Policy Statement page on their contract when they get back to school to see what they have indicated with regard to POS.

POINT OF SERVICE MEAL COUNT 4/15/2017 POINT OF SERVICE MEAL COUNT Procedures must guarantee that meals will: Meet meal pattern requirements for the specific grade grouping and offer versus serve option indicated on Schedule A of the on-line contract for your agency/site. Are served to eligible students (only one lunch per eligible student per meal service may be claimed for reimbursement). Are counted daily by category (free, reduced price and paid).

Point of Service is Required for All Programs including… Special Milk Program ½ day students who do not have access to school breakfast or lunch. Wisconsin School Day Milk Program School Breakfast Program Afterschool Snack Program National School Lunch Program Sack lunches or meals served away from POS

4/15/2017 POS -What Do You Think? During the onsite visit the reviewer observes the following… A. Kindergarten children go through the line but the teacher already has the milk on the table at their place. All components must be available to students prior to the POS . B. An aide comes to the cafeteria and hands a list of students to the foodservice and picks up food for the classroom. Meals must be counted at the time a student receives the meal. In this case a classroom checklist, completed in the classroom, would be necessary to ensure the student received a reimbursable meal. C. A teacher brings all of the cards to be scanned to the cashier. The children go through the line and the bundle is scanned after lunch when it’s not so busy. Meals must be counted as students receive the meal. D. A student tells the monitor that they will pick up a fruit or vegetable at the salad bar located in the middle of the cafeteria. All components must be available to students prior to the POS or alternate authority agreement monitor. C. A monitor could verify that each student has received a reimbursable meal.

Meal Counts by School The number of “schools” or “sites” for your agency is based on the number of “schools” listed on Schedule A of your on-line contract. There may be more than one “school” within a building. You must be able to retrieve meal counts for each “school” serving meals. Individual School counts drive Severe Need breakfast eligibility. Want to remind participants that getting meal counts by school is required and critical for applying for severe need rates for SBP and will be required for all sites once we go to site based claiming. Individual school counts also drive SN breakfast numbers. During the AR the consultant will check that the numbers you report for each school on schedule A agree with the number of meals you reported in the second preceding year to verify eligibility of SN breakfast.

UNACCEPTABLE MEAL COUNT SYSTEMS 4/15/2017 Attendance counts: using the number of students in attendance as a meal count Tray or entrée counts: counting the number of trays or entrees used during the meal service to obtain or validate the meal count Classroom counts: counting the number of students in class, prior to meal service, who intend to order and/or eat a meal

OTHER UNACCEPTABLE SYSTEMS 4/15/2017 OTHER UNACCEPTABLE SYSTEMS Counts taken anywhere other than the point of service. Cash converted to meals: using cash totals to determine the number of meals served Category/cash back-out system: one or more of the meal categories are calculated by subtracting the number of meals of one or more meal categories from the total meal count Delivery counts of meals produced off-site: the number of meals delivered to a school is not necessarily the number of meals that were actually served

4/15/2017 Reimbursement Claims Your reviewer will ask to see the most recent claims* and supporting documentation for each program your SFA participates in *The reviewer may also ask to see Claims from other claim periods. It is important to have the documentation assessable The reviewer may also ask to see claims from other months

All claims must be based on Accurate daily Point of Service meal counts (free, reduced and paid) by school Attendance adjusted edit check on each school’s daily meal counts Accurate consolidation of meal counts Accurate submission of monthly claim electronically These are the steps to submission of accurate claims. We will be going through each on of these in detail in the next slides. Explain that when we go to site based claiming, they will no longer have to consolidate their site claim

Meal Counting and Claiming Common Findings Counts are obtained using improper procedures Are not split out by school Incorrectly combined and consolidated Not completed daily Contain questionable patterns All meal counting and claiming systems must: consistently provide an accurate count taken daily at the point of service by eligibility category taken at each meal service be monitored and checked for inaccuracy Point of Service/Meal Counts: Remember that all meal counting and claiming systems must consistently provide an accurate count. Systems that rely on plate counts, head counts, attendance rosters, entrée counts, etc do not provide accurate counts. Meal counts must be taken at the point of service where it can be verified that a reimbursable meal has been taken by the student and can be claimed for reimbursement. This includes meals served outside of the cafeteria, such as in the classroom or hallway. Meal counts must be taken daily by eligibility category at each meal service. Schools must also track non-reimbursable meals, such as meals served to school staff members, food service employees, visiting adults, visiting students, and food sold a la carte. Meal counts must be monitored at the school/site level as well as the CN office level for inaccuracies. Example 1: A cashier using a computerized system daily keys in a generic free number for a son/daughter to provide the student with free meal benefits. Example 2: Using a paper system, the meal counts (checks, X’s, etc.) are miscounted, resulting in an under- or over-claim. Example 3: Meal count are not documented on a daily basis. Using a computerized system, the day is not “closed,” allowing information for the day to be altered. Using a paper system, the daily meal count may be manipulated without accurate reference to actual participation. Patterns in meal counts identify areas of concern. Look for constant counts (same number of meals every day), extremely high free-eligible participation every day, counts that seem to repeat patterns, and meal counts that are the same as the delivery counts.

4/15/2017 REPORTS Numbers of daily reimbursable meals, for each category (F,R,P) to eligible students are recorded for each site. Recording method must ensure that correct counts by category are reported in a way that is easily read, edited and consolidated (if more than one site) into an accurate online monthly claim for reimbursement. The SFA must be able to provide claims documentation for any time periods requested by the reviewer. SFAs must maintain all program records for a period of 5 years

4/15/2017 INTERNAL CONTROLS Established to ensure that an accurate claim for reimbursement has been made Protects schools from potential claiming errors

The Edit Check Document 4/15/2017 The Edit Check Document Compares meal count data to other information to identify possible problems in the meal count system Based on an attendance adjusted eligible/s factor Meal counts that do not seem reasonable must be explained or investigated The claim preparer is the responsible party When the claim preparer submits the claim they are electronically agreeing that they have reviewed the claim for accuracy and that the claim is appropriate and correct.

EDIT CHECKS The reviewer will ask… 4/15/2017 EDIT CHECKS The reviewer will ask… Most software systems have an edit check calculation in place Schools must be able to access and examine the report for accuracy Schools without software must use a manual edit check system DPI prototype may be downloaded at: http://www.dpi.wi.gov/files/fns/doc/editcheck.doc

Edit Check Common Findings 4/15/2017 Edit Check Common Findings Meal counts that exceed the number of eligible students in attendance Meal counts that are the same every day Meal counts where extremely high percentages of eligible students eat every day Counts that seem to repeat in patterns Counts that are the same as the number of meals delivered Edit Check delegated to FSMC rather than SFA

Monitoring – A Self Check (for SFAs with more than one serving site) 4/15/2017 Monitoring – A Self Check (for SFAs with more than one serving site) Must be completed prior to February 1 SFA’s self check to ensure that meal count reports are based on an approved counting system SFA’s self check to ensure that their counting system yields an accurate count reimbursable free, reduced- price, and paid meals for each day of operation Problems require corrective action and follow up by the SFA May not be delegated to the FSMC Remind participants that this was also discussed during the general session. This slide is just a reminder that the process needs to be completed if SFA has more than one claiming site and that it is addressed during the AR.

Finding the Forms Manual Edit Check On-site Monitoring http://www.dpi.wi.gov/files/fns/doc/editcheck.doc On-site Monitoring SFA must use this form http://fns.dpi.wi.gov/files/fns/doc/on_site_mf_0311.doc

A new Alternative for 2014-2015… Community Eligibility Provision (CEP) Ask if any schools currently participate in CEP. If time permits: go over the new CEP regulations to alert schools to the possibility of participation in the future. If none of the participants are involved in CEP the trainer could skip this section and focus on Q&A for the AR process.

Who is Eligible to participate in CEP? LEAs and schools must have an identified student percentage of 40% or greater. The 40% threshold can be determined by individual schools, groups of schools, or the entire LEA. RCCI’s are not eligible to participate in CEP LEAs and schools would be required to have an identified student percentage of at least 40 percent based on data as of April 1st of the prior school year. LEAs agree to serve both breakfast and lunch at no cost to all students for up to four consecutive school years in qualifying and approved schools. CEP sites must also agree to cover any costs of providing meals above the amounts provided in Federal assistance, with non-Federal funds. Residential Child Care Institutions are not eligible to participate in CEP.

Identified Students Direct Certification Head Start, Even Start Students certified for free meals without the use of a household application Direct Certification Head Start, Even Start Foster Care, Runaway, Homeless, or Migrant Students living in households participating in Food Share, Wisconsin Works (W-2), or FDPIR Enrolled Students include: Students who are enrolled in and attending schools participating in CEP and have access to at least one meal service daily. “Identified Students” are those students that are certified for free meals without a school meal application and thus not subject to verification. CEP sites will not be required to complete the verification process, but will need to complete the required online verification report anytime between November 1st and February 1st. LEAs with mixed districts (CEP and non-CEP sites) will need to continue with verification as usual in non-CEP schools. 1. Students may be directly certified through DCF (Dept of Children and Families) process since they live in households which participate in Food Share, or the W-2 Cash Benefits Program, or are certified as an E code under the state foster care system. 1. Students can be certified with proper documentation: -Head Start, Even Start -Foster care (with appropriate documentation from foster care agency, and eligibility does not extend to other students living in the household) -Homeless, Migrant, Runaways (as certified by an appropriate district liaison) -Participate in FDPIR (Food Distribution Program on Indian Reservations), as certified by an appropriate local FDPIR office

Reimbursement under CEP The ISP is multiplied by a factor (1.6) to obtain total meals served that will be reimbursed at the federal free rate. The remaining percentage of total meals is reimbursed at the Federal paid rate. Claiming percentages are guaranteed for 4 years. There is not a reduced category under CEP. Claiming percentages must be applied separately to SBP and NSLP. Identified Students are a subset of those students who are eligible for free meals. The 1.6 multiplier reflects the typical ratio between Identified Students and all students certified for free and reduced-price meals in schools. The 1.6 multiplier is an estimate of the share of students who would have been approved for free and reduced price meals through applications in the old process, the resulting number determines the free claiming percentage (capped at 100%) and is essentially a reflection of an LEAs total Free and Reduced population. Example: ISP of 0.55 x 1.60 = 0.88 x 100.00= 88% (free claiming percentage) & 1.00 – 0.88 = 0.12 x 100 = 12% (paid claiming percentage) Since the LEA is no longer accepting free and reduced household meal applications there is no longer a “Reduced” reimbursement category, just “FREE” and “PAID”. Once an LEA has approved free and paid claiming percentages, students no longer carry an individual eligibility status. All students have a “free status” based on the make-up of their student population.

Approved claiming percentages Can be obtained: On the most recent CEP approval letter sent to the LEAs authorized representative. On the child nutrition program online contract. Do not confuse the approved claiming percentages with the approved ISP. Currently, claims are to be submitted on a CEP specific paper claim form and faxed or emailed to the Jacque Jordee. Once the online system can be updated, claims will be submitted online.

Example: This school is participating SFA wide with one site School A was approved with a free claiming percentage of 100% and a paid claiming percentage of 0%. The number of meals in each category would be calculated as shown here: (919 x 100%) = 919 free meals; (919 x 0%) = 0 paid meals. Note: claiming percentages are being applied separately to lunch counts during the site specific edit check process prior to entering the claim. LEAs would then apply claiming percentages to the total reimbursable student breakfast counts after the site specific edit check process is completed and enter a separate claim. This is a simplified example, schools may not be approved for 100% free meal reimbursement, in which case not all meals can be submitted under “Free Student Meals”. Some may be entered under the paid student meal category. Schools should continue to perform the edit check by site and consolidate total counts onto one monthly claim separated by program. (NSLP, SBP, SNBP, ASCSP)    CEP sites participating SFA wide will not have student meals to report in the reduced category, enter 0.  

Benefits Considerations All Students eat meals free of charge Participation may increase Reduces paperwork Applications Verification May decrease direct certification runs SFA’s will still be required to collect individual alternative household income data for other programs such as Title 1, SAGE and ISIS. Schools without 100% free reimbursement may not use federal funds to cover the deficit Funds from the non-profit school food service account cannot be used to distribute, process or determine eligibility of alternate applications While participating in CEP, LEAs agree to serve free breakfast and lunch to all students. Not all LEAs are approved to claim 100% of the reimbursable meals served during breakfast or lunch at the free rate. Some districts, groups, or school sites have been approved with a free claiming percentage below 100%, which means a percentage of those total reimbursable meals served during breakfast and lunch will be reimbursed at the lower paid rate. The use of non-federal funds is only necessary to cover a deficit if the total amount of federal reimbursement through CEP does not cover the cost of serving free meals to all students. Examples of non-federal funds may be: -revenue from a la carte sales (non-program foods) -cash donations -in kind contributions from outside sources such as volunteer services

CEP and the Administrative Review At least one CEP site will be reviewed. The latest approved Identified Student Percentage (ISP) certification documents will be verified. direct certification lists extension of benefits documentation homeless, migrant liaison lists Claims will be monitored for accuracy with the claiming percentages. The SA must verify that the claiming percentage identified from the last ISP approval was properly applied to the review period and month of the on-site review from the current school year.

Records Retention Retain any documentation used in the development of the ISP during the entire period CEP is in effect. initial approval year year any updates are made extensions or grace years *Retain for an additional 5 years after the submission of the final claim for reimbursement for the last fiscal year of CEP. If the SA determines that the LEA/School has not maintained the required records for the participating site, the SA must require the school to return to standard application and meal counting procedures.

CEP -What Do You Think? During the onsite visit the reviewer observes the following… A. The number of meals claimed as free exceeds the maximum number of meals allowable under the CEP agreement. The meals claimed must meet the percentages set up for the school based on the online contract. This information is calculated and determined by DPI once the ISP is submitted. B. Adult meals are being claimed for free student reimbursement. As always, schools must track and report non-reimbursable meals on the monthly claim. Adult meals cannot be claimed for student reimbursement. C. Meals for CEP are based on attendance records. Meals claimed under CEP must still meet point of service requirements that ensure students are receiving reimbursable meals.

Additional Materials & Resources: School Nutrition Team website: http://fns.dpi.wi.gov/fns_cep CEP Monthly Reimbursement Estimator Frequently Asked Questions USDA memos on CEP CEP Application Alternative Household application FRAC (Food Research and Action Center) http://frac.org/federal-foodnutrition-programs/ Please visit the school nutrition team’s website at www.fns.dpi.wi.gov. There you will find the forms mentioned in this slide. The CEP Application is currently available on our website to participate. Please look for the alternative household income form in the coming weeks. Also, you may wish to visit FRAC’s website. There are many reports on the success CEP has had in the states which piloted the program.

First steps for a positive AR Experience? Remember the C’s Counts Eligibility Collection procedures Claims Point of Service Internal Edits CEP Accurate ISP Accurate Claims

Remember… The AR process is not intended to “get” schools who don’t comply. It is intended to provide schools with the tools and guidance they need to operate a quality nutrition program. Working Together We will meet that goal! Read slide.

Thank You for all that you do! Feeding children Matters… Thank You for all that you do! The new AR process was developed in the hopes of streamlining the review making it a more meaningful review for both the SFA and SA and allowing more time for technical assistance. We look forward to working with you this year and assisting you in any way possible as we work on our common goal of providing nutritious and healthy meals for Wisconsin’s children. ****** Switch to last slide (nondiscrimination statement) ******