Administrative Review Virginia Department of Health Special Nutrition Programs 2014

Module #8: Administrative Review State Agency Monitoring Requirements Pre-approval visits are conducted for new sponsors. Unannounced sites reviews are conducted to observe meal service and claiming procedures. End-of-season administrative reviews of sponsor operations.

Module #8: Administrative Review State Agency Monitoring Requirements Administrative reviews are scheduled by an SNP Liaison in advance are conducted: o For all new sponsors in their first year o For returning sponsors at least once every three years o For problematic sponsors o As needed to meet federal review requirements

Module #8: Administrative Review Purpose of an Administrative Review To evaluate your SFSP for compliance with federal and state regulations To provide technical assistance on implementing Corrective Action for program areas not in compliance To provide technical assistance on best practices for operating your program

Module #8: Administrative Review Entrance Conference The Administrative review entrance conference is conducted to discuss the program operational areas that will be examined during the review During the entrance conference, the reviewer will discuss the Administrative Review Guidance Tool with the sponsor.

Module #8: Administrative Review Administrative Review Guidance Compliance Area 1 – Program Eligibility Compliance Area 2 – Meal Counts Compliance Area 3 – Meal Requirements Compliance Area 4 – Fiscal Accountability Compliance Area 5 – Site Monitoring and Training by Sponsor Compliance Area 6 – Sanitation and Safety Compliance Area 7 – Civil Rights Compliance Area 8 – USDA Food Program Compliance Area 9 – Vended Programs

Module #8: Administrative Review Compliance Area 1 – Program Eligibility Required program eligibility documentation includes:  Open and closed-enrolled sites in needy area:  Copy of annual public media release  List of media outlet(s) receiving the release  Date(s) sent  Other outreach activities informing community of free meal locations

Module #8: Administrative Review Compliance Area 1 – Program Eligibility Required program eligibility documentation includes:  Eligibility documents for camps and closed- enrolled sites in a non-needy area:  Total number of children enrolled  Total number of children eligible  Certified eligibility forms or other approved alternative documentation verifying children’s eligibility  Income eligibility scale for the current year

Module #8: Administrative Review Compliance Area 2 – Meal Counts Required meal count documents include:  For open and closed-enrolled sites:  Original recorded daily meal count sheets by meal type for each site  Separate meal count sheets for field trips  Documentation for second meals claimed at sites that have fluctuations in attendance (not more than 2% of the first meals served by sponsor).  System used to consolidate meal counts prior to claim submission.

Module #8: Administrative Review Compliance Area 2 – Meal Counts Required meal count documents include:  For camps:  Meal count record

Module #8: Administrative Review Compliance Area 3 – Meal Requirements Required documents include:  Menus listing food items served to meet component requirements. It is recommended to include portion sizes and contribution to the meal pattern.  Recipes for self-prep sponsors  Child Nutrition (CN labels for commercially prepared items (e.g., pizza, chicken nuggets, etc.)  Transport records that have been signed and dated. These are required for vended sites and should be utilized in self-prep sites

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Required documents include:  Daily Meal Count forms  Receipts and disbursements of income to the SFSP  Costs incurred for operation and administration of the SFSP  SFSP ledger of income and costs in a consolidated summary

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Required documents include:  Invoices and payment records for purchase, storage, handling, processing, and transport of food and supplies  Inventory of foods and supplies  Timesheet and payroll records for staff involved in the daily functions of the SFSP operations, such as preparation and supervision of the meal.

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Required documents include:  Timesheet and payroll records for administrative and monitoring staff that do not perform operational duties pertaining to SFSP, but are changing their time to the SFSP  Invoices for printing, office supplies, postage, and mileage log

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Required documents include:  Balance sheets that outline SFSP income and expenses to account for SFSP funds on allowable expenses  Cash advance documentation such as bank account records

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Allowable Costs:  Operational costs are allowable costs incurred by the sponsor for preparing and serving meals to eligible children o Food service labor o Food o Other costs

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Allowable Costs:  Administrative Costs are allowable costs incurred by the sponsor for activities related to planning, organizing, and administering the program o Labor for planning and oversight o Mileage o Printing and advertising o Other costs

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Unallowable Costs: Unallowable costs are costs for which program funds may NOT be used. They include, but are not limited to: o Costs for excess meals ordered or prepared but not served to eligible children, e.g., meals in excess of legitimate program adult meals and reimbursable meals, unless specifically approved by the State agency.

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Unallowable Costs: o Meals served in violation of program requirements; i.e., additional foods served that are not compliant with the meal patterns, meals or components consumed off-site, second meals served in excess of the 2% tolerance o Rental costs for periods beyond the close-out date for program operation

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Unallowable Costs: o The cost to purchase food (including coffee, etc.) for use outside of the SFSP o The cost of meals served to administrative adult personnel, or any other adults that are not in the operation of the food service. o Bad debts, which are any losses arising from non-collectable accounts and other claims and related cost

Module #8: Administrative Review Compliance Area 4 – Fiscal Accountability Unallowable Costs: o For vended sponsors, the cost of meals delivered by a food service management company to a non-approved site, or for meals not delivered within the agreed upon delivery time, meals served in excess of the approved cap, spoiled or unwholesome meals, or meals that do not meet meal requirements or quality standards. o Entertainment and fundraising costs

Module #8: Administrative Review Compliance Area 5 – Site Monitoring & Training by Sponsor Required documents include: Site pre-operational visit reports for new sites and sites with operation problems Site monitoring visit reports o First Week Site Visit report completed within the first week of operation for new sites and sites with operation problems o Site Review report completed by the end of the 4 th week of operation

Module #8: Administrative Review Compliance Area 5 – Site Monitoring & Training by Sponsor Required documents include: Follow-up review reports as warranted Dates and agendas for staff training on program requirements Staff training attendance roster with staff sign-in Documentation supporting additional training and corrective actions provided at sites with identified problems.

Module #8: Administrative Review Compliance Area 6 – Sanitation and Safety Required documents include: Notification letter to the local health authority of the sites participating in the SFSP including addresses, contact information, dates of operation, and meal times Inspection reports from health authority and documents of corrective actions Current health/kitchen permit of the facility used for preparation of meals for SFSP

Module #8: Administrative Review Compliance Area 6 – Sanitation and Safety Required documents include: Each site where meals need preparation. This may include, but is not limited to serving food on plates, reheating unwrapped food, washing fruits, or assembling unwrapped foods into unitized meals before serving. Best Practice: food safety certification for a minimum of one employee at each self- preparation site where meals are prepared

Module #8: Administrative Review Compliance Area 6 – Sanitation and Safety Recommend daily: Temperature logs for refrigeration and freezer units Delivery records for time and temperature of food to verify meals served were safe for consumption

Module #8: Administrative Review Compliance Area 7 – Civil Rights Required documents include: Civil rights complaint procedures Name of Civil rights coordinator Ethnic or racial data form of participants at each site Documentation for accommodating persons with disabilities or special dietary needs (medical statement) “And Justice for All” poster visible at all participating sites.

Module #8: Administrative Review Compliance Area 8 – USDA Food Program Required documents for utilizing USDA Foods at self-preparation and/or food service management company sites include: Inventory system to monitor USDA Foods Ending inventory report of USDA Foods to be utilized in other Child Nutrition Programs Evidence of accepted donated food is used in menu records

Module #8: Administrative Review Compliance Area 9 – Vended Programs Required documents include (if applicable): Contract or Agreement for purchasing meals from a commercial food vendor, school district, or other SFSP sponsor Contract for other services such as consultants, equipment rental, kitchen facilities, or vehicle rental Bid procedures for those sponsors with contracts over the current dollar threshold per State and federal laws.

Module #8: Administrative Review Exit Conference The exit conference is conducted to discuss the review findings and any required corrective action. Sponsors are provided with a written report summarizing the review findings and required corrective action

Module #8: Administrative Review Corrective Action Documentation Sponsors will provide to the reviewer a written corrective action plan explaining new procedures that will be permanently implemented and followed to ensure compliance with regulations

Module #8: Administrative Review Corrective Action Documentation VDH reviewer will determine if corrective actions are met satisfactorily once written correction action is received Fiscal action adjustments will be process for any over-claimed or under-claimed meal count.

Module #8: Administrative Review Fiscal Sanctions for Unallowable Activities: The following is a list of unallowable activities that will lead to fiscal sanctions. Claiming meals taken off-site (except for reported field trips with complete meals accurately claimed) Claiming meals served on-site or on a field trip that did not have prior approval from VDH. Claiming adult meals

Module #8: Administrative Review Fiscal Sanctions for Unallowable Activities: The following is a list of unallowable activities that will lead to fiscal sanctions. Serving incomplete meals (i.e., meals lacking minimum acceptable components and/or quantities) Serving meals outside the approved meal timeframes

Module #8: Administrative Review Fiscal Sanctions for Unallowable Activities: The following is a list of unallowable activities that will lead to fiscal sanctions. Serving meals over the VDH approved maximum number of meals that may be served Claiming meals on days or at sites not approved to operate Claiming meals with no supporting documentation

Module #8: Administrative Review Records to Keep: Document program activities and maintain the following records for three additional yeas after the end of program year: Site information and eligibility Meal counts Menus Fiscal accountability Site monitoring and training

Module #8: Administrative Review Records to Keep: Document program activities and maintain the following records for three additional yeas after the end of program year: Safety and sanitation Civil rights USDA Foods Food Service Agreement/Contract