Meal Counting and Claiming Nuts and Bolts of School Nutrition August 5, 2015 Presented by: Doreen Iovanna, M.Ed., LDN, DT Office for Nutrition, Health & Safety

What is the Purpose of an Accurate Meal Counting and Claiming System?  To ensure the validity of the School Food Authority’s (SFAs) monthly claim for reimbursement  To prevent a Performance Standard I Violation  But most importantly….. To Avoid Fiscal Action 2

Performance Standard I 7 CFR (2)i  All free, reduced price and paid lunches claimed for reimbursement are served only to students eligible for free, reduced price and paid lunches, respectively  Lunches are counted,recorded, consolidated and reported through a system which consistently yield correct claims 3

4 What are the Components of a Successful Meal Counting and Claiming System? Eligibility Documentation Point of Service (POS) Meal Counts Collection Procedures Reports Internal Controls Edit Checks Monitoring Claim for Reimbursement

Video 1 – Making it Count Developing Acceptable Meal Counting and Collection Procedures 5

 Income eligibility documentation must be on file for each student receiving a free or reduced- price meal  Provides the number of eligible students in each category (free, reduced and full price)  Accurately reported on the medium of exchange at the point of service  Supports your claim for Federal reimbursement of meals 6 Eligibility Documentation

What are Point of Service (POS) Meal Counts?  Meal counts must be taken at the point of service (POS)  The point at which staff determines that a reimbursable meal has been served to an eligible child or student  Common POS locations are school cafeterias  Alternate POS include classrooms and hallways  Count:  Reimbursable meals  By category  Each day  Prevent Overt Identification 7

What is Overt Identification?  Overt identification is when a child is openly or physically identified as receiving a free or reduced meal  Some examples are:  Separate meal service lines for students who are eligible for free, reduced-price and paid meals  Color-coded tickets for free/reduced eligible students  Serving different meals  Simple roster coding methods, such as F,R,P; or 1,2,3  A casual observation of your point of service should never be able to tell who is free, reduced, or paid 8

When Are Point of Service Meal Counts Required?  Breakfast  Lunch  After School Snack  At Risk Snack & Supper All meal counts must be conducted without overt identification 9

Coded Rosters Acceptable Coding Examples:  Coding by series: (1000 sequence for free, 2000 sequence for reduced and 3000 sequence for paid)  Coding by student ID number: Using the last digit in a student’s ID number to indicate the appropriate eligibility category (0 for free, odd number for reduced and even number for paid) 10

What is a Medium of Exchange?  The medium of exchange includes any type of ticket, token, I.D., name or number that is issued to the students for obtaining the meals  Should allow for updates on a daily basis (noting transfers, withdrawals and changes in status due to verification, etc.)  The meal count/collection system selected must ensure that the medium of exchange prevents overt identification of free and reduced-price meal recipients in the coding, distribution and collection processes 11

1.Verbal Identifier/Roster 2.Coded ticket/token 3.Coded I.D. cards 4.Cash Register Code System 5.Prepaid List 6.Computerized Bar Code 7.I.D. Cards Acceptable Mediums of Exchange Systems: 12

Verbal Identifier/Roster 13 AdvantagesDisadvantages Cannot be stolen, lost or destroyed Documentation of meal count is produced during meal service as names/numbers are checked off on a roster or number sheet. If used with a number sheet, may be a fast method Can be used by another student or twice by the same student if more than one serving line. Coded roster sheet is time consuming for cashiers using manual system. Examples include: name checklist, class list, number list

14 Examples of Rosters

Coded Ticket/Token 15 AdvantagesDisadvantages When collected at point-of- service, provides a means of physically counting meals by category. When used in small to medium schools, counts by category can be completed quickly after the meal service Can be destroyed, transferred, lost, stolen or sold. In large schools, too cumbersome to collect and count all tickets or tokens by category after the meal service. If not coded properly, may result in overt identification.

16 Automated PIN Pad AdvantagesDisadvantages Provides accurate count and saves time; compiles meal count by category at the same time the students are counted Students do not have to be in the line by classroom; lines moves at the same pace whether the cashier knows all of the students names or not Prevents overt identification on the line Provides automated reports Students may forget their numbers, thus slowing the line Start-up and operating costs may be high If more than one service line, there may be two meals claimed if the electronic machines are not linked

17 Coded Bar Line AdvantagesDisadvantages Provides accurate count and saves time; compiles meal count by category at the same time the students are counted. Students do not have to be in the line by classroom; lines moves at the same pace whether the cashier knows all of the students names or not Prevents overt identification on the line. Provides automated reports. Can be lost, destroyed or transferred. Start-up and operating costs may be high. If more than one service line, there may be two meal claimed if the electronic machines are not linked.

Activity 1: Acceptable Meal Counting Systems are? YES  NO  1. Claims based only on meal counts taken in the morning in the classroom or at any other location before the meal is served? YES  NO  2. Claims based on attendance records? YES  NO  3. Meal counts based on the number of tickets or tokens sold and distributed or the number of meals paid in advance? YES  NO  4. The number of free and reduced-price meals claimed based on the number of students eligible to receive such meals? YES  NO  5. Meal counts by category taken at the beginning of the serving line without checking that the meals served are reimbursable? YES  NO  6. Meal counts by category based on visual identification of students with no backup system available for persons not familiar with the students; e.g., checklists? YES  NO  7. Meal counts based on tray or plate counts? YES  NO  8. Back-out systems used that subtract one number (e.g., number of free and reduced-price meals) from the total count to get another number (e.g., the number of full-price meals)? YES  NO  9. The students who are eligible for meal benefits overtly identified? YES  NO  10. A system that does NOT yield a reliable, accurate count of meals served by category? 18

Unacceptable Meal Count Systems Meal count systems that are not acceptable because they do not provide a daily count at the point-of-service of reimbursable meals, by Category include:  Attendance counts  Tray, plate or entree counts  Classroom counting  Prepaid/charged meals counted on day paid  Second meals claimed for reimbursement  Ineligible persons claimed for reimbursement  Cash converted to meals  A la carte items claimed for reimbursement  Category/cash back-out system  Delivery counts of meals produced off-site  Visual identification without backup 19

20 Determine which type of meal counting system is best for each site. It may vary from site to site. It may also vary from breakfast to lunch.

Eligibility Documentation and Meal Counts  Residential students only – RCCI-1 Form: Record of enrollment for free eligible students based on household of one  Day students – Eligibility Roster: Indicating free, reduced and paid eligibility based on meal benefit applications or direct certification 21

Meal Count Roster 22 Meal Count Roster- must be used when claiming day students as free, reduced, or paid. Counts must be totaled daily across eligibility category. Eligibility code prevents overt identification at POS. Example: 2149, 5315

RCCI-1 Enrollment Form 23  RCCI-1 form for each residential facility/site  Update as residents enter and or withdraw  Maintain separate RCCI-1 for each Fiscal Year

What are Meal Counting and Claiming Collection Procedures? Collection procedures refers to all the steps within the meal count system involved in paying for meals and issuing and collecting the medium of exchange. 24

Meal Counting and Collection Procedures Self Assessment :  What are your current meal counting method(s) used for breakfast and lunch?  Are meal counts conducted at POS?  Are all staff members following them?  Are they accurate for each site?  Policy for adult or visitor meals?  Procedure to count field trips?  Procedure to count student workers’ meals?  Procedure for handling/counting of second meals? 25

 How is the medium of exchange non-overtly coded for free, reduced price and full price?  What safeguards are used to prevent your medium of exchange from being duplicated, used by an unauthorized person, or used twice in one meal service?  Who distributes the medium of exchange? Where and when?  How is the medium of exchange collected at point of service? Include who collects and at what place in the serving line. Who insures that tickets, if used, are not used twice?  How is overt identification avoided for reduced price eligible students who choose to pay in the line? 26 Meal Counting and Collection Procedures Self Assessment :

Meal Counting and Collection Procedures Implementation Brainstorm  Current Challenge:  Future Expectations: 27 Implementation Brainstorm Who What When Where How

Video 2 – Making it Count Consolidation and Reporting 8a/ 28

Meal Count Consolidation Reports 29 Daily Potential Income Sheet FP-9 form

Daily Potential Income Sheet  Daily Cash/Cash Reconciliation Sheet  Tracks daily sales by category  Free, reduced, paid  Breakfast, lunch, snack, special milk  A la carte  Adult sales (including meals tax)  Pre-payments  Cash reconciliation 30

31 Daily Potential Income Sheet

FP-9 Meal Count Sheet  FP-9 for every school site  Record meals by eligibility  Edit checks- A,B,C and D  Signature of site/facility representative  Monthly submission to person consolidating claim 32

33 Reference: ESE Document and Reference Library – NSLP National School Lunch Program - FP-9

Activity 2 Complete the following:  Part A: Attendance Factor  Part C: February 28, 2011  F = 80  R= 15  P =175  Part D: Average Daily Participation  Part B: Edit Checks  Do free counts exceed approved free applications on file?  Do reduced counts exceed approved reduced applications on file?

35 Meal Count Consolidation Self Assessment  Meal count consolidation form(s) and procedures which include staff responsibilities for the tasks identified:  Daily Potential Income  FP-9

Meal Count Consolidation Implementation Brainstorm  Current Challenge:  Future Expectations: 36 Implementation Brainstorm Who What When Where How

Internal Controls  The SFA must establish internal controls to ensure that an accurate claim for reimbursement has been made by:  Completing daily edit checks  Monitoring 37

Edit Checks 38  The purpose of the edit check procedure is to identify errors in the schools’ lunch counts and/or problems with the meal counting and claiming procedures so that necessary corrections are made

Edit Checks 39  USDA regulations require SFAs to complete an edit check for each of its schools that participate in the NSLP prior to consolidation of the daily lunch counts for the monthly reimbursement claim

Edits Checks 40 USDA’ S R EQUIRED E DIT C HECK P ROCEDURES FOR E ACH S CHOOL 1.Obtain and record the highest number of students in each category 2.Compute the attendance factor 3.Multiply the number of enrolled children approved in each meal category (free, reduced-price and paid) by the monthly attendance factor 4.Compare these numbers; know as attendance adjusted eligible figures to the daily free counts of free, reduced- price and paid meals 5.Provide written justification next to the day where any category count exceeds the attendance-adjusted number. (Sample justification could be meal participation increased due to a pizza day or special promotion.)

Highest # of Student Attendance Factor Highest # of Lunches Approved in Month (average daily attendance Expected for Any ÷ school enrollment) Serving Day Free ________________ X ______________ = ________________ Reduced-Price________________ X ______________ = ________________ Paid________________ X ______________ = ________________ Edit Check: Attendance Adjusted Eligible 41

Highest # of Student Attendance Factor Highest # of Lunches Approved in Month (average daily attendance Expected for Any ÷ school enrollment) Serving Day Free______112_______X _____.944_________ = __105.7 or 106___ Reduced-Price_______25_______X _____.944_________ = ___23.6 or 24__ Paid______403______X _____.944_________ = _380.4 or 380__ Edit Check: Attendance Adjusted Eligible School’s highest number of students approved for free meal benefits during the month: 112 School’s highest number of students approved for reduced price benefits during the month: 25 School’s highest daily enrollment for students with access to the lunch program: 540 School’s highest number of students in the paid category: 540 – 137 = 403 School’s average daily attendance: 510 School’s attendance factor: 510 ÷ 540 =

Other Edit Checks  Patterns or repetition of numbers  Counts which equal the number of eligible's  Counts equal to the number of meals delivered  Identical counts on certain days (like every Monday or at breakfast and lunch)  All of these are red flags which may tell you that you need to investigate further 43

Monthly Edits Check  Meal counts on the Claim for Reimbursement must also not exceed the number of children approved in any eligibility category multiplied by the operating days within the month Example (FP-9 activity): 112 Free x 15 operating days = 1680 max meals 44

Activity 3– Making it Count Making the F-9 Count 8a/activity/ 45

Self Assessment Edits Checks  Procedures for conducting edits checks of daily meal counts, including staff responsibilities and when these checks are completed? 46

Edit Check Procedures Implementation Brainstorm  Current Challenge:  Future Expectations: 47 Implementation Brainstorm Who What When Where How

Video 3 – Making it Count Accuclaim Monitoring Report 8b/ 48

Site Monitoring Accuclaim: (Accurate Claim)  SFAs must monitor the lunch service at all sites to evaluate meal counting procedures by February 1 each year. Monitoring of breakfast is also recommended  SFAs participating in the After School Snack Program must monitor snacks twice per year ( the beginning the first 4 weeks of school and one other during the year)  SFAs should record monitoring activities on required forms located in the document library 49

Site Monitoring 50 Monitors should ensure that sites do not claim the following meals/food:  Adult Meals  Second meals eaten by eligible students  Suppers or dinners (third meal of the day) unless the SFA participates in the Child and Adult Care Food Program (CACFP) At-risk Afterschool Program  Snacks served on ineligible days  Meals not meeting the meal pattern  Meals served outside the required meal periods, unless otherwise approved  A la carte items

51 Reference: ESE Document and Reference Library – NSLP National School Lunch Program Accuclaim On-site Review Checklist

After School Snack Monitoring Form On-Site School Review Form for Snacks In After School Care Programs To be used for required self review/NOT to be submitted to any agency. Review must be completed for each school twice each school year. The first review must be conducted within the first four weeks of operation. __________________________________ ________________________ SCHOOL DATE Please check one: ____ The after school snack counting and claiming system was reviewed and found to be IN COMPLIANCE with 7 CFR 210.9(c) of the regulations of the USDA Food and Nutrition Service. The snack menus met the meal pattern regulations correct claims for reimbursement. ________________________________________ Reviewer ____ The after school snack counting and claiming system was reviewed and found to be in NON-COMPLIANCE with 7 CFR 210.9(c) of the Regulations of the USDA Food and Nutrition Service. Please describe the corrective action taken. __________________________________________________________________ __________________________________________________________________ __________________________________________________________________ __________________________________________ Reviewer 52 Reference: ESE Document and Reference Library – NSLP National School Lunch Program

Staff Training & Professional Development 53 All SFAs should have a training plan for meal counting procedures. The plan should include:  Annual training for staff in key positions  Ongoing training for new staff with identified problems  Annual review of all meal counting procedures  Maintain agenda and sign-in sheets

Professional Standard Final Rule Effective July 15,  Training information can be found at:  Professional standard information can be found at: ofStandards/profstandards_flyer.pdf

Monitoring and Training Self Assessment 55  What are your current procedures for conducting site monitoring?  Current training practices?  Who conducts trainings?  Who needs to attend?

Monitoring & Training Implementation Brainstorm  Current Challenge:  Future Expectations: 56 Implementation Brainstorm Who What When Where How

Take A Final Look Before Hitting Submit  Make sure edit checks have been conducted on each school’s counts  Consolidate daily meal counts to monthly site totals by meal  Once you’ve completed the edit, conducted your comparisons, found no problems, you can submit your claim 57

58 School Site Information For All Schools Including RCCI’s with Both Day and Residential Students  Input counts by site (under school selection)  Information from site FP-9 is used to fill out the claim for reimbursement

Remember: Meal Counts Records Retention  SFAs must retain original meal count records for the current day and month by site  SFAs must retain all meal counts records, including rosters and site monitoring reports for three (3) years after the submission of the final claim for reimbursement for the fiscal year, plus the current fiscal year’s records. If there is an open audit for any fiscal year, all records must be retained until closure notification of the audit. 59

Sometimes You Just Have To Put Your Hand On Your Hip… 60 To make sure it’s right!

For All You Do! 61

Questions 62 Created in Partnership: 2014 Meal Counting, Claiming and Reimbursement- A. Chisholm and K. Kefalas