Advisory Council for School Nutrition Thursday, Feb. 22, 2018 Conference Call Thursday, Feb. 22, 2018 Conference Call

Carrie Thielen, MPH, RD Nutrition Programs Senior Consultant Office of School Nutrition

Conference Call Instructions Participants will need to link to view the webinar and call in to the conference line. Link to view the webinar: https://cdeschoolnutrition.adobeconnect.com/rx0pkiu080iu/ Call in to the conference line for audio: Conference Number: 1-877-820-7829 Participant Code: 810806 Please mute your phone. Please do not place your phone on “hold” because of background music. Please save questions for the end of each section. We will be using the phone line for questions. If you are unable to join the call or webinar, please call 720-202-3338 for assistance Participants will need to link to view the webinar and call in to the conference line. Link to view the webinar: https://cdeschoolnutrition.adobeconnect.com/rx0pkiu080iu/ Call in to the conference line for audio: Conference Number: 1-877-820-7829 Participant Code: 810806 Please mute your phone. Please do not place your phone on “hold” because of background music. Please save questions for the end of each section. We will be using the phone line for questions. If you are unable to join the call or webinar, please call 720-202-3338 for assistance

Brehan Riley, MS, RD, SNS Director Office of School Nutrition

Welcome, Legislative and Working Group Updates New members: Region 10: Sharley Schreiner, Fountain-Ft. Carson Region 15: Traci Berg, Holyoke/Haxtun/Fleming/Merino Region 16: Danielle Bock, Weld Co. 6, Greeley-Evans Region 18: Shannon Williams, Ouray Legislative Update Expansion of the School Lunch Protection Program Working Group Updates, Oct. 19, 2017 Direct certification improvement and Technology Innovation grants. Farm to School Grant. ACSN– Best Practices Unpaid Meal Charges Welcome New members: Region 10: Sharley Schreiner, Fountain-Ft. Carson Region 15: Traci Berg, Holyoke/Haxtun/Fleming/Merino Region 16: Danielle Bock, Weld Co. 6, Greeley-Evans Region 18: Shannon Williams, Ouray Legislative Update Expansion of the School Lunch Protection Program Working Group Updates, Oct. 19, 2018 Direct certification improvement and Technology Innovation grants. Farm to School Grant. ACSN– Best Practices Unpaid Meal Charges

Meghan Squires, MHS Senior Program Specialist Jennifer Otey, BA Senior Program Specialist Mountain Plains Regional Office (MPRO) Meghan Squires, MHS Senior Program Specialist Jennifer Otey, BA Senior Program Specialist Mountain Plains Regional Office (MPRO)

Child Nutrition Program Office of Program Integrity February 2018 Child Nutrition Program Office of Program Integrity

CN’s Office of Program Integrity The Office of Program Integrity (OPI) was created in 2014 OPI’s focus is on identifying ways to increase integrity in all CN programs OPI is comprised of staff from the regional and national offices OPI’s first major focus was on school meals The Office of Program Integrity (OPI) was created in 2014 OPI’s focus is on identifying ways to increase integrity in all CN programs OPI is comprised of staff from the regional and national offices OPI’s first major focus was on school meals

Access, Participation, Eligibility and Certification Study (APEC-II) The primary data source OPI used to begin to address error in school meal programs was an FNS study: Access, Participation, Eligibility and Certification Study – (APEC-II): Measuring Erroneous Payments in the National School Lunch and Breakfast Programs The primary data source OPI used to begin to address error in school meal programs was an FNS study: Access, Participation, Eligibility and Certification Study – (APEC-II): Measuring Erroneous Payments in the National School Lunch and Breakfast Programs

Administrative Review The administrative review process looks at: Program and meal access and reimbursement Meal patterns and nutritional quality School nutrition environment Civil rights Resource management The administrative review process looks at: Program and meal access and reimbursement Meal patterns and nutritional quality School nutrition environment Civil rights Resource management

Administrative Review and APEC II The administrative review process looks at: Program and meal access and reimbursement Meal patterns and nutritional quality School nutrition environment Civil rights Resource management APEC II uses data collected in SY 2012-2013 The APEC studies are nationally representative For APEC II, data came from: Surveys of households and SFA directors Administrative data from schools districts and States Direct observations in sampled schools The administrative review process looks at: Program and meal access and reimbursement Meal patterns and nutritional quality School nutrition environment Civil rights Resource management APEC II: APEC II uses data collected in SY 2012-2013 The APEC studies are nationally representative For APEC II, data came from: Surveys of households and SFA directors Administrative data from schools districts and States Direct observations in sampled schools

Overall Improper Payments The APEC studies describe improper payments in three broad categories: Certification Error Meal Claiming Error Aggregation Error The APEC studies describe improper payments in three broad categories: Certification Error Meal Claiming Error Aggregation Error

Focusing on Certification Error APEC II revealed two primary sources of certification error Household reporting error (such as forgetting an income source or not reporting a household member). Household reporting error is more common than administrative error. 16.5% of applications had household reporting errors Administrative error includes errors in processing applications, determining eligibility, and recording certification status information on the master benefit list 8.9% of applications had administrative errors This is looking only at non-CEP Schools (there is a separate conversation on CEP). Certification errors can either be an over-certification (a student being certified for a higher level of benefits than that for which they are eligible) or an under-certification (a student being certified for a lower level of benefits than that for which they are eligible or erroneously denied benefits). It is important to note that the error in the report is the combination of over-certification and under-certification errors. The most frequent type of household reporting errors identified in APEC were not accurately reporting the number of household members with income, the number of types of income, or both. Discrepancies in reported household size were the next most common type of reporting error. In CEP schools – certification error occurs if a CEP group’s ISP is incorrect. Under-certification error occurs if the school claimed a smaller reimbursement amount than it would have if its claiming percentages were correct. Over-certification error occurs if a larger reimbursement amount was claimed than the correct claiming percentages would suggest.

Certification Errors in NSLP About 71% of the errors were overpayments $1.2 billion About 29% of the errors were underpayments $830 million (71%) About half of those errors come from free-reimbursed meals that should have been at the paid rate Given the size of the school meals programs (about $12 billion in SY 2012-13), a relatively small percentage of error can result in a big price tag. The way the error is counted, both under-claims and over-claims are counted as error and added together. (A $2.00 over-claim + a $2.00 under-claim = $4.00 in error, not $0.00) So on this slide we see that certification errors in NSLP resulted in $1.2 billion of errors, 71% of those errors being overpayments and 29% of the errors being underpayments. $330 million (29%) NSLP

Certification Errors in SBP $370 million Similar to NSLP, about 70% of the errors in SBP were overpayments $260 million (70%) About 29% of the errors were underpayments Percentages don’t add up to 100 because they are calculated on actual values and not the rounded values shown here. Similar to lunch, we see that 70% of the certification errors in breakfast were over-claims and 29% were under-claims. Certification error in both breakfast and lunch combined accounts for about 58% of total improper payments. $110 million (29%) SBP

Meal Claiming Error from APEC II $610 million (100%) $370 million (100%) $530 million (87%) Overpayments $360 million (98%) Meal claiming error represents about 37% of total improper payments. Here you see that there is $610 million in meal claiming error in lunch and $370 million of meal claiming error at breakfast, with the majority of both errors being overpayments. $10 million (2%) $80 million (13%) Underpayments $80 million (13%) SBP NSLP

Meal Claiming Error from APEC II. Meal claiming error is more common in breakfast than in lunch Meal claiming error was concentrated in a minority of schools rather than distributed evenly across schools There are lower meal claiming error rates in: Smaller districts Schools serving fewer meals Offer vs. Serve schools Meal claiming error is more common in breakfast than in lunch Meal claiming error was concentrated in a minority of schools rather than distributed evenly across schools There are lower meal claiming error rates in: Smaller districts Schools serving fewer meals Offer vs. Serve schools $80 million (13%)

Error Information Colorado in ARs In School A, selected applications were incorrectly approved. One application was processed as free when the application should have been denied. School B has an alternate point of service that was not approved by State Agency. Meal counts are being taken at the beginning of the serving line before it is verified if a student has taken a reimbursable meal. School C did a great job certifying students for free and reduced priced meals as evidenced by zero errors. All certification and benefit issuance documents were very organized and had thorough documentation. Comments like these in ARs can add to what we know from APEC – but cannot replace APEC studies because the results are specific to just a handful of schools. More importantly we would like to hear from you on thoughts you may have to address some of these errors. At a future meeting we would like to talk to you about some best practices, innovations and challenges you face that may help mitigate or even lead to error. In Schools D and E, meal count records are accurately completed and well maintained.

Erica Boyd, RD Nutrition Programs Senior Consultant Office of School Nutrition

Smart Snacks, Competitive Foods, Fundraising Colorado Competitive Food Rules Federal Smart Snacks in School Effective July 1, 2014 CO Healthy Beverages Policy Effective July 1, 2009 In Colorado we have three pieces of legislation that regulate competitive foods. The CO Comp Food Service Policy and the Health Beverage Policy are state policies and Smart Snacks is a federal regulation. Whenever state policy is more restrictive than federal policy, we must follow state policy. When federal regulation is more restrictive we must follow it. Competitive food means all food and beverages other than meals reimbursed under programs authorized National School Lunch Act and the Child Nutrition Act available for sale to students on the School campus during the School day. CO Competitive Food Service Policy Effective July, 1998

Smart Snacks in School Apply to all foods and beverages sold to students: On the school campus During the school day Outside of the reimbursable meals program Includes items sold: A la carte In school stores At snack bars In vending machines At food and/or beverage fundraisers (i.e., bake sales) Does not apply to: Items brought from home Fundraisers that occur outside of school Birthday or classroom celebrations Items sold in areas in which students have restricted access Smart snacks in schools apply to all foods and beverages sold to students, on the school campus, during the school day and outside of the reimbursable meals program The school campus is defined as all areas of the property under the jurisdiction of the school that are accessible to students during the school day which is defined as midnight before school to 30 minutes after the end of the official school day. Listed on this slide are examples of what is included under smart snack regulation and those which are not. Smart snack nutrition standards apply to all a la carte items, school stores, vending machines, and food/beverage fundraisers. Smart snack nutrition standards do not apply to items brought from home, fundraisers occurring outside of the school, birthday/classroom celebrations and items sold in areas in which students have restricted access.

Smart Snacks – General Food Standards To be allowable for sale, a food item first must meet one of the following general standards: Be a whole grain-rich grain product; OR The first ingredient is either a fruit, vegetable, dairy or protein food; OR Be a combination food that contains at least ¼ cup fruit or vegetable. To be allowable for sale, a food item first must meet one of the following general standards: Be a whole grain-rich grain product; OR The first ingredient is either a fruit, vegetable, dairy or protein food; OR Be a combination food that contains at least ¼ cup fruit or vegetable.

Smart Snacks – Nutrient Standards Then, ensure the food(s) as packaged and sold meet the nutritional criteria for all of these nutrients: Snack Items: ≤200 calories Entrée Items: ≤350 calories Total Calories Total fat (≤35% of calories from total fat) Saturated fat (<10% of calories from saturated fat) Trans fat (0 grams of trans fat) Fats Snack items: ≤230 mg Entrée items: ≤480 mg Sodium ≤35% weight from total sugars in foods Sugar If the item meets the first criteria it then must meet the nutritional criteria for total calories, fat, sodium and sugar. An entrée item is a combination food of meat/meat alternate and whole grain rich food; or a combination food of vegetable or fruit and meat/meat alternate; or a meat/meat alternate alone, with the exception of yogurt, low-fat or reduced fat cheese, nuts, seeds and nut or seed butters and meat snacks.

Smart Snacks and CO Healthy Beverages Policy In November 2016, Colorado Healthy Beverages Policy aligned with Smart Snacks Beverage standards apply to the extended school day. Standards do not apply to beverages sold during school- related events, where parents are a significant part of the audience. In November 2016 the CO Healthy Beverages Policy aligned with Smart Snacks. The beverage standards apply to the extended school day Standards do not apply to beverages sold during school-related events where parents are a significant part of the audience. Extended School Day means the regular hours of operation for any public school including institute charter schools, plus any time spent by students after the regular hours of operation for any purpose, including but not limited to participation in extracurricular activities or childcare programs.

Colorado Competitive Food Service Policy May not be sold in competition with the district’s foodservice Program. Cannot be sold 30 minutes before to 30 minutes after each scheduled meal service. In those schools participating in the School Breakfast and/or National School Lunch program(s), competitive food service is any food or beverage service available to students that is separate and apart from the district’s nonprofit federally reimbursed foodservice program, and is operated by school approved organizations, school staff or by school-approved outside vendors. Such competitive foods cannot be sold 30 minutes before to 30 minutes after each scheduled meal service on any area of the school campus that is accessible to students.

Food Fundraisers Each school building can have up to three exempt fundraisers per school year. (i.e. foods sold that do not meet the Smart Snack standards) Duration of fundraisers is up to local discretion, but must be in line with the intent of the rule. Smart Snacks standards do not apply to fundraisers, in which the food sold, is clearly not for consumption on the school campus during the school day. Each school building can have up to three exempt fundraisers per school year. (i.e. foods sold that do not meet the Smart Snack standards) Duration of fundraisers is up to local discretion, but must be in line with the intent of the rule. Smart Snacks standards do not apply to fundraisers, in which the food sold, is clearly not for consumption on the school campus during the school day.

Healthy Celebrations On the CDE OSN Local Wellness Policy-Best Practices webpage it links to several examples that other states and schools have implemented for non-food fundraisers and examples of healthy celebrations.

Documentation Requirements Resources Requirements Resources Each entity selling food and beverage items must keep records of all items sold. Districts must maintain documentation of compliance with the three exempt fundraiser limit. Resources Example Food and Beverage Sales Documentation Tracker Smart Snacks Documentation Examples   LEA Fundraiser Example Documentation Tracker Requirements Each entity selling food and beverage items must keep records of all items sold. Districts must maintain documentation of compliance with the three exempt fundraiser limit. Resources Example Food and Beverage Sales Documentation Tracker Smart Snacks Documentation Examples   LEA Fundraiser Example Documentation Tracker

Documentation Resources Here are 2 examples of tracking methods that are on our website that show what is necessary to track when hosting an exempt food fundraiser. It is important to note that nutrition labels for each item sold during the non-exempt fundraiser must be on file with the tracker or exemption form.

Documentation Resources - Examples For smart snack documentation the nutrition facts label and the ingredient list must be included. The Alliance for a healthier generation smart food planner print out results are optional, but if you do have them it must be accompanied by the nutrition facts label and the ingredient list.

Responsibilities District School Food Service Fundraisers School stores Vending machines School Food Service A la carte sales District Fundraisers School stores Vending machines School Food Service A la carte sales

Smart Snacks Review in the Administrative Review Interview school district staff and food service staff. Determine all areas where foods and beverages are sold (exempt fundraisers, vending machines, school stores, etc.). Obtain a separate list of all food and beverage items, for sale during the review period, at each reviewed schools. Choose a minimum of 10 percent of the items, from this list, which the school food authority and local education agency must submit documentation. The 10 percent sample selected for documentation review must represent all locations where foods and beverages are sold to students. The 10 percent sample is distinct for each site being reviewed. Interview school district staff and food service staff. Determine all areas where foods and beverages are sold (exempt fundraisers, vending machines, school stores, etc.). Obtain a separate list of all food and beverage items, for sale during the review period, at each reviewed schools. Choose a minimum of 10 percent of the items, from this list, which the school food authority and local education agency must submit documentation. The 10 percent sample selected for documentation review must represent all locations where foods and beverages are sold to students. The 10 percent sample is distinct for each site being reviewed.

Contact Information Erica Boyd, RD Nutrition Programs Senior Consultant Boyd_E@cde.state.co.us 303-866-6306 Erica Boyd Nutrition Programs Senior Consultant Boyd_E@cde.state.co.us 303-866-6306

Carrie Thielen, MPH, RD Nutrition Programs Senior Consultant Office of School Nutrition.

Colorado School Nutrition Association (CSNA) Summer Conference June 13-14, 2018 Embassy Suites, Loveland, CO Registration opening February 2018 Topics for Summer Food Service Program classes Colorado School Nutrition Association (CSNA) Summer Conference June 13-14, 2018 Embassy Suites, Loveland, CO Registration opening February 2018 Topics for Summer Food Service Program classes

Brehan Riley, MS, RD, SNS Director Office of School Nutrition.

Next Steps, Save the Date, Evaluations, Closing CSNA Summer Conference, June 13-14, 2018, TBD Recognition of outgoing charter members. Introduction of past members. Introduction of current members. ACSN region “Meet and Greet” lunch session. Hot topics for next meeting? What worked today? What did not work today? Save the Date: CSNA Summer Conference, June 13-14, 2018, TBD Recognition of outgoing charter members. Introduction of past members. Introduction of current members. ACSN region “Meet and Greet” lunch session. Hot topics for next meeting? What worked today? What did not work today?