Counting and Claiming Jennifer Otey, Senior Consultant Colorado Department of Education Office of School Nutrition Otey_j@cde.state.co.us July 2013

Overview SFAs receive federal and state $ for each meal that: 11/9/2018 Overview SFAs receive federal and state $ for each meal that: Meets program requirements (meal patterns) Is served to an eligible student To receive the reimbursement for meals served to students by category, schools must accurately Count Record Claim 2

11/9/2018 Distribution All meal count/collection systems should include a method for prepayment and/or post billing (charging)* Makes F&R students appear as students who already paid full price Must be publicized Should provide multiple ways to make pre-payments Examples No cash on the line; payments made in advance or parents are billed Cash is accepted on the line—and payments can be made in advance / billing *Post billing is not recommended Hand out DCCP form. 3

Collection - Medium of Exchange 11/9/2018 Collection - Medium of Exchange Is issued to students for obtaining a meal Connects the meal benefit app status to the student who is being served a meal Must be updated (transfers, withdrawals, changes in status) on a timely basis Must prevent overt identification Examples Verbal identifier/roster Coded ID cards Pin pad Ask what they use in their districts. Ask about pros and cons for each example. 4

11/9/2018 Coding Acceptable Series (1 – 1,999 = free; 2,000 – 2,999 = red; 3,000 – 3,999 = paid) Ending number (….0, even number, odd number) Number of digits (4 digits = F; 5 digits = R; 6 digits = P) Coding behind the scenes Electronic system codes students for claiming and tracking balances F&R person uses roster to enter counts in computer for claiming and tracking balances 5

Coding (cont.) Not Acceptable Not Recommended 11/9/2018 Coding (cont.) Not Acceptable The use of a single identifier when used with listed prices F, R, P Color coding Not Recommended Single identifiers unless rotated periodically 6

Overt Identification Definition: Any action that may result in a child being recognized as potentially eligible to receive free or reduced meals Any meal cards, tickets, tokens, etc., cannot be coded or colored in a manner that would overtly identify F&R students SFAs must take steps to assure that rosters, computer-screens, or other equipment used at the POS cannot be viewed by anyone not needing the information, especially students Info on the rosters or screens should be masked or coded to avoid other students discerning any student’s eligibility status 7

Overt Identification (cont.) 11/9/2018 Overt Identification (cont.) Prohibited: separate dining areas, service times, serving lines, or limiting the choices of reimbursable meals based on eligibility All menu items must be available to all students, regardless of their eligibility If certain items are not available to all, they may not be counted toward a reimbursable meal Meals served on an all-cash line may never be claimed for reimbursement Competitive foods during the meal service: SFAs are encouraged to ensure the sale of competitive foods does not inadvertently result in eligible children being identified Competitive foods during the meal service: SFAs are encouraged to ensure the sale of competitive foods does not inadvertently result in eligible children being identified. Examples: Limit competitive foods to those also offered as part of reimbursable meals on the reimbursable lunch lines Offer competitive foods on the same lines as reimbursable meals are offered Only allow competitive foods to be purchased with a pre-paid card 8

11/9/2018 Point of Service “That point in the food service operation when a determination can accurately be made that a reimbursable F, R, P meal has been served to an eligible child” Not allowable Counts taken in the classroom of who is going to eat or who is in attendance Backing out (one meal category’s #s calculated based on other categories) Tray counts or delivery counts Marking off students as they enter the line Visual identification without back-up 9

Point of Service (cont.) 11/9/2018 Point of Service (cont.) 2-person POS If any items for the reimbursable meal are after the POS Includes vegetable subgroups on a salad bar Must be a method to notify cashier if a meal, by type, is not reimbursable Must be approved by CDE Must a school place all food components that are part of the reimbursable meal before the Point of Service (POS)? If a school is not able to position all food components (e.g., salad bar) prior to the POS, State agencies may authorize alternatives to the POS lunch counts. When food components/food items are located in an approved location beyond the POS, they must be labeled, listed on the menu, or otherwise identified so the students can easily identify all the components for a reimbursable meal and select the correct quantities. There must be a system in place to ensure that each reimbursable meal selected by the student under OVS includes a fruit or a vegetable (at least 1/2 cup). Are school districts allowed to offer extra food that could not credit as part of the reimbursable meal (e.g., ice cream bar) after the point of service? Yes. There is no limit on the foods that can be offered for sale to students. However, any extra food that is offered to the student as part of, not in addition to, a reimbursable meal must be included in the nutrient analysis and count toward the limits on calories, saturated fat, sodium and trans fat. May a school offer an un-monitored salad bar and count the vegetables toward meeting the subgroup requirements, if the student leaves the Point of Service (POS) with a reimbursable meal? Salad bars after the POS are acceptable in appropriate circumstances approved by the State agency. In this scenario, for the vegetable subgroups to count, the school has to establish some mechanism to ensure that students are getting the required components and amounts for a reimbursable meal. Otherwise, an un-monitored salad bar after the POS is considered extra food that is not part of the reimbursable meal, but counts toward the dietary specifications. The students must select all the components for a reimbursable meal, including vegetable subgroups, from the hot meal line before the POS. Does free, extra food offered after the Point of Service (POS) to children who have a reimbursable meal count toward the food components and dietary specifications? Additional foods offered to children at no charge who have a reimbursable meal count toward the dietary specifications (calories, sodium, saturated fat, and trans fat). In addition, if the food items are creditable toward a food component in the school meal pattern, they would also be considered when determining compliance with the weekly limits for grains, meat/meat alternates, and juice. However, a school can charge for additional servings of meal components and would be considered a la carte foods. 10

What is a Reimbursable Meal? 11/9/2018 What is a Reimbursable Meal? Reimbursable meals are those that contain all the required food components in the minimum required amounts. 11

Unallowable Meals Off-site Meal Consumption Meals taken off-site are not reimbursable E.g., meals given to children to eat on the bus, take home, etc. Field trip meals are okay since they are part of a school-day related function Watch for sanitation, proper counting, no overt identification Meals not eligible for reimbursement Second meals Meals served to adults A la carte items 12

Claiming

11/9/2018 Overview School meal counts, by category, are submitted to the SFA level on a daily, weekly, or monthly basis Counts are then consolidated into a monthly claim Submitted by the SFA to the OSN in the claim system Claims are due 60 days after the end of the claim month Upward adjustments due 90 days after the end of the claim month Downward adjustments – no time limit but as soon as possible Edit checks at SFA and CDE Claims are paid every other week 7-10 business days after that, to receive check 14

Edit Checks Requirement for lunch; recommended for breakfast 11/9/2018 Edit Checks Requirement for lunch; recommended for breakfast Review count data to ensure claims include only the number of F, R, & P lunches served on any day of operation to eligible children Schools can never claim more F, R, P meals than are served to eligible children x the number of days Attendance factor: 96% Needed Daily number of meals served, by category Number of children approved for free and reduced Go over edit check sheet. Requirement in 210: Each SFA shall review the lunch count data for each school to ensure the accuracy of the monthly claim. Objective: to ensure that monthly claims include only the number of F, R, & P lunches served on any day of operation to children currently eligible. Factors affecting claims: Field trips (students gone) Visiting students (more students) 15

Edit Checks Steps Example 11/9/2018 Edit Checks Steps Compare number of eligible children to number of meals claimed Consider attendance factor Beware of patterns & 100% participation Note factors affecting claims Example See sample edit check sheet Go over edit check sheet. Requirement in 210: Each SFA shall review the lunch count data for each school to ensure the accuracy of the monthly claim. Objective: to ensure that monthly claims include only the number of F, R, & P lunches served on any day of operation to children currently eligible. Factors affecting claims: Field trips (students gone) Visiting students (more students) 16

Reimbursement Rates Federal State Meal type (lunch, breakfast, snack, milk) Eligibility category (F, R, P) Severe need indicator 6 cents State Start Smart (reduced breakfast) All grades $.30 Lunch Protection Act (Reduced lunch) Grades PK, K, 1, & 2 $.40 17

Claim System Needed Walk through 11/9/2018 Claim System https://cde.cnpus.com/codoe/Splash.aspx Needed Password (signs your name to the data) Claim data Number of F, R, enrolled students # of days # of meals by category (including PK2) ACSP: Eligible students, days, snacks served SMP: # of milks purchased, total cost of milk, days, # of milks served Be aware of different pricing options FFVP: Operating & administrative cost info Walk through 18

Miscellaneous

11/9/2018 Monitoring Each SFA with more than 1 school must perform an on-site review of the counting & claiming system By 1 February of each year Follow-up if problems are noted Corrective actions Another visit within 45 days Questions POS: Proper counting & identifying Back-ups Edit checks Non-reimbursable meals Overt identification Go over on-site review handout. 20

Record Keeping Counting and claiming records must be kept on file for five years after the current year – or until audited. 21

Administrative Review Focal Points 11/9/2018 Administrative Review Focal Points The SFA must have a meal counting and claiming system that accurately counts, records, consolidates and reports the number of reimbursable meals claimed, by category (i.e., free, reduced, or paid). Back-up system for counting/claiming meals Training and cross training SOPs for counting/claiming Consolidation process Overt identification Edit checks 2-person POS Policies for student workers, field trips, & pre-paid meals Non-reimbursable meals Non-reimbursable meals: Corrective action may result if the SFA’s policies for incomplete meals, second meals, visiting student meals, adult and non‐student meals, a la carte items…are not in‐line with FNS policy and regulations or require additional information to be appropriate. 22

Review 1. Why is it important to have a pre-payment system? 11/9/2018 Review 1. Why is it important to have a pre-payment system? 2. What are some examples of collection media that can be used? 3. Which coding method would be a best practice? #, $, * Blue = F, red = R, yellow = P 237 = F, 218 = R, 129 = P 4. Y/N: The POS computer screen faces the cafeteria, and there is an A, B, C indicator with the price, but it is very small, in the corner. Is this allowable? 5. T/F: Meals served on an all-cash line may never be claimed for reimbursement. 23

Review 6. Which is allowable? The cashier sits far from the service line and occasionally works on other things, but she knows her count is right since she can easily count the kids who have lunch trays. The cashier is by herself (also serving), so she tries to remember the exact counts, and she writes them down in batches later. The school asks the SA for a 2-person POS approval since there are vegetable subgroups on the salad bar after the POS. 7. T/F: Second meals may be claimed for reimbursement. 8. When are monthly claims due to the SA? 24

Review 9. In your own words, describe an edit check. 10. What 4 pieces of data are needed to enter a lunch claim? 11. T/F: A claim system password may be shared with the superintendent if you are out sick, and the claim is due. 12. Damson Plumb District has an elementary, middle, and high school, and the kids all eat in the same cafeteria. When must the on-site review of counting/claiming be completed? 13. How long must counting/claiming records be kept? 14. What are three focal areas of the Administrative Review for counting/claiming? 25

Thank you. Happy Counting & Claiming! 26