Coordinated Review Effort (CRE) Distance Learning November 7, 2013 Karen Franklin, SNS

CRE school district reviews planned 98 schools within those districts being reviewed Reviewing breakfast and lunch Nutrient Analysis for BOTH breakfast and lunch will be for the week of the review (not previous week)

CRE Announcement Letter Mailed to superintendent and copied to the child nutrition director Sent at least 30 days prior to the review dates Includes list of items needed for review Includes list of items needed for weighted nutrient analysis Includes instructions for information needed to be sent to the area specialist along with the date the information is due

CRE USDA Review Criteria Elementary schools (defined as grades K-8 by USDA) that have 97% of the free eligible students eating lunch each day Secondary schools (defined as grades 9-12 by USDA) that have 77% of the free eligible students eating lunch each day Combination schools (any combination of K-8 with 9-12) that have 87% of the free eligible students eating lunch each day Many high schools in Arkansas are 7-12 schools which would be considered a combination school by USDA regulations

CRE State Review Criteria Low participation schools Provision 2 base year Findings from previous reviews, on-site visits or claims review process Daily meal counts appear questionable Identical or similar claiming patterns Large changes in free meal counts Manager or school never reviewed by state New or unusual accountability system Director or Superintendent request

CRE Site Selection Process Fax or claim along with all daily records or monthly reports to area specialist by date specified on CRE announcement letter Daily records/monthly reports must show each type of meal, by category served at each school (as listed on the Schedule A) for the month of the claim Daily records/monthly reports must also show the free and reduced eligibles for each school (adjusted as needed throughout the month). This is Edit Check 1 and very important part of this record keeping.

CRE Entrance Conference State Agency personnel Superintendent Child Nutrition Director Other personnel as determined to be needed by the superintendent or child nutrition director (for example: determining officials, verifying officials)

CRE Entrance Conference Purpose of the review Description of the review process and scope of review Procedures for findings communications during the review (including technical assistance and corrective action) Set date and time of exit conference

CRE Review Location – Place to Work Private place to work – confidential information Close to or easy access to determining official and all eligibility determination documents Table space to spread out

CRE While the CRE covers many, many aspects of the child nutrition program there are two areas that can cause fiscal action (meaning money would have to be returned )

CRE Fiscal Action PS 1 Certification (application approval) Issuing benefits (rosters, class lists, checklists, tickets) Meal counts and claiming Fiscal Action PS 2 Meal component errors

CRE Performance Standard 1 (PS1) Certification/Counting/Claiming – All free, reduced price and paid breakfasts and lunches claimed for reimbursement are served only to children eligible for free, reduced price and paid meals, respectively; and counted, recorded, consolidated and reported through a system which consistently yields correct claims.

CRE Performance Standard 1 (PS1) Every student receiving free or reduced meals must have a source document (application, name on DC list, etc.) Count by category at point of service must be accurate Consolidation of meal counts for claims must be accurate

CRE Performance Standard 2 (PS2) Components – Breakfasts and Lunches claimed for reimbursement within the school food authority contain food items/components as required by program regulations.

CRE Performance Standard 2 (PS2) Every meal claimed must meet all meal pattern requirements and have appropriate documentation Components (meat/meat alternate, red/orange vegetable, etc.) Contributions (how the item served contributes to meal pattern) Dietary specifications (calories, saturated fat, trans fat, etc.)

CRE Review Period Claim for Reimbursement The month of the most recent claim for reimbursement that has been filed with state agency (must be at least 10 days) We must confirm ALL ASPECTS of the claim – source documents for everything on the claim form Revenues Expenses Eligibles Meals claimed by type and category Unpaid bills, funds due to program, etc. Inventory

Source Documents/Rosters Source Documents Approved F/R meal application Student name on direct certification list Student name listed as other students in household with direct certification students (list, on duplicate app, etc.)

Source Documents/Rosters Student name on other source categorically eligible lists Homeless Migrant Runaway Head Start Even Start Foster

Source Documents/Rosters Rosters Point of Sale Roster APSCN/eSchool Roster Child Nutrition Master Roster Any student listed as F/R must have source document All rosters must match eligibility status for each students source document 100% of students on rosters for the schools reviewed will have source document review

Scope of Review Free & Reduced Price Meal Eligibility Process Child Nutrition Master Roster APSCN or e-School plus Roster with meal status Point of Service (POS) Roster or paper method

Scope of Review Verification: Narrative Description & Verification Collection Report Civil Rights Compliance Reporting & Record Keeping Responsibilities Breakfast & Lunch Program; participation (average daily participation in programs)

Scope of Review Use & Storage of Commodities; warehouse inspection (if applicable) Food Safety Plan (HACCP Plan including Standard Operating Procedures (SOPs)) Sanitation/Copy of the two (2) most recent health inspection forms (most recent inspection posted in publicly visible area?)

Scope of Review Current Wellness Committee Members, Wellness Policy, ACSIP Plan Please review Commissioners Memo FIN Wellness Committee Responsibilities – especially the Wellness Committee Responsibilities Documentation Form

Scope of Review Competitive Foods (State & Federal Standards) Nutrition & Physical Activity Standards (Copy of Pouring Rights/Beverage Contracts) REMINDER – USDA has issued rules for All Foods on Campus which are effective July 1, 2014 – BE PREPARED

Scope of Review Quality of Food Time to Eat Cafeteria Atmosphere/Supervision Facilities/Equipment

Scope of Review After School Snack Program (if applicable) Seamless Summer Program (if applicable) Fresh Fruit and Vegetable Program (FFVP) (if applicable) Pre-School Programs (if applicable)

Nutrient Analysis Sheila is going to talk to you a little about the weighted nutrient analysis as compared to the simplified nutrient analysis The nutrient analysis will be performed for BOTH breakfast and lunch The nutrient analysis will be for the WEEK of the on-site portion of our review Based on completed production records – may have to mail the end of the weeks production records to us after the review

Nutrient Analysis Documentation needed for nutrient analysis Menus served, including serving size and menu contribution Completed production records Recipes to support the daily menu and production record Nutrient fact labels and CN labels or Product Formulation Statements to support each recipe used in production of menus

Nutrient Analysis Menus and Production Records Include all menu items served on all lines open for service Indicate the meal, day, Offer vs. Serve, varied portions, choices and grade levels USDA, ADE or local recipe number on production record The meal pattern contribution for each menu item All condiments, extras, milk, etc., other beverages If the menus have been analyzed using one of the approved USDA nutrient analysis programs, print the menu analysis and production record for review

Nutrient Analysis Standardized Recipes Recipes are needed for each menu item served during the review week. If USDA or ADE recipes are used exactly as printed, indicate the recipe number on the production record. If any changes have been made to the recipe or if it is a local district recipe, include ingredients (type or measure), serving size or preparation techniques or indicate the changes to the original recipe. Print recipes that have been entered on a nutrient analysis program and have a copy available. REMINDER - the Vegetable and Fruit contribution on USDA and ADE recipes may have changed. VERIFY!!!

Nutrient Analysis Standardized Recipes Recipe name Ingredients Exact weight/measure for each ingredient listed Directions/instructions for production Serving size, indicate portion size served if varied portions are served for grade levels. Yield – number servings recipe makes Variations and other notes for success Marketing guide as needed Pan size, as needed Meal pattern contribution

Nutrient Analysis Product/Nutrient Information Provide printed product/nutrient information sheets for all menu items served during the review week, including USDA Donated Foods. In addition, provide copies of current Child Nutrition (CN) product labels for products served to students. In order for a CN label to be used it must be currently approved by USDA and MUST be listed on the USDA CN Label website at:

Nutrient Analysis Product/Nutrient Information If a combination product is purchased that does not have a CN label then a Product Formulation Statement from the manufacturer is required to document meal pattern contribution. Product/nutrient information is needed on all prepared entrees, salad dressings, seasoning mixes, prepared desserts, soup and gravy bases, etc.

Nutrient Analysis Product/nutrient analysis information should include the following: Product name Manufacturer name Meal component contribution CN Label (if applicable) Product Formulation Statement (if applicable) Serving size Calories per serving Grams of Saturated Fat per serving Grams of Trans Fat per serving Milligrams of Sodium per serving

Nutrient Analysis The information for the Nutrient Analysis will be taken back to our office and the area specialist will use nutrient analysis software to analyze the menus served If the area specialist does not have all the information needed they will be contacting you for the information needed. Please respond quickly!! Nutrient Analysis findings letter will be sent to superintendent and child nutrition director

Review Activities During the review any non-compliance issues will be addressed with technical assistance at the time of the review If non-compliance issues cannot be corrected at the time of the review further technical assistance visits may be necessary ALL items addressed through technical assistance during the review process MUST be addressed in the exit conference with the superintendent and MUST be addressed in the CRE results letter We are no longer allowed to just get it fixed and go on – we are required by USDA to document everything in the review findings letter – SORRY!!!

Post Review Exit conference Benefit issuance findings Review results letter Weighted nutrient analysis Nutrient analysis findings letter Corrective action requirements Corrective action plan from district

Exit Conference Exit conference at the end of the review is required by USDA Should include state agency personnel, superintendent, child nutrition director, other personnel as needed (for example if there are benefit issuance problems the determining official may be required to attend the exit conference) Will provide a preliminary assessment of the violations observed, the extent of the violations and a preliminary assessment of action needed to correct the violations. Discuss and define appropriate deadlines for completion of the Corrective Action (CA), provided the deadline(s) result in the completion of CA on a timely basis.

Exit Conference We will discuss which school(s) had findings and/or violations, and cite the causes and magnitude of deficiencies. We will address the numbers and types of errors that were discovered, We will provide a copy of the completed CERTIFICATION AND BENEFIT ISSUANCE ERROR WORKSHEET(s), for use in identifying the eligibility certification, benefit issuance errors, and updating eligibility errors.

Post Review After every review, the State agency must provide written notification of the review findings to the SFAs Superintendent (or equivalent in a non-public SFA) or authorized representative – within 30 days of review. The written notification must include the review findings, the required CAs, the deadlines for completion of the CA, and the potential Fiscal Action.

Post Review If review findings initiate or terminate the SFAs receipt of the performance-based reimbursement (six cents), the State agency must notify the SFA at the exit conference. If findings result in the performance-based reimbursement being terminated, the State agency must provide corrective action and technical assistance and ensure the SFA understands steps that must be taken to reinstate the performance-based reimbursement.

Corrective Action (CA) Corrective actions are those actions that are taken by a SFA to correct any degree of violation in the Critical and General Areas of Review. Additionally, if during the course of the review, a Program violation is identified that is outside the scope of AR, CA would also be required. SFA may provide input on CA approaches that will achieve the desired result SA may offer technical assistance for deficiencies cited

Corrective Action (CA) CA establishes the extent of the fiscal action taken, it is important the SFA implements CA in a timely manner. Explain that withholding of payments will result if CA is not taken Explain how FA will be calculated. At the State agencys option, a potential claim amount may be discussed

Corrective Action (CA) The State agency must provide a preliminary assessment of the actions needed to correct the violations. This assessment should be based on discussions of CAs and TA at the SFA/school levels Problems identified must be corrected system- wide. Therefore, effective CA must be taken by the SFA in all schools and Programs, not just those reviewed.

Corrective Action (CA) Documentation of CA is required for any degree of violation in either the Critical or General Areas that are identified during an review. Documented CA should also include any program violations identified outside the scope of a CRE Unless documented CA is provided at the time of the review, the SFA must send written notification to the State agency certifying that the CA required for each violation has been completed, and notify the State agency of the dates of completion. The State agency will make the determination as to when a problem is satisfactorily corrected.

CA Timeframes The State agency must establish appropriate timeframes for the SFA for each problem requiring CA State agency must receive the documented CA plan by the established deadline – READ the review results letter carefully!!! In the past the CA deadline was not as critical as the new requirement. Please pay close attention to this and follow the required timelines.

CRE Meet the corrective action plan deadline (if applicable) – again read the review findings letter carefully. May receive a separate letter for the nutrient analysis findings which may or may not result in additional corrective action not discussed in exit conference. Read the review results letter carefully. If you have any questions or problems call the area specialist.

Follow Up Review When the follow-up review is required it is primarily the responsibility of the State agency, it may be conducted by either the State agency or FNS. All SFAs found to have exceeded the review threshold(s) are subject to a follow-up review.

CRE Part of the Healthy Hunger Free Kids Act of 2010 will require that review findings be posted at the cafeteria and the findings be made available to the public. At this time USDA has not published the rules and guidance on this issue yet, so there is not a this moment a method of handling this requirement. Keep in mind that this will happen, probably sometime during this new three year review cycle. It may happen that a year or two from now USDA publishes the rule and guidance and requires that all findings beginning with this school year be made available.

CRE Read the announcement letter carefully. If you have any questions or problems call the area specialist. Send pre-review documentation by the date established in the announcement letter. Read the review results letter carefully. If you have any questions or problems call the area specialist.

CRE We have several new staff members now and others coming still during this school year. Do not be surprised if you have more than one person show up to do the review as all the new staff members will be in training this school year. The Southwest Regional Office of USDA (in Dallas) has requested (as usual) our review schedule so that they can determine which reviews they will accompany us. In the past they have let us know ahead of time if they will be with us on a review; if they continue this practice then we will let you know they are coming on the review.

CRE Based on new federal requirements for state agencies we are required to document every thing we do on a review (including technical assistance) and cover it with the exit conference and the review findings letter. While this may seem like we are out to get you that is definitely not the case.We are required to follow federal regulations, just like you are. Please dont take it personally!

Questions? Ask them now!!!