Detailed information for each area covered in this review may be found on the DPI website at 1

The New AR: Performance Standards 2 Critical Areas  Performance Standard 1  Performance Standard 2 General Areas  Resource Management  General Program Compliance Regulatory Authority for the Administrative Review can be found in 7CFR 210, 220 and 245, The Richard B. Russell National School Lunch Act, the Child Nutrition Act of 1966, Section 201 of the Healthy, Hunger-Free Kids Act of 2010 and Public Law

Review Period 3 Most recent month for which a claim was submitted  Must include > 10 operating days  Special Circumstances Reviews early in school year Year round, multi-track, & provision schools May require approval or special procedures

New Administrative Review Structure 4 Section 1Section 2Section 3 Access & Reimbursement Eligibility Determination Benefit Issuance Direct Certification Verification Meal Counting, Claiming and Reimbursement Nutritional Quality/Meal Pattern Meal Components Offer versus Serve Dietary Specifications and Nutrient Analysis Resource Management Nonprofit School Food Service Account Paid Lunch Equity Revenue from Non-program Foods Indirect Costs USDA foods Section 4Section 5 General Program Compliance Civil Rights SFA On-site Monitoring Local Wellness Policy Competitive Foods School Env. Report Card Water Food Safety SBP & SSO Outreach Other Federal Program Reviews Afterschool Care Snack Program Seamless Summer Option Fresh Fruit and Vegetable Program Special Milk Program

Review Frequency & Schedule 5 Review Frequency  SFA must be reviewed every 3 years  Cycle begins July 1, 2013 AR Schedule for SY  Schools scheduled in will be reviewed in 13/14 CESA 2, CESA 8, and Lower half of CESA 4  Schools that did not certify in will be subject to review in  A list of SFAs that will be reviewed in can be found on the DPI website at

School Site Selection 6  If more than one school is listed on Schedule A of your on-line contract, you will need to complete a site selection form  Complete the form using claim information for the month of October 2013 > School Name > Number of serving days > Number of free eligible > Number of free lunches claimed

Minimum Number of Review Sites 7 Review all sites (except RCCI) with free ADP of 100 students and free participation factor of > 100%. All meal patterns must be represented for schools which are NOT $.06 Certified

BENEFIT ISSUANCE ELIGIBILITY DETERMINATION DIRECT CERTIFICATION VERIFICATION MEAL COUNTING & CLAIMING 8 Access and Reimbursement

Access and Reimbursement Overview 9 Administrative Review Performance Standard 1 Eligibility Determination Benefit Issuance Meal Counting and Claiming General AreasVerification

The New Administrative Review Process 10 On-site Review Validation Questions Off-site Assessment Tool Evaluation Questions

School Food Authority (SFA) Certification of Eligibility  Benefit Issuance  Eligibility Determination  Direct Certification  Verification Meal Counting and Claiming  Site-level Review  SFA-level Review 11 Access and Reimbursement

12 Access and Reimbursement CERTIFICATION AND BENEFIT ISSUANCE

Eligibility and Benefit Issuance 13 Information requested:  How student was certified for benefits  Who is Hearing Official  Back-up system  School Calendar for school start date and approval timelines  F/RP meal application materials sent to household  How is Direct Certification conducted

Direct Certification (DC) 14  Name(s) of the individual(s) responsible for processing the DC listings and issuing benefits to eligible students.  A copy of the letter used by the SFA to notify households of their direct certification eligibility.  A description of the SFA’s procedures for extending DC eligibility to all children in the Foodshare or W-2 household

Eligibility 15 Other items that will be assessed:  Conversion factors and income guidelines  How SFA handles carryover of previous school year’s eligibility (up to 30 Operating Days)  Length of time for application approval  How SFA updates eligibility changes  Method used to notify households of student’s eligibility determination  Who has access to benefits issuance documents  Applications include all required elements

Benefit Issuance 16 F/RP meal applications to be reviewed All applications in SFA (must be reviewed if less than 100 students certified for F/RP meal benefits) Statistical Sampling for SFAs with 100 or more students certified for F/RP meal benefits SFA-wide Benefit Issuance List requirements :  Name/Benefit Status for all F/RP eligible students  Generated from Point of Service used in each school  No Duplicate Names  School Name, Certification Method, Certification Date, Total number of eligible students  Do Not Group by Free and Reduced eligibility status  May be any day during the review period

 Review minimum of 10 denied applications  Notification of denial  Reason  Appeal Rights and Instructions  Family may reapply 17 Reviewing Denied Applications

Common Findings 18 Reimbursement claimed for student meals when no approved application is on file F/R apps not processed within 10 operating days of receipt Data entry error results in incorrect eligibility status Income Application missing required information Incorrect number recorded as case number SFA did not use Direct Certification for students who receive Foodshare or W-2. One student is receiving free DC benefits but siblings are not Confidential eligibility information is released for unauthorized purposes or without prior consent Student eligibility status is not updated in (POS) or roster

Corrective Action 19 Required for Findings/Errors Must be applied SFA-system wide Formal response required from SFA

Fiscal Action 20 Reasons Fiscal Action is taken?  Applications missing information  Incorrect categorization of eligibility  Benefit Issuance Errors  Failure to update verified applications How far back is fiscal action taken ?  Can be back to the original date of eligibility

VERIFICATION 21 Access and Reimbursement

Verification Collection Report (FNS 742 Report) Questions Verification Collection Report (FNS 742 Report) Questions  Accuracy of Verification :  Sample Size  Reporting fns.dpi.wi.gov/files/fns/pdf/gm_sp_38_ Verification

23 Verification Official and Confirming Official Description of SFA Verification Process Participation in Training Electronic System

Determining Compliance 24 Verification Requirements  Number of Verified Applications  Calculated Correct Sample Size  Verified Correct Number of Applications for Sample Size  If applicable, replaced applications accurately  Notification letters meet FNS requirements  Household follow-up attempts were made  Notice of adverse action met FNS requirements  Timeliness of eligibility status changes  Completed the verification process by November 15

Common Verification Errors 25 Verification process did not begin on October 1 Verification process did not end by November 15 Verification did not take place at all Verification Collection Report not submitted by February 1 An application was pulled for Direct Cert. student SFA uses an incorrect verification method. The sample pool does not round up No follow-up attempt to collect verification information Follow-up attempt not documented No replacement application selected for withdrawn student The software not updated

MEAL COUNTING & CLAIMING 26 Access and Reimbursement

Counting, Claiming, and reimbursement 27 Meal counting and claiming system accurate by category Meals counted, consolidated, and recorded correctly Accuracy of meals claimed and reported for reimbursement

Electronic vs. Manual Standard Counting Procedures Point of Service Back-up System Training 28 Meal Counting and Claiming

29 Provide an accurate count taken at the point of service daily number of reimbursable meals served by category without overt identification

Meal Counting and Claiming 30 Complete edit checks for potential over-claims  Federally required  Conducted on a daily basis at the school/site level  Conducted on a monthly basis at the SFA level  Resolve discrepancies before filing claim for reimbursement

Meal Counting and Claiming 31 Site Level ● Prevention of Overt Identification ● Accurate Count by Category ● Overrides ● Validate the meal count by type ● Fiscal Action Validating Counting & Claiming

Meal Counting and Claiming 32 Site Leve l ● Meal count comparison to review period ● Meal count comparison to free and reduced-price students ● Meal count comparison to attendance adjusted eligible ● School meal counts vs. SFA claim for reimbursement

Common Findings 33 Each service line does not provide an accurate count by eligibility category at the Point of Sale (POS). Meal counts incorrectly consolidated or not done daily. There are questionable patterns in the meal counts. Effective edit checks are not conducted as federally required.

Systemic Non-Systemic 34 Errors

Systemic Non-Systemic Errors will result in fiscal action CA is required Follow up from SA may be required for the CAP Errors may result in fiscal action CA may be required 35 Meal Counting and Claiming Errors

Fiscal Action Errors 36 Meal Count Combining Errors  Fiscal Action for difference between incorrect and correct meals Counting Errors  Meal counts do not equal number of meals served to eligible students  Meal counts exceed number of eligible students by category  Second and/or ineligible meals were counted

USDA Non-discrimination Statement 37 The U.S Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.) If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at or at any USDA office, or call (866) to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C , by fax (202) or at Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) ; or (800) (Spanish). USDA is an equal opportunity provider and employer USDA Program Discrimination Complaint Form