Joyce Soroka Supervisor of Field Services

P.L , Section 126 Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Administrative Error Reduction Administrative training and technical assistance materials

 State Agency  School Food Authorities (SFA)  Local Education Agencies (LEA) Sec. 126 (a) provides funding to develop and distribute training and technical assistance materials at the Federal level with input from: Materials will relate to improving:  Program integrity  Administrative accuracy  Review of administrative practices of SFA Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Administrative Error Reduction Administrative training and technical assistance materials

Sec. 126 (b) provides funding for additional administrative reviews  Implementation date is July 1,  Beyond current CRE requirements  Performance criteria established by FNS - LEA demonstrates a high level of or high risk for administrative errors Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

Criteria established for additional administrative reviews:  Determined based on an initial and/or first follow- up CRE review  Areas of review similar to CRE Review based on Performance Standard 1  Review only the administrative processes Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

Procedures may include:  Applications  Certifications  Verification  Meal counting  Meal claiming Procedures not included:  Menu & production record type finding  Nutritional content of foods offered to students Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Additional administrative reviews

Correction process similar to CRE review process  Develop and carry out Corrective Action Plan  State Agency provides technical assistance  Conduct a follow-up review  Improperly paid funds may be recovered Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

 is the second year of the current 5- year cycle  2 Areas of Review-Critical and General  Critical Areas are based on Performance Standards Problems found result in Performance Standards being exceeded Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Coordinated Review Effort (CRE)

 Free and Reduced Applications correctly approved  Meals counted and claimed accurately which consistently yield correct claims: At the Point of Service by category on the Day of Observation Meal consolidation for the Review period Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Critical Area – Performance Standard 1:

Menu meets food item requirements for  Day of Observation Meals observed contain required food items for all lunches claimed  Review period  Review of menu determines that food items are offered as required Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Critical Area – Performance Standard 2:

Incorrect determination of Free or Reduced benefit Errors in counting and claiming system Threshold exceeded by building 10% or more of meals observed missing food items Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Review thresholds only for critical areas due to: Performance Standard 1: Performance Standard 2:

Possible Fiscal Action for errors found:  $ disregard for Overclaim per Program  $25.00 disregard for Underclaim per Program Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Corrective Action needed for problems found

Nutrient analysis done for one week of menus in Review Period based on:  Menu Records  Standardized Recipes  Production Records  Manufacturer Product Information Sheets Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 School Meals Initiative (SMI)

 Results compared to USDA Nutrition Standards for age/ grade groups  Advisor does re-analysis, if needed, and suggests correction to meet the Nutrition Standards  Corrective Action written for exceeding the thresholds established for: Total Fat Saturated Fat Calories Protein Vitamin A Vitamin C Iron Calcium Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 School Meals Initiative (SMI)

Common Problem Areas – Coordinated Review Effort  In computerized Point of Sale systems SFA’s need to provide the list of students eligible from the computer system to ensure data entry is input accurately from determining officials benefit issuance list Free and Reduced Applications and Benefit Issuance Lists  In SFA’s using software programs to determine eligibility someone needs to ensure accurate determinations are used for income Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Every 2 weeks 2.15Twice monthly 2.0,Weekly 4.33,

Meals counted and claimed accurately which consistently yield correct claims at the Point of Service by category on the Day of Observation  Computerized System not working during observation of meal service and no adequate back up system in place for accurate meal counting  Claiming newly enrolled children in the free category until an application is submitted Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Common Problem Areas – Coordinated Review Effort

 Students are not required to use the system such as entering their PIN; lunch is entered into the system as “No ID Cash.” No check in place that this is not a second lunch for the student.  Written charge meal policy not followed  Claiming charged lunches when paid not when served Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Meals counted and claimed accurately which consistently yield correct claims at the Point of Service by category on the Day of Observation (continued) Common Problem Areas – Coordinated Review Effort

Meal consolidation for the test month: Math errors found in non-computerized systems Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Common Problem Areas – Coordinated Review Effort

Not many problems unless one of the food items becomes unavailable during lunch service Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Critical Area – Performance Standard 2

Under Reauthorization  Household applications are required  Errors in determination will be applied to all children in the Household  Not just the children in school buildings reviewed Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

Milk Requirement Requires that lunches served include fluid milk in a variety of fat contents. Schools are encouraged to offer children low fat (1%) and fat free milk. Other types of milk may be offered. Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

Common Problem Areas – General areas of review Verification  No change in benefit issuance list based on changes for applications  Adequate number of applications not verified  Not all income listed on the application is verified  No documentation available of how verification determination was made Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005

 No comments when computerized system is utilized  No comments when edit checks exceed number eligible children times attendance factor by category  Not completed by Feb 1 Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Edit Checks Monitoring Common Problem Areas – General areas of review

 Alternative Ed sites either not listed as a separate site or if they are, separate records are not maintained  Correct/change Menu planning option not reported  Implementation of Offer versus Serve not on Application  Foods of Minimal Nutritional Value  Unequal choices offered in Offer versus Serve Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005 Record keeping Few problems with: Common Problem Areas – General areas of review

 Records are incomplete or do not exist. This results in a follow-up review.  Total fat exceeds 30%  Saturated Fat exceeds less than 10%  Lunches are low in calories  Lunches are low in iron  Lunches are low in Vitamin A  Food Service Directors are unable to answer the Nutrition Education Questions Common Problem Areas – School Meals Initiative Reviews Changes in Child Nutrition Program Law and Regulations Pennsylvania Department of Education, June 2005