1. Counting and Claiming Presented by: Linda Stull
Grants Coordination and School Support
School Nutrition Training and Programs
Hi,
I’m Linda Stull, a Consultant for the Michigan Department of Education, School Nutrition Training and Programs unit. The purpose of the following webcast is to provide guidance to the SFA in the implementation of an acceptable meal counting and claiming system.
After viewing this webcast, you are encouraged to view the additional CRE related webcasts, which cover other areas of CRE subject matter in greater detail.

2. Introduction
Counting and Claiming is a Critical Area of Review in a Coordinated Review Effort (CRE) review and is covered under Performance Standard 1.
It should be noted that any system, no matter how well structured, can fail if it is not implemented correctly. It is essential to ensure that all personnel involved in the system are properly trained and that all officials in the school system understand their roles in making the school food service programs accountable.

3. Introduction
A lunch counting system must yield correct claims. A counting system takes into consideration:
Correct claim consolidation
Use of edits checks, prior to submission of monthly claim
The SA will determine whether the system is adequate and within the timeframes established in regulations
The system shall:
Accurately reflect eligibility status as well as changes in eligibility made after the initial approval process due to verification findings, transfers, reported changes in income or household size, etc.

4. Federal Reimbursement
To receive Federal reimbursement payments to finance nonprofit school food service operations, each school food authority (SFA) shall ensure that a monthly Claim for Reimbursement is limited to the number of free, reduced price and paid lunches that are served to children eligible for free, reduced price and paid lunches respectively, for each day of operation.

5. Lunch Count System
To ensure that the Claim for Reimbursement accurately reflects the number of lunches served to eligible children, the SFA shall, at a minimum:
Base the Claim for Reimbursement on lunch counts, taken daily at the point of service
The lunch counts must correctly identify the number of free, reduced price and paid lunches served to eligible children

6. Lunch Count System
To ensure that the Claim for Reimbursement accurately reflects the number of lunches served to eligible children, the SFA shall, at a minimum:
Correctly record, consolidate, and report lunch counts on the Claim for Reimbursement

7. Lunch Count System
To ensure that the Claim for Reimbursement accurately reflects the number of lunches served to eligible children, the SFA shall, at a minimum:
Ensure that the Claim for Reimbursement does not request payment for any excess lunches produced
This includes a la carte sales ,adult lunches, or for more than one meal per child per day

8. Elements of an Acceptable Counting and Claiming System

9. Elements of an Acceptable Counting and Claiming System
Elements of an acceptable counting and claiming system include:
Eligibility documentation
Collection procedures
Point of service (POS) meal counts
Reports
Claim for reimbursement
Internal controls
Let’s review each of these elements in the next slides.

10. Eligibility Documentation
Eligibility documentation is either:
A current, approved free or reduced price application
A list of students’ names obtained under the direct certification process
There must be documentation supporting the eligibility of each child receiving free and reduced price meals.

11. Collection Procedures
Collection procedures refer to all the steps within the meal count system involved in paying for meals and issuing and collecting the medium of exchange.
A medium of exchange is defined as cash or any type of ticket, token, ID, name, or number that eligible students exchange to obtain a meal.
Collection often occurs simultaneously with meal counting. Collection procedures should facilitate rather than inhibit the meal count system. Also, overt identification must be prevented during issuing and collecting the medium of exchange.

12. Collection Procedures
Overt Identification
Eligibility information must never be publicized or used in such a way that students’ eligibility categories may be recognized by other students.
Students receiving free or reduced price benefits must not, at any time, be treated differently from students who do not receive these benefits.
SFAs are required to ensure that there is no physical segregation, discrimination, or overt identification of any student eligible for free or reduced price benefits.

13. Point of Service (POS) Meal Counts
Meals are counted at the point in the food service operation where it can be accurately determined that a reimbursable free, reduced price, or paid meal has been served to an eligible student.
If meals are counted at the beginning of the serving line, someone must check to ensure all required food items have been taken.

14. POS Systems POS systems must ensure that meals counted:
Meet the meal pattern requirements
Are served to eligible students
Are counted daily by category
Also, only one meal per student per meal service may be claimed for reimbursement. Adult meals, a la carte items, and second meals are not reimbursable and should be accounted for separately.

15. Acceptable POS Systems
Class roster check list
School roster check list
Computerized barcode ID cards
Ticket system
Cash register code system
Prepaid list

16. Acceptable POS Systems Key Points
Daily count must be taken at the point of service
Meal count must be by category (free, reduced price, paid)
An application must be on file documenting eligibility for each child claimed as free or reduced
You should never claim more free or reduced price meals than applications you have on file.

17. Unacceptable POS Systems
Morning classroom counts
Claims based on attendance records
Counts based on tickets/tokens sold in advance
Counts at beginning of serving line with no verification that required food items were taken

18. Unacceptable POS Systems
Meal counts based on visual identification
Tray or plate counts
Back-out systems
Systems that overtly identify free or reduced children
Any system that allows students to be counted twice

19. POS Rosters
A roster must be up-to-date and accurately reflect the correct eligibility category of each student in order for the meal count, by category, to be correct.
Inaccurate counts may occur if the rosters are not current with the status and total numbers of eligible students, or if the meals served are not counted at the point where it can accurately be determined that they are reimbursable.

20. POS Rosters
Rosters must be updated in accordance with Food and Nutrition Service (FNS) regulations and policies when there is any change in eligibility determinations.
The names of students who have withdrawn from school should be marked off and the date of withdrawal date should be noted. Names (or codes) and eligibility categories of newly enrolled students must be added and the date noted. Eligibility changes due to verification must also be made and dated.

21. Sample Class Roster
The word “roster” refers to a list of eligible students used at the POS to record reimbursable meals served. Rosters may be manually prepared lists or computer-generated printouts. This form is designed to be used at the point of service to mark as students receive reimbursable meals.
Food service staff may request an estimated participation count from the classrooms since this aids in their planning of meal quantities. Actual meal counts may NOT be taken by the teacher before the meal service and turned into the cashier. This would not result in a POS meal count.

22. Example of a Coded Roster

23. Reports
The numbers of reimbursable meals served daily by category to eligible students are recorded and reported by school food service personnel to the SFA.
The particular recording method used must ensure that correct counts by category are reported in a way that can easily read, edited, and consolidated into an accurate monthly claim for reimbursement.

24. Reports
The following are examples of forms that may be used to consolidate reimbursable meals into daily/weekly/monthly food service reports.
The first two forms are used by schools on a daily or monthly basis. The last form is an SFA form consolidating total meal counts by category from each school for the claiming period.

25. Daily Report
“School Lunch Daily Report” is a simple form that can be completed after the meal service which records daily counts, by category. All of the daily reports for a claiming period would be consolidated to have a total monthly meal count by category.

26. Monthly Report
“Monthly Participation Record” provides the number of meals served, by category, for the claiming period.

27. Monthly Consolidation Report
A monthly edit check/report should be completed as part of the consolidation of school claims to ensure that the number of meals claimed does not exceed the current enrollment and that the number of free or reduced price meals claimed does not exceed the number of approved applications.
“School Breakfast and/or Lunch Tabulation Sheet” is a form on which the school food authority consolidates monthly meal counts by category and by school/agency within its jurisdiction.

28. Claim for Reimbursement
School meal counts, by category, are submitted to the SFA on a daily, weekly, or monthly basis
The counts from all schools are combined to generate a monthly claim for reimbursement
This is called consolidating the claim

29. Claim for Reimbursement
After the claims are consolidated, they are submitted by the SFA to the State agency (SA). The SA is responsible for paying the federal reimbursement for the reimbursable meals claimed as served by category during the claim period.
Reimbursements rates are different for each category of meal benefit (free, reduced-price, and paid) and for each type of meal service (lunch, breakfast, and snacks). Thus, accurately counting, recording and consolidating the number of meals served by category is the only way a claim for reimbursement can be properly submitted and an SFA be correctly paid for the meal served.

30. Claim for Reimbursement
Monthly claims for reimbursement are submitted electronically using the Michigan Education Information System, or MEIS.

31. SM-4012-SL Claim
Claims for reimbursement may be submitted beginning the 10th day of the month following the claim month.

32. Internal Controls
An SFA must establish internal controls to ensure that an accurate claim for reimbursement has been made
Internal controls protect SFAs from having erroneous claims and potential overclaims
Edit checks and monitoring are examples of internal controls

33. Internal Controls – Edit Checks
Edit checks compare meal count data to other information (e.g., number of eligible students and attendance figures, etc.) to identify possible problems in the meal count system.
Any meal counts that do not seem reasonable should be explained or investigated to ensure accuracy
A test of reasonableness cannot be defined for all circumstances, but examples of what could be considered “unreasonable” unless explained will be shown on the following slides.

34. Internal Controls – Edit Checks
National Daily Attendance Factor
The National Daily Attendance Factor is a percentage determined by the United States Department of Agriculture (USDA) at least once each year that accounts for the difference between enrollment and attendance.
The factor is calculated by dividing the total national average daily attendance by the total enrollment.
The CRE reviewer will be checking to see if there were any days when the free lunch count exceeded the number of attendance adjusted eligible students.

35. Internal Controls – Edit Checks
Here’s another example of a completed monthly participation record, by building, using the National Daily Attendance Factor as part of the edit check.

36. Internal Controls – Edit Checks
National Daily Attendance Factor
School food authorities must document any reported total meals that exceed the National Daily Attendance Factor percentage of enrollment multiplied by days served.
The same documentation is required for TOTAL FREE MEALS and TOTAL REDUCED PRICE MEALS that exceed the established attendance factor.
Without completion of the documentation, claims exceeding the National Daily Attendance Factor percentage factor cannot be submitted for payment.

37. Internal Controls – Edit Checks
National Daily Attendance Factor
The required documentation of the National Daily Attendance Factor is part of the monthly claim form. Each time the number of meals for a site exceeds the attendance factor, an error will be displayed on the claim screen.
The “Justification for Exceeding the Attendance Factor” form will be displayed. The reasons(s) for exceeding the factor must be entered and the form submitted (online) in order to certify the claim.

38. Internal Controls – Edit Checks
“Unreasonable counts” may include:
Meal counts that exceed the number of eligible students in attendance on any given day
Constant counts - meal counts are the same every day
Meal counts where extremely high percentages of eligible students eat every day
Pattern counts - counts that seem to repeat in patterns
Served count equals the delivery count for vended meals
The reviewer will look for any patterns in meal counts, considered “unreasonable counts”. Examples of unreasonable counts are listed on this slide.

39. Internal Controls – Monitoring
Monitoring ensures that the school's meal count reports are based on an approved counting system and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price, and paid meals served for each day of operation.
If monitoring discloses problems with a school's meal counting or claiming procedures, the SFA must ensure that a corrective action plan is implemented and problems are resolved.

40. Internal Controls – Monitoring
On-Site Reviews
NSLP regulations require that an SFA with more than one building must conduct an on-site review in each building annually before Feb. 1
Assesses:
Meal count systems
Edit checks
On-site reviews are a self-monitoring tool for SFAs to ensure their programs are in compliance with National School Lunch, School Breakfast, and Afterschool Snack Program regulations.

41. Internal Controls – Monitoring
MDE Administrative Policy for On-Site Reviews
Results of Review - Problems discovered on either NSLP/SBP On-Site Review or Afterschool Snack Program On-Site Review must be discussed with the person overseeing meal service at the school building. A corrective action plan must be developed and implemented for the school building by the SFA.
MDE Administrative Policy No. 9 - School Year addresses the on-site monitoring requirements for an SFA. Included in monitoring responsibilities are: meal count systems, edit checks.

42. Internal Controls – Monitoring
In any buildings with a corrective action plan, a follow-up review must be conducted within 45 calendar days of initial review. This follow-up review must be conducted and documented by the SFA and identify that the problem(s) has been corrected.

43. Point of Service Systems
Each SFA should have a viable Point of Service system. We’ll very briefly address considerations in choosing a POS system in the next few slides.

44. Choosing a System
Several factors should be considered before deciding which POS system to use. The system chosen will depend on the:
Number of meals served
Number of students participating in the program
Grade levels involved
Cost of implementing and maintaining a collection procedure
Personnel (office or food service) who will be responsible for sales and recordkeeping
Number of employee hours available for sales and recordkeeping

45. Areas of Consideration for Choosing a System
Administrative considerations:
Edits and internal checks
Reports, personnel/training
Account balances maintenance
Financial analysis (budget/sales)

46. Areas of Consideration for Choosing a System
Cost of implementation:
Daily operations
Personnel training (cost/time)
Hardware
Software program
Support/updating processes
Maintenance/repair (registers, computer terminals, etc.)

47. Summary
Counting and Claiming is a Critical Area of Review in a Coordinated Review Effort (CRE) review and is covered under Performance Standard 1.

48. Summary
A school food service meal counting and claiming system must contain basic elements:
Eligibility documentation
Collection procedures
POS meal counts
Reports
Claim for reimbursement
Internal controls
How each element is implemented may vary depending on the specific procedures chosen by a SFA. All necessary elements must be in place before any meal counting and claiming system can meet the accountability requirements.