1. Meal Counting and Claiming

2. Learning Objectives
Identify and briefly describe each of the six elements of meal counting and claiming.
Select appropriate OSN meal counting and claiming resources to support program needs.
State the importance of meal counting and claiming in operating a successful school nutrition program. 2

3. What is meal counting and claiming?
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What is meal counting and claiming?
Accurately counting, recording and claiming meals for eligible students (free, reduced, paid)
Count: all actions taken prior to the point of service
Record: all actions taken at the point of service
Claim: all actions taken after the point of service
Meal counting and claiming encompasses all of the required program requirements that must be met to claim a meal for reimbursement.
Count – all actions taken prior to the point of service – examples include determining a student’s eligibility through free and reduced applications and offering a reimbursable meal
Record – all actions taken at the point of service – examples include ensuring the electronic or manual system accurately records the correct student eligibility
Claim – all actions taken after the point of service to receive reimbursement for meals served – example includes accurately consolidating meal counts to enter into the claim system 3

4. Why does Meal Counting and Claiming Matter?
To receive meal reimbursement for the National School Lunch and School Breakfast Programs
Meal counting and claiming is vital to running a successful school nutrition program.
First, all SFAs must adhere to meal counting and claiming requirements in order to receive federal reimbursement for their program.
Errors in meal counting and claiming procedures could be identified during the administrative review , which may result in corrective action and/or fiscal action. 4

5. Eligibility Documentation Collection Procedures Point of Sale
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Six Elements
Eligibility Documentation
Collection Procedures
Point of Sale
Reports and Edit Checks
Claims for Reimbursement
Internal Controls/Monitoring
There are six essential components in operating an accurate meal counting and claiming system.
This module will be broken down into two sections – 1. Counting and Recording and 2. Claiming. The first three elements – eligibility documentation, collection procedures and point of sale fall under counting and recording. Under counting and records, we will discuss reports and edit checks, claims for reimbursement and internal controls/monitoring 5

6. Counting & Recording
Counting and Recording

7. Eligibility Documentation
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Eligibility Documentation
All participating schools must make free and reduced price meals available to all eligible children
Step 1
Correctly determine student eligibility through applications and direct certification
Step 2
Maintain accurate and up-to-date eligibility/benefit issuance list
Step 3
Eligibility list must match point of service and be updated in a timely manner
Eligibility is the foundation of an accurate meal counting and claiming system. If a student’s eligibility is not determined correctly, this error will follow to the service line where the meal will be counted incorrectly, therefore, causing an inaccurate claim for reimbursement.
(Step 1) In order to determine if a student is eligible for a free, reduced or paid meal, the SFA must collect applications or directly certify students.
Applications are used to correctly determine a student’s eligibility by comparing the household size and the total household income to income eligibility guidelines.
Direct certification is a process where SFAs certify children as eligible for free meal benefits based on information exchanged between the State or local agencies administering Assistance Programs such as Supplemental Food Service Program (SNAP).
(Step 2) The eligibility list must be kept up-to-date throughout the year.
(Step 3) The eligibility list MUST match the point of service and be regularly updated as changes to the eligibility list are made (e.g. new students, etc.)
Benefit Issuance List: a list of students eligible for free or reduced-price meal benefits.

8. Collection Procedures
Collection procedures: all the steps within the meal count system involved in paying for meals and issuing and collecting the medium of exchange.

9. Collection Procedures
Acceptable Collection Methods
Coded ID card
Pin-pad/student id
Tokens
Unacceptable Collection Methods
Attendance Records
Classroom Counts
Tray Counts
Collection methods include any type of ticket, token, ID, name or number that is used by students to obtain a meal.
The system in place must be able to connect students to their free and reduced price eligibility. For example, using a tray count will not capture information on a student’s eligibility status or who was served the meal.

10. 9/18/2018
Point of Sale
All SFAs must have an approved collection system or point of service (POS)
Point of Sale (POS): the point in the food service operation where a determination can accurately be made that a reimbursable meal has been served to an eligible student.
Point of Sale: meals are counted at that 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.

11. Point of Sale
Positioning the POS
Personnel must be able to monitor that meals selected meet meal requirements
Ideally located after all meal components have been selected (i.e., at the end of the line)
Positioning of the POS is key in identifying if a reimbursable meal is served

12. 9/18/2018
Point of Sale
Reimbursable meals must meet all meal pattern requirements and provide all students access to the required components and amounts of food.
Offer vs. Serve
Reimbursable meal signage
Age group requirements
Breakfast and lunch requirements
Offer vs. Serve (OVS) allows students to decline some of the food offered in a reimbursable lunch or breakfast meal.
At lunch: offer all 5 components and the student can select 3 or more. One of the 3 must be ½ cup fruit or vegetable, or a combination of both
At breakfast: offer 4 food items and the student can select 3 or more items. One of the 3 must be ½ cup fruit or vegetable, or a combination of both
Schools must identify near or at the beginning of serving lines what foods constitute a reimbursable meal.
Schools using OVS must also identify what a student must select in order to have a reimbursable meal.
Please note, requirements differ between age groups and meal times.
For more information, please visit the OSN meal planning webpage for resources and upcoming trainings.

13. Collection Procedures
Alternate Point of Sale: a POS that is located before the end of the serving line
Scenarios: Positioning of salad bar, limited space, distance from an electrical outlet, etc.
Must be approved by CDE
Must have a method in place to ensure students receive a reimbursable meal
Sometimes referred to as “2 person point of sale.”
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).

14. 9/18/2018
Point of Sale
Overt Identification: Any action that may result in a child being recognized as potentially eligible to receive free or reduced meals
Eligibility must never be publicized or used in such a way that students’ eligibility may be recognized by other students or staff
It is important all steps in the meal counting and claiming process, including the collection methods mentioned in the prior slide, prevent overt identification. Overt identification is any action that may openly or physically identify a student being eligible to receive free or reduced price meals.
Examples of prohibited practices that identify a free and reduced status includes separate serving lines, identifiers on the POS that visually show eligibility status or limiting the choices of reimbursable meals based on eligibility.

15. Point of Sale
Question: Students are offered different meal options based on eligibility. Is this allowable?
Answer: No. All menu items must be available to all students, regardless of their eligibility.
Ask participants to answer yes or no to the question.
Answer explained: 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. Note competitive foods.

16. Policies and Procedures
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Point of Sale
Policies and Procedures
Negative account balances
Adult meals / employee meals
Field trips
Second meals
Back-up system
Interschool agreements
Policies and procedures need to be in place so staff know how to handle different scenarios that arise at the point of sale and how to count and record people appropriately.
For example, the school or district is required to develop a policy on how to handle unpaid meal charges and communicate these policies to parents and students. For more information on unpaid meal charge policies, visit the CDE OSN website.
Another example includes having a back up system in the case of emergency such using a roster if the electronic system goes down.

17. Point of Sale
Special Circumstances: Provisional Programs (i.e., Community Eligibility Provision and Provision 2)
Reimbursable meals are offered to ALL students at NO charge
Counts can be taken through the use of a clicker, tally sheet or POS at the end of the line
Meal counts are not separated by eligibility category
Some eligible districts participate in provisional programs, which improve access to free school meals for high-poverty schools. Special considerations apply, including all students in provisional schools receive free meals regardless of eligibility status. Other considerations:
One reimbursable meal per student
Meal Counts are taken at the point of sale and are reported as total meals served, not by eligibility category. This can be done by using a clicker, tally sheet or electronic POS, etc.
For more information on provisional programs, visit the OSN website -

18. Claiming
Claiming

19. Reports and Edit Checks
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Reports and Edit Checks
All meal count / collection systems should count meals served by eligibility category daily
For every site, meal type, and serving day, you need to know how many meals were served in each eligibility category.
The categories are free, reduced, and paid.
Each school must have a meal count collection system (also referred to as the point of sale system) which will be used during both breakfast and/or lunch, on each operating day. These meal counts are important because they are the documentation that justifies the amount of reimbursement that the SFA will be receiving for that site and claim month.
The meal counts should be submitted to the SFA on a daily, weekly, or monthly basis and then consolidated into a monthly claim in the Colorado Child Nutrition Hub.

20. Reports and Edit Checks
In order to claim any student, they must be included in the October count
Each claiming site must be a recognized CDE site
Each year, all public school districts and facilities across the state of Colorado participate in the Student October Count data submission to the Colorado Department of Education.
The Student October Count is based on a one day membership count in which districts are asked to report all students who are actively enrolled and attending classes through their district on that date.
For meal counting and claiming purposes, if that student is included in your meal count, then that student must also be included in the October count.
In addition to this, for each site that is entered into the Colorado Child Nutrition Hub for reimbursement claims, that site must be included on the CDE School Building Codes list for the current school year.
A list of all CDE recognized sites (i.e., “School Building Codes”) can be found here -

21. Reports and Edit Checks
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Reports and Edit Checks
Reports from the POS system are extremely important
If you are unsure of which report to use to enter information into the reimbursement claim, please contact your POS vendor directly
The SFA must be able to prove the number of reimbursable meals served daily at each site, by category, and, at the district-level.
The reports must be easily interpreted, edited, and consolidated into an accurate monthly claim for reimbursement.
Point of sale vendors usually have a help desk that will provide assistance with the reports that can be generated out of their system.
There are usually many reports to choose from so it’s important that you’re using the correct report and ensuring that the reimbursement claim is accurate.

22. Reports and Edit Checks
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Reports and Edit Checks
Edit checks: internal controls that ensures accurate claims for reimbursement
Schools can never claim more F, R, P meals than are served to eligible children x the number of operational days
Attendance factor always defaults to 96%
An edit check is a required internal control that ensures accurate claims for reimbursement.
USDA regulation requires school food authorities to complete an edit check for each of its schools that participate in the National School Lunch Program. (While not a requirement, they’re also highly recommended for breakfast.) This must be done prior to consolidation of the daily lunch counts for the monthly reimbursement claim.
Each SFA should review the lunch count data for each school to ensure that monthly claims include only the number of Free, Reduced & Paid lunches served on any day of operation to children that were eligible.
You’ll need to multiply each eligible enrollment number by the number of operating days and then multiply that number by 96%. Your meal count number should not exceed that final number unless you had every kid or nearly every kid eat every day.
Some other factors that can affect the claims include field trips and visiting students.
Field trips lower your numbers because the students were gone.
For visiting students, do not claim them at the site where they ate. They need to be claimed at the site where they are enrolled.
Electronic POS systems generate edit checks. SFAs can also use the “Sample Daily Edit Check” form located on the CDE Office of School Nutrition website under Financial and then under the Meal Counting and Claiming section.

23. Reports and Edit Checks
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Reports and Edit Checks
Things to consider -
Be aware of patterns (constant counts and/or repeating counts)
Watch for 100% participation – depending on the size of the school, this may or may not happen
Note any other factors that might be affecting the claims
Again, be aware of patterns in the meal counts.
Watch for warning messages in the Colorado Child Nutrition Hub that will alert you to a repeated number that occurs between two claim months.
Other factors may include the number of serving days that are adjusted for Fall Break, Winter Break and/or Spring Break and/or higher participation for certain meals that are served on special days like pizza days.

24. Claims for Reimbursement
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Claims for Reimbursement
The SFA submits all claims in the CO Child Nutrition Hub
Claims are due 60 days after the end of the claim month
Best Practice: Have a 2nd Reviewer
The Colorado Child Nutrition Hub is the online system that allows SFAs to submit reimbursement claims.
A highly recommended best practice would be to have a 2nd reviewer that is involved with all claims. You should always try to have someone else double-check the numbers that were entered and make sure the numbers match the meal count reports from the point of sale system. Also, that person can ensure that each meal type was claimed so in case you forgot to claim (let’s say breakfast or PK-5 for one site), they can help catch error.

25. Claims for Reimbursement
If the first or last month of program operations for any school year contains 10 operating days or less, that month may be combined with the claim for the appropriate adjacent month
This is due to 7 CFR 210.8(c)(1) which reads, “Unless otherwise approved by FNS, the Claim for Reimbursement for any month shall include only lunches and meal supplements served in that month except if the first or last month of Program operations for any school year contains 10 operating days or less, such month may be combined with the Claim for Reimbursement for the appropriate adjacent month.”

26. Claims for Reimbursement
Upward adjustments: Due 90 days after the end of the claim month
Downward adjustments: No time limit
Make August & September adjustments ASAP
Upward claim adjustments are always due 90 days after the end of the claim month. If they are not submitted by this deadline, the Colorado Child Nutrition Hub will give the user an error message.
Downward adjustments have no time limit because USDA always wants the federal dollars returned to them. However, please let us know as soon as possible if you encounter a downward adjustment situation. August and September claim adjustments are especially important due to the Federal Fiscal Year.
All USDA reimbursement funding is based on a Federal Fiscal Year which is October 1 – September 30. Every year, CDE must close out each USDA grant that ends on September 30. Any delayed August and/or September claim adjustments can affect these USDA deadlines.

27. Claims for Reimbursement
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Claims for Reimbursement
CO Child Nutrition Hub
User ID and Password
Claim data (lunch and breakfast)
Number of F, R and enrolled students
# of days
# of meals by category (include PK-5)
Note: There are additional requirements for the Afterschool Snack Program and the Special Milk Program
In the Colorado Child Nutrition Hub, for enrollment, you should always enter the highest enrollment for the month which means the highest totals within that month. So, you need to enter the highest number of free students approved, and the highest number of reduced students approved within the month. From these numbers, the claim system will determine the number of paid students. Again, the Free and Reduced enrollment should always be your highest totals within the month.

28. Claims for Reimbursement
Reimbursement Rates
Federal
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: Pre-Kindergarten, Kindergarten, 1 - 5
$.40
Schools may qualify for higher "severe need" reimbursements if a specified percentage of their lunches are served free or at a reduced price.
The Healthy Hunger-Free Kids Act provides an additional 6-cents per lunch reimbursement to school districts that certified to be in compliance with the meal patterns.
The Start Smart Breakfast Program was established in 2007 by Colorado Senate Bill That bill eliminated the $0.30-co-payment for reduced price breakfast paid by families for students in all grades.
In 2014, Colorado Senate Bill expanded the School Lunch Protection Program to students in grades 3, 4, and 5. This bill eliminated the need for families to pay the $0.40-co-payment for students in grades PK-5 for lunch.

29. Internal Controls/Monitoring
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Internal Controls/Monitoring
Each SFA with more than 1 school must perform an on-site review of the counting & claiming system by Feb 1
Follow-up if problems are noted
Corrective actions
Another visit within 45 days
Ongoing Staff Training
Go over on-site review handout.
Types of Questions on monitoring form
POS: Proper counting & identifying
Back-ups
Edit checks
Non-reimbursable meals
Overt identification

30. https://www.cde.state.co.us/nutrition/cocnp hubmealcountingandclaiming
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Resources
hubmealcountingandclaiming
There are numerous resources for meal counting and claiming on the CDE Office of School Nutrition website. Please explore these resources and contact us with any questions. Thank you!