1. Advisory Council for School Nutrition
Thursday, Feb. 22, 2018
Conference Call
Thursday, Feb. 22, 2018
Conference Call

2. Carrie Thielen, MPH, RD Nutrition Programs Senior Consultant Office of School Nutrition

3. Conference Call Instructions
Participants will need to link to view the webinar and call in to the conference line.
Link to view the webinar:
Call in to the conference line for audio:
Conference Number:
Participant Code:
Please mute your phone.
Please do not place your phone on “hold” because of background music.
Please save questions for the end of each section. We will be using the phone line for questions.
If you are unable to join the call or webinar, please call for assistance
Participants will need to link to view the webinar and call in to the conference line.
Link to view the webinar:
Call in to the conference line for audio:
Conference Number:
Participant Code:
Please mute your phone.
Please do not place your phone on “hold” because of background music.
Please save questions for the end of each section. We will be using the phone line for questions.
If you are unable to join the call or webinar, please call for assistance

4. Brehan Riley, MS, RD, SNS Director Office of School Nutrition

5. Welcome, Legislative and Working Group Updates
New members:
Region 10: Sharley Schreiner, Fountain-Ft. Carson
Region 15: Traci Berg, Holyoke/Haxtun/Fleming/Merino
Region 16: Danielle Bock, Weld Co. 6, Greeley-Evans
Region 18: Shannon Williams, Ouray
Legislative Update
Expansion of the School Lunch Protection Program
Working Group Updates, Oct. 19, 2017
Direct certification improvement and Technology Innovation grants.
Farm to School Grant.
ACSN– Best Practices
Unpaid Meal Charges
Welcome
New members:
Region 10: Sharley Schreiner, Fountain-Ft. Carson
Region 15: Traci Berg, Holyoke/Haxtun/Fleming/Merino
Region 16: Danielle Bock, Weld Co. 6, Greeley-Evans
Region 18: Shannon Williams, Ouray
Legislative Update
Expansion of the School Lunch Protection Program
Working Group Updates, Oct. 19, 2018
Direct certification improvement and Technology Innovation grants.
Farm to School Grant.
ACSN– Best Practices
Unpaid Meal Charges

6. Meghan Squires, MHS Senior Program Specialist Jennifer Otey, BA Senior Program Specialist Mountain Plains Regional Office (MPRO)
Meghan Squires, MHS Senior Program Specialist Jennifer Otey, BA Senior Program Specialist Mountain Plains Regional Office (MPRO)

7. Child Nutrition Program Office of Program Integrity
February 2018
Child Nutrition Program Office of Program Integrity

8. CN’s Office of Program Integrity
The Office of Program Integrity (OPI) was created in 2014
OPI’s focus is on identifying ways to increase integrity in all CN programs
OPI is comprised of staff from the regional and national offices
OPI’s first major focus was on school meals
The Office of Program Integrity (OPI) was created in 2014
OPI’s focus is on identifying ways to increase integrity in all CN programs
OPI is comprised of staff from the regional and national offices
OPI’s first major focus was on school meals

9. Access, Participation, Eligibility and Certification Study (APEC-II)
The primary data source OPI used to begin to address error in school meal programs was an FNS study:
Access, Participation, Eligibility and Certification Study – (APEC-II):
Measuring Erroneous Payments in the National School Lunch and Breakfast Programs
The primary data source OPI used to begin to address error in school meal programs was an FNS study:
Access, Participation, Eligibility and Certification Study – (APEC-II):
Measuring Erroneous Payments in the National School Lunch and Breakfast Programs

10. Administrative Review
The administrative review process looks at:
Program and meal access and reimbursement
Meal patterns and nutritional quality
School nutrition environment
Civil rights
Resource management
The administrative review process looks at:
Program and meal access and reimbursement
Meal patterns and nutritional quality
School nutrition environment
Civil rights
Resource management

11. Administrative Review and APEC II
The administrative review process looks at:
Program and meal access and reimbursement
Meal patterns and nutritional quality
School nutrition environment
Civil rights
Resource management
APEC II uses data collected in SY
The APEC studies are nationally representative
For APEC II, data came from:
Surveys of households and SFA directors
Administrative data from schools districts and States
Direct observations in sampled schools
The administrative review process looks at:
Program and meal access and reimbursement
Meal patterns and nutritional quality
School nutrition environment
Civil rights
Resource management
APEC II:
APEC II uses data collected in SY
The APEC studies are nationally representative
For APEC II, data came from:
Surveys of households and SFA directors
Administrative data from schools districts and States
Direct observations in sampled schools

12. Overall Improper Payments
The APEC studies describe improper payments in three broad categories:
Certification Error
Meal Claiming Error
Aggregation Error
The APEC studies describe improper payments in three broad categories:
Certification Error
Meal Claiming Error
Aggregation Error

13. Focusing on Certification Error
APEC II revealed two primary sources of certification error
Household reporting error (such as forgetting an income source or not reporting a household member). Household reporting error is more common than administrative error.
16.5% of applications had household reporting errors
Administrative error includes errors in processing applications, determining eligibility, and recording certification status information on the master benefit list
8.9% of applications had administrative errors
This is looking only at non-CEP Schools (there is a separate conversation on CEP). Certification errors can either be an over-certification (a student being certified for a higher level of benefits than that for which they are eligible) or an under-certification (a student being certified for a lower level of benefits than that for which they are eligible or erroneously denied benefits). It is important to note that the error in the report is the combination of over-certification and under-certification errors.
The most frequent type of household reporting errors identified in APEC were not accurately reporting the number of household members with income, the number of types of income, or both. Discrepancies in reported household size were the next most common type of reporting error.
In CEP schools – certification error occurs if a CEP group’s ISP is incorrect.
Under-certification error occurs if the school claimed a smaller reimbursement amount than it would have if its claiming percentages were correct.
Over-certification error occurs if a larger reimbursement amount was claimed than the correct claiming percentages would suggest.

14. Certification Errors in NSLP
About 71% of the errors were overpayments
$1.2 billion
About 29% of the errors were underpayments
$830
million (71%)
About half of those errors come from free-reimbursed meals that should have been at the paid rate
Given the size of the school meals programs (about $12 billion in SY ), a relatively small percentage of error can result in a big price tag.
The way the error is counted, both under-claims and over-claims are counted as error and added together.
(A $2.00 over-claim + a $2.00 under-claim = $4.00 in error, not $0.00)
So on this slide we see that certification errors in NSLP resulted in $1.2 billion of errors, 71% of those errors being overpayments and 29% of the errors being underpayments.
$330
million (29%)
NSLP

15. Certification Errors in SBP
$370 million
Similar to NSLP, about 70% of the errors in SBP were overpayments
$260
million (70%)
About 29% of the errors were underpayments
Percentages don’t add up to 100 because they are calculated on actual values and not the rounded values shown here. Similar to lunch, we see that 70% of the certification errors in breakfast were over-claims and 29% were under-claims.
Certification error in both breakfast and lunch combined accounts for about 58% of total improper payments.
$110
million (29%)
SBP

16. Meal Claiming Error from APEC II
$610 million (100%)
$370 million (100%)
$530
million (87%)
Overpayments
$360
million (98%)
Meal claiming error represents about 37% of total improper payments. Here you see that there is $610 million in meal claiming error in lunch and $370 million of meal claiming error at breakfast, with the majority of both errors being overpayments.
$10 million (2%)
$80
million (13%)
Underpayments
$80 million (13%)
SBP
NSLP

17. Meal Claiming Error from APEC II.
Meal claiming error is more common in breakfast than in lunch
Meal claiming error was concentrated in a minority of schools rather than distributed evenly across schools
There are lower meal claiming error rates in:
Smaller districts
Schools serving fewer meals
Offer vs. Serve schools
Meal claiming error is more common in breakfast than in lunch
Meal claiming error was concentrated in a minority of schools rather than distributed evenly across schools
There are lower meal claiming error rates in:
Smaller districts
Schools serving fewer meals
Offer vs. Serve schools
$80 million (13%)

18. Error Information Colorado in ARs
In School A, selected applications were incorrectly approved. One application was processed as free when the application should have been denied.
School B has an alternate point of service that was not approved by State Agency. Meal counts are being taken at the beginning of the serving line before it is verified if a student has taken a reimbursable meal.
School C did a great job certifying students for free and reduced priced meals as evidenced by zero errors. All certification and benefit issuance documents were very organized and had thorough documentation.
Comments like these in ARs can add to what we know from APEC – but cannot replace APEC studies because the
results are specific to just a handful of schools. More importantly we would like to hear from you on thoughts you may have to address some of these errors. At a future meeting we would like to talk to you about some best practices, innovations and challenges you face that may help mitigate or even lead to error.
In Schools D and E, meal count records are accurately completed and well maintained.

19. Erica Boyd, RD Nutrition Programs Senior Consultant Office of School Nutrition

20. Smart Snacks, Competitive Foods, Fundraising
Colorado Competitive Food Rules
Federal Smart Snacks in School
Effective July 1,
CO Healthy Beverages Policy
Effective July 1, 2009
In Colorado we have three pieces of legislation that regulate competitive foods. The CO Comp Food Service Policy and the Health Beverage Policy are state policies and Smart Snacks is a federal regulation. Whenever state policy is more restrictive than federal policy, we must follow state policy. When federal regulation is more restrictive we must follow it.
Competitive food means all food and beverages other than meals reimbursed under programs authorized National School Lunch Act and the Child Nutrition Act available for sale to students on the School campus during the School day.
CO Competitive Food Service Policy
Effective July, 1998

21. Smart Snacks in School
Apply to all foods and beverages sold to students:
On the school campus
During the school day
Outside of the reimbursable meals program
Includes items sold:
A la carte
In school stores
At snack bars
In vending machines
At food and/or beverage fundraisers (i.e., bake sales)
Does not apply to:
Items brought from home
Fundraisers that occur outside of school
Birthday or classroom celebrations
Items sold in areas in which students have restricted access
Smart snacks in schools apply to all foods and beverages sold to students, on the school campus, during the school day and outside of the reimbursable meals program The school campus is defined as all areas of the property under the jurisdiction of the school that are accessible to students during the school day which is defined as midnight before school to 30 minutes after the end of the official school day. Listed on this slide are examples of what is included under smart snack regulation and those which are not. Smart snack nutrition standards apply to all a la carte items, school stores, vending machines, and food/beverage fundraisers. Smart snack nutrition standards do not apply to items brought from home, fundraisers occurring outside of the school, birthday/classroom celebrations and items sold in areas in which students have restricted access.

22. Smart Snacks – General Food Standards
To be allowable for sale, a food item first must meet one of the following general standards:
Be a whole grain-rich grain product; OR
The first ingredient is either a fruit, vegetable, dairy or protein food; OR
Be a combination food that contains at least ¼ cup fruit or vegetable.
To be allowable for sale, a food item first must meet one of the following general standards:
Be a whole grain-rich grain product; OR
The first ingredient is either a fruit, vegetable, dairy or protein food; OR
Be a combination food that contains at least ¼ cup fruit or vegetable.

23. Smart Snacks – Nutrient Standards
Then, ensure the food(s) as packaged and sold meet the nutritional criteria for all of these nutrients:
Snack Items: ≤200 calories
Entrée Items: ≤350 calories
Total Calories
Total fat (≤35% of calories from total fat)
Saturated fat (<10% of calories from saturated fat)
Trans fat (0 grams of trans fat)
Fats
Snack items: ≤230 mg
Entrée items: ≤480 mg
Sodium
≤35% weight from total sugars in foods
Sugar
If the item meets the first criteria it then must meet the nutritional criteria for total calories, fat, sodium and sugar. An entrée item is a combination food of meat/meat alternate and whole grain rich food; or a combination food of vegetable or fruit and meat/meat alternate; or a meat/meat alternate alone, with the exception of yogurt, low-fat or reduced fat cheese, nuts, seeds and nut or seed butters and meat snacks.

24. Smart Snacks and CO Healthy Beverages Policy
In November 2016, Colorado Healthy Beverages Policy aligned with Smart Snacks
Beverage standards apply to the extended school day.
Standards do not apply to beverages sold during school- related events, where parents are a significant part of the audience.
In November 2016 the CO Healthy Beverages Policy aligned with Smart Snacks. The beverage standards apply to the extended school day
Standards do not apply to beverages sold during school-related events where parents are a significant part of the audience. Extended School Day means the regular hours of operation for any public school including institute charter schools, plus any time spent by students after the regular hours of operation for any purpose, including but not limited to participation in extracurricular activities or childcare programs.

25. Colorado Competitive Food Service Policy
May not be sold in competition
with the district’s foodservice
Program.
Cannot be sold 30 minutes before
to 30 minutes after each scheduled
meal service.
In those schools participating in the School Breakfast and/or National School Lunch program(s), competitive food service is any food or beverage service available to students that is separate and apart from the district’s nonprofit federally reimbursed foodservice program, and is operated by school approved organizations, school staff or by school-approved outside vendors. Such competitive foods cannot be sold 30 minutes before to 30 minutes after each scheduled meal service on any area of the school campus that is accessible to students.

26. Food Fundraisers
Each school building can have up to three exempt fundraisers
per school year.
(i.e. foods sold that do not meet the Smart Snack standards)
Duration of fundraisers is up to local discretion, but must be in line with the intent of the rule.
Smart Snacks standards do not apply to fundraisers, in which the food sold, is clearly not for consumption on the school campus during the school day.
Each school building can have up to three exempt fundraisers
per school year.
(i.e. foods sold that do not meet the Smart Snack standards)
Duration of fundraisers is up to local discretion, but must be in line with the intent of the rule.
Smart Snacks standards do not apply to fundraisers, in which the food sold, is clearly not for consumption on the school campus during the school day.

27. Healthy Celebrations
On the CDE OSN Local Wellness Policy-Best Practices webpage it links to several examples that other states and schools have implemented for non-food fundraisers and examples of healthy celebrations.

28. Documentation Requirements Resources Requirements Resources
Each entity selling food and beverage items must keep records of all items sold.
Districts must maintain documentation of compliance with the three exempt fundraiser limit.
Resources
Example Food and Beverage Sales Documentation Tracker
Smart Snacks Documentation Examples  
LEA Fundraiser Example Documentation Tracker
Requirements
Each entity selling food and beverage items must keep records of all items sold.
Districts must maintain documentation of compliance with the three exempt fundraiser limit.
Resources
Example Food and Beverage Sales Documentation Tracker
Smart Snacks Documentation Examples  
LEA Fundraiser Example Documentation Tracker

29. Documentation Resources
Here are 2 examples of tracking methods that are on our website that show what is necessary to track when hosting an exempt food fundraiser. It is important to note that nutrition labels for each item sold during the non-exempt fundraiser must be on file with the tracker or exemption form.

30. Documentation Resources - Examples
For smart snack documentation the nutrition facts label and the ingredient list must be included. The Alliance for a healthier generation smart food planner print out results are optional, but if you do have them it must be accompanied by the nutrition facts label and the ingredient list.

31. Responsibilities District School Food Service Fundraisers
School stores
Vending machines
School Food Service
A la carte sales
District
Fundraisers
School stores
Vending machines
School Food Service
A la carte sales

32. Smart Snacks Review in the Administrative Review
Interview school district staff and food service staff.
Determine all areas where foods and beverages are sold (exempt fundraisers, vending machines, school stores, etc.).
Obtain a separate list of all food and beverage items, for sale during the review period, at each reviewed schools.
Choose a minimum of 10 percent of the items, from this list, which the school food authority and local education agency must submit documentation.
The 10 percent sample selected for documentation review must represent all locations where foods and beverages are sold to students.
The 10 percent sample is distinct for each site being reviewed.
Interview school district staff and food service staff.
Determine all areas where foods and beverages are sold (exempt fundraisers, vending machines, school stores, etc.).
Obtain a separate list of all food and beverage items, for sale during the review period, at each reviewed schools.
Choose a minimum of 10 percent of the items, from this list, which the school food authority and local education agency must submit documentation.
The 10 percent sample selected for documentation review must represent all locations where foods and beverages are sold to students.
The 10 percent sample is distinct for each site being reviewed.

33. Contact Information
Erica Boyd, RD
Nutrition Programs Senior Consultant
Erica Boyd
Nutrition Programs Senior Consultant

34. Carrie Thielen, MPH, RD Nutrition Programs Senior Consultant Office of School Nutrition.

35. Colorado School Nutrition Association (CSNA) Summer Conference
June 13-14, 2018
Embassy Suites, Loveland, CO
Registration opening February 2018
Topics for Summer Food Service Program classes
Colorado School Nutrition Association (CSNA) Summer Conference
June 13-14, 2018
Embassy Suites, Loveland, CO
Registration opening February 2018
Topics for Summer Food Service Program classes

36. Brehan Riley, MS, RD, SNS Director Office of School Nutrition.

37. Next Steps, Save the Date, Evaluations, Closing
CSNA Summer Conference, June 13-14, 2018, TBD
Recognition of outgoing charter members.
Introduction of past members.
Introduction of current members.
ACSN region “Meet and Greet” lunch session.
Hot topics for next meeting?
What worked today?
What did not work today?
Save the Date:
CSNA Summer Conference, June 13-14, 2018, TBD
Recognition of outgoing charter members.
Introduction of past members.
Introduction of current members.
ACSN region “Meet and Greet” lunch session.
Hot topics for next meeting?
What worked today?
What did not work today?