1. Preparing for an Administrative Review Lindsay Healy, RD, SNS CN Resource June 4 th, 2014

2. The Administrative Review (AR) is the new USDA review process. This AR replaces both the old CRE and the SMI. The AR was introduced with the Healthy Hunger Free Kids Act of 2010. The 2013-2014 school year was the first year that it was implemented. Moving forward it is important to forget the ways of the CRE and SMI and embrace the changes! There are many similarities however, it is a different review and it is important to make sure everyone is aware and comfortable with the new review process. Administrative Reviews will be completed on a 3 year cycle. This increases our opportunity to visit schools and offer technical assistance. Having more frequent reviews will hopefully bring a decrease in review findings and create more effective child nutrition programs in the schools. There are 4 main focus areas of the AR: Performance Standard 1: This focuses on meal eligibility and counting and claiming. Performance Standard 2: This standard focuses on the meal quality; menu components, serving sizes and nutritional quality. Resource Management Comprehensive Review: This is a part of the review that takes an in-depth look at the financial aspects of the program. General Areas: This includes, food safety, civil rights, wellness policy, etc. The Healthy Hunger Free Kids Act also brought along major changes to the meal patterns for breakfast and lunch. The AR reviews the new pattern through an in-depth menu review that is completed prior to the on-site visit as well as meal observation on the review day. What is the Administrative Review?

3. Step 1: Notification of Review The state agency will send a notification to all of the SFAs that are selected for review in SY 2014-2015. They will receive a letter letting them know that they will be contacted to schedule the review. Step 2: Scheduling the Review Determining the site(s) for review: The number of sites selected for review is based on the number of participating schools within the SFA. There are USDA criteria that is used when selecting the specific sites. The length of the on-site review will be based on the number of sites that must be reviewed and the number of meal applications that will need to be reviewed.

4. Step 3: Pre-Review Procedures Selecting the site for a targeted menu review: Meal compliance assessment procedures Additional Pre-review documents: Off-Site Assessment Dietary Specification Assessment Tool (targeted menu site only) Menu Documentation Review

5. Off-Site Assessment When completing the Off-Site Assessment: Work as a team Answer the questions completely Be as accurate as possible Call and ask if there is a question you don’t understand Submit it by the due date Submit all the requested supporting documents

6. Dietary Specification Assessment Only needed for the site that is selected for the Targeted Menu Review. (the reviewer will let you know what site this is) The reviewer will tell you if you need to complete breakfast and lunch or lunch only. Read each statement carefully. Answer each statement honestly.

7. Menu Documentation Review Week of Menu Review A single week from the review month will be selected for the menu documentation review. The reviewer will work with the SFA to determine the week. What Menus are Reviewed? All unique menus that will be observed at the review site(s) must be submitted for menu review. What Menu Documentation Needs to be Submitted? Production Records, Menus, Standardized Recipes, Labels, CN labels

8. Step 4: On-site Review SFA Level: Applications Verification Claims Resource Management* Civil Rights Wellness Policy Food Safety Plan Record Keeping SBP and SFSP outreach FSMC* Site Level: Point of service Meal components OVS Kitchen walk through Civil rights On-site monitoring Competitive Foods Water Food safety Record Keeping

9. Certification and Benefit Issuance Benefit Issuance list from all sites participating within the SFA Total number of eligible students in the SFA Identify which students were selected for Verification List must come from the point of service No duplicates List of students eligible for free and reduced meals (do not include paid students). For each student the list must provide: student’s name, school name, benefit status, method of certification, date of certification Eligibility Documentation Reviewer will determine which applications will be reviewed. Applications will be reviewed district wide, not just selected sites. A percentage of denied applications will also be reviewed. SFA must provide: Certification Document (application, direct certification, eligibility list) Verification documents (if applicable) Notification of benefits Any follow-up documentation and/or communications with the household Income Applications MUST include: Names of all household members All household member’s income and frequency Indication of no income for those that have none Signature of adult household member Last 4 digits of Social Security Number *Must be approved using the correct USDA Income Eligibility Guidelines Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Families (TANF) or Food Distribution Program on Indian Reservations (FDPIR) Applications MUST include: Case Number Signature of adult household member Foster Students MUST: Have an approved application on file OR Have approved documentation from the County indicating their foster status Categorically Eligible Students MUST: Be on an approved and complete list (Homeless, Migrant, Runaway, Head Start) Be on the Direct Certification Report Students Extended Eligibility through the Direct Certification Report MUST: Be documented on the Direct Certification Report or on a separate document. The documentation must include the date they were added, and the student that they reside with that is listed on the Direct Certification Report.

10. Verification All Verified applications will be reviewed Initial application Notifications sent to households Verification documents submitted by households Notification of results of Verification Reviewer will complete a detailed review of 10% of verified applications Summary of Verification Efforts This is the report that the SFA is required to maintain each year, but is NOT required to submit to the State.

11. Claim for Reimbursement and POS Claiming documents from all sites within the SFA will be reviewed Review month claim from each site Edit check from review month for each site Consolidated claim for review month Point of Service (POS) Does the system avoid overt identification? Does it provide an accurate meal count? How are meals consolidated at the end of service? How does the POS ensure that students are not claimed more than once?

12. Meal Compliance Production Records: Are the records complete? Were all components served each day? Were the correct portions served for each component? Production Record Requirements Food components Recipe or food product used Planned/projected number of portions and serving size for each age/grade group Planned/projected number of portions and serving size for adults Total amount of food prepared Actual number of servings for each item served Actual number of non-reimbursable meals served (adult or a la carte) Leftovers and substitutions Meal Preparation Observation During meal preparation are: Standardized Recipes used? Are correct measuring tools used? Are proper food safety practices followed? Meal Service Was each component available to all students? Were portion sizes accurate? Two varieties of milk Were reimbursable meals selected? Offer vs. serve implemented correctly (if applicable) Is there proper signage that identifies a reimbursable meal?

13. Resource Management Audits Non-Profit School Food Service Account Paid Lunch Equity Revenue from Non-Program Foods Indirect Costs USDA Foods Paid Lunch Equity Tool http://www.fns.usda.gov/paid-lunch-equity-school-year-2014- 2015-calculations-and-tool Paid Lunch Equity Tool http://www.fns.usda.gov/paid-lunch-equity-school-year-2014- 2015-calculations-and-tool Non-Program Foods Revenue Tool http://www.fns.usda.gov/cnd/governance/policy2006-2011.htm Non-Program Foods Revenue Tool http://www.fns.usda.gov/cnd/governance/policy2006-2011.htm

14. Civil Rights The SFA's public release Description of the SFA's procedures for receiving and handling a Civil Rights complaint Information on the number and description of complaints alleging discrimination in the current and prior school year Date, agenda and attendees of the recent Civil Rights training for the SFA staff Need and availability of translation services Description of the SFA's procedures for collecting racial/ethnic data The non-discrimination statement used on all program materials "And Justice For All" poster

15. On-Site Monitoring *Important: On-site monitoring is only required if the SFA has more than 1 building that participates in the NSLP and/or SBP. Documents to Review: Current year on-site review forms http://www.fns.usda.gov/cnd/governance/Policy- Memos/2011/SP14-2011_os.pdf http://www.fns.usda.gov/cnd/governance/Policy- Memos/2011/SP14-2011_os.pdf

16. Wellness Policy At a minimum the Wellness Policy must include: 1.Goals for Nutrition Education 2.Goals for Physical Activity 3.Goals for other school based activities to promote wellness 4.Nutritional guidelines for all food sold on campus 5.Goals for Nutrition Promotion *The wellness policy should be developed by a team that includes, teachers, food service staff, parents, administration and students NEW with Reauthorization: 1.SFAs are required to make the Wellness Policy public 2.SFAs must periodically measure the implementation of the policy 3.The SFA must designate one or more school officials to ensure compliance with the wellness policy You need to be able to answer: How is the Public informed? When and how is the policy reviewed and updated? Who is involved with the policy? How can stakeholders participate?

17. Competitive Foods & A la Carte 1. Ensure that there is no sale of competitive foods and that foods of minimal nutritional value are not available during meal service in the serving or dining area. 2. All food sales must be incompliance with the new guidance for the 2014-2015 school year. 3. Have copies of the nutrition labels of all foods sold within the school during the school day available for review.

18. Water The Healthy Hunger Free Kids Act requires that potable water be made available to all program participants free of charge during both breakfast and lunch service. While observing breakfast and lunch you must ensure that free water is available for consumption by program participants. Schools can provide water in a variety of ways: Water pitchers and cups on tables A water fountain Water dispenser with cups in the cafeteria

19. Food Safety Food Safety Inspections Copy of the most recent food safety inspection must be posted at each site in a prominent location The SFA needs to provide documentation of the two most recent inspections Temperature Logs For the cooler(s), Freezer(s) and Store room For all food that required cooking to an established internal temperature For food that needs to be maintained below 41  Food Safety Plan Copy should have already been submitted with off-site assessment, but each site should have a copy maintained on site. Complete a Kitchen Review: Food stored off the floor Temperature logs for storage areas 3 compartment sink Proper storage procedures Recent inspection is posted in a visible location Proper hygiene Cross contamination risks Food Preparation area and cooking utensils are clean No obvious evidence of a pest problem

20. Record Keeping As you review other areas, you should be evaluating that the appropriate reporting and record keeping requirements are in compliance. Page 166-167 of the Administrative Review manual list the common reports and records that the SFA must have on file.

21. Other Programs Afterschool Snack Program (ASSP): Ensure that production records are maintained and all snack items offered are creditable. Fresh Fruit and Vegetable Program (FFVP): Have documentation of products served and detailed claims for reimbursement. Special Milk Program (SMP): Pricing Policy, counting and claiming procedures, milk service procedures and records. Seamless Summer Option (SSO): Meal counting and claiming practices, menu planning, and meal service.

22. Step 5: Administrative Review Report The reviewer must provide the SFA with written notification of the review findings: Superintendent or authorized representative Commendations Review findings Corrective Action Plan Potential for Fiscal Action Right to an appeal

23. How can I have a Great Review? Team work: Get everyone involved Provide in house trainings Don’t leave it up to just one person Organization: Determine the best way to present all the requested materials Binders, folders, paperclips, hanging files, etc. Over prepare!! Double, triple check everything Read all of the guidance and resources that are available

24. This seems overwhelming… Start early Ask questions Submit requested information by requested dates Be responsive Use your team to get prepared Don’t wait until the morning of the review Stay up-to-date on trainings

25. Use the Review tools All of the administrative Review forms are on the USDA website Do an in house review using the tools Make sure you understand the questions and you are in compliance Administrative Review Tools: http://www.fns.usda.gov/cnd/guidanceadminreview.htm Administrative Review Tools: http://www.fns.usda.gov/cnd/guidanceadminreview.htm

26. Questions??