1. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org New Administrative Review Georgia Department of Education School Nutrition Program Finance & Budget Unit Edward Dung Georgia Department of Education School Nutrition Program Finance & Budget Unit Edward Dung

2. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Federal Authorization 7 CFR Part 210 (Resource Management) 2 CFR Part 225 & 230 (Federal Cost Principles)

3. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Old Review Structure The previous review was: – Titled “Coordinated Review Effort” (CRE). – Designed by each State Agency. – Inconsistent among states. – Based on a five (5) year cycle.

4. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org New Review Structure The new review is: – Titled Administrative Review (AR). – Designed by FNS to cover certain minimum areas. – Uniform across all states. – Based on a three (3) year cycle.

5. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Review Procedure Involves three steps: – Step 1 – Risk Assessment. – Step 2 – Comprehensive Review or Technical Assistance. – Step 3 – Issue a review report.

6. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Risk Assessment Risk in School Food Authorities (SFAs) is assessed based on seven (7) major areas: – Student enrollment – Previous audit or review finding and exceptions. – Maintenance of Non-Profit School Food Service Account. – Compliance with Section 205 and 206 of Healthy Hunger Free Kids Act (HHFKA) of 2010. – Compliance with indirect cost application. – Procedures concerning USDA foods.

7. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Review Approach Comprehensive Review Approach - is required for SFAs where 3 (out of 7) or more risk flags are identified. Technical Assistance/Corrective Action Approach – is ONLY required for SFAs where 2 or less risk flags are identified.

8. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Technical Assistance This is only required in the area where risk is identified. – NOTE: That the State Agency has the discretion to conduct a comprehensive review for an SFA even though 2 or less risk flags are identified.

9. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Comprehensive Review A Comprehensive Review is required if 3 or more risk flags are identified in an SFA. FNS requires five (5) major areas to be covered (see next slide). State agencies may, at their discretion, review more areas.

10. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Comprehensive Review (Minimum Areas for Review) Maintenance of Non-Profit SFS Account Paid Lunch Equity (PLE) Revenue From Non-Program Foods Indirect Cost USDA Foods

11. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Maintenance of Non-Profit SFA Account 3 Components – Nonprofit school food service account – Observe regulatory limitations on the use of nonprofit school food service revenue. – Net Cash Resources – Should not exceed 3 months average operating expenses – Allowable costs – Must be reasonable, necessary and allocable to the NSLP.

12. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Paid Lunch Equity (PLE) Addressed in Section 205 of HHFKA 2010 – See also Title 7 CFR Part 210 Requires SFAs to review meal prices if the weighted average meal price is below the difference between free lunch reimbursement rate and paid reimbursement lunch rate. The objective is to ensure equitable allocation of federal reimbursement for student meal claims. PLE Flexibilities – SP 34-2013

13. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Non-Program Foods Addressed in Section 206 of HHFKA 2010 – See also Title 7 CFR Part 210 Requires SFA to ensure that the proportion of revenues generated from the sale of non-program foods to be equal to or greater than the proportion of food cost for producing such non-program foods. The objective is to avoid subsidizing adult and other non- program meals (a la carte) using federal reimbursements.

14. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org Indirect Cost Addressed in Title 2 CFR Part 225 - Appendix E. Ensures that indirect cost, where applicable, is billed to the SNP using the approved rate or a consistent methodology. Objective is to ensure fair and reasonable allocation of indirect cost charged to Child Nutrition Program (CNP).

15. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org USDA Foods Required by Title 7 CFR Part 210 Objective is to ensure that SFAs receive the full credits for USDA products diverted to third parties for processing or from Food Service Management Companies (FSMC) that contract with SFAs.

16. Dr. John D. Barge, State School Superintendent “Making Education Work for All Georgians” www.gadoe.org