1. Preparing for a Food Service Audit
Tips for Surviving a Review
Clare Keating
Preferred Meal Systems, Inc.
May 19, 2011

2. Audit Concerns How much is it going to cost us?
How long is it going to take?
How much work is it going to be?
Who is going to do all this?
When will it be over?
No really, is it going to cost us?

3. Business Goals / Today’s Agenda
Avoiding Fiscal Action during a Review
Accurate Claims for Maximum Reimbursement

4. Tools for Success
Illinois State Board of Education (ISBE) School-Based Child Nutrition Programs Administrative Handbook July updated Jan 2011
ISBE (free) Workshops
NSLP Certification of Eligibility and Verification-
Basic Training Workshops
Meal Planning, Meal Counting, Claiming
Watch website for dates and locations

5. More acronyms defined in ISBE Administrative Handbook
A Few Acronyms to Know
CRE- Coordinated Review Effort
This is your Administrative Review
SMI- School Meals Initiative
This is your Nutritional Review
NSLP- National School Lunch Program
SBP- School Breakfast Program
TANF / SNAP- Temporary Assistance for Needy Families / Supplemental Nutrition Assistance Program
AAR- Additional Administrative Review
More acronyms defined in ISBE Administrative Handbook

6. Coordinated Review Effort (CRE) Review

7. What is a Coordinated Review Effort (CRE) Review?
A CRE Review is an Administrative review of all documents and procedures in federal meal programs. Monitors review eligibility documentation, meal counts and claims, menus, food quantities and serving sizes, and several other areas for compliance.
A CRE Review ensures that students eligible for meal benefits have access to meals that meet all regulations and are counted and claimed in the correct categories.
CRE’s are conducted once every three years. (*new HHFKA 2010)

8. Fiscal Action during a Review
Occurs When:
Eligibility Documentation is inaccurate
Direct Certification
Household Income Applications
Categorical Eligibility
Meal Counting & Claiming Procedures are inaccurate
The most common errors are Application and Claiming Errors

9. Critical Review Areas
Household Eligibility Application determinations, including compliance with the completion of the Electronic Direct Certification process
Benefit issuance
Meal-counting system
Claim consolidation
Menus
Important Note: Critical area violations may result in a fiscal assessment.
ISBE may waive the fiscal assessment if less than $600.
No waiver where substantial evidence of violations of criminal law or civil fraud statutes exist.

10. Determining Eligibility

11. Determining Eligibility
Critical to revenue in NSLP and SBP’s
Errors in Household Income Applications and Direct Certification cause the most fiscal action
Attending a workshop is strongly recommended!
ISBE Certification and Verification Workshop
July 26 Marion Williamson County Pavilion
July 27 Bloomington Doubletree
Aug 10 Schaumburg Courtyard Marriott
Aug 11 Kankakee Hilton Garden Inn

12. Staying Current Changes in procedures and paperwork occur each year:
Attend a workshop annually!
Check ISBE website for new documents
Yearly Application- out with the old- in with the new
Updated Income Guidelines- July 1
Read the Outlook for what’s new

13. Determining Eligibility
Procedures
Send out no earlier than 30 days prior to start of school
Process Applications Centrally
Family Applications may list several students in one district but in different schools
More control over the process- fewer hands, less training needed
Easier to maintain applications in one location
Easier to identify students for extended benefits
Monitors prefer

14. Eligibility Determination Methods
Direct Certification
Certification of SNAP/TANF benefits via Electronic Direct Certification System
Household Eligibility Applications
SNAP/TANF application
Income application
Foster child application
Categorical Eligibility
Homeless, migrant, runaway, or Head Start listing-
*new HHFKA Foster child
Extension of Benefits to all other children in household

15. What to Expect—Administrative Reviews
Review Checklist with details of WHAT is being reviewed is found on pages in the School Food Authority Reviews Section of the Administrative Handbook and online at
Reviews are conducted via a cycle once every three years (*new, was every 5 years)
Review Process
Announcement letter to District Superintendent/Authorized Representative
Phone call to schedule on-site visit
On-site visit (usually 1-3 days, depending on SFA size, *new regs require longer, 1-2 weeks)
Review report documenting review findings sent via mail
If needed, the SFA must respond to citations via a Corrective Action Plan
In the near future, review process will be electronic.

16. Tips to Prepare for the Review
Talk to the Reviewer about documents to send prior to the review (Meal Edits) and school selection
Match Benefit Issuance documents to Applications (Arrange applications in the same order)
Review Applications for accuracy
Use Review Checklist that comes with the announcement letter
Reserve a comfortable area with large table, ample space and easy access to District rep
Have meal times for school of review ready
Be Prepared!
Be Available during the review

17. Common Citations for Eligibility Determination on CRE Reviews
Applications not complete, SS# missing, not signed
Math Errors
Incorrect SNAP/TANF numbers
Students approved in wrong category ($$$)
Extension of Benefits
No documentation
Verification
Process is not complete for every application chosen for review.

18. Meal Counting and Claiming

19. Meal Counting
Accurate Meal Counts are critical to claiming meals for reimbursements and receiving funding
Train Foodservice Staff
To understand and identify a reimbursable meal based on chosen Menu Planning Option
To Ensure all meals are accurately counted and recorded in the correct category
Establish Internal Controls that reconcile Production Records to Meals Counted

20. Meal Counting Procedures
Eligibility Documentation
The SFA must have documentation to claim free or reduce-price meals for reimbursement.
Collection Procedures
Steps must be in place for a medium of exchange that does not overtly identify students as free or reduced-price meals.
Point-of-Service Counts
Meals must be counted daily at that point in the food service line where it can be determined a reimbursable meal has been served to an eligible student.

21. Meal Counting and Claiming
Reports
The number of reimbursable meals served daily, by category of eligible students are recorded.
The SFA must evaluate the meal counts for each site prior to submission of the Claim for Reimbursement through the Meal Count Edit Check.
Claim for Reimbursement
Submitted Electronically
Establish Internal Controls
Segregation of duties
On-site visits
Reconciliation of production records to meals

22. Meal Pricing Paid Meals Adult Meals Pricing of Ala Carte Items
*new- Meal Price must be greater than or equal to the difference between the federal reimbursement rate for free meals and the federal reimbursement for paid meals. May increase 10¢ per year
Adult Meals
Must include Student Rate plus reimbursements and commodity allocation. E.g. Student Price = Adult Price
Pricing of Ala Carte Items
Prices should be set so as to NOT compete with the reimbursable meal
* new- All non-reimbursable foods sold must generate revenue at least equal to their cost.

23. Common Citations for Meal Counting on Administrative Reviews
Benefit Issuance
Not updated for changes from verification or from the previous year’s application rolled over.
Meal Count Edits
Edits are not completed monthly.
Problems noted are not followed up.
Audit your FSMC for accuracy
Incomplete Meals Served

24. Common Citations on Administrative Reviews
Application Errors- Inaccurate determination of student eligibility
Claiming Errors- Incorrect meal counts and inaccurate claims
Meal Count Edits – edits are not completed monthly. Problems noted are not followed up
Benefit Issuance – not updated for changes from verification or from the previous year’s application rolled over.
Verification – process is not completed for every application chosen for review.
Sanitation Reviews – less than two reviews are conducted per school year. No documentation requesting review to the local health department.
On site reviews – not completed by February 1st or 3 or more reviews are completed on the same day by the same individual
Production Records – not completed or did not list all food items available in a given day including condiments.
Wellness Policy- no evaluation of policy to determine how well it is implemented
Hazard Analysis Critical Control Points (HACCP) plan – Not following the established plan or Standard Operating Procedures
Offer versus Serve under food based menu approaches – directing the student selections (entrée and milk).

25. School Meals Initiative (SMI) Review

26. SMI Review
Each School district will be scheduled for an SMI review at least once every five years. (*new HHFKA- 3 years)
ISBE (specifically the SMI reviewer) will inform the district in advance when the review is scheduled.
This notification will include:
What week will be selected for review;
What specific information you will need to provide.
Each school district chooses the school for review.
An on-site visit is scheduled at a mutually agreed upon date and time.

27. What is a School Meals Initiative (SMI) Review?
An SMI Review is a menu and nutritional review of the reimbursable school meals.
An SMI Review ensures that meals served under the NSLP and SBP meet the Dietary Guidelines for Americans and specific nutrient and calorie requirements for the age/grade level of the students you serve.
Nutritional analysis of a school week’s menu to ensure compliance with USDA-established standards for calories and other nutrients.
Conducted every three years (*new).

28. SMI Review - Documents Reviewed
School week menu
Production records
Standardized recipes
Nutritional information for products served
(if Nu-Menu’s) nutrient analysis

29. Tips for a Successful SMI
Be sure Menus are planned according to regulations
Update Standardized Recipes and be sure staff is trained to follow them
Collect Product Labels and Nutritional Information as products are used
Encourage students to take all components, especially fruits and vegetables
Choose a “Serve” school or one that most components are taken
Be sure Production Records are accurately filled out, no food items are missing and portion sizes are correct.

30. Recent and Upcoming Changes to Illinois and Federal Food Programs
What’s New
Recent and Upcoming Changes to Illinois and Federal Food Programs

31. Managing Life-Threatening Food Allergies in Schools
Districts must have policy in place by January 2011.
Guidelines and resources on website

32. Web-based Illinois Nutrition System (WINS)
New Computer System to replace Child Nutrition ACES
Planned to release for School Year
Planned Changes
Application for program will be based on school year – July 1 – June 30
Monthly Claim for Reimbursement will require the submission of DAILY meals claimed (free, reduced-price and paid)
More information will be forthcoming!

33. Healthy Hunger-Free Kids Act 2010
Dietary Guidelines
Proposed Nutrition Standards for meal pattern
Final Rule Winter 2012
Milk- 1% or Fat Free
School Year
Potable Water
Available at no charge to all children
ASAP or SY
Equity in Meal Pricing
Paid Lunch Price- July 1, 2011
Non-reimbursable meal foods sold
Revenue equal or greater than cost- October 1, 2010

34. Healthy Hunger-Free Kids Act 2010, continued
CRE and SMI Reviews
Every 3 years, implementation date pending
Results must be posted
Community Eligibility Option
Phased in over several years, nationwide
Categorical Eligibility for Foster Children, Oct 2010
Outreach to Eligible Families- Summer Food Service
Printed or electronic notification of free meals, Oct 2010
Privacy Protection
Supply last four digits of SS# on household applications, July 1, 2011 (updated application coming soon)

35. Healthy Hunger-Free Kids Act 2010, continued
Local Wellness Policies/ School Nutrition Environment Reporting
TBD
Professional Standards for School Food Service
Required Education, training and certification
Program Evaluation
Full cooperation with USDA and contractors conducting research- Oct 1, 2010
Food Safety Audits and Reports
Report of two required food safety inspections
Food safety applied to entire school campus
Oct 1, 2010

36. Visit www.isbe.net/nutrition for Workshop Dates and other important information

37. Thank You