The NEW Administrative Review
Post on 30-Dec-2015
24 Views
Preview:
DESCRIPTION
Transcript
The NEW Administrative Review
This institution is an equal opportunity provider
It takes a lot of courage to release the familiar and seemingly secure, to embrace the new. But there is no real security in what is no longer meaningful. There is more security in the adventurous and exciting, for in movement there is life, and in change there is power- Alan Cohen
The Healthy, Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process: Consolidate the Administrative Review Processes Incorporate school breakfast, the new meal pattern and
dietary specification, and the 6-cent performance based reimbursement
Implement a 3-year review cycle Provide for offsite monitoring approaches Provide effective training and ongoing technical
assistance
Administrative Review Goals
New processes uses tools and forms designed to be: Modular Efficient Flexible Effective Collaborative
Revamped Resources
Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit
Additional Off-Site Monitoring Tools Include: Meal Compliance Risk Assessment Tool Dietary Specifications Assessment Tool Resource Management Risk Indicator Tool
Off Site Assessment Tools
Maximizing Resources
Review Period Most recent month claim submitted, Must
include 10 or more operating days 2013 Reviews
Postponed Reviews from 2012 Those schools not 6 Cents Certified
Special circumstances Reviews early in school year Year round, multi-track, and Provision schools
3 Year Review Cycle
Just because everything is different doesn’t mean that everything has changed.- Irene Peter
New Administrative Review Areas
Notify Superintendent and Food Service Director
Initiate Off-site Assessment Tools Review SFA Documentation Obtain pre-visit information Select NSLP sites for review
Pre-Visit Procedures
Entrance Conference On-Site Review Exit Conference
On-Site Review Procedures
Certification Household Applications and Direct Certification
7 CFR 245.6 for process Benefit Issuance
Roster and Medium of Exchange 7 CFR 210.7 (c)(1)(ii); 245.6 (a)(4); 245.6 (c)(3)(iii); 245.6
(c)(6)(iii) Verification Meal Counting and Claiming
School level review
Entire School Food Authority
Complete Off-Site Assessment Tool Step 1: Obtain Benefit Issuance Document
Must always use the list used by the Point of Service
Must be a day during the review period Step 2: Select Student Certifications for Review Step 3: Obtain Certification Documents
Off-Site Review Phase
Step 2: Selecting Student Certifications for Review
Step 1: Validate SFA’s procedures as described on the Off-Site Assessment Tool
Step 2: Validate Student Certifications Examine Household Application OR find student on DC
List Step 3: Validate Benefit Issuance Document
Make sure no Overt Identification Validate POS
Step 4: Review Denied Applications Reviewed at least 10 denied applications
On-Site Assessment Phase
If you have always done it that way, it is probably wrong.- Charles Kettering
Accuracy of Verification Applications Verified correctly Sample Size determined correctly Confirmation reviews done as necessary Direct Verification done properly Letter sent to household met FNS requirements Correct documentation received from family and
determined correctly Notice of adverse action met FNS requirements
Verification
Review scheduled for: Validation Review
Prior to completion of Verification Summary Report (FNS742)
*Previous year Verification Summary Report*Previous year’s verified applications
Timeframe that falls BEFORE the Verification Summary Report for the current school year has been submitted BUT after the SFA completed Verification
*Previous Year’s FNS742*Validate the number of applications from the previous school year*Review current year’s verified applications for accuracy
After the Verification Summary Report is completed
*Use current year’s applications and FNS742
Verification Review Documents
Verification Review
Validate Off-Site Assessment Tool Validate the Counting and Claiming Process
Electronic versus Manual Prevention of Overt Identification Point of Service Alternative Points of Service Back-up System Training Consolidation and Reimbursement
Record Errors
Meal Counting and Claiming
Reviewer will assess whether the school: Offers students the required meal components
in the required quantities Gives students access to select required meal
components on all reimbursable meal service lines; and
Records for reimbursement only meals that contain required components in required quantities
Meal Components and Quantities
At Least two varieties of fluid milk at breakfast and lunch Fat Free, Flavored or unflavored Low fat, unflavored
Milk Requirements
Schools must offer vegetables from five vegetable subgroups over the course of a week: Dark Green Red/Orange Beans/peas Starchy Other
Vegetable Subgroup Requirements
Starting July 1, 2013 in NSLP and SBP ½ grains offered over the week must be whole
grain-rich Starting July 1, 2014
All grains offered over the week must be whole grain-rich
Whole Grain-Rich Requirements
Review breakfast and lunch documentation to assess meal pattern compliance Menus/production records 6 Cents reimbursement documentation
Week must be 3-7 consecutive days Missing meal components/insufficient
quantities: expand documentation review to (at least) entire review period
Documentation Review
Production Records By meal service line and age/grade group served Support claims Document what was served and leftovers Food is creditable for portions served Document that daily and weekly meal component
requirements are met Identify if seconds are offered regularly
Pre-Visit Documentation Review
Ensure all reimbursable meal lines offer all required components
Make sure standardized recipes are used and followed
Ensure students have access to, and know how to select a reimbursable meal
Ensure there is a milk variety available to all students
“Like” substitutions strongly encouraged
On-Site Review
The State agency will monitor whether: School is offering enough food on all reimbursable meal
service lines; Signage is posted on the service line; Students are selecting enough components/items to make
a reimbursable meal; Food service staff are accurately judging quantities on self-
serve bars; and Food service staff at the POS are trained and can
recognize a reimbursable meal If they make a child go back for more food when the child has
a reimbursable meal, that is now a OVS violation
Offer Versus Serve
Lunch Must take 3 of 5 components Fruits and Vegetables are 2 separate food components Must take at least ½ cup serving of fruit or vegetable component
Food Component is one of the five food groups for a reimbursable meal
Breakfast 4 food items for OVS versus 3 items for non-OVS Must include the three breakfast components (Fruit (or vegetable
substitute), Grain, and Milk) Food Item is a specific food offered within the five food components
After School Snack
Offer versus Serve
School BreakfastOVS
Must Offer 4 Breakfast Items that include the 3 Breakfast Components:
Fruit (or Vegetable SubstituteGrainMilk
Student may decline:1 Item
Student Must Take:At Least 3 items
One component must be fruit or vegetable (SY 2014-15)
School LunchOVS
Must offer 5 Lunch Components:Fruit
VegetableGrain
Meat/Meat AlternateMilk
Student may decline:2 Items
Student Must TakeAt Least 3 components
One component must be fruit or vegetable
OVS: Breakfast and Lunch
We will be asking you 26 questions to assess your practices and determine if you are a Low Risk or High Risk
We will request and review a weeks worth of menu documentation from the targeted menu review site prior to coming on-site Breakfast & Lunch Menu Corresponding Production Records Corresponding Standardized Recipes
If High Risk will have to complete on-site Dietary specifications Assessment tool and a Nutrient Analysis Nutrition Facts Labels and Manufacturer Specification Sheets will be
requested for all food to complete a nutrient analysis
Dietary Specifications
Possible Findings: Missing Meal Components Insufficient quantities of Fruits/Vegetables Implementation Staff Training Signage
Technical Assistance & Corrective Action
Must review at least 1 school 0-5 schools selected that operate FFVP –
Review 1 6-10 schools selected that operate the FFVP –
Review 2 11-20 schools selected that operate the FFVP –
Review 3 Must review the invoices, timesheets,
purchase orders, etc. submitted for the FFVP claim
FFVP Meal Service observation
Review FFVP
Reviewer will determine if SFA retains final administrative and management responsibility for meeting all afterschool snack requirements
Assess compliance in the following areas: Eligibility Accountability/Meal Counting and Claiming Meal Pattern/Production Records Monitoring General Areas
Review Afterschool Snack Program
General Areas of Review Written Food Safety (HACCP) plan Food Safety Inspections posted in a publicly
visible location Temperatures Monitored Request for two inspections Recordkeeping Storage
Food Safety
Have an “…And Justice for All” poster displayed in a prominent location
Program materials have the correct statement included
Civil Rights policy and procedure Documentation for staff training
Civil Rights
FNS Memo SP42-2011 Copy of the Local School Wellness Policy How does the public know about the Local School Wellness Policy?
Periodic review and update How are stakeholders made aware of their ability to participate Goals for Nutrition Education, physical activity, school based
activities Nutrition promotion goals Designated LWP oversight official Nutrition guidelines Plan for Measuring implementation How does the public know about the results of the most recent
assessment on implementation of LWP?
Local School Wellness Policy
Maintenance of the Nonprofit School Food Service Account
Indirect Costs Paid Lunch Equity Revenue from Non-Program Foods USDA Foods
Resource Management
Nonprofit School Food Service Account Did you conduct a year-end review of revenues and
expenses? Did you have expenses in excess of revenues? If you had a surplus – was this amount moved out of your
account? Net Cash Resources
Less than 3 month operating balance Allowable Costs
Restrict the use of program funds to expenses that meet the requirements of 2 CFR 225 and are reasonable, necessary, and otherwise allowable.
Maintenance of the Nonprofit School Food Service Account
Review the SFA’s most recent full year statement of revenues and expenses
Determine whether selected expenses are allowable
Ensure accurate and sufficient support documents are maintained for allowable costs Select a sample of at least 10% of the SFA’s
expenses to test compliance and allowability
Review
WE will check your PLE calculations and amount you determined to increase prices to make sure prices were increased, and if not, make sure that there is a corresponding move of money from non Federal sources (i.e. the General Fund) to Food Service to make up for not increasing prices.
PLE
Non-Program foods – Foods and beverages sold in a participating school that are purchased using funds from the nonprofit food service account
Includes: A la carte items Adult meals Vending machine food purchased with food service
funds Fundraisers Catered and vended meals
Non-Program Foods Revenue
Does the SFA use the USDA Revenue from Non-program Foods Tool to calculate its non-program food costs and non-program food revenue?
Non-Program Foods Revenue
FNS Instruction 782-5 Rev. 1 Adult meal prices should include the value of any USDA
entitlement and bonus donated foods used to prepare the meal
Lunch Reimbursement Rate $2.88 Commodity Rate $.2275 Tax at 6% Total Lunch Adult Price $3.27-$3.29 depending on lunch
rate Total Breakfast Adult Rate $1.60-$1.91
Adult Meal Prices
Ensure SFAs are correctly determining if their costs are allowable, allocable and appropriately charged as a direct or indirect cost.
Indirect costs are determined on an annual basis at the Department Of Education and are valid for one year. Direct costs – incurred specifically for a program or
other cost objective; clearly identifiable Indirect Costs – Incurred for the benefit of multiple
programs, functions, or other cost objectives; not readily identifiable
Indirect Costs
The reviewer should determine if the SFA is conducting an annual reconciliation to ensure that a purchasing agent of FSMC has credited the SFA for the value of all USDA foods received.
Must also review invoices to make sure all rebates, discounts and credits are properly given back to the SFA
Food Service Management Company
Have at most 30 days to correct. Some corrective action must occur
immediately
Corrective Action
Regulatory Authority Authority for Withholding Payments as a
result of Administrative Review (7 CFR 210.18 (l))
Authority for Withholding payments (7 CFR 210.24)
Withholding Payments
SFA has failed to submit documented Corrective Action by the specified due date
SA finds Corrective Action was not completed
SFA continues to have the same problems with the same cause
Payments are withheld until the SA determines that Corrective Action was properly implemented by the SFA
When???
Applications missing information Miscategorization of Certification Benefit Issuance Errors Failure to update verified applications
Fiscal Action
Missing Meal Components Immediate fiscal action required
Vegetable Subgroup & Milk Type Fiscal Action required for repeat violations
Quantities & Whole Grain Rich Fiscal action discretionary for repeat violations
Fiscal Action
2013-14 SFA’s to be reviewed
Sugar Salem SD
Never doubt that a small group of committed people can change the world. Indeed, it is the only thing that ever has.- Margaret Mead
Thank you
top related