SCN Record Keeping Chart - Pennsylvania …education.ky.gov/federal/SCN/Documents/SCN Record Keeping... · Web view3/2017 Version 2 V Record Keeping for School Meal Programs SFAs

Record Keeping for School Meal ProgramsSFAs must retain records and documentation concerning all aspects of operating a Child Nutrition Program. While it can be tedious and overwhelming, it is important that appropriate and adequate records are maintained.

SFAs must retain documentation to support:

• Information/data reported to the State Agency

• Program operations are in compliance with regulations

• Demonstrate that policies and procedures are properly implemented

• Sound program operational decisions are made

Record Retention RequirementsThe general rule of thumb for record retention of program records is that they must be maintained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. However, if there are any audit findings and they have not been resolved, the three-year period is extended as long as required for resolution of audit issues.

There are three (3) main exceptions to this rule of thumb:

1. Temperature logs are required to be maintained for a period of six (6) months

2. Provision 2 – Base year records

3. CEP - ISP records

All Provision 2 and CEP records must be retained for three years after submission of the final claim for reimbursement. Records must continue to be retained if any audit findings from the period during which the records were in use remain outstanding. In any such case, records must be retained until all issues raised by the audit have been fully resolved.

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3/2017

Version 2

The base year in Provision 2 establishes a claiming percentage that is utilized in subsequent years in the Provision 2 cycle. The base year records must be maintained for three years after the final claim for reimbursement that utilized the percentages established by the base year is filed.

Base year records for Provision 2 to maintain:

Student eligibility certification records

Verification Records

Claims

Meal Count Records

The records demonstrating that the claiming percentages established by the base year are properly applied for the Provision 2 cycle and any approved extensions are:

Monthly claims for reimbursement

Meal count records used in claiming

For Community Eligibility Provision (CEP), SFAs must retain those records used in the development of the Identified Student Percentage (ISP) (e.g., records for the initial approval year and all records from the year any updates are made to the ISP) during the entire period the CEP is in effect.

The SFAs April reporting establishes the ISP that will be used in the CEP cycle. When establishing a base year for a CEP cycle, the April data reported in the school year prior to the base year is the information that must be maintained until the end of the cycle, plus three years after the last claim is filed.

If April reporting indicates that the ISP is higher than the established percentage currently used for claiming, SFAs are encouraged to establish a new base year and start a new cycle. If the SFA does not elect to start a new cycle with the higher ISP, the records for the base year and the updated ISP must be maintained for three years after the last claim is filed for the CEP cycle.

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The records used in the April reporting and used to establish an ISP must come from the Child Nutrition Programs point of service

system. The records that must be reported from and maintained are:

The number of enrolled students on April 1st

The number of identified students (directly certified) on April 1st

The list of student names of the enrolled students

The list of student names of the identified (directly certified) students

SFAs may need to maintain records longer than what is outlined in federal requirements if there are local policies in the districts/organizations that dictate records be maintained for a longer period of time. Local policies cannot be followed if the record retention is for a lesser period of time than the federal requirements.

Records and DocumentsThere are numerous recordkeeping requirements related to the operation of a child nutrition program. Some recordkeeping requirements have a required format or form that must be used. However, most required documentation is up to the SFAs to determine how they will document and maintain theses records in their schools and districts. For example, SFAs must use the “Onsite Monitoring Form” found on SCN’s website to document the onsite reviews they conduct. However, in verification there is not a required form or format that must be used when documenting information concerning follow up attempts with households who haven’t responded. In this instance the SFA has to determine how this recordkeeping requirement will be handled in their operation.

SFAs at times will use their own record keeping documents to record information that is later transferred over to a required form or format. In these instances the SFA’s records that were used to create or develop the information that is transferred or used on the required form is considered the source documentation and must be maintained with the required form. For example, it is a common practice for production staff to record the number of servings prepared in notebooks or commonly called a “cooks’ book” in the kitchen while preparing meals so that they don’t have to write and erase on the actual production record. The manager then rewrites information from the notebook onto the production record after the meal service. In this instance the “cooks’ book” is the source documentation for the number of servings prepared and must be maintained with the production record in order to have the required documentation about the number of portions prepared for the meal service.

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Adequately DocumentedWhen determining how a to document and record program operations the guiding principle of creating an auditable trail should be followed to ensure that operations are adequately documented. This criterion of “adequately documented” does not imply the existence of a one‐size‐fits‐all definition of “adequately.” It means, that the record of a school meal programs’ operation must be able to stand on its own without being dependent on further information, interpretation, or “spin” by the program operator.

For example, it should be self-evident from the review of meal counting records what students ate lunch on which days in the month that made up the number of lunch meals claimed for reimbursement.

Storage of RecordsSFAs are encouraged to develop a system of document retention that allows them to be readily retrieved when needed. Electronic recordkeeping is an allowable form of record storage and is encouraged as an avenue to reduce the amount of paper SFAs maintain. Districts/organizations may have policies related to electronic record keeping that SFA’s may need to include in their record keeping processes.

When storing records electronically, the records should be stored in a manner in which they are accessible to others within LEA when needed and in a secure manner. Any student identifying information should be in a locked cabinet or similar manner in which individuals outside of the Child Nutrition Program do not have access to the information. While it may be convenient to access records when they are stored locally on a computer, the records may easily be lost due to computer issues and will not be accessible to others if needed. It is highly recommended that electronic records are backed up to a secure server or saved a portable storage device that is then stored in a secure location.

Record Keeping Charts

The charts below provide a brief overview of records SFA’s should maintain. This list is not meant to be all inclusive. Depending upon program operations within individual schools and organizations or ongoing changes to policies and regulations there may be additional records that must be maintained. SFA’s should refer to guidance, policy and regulations for further information.

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Meal Counting and Claiming

Record of Meals ServedSFAs must maintain records of the number of meals served at a point of service in order to claim meals for reimbursement. These records must (1) Record the total number of reimbursable meals served by eligibility category and (2) create cumulative monthly reports.

Records POS reports, electronic

record or manual records.

Retention/Submission Per onsite record retention

policy.

Frequency Daily Monthly cumulative

Due Date/s- n/a

Edit Checks Edit Checks are designed to be a tool for SFAs to (1) check the accuracy of the number of meals claimed by eligibility category for a specific meal period and month of operation and (2) reduce the incidence of over claims. SFAs are required to perform Edit Checks daily and monthly on cumulative data prior to filing a claim for reimbursement..If more meals are served than anticipated, the SFA must investigate and document resulting action.

Records- POS software reports or

forms


policy.

Frequency- Daily- Monthly

Due Date/s- Daily- Monthly

Provision 2SFAs operating breakfast and/or lunch under the provision 2 option must maintain the documentation to support the establishment of the base year data and the application of the claiming percentages used in subsequent years.

Records Required for AR Base year eligibility

certification documents Base year verification Base year claims Base year meal counts


policy.

Frequency Daily Monthly

Due Date/s- n/a

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April Reporting/Identified Student Percentage – N/A to residential only RCCI’sSFAs must report the number of identified students through direct certification and the total enrollment at each school site as of April 1st. This data is utilized to identify potential CEP eligibility and to establish the claiming percentage utilized by CEP schools. Reports must be generated by the SFAs point of service system and not the school’s enrollment system.

Records- The number of enrolled

students and the number of directly certified student students on April 1st for each school.

- A list of all students enrolled in each school that makes up the enrollment numbers reported.

- A list of students in each school that are identified as D.C. that make up the number of Identified Students reported.

- Electronic direct certification March history file

Signed lists for homeless, runaway, migrant and Head start.

Documentation of the makeup of households to support extended student eligibility.


policy. Submitted through CNIPS.

Frequency Annually

Due Date/s Annually per SCN.

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Free and Reduced Price Process

Public Media Release – N/A for residential RCCIsNear the beginning of each school year, the public must be notified that free and reduced price meals and free milk are available. This notice must include the eligibility criteria for free and reduced price meals or free milk or the schools participation in the Community Eligibility Provision. It must be provided to the local news media, the unemployment office, and any major employers who are contemplating large layoffs in the attendance area of the school. The media release must contain all informational elements outlined in the current year Eligibility Manual for School Meals.

Records Content of the Public Media

Release must follow the guidelines outlined in the current years USDA Eligibility Manual for School Meals.


policy. Must be submitted to the SA

and approved as part of the Policy Statement.

Frequency Updated annually

Due Date/s Required release at or close

to the beginning of the school year.

Required to be submitted for approval in the Policy Statement prior to use.

Household Application, Letter to Households and Instructions – N/A Full CEP and residential only RCCIsSFAs must (1) retain a copy of each household’s application and (2) record any information related to approval, denial, or termination of benefits on the application. As well as any updates during the program year. SFAs using electronic applications must have a way to record and retain the same information.

Records- Must use the current year

prototype household application. State Agency approval required annually for use of any other form or format.


policy. Must be submitted to the SA

and approved as part of the Policy Statement.

Frequency As needed- Updated annually

Due Date/s Required release prior to or

during the first week of school and as students enroll

- Required to be submitted for the Policy Statement prior to use.

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Individual Determination Form – Used only for residential only children in RCCIsRCCIs must determine residential children’s eligibility status through the use of an Individual Determination Form in order to be reimbursed at the free rate for the meals served.

Records Use form on SCN’s website.


policy.

Frequency As Needed Updated annually

Due Date/s Annually Ongoing

Direct Certification Documents – N/A for residential only RCCIsThe documents used to provide a student a directly certified eligibility status must be maintained. A designation due to SNAP benefits takes precedence for the reason for D.C. if more than one avenue to a D.C. status applies. Once the avenue for D.C. is identified as SNAP, this should remain constant for the rest of the program year regardless if other reasons for D.C. designation are identified.

Records- Electronic copies of each

monthly D.C. file and corresponding history file.

- Signed lists from respective homeless, migrant, runaway and/or Head Start coordinator.

- Documentation of the makeup of households to support extended student eligibility.


policy.

Frequency- Ongoing as needed- Each electronic D.C. list

must be saved on a monthly basis.

Due Date/s- Electronic D.C. downloads

should be conducted on a monthly basis.

- Ongoing for other forms of D.C.

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Income Eligibility Guidelines (IEG) Chart – N/A Full CEP and residential only RCCIsThe income eligibility guidelines are released annually from Congress to be used in determining the income guidelines to qualify for free or reduced meals. The income eligibility chart must be included in the public media release and the letter to households that accompanies the household application.

Records Use format provided in the

current year prototype application packet.


policy.

Frequency As needed Updated annually

Due Date/s Released annually

Appeals related to Student EligibilityWhen households appeal the eligibility determination of their household application, records of the appeals process must be maintained to demonstrate compliance with requirements.

Records Any related Communications Timelines and Outcome

Retention/Submission- Per onsite record retention

policy

Frequency As needed

Due Date/s- Annually

Letter to Household of Approval/Denial of Benefits – N/A for Full CEP and residential only RCCIsThese letters are sent to parents or guardians to inform them that their children are approved or denied for free or reduced-price meals or free milk.

Records- Must use current year

prototype letter or have alternate approved by the SA each program year.


policy.

Frequency As needed Updated annually

Due Date/s- Upon eligibility

determination.

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Letter of Eligibility—Direct Certification – N/A for Full CEP and residential only RCCIsSFAs must notify households that their children are Directly Certified to receive free meals without the submission of a household application.

Records Must use current year



policy.

Frequency Ongoing

Due Date/s Upon certification

Confidentiality and DisclosureSFAs are required to keep all information concerning student eligibility confidential and must maintain documentation that any disclosures to persons outside of the school meals program is in compliance with federal regulations.

Records Disclosure agreements Disclosure policy Requests for information Signed confidentiality

agreements for all persons provided information.


policy.

Frequency Ongoing

Due Date/s- Ongoing

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Effective Date of EligibilitySFAs must be approved by the SA to establish the effective date of eligibility as the date in which an application or D.C. information was received instead of when the information is processed. Refer to the current year eligibility manual for all requirements related to this flexibility.

Records SA approval of the SFAs

procedures for implementing the flexibility date of eligibility (meal counting and claiming procedures)

SA approval of use in the sponsor application

Documentation of the date in which information was received in the district

Records demonstrating that any charges or money collected in the time period between being the information being received and when it was processed is forgiven or reimbursed to the household prior to claiming.


policy. Approval submitted through

CNIPS during online application renewal.

Frequency As needed

Due Date/s Must be approved annually Documentation of time of

receipt and forgiveness/reimbursement in place prior to claiming.

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Independent Review of ApplicationsAs part of an effort to decrease certification error during the eligibility determination process, section 304 of the HHFKA requires that certain local education agencies (LEAs) conduct a second, independent review of applications for free and reduced price meal benefits before eligibility determinations are made. LEAs that demonstrate high levels of, or a high risk for administrative error associated with certification and benefit issuance are required to conduct a second review of applications. Criteria 1: All LEAs with 10 percent or more of the certification /benefit issuances in error as determined by the State agency during an administrative review. Criteria 2: LEAs with greater than or equal to 5% benefit issuance errors and less than 10% benefit issuance errors as determined by the State agency during an administrative review.

Records All applications, free,

reduced, paid, denied as of October 31st.

Documentation and notes included with applications if further information was necessary to complete the application.

Report form 874.


policy.

Frequency Annually until State

Agency determines via Administrative Review that the benefit/issuance errors fall below 5%.

Due Date/s- SFA will be notified they

must do an Independent Review by July 1st.

- Report Form 874 due to State Agency by November 15th.

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Verification Activities and Verification for Cause

Verification Sample Size – N/A for Full CEP and residential only RCCIsDocuments or reports utilized to determine the number of approved free and reduced household applications on file as of October 1st. Documents or reports should indicate the number of apps approved for free or reduced benefits by income or categorical eligibility.

Records should indicate the type of verification conducted the calculation of the number of applications to verify. (All SFAs must conduct standard verification unless approved by the SA to use an alternate method in their sponsor application.)

Records Use of these forms or similar

forms


policy.

Frequency Annually

Due Date/s- October 1st

Confirmation Reviews – N/A for Full CEP and residential only RCCIsAn individual other than the determining official must confirm that the original determination for free or reduced benefits was correctly determined.

Records Document signature and date

of confirmation official per district protocol.


policy.

Frequency- Annually

Due Date/s- Prior to notifying the

household of their selection for verification.

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Replacement of selected application - N/A for Full CEP and residential only RCCIsIf the SFA replaces a selected application for verification, a like application must be selected.

Records Document per district

protocol.


policy.

Frequency Annually

Due Date/s- Prior to notifying household

of their selection for verification.

Notification of Selection for Verification Letter - N/A for Full CEP and residential only RCCIsSFAs must inform households of their selection of their household application in the verification process.

Records Must use current year



policy.

Frequency- Annually

Due Date/s- Upon completion of the

confirmation review.

Follow Up - N/A for Full CEP and residential only RCCIsIf the households have not responded to their notice of verification, SFAs are required to make at least 1 attempt to follow up with the household to try and obtain the necessary documents.

Records- Document per district

protocol.


policy.

Frequency Annually

Due Date/s Prior to November 15th (Best

practice – 2 weeks after notification).

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Household Documentation Submissions - N/A for Full CEP and residential only RCCIsHouseholds must submit documentation to support all of the income information provided on their household application or documentation of any case number provided on a household application. If the determination for the household was based upon the income information provided, proof of income in the allowable timeframe must be submitted to support the income reported. If the determination was made based upon a case number on the application, the household must provide documentation of receiving SNAP or KTAP benefits.

Records- Maintain documents and any

related communication with households per district protocol.


policy.

Frequency- Annually

Due Date/s- November 15th

Results of Verification Notification Letter - N/A for Full CEP and residential only RCCIsSFAs must inform parents or guardians of households the results of the verification process. Prototype letters are released annually with the application packet that includes all of the required content of a letter to inform households as outlined in the most recent USDA Eligibility Manual for School Meals guidance.

Records- Must use current year



policy.

Frequency Annually

Due Date/s Upon completion of

validating a household application. All must be validated and letter sent by November 15th.

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FNS-742/Verification Report – All schools including CEP and RCCIs must report!The SFAs must annually report information related to their verification activities (if applicable). Full CEP districts and RCCIs report the number of schools/sites and the number of enrolled students as of October 1st. Most point of service electronic systems have the capability create a report to provide the information and data required for this reporting event.

Records Entered into CNIPS. SFA’s

should maintain documents that support the submission.


policy. Submitted through CNIPS

Frequency Annually

Due Date/s Per SCN announcement

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Onsite Monitoring - When there are two or more Schools

Onsite Monitor Review FormSFAs with 2 or more schools are required to conduct an onsite review on the lunch meal counting and claiming procedures at each school site by February 1st. While not required, it is highly encouraged that SFAs conduct a review on breakfast meals as well.

Records Must use the onsite

monitoring form on the SCN website.


policy.

Frequency Annually

Due Date/s- By February 1st

Follow up Review When problems are identified during the initial monitor review, SFAs must identify and implement corrective action. A follow up review must be conducted within 45 days to ensure the corrective action is implemented and adequately addresses the issue(s) identified in the monitor review.

Records Must use the monitoring

form on the SCN website.


policy.

Frequency As applicable

Due Date/s 45 days after onsite monitor

review.

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Community Outreach

Breakfast Outreach DocumentationSFAs must inform families of the availability of breakfast. Notification must be relayed just prior to or at the beginning of the school year. Families should be sent reminders regarding the availability of breakfast multiple times throughout the school year.

Records Copy of notification to

families.


policy.

Frequency Annually Ongoing throughout school

year.

Due Date/s Required notification prior

to or at the beginning of school year.

Ongoing throughout the school year.

Summer Feeding Outreach DocumentationSFAs must inform eligible families of the availability and location of free meals for students offered by all summer feeding sponsors in the attendance areas of their school after the regular school year ends. Notification can be through any means normally used to communicate with the households of enrolled children.

Records Copy of notification to

families.


policy.

Frequency Annually

Due Date/s At the end of the school

year.

Record of Student-Community-Parent InvolvementSFAs must document any involvement of students, community members and parents or guardians at sites operating a school nutrition program each school year.

Records Form is available on SCN’s

website.


policy.

Frequency Ongoing annually

Due Date/s- Ongoing annually

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Resource Management

Capital Expenditure RequestSCN must grant prior approval of capital equipment purchases that exceed $5,000 for capital equipment not on the SCN pre-approved list.

Records Required form to submit for

approval is on SCN’s website.


policy. Required to be submitted to

your approving consultant.

Frequency As needed.

Due Date/s Prior to purchase.

Equipment ManagementSFAs are required to maintain records of property with the serial or identification number, source of the property, who holds the title, acquisition date, cost, percentage of federal participation in the cost, the location use and condition and ultimate disposition data including the date of disposal and sale price. A physical inventory of equipment must be taken and reconciled with records at least once every two years.

Records Record per

district/organizational policy Documentation of sales

procedures if sold. Documentation of any

investigation of theft, loss or damage.


policy.

Frequency Annually Inventory at least once every

two years.

Due Date/s- n/a

Equipment DepreciationSFAs should document and determine the depreciation value of equipment with an original value of more than $1000.00.

Records Records per

district/organizational policy.


policy.

Frequency Annually

Due Date/s n/a

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Financial ReportingSFAs must annually report information concerning the financial position of Child Nutrition funds to the State Agency.

Records Statement of revenues,

statement of expenses and balance sheet.

SNP MUNIS Report (public schools


policy. Submitted through CNIPS

Frequency Annually

Due Date/s- Per SCN announcement

Plan for Reducing Excessive Operating Food Service Fund BalanceSFAs must have an approved plan in place when financial reporting indicates the SFA has a greater than 3 month operating balance.

Records SA approved spend down

plan.


policy. Submitted to Program

Branch Manager.

Frequency Annually if applicable

Due Date/s- Upon notification

Statement of Program RevenuesSFAs must track all revenues specific to the Child Nutrition Program separately from all other revenues within the district/organization. SFAs are expected to record information daily and review cumulative weekly, monthly, and yearly reports. Financial statements should conform to all generally acceptable accounting practices. Supporting documentation for each entry must be maintained.

Records Munis (public schools) Financial statement records

(non-public school sponsors)


policy.

Frequency Daily Weekly cumulative Monthly cumulative Annually cumulative

Due Date/s- n/a

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Statement of Program ExpendituresSFAs must track all expenditures specific to the Child Nutrition Program separately from all other expenditures within the district/organization. SFAs are expected to record information daily and review cumulative weekly, monthly, and yearly reports. Financial statements should conform to all generally acceptable accounting practices. Supporting documentation for each entry must be maintained to support that costs are allowable.

Records Munis (public schools) Financial statement records

(non-public schools)


policy.

Frequency Daily Weekly cumulative Monthly cumulative Annually cumulative

Due Date/s- n/a

Balance Sheet (Statement of Net Position)SFAs should monitor the financial position of the Child Nutrition Program at the end of each accounting period by reviewing a balance sheet. The balance sheet should include information about the program’s assets, liabilities and fund balance.

Records Munis (public schools)- Financial statement records

(non-public schools)


policy.

Frequency Monthly Annually cumulative

Due Date/s- n/a

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Indirect CostSFAs must maintain documentation of the approved indirect cost rate, the makeup of the indirect cost base and documentation of how the rate is applied when indirect cost is collected.

Records Approved indirect cost rate

from federal cognizant agency (public schools – KDE website).

Indirect cost base used in the rate approval.

Financial Records.


policy.

Frequency Monthly (if collected) Annually

Due Date/s- n/a

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Paid Lunch Equity Tool (PLE Calculator) – N/A for full CEP districts and RCCIs who do not charge day students a paid meal price.The USDA excel workbook must be used by SFA’s to calculate any necessary increase in meal price in order to meet the PLE requirements. *RCCIs who do not sell meals or food items but provide food to adults who work outside of the child nutrition program may complete the calculator or maintain documents demonstrating that the Child Nutrition Account is reimbursed for the meals provided.

Records Must use USDA excel

workbook 2010-2011 weighted average

price (If applicable) Previous years PLE Paid lunch counts for

October of previous year. Paid lunch prices charged to

students Financial documents if non-

federal funds provided. Increased lunch prices when

applicable.


policy. Submit in CNIPS during

annual renewal.

Frequency Annually

Due Date/s- June

Paid Lunch Equity WaiverFNS annually decides whether or not to provide the SA the ability to grant waivers for raising paid lunch prices in accordance with the PLE. SFAs must submit for a waiver, maintain supporting documentation to demonstrate eligibility to request the waiver and, if approved, maintain a copy of the approval.

Records Copy of request to the SA Supporting documentation Copy of approval


policy. Submit to SCN for approval

per SCN announcement.

Frequency Annually if applicable


23

Revenue from Nonprogram Food Tool – All SFAsSFAs must annually determine if the proportion of revenues from selling or providing non-program food is equal to or greater than the proportion of costs used to produce them. SFAs must follow the procedures outlined in the SCN guidance in order to be considered compliant with this regulation. *RCCI’s must maintain documentation to demonstrate that the Child Nutrition Program is reimbursed for any meals provided to non-program adults and non-program meal services (dinner, snacks, etc.…)

Records Must use USDA tool Must use inTEAM software

to calculate average per meal cost.

Inventory Records Financial Statements Claiming Records Corrective action when

indicated


policy.

Frequency Annually

Due Date/s- After June 30th but prior to

the start of classes for students.

Physical InventorySFAs must conduct a monthly physical inventory on all food and beverages. The value of the inventories must be calculated as well as the cost of the food used for the month. The value of USDA foods must be included when determining inventory values.

Records Required in order to

complete the revenue from non-program food calculator.


policy.

Frequency Monthly


Meals Per Labor HourSFAs should complete an analysis of the meals per labor hour produced in order to assist in evaluating staffing levels.

Records Meals per labor hour form

available on SCN website.


policy.

Frequency Annually


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Procurement

Procurement PlanSFAs should have a written procurement plan that includes the policies and procedures for conducting their procurement of goods and services that conform to local, state and federal laws. The plan should identify the procurement method used and identify awarded contracts currently in use. The written procurement plan should also reference applicable local board policies and procedures that relate to the district’s procurement procedure and written standards of conduct covering conflicts of interest as required by 2 CFR 200.318.

Records Copy of written Procurement

plan. Awarded contracts.


policy.

Frequency Annually


Solicitation DocumentsSFAs must maintain copies of the documents utilized to solicit the procurement of the goods and services utilized in the operation of the Child Nutrition Program

Records Copies of invitations to bid

and request for proposal. Documentation of

announcements


policy.

Frequency As needed

Due Date/sn/a

Small and Micro PurchasesSFAs must maintain copies of the documents utilized to procure goods and services utilizing small and micro purchase procedures to demonstrate that federal requirements were met.

Records Product specifications used

for small purchases Documentation of price

quotes received Documentation of reason for

award


policy.

Frequency- As needed

Due Date/sn/a

25

ContractsThe SFA must maintain documentation of all records related to the execution and management of the contracts awarded from their solicitation activities that are utilized to purchase goods and services for the Child Nutrition Program with federal funds.

Records The bidding and negotiation

history including notes from evaluation if applicable.

Billing and payment records A history of any contractor

claims A history of any contractor

performance (oversight and monitoring

Fully executed contracts Amendments


policy. Vended meal contracts and

Foodservice management Company (FSMC) contracts must be submitted and approved by the SA through CNIPS.

Frequency Annually Ongoing

Due Date/s- Upon contract award- FSMC contracts must be

approved prior to implementation

Non-Competitive Proposals SFAs must obtain approval from the State Agency prior to awarding contracts or purchasing goods and services when there are mitigating factors that the SFA believes prohibits following their normal procurement processes or if an inadequate number of responses for goods and services is received when following the established procedures.

Records Documents that establish one

of the following:- item is available from a single source;- emergency exists;- KDE has expressly authorized use of noncompetitive proposal; or- Competition is deemed inadequate.

- Documents that establish: Dollar amount, vendor, Justification for non-competitive proposal.


policy. Submit request for approval

to State Agency

Frequency As needed

Due Date/s- n/a

26

Buy American SFAs are required, to the maximum extent practicable, use domestic commodity products. Any exceptions to the Buy American Provision requirements must be granted by SFAs only as a last resort, thoroughly documented and used only for reasons allowed by law. SFAs must ensure compliance through incorporating appropriate language in procurement activities, implementing required monitoring procedures and through effective contract management for vendor performance.

Records Procurement solicitations,

bidding documents and awarded contracts and agreements.

SFA Buy American monitoring policies to identify any unapproved non-domestic products while receiving deliveries and periodically to check storage areas.

Exception requests from vendors, alternative considerations and reason for approving exception.

Documentation of vendor performance when unapproved non-domestic products received.


policy.


Due Date/s- n/a

27

Menu Compliance

Production Records SFAs must maintain production records to support the claiming of reimbursable meals. Documentation must support that the meal pattern requirements were met for the total number of meals offered and served and align with standardized recipes.

Records Required to utilize the SA

production record or inTEAM production records.

All others require SA approval annually through the renewal application process.

Any other documentation recorded while producing meals and later transferred to the production record after service.


policy. Required submission to SCN

for approval to use alternate to SA production record or inTEAM production records prior to use.

Frequency Daily for each meal served.

Due Date/s Daily

Standardized RecipesSFAs must develop and utilize standardized recipes for any menu item with 2 or more ingredients. Recipes must provide a list and amount of ingredients used, instructions that include HACCP principles and the corresponding yield information.

Records Written recipe


policy Must be available to

production staff

Frequency Daily

Due Date/s- Daily

28

Food Usage SFAs should record the amounts of the food items removed from inventory to produce the meals they serve.

Records In combination with

production record. Any other documents used to

record food usage.


policy

Frequency Daily

Due Date/s Daily

Menu Worksheets for age/grade groups served – Breakfast and LunchSFAs must enter 1 week of breakfast and lunch into the inTEAM software for each age/grade group menu served using production record information to utilize the pre-cost feature to establish an average per meal price as well as to confirm that planned menus are in compliance. SFAs must enter one week of menus for each age/grade group served for both breakfast and lunch into the inTEAM menu compliance software for an administrative review for each school selected for review.

Records Required to utilize inTEAM

menu planning software Production records Recipes Crediting information Cost information


policy

Frequency Annually to pre-cost Once every three years as

part of the AR

Due Date/s- Prior to the end of the school

year.- Per SCN AR notification.

29

Planned Menus (Refrigerator Menus)SFAs must submit a copy of the planned menu that is provided to households as part of the administrative review process.

Records- Copies of planned menus

made available to households.


policy. Submitted through inTEAM

menu compliance software.

Frequency Once every three years as

part of the AR.

Due Date/s- Per SCN AR notification.

Dietary Specification and Crediting DocumentationSFAs are required to maintain documentation to demonstrate how the menu items served contribute towards meeting the dietary specification and meal pattern requirements. Acceptable documentation includes CN labels, Manufacturer Product formulation Statements, Nutrition Facts labels, USDA Foods facts sheets and the Food Buying Guide.

Records CN labels Manufacturer Specification

Sheets Product Formulation

Statements Nutrition Facts labels USDA Foods fact sheets


policy.

Frequency Upon procurement of food

items used Upon reformulation of food

items used

Due Date/s- Prior to use

30

Waiver for age/grade Group Requirements – RCCI’s OnlyRCCIs may apply for a waiver to adhere to requirements of separate age/grade group meal patterns when certain conditions apply to the population(s) they serve.

Records Copy of waiver submission

and the State Agency approval must be maintained.


policy. Submitted to the Program

Branch Manager

Frequency Prior to implementation

Due Date/s n/a

Reimbursable Meal SignageSFAs must display signage at or near the beginning of the serving line to communicate to students the menu items that makeup a reimbursable meal.

Records Post in schools at or near the

beginning of the serving line.


policy.

Frequency Daily

Due Date/s- Daily

31

Food Safety

Health Department InspectionsSFAs are required to obtain 2 health inspections annually for all production and service sites. If 2 or more inspections are not completed, SFAs are required to formally request inspections be completed. The most recent inspection should be posted where it is visible to the public. SFA’s must annually report to the SA the number of inspections at each site in the previous program year.

Records Health Department

inspection reports. Communication requesting

inspections be conducted. Supporting documentation of

reporting.


policy. The number of health

inspections is reported to SCN through CNIPS

Frequency Twice annually Reported annually

Due Date/s Annually Reporting deadline per SCN

announcement

Site Level Food Safety PlansAll school/site locations under the SFAs jurisdiction are required to develop and implement a comprehensive food safety program based on HACCP principles that is applicable to all areas in which program food is prepared, served or stored.

Records SOPs identified through an

operational description Menu items categorized into

the appropriate Process Approach

CCPs for each process approach identified

Summary of record keeping, monitoring, corrective actions and verification activities.

The plan to review and revise as needed.

Retention/Submission Required to be maintained at

the site it pertains to and made available to all site level staff.

Per onsite record retention policy.


Due Date/s Review and revise annually

or as needed. Upon program approval.

32

Food Safety Plan RecordsThe SOPs in a food safety plan identify what records will be maintained to document that the monitoring and corrective actions are followed as written. SOPs also identify what documentation will be maintained to demonstrate there is verification to ensure monitoring and corrective actions are followed by staff and properly documented on an ongoing basis.

Records All monitoring records (temp

logs, checklists, etc...) as identified in SOPs

All corrective actions records as identified in SOPs

All verification records as identified in SOPs


policy. Temp logs must be

maintained for six (6) months.

Frequency Ongoing

Due Date/s Upon implementation of

SOPs.

Implementation of the Food Safety PlanSFAs must maintain documentation that the food safety plan is implemented as it is written and meets local, state and federal requirements.

Records Initial implementation

information. Overall plan review and

revision documents. Dates of any updates or

revisions (indicate on SOPs, process charts, operational descriptions, etc...)

Staff training records


policy.

Frequency Ongoing

Due Date/s Upon implementation of

SOPs. As indicated by changes in

program offerings and operations

Staff training upon hire and as relevant duties are assigned

33

Local Wellness Policy

Local Wellness PolicyLEAs are required to develop and implement a local wellness policy in each of the school/sites under their jurisdiction. A wellness committee should be formed to develop and implement wellness goals for the all schools within their jurisdiction. The LEA must tri-annually evaluate goal achievement and update the policy as needed.

Records Updates to policy or

corresponding procedures.


policy.

Frequency Review policy ongoing as

needed Update as needed Assess tri-annually

Due Date/s: Assess Tri-annually

Wellness Policy ImplementationLEAs must maintain documentation that the wellness policy is implemented as written and meets federal requirements.

Records- Public Notification of the

wellness policy- Documentation of review and

updates to the policy- Method(s) of notifying

stakeholders of their ability to participate in the development, review, update and implementation of policy.

- Assessment of implementation- Method(s) of public notification

of the assessment results.


policy.

Frequency- update as needed

Due Date/s:- Ongoing

34

Civil Rights

Civil Rights Complaint ProceduresSFA’s must establish a procedure to process complaints alleging discrimination in accordance with FNS Instruction 113-1. This procedure will be different than the organization/district procedure.

Records Written policy/form Tracking system for

complaints per school year


policy.

Frequency Review and update as needed

Due Date/s Upon program participation.

And Justice for All PostersSFA’s are required to post the “And Justice for All” poster where program meals are served and should be posted in a location that is visible to participants.

Records Poster


policy.

Frequency Daily

Due Date/s n/a

Staff TrainingSFA’s must annually train all persons involved in providing a meal service on the applicable civil rights requirements. Civil rights training is included in the Level 1 certification curriculum.

Records Agenda Sign in sheets of attendees


policy.

Frequency Annually- Ongoing as needed

Due Date/s- Annually- Ongoing

35

Services Provided to Limited English Proficiency HouseholdsSFA’s must document any service or accommodation of households with limited English proficiency (LEP).

Records Application used in alternate

languages Any other supporting

documentation of services or accommodations provided.


policy.

Frequency Annually Ongoing as needed


Accommodating Special Dietary Needs PolicySFA’s should develop a policy with corresponding procedures to provide accommodations for special dietary needs. SFA’s must be knowledgeable of the requirements and responsibilities related to accommodating disabling and non-disabling conditions and the documents that must be provided in order for the SFA to accommodate requests.

Records Written policy with

corresponding procedures. Any forms utilized to

implement policy


policy.

Frequency Ongoing

Due Date/s Upon program participation.

Documentation to provide AccommodationsThe documentation provided to the SFA to request an accommodation must be maintained to demonstrate that the required information was submitted in order to provide an accommodation and that the appropriate accommodation is/was provided.

Records Doctors statements Medical Authority

statements Parent notes (non-disabling

milk substitutions only) Copies of IEP or 504 plan (if

applicable)


policy.

Frequency Annually Ongoing as needed

Due Date/s Prior to providing

accommodations

36

Documentation of Accommodations ProvidedWhen special dietary needs are accommodated, SFA’s must maintain documentation to support that appropriate accommodations were provided as required.

Records Production records Invoices Procurement records Food usage records Any other applicable records

that documents the accommodations provided.


policy.

Frequency Annually Ongoing as needed.

Due Date/s- n/a

37

Sponsor Approval and Participation

Permanent AgreementThe agreement and any applicable attachments define the roles and responsibilities of SCN and the LEA in administering a school nutrition program (SNP). The permanent agreement stays in effect as long as the LEA operates a child nutrition program that is funded by USDA and administered by SCN. This form is completed during the application process.

Records Required for program

participation SCN permanent agreement

must be used.


policy. Required submission to SCN

Frequency With new application As needed when amended or

when updates required.

Due Date/s Prior to program

participation Ongoing for updates and

amendments.

AuditPer The Office of Management and Budget Circular No. A-133, Audits of States, Local Governments, and Non-Profit Organizations - Lea’s that expend $500,000 or more a year in federal awards are required to have a single or program-specific audit conducted.

Records Use of standard accounting

procedures required.


policy.

Frequency Annually

Due Date/s Within nine months of end

of the LEA’s accounting fiscal year

38

Policy Statement for Free and Reduced-Price MealsEach LEA participating in the NSLP or SBP must have an approved free and reduced price policy statement on file at the State agency. If an LEA is just starting its participation in the NSLP or SBP, the policy statement must be submitted to the State agency for approval as part of the application process. Once approved, the policy statement becomes a permanent document, but must be amended when the LEA makes a substantive change in its free and reduced price policy or as directed by the SA. The requirements for the policy statement and amendments are outlined in the Eligibility Manual for School Meals.

Records Use of program specific

form required Attachment documents Copy of the SA approved

policy Copies of approved updates.


policy. Required submission

through CNIPS

Frequency Review annually and submit

changes As part of program

participation application process

Due Date/s Review at the beginning of

each school year to ensure accuracy of all application materials, public release, applicable policies and procedures.

Changes must be approved by October 1st.

Online Application/Application Renewal SFAs must complete an online application in order to be approved for program participation and then complete an online renewal application annually. The information provided in the online application and renewal application are electronically maintained by the SA and is accessible to SFAs after the end of the program year. SFAs are not required to print off or save information provided in the online application. Any updates after approval during the program year will be maintained provided that SFA’s do not overwrite previous checklist documents uploaded. Once approved SFAs should “add new” rather than “modify” a previous checklist item submission.

Records All required information and

documentation to be submitted per program year.

Source documentation of information provided in sponsor and site applications.


policy. Required submission in

CNIPS with sponsor application

Required update in CNIPS as appropriate.

Frequency Update Annually Ongoing as needed Upon approval for program

participation

Due Date/s Annually Ongoing Prior to approval for program

participation.

39

Professional Standards and Kentucky One Certification

Child Nutrition Director Credentials (If hired after July 1, 2015)Documentation should be maintained to support that the CND has the required education and work experience as outlined in federal regulations. All CND’s must have completed 8 hours of food safety training within 5 years of hire or within 30 days after hire.

Records Copies of transcripts and

resume. Copy of completion of the

required food safety training.


policy.

Frequency As needed

Due Date/s Upon hire Proof of food safety training

within 40 days of hire if applicable.

Record of TrainingSFAs must maintain documentation of their compliance to the training requirements outlined in regulations and guidance. Records should clearly identify the name of employee, hire date, Title/position, a description of their duties/responsibilities, status (full time, part time, sub, etc.), and their professional standards category (Director, manager or staff). Documentation of training received should provide the informational elements provided on the USDA training tracker even if the USDA tracker is not utilized to record training related information.

Records Required for AR USDA training tracker or

alternate that provides the same information

List of all employees in SFA with corresponding information

Documentation of training received such as agendas, sign in sheets, certificates, etc.


policy.



40

Kentucky One CertificationIndividuals working in child nutrition programs are required to obtain level 1 certification within 40 days of hire.

Records Certificate of completion List of new employees

certified annually.


policy. Certificates maintained with

training tracker documentation.

Frequency Upon hire- Annually

Due Date/s- Within 40 days of hire

Level 2 Certification/ SNS CredentialThe Child Nutrition Director, or the individual identified as the menu planner for the LEA if not the Child Nutrition Director, must obtain SNA Level 2 Certification or SNS credential within three (3) years of hire.

Records Copy of certificate or

credential.


policy.

Frequency Once

Due Date/s Within three (3) years of

hire.

Kentucky One TrainerLevel 1 certification can only be provided by an individual certified as a Kentucky One Trainer. SFA’s must maintain documentation that the Kentucky One training was provided by a certified trainer.

Records Copy of the training

certificate from trainer.


policy.

Frequency Annually


41

Smart Snacks

Smart Snacks Calculator Compliance Reports with corresponding invoices and nutrition labels of a la carte items offered by the Child Nutrition ProgramSFAs must maintain documentation that the food and beverage items they sell a la carte meet smart snacks and competitive food requirements.

Records Alliance Smart Snacks

Calculator reports Invoices Nutrition Labels Recipes


policy.

Frequency Ongoing

Due Date/s Upon selling items a la carte.

Smart Snacks Calculator Compliance Reports with corresponding invoices and nutrition labels for food items offered by others outside of the Child Nutrition ProgramLEAs must maintain documentation that the food and beverage items sold to students outside of the Child Nutrition Program meet smart snacks and competitive food requirements.

Records Alliance Smart Snacks

Calculator reports Invoices Nutrition Labels Recipes


policy.

Frequency Ongoing

Due Date/s Upon selling items a la carte

42

Other Records

WaiversFNS will allow SAs to approve waivers related to program requirements as they determine there is a need for flexibility. The availability and the submission and approval requirements for waivers will be announced through SCN’s communication channels. Documentation related to waivers approved by the State Agency must be maintained by the SFA. (Example: Whole Grain Rich Waiver)

Records Waiver approval submission. Supporting documentation

when approval based upon set criteria.


policy. Submit to the SA as directed

in announcement.



ReportingSFAs must maintain documentation to support any information or data reported to the State Agency. This applies to any of the established annual reporting requirements as well as any other instance in which SFAs are directed to provide information or data to the SA. (Example: Site enrollment)

Records Any supporting

documentation used to provide the information or data reported


policy. Submit to the SA as directed


Due Date/s- As applicable- Per SCN announcement

43

Afterschool Snack Program

Onsite Monitoring Form SFAs must conduct monitoring of the afterschool snack services to monitor compliance to program regulations and promote effective program management.

Records Must use the monitoring

form on the SCN website.


policy.

Frequency Twice annually

Due Date/s First four weeks of operation

and again before the program ends for the school year.

Menu and Production RecordsSFAs must document that snacks are planned to meet meal pattern requirements. Production records must identify the food item, serving size, component contribution to the meal pattern and the quantities served to support the number of snacks claimed for reimbursement.

Records SA prototype production

record on the SCN website.


policy.

Frequency Each snack service

Due Date/s Each snack service.

Meal Counting and Claiming RecordsMeal count records must be maintained for each snack service that identifies the number of reimbursable snacks served to eligible children claimed for reimbursement.

Records Rosters or tally sheets Consolidation records


policy.

Frequency Per snack service Monthly cumulative

Due Date/s- Per Snack service- Monthly

44

Documentation of Area Eligibility and Program EligibilitySFAs should maintain documentation of the data used to determine area eligibility of the location of the snack service and of the program in which the snack service is utilized.

Records October Qualifying Data on

SCN website Information to support

eligibility of the program associated with the snack service.


policy

Frequency- Ongoing annually


45

Fresh Fruit and Vegetable Program

FFVP RecordsSFAs are required to maintain records related to the award of the grant, expenditure of funds and compliance with program requirements.

Records A copy of the application

and agreement. Monthly expenditure reports

and supporting documentation (invoices, receipts, etc.…)

Purchasing/Procurement information.

FFVP Production records on SCN website.

Documentation of activities on the Calendar of events on SCN website.

Financial tracking of grant funds.

Documentation of staff training on the FFVP.

FFVP Handbook Documentation of

community partner participation.


policy. Submit to SA when directed.

Frequency- Ongoing annually- Submit when directed to SA.

Due Date/s Annually apply for grant and

train staff. Monthly submit expenditure

reports. Ongoing documentation of

program activities.

Outreach SFAs are required to widely publicize within the school the availability of free fresh fruits and vegetables.

Records Copies of announcements Pictures of posters, etc.


policy

Frequency Ongoing

Due Date/s Ongoing

46

Seamless Summer Option

Site EligibilitySFAs must maintain documentation to determine a sites’ eligibility to operate as an open, closed enrolled or camp site in the SSO.

Records October Qualifying data Census Data Documents used to certify

children’s eligibility status (non-area eligible and camps)


policy.

Frequency Annually


Media ReleaseSFAs must notify households of the availability of meals. Information concerning the dates, location, meals and times should be included.

Records Copy of information

provided to media outlets List of media outlets the

information was provided to.


policy.

Frequency Annually


Procurement DocumentationSFAs must maintain procurement related documentation for the food and supplies used in providing meals through the SSO.

Records As outlined in approved

procurement plan.


policy.

Frequency Ongoing

Due Date/s- Ongoing

47

Daily Meal CountsSFAs must maintain a record of the number of meals served at each site for each approved service to support the number of reimbursable meals claimed.

Records SCN SSO Meal count form


policy.

Frequency Daily

Due Date/s- Daily

Monitoring FormsSFAs are required to monitor each site to ensure the meal service is provided in compliance with program requirements.

Records SCN SSO monitoring Form


policy.

Frequency Two times per site operation

Due Date/s- 1st within 1st week, 2nd within

4 weeks of site operation.

Planned Menus and Production RecordsSFAs must maintain the planned menus and production records for the meals produced and served to demonstrate that meal pattern requirements are met for the number of meals claimed for reimbursement.

Records State Prototype production

record or SA approved alternate


policy.

Frequency Daily

Due Date/s- Daily

Training RecordsSFAs must maintain documentation that SSO staff was trained on program requirements as it relates to their assigned duties and civil rights.

Records Agenda of training provided Sign in sheets of attendees Training materials used


policy.

Frequency- Annually

Due Date/s- Annually- Prior to start of program

48

Special Milk Program

Procurement, Inventory and Food Safety RecordsSFAs must maintain the invoices and inventory records of the milk served to children in the SMP. SFAs must also maintain food safety records to demonstrate safe handling of program milk.

Records Procurement documentation Invoices P.O.’s Receipts Inventory records Temperature logs


policy. Temp logs must be

maintained for six (6) months.

Frequency Ongoing

Due Date/s- n/a

Milk Count RecordsSFAs must maintain milk count records per meal service of the milks served to children and claimed for reimbursement.

Records Rosters Milk Count forms


policy.

Frequency Daily

Due Date/s- Daily

Free and Reduced Price ProcessSFAs operating a Special Milk with Free Option must maintain documents related to the household applications, media release and verification activities. The procedures outlined in the most recent Eligibility Manual for School Meals must be followed.

Records Household applications Media release List of media outlets release

was sent to Verification documentation Household letters and

communications.


policy. Submit media release to

media outlets.

Frequency Annually

Due Date/s- Annually- Media release at the

beginning of or prior to start of school year

49

Wellness PolicyLEAs are required to develop and implement a local wellness policy in each of the school/sites under their jurisdiction. A wellness committee should be formed to develop and implement wellness goals for the all schools within their jurisdiction. The LEA must annually evaluate goal achievement and update the policy as needed.

Records- Public Notification of the

wellness policy- Documentation of review and

updates to the policy- Method(s) used to notify

stakeholders of their ability to participate in the development, review, update and implementation of the policy.

- Assessment of implementation Method(s) of public

notification of the assessment results.


policy.

Frequency Review of policy yearly,

update as needed

Due Date/s- Annually- Ongoing

Staff TrainingStaff involved in the milk service must be provided training on program requirements including civil rights.

Records Agenda of training Sign in sheets Training materials used


policy.

Frequency Annually

Due Date/s- Prior to involvement in meal

service

50

Financial ManagementSMP funds must be tracked separately from all other funds within an organization. SFAs must maintain documentation to demonstrate compliance to this requirement.

Records Statement of Revenues with

supporting documentation for each entry

Statement of Expenses with supporting documentation of each entry

Balance Sheet


policy.

Frequency Ongoing

Due Date/s- n/a

Civil RightsSFAs must follow the federal civil rights requirements as outlined in FNS Instruction 113-1. This includes establishing a civil rights complaint policy and procedure, providing accommodations and services for LEP households, accommodating special dietary needs and displaying an “And Justice for All “ poster in areas where there is a milk service provided.

Records Complaint policy/procedure

with tracking system of complaints received.

Documentation of services or accommodations provided for households with limited English proficiency.

Documentation related to special dietary needs including the accommodation request, and documentation of the accommodation provided.


policy.

Frequency Ongoing

Due Date/s- Upon approval to participate

in SMP- Ongoing

51

Sponsor approval and participationThe permanent agreement and any applicable attachments must be maintained as well as any other records pertaining to program participation approval. SFA’s must complete an online application in order to be approved to participate in the SMP. An online renewal application is completed on an annual basis in order to continue participation. The information in the online application will be saved and accessible to SFA’s after the end of the program year.

Records Permanent Agreement Policy Statement and any

applicable attachments Online

application/renewal application


policy. Permanent agreement

submitted to the SA. Policy Statement and

online application/renewal application is submitted through CNIPS.

Frequency Upon approval Annually

Due Date/s- Approval by December

31st or June 30th.- Annual renewal by June

30th.

52