child nutrition programs 101

Office of School Nutrition

Presenters:Jane Brand, RD, SNS Director

Jennifer Otey, BA Senior ConsultantCSNA Fall Conference 2012


Objectives

To provide an overview of the Federal Child Nutrition Programs & their administration and structure

To create an understanding of what is expected of those operating the Child Nutrition Programs

To answer questions about the operation of the Child Nutrition Programs


USDAOrganizational

Chart


Six Directors,i.e. , Inspector General

Under Secretary for Natural Resources and Environment

Under Secretary for Farm and Foreign Agricultural Services Under Secretary for Rural Development

Under Secretary for Food Safety Under Secretary for Research, Education and Economics

Under Secretary for Marketing and Regulatory Reforms

Under Secretary for Food, Nutrition, and Consumer Services, Dr. Janey Thornton

Deputy Secretary

Secretary of Agriculture,Thomas J. Vilsack

President of the United States,Barack Obama


FNS Regional Offices

WesternRegion

Mountain Plains Region

SouthwestRegion

MidwestRegion

SoutheastRegion

Mid AtlanticRegion

NortheastRegion


Administrative Flow

Schools

School Food Authorities

State Agencies

FNS HeadquartersAlexandria, VA

FNS Regions


State of Colorado and School Nutrition Programs

Administered by Colorado Dept of Education (CDE) Office of School Nutrition (OSN) CDE OSN administers school district and charter school

SFAs and RCCIs

School Food Authority: a governing body responsible for one or more schools and has the legal authority to operate the Program


Office of School Nutrition (OSN)

Provides oversight and management of Colorado School Nutrition Programs

SUCH AS: Pay reimbursement/manage claimsProvide technical assistance and trainingReview the operation of all public school,

charter school, and RCCI SFAs


School Nutrition Programs

National School Lunch

Program

Afterschool Care Snack

Program

Fresh Fruit and Vegetable

Program

School Breakfast Program

Summer Food Service Program

Special Milk Program


Big Picture: How We Work

SFAs receive reimbursement and continue to feed children

CDE OSN reimburses SFA claims

SFA enters into agreement with CDE

CDE OSN receives annual funding

Congress appropriates funds


Regulatory Process


Regulatory Process

Regulations change because: A law is passed amending the NSLA Other updates - i.e., meal pattern changes

Proposed Rule - published for comments, not to be implemented

Evaluate comments - read/consider comments Final or Interim Regulation – implemented

(comments taken on Interim Regulation) Notices – announce routine updates


210The National School Lunch Program

Regulations


http://www.fns.usda.gov/cnd/governance/regulations.htm





National School Lunch Program - Agreement


Non-profit Food ServiceMAINTAIN A NON-PROFIT SCHOOL FOOD SERVICE

AND OBSERVE THE LIMITATIONS…ON FOOD SERVICE REVENUES IN SEC. 210.14(A) AND

LIMITATIONS ON COMPETITIVE FOOD SERVICE AS SET FORTH IN 210.11(B)

Food Service Funds may be used only for program expenses or program improvements

Accounting procedures must accurately record all revenues and expenditures in the Child Nutrition Program (Fund 51)


Limit Cash Resources

LIMIT NET CASH RESOURCES TO 3 MONTHS’ AVERAGE OPERATING EXPENSES, OR

HIGHER IF APPROVED BY STATE

If over 3 months operating expenses: oConsider food qualityoOther improvementso State can lower reimbursements


Financial Viability: Break Even

Total expenditures/revenue must break even or have a positive balance

Negative balance must be brought up to “0” by a transfer from the general fund

Positive cash balance carried over cannot exceed 3 months’ operating expenses (Notification from CDE)


Paid Lunch Equity (PLE)

Sufficient funds must go to the food service account for paid lunches Involves pricing of ala carte, adult meals, and paid

student lunches Compliant if current paid student lunch price is

>$2.51 OR if nonfederal funds are provided PLE Lunch Pricing Tool located at CDE Website


Non-Program Food Revenue

Percentage of revenues of non-program foods (a la cart, beverages, etc.) Must be at least equal to the % of the cost of

that food Must stay in the non-profit food service

account

Track non-program food revenue separately from all other revenue items


Procurement (Purchasing)

ALL PURCHASES IN SCHOOL NUTRITION PROGRAMS MUST FOLLOW USDA REQUIREMENT

FOR “FREE AND OPEN COMPETITION”

Small purchase procedures depend on the size of the purchase

Federal limit of $100,000 requires a formal bid process

District small purchase threshold requires formal bid process

Include a “Buy American” clause in all bids


Free or Reduced Price Lunches

Serve lunches free or at a reduced price to all children who are determined eligible under 7 CFR 245 --determining eligibility for free and reduced

price meals

This is to ensure that schools provide for children from qualifying households.

It also requires that the same meals be made available to all children.


Meal ServiceServe lunches, during the lunch period, which meet the minimum requirements

prescribed in § 210.10

The lunch period is between 10:00 a.m. - 2:00 p.m.

§ 210.10 describes the minimum nutrition requirements that must be met by the lunches


Point of Service Counts

Count meals where you can accurately determine: o If the meal meets nutritional

requirementso The eligibility status of the

child

Count the number of free, reduced price, and paid reimbursable meals served to eligible children at the point of service, or through another system approved by the state


Nondiscrimination

Comply with requirements of the Department’s regulations regarding nondiscrimination 7 CFR parts 15, 15a and 15b FNS 113 – 6 (replaced by FNS 113-1)

SFA will not discriminate on the basis of race, color, national origin, sex, age, or disability


Civil Rights Requirements

Public Release“And Justice For All …” posterSpecial Needs/ Special DietsAnnual training


Public Release Required to submit to local media -

but not required to pay Prototype in the F&R Packet Keep copies: where, when, and what

is sent Send to:

o Community/grassroots organizations o Local employers reducing hours or

planning layoffs, etc.


“And Justice for All”

All schools must display

the most current “And

Justice for All” poster:

In each school In a location that is

easily visible to students and the public in the food service area


Special Dietary Needs

Disability: Meal accommodations are required for children with disabilities at no additional charge when documented by a licensed physician

Non-disability:Substitutions may be made but are not required for children who are medically certified as having a special medical or dietary need with a note on file from a recognized medical authority

Information on CDE Nutrition Website


Civil Rights Training

Required annually for “front line” school staff and supervisors

Training will be verified during reviews Questions should be directed to the CDE OSN

All staff involved in all levels of the administration of FNS programs must receive

training in order to understand civil rights laws, regulations, procedures, and

directives to assist them in performing good customer service and avoiding

complaints.


Overt Identification

Make no discrimination against any child because of his or her eligibility for free or reduced price meals in accordance with the approved policy statement

SFA will not overtly identify students based upon their eligibility status


Food Distribution and Donated Goods

Enter into an agreement to receive donated foods as required by 7 CFR 250

Part 250 Food Distribution

Regulations

Food Distribution Programs

Accept and use, as much as possible, foods donated by the Department

Encourage the domestic consumption of agricultural products

http://www.fns.usda.gov/fdd/


Maintain Facilities

Ensures proper maintenance of facilities to safeguard against theft, spoilage, or other loss

Maintain necessary facilities for storing, preparing, and serving food

Sec.210.13(c)


Sanitation and Health

Maintain proper sanitation and health standards in conformance with all applicable state and local laws and regulations• Comply with the food

safety inspection requirement of sec. 210.13(b);

Obtain two food safety inspections per year

Develop food safety program/HACCP


Retain Eligibility Records

Retain each household’s application for free and reduced price meals

Keep applications & Direct Certification match reports for at least 3 years + current

Complete Direct Certification at least 3 times per school year

Distribute meal benefit applications Notify parents of student eligibility Conduct Verification


Make Records Available

Records are available for audit or review at a reasonable time and place

Upon request, make all accounts and records pertaining to school food service available to the state and FNSKeep records for at least 3 years + current


Claim Reimbursement

SFA official takes responsibility for accurate claims

Claim reimbursement at assigned rates. The SFA official signing the claim is responsible for review

and analysis for accuracy. Failure may result in withholding, suspension, or

termination


210.8 Claims for Reimbursement

On-site visit - counting & claiming before Feb 1 (if more than 1 serving site in the SFA)

Claims review process– Edit checks: AF x the number eligible, F/R/P

Follow-up - fix the problems Recordkeeping – keep

claims at least 3 years + current File claims monthly


OSN Online Claim System - Applications

Each year before claims can be entered, the claim system must be set up by SFAs (site and sponsor applications and required forms) – Afterschool Care Snack Program - apply using the claim system – Special Milk Program - apply using the claim system

CDE OSN will approve the application packet once everything in the claim system is correct and the following have been completed: – Annual Free and Reduced Training – Direct Certification – Paid Lunch Equity Tool


OSN Online Claim System - Claims

Once the application packet is approved, claims can be entered on a site basis

Claim system is currently comprised of Lunch (including the PK-2 Reduced Lunch Program), Breakfast (including Start Smart), Afterschool Snack, & Special Milk

Claims are due 60 days after the end of the claim month

The OSN makes payments twice per month


OSN Online Claim System – Further Information System will eventually also include Food Safety Inspection Reports,

Certification, Fresh Fruit & Vegetable Program, Summer Food Service Program, Direct Certification, Verification, Administrative Reviews - for a "one-stop shop" for reporting to the OSN

Critical Information is posted at http://www.cde.state.co.us/cdenutritran/nutriprogramrenewal.htm – Link to claim system – Renewal Overview (for beginning of the year requirements) – Simplified Step-by-Step Instructions for Applying – How-to Steps to Upload Forms in the System – Steps for Revising Online Applications – Claiming Instructions

For questions, please contact Jennifer at [email protected]

http://www.cde.state.co.us/cdenutritran/nutriprogramrenewal.htm

mailto:[email protected]


A Brief Overview of NSLP Nutrition

Standards


Participating schools must follow the nutritional guidelines set forth by USDA

Meals patterns follow the Dietary Guidelines for Americans

Nutrition Standards


Food-Based Menu Planning1)

Frui

t

2) V

eget

able

s

3) G

rain

s

4) M

eat/M

eat A

ltern

ates

(P

rote

in)

5) M

ilk (D

airy

)

5 components


Breakfast

Component K-12

Fruit or Vegetable ½ c Grains + Grain 1 oz + 1 oz

Meat/Meat Alternate 1 oz + 1 ozGrain + Meat/Meat Alternate 1 oz

Milk 1 c *Meal patterns changing for school year 2013 – 2014*


Lunch

Component K-5 6-8 9-12

Fruits ½ c ½ c 1 cVegetables ¾ c ¾ c 1 c

Grains 1 oz 1 oz 2 oz

Meat/Meat Alternates 1 oz 1 oz 2 oz

Milk 1 c 1 c 1 c

Offer at least one serving each


Competitive foods are those foods sold in competition with the reimbursable meal during lunch periods

Part 210 prohibits the sale of Foods of Minimal Nutritional Value infood service areas during thelunch period

Specific list of foods Found in Appendix B

of 7 CFR 210

Competitive Foods


Milk and Substitutes

Non-disability: Milk substitutes (Ex: soy milk) may NOT be

counted in a reimbursable meal if they do not meet the USDA Nutrient Standards, including fat content. SFA NOT required to provide for non-disability reasons

Disability: Physician statement must identify substitution. SFA MUST provide substitute at no cost to the student.


OVS - General RulesStudents need to take at

least 3 componentso One must be ½ cup Fruit or

VegetableRequired in high school

luncho Optional K-8

Optional for all grade levels for breakfast


Production Records Required for program compliance

CDE reviews adequate food is prepared

Management toolHow much to plan?What should staff prepare? How much?

Evaluation toolTrends: Popular? Tried it 20x? Forget it?Throwing away food and money?

50


Sample Production Record


Wellness Policies

Objective: Promote student health and reduce childhood obesity

Goals: Nutrition education Physical activity School based activities that promote wellness

Nutrition guidelines for Reimbursable meals All food sold on campus during school day


Wellness Guidelines

Encourage involvement from PE teachers, school health, and the community

Inform and update the public

Review, evaluate, and update policy regularly

Stakeholders must participate in implementation of plan

*CDE Website for Resources*

FNS Wellness Policy Information

http://www.fns.usda.gov/tn/healthy/wellnesspolicy.html


Colorado Healthy Beverage Rules 1 CCR 301-79: Beverages sold to

Students on school grounds during regular/extended school day must meet nutritional standards.

– Extended school day includes before/after school activities

– Includes: school cafeterias, vending machines, school stores, fund-raising activities, on school campuses, etc.


Bottled Water

Unflavored Milk

Flavored Milk

100% Juice No/Lo- Cal

Bevs*

Other

Elementary ≤8oz ≤8oz<150 cal/8oz

≤8oz<150 cal/8oz

X X

Middle ≤10oz ≤10oz<150 cal/8oz

≤10oz≤120 cal/8oz

X X

High School ≤12oz ≤12oz

<150 cal/8oz≤12oz

≤120cal/8oz<10

cal/8oz≤66

cal/8oz

*Diet soda is not allowed

Colorado Healthy Beverage Rules


Water Availability

Water must be easily accessible to students without restriction at no

charge

Available in or adjacent to the meal service areas


Free and Reduced Price

Meals: A Brief Overview


Income Eligibility GuidelinesUsed to determine eligibility for free or reduced price meals

FNS makes these calculations based upon the federal poverty guidelines as determined by the Department of Health and Human Services

To Determine Eligibility Status: Household Application

‾ Income eligibility‾ Categorical eligibility

Direct Certification


Direct Certification

Easier for households and schools Increases participation Enhances accuracy of the

certification process Not part of verification Online CDE-OSN training and

resources available on webpage

Direct Certification confirms a child’s categorical eligibility for free school meals through his or her SNAP or FDPIR participation, without the need for

a household application.


The Verification Process

By law, a sample of applications must be verified (3% of all verification-eligible applications) Income applications Categorical eligibility

Directly certified households not subject to verification

Online training on CDE OSN webpage

Verification is the confirmation of eligibilityfor free and reduced price meals under the

NSLP and SBP.


The materials and tools to help guide your program down the road of success

RESOURCES


Reference Guide– Questions & concerns– Available on CDE Website

http://www.cde.state.co.us/cdenutritran/

nutriadministrators.htm


Reference for federal requirements to:

Determine Verify Disclose (or not!)Student eligibility for

free and reduced price meals

(Available on CDE Website)


Tool to Determine:

How much to purchase

How much to prepare

Creditable Foods


OSN Webpage http://www.cde.state.co.us/cdenutritran/nutriprograms.htm


OSN Webpage


http://teamnutrition.usda.gov/

http://www.nfsmi.org/

http://www.fns.usda.gov/cnd/


Let’s practice navigating the OSN website!CDE OSN Website Activity

http://www.cde.state.co.us/index_nutrition.htm


CDE Monitoring

• Every 3 years• Focus = accountability; following federal

and state regulations? following appropriate program operations?

• More information to be released in the near future

• Overclaim could be assessed as a result of errors (i.e., inadequate records to support a claim for reimbursement)

Administrative Review


Reviews

Purchasing Food Safety Competitive

foods Commodities

Wellness Financial

Management Civil Rights Other Programs

Other Programs Special Milk Program (SMP) School Breakfast Program Afterschool Care Snack Program Fresh Fruit & Vegetable Program

Regulatory Evaluation of Operations


In Summary: USDA Child Nutrition Programs

Reimbursement is claimed by SFAs that meet regulations and:

1.Serve reimbursable meals/snacks to students

2.Record reimbursable meal/snack content

3.Record who receives the meal/snack

4.Claim meals/snacks by eligibility status of

students who receive them

http://teamnutrition.usda.gov/


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child nutrition programs 101

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