New Administrative Review Process What to Expect?

New Administrative Review Process What to Expect?

Wyoming Department of EducationJune 2013Terry Walling ~ Tamra Jackson

Welcome. Introductions. Housekeeping. Attachments. Recorded to post of DE web site.

1Reinvention GoalsThe Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review processConsolidate the Administrative Review processIncorporate school breakfast, the new meal pattern, and dietary specifications, and the 6-cent performance-based reimbursementWyoming Department of Education2We have always consolidated the Administrative Review process. Most states did a Coordinated Review Effort and a 2Reinvention GoalsImplement a 3-yr review cycleProvide for offsite monitoring approachesProvide effective training and ongoing technical assistanceWyoming Department of Education3I run six-to-eight miles a day, plus weights and aerobics in the lunch hour. I also lie a lot, which keeps me thin. Hugh LaurieRevamped ResourcesNew process uses tools and forms designed to be: ModularEfficientFlexibleEffectiveCollaborativeWyoming Department of Education4

Maximizing ResourcesWyoming Department of Education5CRE ApproachNew ApproachPrimarily Conducted On-SiteProcess structured to be conducted off-site and on-site:Off-site Assessment ToolRisk Assessment ToolsNew Approach allows for: Office staff assistanceApplication of risk indicatorsBetter balanced workload and preparationMore on-site technical assistanceThe New ProcessWyoming Department of Education6It is very important that you complete the CNP on line off-site assessment tool by the deadline given. We are lucky that we have the on line system you wont have to mail 100 sheets of paper to Cheyenne.6Off-Site ComponentsAdvantagesFlexibilityUse of specialized staffReduced staff timeOff-site monitoring toolsOff-site Assessment Tool (SFA and SA)Compliance Risk Assessment Tool (SA)Dietary Specifications Assessment Tool (SA)Resource Management Risk Indicator Tool (SA)Wyoming Department of Education7Off-Site Assessment ToolIncludes questions on a number of monitoring areas and is intended for completion prior to the on-site visitFeedback from USDA testing: Tool encourages SA and SFA to work collaboratively and helps shift the process toward the goal of combining compliance/monitoring with technical assistanceSFA has more time to provide information to the SA, and also will better understand why they are providing that informationSA has more time to review documents thoroughly, conduct reviews more consistently, and provide ongoing technical assistance to the SFAWyoming Department of Education8Off-Site Assessment ToolReview a section of the Off-Site Assessment Tool with the classWalk them through some questions and discuss/give examples of how they might answer the question. Note the ordering of the questionsWyoming Department of Education9Off-Site Monitoring ToolsMeal Compliance Risk Assessment ToolTargets error-prone areas of the new meal patternDetermines which site is selected for an in-depth menu reviewDietary Specifications Assessment ToolAssesses food service practices to determine risk for not meeting the Dietary SpecificationsResource Management Risk Indicator ToolIdentifies whether the SFA should receive a comprehensive resource management reviewWyoming Department of Education10Important: Any failure, whether by the SFA or SA, to adhere to the timeframes prescribed above requires a Resource Management comprehensive review to be conducted.10Performance StandardsCritical AreasPerformance Standard 1 Certification and Benefit IssuanceMeal Counting and ClaimingPerformance Standard 2Meal Components & QuantitiesWyoming Department of Education11

Performance StandardsGeneral AreasResource ManagementGeneral Program ComplianceVerification

Wyoming Department of Education12

Review PeriodMost recent month claim submitted, must include > 10 operating daysPeriod of On-Site reviewSpecial CircumstancesReviews early in the school yearYear-round, multi-track & provision schoolsMay require FNS approval or special procedures

Wyoming Department of Education13This slide needs some more creative beefing-up!8/7/201313Pre-Visit ProceduresNotify superintendent and food service directorInitiate Off-Site Assessment ToolReview SFA documentationObtain pre-visit informationSelect NSLP sites for reviewWyoming Department of Education14

On-site Review ProceduresEntrance ConferenceOn-site ReviewExit ConferenceWyoming Department of Education15

Review Frequency & ScheduleReview FrequencySFA must be reviewed every 3 yearsCycle begins July 1, 2013Review ScheduleSA discretionPostponed reviewsNon-compliant SFAsWyoming Department of Education16

Data for Site SelectionSite nameSite typeNumber of serving daysNumber of eligible for free mealsNumber of free meals claimedWyoming Department of Education17

Minimum Number of Review Sites# of Sites in the SFAMinimum # of Sites to Review for NSLP# Sites in SFAMinimum # of Sites to Review for NSLP1 to 5141 to 6066 to 10261 to 80811 to 20381 to 1001021 to 404101 or More12** 12 plus 5 percent of the number of sites over 100. Fractions must be rounded to the nearest whole numberWyoming Department of Education18Review all sites (except RCCI) with free ADP of 100 and free participation factor of 100%Criteria for Additional SitesAdditional NSLP sites: Elementary sites with 100 free ADP and 97% free participationCombination sites with 100 free ADP and 87% free participationSecondary sites with 100 free ADP and 77% free participationState Agency CriteriaWyoming Department of Education19Additional Site Selection RequirementsDietary Specifications and Nutrient AnalysisMeal Compliance Risk Assessment ToolSchool Breakfast Program50% of selected NSLP sitesOther Federal Program ReviewsVaries based on regulationsResource ManagementOffsite Assessment ToolWyoming Department of Education20

Other Federal Programs Afterschool Care Snacks, FFVP20Wyoming Department of Education21Meal Access & ReimbursementNutritional Quality & Meal PatternResource ManagementGeneral Program ComplianceOther Federal Program ReviewsCertification & Benefit IssuanceDietary Specs & Nutrient AnalysisRisk AssessmentCivil RightsAfter-school SnacksVerificationMeal Components & QuantitiesNonprofit School Food Service AccountSFA On-site MonitoringSeamless Summer OptionMeal Counting & ClaimingOffer versus Serve

Revenue from Non-program foodsLocal Wellness PolicyFresh Fruit & Vegetable ProgramPaid Lunch EquityCompetitive FoodsSpecial Milk ProgramWaterFood SafetySBP & SSO OutreachNew Administrative Review StructureIf you provide After-school snacks and/or the Fresh Fruit and Vegetable Program I will be observing those services. If you have the Special Milk Program and there are red flags on the off-site assessment, I will also observe that program.21Access and ReimbursementCertification & Benefit Issuance VerificationMeal Counting and ClaimingWyoming Department of Education22Why Review?Wyoming Department of Education23Off-site AssessmentCertification and Benefit IssuanceQuestion set 100sVerificationQuestion set 200sMeal Counting and ClaimingQuestion set 300sWyoming Department of Education24

Handout of forms24On-site AssessmentCertification and Benefit IssuanceValidate SFAs Procedures from off-site assessment toolValidate Student Certifications: Validate Benefit Issuance DocumentReview Denied ApplicationsVerificationDetermine compliance with Verification requirementsMeal counting and ClaimingValidate off-site assessment toolValidate the counting and claiming processRecord errorsWyoming Department of Education25Fiscal ActionCertification and Benefit Issuance. Why is Fiscal Action taken? Applications missing informationMis-categorization of certificationBenefit Issuance ErrorsFailure to update verified applicationsVerificationNo fiscal action takenMeal Counting and ClaimingInaccurate meal counting or claimingCounting errors include: meal counts to not equal number of meals served to eligible students, second meals were counted, meal counts exceed number of eligible students by category

Wyoming Department of Education26USDA ME we were dinged because we have not taken fiscal action. 26Meal Pattern & Nutritional QualityMeal Components & QuantitiesOffer vs. ServeDietary Specifications & Nutrient AnalysisWyoming Department of Education27Why do we review Meal Components & QuantitiesSupport Learning & Educational AchievementProvide students with well-balanced mealsCombat childhood hungerNutrition EducationTeach students components of a well-balanced meal, varietyStewardship of Federal $Ensure that meals reimbursed with Federal $$ contain required componentsWyoming Department of Education28OverviewReviewer 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; andRecords for reimbursement only meals that contain required components in required quantitiesWyoming Department of Education29Meal Components & QuantitiesAssess meal pattern complianceMilk, Vegetable subgroups, whole grain rich requirements, etcReview breakfast and lunch documentation for complianceMenus/production recordsPerformance-based reimbursement documentation (USDA worksheets)Week must be 3-7 consecutive daysMissing meal components/insufficient quantities: expand documentation review to (at least) entire review periodWyoming Department of Education30Pre-visit Documentation ReviewProduction RecordsBy meal service line and age/grade group servedSupport claimsDocument what was served and leftoversFood is creditable for portions servedDocument that daily and weekly meal component requirements are metIdentify if seconds are offered regularlyWyoming Department of Education31Talk to them about meeting deadlines is there a for lack of better word punishment?31On-site Meal Service ObservationPrior to Meal ServiceWill ensure all reimbursable meal lines offer all required componentsWill observe meal preparationDuring the Meal ServiceWill observe % of meal service for each lineWill determine if meal contain components & quantities for age/grade groupWill ensure students have access to, and know how to select a reimbursable mealWyoming Department of Education32Offer vs. ServeThe WDE Child Nutrition Programs 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; andFood 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.Wyoming Department of Education33OVS: Pre-visit: Documentation ReviewReview OVS PolicyOptional OVS Edit Check

Total # of Food Components or Food Items Total # of Meals servedWyoming Department of Education34

Optional OVS Edit check?34OVS: On-site: Prior to Meal ServiceWDE CNP Determines whether: Staff training has been conductedStaff understands what constitutes a reimbursable meal; Staff understands the number of required meal components/food items for a reimbursable meal; Staff properly distinguish reimbursable meals from a la carte purchases; and, Signage has been posted explaining OVS to studentsWyoming Department of Education35OVS: On-site: Meal Service ObservationWDE CNP Determines whether:Meals selected by students contain a minimum of 3 food components (NSLP) or food items (SBP) as the students exit the meal service line; Each reimbursable meal contains at least cup of fruits or vegetables; Food service staff are accurately judging quantities when the school utilizes service stations, theme bars, and/or self-serve bars; Students understand OVS; and Food service staff/cashiers understand OVSWyoming Department of Education36Dietary Specifications & Nutrient Analysis - OverviewDetermine if SFA is serving reimbursable meals according to Dietary SpecificationsCaloriesSaturated FatSodiumTrans FatDetermine if a one week weighted nutrient analysis is required for each USDA established age/grade group and menu type offered at a lunch and breakfast for one site in the SFAWyoming Department of Education37Resource ManagementMaintenance of the nonprofit school food service accountRevenue from non-program foodsIndirect costsUSDA FoodsWyoming Department of Education38Off-site Assessment ToolResource Management: Question set 700sMaintenance of Nonprofit School Food Service AccountQuestions 702 706 Paid Lunch Equity (PLE)Questions 707 710Revenue from Non-program FoodsQuestions 711 712Indirect CostsQuestions713 714USDA FoodsQuestions 715 - 717

Wyoming Department of Education39Distribute handouts of forms

Information for Bullets 1-4, will be compared to Susans records.39Resource Management Risk Indicator ToolState Agency conducts a risk assessment based on off-site assessment tool 1-2 risk indicators Technical Assistance and Corrective Action3 + risk indicators USDA Comprehensive ReviewAll Resource Management monitoring areasState agencies to consult with State USDA foods staffWyoming Department of Education40General Program ComplianceCivil RightsLocal Wellness PolicyFood SafetyWyoming Department of Education41Off-site Assessment Tool: Section VCivil RightsQuestion set 800sSFA On-site MonitoringQuestion set 900sLocal School Wellness PolicyQuestion set 1000sSchool Breakfast and Summer Food Service Program OutreachQuestion set 1600sWyoming Department of Education42Food SafetyGeneral areas of reviewWritten food safety planFood safety inspectionsRecordkeepingStorageState Agency to determine if regulatory requirements are being metCorrective ActionEach area assessed at the site levelIf all schools compliant, SFA compliantCorrective action prescribed as necessaryWyoming Department of Education43Civil Rights Scope of ReviewOff-site AssessmentSA obtains SFA responses to the Off-site ToolIf necessary, clarification providedIf noncompliant, the SA provides TA and if necessary, prescribes corrective actionOn-site AssessmentIf necessary, validate CA on-site if non-compliance is detected by Off-Site Assessment ToolEnsure the USDA And Justice for All Poster is displayed in a prominent location and visible to program studentsDuring meal observation on day of review, determine if all program students had equal access to the program without discriminationEnsure program materials contain correct non-discrimination statementDetermine if denied applications are disproportionately submitted by minority householdsWyoming Department of Education44Local Wellness PolicyHHFKA added new provisionsChanged content requirementsRequired certain actionsLWP portion of administrative review changed to address HHFKA and FNS Memo SP 42-2011Deficiencies handled through TA onlyNo final ruleLimited implementation guidanceAssess progress and provide implementation suggestionsNo LWP = Corrective ActionComplete Off-site Assessment tool questionsWyoming Department of Education45General Program ReviewsFresh Fruit and Vegetable ProgramAfterschool Snack ProgramWyoming Department of Education46Off-site Assessment Tool: Section VIOther Federal ProgramsIndication of any additional federal programs that will be examined during the reviewAfterschool Snack ProgramFresh Fruit and Vegetable ProgramSpecial Milk ProgramWyoming Department of Education47FFVP ReviewThree components to the FFVP review processEstablishing the FFVP review sample size (WDE)Claim validationOne months claim is validated per siteAny month can be selectedCheck status of administrative costsFFVP meal service observationOccurs at each FFVP siteFiscal Action must be used to recover any payments in whole or in part, that is inconsistent with FFVP requirementsWyoming Department of Education48Afterschool Snack Program: Evaluating ComplianceReviewer will:Determine if SFA retains final administrative and management responsibility for meeting all afterschool snack requirementsAssess compliance in the following areas: EligibilityAccountability/Meal Counting and ClaimingMeal Pattern/Production RecordsMonitoringGeneral AreasWyoming Department of Education49Post Review ActivitiesWyoming Department of Education50Post Review ProceduresAdministrative Review Exit Conference

Administrative Review Report (i.e., Notification Letter of Review Results

Documented Corrective Action

Wyoming Department of Education51Intent/ScopeCorrective Action PlanDocumented Corrective ActionFiscal ActionReview FindingsCorrective Action/CAPTimeframesFiscal ActionIntent/ScopeDocumented CA/Written NotificationTimeframesWyoming Department of Education52Thank You!!Questions?