School Nutrition Program (SNP) Administrative Review Process

The School Nutrition Program (SNP) Administrative Review Process is a vital aspect of ensuring compliance with National School Lunch Program (NSLP) and School Breakfast Program (SBP) requirements. This process involves assessing critical areas of review and general accountability to maintain program integrity. Participants will learn about the purpose, frequency, components, communication, deadlines, assessments, and activities related to the Administrative Review. The scope encompasses a unified accountability system overseen by the Pennsylvania Department of Education to support School Food Authorities (SFAs).

• School Nutrition Program
• Administrative Review
• Compliance
• Accountability
• National School Lunch Program

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1. School Nutrition Program (SNP) Administrative Review Process Begin Course Click Arrow to Begin Home Button Found on each page. Selecting the Home button returns you to this page. Home button returns you to this page. Home button returns you to this page. Home button returns you to this page. Home Button Found on each page. Selecting the Found on each page. Selecting the Found on each page. Selecting the Home Button Home Button Shortcut Buttons These buttons link to major sections of this course. Double-Click to navigate. H Topic 3 Topic 2 Topic 4 Topic 5 Topic 6 Topic 8 Topic 9 Topic 10 Topic 11 Topic 12 Topic 13 Topic 1 Topic 7 Topic 3 Topic 2 Topic 4 Topic 5 Topic 6 Topic 8 Topic 9 Topic 10 Topic 11 Topic 12 Topic 13 Topic 1 Topic 7 Topic 14 Topic 15 Topic 16 Topic 17 Topic 18 Topic 26 Topic 19 Topic 20 Topic 24 Topic 25 Topic 21 Topic 22 Topic 23 Topic 14 Topic 15 Topic 16 Topic 17 Topic 18 Topic 26 Topic 19 Topic 20 Topic 24 Topic 25 Topic 21 Topic 22 Topic 23

2. School Nutrition Program (SNP) Administrative Review Process N NAVIGATION AVIGATION School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Navigation is pretty basic. Back Button, Forward Button, and Home Button. Forward Button Back Button Found on each page. Selecting the Back button returns you to the previous page. Found on each page. Selecting the Forward button advances you to the next page. Home Button Found on each page. Selecting the H H H H H H H H Home button returns you to the very beginning page. H H H H

3. School Nutrition Program (SNP) Administrative Review Process GOALSOFTHE ADMINISTRATIVE REVIEW Participants will: 1. State the purpose of Administrative Reviews. 2. State the frequency of reviews. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox 3. Name the two primary review components. Marketing School Meals Put Course Name Here Put Course Name Here 4. List the areas addressed under the two review components. 5. Describe the communication about the Administrative Review School Food Authorities will receive from the Pennsylvania Department of Education. 6. State the deadlines for submission of requested documentation and/or information. 7. Describe the expectations for the Off-site Assessment. 8. Explain how to access the Off-site Assessment. 9. Describe what will occur during the On-site Review. 10. Describe Post-review activities. H H H H H H H H H H H H 3

4. School Nutrition Program (SNP) Administrative Review Process TOPIC 1 | SCOPEOFTHE ADMINISTRATIVE REVIEW Background The Richard B. Russell National School Lunch Act, as amended by the Healthy Hunger-Free Kids Act of 2010 (HHFKA), requires a unified accountability system designed to ensure that participating School Food Authorities (SFAs) comply with National School Lunch Program (NSLP) and School Breakfast Program (SBP) requirements. The Act also requires an accountability system that conducts Administrative Reviews to evaluate Program requirements for NSLP and SBP during a five-year cycle. The Pennsylvania Department of Education (PDE), Division of Food and Nutrition (DFN) is responsible for conducting these reviews in Pennsylvania. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Scope of the Administrative Review The scope of the Administrative Review focuses on two primary review components: Critical Areas of Review and General Areas of Review. The Critical Areas of Review are Performance Standard 1 and Performance Standard 2: Performance Standard 1 focuses on the certification and benefit issuance process and the accuracy of meal counting and claiming. Performance Standard 2 focuses on whether meals claimed for reimbursement meet meal pattern and nutritional quality requirements. H H H H H H H H H H H H Continued on next slide. 4

5. School Nutrition Program (SNP) Administrative Review Process TOPIC 1 | SCOPEOFTHE ADMINISTRATIVE REVIEW Scope of the Administrative Review (continued) The General areas of review includes requirements for: Civil Rights School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Food Authority (SFA) On-site Monitoring Marketing School Meals Put Course Name Here Put Course Name Here Local School Wellness Policy Smart Snacks in School Professional Standards Serving Water Food Safety and Storage Requirements Buy American Reporting and Recordkeeping School Breakfast Program (SBP) and Summer Food Service Program (SFSP) Outreach Resource Management H H H H H H H H H H H H 5

6. School Nutrition Program (SNP) Administrative Review Process TOPIC 2 | COMMUNICATIONABOUTTHE ADMINISTRATIVE REVIEW All SFAs should have their PEARS Sponsor application up to date with the correct name and e-mail address of the Chief Administrator and the Primary Contact. The majority of the communication concerning the Administrative Review will be sent via email to the Chief Administrator and the Primary Contact. Administrative Review communications are not sent to the Food Service Director. In many SFAs, the Food Service Director is a Food Service Management Company (FSMC) employee. The SFA must always provide oversight over all aspects of the School Nutrition Program and therefore, only a SFA employee may assume responsibility for the Administrative Review. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here If the SFA employee in your district that is responsible for the Administrative Review is someone other than the Chief Administrator or the Primary Contact listed on your PEARS sponsor application, please inform him/her that communications will need to be forwarded to the appropriate SFA employee. You can expect to receive communications from a variety of PDE staff throughout the Administrative Review process. The first communication will be sent from the Harrisburg office. Additional communications will be sent by: Staff responsible for the review of the Resource Management which is conducted off-site Lead Reviewer-who is responsible for the review of the SFA response to the off-site questions and will also conduct the On-site Review Staff responsible for the review of the Local Wellness Policy which is conducted off-site Staff responsible for the review of Professional Standards which is also conducted off-site Staff responsible for review of Fresh Fruit and Vegetable Program (FFVP) H H H H H H H H H H H H Continued on next slide. 6

7. School Nutrition Program (SNP) Administrative Review Process TOPIC 2 | COMMUNICATIONABOUTTHE ADMINISTRATIVE REVIEW The Administrative Review Announcement Letter will be the first of several communications concerning the Administrative Review. Approximately 12 weeks prior to the month of the on-site review, the SFA Chief Administrator and the Primary Contact listed on the SFA PEARS application will receive the Administrative Review Announcement letter. The Announcement letter will identify: School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox The month of the on-site review Marketing School Meals Put Course Name Here Put Course Name Here The month of review or more commonly referred to as the test month Deadline for SFA to complete the off-site assessment which is approximately 6 weeks from the date the Announcement letter is sent You should expect to receive the first of several communications from Resource Management staff approximately two days after the Announcement letter from the Harrisburg Office. The email from the Resource Management staff will include: A list of the required documentation that must be attached to the Administrative Review Instructions for submitting the requested documentation Guidance concerning Non-program Foods and Indirect costs Reference to guidance that can be found on PEARS Download Forms for Equity in School Meals Pricing H H H H H H H H H H H H Continued on next slide. 7

8. School Nutrition Program (SNP) Administrative Review Process TOPIC 2 | COMMUNICATIONABOUTTHE ADMINISTRATIVE REVIEW Additional reminder emails will be sent by the Resource Management staff three weeks prior to the established deadline and again one week prior to the established deadline. Both the Announcement letter and each of the written communications that are sent by the Resource Management staff include a reminder that failure to complete ALL parts of the Off-Site assessment and submit all requested documentation will result in a Corrective Action and may result in Batch Hold. Additional communication throughout the Administrative Review will include an email that will be sent approximately 6 weeks after the Announcement letter. This email will identify: The specific buildings or buildings selected for meal observation during the On-site review (if SFA has more than one building) Request for a variety of documentation Established deadlines for submission List of documentation and information that will be required during the On-site review Approximately two weeks prior to the actual date of the on-site review, the Lead Reviewer will send an email indicating the exact date and time that he or she will arrive for the on-site portion of the Administrative Review. Therefore, if you know that the month of your On-site review is January and you have not received this email by mid December, chances are your on-site review is scheduled for the later part of January and you should expect to receive this communication sometime during the first or second week of January. This communication will identify: The specific date of the On-site review Time of arrival Specific meals that will be observed during the On-site review School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here NOTE: Administrative Reviews are scheduled months in advance and due to the considerable length of time allotted for off-site activities, the ability to reschedule is very limited. Rescheduling of the Administrative Review will be considered only in situations involving an emergency. H H H H H H H H H H H H 8

9. School Nutrition Program (SNP) Administrative Review Process TOPIC 3 | OFF-SITE ASSESSMENTAND ON-SITE REVIEW OVERVIEW The Administrative Review Process is designed to allow the State Agency to conduct specified aspects of the review off-site and other aspects on-site. The Off-site Assessment allows the State Agency to gain a better understanding of SFA operations prior to the on-site review, thus decreasing the State Agency s on-site review time. The State Agency s On-site Review is intended to validate the information collected on the Off-site Assessment and provide an opportunity for the State Agency to observe the operation of the school nutrition programs at the SFA and in selected schools. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Who at the SFA should be involved in completing the Off-site Assessment? Responsible SFA staff may include, but are not limited to: Chief Administrator and/or the School Principal Perhaps one or both of these people may need to address the Local Wellness Policy which is a district wide policy and not necessarily the responsibility of the Food Service Department. PEARS Primary Contact and/or the PEARS Claim Contact These employees may need to respond to questions concerning the procedures for submission of monthly claims. Business Manager or Fiscal Director These school employees are often responsible for the financial management aspect of the food service and will need to respond to questions Staff responsible for Direct Certification, Application processing, and Verification will need to provide information concerning the processes and procedures implemented by the SFA in these areas. The Food Service Director who has direct knowledge of the food service operation, menus and meal counting procedures. H H H H H H H H H H H H Continued on next slide. 9

10. School Nutrition Program (SNP) Administrative Review Process TOPIC 3 | OFF-SITE ASSESSMENTAND ON-SITE REVIEW OVERVIEW, PAGE 2 NOTE: FSMC employees may never have access to PEARS. SFA employees may never share their PEARS password with an FSMC employee or any other SFA employee. Any information during the Off-site Assessment that requires input from a FSMC employee must be entered into PEARS by the SFA employee who has direct oversight of the food service operations and of course has access to PEARS. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Ultimately, the SFA must have complete oversight of the School Nutrition Programs. There are numerous responsibilities that may not be assigned to a FSMC. Therefore, a SFA employee must respond to all questions as part of the Off-Site Assessment. The Administrative Review encompasses more than just the National School Lunch Program. The SFA must provide information during the Off-Site Assessment concerning the processes and procedures for each of the School Nutrition programs listed here: National School Lunch Program School Breakfast Program After School Snack Program Special Milk Program Fresh Fruit and Vegetable Program Seamless Summer Option H H H H H H H H H H H H Continued on next slide. 10

11. School Nutrition Program (SNP) Administrative Review Process TOPIC 3 | OFF-SITE ASSESSMENTAND ON-SITE REVIEW OVERVIEW, PAGE 3 After receiving the Announcement letter (12 weeks prior to the month of the on-site review) the SFA must complete the Off-site Assessment by answering questions related to a variety of process and procedures implemented by the SFA. In addition, several areas of the Off-site Assessment require the submission of documentation. All parts of the Off-Site Assessment and submission of all requested documentation must be completed by the deadline established in the initial Announcement letter. The deadline is approximately 6 weeks from the date the letter is sent. A reminder once again, failure to complete all aspects of the Off-Site Assessment will result in Corrective Action and may result in Batch Hold. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here After the 6-week deadline, various PDE, DFN staff will communicate with the SFA to review the responses to the off- site portion and if applicable, may request clarifying information and/or provide technical assistance. The Administrative review is no longer conducted exclusively by your assigned Field Service Advisor. A team of PDE staff from the Harrisburg office works along with the Lead Reviewer, more commonly referred to as the Field Advisor, to complete the Administrative review. After the State Agency staff has reviewed the responses entered by the SFA on the Off-site assessment, staff may contact the SFA to discuss specific questions, request clarification, obtain additional information or provide technical assistance. A variety of SFA staff may need to be available depending on the specific questions or clarification requested by the State Agency reviewers. In some limited situations, the SFA will be encouraged to implement Technical Assistance immediately in order to avoid a Corrective Action. The Administrative Review assesses school meal programs in 21 topic areas. Each Administrative Review monitoring area is assigned a unique number. The numbers are identified on all associated questions, forms and related material. The following sections of this module will describe each of these areas and identify if the review is part of the Off-site assessment, On-site Review, or both. H H H H H H H H H H H H 11

12. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET) The certification and benefit issuance process covers the SFA s certification of a student s eligibility for free or reduced-price meals and the link to the SFA s meal counting and claiming system. The State Agency s examination of certification and benefit issuance is essential to ensure eligible children receive meals to which they are entitled, and that Claims for Reimbursement are valid. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Off-site Assessment Marketing School Meals Put Course Name Here Put Course Name Here During the Off-site Assessment, the SFA must provide information concerning the process and procedures that are implemented to ensure certification is determined accurately and granted to all students at the Point of Service. Information must be provided about the following: Procedures for processing Household Applications and conducting Direct Certification Household notification of approval or denial Type of system used to determine applications and grant benefits to students (e.g. electronic, manual, or a combination) Names and titles of specific staff that have access to these systems Benefit Issuance List Generated from the Point of Sale All students with access to school meals (including pre-K or Head Start students) Generated on a day within the test month Must NOT include students enrolled in a Cyber-School, Technical school or learning environment that do not receive meals in the school building Must include the complete first and last name of all students certified for free and/or reduced-price students (NOTE: Do not include Paid Students) H H H H H H H H H H H H Continued on next slide. 12

13. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET), PAGE 2 Off-site Assessment Benefit Issuance List (continued) Must include the eligibility status for each student Must include the method of certification Must include the date of certification Must include the date of withdrawal or transfer (if applicable) Ensure that student names are not duplicated Ensure that student names are not grouped by benefits status. (may be alphabetical order, by building, by ID number, etc.) Do not include student Social Security numbers Do not include students in the paid category Submit Benefit Issuance list via an Excel spread sheet The Benefit Issuance List must be submitted via the PEARS Compliance Module (described later in this module) Must be submitted by the deadline established by the Lead Reviewer School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 13

14. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET), PAGE 3 Off-site Assessment (continued) For SFAs with 100 or fewer students eligible for free and/or reduced-priced meals, certification documentation will be reviewed for all students. For SFAs with more than 100 students eligible for free and/or reduced-priced meals, a statistical sampling of students will be determined by the Lead Reviewer using the Benefit Issuance List provided by the SFA. The Lead Reviewer will contact the SFA with the list of students chosen for review. The SFAs may either provide scanned copies of the household income eligibility applications off-site or have all supporting certification documentation available for review on the first day of the on-site review. If the SFA has implemented the PrimeroEdge Student Eligibility System for all buildings, it will not be necessary to submit the Benefit Issuance list. All certification documentation will be reviewed by the Lead Reviewer prior to the on- site review via the PrimeroEdge web-based system. On-site Review The On-site validation of Certification and Benefit Issuance will include a review of the following: If not provided during the Off-site Assessment, the Lead Reviewer will review income eligibility applications for all students chosen for review. The Lead Reviewer will validate that Direct Certification matching is completed a minimum of 3 times per year. (However, DFN recommends the Direct Certification list is run monthly.) The Lead Reviewer will request documentation of homeless and runaway from the school liaison if applicable. The Lead Reviewer will request documentation of Head Start from the Head Start representative if applicable. For foster children not on a household application, documentation from the county court or Children & Youth will be required. DFN will validate that the SFA process for informing households of either approval or denial of benefits is in compliance. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 14

15. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET), PAGE 4 Please refer to the following Technical Assistance concerning Certification and Benefit Issuance. Technical Assistance Notification of eligibility can occur electronically or by phone. If choosing to implement a verbal notification of approval, all verbal communication must be documented. Include the date, initials of the SFA staff who placed the phone call, and the name of the household member who was issued the notification. Denial of benefits must always be in writing and include the reason for denial, right to appeal, instructions on how to appeal, and must inform the household of their ability to re-apply at any time during the school year. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Sending and Receiving Schools: If an SFA that "sends" students to another SFA and is responsible for the Certification and Benefit Issuance for these students, the sending SFA must provide the "receiving" school with all applicable documentation to validate the eligibility determined by the sending SFA. Acceptable documents include: Copies of the Household Income Eligibility Applications with the dated signature of the determining official and the eligibility determination. Copy of the dated Direct Certification List with applicable students, or a copy of the DC Notification Letter, or a list of the DC students on School District Letterhead with signature of appropriate school official. Cyber School Students: Cyber school students should not be included in the total enrollment reported on the monthly claim or on the Benefit Issuance list provided during the Administrative review. Only include students that have access to NSLP or SBP. If you are currently or plan to provide meals for cyber school students, please contact PDE for guidance. H H H H H H H H H H H H 15

16. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET), PAGE 5 Residential Child Care Institutions (RCCIs): For residential students, the RCCI may document eligibility either using household applications for each residential student (each student is considered a household of one) or they may document eligibility by completing and maintaining a master list of residential students. The list must include the student's first and last name, birth date, date of enrollment, date of withdrawal, and personal income if applicable. The Master list must be signed by the appropriate official including title and contact information. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Enrollment Numbers: During the AR, the Lead Reviewer will validate that the total number of students on the Benefit Issuance list for the test month is reasonable when compared to the number of free and reduced students reported on the monthly claim for reimbursement for the test month. When reporting enrollment numbers on the monthly claim for reimbursement: Include ALL students with access to NSLP or SBP. For example, if there is a classroom of Head Start students that does not participate in the SBP or the NSLP, do not include these students in reported enrollment. However, if the Head Start students participate in SBP or NSLP, then these students must be included in the reported enrollment for the applicable school. When reporting the number of free and reduced students on the monthly claim for reimbursement, report the total number of free eligible for the day during the month with the highest count of free eligible. Report the corresponding number of reduced-price eligible and total enrollment for the same day. H H H H H H H H H H H H Continued on next slide. 16

17. School Nutrition Program (SNP) Administrative Review Process TOPIC 4 | CERTIFICATIONAND BENEFIT ISSUANCE (100 FORMSET), PAGE 6 Enrollment Numbers (continued): The number of Directly Certified students reported on the monthly claim for reimbursement must include the total number of students identified as: Directly certified via SNAP, TANF, or Medical Assistance on the Direct Certification List from PA SES Homeless (documented by designated school official) Runaway (documented by designated school official) Foster (identified through the County Assistance Office) Migrant (documented through COMPASS) Head Start (documented by designated school official) The following are not to be reported as Directly Certified: Students who are categorically eligible based on a SNAP or TANF number on a Household Income Eligibility application Foster children submitted through a Household Income Eligibility application Students who are eligible for free or reduced meals through Household Income Eligibility application School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Reference the Eligibility Manual for Schools (This link will open in web browser) www.fns.usda.gov/eligibility-manual-school-meals for additional guidance. H H H H H H H H H H H H 17

18. School Nutrition Program (SNP) Administrative Review Process TOPIC 5 | VERIFICATION (200 FORMSET) Verification is a process used by SFAs to confirm selected students eligibility for free and reduced-price meals in the NSLP and SBP. Verification is only required for a sample of students whose eligibility is certified using a household application submitted with income information or if applicable, applications with a case number for the Supplemental Nutrition Assistance Program (SNAP), Food Distribution Program on Indian Reservations (FDPIR), or Temporary Assistance for Needy Families (TANF). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Students certified for free meal benefits through direct certification are not subject to verification. Off-site Assessment The Off-site Assessment for Verification will require the SFA to do the following: Describe the process for conducting Verification Provide the name and title of specific staff involved in this process Indicate the most recent Verification training that was completed by staff involved in this process Describe the process and procedure for verification for cause H H H H H H H H H H H H 18

19. School Nutrition Program (SNP) Administrative Review Process TOPIC 5 | VERIFICATION (200 FORMSET), PAGE 2 On-site Review On-site the Lead Reviewer will: Validate the number of applications on file as of October 1st (Sampling Pool) Validate that the correct sampling method was used Validate that the correct number of applications were verified (Sample Size) Validate that the SFA conducted a confirmation review Validate that the SFA correctly implemented follow-up attempts for households that failed to respond or only partially responded. (Technical Assistance: A household that submits documentation for only one income when the initial application included two incomes, is considered a non-response and requires a second attempt.) Validate that application determinations were correctly verified based on documentation submitted by the household. Validate that changes in benefits as a result of verification were implement in required timeframes Validate that the SFA Notice of Adverse Action contains all required information Validate that the verification information was reported correctly on the FNS-742, more commonly referred to as the Verification Collection Report School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here If the SFA has implemented the PrimeroEdge web-based Student Eligibility System, the review of Verification by will be conducted prior to the on-site review due to the State Agency ability to access all required information via this web-based system. H H H H H H H H H H H H 19

20. School Nutrition Program (SNP) Administrative Review Process TOPIC 6 | MEAL COUNTINGAND CLAIMING (300 FORMSET) The SFA must have a meal counting and claiming system that accurately counts, records, consolidates, and reports the number of reimbursable meals claimed, by category (i.e., free, reduced-price, or paid). The meal counting and claiming process must include a mechanism, whether manual or electronic, for counting meals and consolidating meal totals at each school within the SFA. The mechanism must include an internal control system that validates the total meal counts prior to the submission of the Claim for Reimbursement to the State Agency. The goal for monitoring Meal Counting and Claiming is to ensure the processes the SFA uses to count, consolidate, and claim meals for the SBP and NSLP are in compliance with Program requirements. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Off-site Assessment During the Off-site Assessment, the SFA will answer questions relating to the process and procedures of the meal counting and claiming. Questions will include the type of system or systems used for counting and consolidating reimbursable meals and the type of Point of Service system used in each of the school buildings. Additional questions will collect information on the SFA s meal counting and claiming procedures for the following: Offer vs. Serve, Incomplete Meals, Second Meals, Visiting Students, Adult Non-Student Meals, Student Worker Meals, A la Carte, Field Trips Training for Cashiers and Substitute Cashiers H H H H H H H H H H H H Continued on next slide. 20

21. School Nutrition Program (SNP) Administrative Review Process TOPIC 6 | MEAL COUNTINGAND CLAIMING (300 FORMSET), PAGE 2 Off-site Assessment (continued) This information must be provided for all school buildings. For example, the SFA may implement a computerized POS system in the high school but use a manual meal count roster in the elementary schools. Perhaps a roster is used to count meals for the Afterschool Snack Program but a computerized POS system is used for lunch and breakfast. All meal counting systems for all buildings, grades, and meal types must be included by the SFA when answering the off-site questions. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here The SFA will be required to provide a copy of the SFA s current local meal charge policy for review during the off-site assessment. The SFA must also provide documentation demonstrating that the local meal charge policy was communicated to all households at the start of the school year and to all households that transfer into the SFA during the school year. On-site Review During the on-site meal observations, the Lead Reviewer will validate the systems described by the SFA and also validate the accuracy of these systems. The Lead Reviewer will validate the following: Food service staff accurately identifies a reimbursable meal at the Point of Service. Offer Versus Serve is properly implemented. Student meals are counted and recorded in the correct benefit status. The SFA conducts edit checks to identify potential counting and claiming errors. The claim for reimbursement that was submitted by the SFA for the test month. H H H H H H H H H H H H 21

22. School Nutrition Program (SNP) Administrative Review Process TOPIC 7 | MEAL COMPONENTSAND QUANTITIES (400 FORMSET) The scope of review for Meal Component and Quantities is to establish that meals claimed for reimbursement contain the appropriate meal components (also referred to as food components) and quantities for the SBP and the NSLP. There are no Off-site requirements for this section of the assessment. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals On-site Review During the On-site review the State Agency must ensure that every reimbursable meal service line meets the daily and weekly meal pattern requirements for the appropriate age/grade group served. This includes verifying how an SFA is meeting the meal pattern requirements if serving multiple age/grade groups in a single location, and if children are using self-service stations. During the On-site review, the State Agency must obtain documentation from the SFA for each of the sites/schools chosen for review. Required documentation includes a Weekly Food Component Report from Primero Edge or another USDA approved Nutrient Analysis software, menus, production records, and related materials (e.g., CN Labels, standardized recipes). Put Course Name Here Put Course Name Here The State Agency will evaluate all documentation to ensure the following: All reviewed sites/schools are meeting weekly requirements for fruits, vegetable sub-groups, grains, meat/meat alternates and milk variety. Weekly juice limits are not exceeded. All required meal components are available on each reimbursable meal service line. Records include all information necessary to support the claiming of reimbursable meals and any additional SA requirements (i.e., all menu items are listed and all required meal components are offered). Records are used for proper planning (e.g., evaluate for consumption and leftovers). H H H H H H H H H H H H Continued on next slide. 22

23. School Nutrition Program (SNP) Administrative Review Process TOPIC 7 | MEAL COMPONENTSAND QUANTITIES (400 FORMSET), PAGE 2 Records document a la carte, adult, and/or other non-reimbursable meals, including number of portions for each of these food items. Records align with standardized recipes (e.g., if chicken salad sandwich is on the menu but mayonnaise is not listed on the production records, the State Agency may examine standardized recipes for additional information). School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 23

24. School Nutrition Program (SNP) Administrative Review Process TOPIC 8 | OFFERVERSUS SERVE (500 FORMSET) Offer versus Serve is a provision in the NSLP and SBP that allows students to decline some of the food components/items offered. The goals of Offer versus Serve are to reduce food waste in the school meals programs while permitting students to decline foods they do not intend to eat. The review of Offer versus Serve is a Performance Standard 2 review element. There are no off-site requirements for this section of the assessment. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here On-site Review In SFAs that implement Offer versus Serve, menu planners must ensure they prepare and offer enough food to meet meal pattern requirements. Point-of-service staff must also consider Offer versus Serve when determining whether a student has selected enough components/items to make a reimbursable meal. The State Agency must consider the following: Is the school offering the appropriate food components/items on all reimbursable meal service lines? Is signage posted on the service line to assist students in selecting a reimbursable meal? Are students selecting at least three food components (in NSLP) or items (in SBP) in the proper quantities to make a reimbursable meal, which must include at least a cup of fruit and/or vegetable? Are food service staff members at the point-of-service trained and accurately recognizing a reimbursable meal, including appropriate quantities? H H H H H H H H H H H H 24

25. School Nutrition Program (SNP) Administrative Review Process TOPIC 9 | NUTRIENT ANALYSISAND DIETARY SPECIFICATIONS (600 FORMSET) The review of Nutrient Analysis and Dietary Specifications, often referred to as the In-Depth Menu review, may occur either off-site or on-site depending on the specific menu planning software implemented by the SFA. For one of the reviewed sites, the Lead Reviewer will request a nutrient analysis and meal compliance assessment report in order to validate compliance with the meal pattern requirements and Dietary Specifications for calories, saturated fat, sodium and trans fat. DFN will conduct this portion of the review by validating an existing analysis and meal compliance report completed by the SFA. The new meal pattern requirements, which began in the 2012/13 School Year, have elevated the level of knowledge and effort needed to plan menus. SFAs must fully understand how to properly plan menus that meet these requirements. Because of the complexity of the new meal standards, it is no longer possible to sketch out a menu with the five required components and eyeball it to assess whether or not it meets the requirements. Conducting a meal compliance assessment and nutrient analysis using USDA approved software helps to ensure that all menus are in compliance before they are served and claimed for reimbursement. This is essential since only meals that meet requirements are eligible to be claimed for reimbursement. If the SFA has implemented the PDE-provided PrimeroEdge Menu Planning system: The SFA will select one week within the test month for the in-depth menu review. The SFA will complete the menus for one week on PrimeroEdge Menu Planning system as part of the off-site Assessment. The review of the analysis will be conducted off-site by the Lead Reviewer who will also provide technical assistance if required. During the on-site review, DFN will validate a sampling of ingredients, recipes, and CN labels for food items to ensure that items entered into PrimeroEdge Menu Planning system are an accurate reflection of the food items that are actually served at the school and to validate that crediting and nutritional information was correctly entered into the system. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 25

26. School Nutrition Program (SNP) Administrative Review Process TOPIC 9 | NUTRIENT ANALYSISAND DIETARY SPECIFICATIONS (600 FORMSET), PAGE 2 If the SFA chooses to use another USDA approved software: This portion of the review will be conducted during the on-site review. The Lead Reviewer will select the specific week for the in-depth menu review when arriving for the On-site review. The SFA will be required to provide menus, productions records, recipes, CN labels, and nutritional information for all menu items in addition to the required nutritional analysis. Failure to complete a nutrient analysis and the corresponding food component report in either PrimeroEdge Menu Planning system or another USDA approved menu planning system will result in the SFA being placed on Batch Hold until DFN is able to validate compliance and corrective action will be required for this finding. Corrective Action will include instructions for SFA to complete a nutrient analysis of the entire menu cycle implemented by the school. For example, if the school is implementing a four-week cycle menu, all four weeks will need to be entered into either PrimeroEdge or another USDA approved menu planning system as part of the Corrective Action. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 26

27. School Nutrition Program (SNP) Administrative Review Process TOPIC 10 | RESOURCE MANAGEMENT (700 FORMSET) Off-site Assessment SFAs will answer a series of question that pertain to: Nonprofit School Food Service Account (NSFSA) Paid Lunch Equity Revenues from Non-program Foods Allowable/Unallowable costs Indirect Costs During the Off-Site Assessment of the Nonprofit School Food Service, the following must be submitted: Maintenance of the Nonprofit School Food Service Account: Detailed food service general ledger Internal control procedure The written internal control procedure/policy must explain how effective oversight is maintained over Federal funds to ensure charges to the NSFSA are allowable. The policy may include, but is not limited to: o Training on financial management, including allowable vs. unallowable costs o Separation of duties so that staff who receive or manage the collection of money are not also involved in the disbursement of funds o Process of ensuring bad debt is not paid for with food service funds o Sales of food service equipment o Physical controls to ensure funds are not lost or stolen (i.e. lock boxes for petty cash, etc.) School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 27

28. School Nutrition Program (SNP) Administrative Review Process TOPIC 10 | RESOURCE MANAGEMENT (700 FORMSET), PAGE 2 Paid Lunch Equity: Paid Lunch Equity Compliance Form (if not already submitted) Paid Lunch Equity Tool If the NSFSA had a negative balance as of December 31 School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Revenue from Nonprogram Foods: Nonprogram foods are defined as any non-reimbursable food and/or beverage purchased using funds from the NSFSA. Types of nonprogram foods include: Adult meals and a la carte food items, which includes meals sold to teachers, parents, or a non-student. A la carte sales may include, but are not limited to, the sale of milk, extra entr e, or second meals Catering includes internal catering, such as a meal served during the school board meeting. Catering may also include external catering such as a meal served to the local Rotary Club Reimbursable meals and/or beverages sold outside the LEA s district or to another program. An example of this would be the sale of meals to a local Head Start for a child-care center Food and/or beverages sold during school hours, but outside of the meal service, which could include those food items sold in the school store Food sold as fundraisers. For example, food items sold to the High School Music Club who will then sell them to raise funds for a trip Food and/or beverages via vending machines Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 28

29. School Nutrition Program (SNP) Administrative Review Process TOPIC 10 | RESOURCE MANAGEMENT (700 FORMSET), PAGE 3 SFAs that sell nonprogram foods must provide the following for this section of review: Nonprogram food attestation The attestation must state I attest all nonprogram foods are sold at or above costs. This statement must be entered into the comment box of the first question in the Revenue from nonprogram foods section. List of all nonprogram foods sold The list of all nonprogram foods sold must include, but is not limited to the cost per unit, mark-up, and selling price per unit Point of Service sales report for one day If adult meals are sold, the sales report must include adult meal sales One catering invoice A written pricing policy for all nonprogram foods sold. The policy must be inclusive of all nonprogram foods sold. It should explain: o Calculation of the adult meal price o How all nonprogram food items (i.e. adult meals, second entrees, a la carte items sold in the cafeteria, foods sold in school stores or snack bars, and vending machines, catering, etc.) are priced. Some examples are: Flat mark-up Percentage mark-up Combination of flat mark-up and percentage mark-up School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 29

30. School Nutrition Program (SNP) Administrative Review Process TOPIC 10 | RESOURCE MANAGEMENT (700 FORMSET), PAGE 4 Resource Management staff will contact the SFA to discuss the responses in this section. Results from these questions are used to determine if a more comprehensive Resource Management review is required. If the Off-Site portion of Resource Management is not completed by the SFA by the established due date, the SFA will automatically flag for a comprehensive Resource Management review. The State Agency (SA) previously provided training webinars on the topics covered in the Resource Management section. Webinars covered topics including the Child Nutrition Financial Report, Paid Lunch Equity, Revenue from Nonprogram Foods, allowable and unallowable costs, and indirect cost rates. These presentations and additional resources are available on PEARS Download Forms. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here References: PEARS > Download Forms > Equity in School Meal Pricing PLE Tool Instructions from completing the PLE Tool USDA Nonprogram Food Revenue Tool USDA Memo SP 20-2016 Nonprofit School Food Service Account Nonprogram Food Revenue Requirements Adult meal pricing memo PEARS > Download Forms > Equity in School Meal Pricing USDA Memo SP 60-2016 Indirect Costs Guidance for State Agencies & School Food Authorities USDA presentation Indirect Cost Guidance for SA s and SFA s H H H H H H H H H H H H 30

31. School Nutrition Program (SNP) Administrative Review Process TOPIC 11 | CIVIL RIGHTS (800 FORMSET) USDA requires that all SFAs administer program services and benefits in accordance with all laws, regulations, instructions, policies, and guidance related to nondiscrimination in program delivery. The State Agency must assess whether the SFA is complying with civil rights requirements as applicable to the Child Nutrition Programs, i.e., NSLP (including the Fresh Fruit and Vegetable Program, Seamless Summer Option, and Afterschool Snacks), SBP, and SMP. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Off-site Assessment The SFA will be required to provide: The specific Nondiscrimination Statement that is used on SNP program materials. The SFA will be required to attach a copy of the statement. A written procedure for processing complaints alleging discrimination Please note that a civil rights complaint is one that is specifically related to one of the protected classes Technical Assistance Reference PDE Procedure for Civil Rights Complaints on PEARS > Download Forms > PDE-05013 Information related to feedings students with special dietary needs. Specific date of the annual Civil Rights training for all staff and attach a copy of the training agenda. NOTE: The School Nutrition Toolbox includes a Civil Rights Training module that may be used to meet this requirement. Method for collection of racial and ethnic data. A copy of the training agenda, training materials, and staff sign-in sheet will be requested during the off-site portion of the Administrative Review. The Civil rights section also includes a question concerning the annual Public Release. This is taken care of by the State Agency at the beginning of each school year by releasing a statewide Associated Press release. SFAs may do additional releases, but the statewide release ensures compliance with this requirement. H H H H H H H H H H H H 31

32. School Nutrition Program (SNP) Administrative Review Process TOPIC 11 | CIVIL RIGHTS (800 FORMSET), PAGE 2 On-site Review During the On-site review, the Lead Reviewer will validate all responses provided by the SFA on the Civil Rights form set. In a limited number of situations Technical Assistance may be offered during the off-site assessment that could assist the SFA in avoiding a Corrective Action. An example would be if the off-site assessment finds that the SFA has failed to use the correct Non-Discrimination Statement, technical assistance will be provided by the Lead Reviewer during the off-site Assessment. During the on-site review, the Lead Reviewer will validate that the SFA has implemented the correct Non-Discrimination Statement on program materials. If they have, no Corrective action will be required. If they have not, this finding will result in a Corrective Action. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 32

33. School Nutrition Program (SNP) Administrative Review Process TOPIC 12 | SFA MONITORING (900 FORMSET) The State Agency must determine whether each SFA with more than one school operating the NSLP performs no less than one on-site review of the lunch counting and claiming system used by the school and observe the general areas of review that are readily observable in each school under its jurisdiction. The SA must also determine whether each SFA with more than one school performs no less than one on-site review of the breakfast counting and claiming system used by the school and observe the general areas of review that are readily observable at a minimum of 50 percent of the schools operating the SBP under its jurisdiction with each school operating the School Breakfast Program being monitored at least once every two years. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here The on-site reviews must occur by February 1st of each year. The SFA is required to provide a description of the procedure used to fulfill this requirement. The State Agency will request documentation during the on-site review to validate compliance. H H H H H H H H H H H H 33

34. School Nutrition Program (SNP) Administrative Review Process TOPIC 13 | LOCAL SCHOOL WELLNESS POLICY (1000 FORMSET) Schools play a critical role in promoting children s health, preventing childhood obesity, and preventing diet-related chronic diseases. To help foster a healthy school environment, the Healthy, Hunger Free-Kids Act (HHFKA) requires each LEA to establish a comprehensive Local School Wellness Policy. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox New regulations under the HHFKA went into effect on June 30, 2017 which required all LEAs to update their Local School Wellness Policy for compliance with federal law. Marketing School Meals Put Course Name Here Put Course Name Here Off-site Assessment SFAs will be required to attach a copy of their Local School Wellness Policy to the review tool as well as provide information and documentation related to: Public notification of the policy and policy assessment Policy review and updates Stakeholder participation in the development, review, update, and implementation of the policy Assessment of the Local Wellness Policy The information provided by the SFA will be evaluated by one of PDE s Nutritionists off-site. H H H H H H H H H H H H 34

35. School Nutrition Program (SNP) Administrative Review Process TOPIC 13 | LOCAL SCHOOL WELLNESS POLICY (1000 FORMSET), PAGE 2 Local Wellness Policy resources can be found on PEARS, Download Forms, in the Wellness Policy section. Resources include: Webinar recording with PowerPoint slides Local school wellness policy checklist Compliant policy templates from Pennsylvania School Boards Association and Alliance for a Healthier Generation Links to wellness policy resources Wellness Policy Assessment Tool and Report Template to complete the required triennial assessment School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Technical Assistance When responding to questions 1001 through 1006, describe how you actually accomplish the activities. (Copying and pasting language from your Wellness Policy is not an appropriate response.) Where requested, provide supporting documentation as you complete each of the questions that are included in the off-site assessment of the Local Wellness Policy. If your response indicates that the Local Wellness Policy or other supporting documentation is found on your website, provide either: The exact URL for PDE to copy and paste; or The path to navigate to the correct webpage (e.g., From www.FakeSchoolDistrict.edu, click on District, then District Policies, then Policy 246. ). An assessment must be completed by June 30, 2020 and every three years thereafter. On-site Review During the on-site review, PDE will validate the information provided during the off-site assessment. H H H H H H H H H H H H 35

36. School Nutrition Program (SNP) Administrative Review Process TOPIC 14 | SMART SNACKSIN SCHOOL (1100 FORMSET) Schools must meet the minimum Smart Snacks in School requirements for all foods and beverages sold in school to increase consumption of healthful foods during the school day and support a healthy school environment. The State Agency s responsibility is to understand the entities responsible for selling foods/beverages to students, and to ensure that food and beverages sold meet the minimum requirements. Off-site Assessment The SFA s procedures for the sale of non-program foods are included in the review. The off-site assessment includes questions concerning: SFA food sale policies during the school day The SFA process for determining that non-program or a la carte food items are in compliance with the Smart Snack requirements. On-site Review During the on-site review, the State Agency will evaluate compliance and ensure that all foods and beverages sold on the school campus (excluding reimbursable meals), during the school day (defined as 12 AM on a day of instruction to 30 minutes after the end of the official school day), meet regulatory requirements. This includes a la carte items sold during meals, and foods/beverages sold in vending machines, school stores, and any other venue. The Lead Reviewer will visit all locations where food is sold to students throughout the school day and will choose a sampling of the non-program foods and beverages sold at each location to validate compliance with Smart Snacks. The Lead Reviewer will also validate that the SFA has established a process for ensuring the number of exempt fundraisers, that include the sale of food during the school day, do not exceed the maximum of: Five in each elementary and middle school building Ten in each high school building And lastly, the SFA will be required to provide production records in order for the Lead Reviewer to ensure that exempt leftover food items are sold only on the same day or the day after they were initially offered as part of a reimbursable meal. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 36

37. School Nutrition Program (SNP) Administrative Review Process TOPIC 15 | PROFESSIONAL STANDARDS (1200 FORMSET) The Professional Standards for School Nutrition Personnel regulations establish: 1. Hiring standards for new school nutrition program (SNP) directors; and 2. Annual training standards for all SNP directors, managers, and staff. Annual Training Standards All individuals involved in operating and administering the school nutrition program (SNP) on a continuous basis throughout the school year must complete annual training each school year (July 1 through June 30). The number of annual training hours required of each employee depends on his/her role in the SNP operation: Program Director - 12 hours per school year Program Manager - 10 hours per school year Full-time Program staff (working 20 hours/week) - 6 hours per school year Part-time Program Staff (working < 20 hours/week) - 4 hours per school year Training should be job-specific and is intended to help employees perform their duties well. Training may be obtained in a variety of ways, including in-person or virtual attendance at national or local meetings or conferences, on-line modules or webinars, self-study courses, etc. Training topics should focus on four key areas: nutrition, operations, administration, and communications/marketing. During the Administrative Review, compliance with the Professional Standards requirements are reviewed exclusively off-site by a PDE Nutritionist. Proper recordkeeping is extremely important. Annual training should be logged and tracked in an organized manner. PA sponsors are strongly encouraged to use PrimeroEdge Team Work (https://paschoolmealsses.com) to log and track annual training. School Food Authorities (SFA) must attach documentation to the off-site questions (certificates, agendas, and sign-in sheets) to demonstrate training has been completed during the current school year by all school nutrition personnel. Reports generated from Primero Edge s Team Work will be accepted in lieu of providing these documents. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 37

38. School Nutrition Program (SNP) Administrative Review Process TOPIC 15 | PROFESSIONAL STANDARDS (1200 FORMSET), PAGE 2 Annual Training Standards (continued) If an SFA chooses to use its own tracking system to log and track training, a spreadsheet listing all current school nutrition personnel and all the following information is required: Name of each staff person Date hired Official job title provided by the LEA Brief list of core duties or responsibilities Employment status (full-time, part-time, acting, etc.) and the average number of hours worked per week for each part-time employee Professional Standards category (program director, program manager, program staff, FT program staff, and 20 hours PT program staff) Required Hours of Annual Training Training Title/subject Training date(s) Length of training (creditable time) School Year training applied to Completed training hours (year to date) Planned training to meet required training hours for the school year. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 38

39. School Nutrition Program (SNP) Administrative Review Process TOPIC 15 | PROFESSIONAL STANDARDS (1200 FORMSET), PAGE 3 Annual Training Standards (continued) All new SNP directors, hired on or after July 1, 2015 must meet minimum Hiring Standards for education and experience. Hiring credentials/requirements vary based on three (3) LEA enrollment categories. New SNP directors must also possess at least 8 hours of food safety training within 5 years prior to or within 30 days of his/her start date. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here SFAs that have hired a new program director on/after July 1, 2015, or since your last completed Administrative Review, must attach documents (current resume and copy of degree(s) and/or transcripts) to the off-site questions to support that hiring standards have been met, and attach documentation that 8 hours of food safety training was completed. SFAs are strongly encouraged to use Team Work in PrimeroEdge (www.paschoolmealsses.com) to log and track annual training. It is to your benefit to utilize this system as much as possible. The more information that is available to the State agency through Team Work, the less contact the SFA will have with the reviewer. For assistance using the Team Work system, please contact Child Nutrition (CN) Resource at 1-855-286-7685 or pahelp@cnresource.com. For more information on the Professional Standards requirements, please visit the Professional Standards for School Nutrition Personnel section of PEARS, Download Forms. H H H H H H H H H H H H 39

40. School Nutrition Program (SNP) Administrative Review Process TOPIC 16 | POTABLE WATER (1300 FORMSET) The goal of the water review, which will occur during the on-site review, is to ensure that children have access to water during the lunch and breakfast meal services. During the on-site visit, the State Agency will observe and assess whether the school makes free water available to students as required. There are no Off-site requirements for this section of the assessment. The State Agency s responsibility is to determine whether free potable water is available at each school selected for review during the lunch and breakfast meal services on the day of review. Any school that does not make free water available or restricts access during the lunch and breakfast meal periods is out of compliance. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Technical Assistance Schools can provide free water in a variety of ways. Examples include: water pitchers and cups on lunch tables water fountain faucet that allows students to fill their own bottles or cups with drinking water While water must be made available to students during meal service, water or any other beverage may not be served as an alternative selection to fluid milk. Additionally, water is only required when breakfast is served in the cafeteria. H H H H H H H H H H H H 40

41. School Nutrition Program (SNP) Administrative Review Process TOPIC 17 | FOOD SAFETY, STORAGE, BUY AMERICAN (1400 FORMSET) The State Agency must ensure that all selected schools meet the food safety and storage requirements and comply with the Buy American provisions specified by the regulations. This includes any facility where food is stored, prepared, or served for the purposes of the NSLP, SBP, or other FNS programs. The 1400 form set includes questions that will be answered by the Lead Reviewer during the on-site review. There are no Off-site requirements for this section of the assessment. To evaluate compliance with these requirements during the On-site review, the Lead Reviewer will: Determine whether the SFA has any contracted or self-operated warehouses and, if so, determine whether all foods in all locations are being stored properly. The Lead Reviewer will validate that: Food is stored 6 inches from the ceiling and 6 inches off the floor. The food storage facility is clean and neat. Canned goods are free from bulges, leaks, and dents. Chemicals are clearly labeled and stored away from food and food-related supplies. Open bags of food are stored in containers with tight fitting lids. The First In, First Out (FIFO) method of inventory management is used. Review the food labels on a variety of foods by category to assess if the country of origin is the United States or territories, as applicable and; Determine whether two food safety inspections have been conducted or requested. Verify the posting of Food Safety Inspections. Check temperature logs to ensure proper recordkeeping. Review the written food safety plan for compliance with Hazard Analysis Critical Control Point (HACCP) program criteria found in 7 CFR 210.13(c) and verify compliance with HACCP principles and local and state health standards. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 41

42. School Nutrition Program (SNP) Administrative Review Process TOPIC 17 | FOOD SAFETY, STORAGE, BUY AMERICAN (1400 FORMSET), PAGE 2 Observe meal preparation and service on the day of review at the selected school or schools to determine that the SFA has a written food safety plan based on HACCP principles and has successfully implemented the food safety program. To make this determination, the reviewer will ensure: Proper personal hygiene is evident (e.g., hairnets, gloved hands, appropriate hand washing) Cross-contamination is prevented Food temperatures are monitored and recorded Refrigerator and freezer temperatures are monitored and recorded Food preparation and service areas are clean Clean utensils and equipment are used for food preparation and meal service No obvious evidence of pests is present School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Additionally, the Lead Reviewer will interview food service staff to validate that all food service employees have been trained, fully understand, and follow the food safety program. H H H H H H H H H H H H 42

43. School Nutrition Program (SNP) Administrative Review Process TOPIC 18 | REPORTINGAND RECORDKEEPING (1500 FORMSET) There are no Off-site requirements for this section of the assessment. On-site Review The Lead Reviewer must determine whether required documentation is maintained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. If audit findings have not been resolved, the three-year period is extended as long as required for resolution of audit issues. These reports and records include, but are not limited to: Approved and denied free and reduced-price meal applications; Procedures and documentation for direct certification for free meals, if applicable; Verification records, including: description of verification efforts, documentation of verification, results of verification, and verification reports; Claims for Reimbursement (including supporting documentation, such as point of service benefit issuance rosters); Meal count participation data by school; Documentation of edit checks, on-site reviews, internal controls; October enrollment, free and reduced-price eligible data; Menu and food production records and, if applicable, nutrient analysis records; School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 43

44. School Nutrition Program (SNP) Administrative Review Process TOPIC 18 | REPORTINGAND RECORDKEEPING (1500 FORMSET), PAGE 2 On-site Review These reports and records include, but are not limited to (continued): All documentation provided in support of the Resource Management Section (including appropriate records to document compliance with the paid lunch equity and revenue from non-program foods requirements); Documentation associated with the local wellness policy; Number of food safety inspections obtained per school year by each school; Food temperature records; Records from the most recent food safety inspection; Documents demonstrating compliance with Civil Rights requirements; Audit reports and written responses; and any related corrective action. Permanent documents that must be maintained indefinitely include: Agreements and free and reduced-price policy statements; If the SFA is participating in the Community Eligibility Provision (CEP), documentation must be maintained by the SFA or LEA for the duration of the four-year cycle plus an additional three years. The Lead Reviewer will also validate that all required reports are submitted to the State Agency by established deadlines. Reports include, but are not limited to: Verification Summary Report Annual Financial Report Food Safety Inspection Report Failure to provide any documentation requested by the State Agency during the off-site assessment will result in a finding for Reporting and Recordkeeping. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 44

45. School Nutrition Program (SNP) Administrative Review Process TOPIC 19 | OUTREACH (1600 FORMSET) Off-site Assessment Research has shown that starting the day with a nutritious breakfast helps students stay alert and perform better in school. In an effort to help more children benefit from the nutritious meals served in the SBP, participating SFAs must inform eligible families of the availability of reimbursable breakfasts served under the SBP Schools can provide reminders to children through their public address systems or through means normally used to communicate with the households of enrolled children. Other acceptable outreach activities may include developing or disseminating printed or electronic material to families and school children. For example, information about the SBP should be posted on the school s website. The off-site assessment includes questions involving outreach. All SFAs that operate the School Breakfast Program must advertise the availability of School Breakfast prior to or at the beginning of each new school year. The SFA must also provide reminders throughout the school year. The off-site assessment will require the SFA to indicate how the availability of breakfast is disseminated to enrolled students and households. If the SFA does not offer the School Breakfast Program, this is not a requirement. All SFAs, regardless of participation, are required to advertise the availability of summer meals. This does not necessarily mean that the SFA is offering meals during the summer months. However, all SFAs are required to inform households throughout the community that meals are available during the summer months and inform households of the location of the Summer Food Service Program meals. This requirement applies to ALL SFAs including Residential Child Care Institutions. It is not acceptable for any SFA to answer this off-site question concerning outreach for Summer Food Service Program as Not Applicable. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 45

46. School Nutrition Program (SNP) Administrative Review Process TOPIC 19 | OUTREACH (1600 FORMSET), PAGE 2 Technical Assistance Households may learn about the location of Summer Food Service Programs through the following means: Call: 211 or 1.866.3Hungry or 1.877.8Hambre Text: FOOD or COMIDA to 877877 Download: RangeAPP.org mobile app Visit: www.fns.usda.gov/summerfoodrocks In order to meet the requirement to disseminate information to families about summer meals, any or all of the suggestions listed below will fulfill the requirement: Robo calls Fliers Posting on the SFA website For more information, access PEARs > Download Forms > PDE-SNP-078 for the PDE memo addressing this requirement. On-site Review During the On-site review, the State Agency will determine whether the information provided through the Off-site Assessment and supporting documentation establishes that the SFA conducts the required Breakfast and Summer Food Service Program outreach. Technical assistance will once again be provided to SFAs not in compliance with these requirements during the Off- site Assessment. However, if the SFA is still non-compliant during the On-site portion of the review, this will result in a finding. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 46

47. School Nutrition Program (SNP) Administrative Review Process TOPIC 20 | AFTER SCHOOL SNACK PROGRAM (1700 FORMSET) Schools participating in the After School Snack Program must serve students nutritionally-balanced snacks, provide appropriate activities, and count and claim snacks accurately. The State Agency will examine afterschool snack documentation for each school selected for the Administrative Review that operates afterschool snacks. There are no Off-site requirements for this section of the assessment. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox On-site Review During the On-site review, the Lead Reviewer will: Verify the school eligibility and ensure that the SFA maintains required documentation to validate the school eligibility Area-Eligible Sites: The site is at a school or located within the attendance area of a school in which at least 50% of enrolled students are certified for free or reduced-price meals. Snacks are served free to all children, and reimbursed at the free rate. Non Area-Eligible Sites: Snacks are served at free, reduced-price, and paid rates based on approved eligibility. Ensure that an accurate counting and claiming system is in place. Validate that snacks meet component and nutritional requirements via a review of daily production records. Production records must reflect menus that meet serving size requirements and all meal pattern requirements. Validate that the SFA conducts self-monitoring activities twice per year. The SFA is required to conduct the first self-review during the first four weeks of the operation of the afterschool snack program each school year. The SFA must conduct the second self-review of the afterschool snack program prior to the end of each school year. Make certain that food safety regulations are being followed. Validate that Civil Rights requirements are met. Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H Continued on next slide. 47

48. School Nutrition Program (SNP) Administrative Review Process TOPIC 20 | AFTER SCHOOL SNACK PROGRAM (1700 FORMSET), PAGE 2 On-site Review During the On-site review, the Lead Reviewer will (continued : Validate that schools serve snacks in an afterschool care program that offers educational or enrichment activities. Validate that schools serve snacks only after the end of the school day. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here H H H H H H H H H H H H 48

49. School Nutrition Program (SNP) Administrative Review Process TOPIC 21 | SEAMLESS SUMMER OPTION (1800 FORMSET) The Seamless Summer Option (SSO) permits SFAs participating in the NSLP and/or SBP to serve meals during summer and/or other school vacation periods using the same meal service rules and claiming procedures they use during the regular school year. The State Agency will determine Seamless Summer compliance in the same manner it assesses the NSLP and SBP. In most cases, the review of Seamless Summer will occur the summer AFTER the Administrative Review. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here The State Agency will: Observe at least one meal service Count the number of reimbursable meals served at the actual point-of-service; meal counts must represent only complete meals served to children Assess the site s procedures for counting and claiming by comparing meal counts on the day of review to the last full week of operation from the review period Review menus and production records for meal pattern compliance although the review of Seamless Summer Option will not require a Nutrient Analysis of menus Verify proper food safety H H H H H H H H H H H H 49

50. School Nutrition Program (SNP) Administrative Review Process TOPIC 22 | FRESH FRUITAND VEGETABLE PROGRAM (1900 FORMSET) The Fresh Fruit and Vegetable Program (FFVP) aims to increase children s exposure to and consumption of a variety of fruits and vegetables. From elementary schools that apply to participate in the program in a given school year, FFVP funding is awarded to those with the highest free and reduced meal eligibility rates. Goals include increased access to fresh produce and introduction of healthier snack options. The State Agency is required to ensure that participating schools are proper stewards of federal funds and operate this program as prescribed by USDA. Compliance is validated during both the Off-site and On-site Review. School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox School Nutrition Toolbox Marketing School Meals Put Course Name Here Put Course Name Here Off-site Assessment To evaluate compliance, the State Agency will validate one Claim for Reimbursement for each FFVP school selected for review as part of the off-site assessment. The SFA will receive communication from the FFVP Coordinator during the Off-site Assessment requesting documentation to support the monthly claim for reimbursement for the identified test month. The following documentation will be required: Test month FFVP invoices for selected site Test month FFVP timesheets for selected site Sample nutrition education materials The FFVP Coordinator will review these documents to validate: Administrative spending is on track to be no more than 10% of the total grant amount Cost documentation supports the claim for the test month Cost documentation is for allowable FFVP costs H H H H H H H H H H H H Continued on next slide. 50

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