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Smart Snacks implementation State Agency attendees will be asked to share their implementation stories Would it be possible for State Agencies to exercise flexibilities (under the Interim Final Rule) when implementation of the Smart Snacks rule creates significant problems for SFAs ?
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Smart Snacks implementation • State Agency attendees will be asked to share their implementation stories • Would it be possible for State Agencies to exercise flexibilities (under the Interim Final Rule) when implementation of the Smart Snacks rule creates significant problems for SFAs? • What is the rationale for ambiguities between allowable a la carte items and items approved for inclusion in the reimbursable meal? • Many have heard USDA officials state “while the Smart Stacks comment period has closed, the agency is still accepting comments.” What does this mean and how can State Agencies share comments with USDA to ensure all comments are heard and given reasonable consideration? State Agency Section MeetingPenn Avenue TerraceSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM
State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM • Consolidated Appropriations Act of 2014 • How will SFAs certify they are eligible for a waiver based on need? • How will SAs approve the certification process in order to issue waivers? • Direct Certification • Provide further clarification on the FNS-742; what calculation is used to determine each state’s percentage of students that are directly certified.
State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM • USDA Policy Memo - SP 11 – 2014 Effective Date of Free or Reduced Price Meal Eligibility Determinations • Is it reasonable to assume that State Agencies have the authority to exercise their discretion in allowing SFAs to approve students for direct certification when an error (through no fault of the student/household) created a situation where the student was not immediately identified in the direct certification match? • This request seems consistent with the process of approving student for meal benefits on the date of the application as opposed to the date the application was processed by the SFA.
Flexibilities for the Administrative Review Process and Timeline for State Agencies • While some State Agencies have been able to adapt to the requirement for conducting the Administrative Reviews every three years, some struggle to achieve this schedule and are concerned the aggressive schedule prevents the time/resources to conduct meaningful technical assistance and subsequent training for SFAs. Would USDA consider a risk-based assessment process (similar to the assessment that USDA uses to identify high-risk SAs) that enables SAs to identify high-risk SFAs and conduct an Administrative Review as frequently as necessary while requiring all SFAs to undergo a comprehensive review every five years? • (continued on next slide) State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM
(continued from previous slide) • Flexibilities for the Administrative Review Process and Timeline for State Agencies • Those SAs that have comfortably implemented the three-year Administrative Review timeline, may continue to do so or they may consider operating under the flexibilities available to them. Would this be possible? Our collective goal is to build flexibility where needed in the AR process while demonstrating SAs effectively and efficiently use the resources available to them to ensure SFAs are operating in compliance through risk-based monitoring and oversight responsibilities. • Would USDA consider utilizing various risk measures to identify which reviews could be conducted off-site in their entirety when risks are minimal? State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM
State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM • USDA Policy Memo– SP 17 – 2014Discretionary Elimination of Reduced Price Charges in the School Meal Programs • Please discuss the rationale for this memorandum. • Does USDA anticipate extending this provision to allow the revenues from a la carte meal sales to be considered sources of non-Federal revenue? • Will the provision allowing SFAs with three or more months operating balance to apply for a waiver exempting them from the requirements of Paid Lunch Equity be extended through the current operating year?
State Agency Section MeetingSunday, March 2, 2014 ~ 9:45 AM – 12:00 PM • Proposed Rule – Professional Standards • Other than providing continuing education and training programs that meet the annual requirements for achieving the professional standards, what oversight and monitoring requirements are expected of State Agencies?
