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New Administrative Review Process – What to Expect?

New Administrative Review Process – What to Expect?. Wyoming Department of Education June 2013 Terry Walling ~ Tamra Jackson. Reinvention Goals. The Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process Consolidate the Administrative Review process

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New Administrative Review Process – What to Expect?

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  1. New Administrative Review Process – What to Expect? Wyoming Department of Education June 2013 Terry Walling ~ Tamra Jackson

  2. Reinvention Goals • The Healthy Hunger-Free Kids Act of 2010 calls for a more effective and efficient review process • Consolidate the Administrative Review process • Incorporate school breakfast, the new meal pattern, and dietary specifications, and the 6-cent performance-based reimbursement Wyoming Department of Education

  3. Reinvention Goals • Implement a 3-yr review cycle • Provide for offsite monitoring approaches • Provide effective training and ongoing technical assistance I 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 Laurie Wyoming Department of Education

  4. Revamped Resources • New process uses tools and forms designed to be: • Modular • Efficient • Flexible • Effective • Collaborative Wyoming Department of Education

  5. Maximizing Resources Wyoming Department of Education

  6. The “New” Process Wyoming Department of Education

  7. Off-Site Components • Advantages • Flexibility • Use of specialized staff • Reduced staff time • Off-site monitoring tools • Off-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 Education

  8. Off-Site Assessment Tool • Includes questions on a number of monitoring areas and is intended for completion prior to the on-site visit • Feedback 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 assistance • SFA has more time to provide information to the SA, and also will better understand why they are providing that information • SA has more time to review documents thoroughly, conduct reviews more consistently, and provide ongoing technical assistance to the SFA Wyoming Department of Education

  9. Off-Site Monitoring Tools • Meal Compliance Risk Assessment Tool • Targets error-prone areas of the new meal pattern • Determines which site is selected for an in-depth menu review • Dietary Specifications Assessment Tool • Assesses food service practices to determine risk for not meeting the Dietary Specifications • Resource Management Risk Indicator Tool • Identifies whether the SFA should receive a comprehensive resource management review Wyoming Department of Education

  10. Performance Standards • Critical Areas • Performance Standard 1 • Certification and Benefit Issuance • Meal Counting and Claiming • Performance Standard 2 • Meal Components & Quantities Wyoming Department of Education

  11. Performance Standards • General Areas • Resource Management • General Program Compliance • Verification Wyoming Department of Education

  12. Review Period • Most recent month claim submitted, must include > 10 operating days • Period of On-Site review • Special Circumstances • Reviews early in the school year • Year-round, multi-track & provision schools • May require FNS approval or special procedures Wyoming Department of Education

  13. Pre-Visit Procedures • Notify superintendent and food service director • Initiate Off-Site Assessment Tool • Review SFA documentation • Obtain pre-visit information • Select NSLP sites for review Wyoming Department of Education

  14. On-site Review Procedures • Entrance Conference • On-site Review • Exit Conference Wyoming Department of Education

  15. Review Frequency & Schedule • Review Frequency • SFA must be reviewed every 3 years • Cycle begins July 1, 2013 • Review Schedule • SA discretion • Postponed reviews • Non-compliant SFAs Wyoming Department of Education

  16. Data for Site Selection • Site name • Site type • Number of serving days • Number of eligible for free meals • Number of free meals claimed Wyoming Department of Education

  17. Minimum Number of Review Sites Review all sites (except RCCI) with free ADP of 100 and free participation factor of ≥100% Wyoming Department of Education

  18. Criteria for Additional Sites • Additional NSLP sites: • Elementary sites with ≥ 100 free ADP and ≥ 97% free participation • Combination sites with ≥ 100 free ADP and ≥ 87% free participation • Secondary sites with ≥ 100 free ADP and ≥ 77% free participation • State Agency Criteria Wyoming Department of Education

  19. Additional Site Selection Requirements • Dietary Specifications and Nutrient Analysis • Meal Compliance Risk Assessment Tool • School Breakfast Program • 50% of selected NSLP sites • Other Federal Program Reviews • Varies based on regulations • Resource Management • Offsite Assessment Tool Wyoming Department of Education

  20. New Administrative Review Structure Wyoming Department of Education

  21. Access and Reimbursement Certification & Benefit Issuance Verification Meal Counting and Claiming Wyoming Department of Education

  22. Why Review? Wyoming Department of Education

  23. Off-site Assessment • Certification and Benefit Issuance • Question set 100s • Verification • Question set 200s • Meal Counting and Claiming • Question set 300s Wyoming Department of Education

  24. On-site Assessment • Certification and Benefit Issuance • Validate SFA’s Procedures from off-site assessment tool • Validate Student Certifications: Validate Benefit Issuance Document • Review Denied Applications • Verification • Determine compliance with Verification requirements • Meal counting and Claiming • Validate off-site assessment tool • Validate the counting and claiming process • Record errors Wyoming Department of Education

  25. Fiscal Action • Certification and Benefit Issuance. Why is Fiscal Action taken? • Applications missing information • Mis-categorization of certification • Benefit Issuance Errors • Failure to update verified applications • Verification • No fiscal action taken • Meal Counting and Claiming • Inaccurate meal counting or claiming • Counting 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 Education

  26. Meal Pattern & Nutritional Quality Meal Components & Quantities Offer vs. Serve Dietary Specifications & Nutrient Analysis Wyoming Department of Education

  27. Why do we review Meal Components & Quantities • Support Learning & Educational Achievement • Provide students with well-balanced meals • Combat childhood hunger • Nutrition Education • Teach students components of a well-balanced meal, variety • Stewardship of Federal $ • Ensure that meals reimbursed with Federal $$ contain required components Wyoming Department of Education

  28. Overview • Reviewer 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; and • Records for reimbursement only meals that contain required components in required quantities Wyoming Department of Education

  29. Meal Components & Quantities • Assess meal pattern compliance • Milk, Vegetable subgroups, whole grain rich requirements, etc • Review breakfast and lunch documentation for compliance • Menus/production records • Performance-based reimbursement documentation (USDA worksheets) • Week must be 3-7 consecutive days • Missing meal components/insufficient quantities: expand documentation review to (at least) entire review period Wyoming Department of Education

  30. Pre-visit Documentation Review • Production Records • By meal service line and age/grade group served • Support claims • Document what was served and leftovers • Food is creditable for portions served • Document that daily and weekly meal component requirements are met • Identify if seconds are offered regularly Wyoming Department of Education

  31. On-site Meal Service Observation • Prior to Meal Service • Will ensure all reimbursable meal lines offer all required components • Will observe meal preparation • During the Meal Service • Will observe % of meal service for each line • Will determine if meal contain components & quantities for age/grade group • Will ensure students have access to, and know how to select a reimbursable meal Wyoming Department of Education

  32. Offer vs. Serve The 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; and • Food 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 Education

  33. OVS: Pre-visit: Documentation Review • Review OVS Policy • Optional OVS Edit Check Total # of Food Components or Food Items Total # of Meals served Wyoming Department of Education

  34. OVS: On-site: Prior to Meal Service WDE CNP Determines whether: • Staff training has been conducted • Staff 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 students Wyoming Department of Education

  35. OVS: On-site: Meal Service Observation WDE 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 ½ 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 OVS Wyoming Department of Education

  36. Dietary Specifications & Nutrient Analysis - Overview • Determine if SFA is serving reimbursable meals according to Dietary Specifications • Calories • Saturated Fat • Sodium • Trans Fat • Determine 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 SFA Wyoming Department of Education

  37. Resource Management Maintenance of the nonprofit school food service account Revenue from non-program foods Indirect costs USDA Foods Wyoming Department of Education

  38. Off-site Assessment Tool Resource Management: Question set 700s • Maintenance of Nonprofit School Food Service Account • Questions 702 – 706 • Paid Lunch Equity (PLE) • Questions 707 – 710 • Revenue from Non-program Foods • Questions 711 – 712 • Indirect Costs • Questions713 – 714 • USDA Foods • Questions 715 - 717 Wyoming Department of Education

  39. Resource Management Risk Indicator Tool • State Agency conducts a risk assessment based on off-site assessment tool • 1-2 risk indicators  Technical Assistance and Corrective Action • 3 + risk indicators  USDA Comprehensive Review • All Resource Management monitoring areas • State agencies to consult with State USDA foods staff Wyoming Department of Education

  40. General Program Compliance Civil Rights Local Wellness Policy Food Safety Wyoming Department of Education

  41. Off-site Assessment Tool: Section V • Civil Rights • Question set 800s • SFA On-site Monitoring • Question set 900s • Local School Wellness Policy • Question set 1000s • School Breakfast and Summer Food Service Program Outreach • Question set 1600s Wyoming Department of Education

  42. Food Safety • General areas of review • Written food safety plan • Food safety inspections • Recordkeeping • Storage • State Agency to determine if regulatory requirements are being met • Corrective Action • Each area assessed at the site level • If all schools compliant, SFA compliant • Corrective action prescribed as necessary Wyoming Department of Education

  43. Civil Rights – Scope of Review Wyoming Department of Education

  44. Local Wellness Policy • HHFKA added new provisions • Changed content requirements • Required certain actions • LWP portion of administrative review changed to address HHFKA and FNS Memo SP 42-2011 • Deficiencies handled through TA only • No final rule • Limited implementation guidance • Assess progress and provide implementation suggestions • No LWP = Corrective Action • Complete Off-site Assessment tool questions Wyoming Department of Education

  45. General Program Reviews Fresh Fruit and Vegetable Program Afterschool Snack Program Wyoming Department of Education

  46. Off-site Assessment Tool: Section VI • Other Federal Programs • Indication of any additional federal programs that will be examined during the review • Afterschool Snack Program • Fresh Fruit and Vegetable Program • Special Milk Program Wyoming Department of Education

  47. FFVP Review • Three components to the FFVP review process • Establishing the FFVP review sample size (WDE) • Claim validation • One month’s claim is validated per site • Any month can be selected • Check status of administrative costs • FFVP meal service observation • Occurs at each FFVP site • Fiscal Action must be used to recover any payments in whole or in part, that is inconsistent with FFVP requirements Wyoming Department of Education

  48. Afterschool Snack Program: Evaluating Compliance • Reviewer will: • Determine if SFA retains final administrative and management responsibility for meeting all afterschool snack requirements • Assess compliance in the following areas: • Eligibility • Accountability/Meal Counting and Claiming • Meal Pattern/Production Records • Monitoring • General Areas Wyoming Department of Education

  49. Post Review Activities Wyoming Department of Education

  50. Post Review Procedures • Administrative Review Exit Conference • Administrative Review Report (i.e., Notification Letter of Review Results • Documented Corrective Action Wyoming Department of Education

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