joyce soroka supervisor of field services. p.l. 108-265, section 126 changes in child nutrition...

Joyce Soroka

Supervisor ofField Services

P.L. 108-265, Section 126

Changes in Child Nutrition Program Law and RegulationsPennsylvania Department of Education, June 2005

Administrative Error ReductionAdministrative training and technical assistance

materials

State Agency School Food Authorities (SFA) Local Education Agencies (LEA)

Sec. 126 (a) provides funding to develop and distribute training and technical assistance materials at the Federal level with input from:

Materials will relate to improving: Program integrity Administrative accuracy Review of administrative practices of SFA


Administrative Error ReductionAdministrative training and technical assistance

materials

Sec. 126 (b) provides funding foradditional administrative reviews

Implementation date is July 1, 2005.

Beyond current CRE requirements

Performance criteria established by FNS - LEA demonstrates a high level of or high risk for administrative errors


Criteria established foradditional administrative reviews:

Determined based on an initial and/or first follow-up CRE review

Areas of review similar to CRE Review based on Performance Standard 1

Review only the administrative processes


Procedures may include: Applications

Certifications

Verification Meal counting

Meal claiming

Procedures not included: Menu & production record type finding

Nutritional content of foods offered to students


Additional administrative reviews

Correction process similar toCRE review process

Develop and carry out Corrective Action Plan

State Agency provides technical assistance

Conduct a follow-up review

Improperly paid funds may be recoveredChanges in Child Nutrition Program Law and Regulations

Pennsylvania Department of Education, June 2005

2004-2005 is the second year of the current 5-year cycle

2 Areas of Review-Critical and General

Critical Areas are based on Performance Standards

Problems found result in Performance Standards being exceeded


Coordinated Review Effort (CRE)

Free and Reduced Applications correctly approved

Meals counted and claimed accurately which consistently yield correct claims:

At the Point of Service by category on the Day of Observation

Meal consolidation for the Review period


Critical Area – Performance Standard 1:

Menu meets food item requirements for

Day of Observation

Meals observed contain required food items for all lunches claimed

Review period

Review of menu determines that food items are offered as required


Critical Area – Performance Standard 2:

Incorrect determination of Free or Reduced benefit

Errors in counting and claiming system

Threshold exceeded by building

10% or more of meals observed missing food items


Review thresholds only for critical areas due to:

Performance Standard 1:

Performance Standard 2:

Possible Fiscal Action for errors found:

$600.00 disregard for Overclaim per Program

$25.00 disregard for Underclaim per Program


Corrective Action needed for problems found

Nutrient analysis done for one week of menus in Review Period based on:

Menu Records

Standardized Recipes

Production Records

Manufacturer Product Information Sheets


School Meals Initiative (SMI)

Results compared to USDA Nutrition Standards for age/ grade groups

Advisor does re-analysis, if needed, and suggests correction to meet the Nutrition Standards

Corrective Action written for exceeding the thresholds established for:

Total Fat Saturated Fat Calories Protein

Vitamin A Vitamin C Iron Calcium


School Meals Initiative (SMI)

Common Problem Areas – Coordinated Review Effort

In computerized Point of Sale systems SFA’s need to provide the list of students eligible from the computer system to ensure data entry is input accurately from determining officials benefit issuance list

Free and Reduced Applications and Benefit Issuance Lists

In SFA’s using software programs to determine eligibility someone needs to ensure accurate determinations are used for income


Every 2 weeks 2.15Twice monthly 2.0, Weekly 4.33,

Meals counted and claimed accurately which consistently yield correct claims at the Point of Service by category on the Day of Observation Computerized System not working during

observation of meal service and no adequate back up system in place for accurate meal counting

Claiming newly enrolled children in the free category until an application is submitted



Students are not required to use the system such as entering their PIN; lunch is entered into the system as “No ID Cash.” No check in place that this is not a second lunch for the student.

Written charge meal policy not followed

Claiming charged lunches when paid not when served


Meals counted and claimed accurately which consistently yield correct claims at the Point of Service by category on the Day of Observation (continued)


Meal consolidation for the test month:

Math errors found in non-computerized systems



Not many problems unless one of the food items becomes unavailable during lunch service


Critical Area – Performance Standard 2

Under Reauthorization

Household applications are required

Errors in determination will be applied to all children in the Household

Not just the children in school buildings reviewed


Milk Requirement

Requires that lunches served include fluid milk in a variety of fat contents. Schools are encouraged to offer children low fat (1%) and fat free milk. Other types of milk may be offered.


Common Problem Areas – General areas of review

Verification No change in benefit issuance list

based on changes for applications

Adequate number of applications not verified

Not all income listed on the application is verified

No documentation available of how verification determination was madeChanges in Child Nutrition Program Law and Regulations

Pennsylvania Department of Education, June 2005

No comments when computerized system is utilized

No comments when edit checks exceed number eligible children times attendance factor by category

Not completed by Feb 1


Edit Checks

Monitoring


Alternative Ed sites either not listed as a separate site or if they are, separate records are not maintained

Correct/change Menu planning option not reported

Implementation of Offer versus Serve not on Application

Foods of Minimal Nutritional Value

Unequal choices offered in Offer versus Serve


Record keeping

Few problems with:


Records are incomplete or do not exist. This results in a follow-up review.

Total fat exceeds 30%

Saturated Fat exceeds less than 10%

Lunches are low in calories

Lunches are low in iron

Lunches are low in Vitamin A

Food Service Directors are unable to answer the Nutrition Education Questions

Common Problem Areas –School Meals Initiative Reviews


joyce soroka supervisor of field services. p.l. 108-265, section 126 changes in child nutrition...

Documents

child nutrition program

review period changes

review period review

administrative errors

followup review

cre review process

required changes

technical assistance