preparing for a food service audit

Clare KeatingPreferred Meal Systems, Inc.

May 19, 2011

Illinois Association of School Business Officials 2011 Conference

How much is it going to cost us? How long is it going to take? How much work is it going to be? Who is going to do all this? When will it be over? No really, is it going to cost us?


Avoiding Fiscal Action during a Review Accurate Claims for Maximum Reimbursement


Illinois State Board of Education (ISBE) School-Based Child Nutrition Programs Administrative Handbook July 2010- updated Jan 2011› http://www.isbe.net/nutrition/sbn_handbook/toc.htm

ISBE (free) Workshops› NSLP Certification of Eligibility and Verification-

http://webprod1.isbe.net/cnscalendar/asp/EventList.asp › Basic Training Workshops

Meal Planning, Meal Counting, Claiming Watch website for dates and locations


CRE- Coordinated Review Effort› This is your Administrative Review

SMI- School Meals Initiative› This is your Nutritional Review

NSLP- National School Lunch Program SBP- School Breakfast Program TANF / SNAP- Temporary Assistance for Needy

Families / Supplemental Nutrition Assistance Program AAR- Additional Administrative Review

More acronyms defined in ISBE Administrative Handbook


A CRE Review is an Administrative review of all documents and procedures in federal meal programs. Monitors review eligibility documentation, meal counts and claims, menus, food quantities and serving sizes, and several other areas for compliance.

A CRE Review ensures that students eligible for meal benefits have access to meals that meet all regulations and are counted and claimed in the correct categories.

CRE’s are conducted once every three years. (*new HHFKA 2010)


Occurs When:› Eligibility Documentation is inaccurate

Direct Certification Household Income Applications Categorical Eligibility

› Meal Counting & Claiming Procedures are inaccurate

The most common errors are Application and Claiming Errors

• Household Eligibility Application determinations, including compliance with the completion of the Electronic Direct Certification process

• Benefit issuance• Meal-counting system• Claim consolidation• Menus Important Note: Critical area violations may result in a fiscal

assessment.– ISBE may waive the fiscal assessment if less than $600. – No waiver where substantial evidence of violations of

criminal law or civil fraud statutes exist.


Critical to revenue in NSLP and SBP’s› Errors in Household Income Applications and Direct

Certification cause the most fiscal action› Attending a workshop is strongly recommended!

ISBE Certification and Verification Workshop › July 26 Marion Williamson County Pavilion › July 27 Bloomington Doubletree › Aug 10 Schaumburg Courtyard Marriott › Aug 11 Kankakee Hilton Garden Inn


Changes in procedures and paperwork occur each year:› Attend a workshop annually!› Check ISBE website for new

documents Yearly Application- out with the

old- in with the new Updated Income Guidelines- July 1

› Read the Outlook for what’s new


Procedures Send out no earlier than 30 days prior to start

of school Process Applications Centrally

Family Applications may list several students in one district but in different schools

More control over the process- fewer hands, less training needed

Easier to maintain applications in one location Easier to identify students for extended benefits Monitors prefer


Direct Certification› Certification of SNAP/TANF benefits via Electronic Direct

Certification System Household Eligibility Applications

› SNAP/TANF application› Income application› Foster child application

Categorical Eligibility Homeless, migrant, runaway, or Head Start listing- *new HHFKA 2010- Foster child

Extension of Benefits to all other children in household


• Review Checklist with details of WHAT is being reviewed is found on pages 10-14 in the School Food Authority Reviews Section of the Administrative Handbook and online at http://www.isbe.net/nutrition/pdf/nslp_review_checklist.pdf

• Reviews are conducted via a cycle once every three years (*new, was every 5 years)

• Review Process1. Announcement letter to District Superintendent/Authorized

Representative2. Phone call to schedule on-site visit3. On-site visit (usually 1-3 days, depending on SFA size, *new regs

require longer, 1-2 weeks)4. Review report documenting review findings sent via mail5. If needed, the SFA must respond to citations via a Corrective Action

Plan• In the near future, review process will be electronic.


Talk to the Reviewer about documents to send prior to the review (Meal Edits) and school selection

Match Benefit Issuance documents to Applications (Arrange applications in the same order)

Review Applications for accuracy Use Review Checklist that comes with the

announcement letter Reserve a comfortable area with large table, ample

space and easy access to District rep Have meal times for school of review ready Be Prepared! Be Available during the review


Eligibility Determination› Applications not complete, SS#

missing, not signed› Math Errors› Incorrect SNAP/TANF numbers› Students approved in wrong

category ($$$) Extension of Benefits

› No documentation Verification

› Process is not complete for every application chosen for review.


Accurate Meal Counts are critical to claiming meals for reimbursements and receiving funding

Train Foodservice Staff › To understand and identify a reimbursable meal based on

chosen Menu Planning Option› To Ensure all meals are accurately counted and recorded

in the correct category Establish Internal Controls that reconcile

Production Records to Meals Counted


Eligibility Documentation› The SFA must have documentation to claim free or

reduce-price meals for reimbursement. Collection Procedures

› Steps must be in place for a medium of exchange that does not overtly identify students as free or reduced-price meals.

Point-of-Service Counts› Meals must be counted daily at that point in the food

service line where it can be determined a reimbursable meal has been served to an eligible student.


Reports› The number of reimbursable meals served daily, by

category of eligible students are recorded. › The SFA must evaluate the meal counts for each site prior

to submission of the Claim for Reimbursement through the Meal Count Edit Check.

Claim for Reimbursement› Submitted Electronically

Establish Internal Controls› Segregation of duties › On-site visits › Reconciliation of production records to meals


Paid Meals› *new- Meal Price must be greater than or equal to the

difference between the federal reimbursement rate for free meals and the federal reimbursement for paid meals. May increase 10¢ per year

Adult Meals› Must include Student Rate plus reimbursements and

commodity allocation. E.g. Student Price + .26 + .2275 = Adult Price

Pricing of Ala Carte Items› Prices should be set so as to NOT compete with the

reimbursable meal › * new- All non-reimbursable foods sold must generate

revenue at least equal to their cost.


Benefit Issuance› Not updated for changes from

verification or from the previous year’s application rolled over.

Meal Count Edits › Edits are not completed

monthly.› Problems noted are not

followed up.› Audit your FSMC for accuracy

Incomplete Meals Served


Application Errors- Inaccurate determination of student eligibility Claiming Errors- Incorrect meal counts and inaccurate claims Meal Count Edits – edits are not completed monthly. Problems noted are

not followed up Benefit Issuance – not updated for changes from verification or from the

previous year’s application rolled over. Verification – process is not completed for every application chosen for

review. Sanitation Reviews – less than two reviews are conducted per school year.

No documentation requesting review to the local health department. On site reviews – not completed by February 1st or 3 or more reviews are

completed on the same day by the same individual Production Records – not completed or did not list all food items available

in a given day including condiments. Wellness Policy- no evaluation of policy to determine how well it is

implemented Hazard Analysis Critical Control Points (HACCP) plan – Not following the

established plan or Standard Operating Procedures Offer versus Serve under food based menu approaches – directing the

student selections (entrée and milk).


Each School district will be scheduled for an SMI review at least once every five years. (*new HHFKA- 3 years)

ISBE (specifically the SMI reviewer) will inform the district in advance when the review is scheduled.

This notification will include:› What week will be selected for review;› What specific information you will need to provide.

Each school district chooses the school for review. An on-site visit is scheduled at a mutually agreed upon date

and time.


An SMI Review is a menu and nutritional review of the reimbursable school meals.

An SMI Review ensures that meals served under the NSLP and SBP meet the Dietary Guidelines for Americans and specific nutrient and calorie requirements for the age/grade level of the students you serve.

Nutritional analysis of a school week’s menu to ensure compliance with USDA-established standards for calories and other nutrients.

Conducted every three years (*new).

School week menu Production records Standardized recipes Nutritional information for products served (if Nu-Menu’s) nutrient analysis


Be sure Menus are planned according to regulations Update Standardized Recipes and be sure staff is trained

to follow them Collect Product Labels and Nutritional Information as

products are used Encourage students to take all components, especially

fruits and vegetables Choose a “Serve” school or one that most components

are taken Be sure Production Records are accurately filled out, no

food items are missing and portion sizes are correct.


Districts must have policy in place by January 2011.

Guidelines and resources on website http://www.isbe.net/nutrition/htmls/food_allergy_guidelines.htm


New Computer System to replace Child Nutrition ACES

Planned to release for School Year 2011-2012

Planned Changes› Application for program will be based on

school year – July 1 – June 30› Monthly Claim for Reimbursement will require

the submission of DAILY meals claimed (free, reduced-price and paid)

More information will be forthcoming!


Dietary Guidelines› Proposed Nutrition Standards for meal pattern

Final Rule Winter 2012 Milk- 1% or Fat Free

› School Year 2011-12 Potable Water

› Available at no charge to all children ASAP or SY 2011-12

Equity in Meal Pricing› Paid Lunch Price- July 1, 2011

Non-reimbursable meal foods sold› Revenue equal or greater than cost- October 1, 2010


CRE and SMI Reviews› Every 3 years, implementation date pending› Results must be posted

Community Eligibility Option› Phased in over several years, nationwide 2013-14

Categorical Eligibility for Foster Children, Oct 2010 Outreach to Eligible Families- Summer Food Service

› Printed or electronic notification of free meals, Oct 2010 Privacy Protection

› Supply last four digits of SS# on household applications, July 1, 2011 (updated application coming soon)


Local Wellness Policies/ School Nutrition Environment Reporting› TBD

Professional Standards for School Food Service› Required Education, training and certification› TBD

Program Evaluation› Full cooperation with USDA and contractors conducting

research- Oct 1, 2010 Food Safety Audits and Reports

› Report of two required food safety inspections› Food safety applied to entire school campus› Oct 1, 2010

preparing for a food service audit

Documents

isbe certification

meal benefits

federal meal programs

fiscal assessment

check isbe website

claiming procedures

verification workshop

fiscal actionattending