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Preparing for your Administrative Review (AR)

The U.S. Department of Agriculture’s (USDA) Administrative Review (AR) replaces the Coordinated Review Effort (CRE) in assessing School Food Authorities’ (SFA) administration of the National School Lunch Program (NSLP), School Breakfast Program (SBP), and other school nutrition programs. The AR is a three year review cycle, starting July 1, 2013.

The following information includes school year (SY) 2018-19 materials to assist in preparing for the AR. Your assigned reviewer will be either a Nutrition Program Consultant (NPC) from the State Agency (SA), Wisconsin Department of Public Instruction (DPI), or a TCB Consulting reviewer, from the contract company TCB Consulting. This company has been contracted to assist in the completion of ARs throughout the state. Either reviewer will send supplementary materials following the scheduling of your review.

Included below are preparation resources including training webcasts, Power Points, and an overview of the areas that will be reviewed. Additional information can be accessed by visiting the specific webpage associated with each review area.   

 Use the hyperlinks below to access overview sections of the AR



Performance Standard I: Meal Access and Reimbursement

Fiscal action assessed for error in this section

Certification and Benefit Issuance

This section of the AR determines if all free, reduced-price and paid meals claimed for reimbursement are served only to children eligible for free, reduced-price and paid meals, respectively. It also assesses if meals are counted, recorded, consolidated and reported accurately through a system which consistently yields correct claims.

To assess compliance the SA will:
  • Review the Benefit Issuance documents for all schools in the SFA.
  • Review all free and reduced-price students, or a statistically valid sample.

Household Applications

The SA will assess the SFA's procedures for processing applications by reviewing the use of proper income conversion factors and income guidelines; the carryover of prior year eligibility; compliance with required timeframes for household notification(s); compliance with the independent review of applications (if applicable), and review of denied applications.

Direct Certification (DC)

The SA will assess the SFA's procedures for DC by reviewing whether documentation was obtained from the appropriate agency, contained all required elements, and was obtained the appropriate number of times designated by USDA.

Meal Counting and Claiming

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).

Unpaid Meal Charge Policy

Beginning July 1, 2017 an SFA participating in the NSLP or SBP must have a written unpaid meal charge policy that is communicated to all households and staff responsible for enforcement within the SFA, annually.

To assess compliance the SA will:
  • Request a copy of the SFA’s written unpaid meal charge policy; and
  • Review procedures for communicating the policy to all households and SFA staff as required annually. The policy is local discretion and will not be reviewed by the SA for approval

Verification

Fiscal Action is not assessed for errors in the verification process

Verification is a process to confirm selected students’ eligibility for free and reduced-price meals in the NSLP and SBP. The SA will verify if the SFA is in compliance with verification requirements (7 CRF 245.6a).

To assess compliance the SA will review that the SFA:  
  • Selects the correct verification sample size;
  • Conducts verification appropriately;
  • Completes the Verification Collection Report in a timely manner;
  • Appropriately identifies a verification official and confirming official, if applicable;
  • If applicable, has an electronic system that accurately pulls the correct verification sample size and application type;
  • Has a verification notification letter and notice of adverse action that meets all Federal requirements; 
  • Appropriately attempted to follow-up with unresponsive households selected for verification;
  • Made changes in eligibility status within prescribed timeframes; and
  • Completed the verification process by November 15.
  • Verification webcasts 

Performance Standard II: Nutritional Quality and Meal Pattern

Fiscal action assessed for errors in this section

Meal Components and Quantities

Meals claimed for reimbursement must contain the appropriate components (or items at breakfast) and quantities, as specified in the NSLP and SPB meal patterns. During the AR, the state agency will assess:
  • Documentation including production records, menus, standardized recipes, Child Nutrition (CN) labels, Product Formulation Statements (PFS) from a week's menu to ensure compliance with meal pattern requirements for the specific age/grade group;
  • Meal preparation to ensure standardized recipes are followed;
  • Offer versus Serve (OVS) understanding by observing meal service, and
  • Signage is posted with the day's menu, showing students how to select a reimbursable meal.

Fiscal Action

  • Repeat violations involving the following will be subject to fiscal action: missing vegetable subgroup(s), missing milk variety or unallowable milk type, insufficient quantities to meet daily and/or weekly minimum requirements of any components, and all grain items offered are not whole grain-rich. Repeat violations are determined at the SFA level and are not site specific. Findings prior to the 2013-14 SY are not subject to fiscal action.
  • Missing components during the week or review or on the day of review will also be subject to fiscal action.
  • Fiscal action for central/satellite kitchens and/or district-wide menus will be assessed for all sites, review or non-reviewed, in which the non-reimbursable meals were served.
  • Fiscal action may be applied for violations involving calories, saturated fat, sodium, and/or trans fat. Fiscal action is limited to the school selected for the targeted menu review.
  • For severe non-compliance, a district's performance‐based cash assistance (6 cents) may be turned off until immediate corrective action occurs. This may be turned back on once corrective action is submitted and satisfactory.

Offer versus Serve (OVS)

OVS allows students to decline some of the food components (or items at breakfast) offered. At lunch, students must select three different and full food components, one of which is 1/2 cup fruit and/or vegetable or a combination. At breakfast, students must select at least three food items, one of which is 1/2 cup fruit and/or vegetable or a combination.

Dietary Specifications and Nutrient Analysis

The Dietary Specifications are calories, saturated fat, trans fat, and sodium. Meals are based on a weekly average of the dietary specifications, which can be found on the breakfast and lunch meal patterns. This means that some days meals may be higher in dietary specifications and other days may be lower; just so that they average out to fit within the ranges. 

Meal Compliant Risk Assessment Tool (MCRAT) and Dietary Specification Assessment Tool (DSAT)

  • Will be completed via a phone call with a Public Health Nutritionist.
  • MCRAT - gathers more information about how service is operated and will determine breakfast sites to review if multiple sites are selected (only need to review breakfast at 50% of the sites selected).
  • DSAT - assesses compliance with the dietary specifications.
    • If a school is found to be low-risk, an on-site review to verify compliance will be conducted. A nutrient analysis may not be required.
    • If a school is found to be high-risk, a nutrient analysis for breakfast (if applicable) and lunch for each age/grade group and menu type is required.

For production record, standardized recipe, signage, cycle menu resources, and meal component information, visit the Menu Planning Webpage

Resource Management

This section consists of a review of four areas integral to the financial health of the SFA’s school food service.  The monitoring areas are:

  • Maintenance of the Nonprofit School Food Service Account
  • Paid Lunch Equity (PLE)
  • Revenue from Non-Program Foods
  • Indirect Costs

A Resource Management Risk Indicator Tool will be completed for each SFA to target the review areas where risk is indicated. If a risk indicator is identified, the SA must conduct a comprehensive review of the area where risk was indicated. 

Note: If the Resource Management Risk Indicator Tool is not completed prior to the on-site visit, USDA mandates a comprehensive resource management review of all monitoring areas to automatically take place.

Maintenance of the Nonprofit School Food Service Account

The SA must ensure that revenues and expenditures under the nonprofit school food service account are necessary, reasonable, and allowable (i.e., used only for the operation and improvement of the school food service) and that net cash resources do not exceed three months average operating costs.

Paid Lunch Equity (PLE)

The SA must ensure that SFAs are in compliance with the PLE requirements for pricing paid student lunches.

Revenue from Nonprogram Foods

The SA must ensure that revenues from the sale of nonprogram foods (such as ala carte, vending machines, second entrees) generate at least the same proportion of total school food service account revenues as expenses from the purchase of nonprogram foods contribute to total school food service account food costs.

Either the USDA Non-Program Food Revenue Tool or the DPI Non-Program Food Price Calculator can assist SFAs in determining compliance with this requirement and is required to be run annually.

In addition, the SFA must price adult meals so the adult payments are sufficient to cover the overall cost of meals.

Indirect Costs

DPI does not allow the annual assigned indirect cost rate to be applied to Fund 50 (Foodservice account within WUFAR). For both public and private schools in Wisconsin, any costs assessed to foodservice must be based on documented and justifiable costs for each school building as they pertain to your school situation rather than on the indirect cost rate. This could include items such as utilities, rent, printing and mailing services, administrative oversight, etc. The DPI Nutrition Program Consultant will ensure that indirect costs are not being charged to the nonprofit food service account.

For more information on resource management, visit the Financial Management webpage.

General Program Compliance

Civil Rights

The SA must assess whether the SFA is complying with civil rights requirements as applicable to the Child Nutrition Programs including:

  • Submitting a public release to notify the public of program participation.
  • Process and procedures for handling Civil Rights complaints.
  • Annual staff training on Civil Rights.
  • Process for collecting racial/ethnic data (form PI-1441).
  • Procedures for accommodating students with special dietary needs.
  • Correct non-discrimination statement on program materials.
  • “And Justice For All” Poster is displayed in a prominent location where meals are served.
  • Services offered to Limited English Proficient (LEP) households.
  • All children receive equal benefits without discrimination.

SFA On-Site Monitoring

The SA must determine whether each SFA with more than one school performs no less than one on‐site review of the National School Lunch Program counting and claiming system in use in each school under its jurisdiction by February 1 of each year.  Necessary follow up is required for non-compliance findings during these internal monitoring reviews

On-site monitoring is required for the School Breakfast Program (SBP). A minimum of 50% of schools participating in the SBP must be monitored annually by February 1, with each school operating the SBP being monitored at least once every two years.

Local School Wellness Policy

To help foster a healthy school environment, the Healthy, Hunger Free‐Kids Act requires each SFA to establish a comprehensive Local School Wellness Policy. The SA will assess whether the:
  • Local School Wellness Policy contains the required elements including:
    • Goals for nutrition education, physical activity, nutrition promotion and nutrition guidelines for all foods available on the school campus.
  • SFA has taken the required steps regarding implementation, transparency, public input and availability.
  • Wellness policy has been reviewed and updated and triennial assessment has been completed.

Smart Snacks (All Foods and Beverages Sold in Schools)

The SA must assess compliance with Smart Snacks requirements at all the schools selected for review. The requirements apply to all entities selling foods and beverages to students on the school campus during the school day, which includes entities operating independently from the school food service.

Examples of areas where smart snack standards apply: fundraisers, a la carte items, school stores, snack or coffee bars, vending machines, a home economics or special education classroom selling food, etc. If multiple age/grade groups are in the same building, beverage standards must meet requirements for the youngest age/grade group. All food must meet one of the general standards and all of the nutrient standards. View the Smart Snacks In a Nutshell for more information.

To assess compliance the SA will:
  • Examine foods and beverages sold outside of a reimbursable meal during the week of review. Smart snacks documentation may include product labels (nutrition facts label and ingredient list), Alliance for a Healthier Generation Smart Snack Calculator print outs showing compliance, or Recipe Analysis Tool printouts for products made in-house.
  • Interview school district staff (e.g., superintendent, principals) and school food service staff to understand the food and beverage sales at the reviewed school(s). 

Note: Schools that receive a HealthierUS Schools Challenge (HUSSC) Award (any level) by meeting the HUSSC criteria effective August 31, 2014, have been certified compliant with these requirements, therefore, are exempt from this part of the review.  

Visit the Smart Snacks webpage for more information.

Professional Standards

Beginning July 2015, hiring standards were established for new school nutrition program directors at the SFA and annual training standards for all school nutrition personnel.

To assess compliance the SA will:
  • Review documents to confirm education and experience qualifications were met and food safety training has been completed for new food service directors hired after July 2015.
  • Review documentation of annual job-specific training received by each school food service employee.  It is strongly recommended to use the DPI or USDA tracking tool to ensure all the required information is available upon review.

Water

The goal of the water review is to ensure that children have unrestricted access to water during the lunch and breakfast meal services. During the on-site visit, the SA must observe and assess whether the school makes free water available to students as required. 

Food Safety

To assess compliance the SA will:
  • Review the written food safety plan specific to each site and ensure it has been reviewed annually and updated, if needed.
  • Determine whether the SFA has any contracted or self-operated warehouses and, if so, determine whether all foods (commercial and USDA) are being stored properly.
  • Determine if two annual food safety inspections have been obtained.
  • Confirm the posting of the most recent food safety inspection report at the serving site in a publicly visible and readable location.
  • Verify compliance with HACCP principles and local and state health standards.
  • Check temperature logs to ensure proper recordkeeping.
  • Examine on‐site food storage for dates and condition of foods.

Buy American

Each SFA is required to purchase domestic agricultural commodities or products that are produced and processed in the United States.  Limited exceptions exist when products are prohibitively costly or not available in required quantities. To assess compliance the SA will:
  • Check food labels in all food storage facilities at reviewed schools, including warehouse storage facilities, if applicable.
  • Ensure contract and solicitation language includes the requirement to purchase domestic agriculture products.
  • Review tracking system for non-compliant agriculture products and documentation to certify products are of domestic origin.

Reporting and Recordkeeping

The SA must determine if reports are submitted, as required, and maintained with other Program records for a period of three years after submission of the final claim for reimbursement for the fiscal year.

School Breakfast Program (SBP) Outreach

SFAs must inform eligible families of the availability of reimbursable breakfasts served under the SBP. The goal is to determine if the SFA conducts the required outreach activities to increase participation in the SBP.

Summer Food Service Program Outreach

SFAs must inform eligible households before the end of the school year of the availability and location of meals offered through the Summer Food Service Program (SFSP).

Other Federal and State Program Reviews

Afterschool Snacks

The SA’s review is intended to ensure participating schools serve students snacks that comply with USDA requirements, provide appropriate activities, and count and claim snacks accurately. The SA must examine afterschool snack documentation for each school selected and that operates the snack program.

Fresh Fruit and Vegetable Program (FFVP)

FFVP aims to increase children’s exposure to and consumption of a variety of fruits and vegetables. The review of the program is to ensure that participating schools are proper stewards of federal funds and operate the program as prescribed by USDA.

Special Milk Program (SMP)

The SA must examine SMP documentation for each school selected that participates in the SMP. The SA must evaluate the pricing policy, counting and claiming, milk service procedures and record keeping, if applicable. 

Elderly Nutrition Program

An assessment will be made to determine if the SFA choosing to participate in this program are meeting the federal and state requirements as specified under Section 115.345 of Wisconsin Statutes.  

Wisconsin School Day Milk Program (WSDMP) (state funded program)

The operation of this state-funded program will be reviewed to determine if the SFA is in compliance with rules under Section 1741s of the 1987 Wisconsin Act 27 and amended by 1991 Wisconsin Act 39 and 2001 Act 16. To meet requirements, milk must be served at no cost to children in grades pre-kindergarten through five at a milk break who meet the NSLP income guidelines for free and for reduced price meals. Annual claims may only be submitted for the milk served to these eligible students.

Special Provisions: Community Eligibility Provision (CEP)

 
If a CEP school is under review, the SA must: 
  • Review the certification documentation used to determine the Identified Student Percentage (ISP) and claiming percentages that were submitted for the latest ISP approval to operate CEP. This may include direct certification lists, documentation for extension of eligibility, and lists from homeless/migrant liaisons;
  • Review the meal counting and claiming system to verify correct claiming percentages were properly applied to claims for reimbursement; and
  • Ensure records used in the development of the ISP are maintained during the entire time the school is in CEP. This documentation must be retained for 3 years after submission of the final Claim for Reimbursement for the last fiscal year of CEP. 

Procurement Review (Separate from the AR)

The New Procurement Review (PR)

  • DPI must conduct Procurement Reviews (PRs) of SFA purchases and awarded contracts as outlined in USDA memorandum SP 45-2016.
  • PRs will utilize DPI-developed Procurement Review Form to start the PR and gather applicable information and documentation. Additional Procurement Review Checklists will be used to conduct the PR. The SFA will receive a PR Closeout Report with results.
  • The PR no longer follows the same cycle as the AR. The SFA may or may not receive a PR in the same year its AR.The SNT will try to schedule the PR on a different date and time from the AR. However, some PRs may occur right after the AR.
  • The PR cycle ranges from three to five years depending on the type of agreements held by the SFA and other factors. Examples of types of agreements include: Food Service Management Companies (FSMC), Vended Meals, Joint, School Cooperative, and Group Purchasing Organization.
  • Most PRs will be offsite, but some PRs will be onsite due to the number or complexity of awarded contracts and purchases.
  • SFAs may be asked to provide documentation showing they purchased products and services using competitive procurement methods and practices that provide open and free competition for program-related expenses.​​​
  • Documentation may include:
    • Requests for Proposals (RFPs)
    • Competitive sealed bids
    • Bid awards
    • Price quotations
    • Price comparisons
    • Product specifications
    • Code of conduct
    • Contract management
    • USDA Foods awards and crediting

DPI Procurement Review webpage

DPI USDA Foods webpage