Overview
The U.S. Department of Agriculture’s (USDA) Administrative Review (AR) assesses a School Food Authorities (SFA) administration of the National School Lunch Program (NSLP), School Breakfast Program (SBP), After School Snack Program (ASP), Fresh Fruit and Vegetable Program (FFVP), Seamless Summer Option (SSO), and other Federal or State school nutrition programs. The School Nutrition Team (SNT) has been approved for a five-year review cycle.
The objectives of the AR are to:
- Determine whether the SFA meets program requirements.
- Provide technical assistance and support for the program.
- Secure any needed corrective action and assess fiscal action, if applicable.
Resources
List of SFAs Scheduled for an AR in school year (SY) 2024-25
AR Preparation:
- AR Documents Needed 2024-25 SY
- AR Documents Needed Quick List
- AR Checklist - Meal Pattern
- AR Checklist - Smart Snacks
- AR Checklist - Fresh Fruit and Vegetable Program
- AR Process In A Nutshell
- 2024-25 SY AR and You Workshop Presentation
- Calendar of School Nutrition Program Requirements
- SNACS "How-to" Guides
- Benefit Issuance List In a Nutshell
Memo:
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AR in the School Nutrition Programs Final Rule, USDA, 07/29/16
Administrative Review Areas
Fiscal Action
Fiscal action is the recovery of improperly paid funds and is assessed when errors are found in the Performance Standard I: Meal Access and Reimbursement section (excluding verification errors) and the Performance Standard II: Nutritional Quality and Meal Pattern section. Fiscal action is not required for errors found in the General Program Compliance areas, unless repeated or egregious violations are not corrected.
A USDA fiscal action workbook is utilized to calculate fiscal action. The SA may disregard an overclaim, if it does not exceed $600 per program. SFAs that have an overclaim of $600 or more that must be reclaimed, may appeal using the appeal procedures for the Child Nutrition Programs.
Child Nutrition Program Integrity Rule - Follow-Up Reviews
- A five percent or greater certification and benefit issuance error rate.
- Incomplete verification for the review year.
- One or more significant or systemic errors in Performance Standard 1, including errors with certification and benefit issuance process and the accuracy of meal counting and claiming.
- One or more significant or systemic errors in Performance Standard 2, including meal pattern, nutritional quality and supporting documentation.
- One or more significant or systemic errors in allowable costs.
Follow-up reviews will include completing targeted oversight measures that address the high-risk area(s) within two school years from the most recent AR. Follow-up reviews may be conducted as a documentation review or an on-site visit.
If continued significant or repeat noncompliance is observed through the follow-up review, fiscal action may apply. In addition, SFAs with continued significant and/or repeat noncompliance will receive an AR more frequently than five years, until the SFA can demonstrate to the SA’s satisfaction that program requirements are met.Child Nutrition Program Integrity Rule – Fines for Violating Program Requirements
The U.S. Department of Agriculture (USDA) Child Nutrition Program Integrity Final Rule strengthened the administrative oversight of the National School Lunch Program (NSLP), School Breakfast Program (SBP), Afterschool Snack Program (ASP) and Special Milk Program (SMP) by including the ability of the State Agency to implement a fine for school food authorities (SFA) who have severe or repeated program violations that threaten the integrity of the Child Nutrition Programs.
The Department of Public Instruction (DPI) School Nutrition Team (SNT) may implement a fine if the SFA or a school under its agreement has:
- Failed to correct severe mismanagement of the NSLP, ASP, SBP or SMP;
- Disregarded a NSLP, ASP, SBP or SMP requirement of which the SFA or school had been informed; or
- Failed to correct repeated violations of NSLP, SBP, ASP and/or SMP requirements.
The WI DPI SNT has the discretion to use fines for other serious repeat findings if deemed appropriate and necessary to bring the program(s) into compliance. Fines will be imposed only after the DPI SNT has informed the SFA of the program violation and has provided technical assistance and requested corrective action previously.
The fine is calculated based on the amount of program reimbursement earned by the SFA or school in the most recent state fiscal year for which full year data is available.
- For the first fine, one percent of the amount of meal reimbursement earned for the fiscal year;
- For the second fine, five percent of the amount of meal reimbursement earned for the fiscal year; and
- For the third or subsequent fine, 10 percent of the amount of meal reimbursement earned for the fiscal year.
The DPI SNT will consult legal counsel to carefully consider whether a fine is the appropriate response for a situation. A fine is required to be paid with non-Federal funds, the nonprofit school food service account (Fund 50) cannot pay the fine.