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Administrative Review (AR)

Overview

The U.S. Department of Agriculture’s (USDA) Administrative Review (AR) assesses School Food Authorities’ (SFA) administration of the National School Lunch Program (NSLP), School Breakfast Program (SBP), and other 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 the SFA's compliance with program requirements,
  • provide technical assistance,
  • secure any needed corrective actions, and
  • assess fiscal action, if applicable.
Materials below will assist SFAs in preparing for the AR. Additional information for each review area can be accessed under the Program Requirements tab on the left-hand side menu. Each SFA's review will be conducted by a Nutrition Program Consultant (NPC) and a Public Health Nutritionist (PHN) from the SNT at the State Agency (SA), the Wisconsin Department of Public Instruction (DPI). The NPC and PHN will be in contact and send supplementary materials 4-6 weeks prior to the scheduled AR.
 
All SFAs will be required to utilize the DPI SNT's School Nutrition Accountability Software (SNACS) to complete the AR process. Within SNACS, SFAs will complete the off-site questionnaire, upload corrective actions, and communicate with reviewers. A WAMS ID is required to access this system. More information will be provided when your SFA is scheduled for an AR.

Resources

Due to the COVID-19 pandemic, there are no ARs scheduled for SY 2020-21

 

AR Preparation:

 

 

Memo:

 

Administrative Review Areas

Performance Standard I: Meal Access and Reimbursement

Certification and Benefit Issuance (BI):

This section of the AR will:

 

Meal Counting and Claiming:

This section of the AR will:
  • assess the SFA's system to ensure accurate numbers of reimbursable meals claimed, by category (i.e., free, reduced price or paid)
  • ensure completion of monthly Edit Checks
  • assess the SFA’s written unpaid meal charge policy
  • review procedures for communicating the unpaid meal charge policy to all households and SFA staff as required annually (the policy content is at local discretion and will not be reviewed by the SA for approval)
Performance Standard II: Meal Pattern and Nutritional Quality

Meal Components and Quantities

This section of the AR will:
  • ensure that all meals claimed for reimbursement contain the appropriate components (or items at breakfast) and quantities, as specified in the NSLP and SBP meal patterns.
  • 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.
  • assess meal preparation to ensure standardized recipes are followed.
  • assess Offer versus Serve (OVS) understanding by observing meal service.
  • ensure signage is posted with the day's menu, showing students how to select a reimbursable meal.
Dietary Specifications and Nutrient Analysis
This section of the AR will:
  • assess compliance with the dietary specifications (calories, saturated fat, trans fat, and sodium), which can be found on the breakfast and lunch meal patterns. Some days meals may be higher in dietary specifications and other days may be lower, as long as the average during the week fits within the ranges.
Meal Compliance Risk Assessment Tool (MCRAT) and Dietary Specification Assessment Tool (DSAT)
These tools 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

Repeat Violations

  • 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 none of the grain items offered are 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 of 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, reviewed 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 (7 cents) may be turned off until immediate corrective action occurs. This may be turned back on once corrective action is submitted and satisfactory.
Resource Management

This section of the AR will review four areas integral to the financial health and integrity of each SFA’s school food service management. The monitoring areas include:

  • 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 in one of the four areas above, the SA will conduct a comprehensive review of that area.

Maintenance of the Non-Profit School Food Service Account

This area will:
  • ensure that all revenues and expenditures under the non-profit school food service account are allowable (i.e. necessary, reasonable, and allocable) and used only for the operation and improvement of school food service.
  • ensure that net cash resources do not exceed three months average operating costs.

Paid Lunch Equity (PLE)

This area will:
  • ensure that SFAs are in compliance with the PLE requirements for pricing paid student lunches.

Revenue from Nonprogram Foods

This area will:
  • ensure the proportion of nonprogram food revenue to total food service revenue is equal to or greater than the proportion of nonprogram food cost to total reimbursable meal food costs plus nonprogram food cost.
  • assess the completion of either the USDA Non-Program Food Revenue Tool or the DPI Non-Program Food Price Calculator, which assist SFAs in determining compliance with the non-program foods requirement (this tool is required to be run annually for SFAs that sell nonprogram foods beyond just adult meals and extra milks).
  • review adult meal prices to ensure the adult payments are sufficient to cover the overall cost of meals.

Indirect Costs:

This area will:
  • ensure that indirect costs are not charged to the non-profit school food service account, or Fund 50 (the food service account within WUFAR).
General Program Compliance

Civil Rights

This section of the AR will:

On-Site Monitoring

This section of the AR will:
  • ensure that each SFA with more than one school performs an on‐site review of each site operating NSLP, and 50% of the sites operating SBP (complete by February 1 annually).

Local Wellness Policy (LWP)

This section of the AR will:
  • assess the SFA's compliance with all LWP requirements.
  • ensure the LWP meets all content requirements
  • ensure the LWP has been reviewed, updated, made available to the public, and that a triennial assessment has been completed.

Professional Standards

This section of the AR will:
  • ensure that hiring standards for new food service directors are met (these standards went into effect in July 2015).
  • ensure that annual training standards for all school nutrition personnel are met.
  • assess required training trackers for all school nutrition personnel and other school staff with responsibilities related to the school meals programs (DPI tracking tool or USDA tracking tool).

Water

This section of the AR will:

Food Safety

This section of the AR will:
  • review the written food safety plan specific to each site and ensure it has been reviewed annually and updated.
  • determine if all foods are stored properly.
  • ensure two annual food safety inspections have been completed.
  • 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.

Buy American Provision

This section of the AR will:
  • ensure that each SFA has purchased domestic agricultural commodities or products that are produced and processed in the United States, in accordance with the Buy American Provision.
  • 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

This section of the AR will:
  • determine if reports are submitted, as required, and maintained for a period of three years plus the current school year (refer to calendar of requirements for more details).

School Breakfast Program (SBP) Outreach

This section of the AR will:

Summer Food Service Program Outreach

This section of the AR will:

Smart Snacks (All Foods and Beverages Sold in Schools)

This section of the AR will:
  • assess compliance with Smart Snacks requirements at all 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 (e.g. fundraisers, a la carte items, school stores, snack or coffee bars, vending machines, a home economics or special education classroom selling food, etc.).
  • 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).
Other Federal and State Program Reviews

Afterschool Snack Program

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 Program documentation for each school selected for the Administrative Review that operates the program.

Fresh Fruit and Vegetable Program

The Fresh Fruit and Vegetable Program (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 for the AR 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 is meeting the federal and state requirements as specified under Section 115.345 of Wisconsin Statutes.  

Wisconsin School Day Milk Program (WSDMP)

The operation of this state funded program will be reviewed to determine if the SFA is in compliance with rules under Wis.Stat. sec.115.343To meet WSDMP requirements, milk must be served at no cost to children in participating grades who meet the NSLP income guidelines for free or reduced price meals. Only grades pre-kindergarten through fifth are eligible to participate in the WSDMP. SFAs may use local discretion to determine which schools and eligible grades will operate WSDMP.

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 can 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.
  • ensure records used in the development of the ISP are maintained during the entire time the school is in CEP. In addition, 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

DPI must conduct Procurement Reviews (PR) of SFA purchases and awarded contracts, as outlined in USDA memorandum SP 45-2016. For more information on the PR, see the DPI Procurement Review webpage.
 
The PR is separate from the AR and does not follow the AR cycle and requirements.

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.

Contact

For questions related to any specific area of the AR, please see the DPI SNT Staff Directory.