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Preparing for your Administrative Review

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 you in preparing for your AR. Your assigned reviewer, either a Nutrition Program Consultant (NPC) from the Wisconsin Department of Public Instruction (DPI), also referred to as the State Agency (SA), or a TCB Consulting reviewer, who has been contracted to assist in the completion of ARs throughout the state, will send supplementary materials following the scheduling of your review. Also included are preparation resources, training webcasts, PowerPoints 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 different overview sections of the AR.



Performance Standard I: Meal Access and Reimbursement (Fiscal Action assessed for errors 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; and are counted, recorded, consolidated and reported through a system which consistently yields correct claims. The SA will:

  • Review the Benefit Issuance documents for each school in the SFA, not just the schools selected for the Administrative Review.
  • Review all free and reduced-price students or a statistically valid sample.

Household Applications

To assess the SFA’s procedures for processing applications, the SA will review 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), review of denied applications, etc.

Direct Certification

To assess the SFA’s procedures for Direct Certification, the SA will review whether the Direct Certification 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 SFAs participating in the NSLP and SBP must have a written unpaid meal charge policy that is communicated to all households and staff responsible for enforcing it within the SFA annually. The SA will:

  • Request a copy of the SFA’s written unpaid meal charge policy
  • 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 (Note: Fiscal Action is not assessed for errors in the verification process)

Verification is a process used by SFAs 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) and will review the following:  

  • SFA selects the correct verification sample size.
  • Conducted verification appropriately.
  • Completed the Verification Collection Report in a timely manner.
  • Appropriately identified 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.
  • Did the SFA’s verification notification letter and notice of adverse action meet all Federal requirements?
  • Did the SFA appropriately attempt to follow-up with unresponsive households selected for verification?
  • Were changes in eligibility status due to verification made within prescribed timeframes?
  • Was the verification process completed by November 15?

Resource:

Performance Standard II: Nutritional Quality and Meal Pattern (Fiscal Action assessed for errors in this section)

Meal Components and Quantities

The scope of the review for this section is to establish that meals claimed for reimbursement contain the appropriate components and quantities, as specified in the meal pattern for the SBP and the NSLP.

  • Meal preparation for breakfast and lunch will be observed to ensure standardized recipes are followed.
  • Visual observation of meal service lines on the day of review.
  • Documentation review of meal components/quantities for each school selected for the AR including production records, menus, recipes, food receipts, CN labels, standardized recipes, etc.
  • A distinct menu worksheet from the USDA Menu Planning tool for Certification for Six Cent Reimbursement for each age/grade group, and separate menus for breakfast and lunch will be completed by the SA or SFA.
  • Ensure that signage is posted and students know how to select a reimbursable meal.

Fiscal Action

  • Fiscal action is required when a meal component is missing.
  • Fiscal action involving vegetable subgroups, milk type violations, food quantities and whole grain rich foods will apply for repeat violations

Note: “Repeated violations” are:

  • Determined at the SFA level and are not school specific.
  • Defined from one administrative review to the next.  Any findings prior to the 2013-2014 SY AR do not result in initiation of fiscal action.

Performance‐Based Certification Funding (6 Cents)

In addition to the above fiscal action, SFAs performance‐based cash assistance (6 cents) may be turned off unless immediate corrective action occurs.  This will be turned back on once corrective action occurs.

Offer versus Serve

“Offer versus Serve” is a provision in the NSLP and SBP that allows students to decline some of the food components/items offered.  If the SFA implements Offer versus Serve, the SA must consider if:

  • The school is offering sufficient quantities of food on all reimbursable meal service lines.
  • Signage is posted on the service line to assist students in identifying a reimbursable meal.
  • Students are selecting at least three food components in the proper portion sizes to make a reimbursable  lunch and at least three menu items for a reimbursable breakfast.
  • Students are selecting at least a ½ cup of either the fruit or the vegetable component (or a combination of both) for lunch and breakfast for a reimbursable meal.
  • Food service staff or designated meal monitors at the point‐of‐service are trained and accurately recognize a reimbursable meal, including appropriate portion sizes.

Dietary Specifications and Nutrient Analysis

The Dietary Specifications and Nutrient Analysis section assesses whether meals served to children through school meal programs are consistent with federal standards for calories, saturated fat, sodium, and trans fat.

  • A  Meal Compliance Risk Assessment Tool will be completed for each reviewed school.
  • Based on results, one school is subject to a targeted menu review to include review of:
    • Menus
    • Production records
    • Standardized recipes
    • Crediting documentation (including product formulation statements, CN labels, USDA Foods Fact Sheets, etc.
    • Nutrition facts labels

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.

Fiscal action could be applied for repeat violations involving calories, saturated fat, sodium, and/or trans fat. Fiscal action is limited to the school selected for the targeted menu review.

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.

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 in School (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, including entities operating independently from the school food service. The SA will:

  • Examine one week of menu documentation from the review period to ensure that foods and beverages sold a la carte during meal services are compliant with requirements.
    • Examples of acceptable documentation may include, but are not limited to, menus, production records, USDA Food Information Sheets and related materials (e.g., CN Labels, food item specifications, standardized recipes) for the school week under review.
  • Interview school district staff (e.g., superintendent, principals, or other administrative designees) and school food service staff to understand the scope of food and beverage sales at the reviewed school(s), including the number of exempt fundraisers, and sales of foods and beverages in the cafeteria, school stores, snack bars, coffee bars, vending machines, and any other food or beverage points of sale available to students.
  • Review nutrition documentation of foods and beverages sold in schools (reimbursable meals excluded) to ensure that Smart Snacks requirements are met.  Reviewers must obtain the nutrition documentation from the entities responsible for each point of sale, which may include entities outside the school food service. The 10% sample selected for documentation review must represent all locations where foods and beverages are sold to students. Any documentation that contains the necessary information is acceptable; examples include, but are not limited to, Alliance for a Healthier Generation Smart Snacks Calculator print outs, recipes, product specifications, purchase orders, receipts, or other documentation. 

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.  

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 evaluate compliance, the SA will review the following:

  • 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 the labels on the foods in all 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 for monitoring this area 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 for the Administrative Review that operates the snack 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 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 can include direct certification lists, documentation for extension of eligibility, and lists from homeless/migrant liaisons.
  • Meal counting and claiming system will be reviewed to verify correct claiming percentages were properly applied to claims for reimbursement.
  • 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 (Separate from AR)

The New Procurement Review

  • 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. Addition Procurement Review Checklists will be used to conduct the PR. The SFA will receive a PR Closeout Report with results of the SFA's PR.
  • The PR no longer follows the same cycle as the Administrative Review (AR). As a result, the SFA may or may not receive a PR in the same year it receives its 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: FSMC, Vended Meals, Joint, School Cooperative, and Group Purchasing Organization.
  • 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.
  • Most PRs will be offsite, but some PRs will be onsite because of the number or complexity of the awarded contracts and purchases.
  • If the SFA is reviewing a PR, the 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 examples 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