Preparing for Your Reviews Debbie Calhoun, MS, RD, SNS School - - PDF document
Preparing for Your Reviews Debbie Calhoun, MS, RD, SNS School Meals Program Specialist OSPI Child Nutrition Services Hello! Welcome to OSPI's Annual Training, for SY 2020-21 This presentation is titled "Preparing for Your Reviews"
Debbie Calhoun, MS, RD, SNS School Meals Program Specialist OSPI Child Nutrition Services
Hello! Welcome to OSPI's Annual Training, for SY 2020-21 This presentation is titled "Preparing for Your Reviews" Introduce self... This is a recorded presentation, and therefore "live" questions will not be taken 1
Preparation for the Administrative Review The Procurement Review Process
During this presentation, we'll discuss: How best to prepare for your AR The PR process 2
How do I prepare? What are you looking for? What documents will be looked at?
What happens if you find something wrong?
What happens during a review? How long will you be here? What staff will you talk to? What schools will you visit?
We know you have lots of questions/concerns when you have an upcoming Administrative Review. READ SLIDE The purpose of this presentation is to share with you what to expect during an AR, and how best to prepare. Remember that we are all on the same team and have the same goal: Providing students the nutrition they need to learn and grow. We WANT you to be prepared and to know what to expect. 3
Now, to answer the big question: “How do I prepare for the Administrative Review?” The answer is: ORGANIZATION. Proper organization of the requested documents is the key to a smooth review and a more confident/prepared YOU. 4
Large amount of information Information constantly changing Ability to recognize where improvements can be made Ability to make corrections Quicker review
It’s not just about being organized for the purpose of the Administrative
efficient and manageable program in the long run. It will make every review that follows feel like just another day. As you probably all know by now,: a great deal of information must be processed to complete an Administrative Review. And without proper
doesn’t have to be this way – organization will really help! Whether it be changes in meal preferences for students or updated meal applications, the data you maintain in the school meal program is ever-
constant change. Proper organization also allows you to identify areas where improvements can be made, to identify errors and to make corrections. Lastly, to the benefit of us all, organized paperwork makes for a quicker review 5
– allowing us to spend more time with you addressing your concerns, rather than with our heads down in a pile of papers! 5
School Meals Administrative Review
Critical Areas General Areas
School Meals Administrative Review
Critical Areas General Areas
Let's begin by reviewing exactly what the AR contains. The AR is divided into two major categories: the Critical Areas and the General Areas. Let’s take a closer look at each of these areas. 6
Critical Areas
Meal Access and Reimbursement
Certification and Benefit Issuance Verification Meal Counting and Claiming
Nutritional Quality and Meal Pattern
Meal Components Dietary Specifications and Nutrient Analysis Offer vs Serve Performance Standard 1 Performance Standard 2
The Critical Areas are further divided into Performance Standard 1 and Performance Standard 2. (CLICK) PERFORMANCE STANDARD I - MEAL ACCESS AND REIMBURSEMENT: WE
MUST ENSURE THAT All free, reduced-price, and paid lunches claimed for
reimbursement are served only to children eligible for free, reduced-price, and paid lunches, respectively. We must also ensure that meals are counted, recorded, consolidated, and reported through a system that consistently yields correct claims. (CLICK) PERFORMANCE STANDARD 2 – MEAL PATTERN AND NUTRITION QUALITY: WE
MUST ENSURE THAT ALL Reimbursable meals meet meal pattern requirements
as applicable to the age group reviewed. 7
Benefit Issuance Documents (BID) Free and reduced-price meal eligibility Verification Meal counting Reliable System?
Let’s discuss each area in detail: Describe all items that will be requested during the review Talk about best practices for organizing/preparing your documentation READ BULLET POINTS 8
Need: Certification documentation for all names
The first area in Performance Area 1 is Certification and Benefit Issuance: The BID (Benefit Issuance Document) is a list of students receiving Free or Reduced price benefits in the district. We’re required to review a sample of these student’s certification documents, to verify that students are receiving the correct benefits. This list will be created prior to the review. We’ll validate ALL names on the sample BID list. Certification documents include: READ SLIDE. Let’s talk about each of these documents in greater detail. 9
Place in same order as BID Check, do they include:
Let’s discuss the Free & Reduced-Price Meal Applications: READ SLIDE Now let’s take a closer look at each of these items… 10
Must indicate FREQUENCY of each income listed!
Section 3: The names of all other household members – excludes students (whether the members of the household are related to each other or not) Income (in whole dollars) and how often the income is received. 11
IF applying based on income, an adult must provide the last four digits of their social security number OR mark the box that they do not have one 12
address.
What is Extended Eligibility? When one student is found on the Direct Certification list, and a sibling (or other shared household member) of that directly certified student does not also appear on the DC list, free meal eligibility (benefits) is extended to the sibling. These free meal benefits are extended for the remainder of the school year. …So, what do you need to do? You will need to show that the student who was not on the DC list lives at the same household as the directly certified student. You’ll need:
qualified student
linking ALL household members together at the same address. Attach this documentation to the DC screenshot
application” already received, containing ALL household members 13
What ideas come to mind for keeping this information well organized? 13
Household application including:
Copy of current documentation from DHS Indication as foster on DC list
To certify a foster child as eligible, you either need either: READ SLIDE 14
List of homeless or migrant student names SIGNED by homeless liaison or migrant coordinator Migrant students can now be identified on the DC list
To certify a Homeless student as eligible: READ SLIDE To certify a Migrant student as eligible: READ SLIDE 15
Copies of your Approval and Denial Letters All Denied Applications
Photo by Damian Gadal | CC BY 2.0Lastly, copies of your notification letters will be requested and ALL denied applications must be available for review. 16
Electronic Systems: Waiver of 2nd party confirmation review All Verification Documents
The next area in Performance Standard 1 is: Verification. Verification will be reviewed for the current school year unless the review takes place before November 15. Your program specialist will review all or select a sample of the verified applications to review depending on the number of applications verified. If you use an electronic system: Print/retain a copy of the Waiver of 2nd Party Confirmation Review with your verification documents. The waiver can be found on our OSPI‐CNS website: OSPI Instructions & Tools for Completing Verification ‐ Tool 7 If using an electronic system to select the sample size, double check the math! Round fractions up to the nearest whole number of applications. Verify only the required amount – no extra. READ Second Bullet 17
Double Check:
Math! Sample Size Selection method
READ SLIDE Math!! Sample Size: Round fractions up to the nearest whole number of applications. Verify only the required amount – no extra. And double check the sample type (focused, random). The OSPI‐CNS website contains a list of districts that had a nonresponse rate greater than 20% in the previous year. Districts on that list MUST conduct focused sampling. Please find our verification resources on our OSPI‐CNS website: Tool 1 can be especially helpful because it walks through each of the steps. 18
Contact family to collect information. Parent may need to come in and provide signature. Correct meal status if necessary. Just let us know when we arrive
READ TITLE: Don’t Panic!! If you find an error, that’s actually a good thing – you can correct the issue before we arrive! Some examples include:
family of change in meal status
adult from application to collect necessary information. Approving official may annotate necessary information, sign and date the application when modifications are made.
they must come in person to sign the application. 19
Must compile meal counts for month of review
for month of review
by category, for each day, at each site
The final area in Performance Standard 1 is Meal Counting & Claiming: The claim will be validated for the month of review (the month prior to the
Reviewed documentation includes: meal counts by category for each day and each site. This data is reviewed to support the claim. 20
Self-Check
Look for:
Mathematical errors Figures are not transposed/copied incorrectly Ineligible meals (adult meals/second meals) are not counted Accurate number of days are reported Counts compared with Attendance Factor / Attendance Adjusted- eligible Counts compared with enrollment / number eligible in each category To be confident in your meal counting and claiming documents, conduct a self- check. Ensure claim information is checked for: READ SLIDE 21
Revise claims if necessary. Let us know when we arrive.
READ TITLE: Don’t panic! If you find an error, that’s a good thing – you can correct the issue before we
Revise the claim if necessary to reflect the number of meals that should have been claimed. Document the entire process and explain what happened when we arrive. Remember, we’re only human! 22
The next major area of review is Performance Standard 2: Meal Components and Quantities. Once again, organization is the key here to being confident in your administrative review preparations! 23
Prior to the review, OSPI will select sites to focus the review on, and the sponsor will be informed of the site(s) selected. This is based on a USDA site selection process: the more sites a sponsor operates, the more sites OSPI will review. Some terms to remember when we talk about Performance Standard 2 include; Month of Review: the month prior to the onsite visit. Menus, production records, standardized recipes, and product statements from the month of review will be reviewed. Day of Review: the day that actual meal service is observed. What meals will be observed? Lunch: at all sites selected for review Breakfast: at 50% of sites selected for review Snack, Supper and/or Fresh Fruit and Vegetable Program would also be observed, if applicable 24
day
An entire month of documentation can be overwhelming... (CLICK) Please organize all menu documentation by day. To minimize our on-site review time, we want to be able to find things easily & quickly. All documentation should match the daily menu and be self-explanatory. Each day’s folder/binder of supporting documentation should contain: Production record 25
CN label/Manufacturer Specification for processed products. Product Formulation Statement/Label for whole grain products. Associated recipes or product documentation necessary to validate meal pattern.
separately
Each day’s folder/binder of supporting documentation should contain (cont.): Product documentation including: CN labels; product manufacturers’ formulation statements; and corresponding standardized recipes Alternate production records: ie. for a salad bar if maintained separately. Let’s review an example… 26
Monday Menu: Chicken Nuggets with Whole Grain Roll, Steamed Broccoli, Carrots, Apple Slices & Milk Folder or Binder should contain: Monday production record Associated product documentation including:
pattern for fruits & veggies.
READ MENU The organization of your corresponding documents should match this menu. READ Each page after this one should follow suit: Tuesday Menu, Production Record, Product Documentation; etc. Get creative to prevent duplication of efforts - for example: If a Whole Grain Roll is served multiple times during the month, create a page that states “Refer to Monday, May 1st for Whole Grain Roll documentation”. This method may also be used for Milk and Juice. It’s OK to include the milk label or other repeat items just once in the packet. We only need to validate the product and serving size one time. 27
Prior to meal service ask yourself:
Will Meal Pattern be met? Menu - Production Record - Product Documentation Check ‘General Areas’
During meal service:
Observe POS procedures Ensure all meals claimed for reimbursement are counted correctly
After meal service:
Collect a DOR Meal Count
You will feel more confident approaching an Administrative Review if you’ve conducted many self-checks: Go to the site(s) selected for review and conduct an on-site review:
PRIOR to service, to assess if meal pattern will be met.
service
reimbursable meal will look like that day
all meals are reimbursable
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Following Performance Standards 1 and 2, the remainder of the review consists of “General Areas” 29
On-site Reviews
READ SLIDE 30
during school hours.
pop-up sales.
Smart Snacks READ SLIDE Best practice: Create a binder of ALL foods sold throughout each selected school. A common misconception is that if these foods aren’t purchased by the foodservice department then they are not subject to Smart Snacks
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Develop a plan at the beginning of the year Numerous resources available – consider:
Professional Standards refers to the training requirements of School Nutrition Program staff. Best practice: develop a plan at the beginning of the year, to meet the annual requirements for each staff person. During a review, we will need to see that all foodservice staff have either completed training, or have planned to complete training by the end of the school
have already met expectations if you’ve developed a plan for all employees to complete training by the end of the year. There are many resources available to assist you in providing meaningful training to your staff. READ SLIDE. Remember, training should apply to an employee’s work duties. 32
Lastly, during an Administrative Review, all other federal programs offered at the sites selected for review will be reviewed. These include: READ SLIDE 33
Meal counts for entire month of review Menu for each day (may be included on meal count form) Product documentation to support menu items Day of Review observation
When a site of review operates the Afterschool Snack Program, review activities will
‐ Validating meal counts supporting the claim for the month of review ‐ Remember to check for point of service meal counting when gathering documents ‐ Menu for each day will be evaluated. Check: Were two different components
‐ Do you have product documentation for all items offered in the program ‐ Day of review observation will occur, meal service watched, point of service meal count taken 34
Most recent claim documentation Invoices supporting claim Product documentation to support any non-produce items Advertising materials Day of Review observation
READ SLIDE 35
Next, we’ll discuss the Procurement Review 36
A review conducted offsite by an OSPI CNS Program Specialist that looks at the procurement and purchasing activities of an LEA.
same year as the AR.
Because your program receives federal reimbursement for the meals you serve, you are “playing with” federal money and therefore, there are regulations attached. Ultimately it’s about getting the best prices and being good stewards of public funds – it is your tax dollars we are spending! 37
federal Child Nutrition Program regulations and government-wide procurement standards.
ensure Program integrity.
There are lots of sources of information that tell us what we need to do: CFRs (the federal Code of Regulations); RCWs (the Revised Code of Washington); FNS Policy Memos: and CNS Updates. The Procurement Reviews are designed to assist you in implementing all requirements that come your way. READ SLIDE
Nutrition Program regulations and government-wide procurement standards.
to LEAs to ensure Program integrity. 38
Image by Pixabay | CC0
The process takes a lot of “back and forth”. You can expect the review to last about two months (or possibly longer) from start to finish. READ SLIDE Details will be provided in the following slides. 39
back in September.
Sent to the Superintendent - explains what the review is and materials are needed: Procurement Plan Code of Conduct Vendor Paid List Completed Procurement Tool Off Site Cover Page
1st Step: Announcement Letter: READ SLIDE 40
conducts procurement transactions.
for all the Board Policies and Procedures pertaining to purchasing.
2nd Step: Return Materials – Procurement Plan: READ SLIDE 41
using federal funds.
for all the Board Policies and Procedures pertaining to a “Code
Return Materials – Code of Conduct: READ SLIDE 42
expenditures for the year of review in Program 98.
Business Services Department. Data is available in the accounting system.
Return Materials – Vendor Paid List: READ SLIDE 43
Return Materials – Procurement Tool: READ SLIDE 44
Contacts Local Purchasing Thresholds (if different from State or Federal Thresholds Information about group purchasing
Return Materials – Off-Site Cover Page: READ SLIDE 45
for the AR and PR
Invoices for Micro, Small/Informal, Formal purchases Quotes and contracts associated with the procurement for those purchases
3rd Step: Notification Letter READ SLIDE 46
Addresses anything that was
Return signature page
Superintendent.
Final Steps: Technical Assistance/Review Closed READ SLIDE 47
Think back to a previous Administrative Review, what are some things from this training you would like to focus on for your next review? What about for a Procurement Review? What would you like to bring forward to help prepare for your PR?
READ SLIDE 48
Preparation for the Administrative Review The Procurement Review Process
So, to summarize: READ SLIDE 49
Please email your Program Specialist. We are always willing to help and answer questions!
https://www.k12.wa.us/policy-funding/child- nutrition/child-nutrition-contacts
READ SLIDE https://www.k12.wa.us/policy‐funding/child‐nutrition/child‐nutrition‐contacts THANK YOU for your time & attention during this presentation! We sincerely appreciate your “flexibility in learning” during this pandemic. 50
READ SLIDE Professional Standards Credit Form - Please keep a copy or add it to your record to track them. 51
Preparing For Your Reviews Date: ________________ Key Areas: 3000 – Administration
3200 – Program Management – 1 hour
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