Slide 1 Welcome to Meal Counting and Claiming training presented by - - PDF document

Slide 1

School Nutrition Programs (SNP)

Welcome to Meal Counting and Claiming training presented by Oregon Department of Education Child Nutrition Program. Slide 2

• Importance of Meal Counting and Claiming
• Elements of a Meal Counting and Claiming

System

• Site Monitoring
• Acceptable Systems
• Timely and Accurate Claims

2

This training will give guidance to assure that an Accurate Counting and Claiming System is in place. We will discuss:

• The Importance of Meal Counting

and Claiming

• Elements of a meal counting and

claiming system

• Site Monitoring
• Acceptable systems
• And Timely and Accurate Claims

In this presentation we will discuss the framework that will help systems to

• perate effectively.

Slide 3

• Federal reimbursement is provided for each

meal

• meets program requirements
• served to eligible students
• Must accurately count, record, and claim
• Must have adequate documentation on file to

support claim

3

(click) Federal reimbursement is provided for each meal (free, reduced- price and paid) that meets program requirements and is served to an eligible student. (click)To obtain this reimbursement, school personnel must accurately count, record and claim the number of meals actually served to students by

• category. Reimbursement rates are

different for each category of meal benefit (free, reduced-price and paid, and for each type of meal served (lunch and breakfast). Therefore, accurately counting, recording and consolidating the number of meals served by category is the only way a claim for reimbursement can be properly submitted and the sponsors correctly paid for the meals served. (click)Additionally, the number of meals served to students and claimed for reimbursement must have adequate documentation on file to support the claim. Slide 4

• Eligibility Documentation
• Collection Procedures
• Point of Service Meal Counts
• Reports & Edit Checks
• Claim for Reimbursement
• Internal Controls

4

Each of these elements is essential to

• perating an accurate meal counting

and claiming system.

• Eligibility Documentation
• Collection Procedures
• Point of Service Meal Counts
• Reports & Edit Checks
• Claim for Reimbursement
• Internal Controls

Slide 5

Counting and claiming meals starts with eligibility process

• Eligibility is backbone of system
• Eligibility master list must match list at

point of service

• Benefit Issuance Document

5

Accurately counting and claiming meals starts with the eligibility process. Eligibility is the backbone of the system. If a student’s eligibility is not determined correctly when a household application is processed, then the error will follow through to the meal service line where the meal will be counted incorrectly for

• reimbursement. The sponsor’s current

and correct eligibility master list, or Benefit Issuance Document, must match the list at the point of service for meal counts to be accurate. Slide 6

• Medium of Exchange
• System updated on a timely basis
• Transfers
• Withdrawals
• Changes in Status
• Prevents overt identification of free and

reduced-price meal recipients

6

Procedures for meal counting, claiming and collection procedures should be available in writing for all staff that work at the point of service. Sponsors should have an established collection procedure that institutes an acceptable medium of exchange that does not overly identify the status of

• students. The medium of exchange can

be any type of ticket, token, I.D., name

• r number that is issued to the

students for obtaining a meal. It might even be a finger scan. This can be a manual or computerized system. The system in place that connects the application for free and reduced-price meals to the medium of exchange must be updated on a timely basis (noting transfers, withdrawals and changes in status due to verification, etc.). The meal count/collection system selected must ensure that it prevents

• vert identification of free and

reduced-price meal recipients. Slide 7

• One reimbursable meal per

student per program.

• Count is taken at the point of service.
• A clicker, tally sheet or electronic system

may be used to record meals as they are counted.

• POS counts are of total meals served,

not separated by category.

7

CEP and Provision 2 meal counting is similar to traditional counting in many aspects and different in others. CEP and Provision 2 offer meals to all students at no charge, essentially making all students the same status and alleviating the burden of privacy surrounding status. Students are allowed one reimbursable meal per program and the count is taken at the end of the line at the point

• f service. Counts can be taken through

the use of a clicker, a tally sheet or by electronic means. These counts are of total meals served and are not separated by category. Slide 8

• Student Labor Meals
• Counted by category for reimbursement
• Second Meals
• Counted but not claimed for reimbursement
• Adult Meals
• Counted but not claimed for reimbursement

8

Several different categories of meals served may be considered alternate meals or meals other than traditional reimbursable student meals. Some of these meals may be included in the reimbursable meal count, and some may not. (Click) – Student Labor Meals or Earned Meals should be counted by category for reimbursement. (Click) – Second Meals and Adult Meals – should be counted for forecasting and planning purposes, but cannot be claimed for reimbursement.

Slide 9

Attendance Records Classroom Counts Tray Counts Cannot be used as an acceptable meal counting system

9

These following methods cannot be used as an acceptable meal counting system because they do not provide an accurate daily count of reimbursable meals served. (Click) Attendance records- using the total number of students in attendance, (Click) classroom counts – using the number of students in a class who indicate that they intend to eat a meal, and/or (Click)tray counts – counting the number of trays or entrées used during the meal service Again, these are unacceptable meal counting systems because they are not a count of reimbursable meals, taken at the point of service Slide 10

 The point in the food service operation

where a determination can accurately be made that a reimbursable snack or meal has been served to an eligible student.

10

A reliable Point of Service (POS) for meal counts must be established. This means that meals are counted where students receive the food and a reimbursable meal can be determined. Point of service is defined as that point in the food service operation where a determination can accurately be made that a reimbursable free, reduced- price, or full-price snack or meal has been served to an eligible student. The meal-counting and meal-claiming procedures used by sponsors are a local

• decision. When establishing and

evaluating a system for acceptability, always keep in mind the following requirements.

Slide 11

• Reimbursable meals served
• By type
• free
• reduced-price
• paid
• Each Day
• Without overtly identifying students’ eligibility

categories

11

The meal-counting system chosen must provide a point of service count:

• Of reimbursable meals served.

Regulations require that meals must be determined to be reimbursable and must be counted at the point-of- service.

• By type (free, reduced-price, or paid).

Or in the case of CEP and Provision 2 schools, by total number

• Meals must be counted each day.
• And should be counted without
• vertly identifying students’ eligibility
• categories. Codes used on rosters or
• ther forms of

exchange, such as tickets or debit cards, must not overtly identify the eligibility category of the student. Slide 12

End of the Line

Entrée Milk Fruit/Veg Bar POS

12

The Point of Service at the End of the Line is the best place to accurately determine that a complete reimbursable meal is served. By the time the student reaches the Point of Service they have had the opportunity to select all of food components for a complete meal. The person at the POS is able to accurately count complete reimbursable meals. Any alternate counting/collection procedure used must be approved by the state agency on a yearly basis and must provide for someone stationed at the end of the serving line to monitor the meals selected to ensure that each meal claimed for reimbursement meets meal requirements. In addition, the procedure must provide a method for removing any meal that is not reimbursable from the

proper meal category. The above is also true of any system that stations the cashier/ticket taker/counter at the beginning or middle of the line. Slide 13

 Middle of the Line  Beginning of the Line POS Entrée Milk Fruit/Veg Bar Entrée Milk POS Fruit/Veg Bar

13

The placement of the Point of Service is very important to be sure that complete reimbursable meals are served to students. In our first example; (click) if the POS is at the beginning of the line the student’s meal is counted before they receive their food. The student has the

• pportunity to choose milk, an entrée

and then go to the fruit and veggie bar. The adult serving the main dish can determine that the student has taken the 3 food items for a reimbursable meal under Offer vs. Serve but they cannot be sure the student has selected at least ½ cup of fruits and vegetables that are a required part of a reimbursable meal. To make this system work a person (click) would need to be stationed at the fruit and vegetable bar and (click) they would need to have a way of communicating with the person at the POS if a student did not choose a complete reimbursable meal. The second example (click) Point of Service in the middle of the line poses similar problems. The student has choices for milk and an entrée before they come to the Point of Service. This, however, does not ensure that the minimum fruits and vegetables have been selected for a complete reimbursable meal. Again, (click) a person would need to be stationed at

the Fruit and Veggie Bar and they would need to have a way of (click) communicating with the person at the POS if a student did not have a complete reimbursable meal. Slide 14

• Ensure number of meals match number of

eligible students

• Cannot claim more free, reduced-price or paid

meals than are served to eligible children

• Edit Checks must be completed daily and

monthly

• Either use the national attendance factor or

determine for their own district or site

14

Reports must be maintained that document students receiving meals on a daily basis. Edit checks must be done to ensure that the number of meals that are served at each meal period matches the number of eligible students on any given day. During an administrative review, the assigned specialist will check that the number of meals claimed does not exceed the number that was possible. The sponsor will need to show that they have completed Edit Checks and that there is adequate documentation for any exceptions. (click) Sponsors cannot claim more free, reduced-price or paid meals than are served to eligible children. If claims are in excess of the number of approved students in each category or the total number of enrolled students, the district will be required to repay any over-claims. Proper implementation of these regulations, which includes edit checks, will ensure an accurate system. (click)Before submitting a monthly claim for reimbursement, every sponsor must compare each eating site’s daily count against data that assists in the identification and correction of counts.

Edit Check must be completed by individual eating sites. (click)฀ This can be done using the national attendance factor of 93.8%, or by using a district or site determined attendance factor Slide 15

Happy School October 2014 Daily Attendance 2 215 17 209 3 210 18 215 4 212 19 216 5 214 20 214 6 209 23 219 9 210 24 219 10 213 25 217 11 210 26 215 12 215 27 214 13 207 Total 4053 Total Days 19 4053 ÷ 19 = 213 Average Attendance Happy Day School October 2014 Daily Enrollment 2 240 17 244 3 240 18 244 4 240 19 244 5 240 20 244 6 238 23 243 9 237 24 243 10 237 25 243 11 237 26 243 12 237 27 243 13 237 Total 4574 Total Days 19 4574 ÷ 19 = 241 Average Enrollment

15

• Attendance data from October must be used

to determine factor for the school year

• Average Attendance ÷ Average Enrollment
• Factor must be used for edit checks for sites

for the current school year

Attendance Factor 213 ÷ 241 = .88 or 88%

If a district or site chooses to use their

• wn attendance factor, they must

utilize data from the month of October. The factor is determined by taking the average attendance for the month of October and dividing it by the average enrollment for that month. Once determined this factor must be used for edit checks for sites for the current school year. (Click)Average Attendance represents an average of the total number of students in attendance on any particular day at a site. (Click) The school calculates this average by dividing the number of students in attendance each day of the month by the number of days in the month. Here is an example for Happy Days School for the month of October – Each days attendance is totaled to equal

• 4053. There were 19 school days in
• February. Divide 4053 by 19 to equal

213 which is the Average Daily

• Attendance. (Click)

(Click) Average Enrollment represents an average of the total number of students currently enrolled on any

particular day in a site. (Click) For our sample school, here is how the enrollment (also known as membership) fluctuated for the month

• f October. The total of all days

enrollment is then divided by the number of days in the month to obtain the Average Daily Membership of 241. (Click) The Attendance Factor is the monthly average of the number of students that would be available to participate on any given day in the month. To determine the Attendance Factor divide the Average Attendance by the Average

• Enrollment. Here is the Attendance

Factor for our sample school. The Average Daily Attendance of 213 students is divided by the Average Daily Enrollment of 241 to obtain the Attendance factor of .88 or 88% . This means that 88% of the students enrolled at Happy Days Elementary School are available to participate on any given day. Slide 16

16

• Computer POS systems have built in Edit

Check capabilities

• Enter the chosen attendance factor into the

computer program

• If number of meals served is legitimately

higher than edit check and maintain documentation

• If claim made was in error, make

adjustments to reflect correct count

If you are using a computer Point of Service system, it most likely has a built in Edit Check but you will need to be sure you enter the correct Attendance Factor for it to calculate correctly. Once you enter your daily numbers for each meal, the computer will calculate an edit check based on the attendance factor you entered. If you do have a count that is higher, a simple explanation should be noted and documentation to show the legitimacy of the claim must be saved.

If you find you had a verified incidence

• f higher than edit check meals served,

for instance a special holiday meal, or grandparents day event, an error may

• ccur when the claim is entered into

CNPweb. It is important that the sponsor looks at the daily and monthly Edit Checks to be sure that the number of meals served is within the number possible for that

• site. If an error is found, some research

needs to be done. If it was a mistake in the meal count then the count needs to be adjusted to reflect a correct count. Slide 17

• Participation in CEP or Provision 2

does not change the requirement to conduct edit checks.

• When an edit check is exceeded,

schools must maintain documentation to demonstrate why or corrective action may be required.

17

Schools participating in Community Eligibility Provision are not exempt from the requirement to conduct edit checks. Additionally, as with non-CEP schools, if an edit check is exceeded on any given day, documentation demonstrating the circumstances that support the numbers must be maintained or corrective action may be required.

Slide 18

18

CNP Web does an Edit Check on your monthly claim. If the sponsor exceeds the Edit Check for any site, CNP Web will show an error and will not let the claim be processed. If this happens, contact your assigned specialist. The specialist will have you submit your documentation to show that you had a valid reason for exceeding the Edit Check in CNP Web. A claim exceeding the edit check supported by adequate documentation will allow ODE staff to provide a system override in CNPweb. This will allow for the full payment of the claim, even when the edit check is exceeded. Slide 19

• More than 1 serving site
• February 1st
• Review of lunch counting and

claiming system

• Corrective Action
• Follow-up review within 45 days

19

On-Site Monitoring According to federal regulations: every school year, prior to February 1, every sponsor, including Residential Child Care Institutions (RCCIs), with more than one school or serving site must perform no less than one on-site review

• f the lunch counting and claiming

system employed by each school under its jurisdiction. Though sponsors with only one school are not required to conduct such on- site reviews for their approved school, the Food and Nutrition Service (FNS) highly encourages those SFAs to conduct a self-assessment in the form

• f an on-site review to ensure integrity

and accountability of the Program. Each on-site review must ensure the school’s claim is based on the counting system, as implemented, and yields the

actual number of reimbursable free, reduced price, and paid lunches, respectively, served for each day of

• peration.

If the review discloses problems with a school’s meal counting or claiming procedures, the sponsor must ensure that the school implements corrective action, and within 45 days of the review conduct a follow-up on-site review to determine that the corrective action resolved the problems. Slide 20

• When school is not in session
• When meals are given to students at the

end of their school day (not to include Field Trips)

20

Meals are not reimbursable when school is not in session. For example: The school week is 4 days, and Friday is used for remedial purposes only; because Fridays are not part of the regular school calendar, meals served on Fridays are not reimbursable. Meals served on weekends may be reimbursed if the school activity on the weekend is an integral part of the curriculum or an actual extension

• f the school calendar (i.e., make up

days to meet minimum hours students must attend). Meals served during vacations ARE NOT reimbursable. National School Lunch and School Breakfast Program regulations clearly intend that meals reimbursed under the programs are to be served and consumed on school or school-related

• premises. Therefore, meals taken off-

site are not reimbursable. This would include meals given to children to eat

• n the bus, take home with them due

to early dismissal, etc.

Meals consumed on school-sponsored, supervised field trips may be reimbursed since the meals are prepared by the school foodservice department and served and consumed as part of a school-related function. A list, roster or other method of counting the meals by category should be used to record counts. Meals served during such field trips should be subject to especially stringent sanitary and precautionary measures to avoid food contamination and spoilage and must meet the meal pattern. Slide 21

Reimbursable = served/consumed on school

• r school-related premises.

Meals taken off-site are not reimbursable Bus, take home Early dismissal Field Trips

21

Off-site Meal Consumption National School Lunch and School Breakfast Program regulations clearly intend that meals reimbursed under the programs are to be served and consumed on school or school-related

• premises. (Click) Therefore, meals

taken off-site are not reimbursable. This would include meals given to children to eat on the bus, take home with them due to early dismissal, etc. (Click) Meals consumed on school- sponsored, supervised field trips may be reimbursed since the meals are prepared by the school foodservice department and served and consumed as part of a school-related function. A list, roster or other method of counting the meals by category should be used to record counts. Meals served during such field trips should be subject to especially stringent sanitary and precautionary measures to avoid food contamination and spoilage and must meet the meal pattern.

Slide 22

• May be claimed by the host district or

sending district

• Must not be claimed by both districts.

22

Many sponsors participate in some type of alternative school or campus that includes several sponsors. Procedures for maintaining applications and the counting and claiming of reimbursable meals for this type of school must be established. One accepted procedure is for the host sponsor (physical site of the school campus) to keep copies of the students' applications, certification eligibility or a roster with each student’s eligibility on file from the sending sponsor. The host sponsor, which is providing meal service, may claim reimbursement for eligible students in the proper category. In some situations, a student's attendance in such a school may be short term (a few days such as outdoor education) or long term (entire school year). Adjustments and notations should be entered on records to justify the claim when applicable and to document current numbers of approved students. Slide 23

 Number of meals

• rdered

 Number of meals

delivered

 Number of meals

actually served to students

23

If a sponsor receives vended meals: (click) The correct way to count meals received from a vendor is when the meal is actually served to a student. And remember, even though the vendor is providing complete reimbursable meals, someone at the Point of Service where the meal is actually served must be ensuring that the student took a complete meal (click) Counting the number of meals

• rdered from the vendor is an

unacceptable meal count method. The meals cannot be counted until they are actually served to students. (click) Counting the number of meals

delivered to a site is not necessarily the number of meals that were actually served and would be an unacceptable meal count method Slide 24

• 1. Claims based only on meal counts taken at

any location before the meal served?

• 2. Claims based on attendance records?
• 3. Meal counts based on the number of tickets

sold and distributed or the number of meals paid in advance?

24

Answer the following 10 questions about your counting system.

• Are claims based only on meal

counts taken in the morning in the classroom or at any other location before the meal is served? (click) 2. Are claims based on attendance records? (click) 3.Are meal counts based on the number of tickets sold and distributed

• r the number of meals paid in

advance? Slide 25

 4. Is the number of

free and reduced-price meals claimed based

• n the number of

students eligible to receive such meals?

 5. Are meal counts by

category taken at the beginning of the serving line without checking that the meals served are reimbursable?

 6. Are meal counts by

category based on visual identification of students with no backup system available for persons not familiar with the students; e.g.,Checklist

 7. Are meal counts

based on tray or plate counts?

25

• 4. Is the number of free and reduced-

price meals claimed based on the number of students eligible to receive such meals?

• 5. Are meal counts by category taken at

the beginning of the serving line without checking that the meals served are reimbursable?

• 6. Are meal counts by category based
• n visual identification of students with

no backup system available for persons not familiar with the students; e.g.,Checklist

• 7. Are meal counts based on tray or

plate counts?

Slide 26

 8. Are back-out

systems used that subtract one number (e.g., number of free and reduced-price meals) from the total count to get another number (e.g., the

 number of full-price

meals)?

 9. Are the students who

are eligible for meal benefits overtly identified?

 10. Is this a system that

does NOT yield a reliable, accurate count

• f meals served by

category?

26

• 8. Are back-out systems used that

subtract one number (e.g., number of free and reduced-price meals) from the total count to get another number (e.g., the number of full-price meals)?

• 9. Are the students who are eligible for

meal benefits overtly identified?

• 10. Is this a system that does NOT yield

a reliable, accurate count of meals served by category? If the answer to any of these questions is YES, your counting system is NOT acceptable and must be revised (unless approved as an alternative system by the state agency. Slide 27

Recording method must ensure correct counts by category

• easily read
• edited
• consolidate into an accurate monthly claim

27

• 1. Reimbursement claim is an accurate number of

meals served to eligible students in each of the three eligibility categories

• 2. Cashiers and other staff members are skilled in

recognizing a reimbursable meal

The numbers of reimbursable meals served daily, by category, to eligible students are recorded and reported by school food service personnel. The particular recording method used must ensure that correct counts by category are reported in a way that can be easily read, edited and consolidated into an accurate monthly claim for

• reimbursement. Any report format

used must provide a complete record of the day's meal service so that the required information can be transferred to the district report. Accurately counting, recording and consolidating the number of meals served by category is the only way a claim for reimbursement can be properly submitted and the Sponsor correctly paid for the meals served. When the sponsor’s authorized representative submits claims for the

school or district, that person is responsible for (Click) 1. ensuring that the reimbursement claim is based on an accurate number of meals served to eligible students in each of the three eligibility categories—free, reduced- price, and paid meals—and (Click) 2. ensuring that the cashier or

• ther staff member is knowledgeable

and skilled in recognizing a reimbursable meal By entering the user name and password, in CNPweb the authorized representative for the sponsor is providing a legal signature on each claim for reimbursement. Slide 28

• 60 calendar day rule
• Late claim, one-time exception

28

60-Calendar Day Rule. Federal regulations governing the SNP require that claims for reimbursement be submitted to CNPweb within 60- calendar days of the claim month. Late Claim, One-Time Exception. A late claim is one received more than 60 calendar days after the last day of the claim month. A one-time exception may be used for one specific month within a 36-month time period for each USDA Child Nutrition Program that a sponsor administers. The sponsor may choose the claim month for which the

• ne-time exception payment provision

is used. Sponsors wishing to file a late claim should contact your Assigned Specialist.

Slide 29

• Claim is based on accurate meal counts by

category

• Never claim more free, reduced-price or paid

meals than served to eligible students

• Ensure an accurate system and prevent over

claims

29

Federal regulations were developed to improve the accuracy and accountability of reimbursement claims by clarifying Sponsors meal counting and claiming requirements. Whatever system or procedure is used for counting and claiming meals, the sponsor is responsible for ensuring the reimbursement claim is based on accurate meal counts by category. A Sponsor can never claim more free, reduced-price or paid meals than are served to eligible children. If claims are in excess of the number of approved free, reduced-price, paid or total number of enrolled students, the Sponsor will be required to repay any

• ver claims. Proper implementation of

these regulations, which include edit checks and on-site reviews, will ensure an accurate system and prevent over claims. Slide 30

30

Slide 31

 In accordance with Federal Law and U.S.

Department of Agriculture policy, this institution is prohibited from discriminating on the basis of race, color, national origin, sex, age, or disability. To file a complaint of discrimination, write USDA, Director, Office of Adjudication, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410 or call toll free (866) 632-9992 (Voice). Individuals who are hearing impaired

• r have speech disabilities may contact USDA

through the Federal Relay Service at (800) 877- 8339; or (800) 845-6136 (Spanish). USDA is an equal opportunity provider and employer.

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