Coordinated Review Effort

1
Coordinated Review Effort

• Suzanne Davidson
• Distance Learning
• October 1, 2009

2
CRE Review

• CRE is the administrative review mandated by the
  United States Department of Agriculture. Each
  District is reviewed at least once during the
  five year cycle.
• The 4th CRE Cycle will run from SY 2008-09
  through SY 2012-13.
• 2009-10 is the second year of the cycle

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CRE Review cont

• The CRE review covers two periods
• the review month (the most recent month in which
  a claim has been submitted) and
• the review day (the day or days of the actual
  review).

4
Announcement Letter for the Review

• The announcement letters for the CRE review is
  mailed to the district about one month prior to
  the CRE review date. Enclosures are included
  with both letters.
• The CRE letter is addressed to the Superintendent
  and copied to the Child Nutrition Director.

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Announcement Letter cont

• In the CRE letter the Child Nutrition Director is
  ask to mail or fax copies of each schools daily
  record for breakfast and lunch used to back up
  the most recently submitted claim for
  reimbursement that is in the CNU office.
• Enclosures with CRE Letter
• List of information needed for the CRE review
• School year 2009-10 calendar

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Critical Areas of the CRE

• Performance Standard 1 Certification/Counting/Cl
  aiming-All free, reduced price and paid lunches
  claimed for reimbursement are served only to
  children eligible for free, reduced price and
  paid lunches respectively and counted, recorded,
  consolidated and reported through a system which
  consistently yields correct claims.

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Critical Areas cont

• Performance Standard 2
• Components Lunches claimed for reimbursement
  within the school food authority contain food
  items/components as required by the Program
  regulations.

8
Corrective Action

• A corrective action plan is required for any
  program deficiency found during the review.
• The corrective action plan has a due date that is
  stated in the letter back to the District
  Superintendent. It is IMPORTANT for the District
  to respond ADE/CNU by the due date for the
  corrective action.

9
Fiscal Action

• Fiscal action is required for all violations for
  P.S. 1 P.S. 2
• Fiscal action is assessed for errors in
• Certification
• Benefit Issuance
• Updating Eligibility Status/Drops Adds
• Meal Counting and Claiming
• Meal Component

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Certification

• Applications Must be kept secure and
  confidential
• Applications MUST be processed, determination
  made, and households notified within 10 working
  days from receipt of application
• Foster Child each foster child goes on an
  application by themselves as a household of one
• the income that is designated for the foster
  child as personal income is reported in Part 2 of
  the application
• the foster child IS NOT included in the household
  size in which they reside (considered a household
  of one)
• the income a household receives for the care of
  a foster child IS NOT reported as income on the
  application

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Certification cont.

• Temporary approval
• 45 day interval time period, no longer 90 day
  time period
• can convert to permanent if no changes after
  first 45 day re-contact of household (LEA choice)
  
• Lists
• Direct Certification
• Homeless
• Migrant
• Runaway
• Head Start/Even Start

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Categorical Eligibility ExtendedFIN-10-021 NEW

• Direct Certification extended to all children in
  the household if one child is on DC list
• LEA may use district records to determine the
  additional children in the household
• Applications with a SNAP case number applies to
  all children on the application, no need to check
  the box of the individual children

13
Verification

• All applications are subject to verification
• District must follow all normal verification
  procedures
• Eligibility adjustments must be made as a result
  of verification
• Completed by November 15 (16th for 09-10)
• Verification Summary due to ADE/CNU by December
  15th

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Benefit Issuance

• Rosters
• Child Nutrition Master Roster
• APSCN Roster
• Point of Service Roster
• All rosters must be kept current with student
  name and eligibility status. The Child Nutrition
  Roster must include an eligibility date and a
  drop date if the student leaves school.

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Meal Counting and Claiming

• Meal counts MUST be taken at the point of service
  
• Counts MUST be taken on a daily basis by category
  (free, reduced, paid) for each meal served
  (breakfast/lunch)
• Student eligibility status MUST not be
  identifiable to unauthorized personnel
• Second meals MUST NOT be claimed under any
  category

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Edit Checks

• Edit Check 1
• District shall compare each schools eligibility
  counts of free, reduced, and paid to the daily
  counts of meals served by category recorded on
  the daily record sheet for the month
• Edit Check 2
• Calculate an attendance factor for the school by
  dividing the ADA by the ADM from the districts
  quarterly reports
• Apply the attendance factor to the highest number
  of eligible free, reduced and paid for the month
• Compare the attendance adjusted eligibles to the
  number of meals served by category

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Edit Check 2 cont..

• Days when the attendance adjusted number is
  exceeded a potential problem may exist
• Document reasons for variances and take
  corrective action

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Meal Component Errors

• Meal Pattern Requirements
• Menu missing a component
• Incorrect portion size
• Milk Requirement not met
• Weekly Grain/Bread Requirement not met

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CRE General Areas

• Deficiencies in the General Areas of Review will
  require the school district to implement a
  Corrective Action Plan to correct errors found
  during the review

20
Health Inspection

• Two per school year
• Latest inspection posted in public area (both
  pages)
• Inspection problems corrected

21
Food Safety Plan and SOPs

• HAACP implemented and documented
• For example temperature logs
• SOPs available for all personnel
• Do personnel know where to find the SOPs
• Are the SOPs up to date and accurate
• Are the SOPs being used by the staff
• Food secured
• Kitchen lockable
• Locked store rooms

22
Cafeteria Atmosphere/Supervision

• Decorated
• Happy students
• Supervised by adults
• Adults participating
• Student seating non discriminatory

23
Student/Parent Involvement

• Must have Student/Parent Involvement at ALL
  schools, including secondary schools
• Must have documentation available
• sign in sheets
• photos
• flyers to families

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Quality of Food

• Hot food served hot (135 or above)
• Cold food served cold (41 or below)
• Batch cooking
• Scratch cooking
• Just in time cooking
• Appropriate eating utensils

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Time to Eat

• Breakfast
• Bus schedules allow time to eat breakfast
• Lunch
• How long students stand in line
• How much time to eat after being served

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Wellness

• Wellness Committee reviews foods served and sold
  in cafeteria quarterly
• Current list of Wellness Committee members
• Wellness Plan
• ACSIP Plan

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Nutrition Standards

• Elementary Schools nothing available to
  students outside of cafeteria
• Middle and High Schools
• 12 ounce maximum serving size on sodas
• Competitive foods available ½ hour after last
  lunch period has ended
• 50 servings in beverage machines must be
• unflavored, unsweetened water,
• low fat or fat free milk or
• 100 juice

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Nutrition Standards cont

• Products available to students meet the Maximum
  Portion Size chart for the current school year
• A la carte must have already been offered as a
  component of a reimbursable meal (5.01.5)
• Fat Restriction 23 grams

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Beverage or Vending Contracts

• If contract is new or renewed after September
  2005 then must follow the Arkansas Nutrition
  Standards.
• Contracts signed prior to September 2005 must
  follow the contract terms until the contract
  expires.
• Renewals must follow Nutrition Standards.

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Ala Carte Lines

• Meet nutrition standards
• Production Records
• Potential income
• Priced appropriately to cover ALL costs

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Bad Debts

• Charges not paid by students or staff
• Reimbursed to Child Nutrition by the district
• Audit trail

32
Staff Training

• 10 hours each year for each full time employee
• Documentation of training
• Sign in sheets
• Education Co-op documentation
• Subject of training sessions
• Agenda

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Pre-School Programs

• Claimed with ADE/CNU or
• Contract Meals
• Prices charged sufficient to cover ALL costs
• Not the same charge as paid student meals or
• Combination
• Claimed with ADE/CNU
• Student portion billed to third party (program)
• Must be an audit trail to show third party
  payment to Child Nutrition Account

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Adult Meals

• Adults participate in program
• Adult meal prices adequate
• Adult charges
• Number of adults eating free
• Adults only eat free if they contribute to the
  Child Nutrition Program

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Adult Meals cont.

• Adult meals paid by district
• Must have audit trail
• Must pay full price of producing adult meals
• District Must provide adults a1099 to show value
  of those meals as part of compensation

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Commodities

• Use commodities
• Menu planning
• Storage of commodities
• Separated
• Date marked

37
On-Site Review

• Required for districts with more than one serving
  site
• ADE/CNU strongly recommends that all districts
  complete the on-site review
• Completed by February 1st
• Kept on file in district

38
Civil Rights Compliance

• And Justice for All poster displayed in a
  public area
• Non-Discrimination Statement on letters and
  applications
• Privacy Act Statement on letters and applications
• Procedure for receiving discrimination complaints
• Denied applications should not be
  disproportionately minority students
• Seating in cafeteria-cannot segregate boys
  girls
• Correct years application used

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Recordkeeping

• USDA requires records be kept for the current
  year plus 3 preceding years.
• Arkansas Legislative Audit requires all
  documentation be kept for a minimum of 5 years
  after submission of the final claim relating to
  the documentation.
• Documentation must be kept longer if required by
  an audit or for resolution of issues raised by an
  audit.

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Recordkeeping cont

• Application documentation must be readily
  retrievable by school.
• LEAs must ensure that all changes and transfers
  are accurately and promptly reflected on the
  appropriate categorically eligible lists and on
  each schools master roster.

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Breakfast Program

• Purchased products meet meal pattern
• Production Records
• Offer vs. Serve implemented correctly
• Participation
• Accessable to all students
• Time to eat

42
Procurement Practices

• Specifications of products to procure kept
  current
• Bids/RFPs conducted correctly
• Quotes documented
• Buy American

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Afterschool Snack Program

• Educational or Enrichment Program
• Served after school day has ended
• Approved Schedule B
• Menus
• Production Records
• Counting and Claiming Daily Record
• 2 self-reviews of the program 1st review within
  first 4 weeks and 1 at some other time during the
  time period for ASSP

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Seamless Summer Program

• Approved Schedule C
• Menus
• Production Records
• Counting and Claiming Daily Record
• Self Review after 3rd or 4th week
• SSP will be reviewed by SA if district had a CRE
  review during the school year

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After the CRE Review is Completed

• A follow up letter is sent back to the
  Superintendent of the District with review
  findings noted for both fiscal action and
  corrective action deficiencies about 1 month
  after the exit conference.
• If fiscal action or corrective action is needed
  the District MUST respond back to CNU in writing
  by the due date with how these deficiencies are
  going to be corrected or have been corrected by
  the District.

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To Receive Credit for this Training

• A LEGIBLE Sign-in Sheet must be faxed to
• [phone]
• NO LATER THAN CLOSE OF BUISNESS TOMORROW (October
  2, 2009)