CRE-SMI Training

1
CRE-SMI Overview
Please turn on your speakers or headphones!
2
What is CRE-SMI?

• CRE/SMI Two different reviews
• CRECoordinated Review Effort
• Performance Standard 1-Meal Counting and
  Claiming/Eligibility
• Performance Standard 2- Meal Components
• General Review Areas
• State Agency (ODE) Specific Areas
• SMISchool Meals Initiative
• Comprehensive nutritional review of School Food
  Authoritys (SFA) selected menu planning option

3
CRE review cycle and schedule

• SFAs must be reviewed at least once every 5 year
  cycle.
• SFAs are notified in August that they will be
  reviewed.
• Confirmation letter sent at least 30 days prior
  to review.

Hint Always be prepared!
4
Review Period and Number of Sites to be Reviewed

• CRE includes
• Day of review (the day we are on-site)
• Review period
• Review period most recent month for which a
  claim for reimbursement was submitted.
• When selecting school(s) to be reviewed, ODE must
  use USDA required procedures.

of Schools in SFA Minimum of School to Review
1-5 1
6-10 2
11-20 3
21-40 4
41-60 6
61-80 8
81-100 10
101 or more 12 plus 5 of the numbers of schools over 100
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School selection cont.

• School Selection Worksheet.
• Schools w/free ADP of 100 or more and 100 or
  more free participation must be reviewed.
• Additional schools that must be reviewed
• Elementary schools (pre-K, K-8) w/free ADP of 100
  or more and 97 free participation.
• Combination schools (K-12, 7-9, 7-12, etc.)
  w/free ADP of 100 or more and 87 free
  participation.
• Secondary schools (9-12) w/free ADP of 100 or
  more and 77 free participation.
• If none of these criteria are met, then optional
  criteria can be used.

6
Program areas to be reviewed

• Performance Standard 1
• Meal Counting and Claiming/Eligibility
• Performance Standard 2
• Meal Components
• General Areas Wide variety of subjects and ODE
  specific subjects

7
The Review Process

1. CRE announcement letter sent to SFA in August.
2. ODE will contact SFA to set exact date for
   review.
3. Second CRE announcement letter sent to SFA
   approximately 30 days before review date.
4. ODE reviewers will conduct entrance conference
   with the superintendent and/or their designee(s).
   ODE reviewers may review breakfast service prior
   to the entrance conference.
5. ODE reviewers will conduct an exit conference
   with the superintendent and/or their designee(s)
   to discuss the review findings. ODE reviewers
   will issue a Document of Administrative Findings
   (DAF) outlining the Corrective Action required by
   the SFA.
6. The SFA has 30 days to adequately respond to all
   findings noted in the DAF. Should the DAF be
   incomplete or past due, the SFAs claims will be
   placed on HOLD until all review findings are
   corrected.
7. If there are no findings or the DAF has been
   adequately addressed, ODE will issue a closure
   letter for the review.

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The First Review

• Breakfast and Lunch will be reviewed.
• What will ODE reviewers be looking at
• Applications/Benefit Issuance Process
• Applications should be sorted by review school
  and Benefits Issuance Document.
• 100 Percent of applications will be reviewed (ODE
  retains right to review less).
• Temporary and denied applications.
• Approved eligible student counts vs. reviewers
  count.
• Applications will be checked for correct approval
  on income and family size.
• Determine if questionable applications were
  researched before a determination was made.

9
The First Review Cont.

• Direct Certification (DC)
• Official ODE downloaded DC list.
• DC list updated regularly?
• Predetermined Eligibility letter for DC sent to
  households?
• Are siblings of directly certified students
  included in the eligibility benefits following
  new USDA guidelines?
• Is DC list only used for first 30 operating days
  of the school year?
• Head Start Documentation
• Are Head Start students enrolled in the school
  district in an academic program?
• Is a statement of low income provided by an
  authorized Head Start employee? OR
• A list of income eligible Head Start students.
• Is the list new for each school year?
• Was predetermined eligibility letter sent to
  households?

10
The First Review Cont.

• Even Start Program Documentation
• Approved Even Start application, or
• Statement of enrollment in Even Start or a list
  of children in Even Start must be on file.
• Confirmation of pre-kindergarten status.
• Re-certify each year.
• Runaway Youth Documentation
• To document a childs runaway status and
  eligibility for free meal benefits, the school
  must obtain a list with each childs name and the
  signature of the local runaway coordinator.
• Homeless Youth Documentation
• To document a childs homeless status and
  eligibility for free meal benefits, the school
  must obtain a list with each childs name and the
  signature of the local homeless coordinator.

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The First Review Cont.

• Migrant Youth Documentation
• To document a childs migrant status and
  eligibility for free meal benefits, the school
  must obtain a list with each childs name and the
  signature of the local migrant coordinator.
• Master List/Roster
• Is there a listing of all students and their
  approved categories by school?
• The list/roster should include
• Childs name
• Approved status
• Date approved
• Date noting a change must be on roster or
  application
• School master list will be compared to all F/R
  applications, DC list, runaway, homeless,
  migrant, Head Start/Even Start.
• Denied (paid) applications will be checked for
  correct approval and students status will be
  checked on roster to make sure student is
  receiving proper benefits.

12
The First Review Cont.

• Documentation of any Changes
• Any change on the master list/roster or the
  application must be initialed and dated by the
  person making the change.
• Verification Process
• Is the correct sample size based on October 1
  count of applications?
• Is the district summary sheet completed?
• Did the district document by application?
• Was verification completed by November 15?
• Were an adequate number of applications selected?
• Were required income and SSN documentation
  obtained?
• Is the Verification Record completed?
• Were correct letters sent to households
• Were changes to the master list/roster made if
  verification results changed eligibility?
• Meal Count/Collection Procedures
• Is the counting, recording, and claiming of the
  number of meals served to students by category
  accurate?
• Is there adequate documentation to support the
  claim?
• Is the medium of exchange used correctly? No
  overt identification? Is the collection procedure
  observed the same as approved by ODE?
• Is there equal access for all students?

13
The First Review Cont.

• Point-of-Service Count
• Is the system used providing an accurate point-of
  service count of reimbursable meals served (one
  per eligible student per day) by category (free,
  reduced and paid) each day without overtly
  identifying students eligibility?
• Consolidation of Claims
• Are the edit checks conducted to prevent claiming
  more students than in attendance?
• Are edit checks performed daily (compare each
  schools daily claim against the number of
  students approved for free and reduced-price
  lunches, the schools average daily attendance
  and the schools enrollment?
• Are on site reviews completely annually for an
  SFA with more than one feeding site?

14
The First Review Cont.

• Menu Requirements for all meal patterns
• Are all required components/food items available
  in correct portion sizes on reimbursable meal
  serving lines on day of review?
• Are all items offered before the point-of-service
  count?
• Are food production records complete and adequate
  to support claims?
• Do the Month of Review menus meet meal pattern
  requirements?
• Are CN labels available for food based menus,
  product data sheets for Nutrient Standard menus?
• General Record Keeping Policies
• Are records kept for 3 years plus current
  operating year?
• Are approved applications (date approved, level
  of benefits, signature or initials of reviewing
  official) kept?
• Is supporting information, such as dates of
  transfers, withdraws and changes in eligibility,
  maintained?

15
The First Review Cont.

• Records to maintain daily
• Is the daily record of Reimbursable Meals
  maintained?
• Is the daily record of Income updated?
• Are food production records completed by the end
  of each day?
• Is the system that notes transfers, withdrawals,
  etc. updated as needed?
• Are edit checks conducted daily?
• Records to maintain monthly
• Is the consolidation of school meal counts by
  category correct?
• Is the reimbursement claim submitted
  electronically via CNPweb no later than 60 days
  following the completion of the claim month?

16
The First Review Cont.

• Financial Records
• Are financial records, purchasing procedures, and
  meal pricing available for review?
• Is the fund balance from last year carried
  forward (positive or negative)?
• Is the net cash balance less than three months
  operating expenditures?
• Is all interest posted to Child Nutrition Program
  account?
• Does payroll account for only Child Nutrition
  personnel?
• Are meals priced as a unit?
• Do reduced-price charges exceed maximum allowed?
  (40 cents for lunch and 30 cents for breakfast,
  public schools must have zero charge for
  reduced-price breakfasts due to Oregon law)
• Are adult meals prices at least the free
  reimbursement rate plus commodity entitlement
  rate?
• Is there a bidding process in place? Is district
  purchasing awarded items?
• Are state matching funds deposited in the CN
  account?

17
The First Review Cont.

• Policy Statement
• Is the district following all attachments to
  their free/reduced policy statement?
• Civil Rights
• Are disabled children receiving accommodations
  for feeding?
• Nondiscrimination poster posted?
• Is the nondiscrimination statement printed on
  correspondence?
• How is the district handling complaints of
  discrimination?
• Is the district providing/using foreign language
  translation applications, if needed?
• Is there separation by race, color, national
  origin, sex, age or disability in the eating
  periods, seating arrangements, serving lines or
  eating areas?
• Is there overt identification?

18
The First Review Cont.

• Procurement Process
• Do you know what the Federal procurement
  regulations are? If not review 7 CFR 3016.
• Do you know what your local small bid threshold
  is? If not are you using Oregon small bid
  threshold of 5,000?
• If you are purchasing below the small bid
  threshold are you obtaining at least 3 quotes?
• If you are purchasing above small bid threshold
  are you using an Invitation for Bid or Request
  for Proposal?
• Are all purchases being procured competitively
  with no restrictive requirements?
• Is the Buy American provision being followed?
• Is child nutrition required to purchase off an
  exclusive school beverage contract?

19
The First Review Cont.

• Competitive Foods
• Does the SFA have a board policy allowing foods
  to be sold in competition with school meals?
• Foods of Minimal Nutritional Value
• Is serving/purchasing of Foods of Minimal
  Nutritional Value (FMNV) in foodservice area or
  with CNP funds observed?

20
The First Review Cont.

• Provision 2 Base Year
• Is there a notification document to
  parent/guardian on file including media release?
• Meals being provided at no charge to students?
• Meals being counted and claimed by eligibility
  category of student?
• All other eligibility rules still apply.
• Provision 2 Non-Base Year
• Is documentation of public announcement regarding
  Provision 2 on file?
• Meals being provided at no charge to students?
• Is the percentage of free/reduced/paid
  established in the base year being applied to
  monthly count correctly?
• Are base year free/reduced applications still
  available for review?

21
The First Review Cont.

• Food Service Management Company Operations (if
  applicable)
• Is the contract being followed?
• Is the SFA monitoring the management company
  operations?
• SFA employee completing yearly on-site reviews?
• Is SFA filing monthly claim for reimbursement,
  establishing meal pricing, and retaining
  signature authority?
• Is SFA monitoring free/reduced applications and
  verification process if management company is
  completing? Is this agreement in contract?
• Does the SFA have an advisory board composed of
  parents, teachers, and students to assist in menu
  planning? Documentation of attendance on file?
• Is FSMC following all applicable rules regarding
  commodities and rebates?

22
The First Review Cont.

• After School Snacks (if applicable)
• Documentation of education or enrichment activity
• Attendance records
• Snack Production Records
• Roster/tally sheet of daily count of snack
• Two afterschool on-site reviews per year
• Fresh Fruit and Vegetable Program (if applicable)
• Invoices and time and effort document Month of
  Review FFVP claim
• Adequate amount of produce to serve the enrolled
  number of students in the school
• Sponsor/school is serving a variety of fruits and
  vegetables
• Sponsor/school following the Implementation Plan
• Sponsor/school completing two yearly self-reviews

23
The First Review Cont.

• Commodities
• Is the district storing foods properly
• Off floor, away from walls?
• Cleaning supplies stored separately?
• Old, excessive or damaged commodities utilized or
  removed?
• Annual Commodity Storage Evaluation completed?
• Health Inspections/Food Safety
• Has the school been inspected twice within the
  last 12 months? Most recent inspection posted?
• Have violations been addressed, if noted on
  inspection?
• Is HAACP food safety plan available at every
  production, serving site in SFA?

24
Follow-up Review

• Review Threshold
• Review threshold or degree of error in a critical
  area of review is exceeded and triggers a
  follow-up review
• Review Findings classified as either
• Non-systemic
• Unusual factors contributed to the error
• Systemic
• An error is built into a system and would likely
  re-occur if no changes to system.
• Clerical
• Means the error may or may not be non-systemic or
  systemic.

25
Fiscal Action

• If an over-claim is noted during a review, fiscal
  action could occur we take money back!
• ODE has option to disregard any over-claim of
  600 or less per program.
• Month of review claim (and possibly others) will
  be adjusted by ODE.
• Eligibility errors normally go back to beginning
  of month of review to date of correction.
  Reviewer retains discretion.
• Meal counting/meal component errors normally go
  back to the beginning of the school year to date
  of correction. Reviewer retains discretion.
• ODE has discretion to go into previous fiscal
  years depending on severity of the situation.

26
Lack of Response or Documented Administrative
Findings (DAF) Plan Past due

• No response
• Claims put on hold until DAF received
• Response past due
• Claims put on hold until DAF received
• Appeals Procedure
• Available when fiscal action is assessed.
• Cannot appeal findings.

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Scope and Timeline for Follow-up Review

• If Follow-up review has been triggered
• Problem areas addressed
• All other Child Nutrition Programs reviewed
• Follow-up review must be conducted before
  December 31 of the following year.
• If a second follow-up review is required, ODE can
  place a HOLD on program funds.
• Eliminate possibility for follow-up reviews
• Program termination?

28
School Meals Initiative (SMI)

• Comprehensive evaluation of districts lunch menu
  to ensure compliance with the Dietary Guidelines
  for Americans.

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Required Nutrient Levels
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What must sponsors do?

• Traditional Food Based Menu Planning (TFBP)
• After the on-site visit by ODE during the week of
  review, you will send us
• Printed Menu
• Production Records for SMI week of review
• Standardized recipes used
• Nutrition Fact Labels for non-single food items.
• Condiment recording form

31
What must sponsors do?

• Nutrient Standard Menu Planning (NSMP)
• Prior to the on-site visit by ODE, you will send
  us
• Printed Menu for SMI week of review
• Menu spreadsheet detail report using portion
  values
• Recipe audit report
• Nutrition facts labels for products used
• Data entry for local ingredients
• During on-site visit, ODE will evaluate
• Production Records are being completed
• Adjustments made to servings planned from
  production records
• Data entry for local ingredients
• Portion sizes used in analysis are the same as
  on-site day of review
• Use of standardized recipes in analysis and
  production
• Verify ingredients used in analysis and those
  used in production
• After on-site visit, you will send ODE
• Completed production records for the week of
  review

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Compliance or Corrective Action

• Whether on NSMP or TFBP, if any of the 8 required
  Federal nutrient levels are inadequate, a
  improvement plan will be issued.
• If any of the 3 recommended state nutrient levels
  are inadequate, a improvement plan will only be
  necessary if at least 1 federal nutrient level is
  inadequate.
• If you meet all requirements you will receive a
  congratulations letter.

33
Lack of response or Corrective Action Plan Past
Due

• No response to information requested
• Claims put on hold until information received
• Corrective Action past due
• Claims put on hold until corrective action
  received

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The whole point of the CRE-SMI review is to
ensure that money is being spent appropriately
and you are providing nutritious meals to
children that meet Federal requirements.

• We are here to help. If you need any assistance
  in the operation of your child nutrition program,
  please call or e-mail your assigned child
  nutrition specialist.