The landscape of School Nutrition Programs (SNPs) underwent significant changes following Section 207 of the Healthy, Hunger-Free Kids Act of 2010. This amendment to Section 22 of the Richard B. Russell National School Lunch Act (Title 42, U.S. Code 1769c) mandated a more robust and unified accountability system. In response, the U.S. Department of Agriculture (USDA), after a comprehensive evaluation of review requirements in Title 7, Code of Federal Regulations, Section 210.18, introduced a revised process for reviewing SNPs, known as the Administrative Review (AR). This update was particularly relevant to programs like the 2016-2017 Meal Supplement For After School Care Program Site Assessment.
Implementing the Administrative Review Process
Prior to the School Year (SY) 2013–14, the California Department of Education (CDE) utilized the Coordinated Review Effort for program evaluations. The new AR process brought about several key modifications:
- Introduction of a New Off-site Assessment Tool
- Heightened emphasis on the financial stability of a School Food Authority’s (SFA) nonprofit school food service account (cafeteria fund), addressed in a new Resource Management section. This includes using a Resource Management Risk Indicator Tool to determine the necessity for a comprehensive SNP AR.
- Comprehensive review coverage extended to the School Breakfast Program (SBP) and other federal SNPs, including Afterschool Meal Supplements (snacks), Seamless Summer Option, Special Milk Program, and Fresh Fruit and Vegetable Program. Of particular interest during this period was the 2016-2017 meal supplement for after school care program site assessment.
- Elimination of follow-up review thresholds, streamlining the process.
On July 29, 2016, the USDA finalized the rule on ARs in SNPs. This final rule, effective from September 27, 2016, established a unified accountability framework for SNPs by revising state agencies’ review processes for the National School Lunch Program (NSLP) and SBP. California was already ahead of the curve, having implemented an updated SNP AR process beforehand, meaning many of the final rule’s changes were already in effect. However, some key changes were new to California, impacting programs like the 2016-2017 meal supplement for after school care program site assessment:
- Modified authority for the CDE to limit fiscal action for specific critical area violations when corrective action is promptly completed, offering a more nuanced approach to enforcement.
- Clearer guidelines on the scope and duration of fiscal action for repeated violations related to essential nutritional elements: vegetable subgroups, milk type, food quantities, whole grain-rich foods, and dietary specifications. While effective in SY 2017–18 in California due to a special waiver, the groundwork was laid in the 2016-2017 meal supplement for after school care program site assessment reviews.
- Clarified responsibilities for SFAs concerning indirect costs and donated foods, providing greater financial transparency and accountability.
- Expanded on-site review requirements for SFAs to include the SBP and readily observable general areas of review. A claims review process requirement for the SBP was also introduced, impacting how 2016-2017 meal supplement for after school care program site assessment sites were evaluated.
- Allowed the use of email or fax, alongside traditional methods, for sending specific documents, modernizing communication. This included notices about claim denials or payment withholding, documented corrective action, SFA appeal requests, and hearing notifications.
- Mandated the CDE to review at least one school from each Local Education Agency (LEA) for SFAs encompassing more than one LEA, ensuring broader oversight.
The complete final rule is accessible on the Federal Register ARs on the SNPs web page.
Further refining the implementation, on May 17, 2017, the USDA issued Policy Memorandum SP 31-2017: Clarifications for Fiscal Action School Food Authority-Wide for Administrative Reviews in School Year 2016–2017 . This policy memo presented two options for the CDE to implement fiscal action SFA-wide starting in SY 2016–17. The CDE chose option two: state agency discretion to initiate fiscal action SFA-wide using a 3 percent error threshold, directly influencing the 2016-2017 meal supplement for after school care program site assessment outcomes.
Objectives of the Review
The AR is a collaborative effort between the CDE and the SFA, aimed at upholding program integrity and enhancing overall compliance. Key objectives include:
- Determining SFA adherence to all federal and state SNP requirements, crucial for programs like the 2016-2017 meal supplement for after school care program site assessment.
- Providing targeted technical assistance (TA) to support SFAs in rectifying any identified issues.
- Securing necessary corrective action documentation to verify permanent corrections implemented by the SFA.
- Assessing fiscal action and, where necessary, recovering improperly disbursed funds.
The CDE prioritized clear and consistent communication, extensive TA, and excellent customer service throughout the transition to the updated review process, especially concerning the 2016-2017 meal supplement for after school care program site assessment reviews.
To streamline the AR process, the Nutrition Services Division (NSD) adopted a multiprogram review approach, integrating reviews of both the NSLP and the Child and Adult Care Food Program (CACFP) within the same review period if an SFA operates both. Federal guidance, outlined in USDA policy memorandums SP 09-2013 and CACFP 04-2013, encourages this streamlined method to reduce the burden on SFAs, including those managing 2016-2017 meal supplement for after school care program site assessment programs.
Phases of the Review Process
The AR process is structured into four distinct phases: prereview, on-site review, off-site review, and post-review. For a detailed visual representation of these phases, refer to the Administrative Review Process from the School Food Authority Perspective (DOC) flowchart. A comprehensive description of each phase is also available in Management Bulletin SNP-23-2015 under Administrative Review Process, with further details accessible through subsequent tabs: Prereview, Off-site Review, On-site Review, and Post-review. These phases were crucial for the effective 2016-2017 meal supplement for after school care program site assessment.
Review Schedule
The review schedule is regularly updated to ensure consistent oversight.
On January 25, 2023, the NSD requested a waiver from the USDA for Title 7, Code of Federal Regulations (7 CFR), Section 210.18(c) to extend the current SNP three-year cycle (SY 2023–24 through SY 2025–26) to a five-year cycle (SY 2023–24 through SY 2027–28).
This waiver was approved by the USDA on March 22, 2023.
The current SNP AR cycle is as follows:
Previous Review Schedule
Reflecting on past cycles, particularly relevant to understanding the context of the 2016-2017 meal supplement for after school care program site assessment, the prior review schedule provides valuable perspective.
On February 5, 2019, the CDE NSD submitted a waiver to the USDA for Title 7, Code of Federal Regulations (7 CFR), Section 210.18(c) to extend the SNP three-year cycle (SY 2017–18 through 2019–20) to a five-year cycle (SY 2017–18 through 2021–22).
The USDA approved this waiver on May 28, 2019.
Further adjustments were made due to unforeseen circumstances. On December 24, 2020, the CDE NSD submitted a Child Nutrition Program (CNP) monitoring waiver to the USDA, requesting to waive 7 CFR, Section 210.18(c) to extend the SNP five-year cycle (SY 2017–18 through 2021–22) to a six-year cycle (SY 2017–18 through 2022–23) due to the federally declared public health emergency caused by COVID-19. This waiver also included waiving state-level monitoring for five general areas (Special Milk Program, Competitive Food Standards, Program Outreach, Professional Standards, and Local School Wellness Policy) for SNP ARs in SY 2020–21 and waiving state AR requirements at 7 CFR, sections 226.6(m)(6)(i) and (ii) for CACFP Operators closed throughout Federal Fiscal Year 2020–21 due to the public health emergency.
The USDA approved the CNP monitoring waiver on January 26, 2021.
The previous SNP AR cycle was:
Year 1, SY 2017–18 Year 2, SY 2018–19 Year 3, SY 2019–20 Year 4, SY 2020–21 Year 5, SY 2021–22 Year 6, SY 2022–23
It’s important to note that the review schedule is subject to change, and the CDE will notify SFAs scheduled for review via email.
Prereview
The prereview phase is intentionally designed to be conducted off-site, aiming to minimize on-site review time without compromising review quality. Throughout this phase, the reviewer maintains communication and offers technical assistance (TA) as needed, crucial for preparing for the 2016-2017 meal supplement for after school care program site assessment. The sequence and timing of prereview activities are adaptable, depending on the reviewer, the SFA, and other factors influencing the AR.
Communications
The CDE initiates the prereview phase by sending an AR Notification Letter via email to the SFA’s Superintendent, Chief Business Officer (CBO), and Food Service Director (FSD). For agencies without these specific positions, the email is addressed to the highest-ranking official(s). The receipt of the AR Notification Letter officially marks the commencement of the AR process and includes essential information:
- An introduction to the administrative review process, especially as it pertains to programs like the 2016-2017 meal supplement for after school care program site assessment.
- The assigned reviewer’s name.
- Instructions to complete mandatory prereview training.
- Information regarding the Off-site Assessment Tool (OAT).
- Other relevant information and updates concerning ARs.
Before the prereview phase concludes, the reviewer also sends a confirmation letter containing the scheduled date and time for the on-site review.
Prereview Training
The CDE mandates that SFAs scheduled for an AR complete a prereview training (PRT) at the beginning of the school year. Details about the PRT are provided in the AR notification email, or SFAs can contact their assigned reviewer for information.
Starting in School Year (SY) 2018–19, PRTs are offered as online training modules, enhancing accessibility. The PRT can be accessed through the CDE Child Nutrition Programs Course Catalog web page.
Off-Site Review
Off-site Assessment Tool
The Off-site Assessment Tool (OAT) is a vital component of the AR process. It assists the reviewer in gaining a comprehensive understanding of the SFA’s SNP operation before the on-site review, including aspects relevant to the 2016-2017 meal supplement for after school care program site assessment. The OAT comprises a series of questions covering the five key compliance areas. Reviewers utilize the OAT responses to complete necessary forms and tools in preparation for the review. The OAT is made accessible to the SFA in the Child Nutrition Information and Payment System (CNIPS) by the reviewer.
SFAs selected for review are required to complete and submit the OAT in the AR module within CNIPS. Access to the OAT is granted upon receipt of the AR Notification email. SFAs must complete and submit the OAT eight weeks prior to the entrance conference date. The CDE strongly advises SFAs to complete the mandatory prereview training before submitting the completed OAT to better prepare for reviews like the 2016-2017 meal supplement for after school care program site assessment.
OAT Video: A step-by-step guide to accessing and completing the tool in CNIPS is available in the Learning About the Off-site Assessment Tool video.
OAT Guidance: The Off-Site Assessment Tool Guidance document can be downloaded from CNIPS under Download Forms, offering further support for programs like the 2016-2017 meal supplement for after school care program site assessment.
Note: The CDE is currently seeking a waiver for OAT question 701 for program operators under a state agency-approved budget agreement, which may affect some 2016-2017 meal supplement for after school care program site assessment reviews.
Site Selection
To determine the minimum number of sites for review, the CDE requires specific data from the SFA:
- Names and types of all schools within the SFA participating in the NSLP.
- Number of serving days for each school during the selected month.
- Highest number of free-eligible students for each school during the selected month.
- Number of free lunches claimed in the selected month.
Based on USDA guidelines and this data, the CDE determines the minimum number of NSLP sites to be reviewed. The selection of specific sites is based on factors such as average daily participation, findings from previous on-site visits or claims reviews, questionable daily meal counts, or recommendations from the Food Service Director (FSD), all of which are relevant to ensuring effective 2016-2017 meal supplement for after school care program site assessment.
On-site Review
The on-site review is conducted by the reviewer to validate the information provided in the Off-site Assessment Tool (OAT) and to directly observe program operations at the SFA and selected schools, including those providing 2016-2017 meal supplement for after school care program site assessment.
Entrance Conference
The on-site review process begins with an entrance conference. During this meeting, the reviewer summarizes the findings from the OAT, explains the on-site review process in detail, and announces the sites selected for review. Attendance at both the entrance and exit conferences is expected for the Superintendent, Chief Business Officer (CBO), and Food Service Director (FSD), ensuring leadership involvement in reviews like the 2016-2017 meal supplement for after school care program site assessment.
Scope of Review
The AR process encompasses five key compliance areas, categorized as either critical areas of performance or general areas of review. The USDA mandates that the CDE take regulatory fiscal action for noncompliance in critical areas. However, the CDE has discretion in determining fiscal action for general areas. These five key compliance areas are summarized in an accessible format in What is an Administrative Review? (PDF).
Meal Access and Reimbursement
This is a Critical Area, Performance Standard 1, focusing on:
100 Series: Certification and Benefit Issuance (number series 100)
- This area reviews the SFA’s process for determining student eligibility for free, reduced-price, or paid meals, which directly links to the SFA’s meal counting and claiming system.
- Review of benefit issuance practices.
- Fiscal action is mandated if information is missing, certifications are miscategorized, benefit issuance errors occur, or failure to update status when required.
- Ensures eligible children receive entitled meals, and reimbursement claims are valid, essential for programs like 2016-2017 meal supplement for after school care program site assessment.
- Resource: SNP Eligibility Materials
200 Series: Verification
- This reviews the mandatory verification process used by the SFA to confirm the eligibility of selected students by verifying income information on household applications.
- Ensures proper completion of the verification process within the specified timeframe.
- Tips for Success:
- Maintain thorough records.
- Keep supporting documents organized.
- Double-check income conversion if used.
- Verify mathematical calculations.
- Complete verification by November 15.
- Document all correspondence and contacts.
- Ensure correct identification of error-prone applications.
- Tips for Success:
- Resource: SNP Verification Materials
300 Series: Meal Counting and Claiming
- This area reviews the SFA’s system for accurately counting, recording, consolidating, and reporting the number of reimbursable meals claimed, including those in 2016-2017 meal supplement for after school care program site assessment.
- Review methods include interviewing site staff, meal observation, meal count documentation review, monthly claim review with supporting documents, and verification of edit checks and supporting documentation.
Meal Pattern and Nutritional Quality
This is a Critical Area, Performance Standard 2, focusing on:
400 Series: Meal Components and Quantities
- Reviews the preparation, offering, and service of meals that meet the meal pattern requirements for the appropriate student grade groups across all reimbursable meal service lines.
- Ensures every reimbursable meal service line meets daily and weekly meal pattern requirements for the relevant grade group served, a crucial aspect of 2016-2017 meal supplement for after school care program site assessment compliance.
- Resources: Available through CDE and USDA websites.
500 Series: Offer Versus Serve
- Reviews the SFA’s implementation of offer versus serve, which allows students to decline some food items they don’t intend to eat, reducing food waste.
- Ensures adequate provision of all food components, student selection of sufficient components, and that meals claimed for reimbursement meet meal pattern requirements, important for efficient 2016-2017 meal supplement for after school care program site assessment operations.
- Resource: Offer versus Serve Guidance
600 Series: Dietary Specifications and Nutrient Analysis
- Reviews the amounts of calories, saturated fat, trans fat, and sodium in meals offered to children in school nutrition programs.
- Ensures meals served comply with dietary specification standards, a key nutritional aspect of 2016-2017 meal supplement for after school care program site assessment.
Resource Management
This is a General Area addressing financial health aspects of the SFA school food service: nonprofit school food service account maintenance, Paid Lunch Equity, revenue from nonprogram foods, and indirect costs. The Risk Indicator Tool assesses potential risks and the need for further review.
700 Series: Resource Management
- Reviews six risk areas:
- Enrollment trends.
- Past audit findings.
- Maintenance of the nonprofit school food service account.
- Paid Lunch Equity compliance.
- Revenue from nonprogram foods.
- Management of indirect costs.
- Ensures the overall financial health of the SFA’s cafeteria fund, vital for the sustainability of programs like 2016-2017 meal supplement for after school care program site assessment.
- Resource: Cafeteria Fund Guidance
General Program Compliance
This General Area includes reviews of:
800 Series: Civil Rights
- Reviews compliance with laws, regulations, instructions, policies, and guidance related to nondiscrimination in child nutrition programs.
- Ensures the SFA has written procedures and adheres to requirements.
- Resource: USDA Civil Rights: USDA Food and Nutrition Service policies and procedures on nondiscrimination are available at the CDE USDA Civil Rights web page.
900 Series: SFA On-site Monitoring
- Reviews the SFA’s completion of at least one on-site review of the lunch counting and claiming system in each school for SFAs with multiple schools under their jurisdiction.
- Ensures required monitoring is completed within appropriate timeframes.
1000 Series: Local School Wellness Policy
- Reviews the effectiveness of the SFA’s local school wellness policy (LSWP) in promoting children’s health, preventing childhood obesity, and preventing diet-related chronic diseases through a healthy school environment.
- Ensures the LSWP includes all mandated components: stakeholder engagement, implementation, public notification, and reporting.
- Resource: Local School Wellness Model Policies
1100 Series: Smart Snacks in School
- Reviews requirements for all food and beverages sold to students on school campus from midnight until 30 minutes after the school day ends, outside of the reimbursable meal program.
- Ensures SFAs meet minimum requirements for all foods and beverages sold in school to promote healthier food consumption and support a healthy school environment.
- Resource: Competitive Foods and Beverage
1200 Series: Professional Standards
- Reviews new professional standards for SNP personnel, effective July 1, 2015, including California-specific policies and resources for hiring and training standards.
- Resource: Professional Standards
1300 Series: Water
- Reviews requirements for schools to provide potable water to all students during lunch and to breakfast students in the cafeteria.
- Ensures access to water during meal service times in meal service areas.
1400 Series: Food Safety
- Reviews safe handling, storage, preparation, and service of food.
- Ensures SFA compliance with state and federal food safety requirements, critical for all programs including 2016-2017 meal supplement for after school care program site assessment.
1500 Series: Reporting and Recordkeeping
- Reviews the SFA’s submission and maintenance of reports and records according to retention requirements.
- Ensures compliance with reporting and recordkeeping mandates.
1600 Series: School Breakfast Program and Summer Food Service Program Outreach
- Reviews SFA requirements to inform eligible households about the SBP and Summer Food Service Program meals.
- Ensures required outreach activities are conducted to increase program participation.
- Resource: Summer Food Service Program
Other Federal Program Reviews
This component, a General and Critical Area, focuses on programs such as:
Afterschool Meal Supplements (Snacks) (1700)
- Reviews the SFA’s option to serve NSLP snacks to students in structured afterschool programs providing educational or enrichment activities, directly related to 2016-2017 meal supplement for after school care program site assessment.
- Ensures participating schools serve nutritionally balanced snacks meeting meal pattern requirements, provide appropriate activities, and accurately count and claim snacks.
- Resource: After School Snack Supplement
Seamless Summer Feeding Option (1800)
- Reviews the SFA’s option to serve meals during summer or school vacation periods using NSLP meal service rules and claiming procedures.
- Ensures compliance with meal counting, claiming, menu planning, and food safety requirements.
- Resource: Summer Food Service Program
Fresh Fruit and Vegetable Program (1900)
- Reviews the SFA’s ability to increase elementary school students’ exposure to and consumption of fresh fruits and vegetables outside of the NSLP.
- Ensures program operation compliance with USDA and CDE requirements.
- Resource: Fresh Fruit and Vegetable Program
Special Milk Program (2000)
- Reviews the SFA’s offering of milk to eligible children in schools, residential child care institutions, and eligible camps not participating in other federal child nutrition programs.
- Ensures program operation in accordance with approved agreements and federal regulations.
- Resource: Special Milk Program
Exit Conference
The post-review phase begins with an exit conference where the reviewer informs the SFA of preliminary findings and discusses the initial corrective action assessment with deadlines. Superintendents, CBOs, and FSDs are expected to attend to receive information on findings, corrective actions, and TA. The reviewer and SFA collaborate on a Corrective Action Plan, finalized during the exit conference or later in the post-review phase. Documented corrective action may be accepted during the on-site review itself.
Post-review
Administrative Review Report
The reviewer compiles an electronic AR Report detailing findings, corrective actions with deadlines, and potential fiscal action. The exact fiscal action amount is determined after full processing by the CDE. All findings are documented in the AR Report, even if corrective action was immediately implemented. Within 30 calendar days of the exit conference, the AR Report is provided to the SFA’s Superintendent, CBO, and FSD, and preliminary findings are discussed.
The electronic AR Report is saved in CNIPS. SFAs can access AR findings in CNIPS by:
- Logging into CNIPS with User ID and password.
- Selecting School Nutrition Programs on the Programs screen.
- Selecting the Compliance tab on the Welcome screen.
- Selecting Review Tracking on the Compliance screen.
- Selecting Details next to the current Review Year on the SNP Reviews screen.
- Selecting View next to Corrective Action Documents on the Review Dashboard screen.
If no findings are present, a closure letter marks the end of the AR. If findings exist, the SFA must submit corrective action documentation (CAD).
Administrative Review Transparency Requirement
USDA Policy Memo SP 56-2016 provides additional guidance on AR implementation in SNPs. Rule 7 CFR, Section 210.18(m) mandates the CDE to post a summary of the most recent final AR results for each SFA, enhancing transparency in programs like 2016-2017 meal supplement for after school care program site assessment. Final AR results can be viewed in the Child Nutrition Information and Payment System.
Corrective Action Documents
SFAs must provide CAD for all findings within 30 calendar days of each action’s deadline. Incomplete, incorrect, or late CAD submission may result in reimbursement holds. Written extension requests are required for deadline extensions. Upon CDE acceptance of CAD, fiscal action is processed, and a closure letter with claim adjustment and appeal notice (if applicable) is sent to the SFA.
Final Closure of Review
Once the CDE deems the CAD acceptable, a closure letter is sent to the SFA outlining any actions to be taken. If fiscal action is necessary, the closure letter explains findings, the claim adjustment amount, and appeal procedures, adhering to USDA and CDE regulations and guidance, ensuring accountability in programs like 2016-2017 meal supplement for after school care program site assessment.
Resources
The CDE is dedicated to providing ongoing technical assistance (TA), training, and resources to support SFAs in successfully completing their ARs, including those related to 2016-2017 meal supplement for after school care program site assessment. The following resources are available:
U.S. Department of Agriculture (USDA) Administrative Review Manual:
Federal-level guidance and resources to standardize the AR process are provided by the USDA Food and Nutrition Service. The AR Manual can be accessed by:
Logging into the Child Nutrition Information and Payment System (CNIPS) with User ID and password. Accessing the Applications tab on the Welcome screen, then Download Forms, and selecting Manual AR.
What is an Administrative Review? Diagram:
The What is an Administrative Review? (PDF) diagram visually summarizes the five key compliance areas and their importance in the AR. An accessible text version is available in the On-site Review tab.
Tips for Success:
The Tips to Increase Success in a SNP Administrative Review offers SFAs advice for successfully navigating the prereview portion of the AR, beneficial for all reviews including 2016-2017 meal supplement for after school care program site assessment.
Contacts
For questions, contact your NSD Field Services Unit (FSU) representative. The FSU contact list is in the Child Nutrition Information and Payment System Download Forms section, Form ID Caseload. The FSU office can also be reached by phone at 916-323-4558.
The Resource Management Unit (RMU) can be contacted via email at [email protected].
The Procurement Resources Unit (PRU) can be reached at [email protected].
