School Food Authority Reviews

School Food Authority

Reviews

 Notes

School Food Authority Reviews

On-Site Review Requirements

National School Lunch Program (NSLP) regulations require each school food authority (SFA)

with more than one site where reimbursable meals are served to annually conduct their own

review of each site’s meal count and claiming procedures. ISBE recommends even districts

with one site perform an annual On-Site Review of meal counting and claiming procedures. In

addition, we recommend observing all reimbursable meal services, especially if meal service

times have different staff performing the meal counting function.

This review must be completed by February 1 of each school year for each site. The individual

should be outside the daily operations to provide an objective look at the operations. The

review must be conducted by SFA personnel and may not be conducted by contracted parties.

A sample copy of the review form is available on page 7 of this section and electronically on our

website at

http://www.isbe.net/nutrition/pdf/67-35_onsite_review.pdf.

Documentation must be maintained on file at the site or SFA office for three years plus the

current year. The review must be conducted by SFA personnel and may not be conducted by

contracted parties. The individual should be outside the daily operations to provide an objective

look at the operations.

If the review disclosed problems, the SFA must correct problems within 45 calendar days of the

review. A Follow-Up Review must be conducted to determine if the corrective action resolved

the problem. Written documentation is required to be maintained at the SFA or at the site.

On-Site Reviews are conducted to ensure at each meal service claimed, the following internal

controls are operating correctly:

• Meals counts are taken at the point of service

• Meals are counted correctly by category

• All meals claimed meet meal pattern requirements

• Meals are counted on a daily basis

• Overt identification is prevented

• Accurate counts are collected

• General areas (new regulations)

After-School Care Program

For those participating in the After-School Care Program through the NSLP, the SFA must

review each site two times per year. The SFA must make the first review during the first four

weeks of operation each school year. The purposes of the reviews are to ensure reimbursable

snacks are provided and served to eligible students and acceptable counting procedures have

been implemented. Documentation must be maintained on file for three years plus the current

year. A copy of the review form is available on page 9 of this section, or electronically on our

website at

http://www.isbe.net/nutrition/pdf/67-80_review_af_10-07.pdf.

School Food Authority Reviews

Local Health Department Reviews

Annual Sanitation Reviews

Each school year SFAs must obtain two food sanitation inspections for each site where food is

prepared or served. For most counties, the local health department will conduct such

inspections. If the SFA is not in a county that has a local health department, then the SFA must

contact neighboring county health departments to conduct food sanitation inspections. Copies

of these inspections must be maintained at the SFA or at the site for three years plus the current

year. The most recent food sanitation report must be posted in a predominant location that is

viewable by the general public; i.e., eating area or near the school office.

If an SFA has not received a food sanitation inspection several months into the school year (i.e.,

January 31), a letter must be written to the local health department requesting the required two

food service inspections for each site where food is prepared or served. The letter must be

maintained at the SFA or at each site as documentation of your attempt to comply with two food

inspections as required by USDA regulations.

Illinois State Board of Education Reviews

Administrative Reviews/Coordinated Review Effort

Administrative Review is the name used to describe the Coordinated Review Effort (CRE)

process. The CRE guidance was issued by the USDA in 1993. The Administrative Review is

the term used in code of federal regulation. ISBE will use the term Administrative Review for

this section.

ISBE must conduct Administrative Reviews as prescribed by the USDA. The Administrative

Review is the initial comprehensive on-site evaluation of all SFAs participating in the NSLP.

Administrative Reviews of all SFAs are conducted, at a minimum, once every five years.

The review process will include the evaluation of the critical areas with two performance

standards that serve as a measure of compliance with program regulations and the general

areas of the review. During the review process, if there are problems in critical areas, an over-

claim may be assessed dependent on the severity of the problem.

Critical Areas Non-compliance in critical areas may result in a financial assessment.

Performance Standard 1

• Free and reduced-price eligibility determinations are correct.

• All free, reduced-price, and paid lunches claimed for reimbursement are served only to

children eligible for free, reduced-price, and paid lunches.

• All free, reduced-price, and paid lunches claimed for reimbursement are counted, recorded,

consolidated, and reported through a system that consistently yields correct claims.

School Food Authority Reviews

Performance Standard 2

Lunches claimed for reimbursement within the SFA contain food items/components as required

by the performance standard.

General Areas

In addition to critical areas, there are general areas of program compliance that will be

reviewed. There are no financial assessments for a problem in a general area. The general

areas include:

• Civil Rights

• Competitive Foods

• Daily Meal Edit Checks

• Food Quantities and Serving Sizes

• Food Safety Policy

• Illinois Free Breakfast and Lunch Programs

• Illinois School Food Services Rule Part 305

• Local Wellness Policy

• Offer versus Serve

• On-Site Review Process

• Overt Identification of Free and Reduced-Price Meal Recipients

• Procurement

• Sanitation

• Verification

Follow-Up Reviews may be conducted if there is a violation in excess of the review thresholds

established by the USDA.

A written report will be mailed to the SFA detailing the review findings, corrective actions

needed, deadlines for the corrective actions, and any financial assessment. The SFA must then

respond to the review findings by defining the process and procedures the SFA will implement

to ensure compliance with program regulations. The Corrective Action Plan must be applied to

all sites in the SFA. The Corrective Action Plan must contain:

• SFA name or submitted SFA letterhead

• Agreement number

• Signature of the authorized representative

ISBE has provided an Administrative Review Checklist to assist in preparing for an

Administrative Review. The checklist can be found on page 10 of this section, or electronically

at:

http://www.isbe.net/nutrition/pdf/nslp_review_checklist.pdf.

School Meals Initiative Review

ISBE must evaluate compliance, over a school week, with the USDA-established calorie and

nutrient standards. The USDA determines the school week as a minimum of three days and no

more than seven days. At a minimum, these evaluations shall be conducted once every five

years. The School Meals Initiative (SMI) Review may be conducted at the same time as an

Administrative Review, or separately. The type of evaluation conducted will depend on the

menu planning approach chosen by the SFA.

School Food Authority Reviews

ISBE’s Nutrition Programs Division requires weighted analysis as it is a more accurate and

useful method for conducting nutrient analysis. It is based on student selection, therefore,

allowing SFAs, schools, states, and federal policy makers to assess whether students are

actually making more informed, healthier choices. Once an SFA or state knows what kind of

choices students are making, they are in a better position to modify menus and design nutrition

education programs to address any issues revealed by the nutrient analysis. Therefore, SFAs

in Illinois are required to complete a nutritional analysis using weighted averages (effective

school year 2006–2007).

NuMenu Planning Approach

ISBE will assess the nutrient analysis for the last completed school week prior to the review

period to determine if the SFA is applying the methodology as described in the regulations. Part

of this assessment shall be an independent review of the menus and production records to

determine if they correspond to the nutrient analysis conducted by the SFA and if the menu, as

offered over a school week, corresponds to the appropriate calorie and nutrient standards.

The following information must be mailed by a specified date in order to begin the SMI Review:

• One school week LUNCH menu (it is recommended you select a five-day school week);

• Nutrient Analysis for the week of review using approved USDA software;

• Production records for each day of the week selected ;

• Standardized recipes for any item served during selected week; and

• For each food served during the week of review, one of the following items from cans,

boxes, jars, and packages:

o Nutrition Facts label, or

o Purchased product information sheets/labels

Food-Based Menu Planning Approach

ISBE shall conduct nutrient analysis on the menu served during the review period to determine

if the calorie and nutrient standards are met.

The following information must be mailed by a specified date in order to begin the SMI Review:

• A copy of the school week LUNCH menu for the week of SELECTED WEEK

• Production records for each day of the week selected

• Standardized recipes for any item served during selected week

• For each food served during the week of review, include one of the following items from

cans, boxes, jars, and packages:

o Nutrition Facts label or

o Purchased product information sheets/labels

If the menu for the week of review fails to comply with the calorie and nutrient standards, the

SFA must develop with the assistance and concurrence of the state agency, a Corrective Action

Plan designed to rectify those deficiencies. If the SFA fails to meet the terms of the Corrective

Action Plan, the state agency must determine if the SFA is working in good faith towards

compliance and if so may renegotiate the plan. If the SFA refuses, then the state agency must

determine if a disallowance of reimbursement funds is warranted.

ILLINOIS STATE BOARD OF EDUCATION

Nutrition Programs Division

100 North First Street, W-270

Springeld, Illinois 62777-0001

NATIONAL SCHOOL LUNCH PROGRAM

ON-SITE REVIEW FORM

ASSESSMENT OF SCHOOL MEAL COUNTING AND CLAIMING PROCEDURES

INSTRUCTIONS: Each school year, prior to February 1, school districts with more than one school are required to perform at least

one On-Site Review of the lunch counting and claiming system employed by each school under its jurisdiction. In addition, an

observation of staff in action, e.g. cashiers, managers, and servers must be conducted. Answer the following questions by checking

the appropriate response.

DISTRICT NAME SCHOOL NAME (One Per Building)

LEA REVIEWER’S NAME DATE OF VISIT (By February 1) TIME OF VISIT

In: ____________ Out: __________

Approved Menu Planning Approach: Traditional Enhanced NuMenu Assisted NuMenu

Offer vs. Serve used with approved menu planning approach: Yes No

(High schools must implement Offer vs. Serve.)

Grades participating in Offer vs. Serve (Circle all that apply): Pre-K, K, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, or not participating

MEAL COUNT SYSTEM

Yes No

1. Are meals counted at the point of service? (The person responsible for monitoring meals is located

where a complete meal can be observed, usually at the end of the service line.)

Yes No

2. Does the person taking meal counts understand what constitutes a reimbursable meal under the

menu planning approach being implemented?

Yes No

3. Does the person monitoring the meals know the school’s policies for handling the following meal

count procedures? If no, check the procedures that are not known below and follow-up with staff on

the correct procedures.

a. Lost, stolen, forgotten, or

destroyed tickets, tokens, IDs

e. A la carte selections

f. Second meals

b. Power failure (for automated systems) g. Incomplete meals

c. Student worker meals

d. Adult meals

Yes No

4. Is there a back-up system if the automated system(s) is down?

Yes No

5. Is someone trained as a “back-up” to count meals if routine employees are absent?

Yes No

6. Does the meal count system produce an accurate count of reimbursable meals by category (free,

reduced-price, and paid) served to eligible children? If no, check reasons(s):

a. Math errors f. Attendance counts

b. Counts taken at beginning of line g. Morning/classroom counts

c. Free and/or reduced-price backed out h. Incomplete meals

d. Cash backed out i. Based on meals delivered/prepared, not

meals observed

e. Tray counts

Student workers not claimed by correct

category

Yes No 7. Does the meal counting system prevent overt identication? If no, check reasons(s):

a. Unacceptable coding system f. All meals offered/served not available

to students eligible for free or reduced-

price meals

b. Use of special tickets, tokens

c. Cash only line

d. Visual or vocal ID

g. Checklist visible to students in line

e. Separate serving times, lines, or dining

areas

h. Cash register display identies price of

meals

ISBE 67-35 (5/09)

1st Review

Follow-up Review

Yes No 1.

Was the menu reviewed prior to the meal serviced?

Yes No 2.

Is the meal pattern met for the menu planning approach being used?

Yes No

3. If Offer vs. Serve is utilized at the school, does each child have the opportunity to select their own

food items for a reimbursable meal? (Under NuMenu, the child must take the entrée).

Yes No 4.

Were all required food items/components available through the meal service on all serving lines?

MEAL CLAIMING PROCEDURES

Yes No 1.

Are meal counts recorded daily?

Yes No

2. Is the school following procedures to ensure only one reimbursable meal per child per meal service

is claimed? (It must be ensured that seconds are not claimed even when there are multiple service

stations.)

Yes No

3. Are daily counts in this building properly taken from each serving line, meal period, etc. and cor-

rectly totaled and recorded on the daily cashier report?

Yes No 4.

Are counts correctly reported to the local education agency (LEA)?

Yes No 5.

Are meal count edits completed monthly? If required, was follow-up performed?

MEAL/MENU SUPPORT FUNCTIONS

Sanitation

Yes No

1. Did the school received two (2) food safety inspections? If no, a letter must be sent requesting

sanitation reviews from the local health department.

Yes No 2. Is the school’s Hazard Analysis and Critical Control Point (HACCP) plan in effect?

Yes No 3. If yes, has the plan been reviewed and/or revised for the current school year?

Yes No 4.

Does staff implement the HACCP plans in their daily activity? (for example, temperature logs and

procedures for deliveries)

Illinois School Food Rules

Yes No

Are all school foods and beverages compliant with the School Food Service Rules

(23 IL Administrative Code Part 305)?

School Wellness

Yes No 1.

Has the evaluation of school wellness goals been completed? If yes, what changes were

implemented based on the goals and results?

MEAL PATTERN REQUIREMENT

IF ANY OF THE ABOVE QUESTIONS WERE ANSWERED “NO,” A CORRECTIVE ACTION PLAN

IS MANDATORY AND MUST BE COMPLETED WITH 45 DAYS.

CORRECTIVE ACTION PLAN

Recommend corrective action for above “No” answers

Follow-Up Reviews (within 45 days of initial review)

Corrective action taken by school and date implemented

__________________________________________ ____________________________

Site Administrator Signature

Date

__________________________________________ ____________________________

LEA Reviewer Signature

Date

Follow-Up Review completed and approved by LEA reviewer. ____________________________

Date

ISBE 67-35 (5/09)

School Food Authority Reviews

National School Lunch Program

Administrative Review Checklist

During the Administrative Review, the Illinois State Board of Education’s principal consultant

will review program records for compliance with state and federal regulations. The following

checklist will assist in preparing for reviews of the National School Lunch Program, School

Breakfast Program, Special Milk Program, and/or After-School Care Program. This list presents

an overview of major areas which will be evaluated. Records for the entire current fiscal year

should be available for review.

Eligibility Documentation

______Documentation for children directly certified will be evaluated.

______Income applications must contain the required information:

• Names of all household members

• All household income and how frequently received

• Signature of an adult household member

• Social security number of the adult household member who signs the application

Temporary Assistance for Needy Families (TANF) or Supplemental Nutrition Assistance

Program (SNAP) applications must contain the required information:

• Accurate case number

• Signature of an adult household member

A separate application must be on file for each foster child and contain the required

information:

• Personal use income for a foster child or “0” if the child has no personal use income

• Signature of an adult household member

Documentation for categorically eligible children must be on file. Categorically eligible

includes homeless, migrant, runaway, and children enrolled in Head Start or Even Start.

Applications must be correctly approved for free and reduced-price meals based on the

current USDA income guidelines.

Written notification to parents for the denial of applications must be available for review.

Benefit Issuance

Current Master List of Enrolled Children and their eligibility status (free, reduced, or paid)

must be available for review.

Verification of Household Eligibility Applications

Verification of applications must be completed, documented, and available for review.

• Adequate number of applications must be verified and the verification process

completed by November 15

• Acceptable documentation must be received

• Summary of verification must be maintained and include the number of applications

on file as of October 1, the selection method used, number verified, and results

• Termination/reduction notice to households (if applicable)

School Food Authority Reviews

Claim for Reimbursement

Available claim data, by site, for each month must be available for review and include:

• Daily meal counts by category (free, reduced, or paid)

• Enrollment

• Number of children eligible for free and reduced-price meals

Claim information is checked to ensure:

• No mathematical errors occurred

• Figures are not transposed or copied incorrectly

• Site meal counts are claimed by calendar month

• Accurate number of days are reported for each claim period

• Individual site figures are used

Edit Checks

Before submitting the monthly Claim for Reimbursement for each site, the district must

conduct and document an edit which:

• Compares meals claimed to the maximum claimable meals for the month

• Compares daily meal counts to the number of eligibles in each category

• Compares meals claimed to the average daily attendance by category

• Corrects the claim or identifies reasons for meals claimed in excess of the number of

eligibles

• Identifies reasons for meals claimed which significantly exceed the average

attendance or average daily meal participation

On-Site Reviews

If the school food authority has more than one feeding site, On-Site Reviews must be

conducted and documented for all sites by February 1.

Menus

Menus/production records must contain all components/menu items.

For NuMenus, a nutrient analysis for each week must be available for review and include

all menu items and planned portion sizes.

Food Quantities

Adequate food quantities must be prepared and correct portion sizes served.

Meal Count Procedures

Free, reduced-price, and paid meals must be counted, by category, at the point of

service.

Meals counted for reimbursement must contain components or menu items required by

the selected menu planning approach.

Anonymity of children receiving free and reduced-price meals must be protected.

School Food Authority Reviews

If Offer versus Serve is used, it must be implemented correctly for the selected menu

planning approach.

Food Production

Production records must be available and contain the required information.

Recipes must be standardized and contain the required information.

Processed product information and Nutrition Facts labels must be on file.

Food and Beverage Requirements

Federal regulations prohibit the sale of food of minimal nutritional value including

carbonated water, water ices, chewing gum, and certain candies (hard,

marshmallows, fondants, licorice, jellies, gums, and candy-coated popcorn) in the

food service area during regular lunch and breakfast periods.

Illinois School Food Service Rules established beverage requirements for beverages

sold by participating schools before and during the regular school day including the meal

periods and food service areas. Beverages that may be sold include only the following:

• Flavored or plain whole, reduced-fat (2 percent), low-fat (1 percent), or nonfat fluid

milk that meets State and local standards for pasteurized fluid milk;

• Reduced-fat and enriched alternative dairy beverages (i.e., rice, nut, or soy milk, or

any other alternative dairy beverage approved by the United States Department of

Agriculture [USDA]);

• Fruit and vegetable drinks containing 50 percent or more fruit or vegetable juice;

• Water (non-flavored, non-sweetened, and non-carbonated);

• Fruit smoothie (yogurt or ice-based) that contains less than 400 calories and no

added sugars, and is made from fresh or frozen fruit or fruit drinks that contain at

least 50 percent fruit juice; and

• Any beverage exempted from the USDA’s list of Foods of Minimal Nutritional Value.

Illinois School Food Service Rules established requirements against the sale of

confections, all candies, and potato chips during the meal periods in the food service

area at participating schools in which classes of grades 5 and below are operating.

(This is a change to how the previous rules were implemented.)

All revenue from the sale of any food or beverage to students in the food service areas

during the meal periods must accrue to the nonprofit school lunch program account.

Local Wellness Policy

A locally developed wellness policy must be in place and re-evaluated periodically.

Food Service Management Company or Vended Meals Contracts

Current contract(s) and/or renewal agreement(s) must be available for review.

Invoices must be available from the previous and current school years.

Information regarding an advisory board to assist/evaluate menu planning must be

available.

School Food Authority Reviews

Food Distribution Program

Inventory records must be available for review.

All foods must be dated with the month and year of receipt.

All foods must be used on a first-in, first-out basis.

Written agreement must be on file for foods stored in a non-owned facility.

Processing agreement must be available for review, if applicable.

Contract/Bidding

Written bidding procedures must be established and followed for purchases or contracts

in excess of $100,000 per category per year.

Sanitation

Two Board of Health sanitation reviews must be conducted each school year, available

for review. If two inspections have not been conducted, a letter to the local health

department requesting the inspection(s) must be on file.

A copy of the most current review must be posted in a prominent place. Citations must

be corrected.

An Emergency Care for Choking poster must be posted in a prominent place.

Each site must have a food safety program for the preparation and service of school

meals to students based on Hazard Analysis and Critical Control Point (HACCP).

Civil Rights

Data must be on file to ensure denied applicants are not proportionately composed of

minority groups.

Data regarding the target population and beneficiaries of the program, by racial/ethnic

category, must be on file.

The following public notification requirements must be fulfilled:

• USDA-approved poster must be displayed.

• Informational materials must be made available in the appropriate translation, as

needed.

• Program material must include the nondiscrimination statement and the procedure for

filing a complaint.

Special Milk Program

The information reported on the Claim for Reimbursement must be supported by

adequate documentation.

• Accurately approved Household Eligibility Applications, direct certification

documentation, or categorically eligible documentation must be on file for children

receiving free milk. Monthly milk counts must validate the number of half-pints of

milk served to eligible children and claimed for reimbursement.

School Food Authority Reviews

• Dairy receipts must ensure an adequate amount of milk is purchased to support the

monthly milk counts.

School Breakfast Program

Accurately approved Household Eligibility Applications, direct certification

documentation, or categorically eligible documentation must be on file for children

receiving free or reduced-price breakfast.

Available claim data, by site, for each month must be available for review and include:

• Daily breakfast counts by category (free, reduced, or paid)

• Enrollment

• Number of children eligible for free and reduced-price breakfasts

Free, reduced-price, and paid breakfasts must be counted, by category, at the point of

service.

Breakfasts must contain components or menu items required by the selected menu

planning approach.

Anonymity of children receiving free and reduced-price breakfasts must be protected.

If Offer versus Serve is used, it must be implemented correctly for the selected menu

planning approach.

Menus/production records must contain all components/menu items.

For NuMenus, a nutrient analysis for each week must be available for review and include

all menu items and planned portion sizes.

After-School Snack Program

Non-area eligible sites must have accurately approved Household Eligibility Applications,

direct certification documentation, or categorically eligible documentation on file for

children receiving free or reduced-price snacks.

Area eligible sites must maintain attendance documentation on a daily basis.

Non-area eligible sites must count free, reduced-price, and paid snacks, by category, at

the point of service.

Area eligible sites must take an accurate daily count of the total number of snacks

served.

Monthly counts must validate the number of snacks served to eligible children and

claimed for reimbursement.

Menus must contain all components.

Anonymity of children receiving free and reduced-price snacks must be protected.

On-Site Reviews must be conducted twice annually for each site participating in the

snack program.

November 2009