Administrative Review Summary and Corrective Actions SFA Name: St John's Lutheran School Administrative Review Conducted on: 2/9/2017 SFA Contact Name and Title: Ms. Schneider, Principal CNR Reviewer: Diane Ruff The purpose of this spreadsheet is to inform you of the results of the Administrative Review that was conducted on February 9, 2016; an exit conference summarizing the findings took place on the same day. The Administrative Review is a comprehensive evaluation of the Local Education Agency s (LEA s) National School Lunch Program (NSLP) and School Breakfast Program (SBP). The AR consists of two performance standards. While findings were identified, the two performance standards reviewed were found to be satisfactory. During the Administrative Review, compliance with the new meal pattern requirements is also evaluated, at this time there are no menu findings that warrant the termination of the performance based reimbursement. This summary includes a comprehensive list of the technical assistance that was provided throughout the review as well as all findings that require a written response from the SFA. All items listed in the Corrective Action Plan must be submitted in writing to CN Resource, by Wednesday, May 3, 2017. Please complete the chart, an electronic version or a hand written response will be acceptable. If any additional responses are needed, please respond on district letterhead. Failure to submit the required materials by the due date may result in the withholding of claims. Should corrective actions not be submitted, a follow-up review may take place to ensure all required corrective actions were completed and implemented system-wide as appropriate. Any potential fiscal action will be calculated once the corrective action responses have been received and approved. I appreciate the courtesies extended by you and your personnel during the review. If you have questions or need assistance concerning the school food service program, please call our office. Please respond to the AR Corrective Action Document by Wednesday, May 3, 2017. Thank you,
Administrative Review Summary and Corrective Actions SFA Name: Administrative Review Conducted on: SFA Contact Name and title: CNR Reviewer: St John's Lutheran School 2/9/2017 Ms. Schneider, Principal Diane Ruff Commendations & Suggestions The staff listened to suggestions regarding the nutrition program. They were very willing to improve the program as necessary. The food was fresh and the staff was very nice to the students in the lunch line. Other areas of Technical Assistance (NOT requiring Corrective Action) Menu Review- Additional technical assistance was provided in an email to the SFA with the menu review results. Suggestions were provided to bring the menus into compliance. Menu Review- The egg noodles served on Wednesday are not whole grain-rich and therefore are not a creditable grain. They can still be served, but do not credit towards the grain requirements. The daily grain requirement is met this day with the bread served with the sandwich. If you want the egg noodles to credit toward the daily and weekly grain requirements, you must choose a whole grain-rich product. Cashier Training - During the review, training for cashiers and substitute cashiers was discussed. The SFA does not provide training to cashiers and substitute cashiers. It is recommended that the SFA provide training annually or as needed to cashiers and substitute cashiers. The SFA acknowledged the technical assistance and will implement needed changes. Direct Certification - During the review, retaining records was discussed with the SFA. The SFA must maintain Direct Certification lists on file or 3 years after the date of the fiscal year to which they pertain, except that if audit findings have not been resolved, the documentation must be maintained as long as required for resolution of the issues raised by the audit. Even if the SFA does not have any Direct Certification matches, they should still maintain copies of the lists showing that no matches occurred.
Local Wellness Policy - During the review, Local Wellness Policies were discussed with the SFA. The Local Wellness Policy is required to be made available to the public. The easiest method would be to post the wellness policy on the SFAs website. They can also send it out in a newsletter. The Local Wellness Policy is required to be reviewed and updated on a periodic basis to ensure that the policy reflects current requirements and SFA practices. The SFA is required to allow certain parties - parents, students, representatives of the school food authority, teachers of physical education, school health professions, the school board, school administrators, and the general public - to participate in the development, implementation, periodic review, and update of the Local Wellness Policy. The SFA must reach out to these parties to make them aware of their ability to participate. The SFA is required to perform an assessment of the Local Wellness Policy at a minimum once every three years. The results of the assessment need to be made available to the public. The SFA should use the results of the assessment to determine any changes or updates that need to be made to the wellness policy.
4 18 SFA Name: Administrative Review Conducted on: Sites Selected for Review: St John's Lutheran School 2/9/2017 St John's Lutheran School Date Corrective Action Plan was provided to SFA: Monday, April 3, 2017 Due Date for Corrective Action Plan: Wednesday, May 3, 2017 The following pages address the findings that were identified during your Administrative Review. For each finding you will be presented with the following: The finding, and details specific to the SFA regarding the finding The Code of Federal Regulations citation number or alternate resource citation A summary of the regulation / requirement Suggested guidance for the SFA in order to achieve compliance SFA area for reply to state how, when and by whom corrections will be made Please provide a detailed response to each finding in the spaces provided. Finding #1- Meal Components and Quantities: Review Month For the week of menu review, the K-8 lunch menu did not meet the minimum daily requirement of 1 ounce equivalent grain. A grain was provided, however the minimum required portion size was not met. During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. The SFA should review all menus to ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/ 210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: K-8: 1 oz. equivalent daily grain.
5 18 To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide an updated label for the bread showing at least a 1 oz. slice will be served to meet the daily grain requirements on Monday. Finding #2- Meal Components and Quantities: Review Month For the week of menu review, the K-8 lunch menu did not meet the minimum weekly requirement of 8 ounce equivalent grain. During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. The SFA should review all menus to ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/ 210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: K-8: minimum of 8 oz. equivalent of grains per week.
6 18 To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all weekly requirements for grains are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide an updated label for the bread showing at least a 1 oz. slice will be served to meet the daily grain requirements on Monday. This will also meet the weekly grain requirement. Finding #3- Meal Components and Quantities: Review Month For the week of menu review, the K-8 lunch menu did not meet the minimum daily requirement of 3/4 cup vegetable. Vegetables were provided, however the minimum required portion size was not met on Tuesday, Wednesday, and Friday. During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. The SFA should review all menus to ensure that at least the minimum portion size is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/ 210.10(c) Meal pattern for school lunches. Schools must offer the food components and quantities required in the lunch meal pattern established: K-8: 3/4 cup of vegetable.
7 18 To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all portion sizes planned meet at least the minimum required amount for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide updated production records showing that at least 3/4 cup creditable vegetables will be offered daily. This requirement was not met on Tuesday, Wednesday, and Friday of the review week. Finding #4- Meal Components and Quantities: Review Month For the week of menu review, the K-8 lunch menu did not meet the minimum weekly requirement of 1/2 cup dark green vegetable subgroup. During the review, the portion sizes required by the meal patterns were discussed with the SFA. The SFA must ensure that all meals counted for reimbursement contain the required components in the minimum portion size required for the specific grade group. This includes meeting the weekly requirements for the vegetables sub-groups. Over the course of the standard school week the SFA must at a minimum meet the required servings for each sub-group. The SFA should review all menus to ensure that at least the minimum serving for each sub-group is planned for the specific grade group. The SFA should also provide additional training to the kitchen staff on the requirements of a reimbursable meal. The training should include what to do if a certain planned menu item is not available or if the item runs out during service. The USDA FNS website can be used for training materials, resources and guidance on the meal pattern. http://healthymeals.nal.usda.gov/ 210.10(c)(iii) Vegetables component. Vegetable offerings at lunch over the course of the week must include the vegetable subgroups, as defined in this section in the quantities specified in the meal pattern in paragraph (c) of this section: K-12: 1/2 C dark green.
8 18 To come into compliance with meal pattern requirements, the SFA must provide a written plan that will be implemented to ensure future compliance. The plan should include; a statement that all menus will be reviewed to ensure that all weekly requirements for vegetable subgroups are met for the specific grade group, a process for sites to reference when they do not have one of the planned menu items or there is insufficient quantities, a statement that the serving line will be visually reviewed prior to service to confirm that all required components are available and that additional menu training for all SFA staff will be provided. Provide the outline and dates for the trainings that will be completed. In addition please submit the name(s) and title(s) of the SFA representative(s) that will oversee this area and ensure future compliance. Submit the menu from the week of review with the corrections that were made to the menu to bring it into compliance moving forward. Provide updated production records showing that at least 1/8 cup dark green vegetable was added to the menu for the review week. Finding #5 - Verification The SFA did not maintain documentation to demonstrate that Verification was completed. During the review, completing verification was reviewed with the SFA. The SFA was informed that they must complete verification according to regulations and within the correct timeframe. The SFA should review the current Income Eligibility Manual for additional verification information. CFR 245.6a(C)(1) General. The local educational agency must verify eligibility of children in a sample of household applications approved for free and reduced price meal benefits for that school year. To come into compliance the SFA must provide an assurance that staff conducting verification understand that verification must be completed each year. The SFA must put a plan in place to ensure that verification is completed correctly and within the correct timeframe. The plan should include when verification will begin and end, the process for completing verification, the person by position who will oversee verification, and how and where paperwork will be maintained. Finding #6 - Certification and Benefit Issuance The confirming official may not also be the determining official.
9 18 During the review the SFA was informed that the confirming official may not also be the determining official. The SFA should review the current Income Eligibility Manual for additional verification requirements. The SFA was also reminded that the hearing official may not be the determining, confirming, nor the verifying official. CFR 245.6a(e)(1)(i) Confirmation of a household's initial eligibility. Prior to conducting any other verification activity, an individual, other than the individual who made the initial eligibility determination, shall review for accuracy each approved application selected for verification to ensure that the initial determination was correct. If the initial determination was correct, the local educational agency shall verify the approved application. To come into compliance with basing the sample pool on the count as of October 1, the SFA must provide an assurance that staff conducting verification understand this requirement, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. Finding #7 - Meal Counting and Claiming The SFA does not complete an edit check for each meal service. During the review, edit checks were discussed with the SFA. The SFA does not conduct a daily edit check for each meal service. To be in compliance, the SFA must ensure that edit checks are completed daily. How to complete edit checks to ensure meal counts do not exceed attendance adjusted eligible and/or total enrollment was reviewed with the SFA. The SFA acknowledged the finding and will implement needed changes immediately. 210.8(a)(3) Edit checks. (i) The following procedure shall be followed for school food authorities identified in paragraph (a)(2)(ii) of this section, by other school food authorities at State agency option, or, at their own option, by school food authorities identified in paragraph (a)(2)(i) of this section: the school food authority shall compare each school's daily counts of free, reduced price and paid lunches against the product of the number of children in that school currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor.
10 18 To come into compliance with the requirements for counting and claiming, the SFA must provide an assurance that the appropriate staff understand these requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan to the State Agency. The plan must include: an indication that the SFA is now conducting a daily edit check for each meal service, a description of the new process that has been implemented, a description of the training that was provided to staff to inform them of the new process, the date the training was completed and the name and title of the SFA representative that will ensure compliance moving forward. Finding #8 - Civil Rights The SFA is using the incorrect civil rights statement. They are using an outdated version of the statement. During the review the requirement for the civil rights statement to appear on all Program material was discussed with the SFA. The SFA must use the statement on all Program material. FNS Instruction 113-1 IX A 3 Nondiscrimination Statement. All information materials and sources, including Web sites, used by FNS, State agencies, local agencies, or other subrecipients to inform the public about FNS programs must contain a nondiscrimination statement. It is not required that the nondiscrimination statement be included on every page of the program information Web site. At the minimum, the nondiscrimination statement, or a link to it, must be included on the homepage of the program information. To come into compliance with civil rights requirements, the SFA must submit an assurance that the current non-discrimination statement has been added to all program materials. In addition, the SFA must submit a sample of program materials, such as a menu or letter to households with the statement added. Finding #9 - Civil Rights The SFA does not have a procedure in place for handling civil rights complaints.
11 18 During the review the requirement for the SFA to have a complaint procedure was discussed. The procedure must indicate: that any person or representative alleging discrimination based on a prohibited basis has the right to file a complaint; all complaints, written or verbal, must be forwarded to the appropriate Regional or FNS OCR Director, unless an approved State complaint procedure is in place; in the event a complainant makes the allegations verbally or in person and refuses or is not inclined to place such allegations in writing, the person to whom the allegations are made must write up the elements of the complaint for the complainant. The procedure must also identify the outside agency to which the complaints are forwarded. FNS Instruction 113-1 Section XV All complaints, written or verbal, must be forwarded to the appropriate Regional or FNS OCR Director, unless an approved State complaint procedure is in place. Anonymous complaints will be handled as any other complaints, to the extent feasible, based on available information. To come into compliance with civil rights requirements, the SFA must develop a procedure that will be put into place to handle any discrimination complaints and to forward them to an appropriate agency. The process must outline the steps that will be taken when a complaint is received, the name and contact information of the agency that the complaint will be forwarded to, and the name(s) and title(s) of the person(s) who will be responsible for forwarding complaints to the appropriate agency. Please submit the procedure. Finding #10 - Local School Wellness Policy The SFA does not have a Local School Wellness Policy. During the review, Local Wellness Policies were discussed with the SFA. The Local Wellness Policy is required to contain the following: a designation of one or more SFA officials in charge of school compliance oversight; a plan for measuring compliance; goals for nutrition education, nutrition promotion, other school based activities to promote student wellness, and physical activity; and guidance for all foods available on school campus. The SFA should also contact the state agency to determine if there are any additional requirements from the state or if they have any state specific resources. The SFA was provided with the USDA link for Wellness Policies. http://www.fns.usda.gov/tn/local-school-wellness-policy 210.30 Local School Wellness Policy. (c) Content of the plan. At a minimum, local school wellness policies must contain: (1) Specific goals for nutrition promotion and education, physical activity, and
12 18 policies must contain: (1) Specific goals for nutrition promotion and education, physical activity, and other school-based activities that promote student wellness. In developing these goals, local educational agencies must review and consider evidence-based strategies and techniques; (2) Standards for all foods and beverages provided, but not sold, to students during the school day on each participating school campus under the jurisdiction of the local educational agency; (3) Standards and nutrition guidelines for all foods and beverages sold to students during the school day on each participating school campus under the jurisdiction of the local educational agency that; (i) Are consistent with applicable requirements set forth under 210.10 and 220.8 of this chapter; (ii) Are consistent with the nutrition standards set forth under 210.11; (iii) Permit marketing on the school campus during the school day of only those foods and beverages that meet the nutrition standards under 210.11; and (iv) Promote student health and reduce childhood obesity. (4) Identification of the position of the LEA or school official(s) or school official(s) responsible for the implementation and oversight of the local school wellness policy to ensure each school s compliance with the policy; (5) A description of the manner in which parents, students, representatives of the school food authority, teachers of physical education, school health professionals, the school board, school administrators, and the general public are provided an opportunity to participate in the development, implementation, and periodic review and update of the local school wellness policy; and (6) A description of the plan for measuring the implementation of the local school wellness policy, and for reporting local school wellness policy content and implementation issues to the public, as required in paragraphs (d) and (e) of this section. To come into compliance with the requirements for Local School Wellness Policies, the SFA must submit a written assurance that the appropriate staff understand the requirements for the wellness policy. The SFA must also develop a Local Wellness Policy that has all of the required areas and submit this. If the SFA needs additional time to develop the wellness policy and have it approved by the school board, the SFA must submit a detailed timeline that shows when each step will be completed. Once the policy is in place it must be submitted to the state agency for review. Submit the name and title of the SFA representative that will oversee this process and ensure compliance. Finding #11 - Professional Standards No one person has been designated as the food service director. Someone must complete the training hours required for a food service director. During the on-site review, hiring requirements were discussed with the SFA. To be in compliance in Illinois, the SFA must ensure that they will have a Food Service Director selected and that the required training hours are fulfilled. 210.30(b) Minimum standards for all school nutrition program directors. Each school food authority
13 18 must ensure that all school nutrition program directors meet minimum hiring standards, as set forth in this section for Illinois. To come into compliance, one person must be assigned as food service director. Please ensure that the hiring standards and training requirements are met. Please submit a copy of all hours of training completed and the dates of all future trainings. The SFA has not performed SFSP outreach. Finding #12 - Summer Food Service Program Outreach It was determined during the review that the SFA has not performed SFSP outreach. The SFA must perform SFSP outreach before the end of the school year. Methods of outreach such as posting SFSP information on the SFA's website, parent newsletters and district-wide emails were discussed with the SFA. Schools may fulfill this requirement through Robo calls, flyers or other methods that notify the community of locations of summer meal sites. Methods to locate sites that serve free meals to children during the summer include the following: Call 211 Call 1.866.3Hungry or 1.877.8Hambre Visit the website: www.fns.usda.gov/summerfoodrocks (note, this replaces the whyhunger.org website) Use the site locator for smartphones - Rangeapp.org 210.12(d)(2) School food authorities must cooperate with Summer Food Service Program sponsors to distribute materials to inform families of the availability and location of free Summer Food Service Program meals for students when school is not in session. To come into compliance with this requirement, the SFA must submit an assurance that the SFA will cooperate with Summer Food Service Program sponsors to conduct outreach on the availability of the Summer Food Service Program. Additionally, please state the name and position of the person who will oversee compliance in this area. Finding #13 - Reporting and Recordkeeping
14 18 Records were not retained for 3 years after the final Claim for Reimbursement for the fiscal year or until resolution of any audits. The SFA did not maintain documentation for notification letters, or the verification process. Records must be retained for three (3) years after the final Claim for Reimbursement for the fiscal year or until the resolution of any audits. It was determined that the SFA was not retaining records for 3 years after the final Claim for Reimbursement. The requirement for the SFA to retain records for the required time period was discussed with the SFA. 210.23 (c) Retention of records. State agencies and school food authorities may retain necessary records in their original form or on microfilm. State agency records shall be retained for a period of 3 years after the date of submission of the final Financial Status Report for the fiscal year. School food authority records shall be retained for a period of 3 years after submission of the final Claim for Reimbursement for the fiscal year. In either case, if audit findings have not been resolved, the records shall be retained beyond the 3-year period as long as required for the resolution of the issues raised by the audit. To come into compliance with reporting and recordkeeping requirements, the SFA must provide written assurance that the appropriate staff understand these requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. The plan must include: an indication that records will now be maintained for required time period, the process that has been put into place to ensure that all required records will be maintained for 3 years after the final claim for reimbursement or until the resolution of an audit, and state the person(s) name(s)/title(s) who will oversee that all records are properly retained. Finding #14 - Certification and Benefit Issuance The SFA does not have a copy of the household notification of approval/denial of benefits letter on file, there is no documentation to ensure that the notification letters included all required fields. During the review, household notification of eligibility status was discussed with the SFA. For all households that qualify for benefits must be notified within 10 days of receipt of the completed application, however it is not required that these households are notified in writing. The SFA must notify the household of denied benefits in writing, the notification must be provided within 10 days of receipt of a completed application. At a minimum the notification of denial letter must include The reason for the denial of benefits, e.g. income in excess of allowable limits or incomplete application, notification of the right to appeal, instructions on how to appeal, and a statement reminding parents that they may reapply for free or reduced price benefits at any time during the school year. For additional information on the notification letter the SFA should review the Eligibility Manual for School Meals, Chapter 3.
15 18 245.6(c)(6) Notice of approval (i) Income applications. The local educational agency must notify the household of the children's eligibility and provide the eligible children the benefits to which they are entitled within 10 operating days of receiving the application from the household. 245.6(c)(6)(ii) Direct Certification. Households approved for benefits based on information provided by the appropriate State or local agency responsible for the administration of the SNAP, FDPIR or TANF must be notified, in writing, that their children are eligible for free meals or free milk, that no application for free and reduced price school meals or free milk is required. To come into compliance with the requirements for household notification, the SFA must provide a written assurance that staff administering the free and reduced lunch program understand these requirements. The assurance should include a statement that, the SFA will notify the household of eligibility status within 10 days of receipt of the completed application, a statement that any denied households will be notified in writing, and a process that will be implemented to ensure that are households are notified of eligibility within the required timeframe. Please submit a copy of the notification of denied benefits letter with the corrective action response. Finding #15 - Meal Components and Quantities - Day of On-Site Observation Signage is not posted near or at the beginning of the serving line identifying what constitutes a reimbursable meal for breakfast or lunch. During the review, the importance of signage was discussed with the SFA. The SFA must ensure that signage is posted near or at the beginning of the serving line identifying what constitutes a reimbursable meal. 220.8(a)(2) Unit pricing. Schools must price each meal as a unit. The price of a reimbursable lunch does not change if the student does not take a food item or requests smaller portions. Schools must identify, near or at the beginning of the serving line(s), the food items that constitute the unit-priced reimbursable school meal(s). 210.10(a)(2) Unit pricing. Schools must price each meal as a unit. Schools need to consider participation trends in an effort to provide one reimbursable lunch and, if applicable, one reimbursable afterschool snack for each child every school day. If there are leftover meals, schools may offer them to the students but cannot get Federal reimbursement for them. Schools must identify, near or at the beginning of the serving line(s), the food items that constitute the unit-priced reimbursable school meal(s). The price of a reimbursable lunch does not change if the student does not take a food item or requests smaller portions.
16 18 To come into compliance with the meal signage requirements the SFA must state that the proper signage has been posted. Please submit a copy of the signage used and indicate where in the serving line it was posted. Also please note the date that the signage was posted. Include the person by position that will oversee that the signage has been posted and how this person will keep all staff informed that signage is required. Finding #16 - Certification and Benefit Issuance Not all selected applications were approved correctly. 1 application was calculated incorrectly resulting in the application going from Free to Reduced, 1 application should go from free to denied because the household did not provide income frequency. 1 application was selected for Verification and the household did not respond, this application moves from Free to Denied. During the review, determining applications was discussed with the SFA. When determining eligibility, the SFA must ensure that updated information obtained by the SFA is properly documented as outlined in the Eligibility Manual for School Meals, Chapter 3. Complete applications must include the appropriate documentation. 245.2 Documentation means: (1) The completion of a free and reduced price school meal or free milk application which includes: (i) For households applying on the basis of income and household size, names of all household members; income received by each household member, identified by source of the income (such as earnings, wages, welfare, pensions, support payments, unemployment compensation, and social security and other cash income); the signature of an adult household member; and the last four digits of the social security number of the adult household member who signs the application or an indication that the adult does not possess a social security number. When determining eligibility, the SFA must ensure that the household has listed the amounts, source, and frequency of current income for each household member; otherwise, the application is incomplete. For more information, see the Eligibility Manual for School Meals, Chapter 3. When determinizing the total household income the SFA must use all income provided on the application. 245.6(c)(4) Calculating income. The local educational agency must use the income information
17 18 provided by the household on the application to calculate the household's total current income. When a household submits an application containing complete documentation, as defined in 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in 245.2, the children in that household must be approved for free or reduced price benefits, as applicable. Eligibility Manual, Chapter 3: A complete application must provide: Names of all household members; Amount, source, and frequency of current income for each household member. Eligibility Manual, Chapter 3: If any change is made after the initial approval of eligibility for free or reduced price benefits during the current school year such as a household s request to decrease their meal benefits or voluntary withdraw the determining officials must indicate the change on the application, using the same method used to record initial eligibility determinations, by: Noting the change; Recording the date of the change; and Implementing the change by updating rosters or other methods used at point of sale, if necessary. To come into compliance with the requirements for determining applications, the SFA must provide an assurance that staff administering the free and reduced lunch program understand these requirements, and the SFA must put a plan in place to ensure future compliance. Please submit the assurance and plan. Applications found to be incorrectly determined during the review must be corrected, and the corrected application and date of the correction must be submitted to the State Agency. If the SFA is unable to correct the error because of missing/incomplete information from the household, after allowing the household an adequate amount of time to respond, the SFA must send a letter of adverse action and advise of the date that this letter was sent. Signature of Reviewer: Diane Ruff Date: 2/9/2017 Signature of SFA Representative: Date: If you have any questions, feel free to contact CN Resource at your convenience. Thank you. Administrative Review Team CN Resource P.O. Box 31060 Mesa, AZ 85275 866-941-6368 adminreview@cnresource.com
18 18 Please insert your detailed responses, save, print, sign, scan and upload the signed copy to cnrsupport.com by the due date indicated. Thank you.