Meal Counting and Claiming Nuts and Bolts of School Nutrition August 2, 2017

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Meal Counting and Claiming Nuts and Bolts of School Nutrition August 2, 2017 Presented by: Cindy Sarapas Julianna Valcour Office for Food and Nutrition Programs USDA Non-Discrimination Statement In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov. 2 This institution is an equal opportunity provider. and Secondary Education and Secondary Education 1

What is the Purpose of an Accurate Meal Counting and Claiming System? To ensure the validity of the School Food Authority s (SFAs) monthly claim for reimbursement 3 Components of a Successful Meal Counting and Claiming System Eligibility Documentation Point of Service (POS) Meal Counts Collection Procedures Reports Internal Controls 4 Claim for Reimbursement and Secondary Education 2

Applicable Regulation 7 CFR 210.18 (2)i All free, reduced price and paid lunches claimed for reimbursement are served only to students eligible for free, reduced price and paid lunches, respectively Lunches are counted,recorded, consolidated and reported through a system which consistently yield correct claims 5 Video 1 Making it Count Developing Acceptable Meal Counting and Collection Procedures http://www.makingitcount.info/training/module-7 6 and Secondary Education 3

Quiz What does a meal need in order to be counted as reimbursable? Meet meal pattern requirements Accurately recorded at the point of service No overt identification of eligibility 7 Eligibility Documentation Must include: Documentation for each student receiving a free or reduced price meal, i.e., -D/C matches and household members -application -source eligibility The number of eligible students in each category (free, reduced and full price) -Meal benefit issuance roster Eligibility information within the medium of exchange is accurate 8 and Secondary Education 4

Point of Service (POS) Meal Counts The point at which staff determines that a reimbursable meal has been served to an eligible child or student. Common POS locations are school cafeterias Alternate POS include classrooms and hallways POS meal counts must be done for every meal claimed for reimbursement. Breakfast Lunch After School Snack At Risk Snack & Supper 9 Count and Claim Accurate meal count: Reimbursable meals -meal pattern -one meal per child per day By category Recorded each day Prevent Overt Identification 10 and Secondary Education 5

Collection Procedures Overt identification is when a child is openly or physically identified as receiving a free or reduced price meal Separate meal service lines for students who are eligible for free, reduced-price and paid meals Color-coded tickets for free/reduced eligible students Serving different meals Simple roster coding methods, such as F,R,P; or 1,2,3 Asking a student their eligibility No prepayment system or an underutilized prepayment system A casual observation of your point of service should never be able to tell who is free, reduced price, or paid 11 Medium of Exchange Cash or any type of ticket, token, I.D., name or number which eligible students trade for obtaining a meal Must allow for daily updates The meal count/collection system must prevent overt identification throughout the entire process 12 and Secondary Education 6

Acceptable Mediums of Exchange Systems: 1. Coded Roster 2. Coded ticket/token 3. Coded I.D. cards/bar code/pin pad 13 Collection Procedures Coded rosters Acceptable Coding Examples: Coding by series: (1000 sequence for free, 2000 sequence for reduced and 3000 sequence for paid) Coding by student ID number: Using the last digit in a student s ID number to indicate the appropriate eligibility category (0 for free, odd number for reduced and even number for paid) 14 and Secondary Education 7

Coded Roster Examples include: name checklist, class list, number list Advantages Cannot be stolen, lost or destroyed Documentation of meal count is produced during meal service as names/numbers are checked off on a roster or number sheet. If used with a number sheet, may be a fast method Disadvantages Can be used by another student or twice by the same student if more than one serving line. Coded roster sheet is time consuming for cashiers using manual system. 15 Coded Ticket/Token Advantages Disadvantages When collected at point-ofservice, provides a means of physically counting meals by category. When used in small to medium schools, counts by category can be completed quickly after the meal service Can be destroyed, transferred, lost, stolen or sold. In large schools, too cumbersome to collect and count all tickets or tokens by category after the meal service. If not coded properly, may result in overt identification. 16 and Secondary Education 8

Coded I.D. cards/bar code/pin pad Advantages Disadvantages Provides accurate count and saves time; compiles meal count by category at the same time the students are counted Students do not have to be in the line by classroom; lines moves at the same pace whether the cashier knows all of the students names or not Prevents overt identification on the line Provides automated reports Students may forget their numbers, thus slowing the line I.D. cards can be lost, destroyed or transferred. Start-up and operating costs may be high If more than one service line, there may be two meals claimed if the electronic machines are not linked 17 Quiz! Acceptable Meal Counting Systems? YES NO YES NO YES NO YES NO YES NO 1. Claims based only on meal counts taken in the morning in the classroom or at any other location before the meal is served. 2. Claims based on attendance records. 3. Meal counts based on the number of tickets or tokens sold and distributed or the number of meals paid in advance. 4. The number of free and reduced-price meals claimed based on the number of students eligible to receive such meals. 5. Meal counts by category taken at the beginning of the serving line without checking that the meals served are reimbursable. 18 and Secondary Education 9

Quiz! Acceptable Meal Counting Systems? YES NO YES NO YES NO YES NO YES NO 6. Meal counts by category based on visual identification of students with no backup system available for persons not familiar with the students; e.g., checklists. 7. Meal counts based on tray or plate counts. 8. Back-out systems used that subtract one number (e.g., number of free and reduced-price meals) from the total count to get another number (e.g., the number of fullprice meals). 9. The students who are eligible for meal benefits overtly identified. 10. A system that does NOT yield a reliable, accurate count of meals served by category. 19 Unacceptable Meal Count Systems Attendance counts Tray, plate or entree counts Classroom counting Prepaid/charged meals counted on day paid Second meals claimed for reimbursement Ineligible persons claimed for reimbursement Cash converted to meals A la carte items claimed for reimbursement Category/cash back-out system Delivery counts of meals produced off-site Visual identification without backup 20 and Secondary Education 10

Determine which type of meal counting system is best for each site. It may vary from site to site. It may also vary from breakfast to lunch. 21 Other types of Eligibility Documentation and Meal Counts Residential students only RCCI-1 Form: Record of enrollment for free eligible students based on household of one Day students Eligibility Roster: Indicating free, reduced and paid eligibility based on meal benefit applications or direct certification 22 and Secondary Education 11

RCCI-1 Enrollment Form RCCI-1 form for each residential facility/site Update as residents enter and or withdraw Maintain separate RCCI-1 for each Fiscal Year 23 Meal Count Roster Meal Count Roster- must be used when claiming day students as free, reduced, or paid. Counts must be totaled daily across eligibility category. Eligibility code prevents overt identification at POS. 24 and Secondary Education 12

Video 2 Making it Count Consolidation and Reporting http://www.makingitcount.info/training/module- 8a/ 25 Meal Count Consolidation Reports Daily Potential Income Sheet FP-9 form 26 and Secondary Education 13

Daily Potential Income Sheet Daily Cash/Cash Reconciliation Sheet Tracks daily sales by category Free, reduced price, paid Breakfast, lunch, snack, special milk A la carte Adult sales (including meals tax) Pre-payments Cash reconciliation 27 Daily Potential Income Sheet 28 and Secondary Education 14

FP-9 Meal Count Sheet FP-9 for every school site Record meals by eligibility Edit checks- A,B,C and D Signature of site/facility representative Monthly submission to person consolidating claim 29 30 Reference: ESE Document and Reference Library NSLP National School Lunch Program - FP-9 and Secondary Education 15

Complete the following:.944 Part A: Attendance Factor Part C: February 28, 2011 F = 80 R= 15 P =175 Part D: Average Daily Participation Part B: Edit Checks Do free counts exceed approved free applications on file? Do reduced counts exceed approved reduced applications on file? 80 15 175 172 87 17 31 Internal Controls The SFA must establish internal controls to ensure that an accurate claim for reimbursement has been made by: Completing daily edit checks Monitoring 32 and Secondary Education 16

Edit Checks Helps identify errors in the schools lunch counts and/or problems with the meal counting and claiming procedures so that necessary corrections are made USDA requires SFAs to complete an edit check for each site prior to consolidation of the daily meal counts for the monthly claim for reimbursement 33 Edits Checks USDA S REQUIRED EDIT CHECK PROCEDURES FOR EACH SCHOOL 1. Obtain and record the highest number of students in each category 2. Compute the attendance factor 3. Multiply the number of enrolled children approved in each meal category (free, reduced-price and paid) by the monthly attendance factor 4. Compare the attendance adjusted eligible figures to the daily counts of free, reduced-price and paid meals 5. Provide written justification next to any day where the count exceeds the attendance-adjusted number. (Sample justification could be meal participation increased due to a pizza day or special promotion.) 34 and Secondary Education 17

Edit Check: Attendance Adjusted Eligible Highest # of Student Attendance Factor Highest # of Lunches Approved in Month (average daily attendance Expected for Any school enrollment) Serving Day Free X = Reduced-Price X = Paid X = 35 Edit Check: Attendance Adjusted Eligible School s highest number of students approved for free meal benefits during the month: 112 School s highest number of students approved for reduced price benefits during the month: 25 School s highest daily enrollment for students with access to the lunch program: 540 School s highest number of students in the paid category: 540 137 = 403 School s average daily attendance: 510 School s attendance factor: 510 540 =.944 Highest # of Student Attendance Factor Highest # of Lunches Approved in Month (average daily attendance Expected for Any school enrollment) Serving Day Free 112 X.944 = 105.7 or 106 Reduced-Price 25 X.944 = 23.6 or 24 36 Paid 403 X.944 = _380.4 or 380 and Secondary Education 18

Other Edit Checks Patterns or repetition of numbers Counts which equal the number of eligibles Counts equal to the number of meals delivered Identical counts on certain days (like every Monday or at breakfast and lunch) All of these are red flags which may tell you that you need to investigate further 37 Making it Count Making the FP-9 Count http://www.makingitcount.info/training/module- 8a/activity/ 38 and Secondary Education 19

Video 3 Making it Count Accuclaim Monitoring Report http://www.makingitcount.info/training/module- 8b/ 39 Site Monitoring Accuclaim: (Accurate Claim) SFAs must monitor the lunch service at all sites to evaluate meal counting procedures by February 1 each year. Monitoring of breakfast is also required at 50% of school breakfast sites. SFAs participating in the After School Snack Program must monitor snacks twice per year (once during the first 4 weeks of school and one other during the year). SFAs should record monitoring activities on required forms located in the document library. Report results to ESE by February 9, 2018. 40 and Secondary Education 20

Site Monitoring Monitors should ensure that sites do not claim the following meals/food: Adult Meals Second meals eaten by eligible students Suppers or dinners (third meal of the day) unless the SFA participates in the Child and Adult Care Food Program (CACFP) At-Risk Afterschool Program Snacks served on ineligible days Meals not meeting the meal pattern Meals served outside the required meal periods, unless otherwise approved A la carte items Meals being claimed through another program. 41 Accuclaim On Site Review Breakfast 42 and Secondary Education 21

Accuclaim On Site Review Lunch 43 After School Snack Program Site Review 44 and Secondary Education 22

Take A Final Look Before Hitting Submit Make sure edit checks have been conducted on each school s counts Consolidate daily meal counts to monthly site totals by meal Once you ve completed the edit, conducted your comparisons, found no problems, you can submit your claim 45 School Site Information For All Schools Including RCCI s with Both Day and Residential Students Input counts by site (under school selection) Information from site FP-9 is used to fill out the claim for reimbursement 46 and Secondary Education 23

Remember: Meal Counts Records Retention SFAs must retain original meal count records for the current day and month by site SFAs must retain all meal counts records, including rosters and site monitoring reports for three (3) years after the submission of the final claim for reimbursement for the fiscal year, plus the current fiscal year s records. If there is an open audit for any fiscal year, all records must be retained until closure notification of the audit. 47 For All You Do! 48 and Secondary Education 24

Questions 49 Created in Partnership: 2014 Meal Counting, Claiming and Reimbursement- A. Chisholm and K. Kefalas and 2015 Meal Counting and Claiming- D. Iovanna and Secondary Education 25