SNP Administrative Review

Resources

Administrative Review Manual

Administrative Review Checklist

USDA Food and Nutrition Service

What is an administrative review?

An administrative review is a comprehensive evaluation by state agencies (SAs) of school food authorities (SFAs) who participate in the National School Lunch Program (NSLP) and School Breakfast Program (SBP), and includes both critical and general areas of review.

General areas mean the areas of review as specified in 7 CFR 210.18(h). There is no fiscal action attached to general areas.

Critical areas mean Performance Standard 1 (PS1) and Performance Standard 2 (PS2) measures of performance under the administrative review, as described in 210.18(g). There are fiscal implications attached to critical areas.

  • PS1 means the standard requiring that all free, reduced-price, and paid meals claimed for reimbursement are served only to children eligible for free, reduced-price, and paid meals, respectively; and counted, recorded, consolidated, and reported through a system which consistently yields correct claims (7 CFR 210.18(g)).
  • PS2 means the standard requiring that reimbursable lunches must meet the meal requirements in 7 CFR 210.10, as applicable to the age/grade group reviewed. Reimbursable breakfasts must meet the meal requirements in 7 CFR 220.8 and 220.23, as applicable to the age/grade group reviewed (7 CFR 210.18(g)).

There are several different modules to go through during an administrative review. The module numbers are listed in the accordions below. Module numbers that have a "PS1" or "PS2" next to them mean that they are critical areas of review. Module numbers without those listed next to them mean that they are general areas of review.

100—Certification and Benefit Issuance (PS1)

The certification and benefit issuance process covers the SFA's certification of a student's eligibility for free or reduced-price meals and the link to the SFA's meal counting and claiming system. The SA's examination of certification and benefit issuance is essential to ensure eligible children receive meals to which they are entitled, and that Claims for Reimbursement are valid.  More detailed information on Certification and Benefit Issuance is available here.

Documents Reviewed

  1. Point of sale rosters from month of review (all schools except CEP)
  2. Free and reduced meal applications (all schools)
  3. Benefit notification letters
  4. Minimum of 10 denied meal applications
  5. Direct certification (DC) downloads
  6. Migrant, homeless, and runaway DC documentation
  7. Head Start direct certification enrollment list(s)
  8. Residential Child Care Institution (RCCI) eligibility documentation sheet
200—Verification

Verification is a process used by SFAs to confirm selected students' eligibility for free and reduced-price meals in the NSLP and SBP. Verification is only required for a sample of students whose eligibility is certified using a household application submitted with income information or a case number for the Supplemental Nutrition Assistance Program (SNAP), Food Distribution Program on Indian Reservations (FDPIR), or Temporary Assistance for Needy Families (TANF). More detailed information on verification is available here.

Documents Reviewed

  1. Verification file to include a minimum of three verified applications
  2. Correspondences
  3. Notification letter
  4. Summary of results
  5. Direct verification list (if available)
300—Meal Counting and Claiming (PS1)

The SFA must have a meal counting and claiming system that accurately counts, records, consolidates, and reports the number of reimbursable meals claimed, by category (i.e., free, reduced-price, or paid). The meal counting and claiming process must include a mechanism, whether manual or electronic, for counting meals and consolidating meal totals at each school within the SFA. The mechanism must include an internal control system that validates the total meal counts prior to the submission of the Claim for Reimbursement to the SA. More detailed information on meal counting and claiming is available here.

Documents Reviewed

  1. Breakfast and lunch daily meal counts for all schools (review month, and the day and week of the onsite review)
  2. Attendance adjusted edit checks (review month)
  3. Meal counting documentation to support the claim for reimbursement (review month)
  4. Meal waivers (if applicable)
400—Meals Components and Quantities (PS2)

The scope of review for this module is to establish that meals claimed for reimbursement contain the appropriate meal components (also referred to as food components) and quantities for the SBP and the NSLP. The meal pattern is the foundation of federal school nutrition programs, and SA staff must ensure SFAs are offering reimbursable meals at breakfast and lunch according to the regulations. More detailed information on meal components and quantities is available here.

Documents Reviewed

  1. One week's menu (must be a minimum of three consecutive days [review month])
  2. Six Cent Worksheet (breakfast and lunch worksheets for the review month for all reviewed schools)
  3. Production records (review month, and the day and week of the on-site review for all reviewed schools)
  4. Nutrition labels
  5. Standardized recipes
  6. Crediting documentation (Child Nutrition labels, USDA Foods Fact Sheets, product formulation statements)
  7. Whole grain-rich labels and/or supporting documentation
  8. Product specifications in the procurement documents
  9. Meal compliance risk assessment tool (MCRAT) (all schools reviewed)
  10. Grain and milk waivers (if applicable)
500—Offer versus Serve (OVS)

OVS is a provision in the NSLP and SBP that allows students to decline some of the food components/items offered. The goals of OVS are to reduce food waste in the school meals programs while permitting students to decline foods they do not intend to eat. The review of OVS is a PS2 review element. More detailed information on OVS is available here.

Documents Reviewed

  1. OVS training documentation
600—Dietary Specifications and Nutrient Analysis

The Dietary Specifications and Nutrient Analysis module details procedures to assess whether meals offered to children through the school meal programs are consistent with federal standards for calories, saturated fat, sodium, and trans fat (7 CFR 210.10 (f)). To reduce childhood obesity and minimize students' risk of chronic disease, SA staff must ensure SFAs are offering meals that meet regulatory requirements. More detailed information on dietary specifications is available here.

Documents Reviewed

  1. Dietary specifications assessment tool (completed on the school with the highest MCRAT score)
  2. Nutritional analysis (must be conducted on high-risk indication on the dietary specifications assessment tool)
700—Resource Management

The intent and scope of monitoring in this section is to apply a systematic approach to ensuring the overall financial health of an SFA's nonprofit school food service. This section consists of a review of four areas integral to the financial health of the SFA's school food service. The monitoring areas are:

  1. Maintenance of the Nonprofit School Food Service Account
  2. Paid Lunch Equity (PLE)
  3. Revenue from Nonprogram Foods
  4. Indirect Costs

More detailed information on resource management is available here.

Documents Reviewed

  1. Off-site assessment must be completed four weeks prior to the onsite assessment
  2. District enrollment reports/data
  3. Audit reports and findings and follow-up actions from the previous three years
  4. Reports to validate total revenues, expenditures, and operating balance from the previous year
  5. PLE Tool (current and previous school year)
  6. PLE flexibility approval (current and previous school year) (if applicable)
  7. PLE waivers
  8. Revenue from non-program foods tool (current and previous school year)
  9. Indirect cost documentation (if applicable)
  10. Fund balance on July 1 (current and previous school year)

If an SFA receives one or more risk indicators in one of the four Resource Management areas, the SA must conduct a comprehensive review of the area in which the risk indicator was received using the Resource Management Comprehensive Review Tool. If an SFA receives one or more risk indicators in more than one area, the SA must conduct a comprehensive review of each area in which a risk indicator was assessed.

Comprehensive Review Documents Reviewed

  1. Balance sheet (most recently closed school year)
  2. General ledger or comparable document of allowable expenditures (10 percent sample of expenditures)
  3. All accounting information by school and consolidated (money reconciliation, deposits, income, and expenditures)
  4. Cash disbursement journal and revenue journal (previous school year)
  5. Reconciliation (all SNP accounts)
  6. Deposit slips and reconciliation working papers
  7. Indirect costs documentation to confirm current and past years' calculations and any loan agreements (if applicable)
800—Civil Rights

Food and Nutrition Service (FNS) requires SFAs to administer program services and benefits in accordance with all laws, regulations, instructions, policies, and guidance related to nondiscrimination in program delivery. The SA must assess whether the SFA is complying with civil rights requirements as applicable to the Child Nutrition Programs, e.g., NSLP (including the Fresh Fruit and Vegetable Program, Seamless Summer Option, and Afterschool Snack Program), SBP, and Special Milk Program. More detailed information and training materials is available here.

Documents Reviewed

  1. Board-approved civil rights policy
  2. Civil rights training documentation (agenda and sign-in sheets)
  3. Special diet documentation (if applicable)
900—Onsite Monitoring

The SA must determine whether each SFA performs no less than one on-site review of the lunch counting and claiming system used by the school and observe the general areas of review that are readily observable in each school under its jurisdiction. For breakfast, at least 50 percent of the SBP have to be monitored every two years.

*SFAs with only one site do not have to complete the onsite monitoring piece.

The on-site monitoring toolkit is available here.

Documents Reviewed

  1. On-site review documents for breakfast and lunch (reviewed schools)

*May be current year or prior year depending on review date

1000—Local Wellness Policy and School Meal Environment

To help foster a healthy school environment, the Healthy, Hunger Free-Kids Act of 2010 requires each Local Education Agency (LEA) to establish a comprehensive Local School Wellness Policy. The scope of monitoring may require the SA to assess how unit(s) of the LEA—other than school food service—implement their Local School Wellness Policy responsibilities, as applicable. More detailed information on Local School Wellness Policy is available here.

Documents Reviewed

  1. Documentation supporting a local school wellness policy
1100—Smart Snacks in Schools

Schools must meet the minimum requirements in 7 CFR 210.11 for all foods and beverages sold in school (also known as Smart Snacks in Schools) to increase consumption of healthful foods during the school day and support a healthy school environment. The SA's responsibility is to understand the entities responsible for selling foods/beverages to students, and to ensure that food and beverages sold meet the minimum requirements established in 7 CFR 210.11. More detailed information on Smart Snacks in Schools is available here.

Documents Reviewed

  1. Documentation showing total amount of food and beverages sold (review month)
1200—Professional Standards

The Professional Standards regulations in 7 CFR 210.30 establish hiring standards for new school nutrition program directors at the SFA level. In addition, the regulations establish annual training standards for all school nutrition program directors, managers, and staff. The required annual training hours vary according to the employee's role in the management and operation of the school nutrition program. More detailed information on professional standards is available here.

Documents Reviewed

  1. District enrollment report or documentation
  2. Employee counts from offsite review and day of review
  3. Employee position, status, and date of hire
  4. Employee training hours conducted and/or planned (current school year)
  5. For directors hired after July 1, 2015, documents to support highest level of education obtained, school nutrition experience, and food safety training documentation
1300—Water

The goal of the water review is to ensure that children have access to water during the lunch and breakfast meal services. During the on-site visit, the SA must observe and assess whether the school makes free water available to students as required.

1400—Food Safety, Storage, and Buy American

It is the SA's responsibility to ensure that all selected schools meet the food safety and storage requirements and comply with the Buy American provisions specified by the regulations referenced in (7 CFR 210.13) and (7 CFR 210.21). This includes any facility where food is stored, prepared, or served for the purposes of the NSLP, SBP, or other FNS programs. here.

Documents Reviewed

  1. Hazard Analysis Critical Control Points Plan and updates
  2. Temperature charts (review month, all reviewed schools)
  3. Food safety inspections (two most recent)
  4. Food safety training documentation
  5. Documentation that sample items were grown and produced in the U.S. or territories
  6. Documentation of pre-approved exception for items not grown or produced in the U.S.
1500—Reporting and Record Keeping

The SA must determine whether reports are submitted (as required by the SA) and maintained with other program records for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. If audit findings have not been resolved, the three-year period is extended as long as required for resolution of audit issues. Additionally, the record retention period required by a state may exceed the three-year period (7 CFR 210.23(c)). More information on recordkeeping is available here.

Documents Reviewed

  1. Documentation supporting three years of record retention
1600—SBP and Summer Food Service Program (SFSP) Outreach

The goal for monitoring this area is to determine whether the SFA conducts the required outreach activities to increase participation in the SBP and SFSP.

SFAs must inform families of the availability of breakfasts offered under the SBP and meals offered through the SFSP. FNS also requires schools to conduct SFSP outreach before the end of the school year to ensure that eligible families are informed of the availability and location of SFSP meals. More information on SFSP is available here.

Documents Reviewed

  1. Documentation supporting outreach efforts
1700—Afterschool Snacks

The SA's review is intended to ensure participating schools serve students nutritionally-balanced snacks, provide appropriate activities, and count and claim snacks accurately. The SA must examine afterschool snack documentation for each school selected for the administrative review that operates after-school snacks. More information on after school snacks is available here.

Documents Reviewed

  1. Documentation to support claim
  2. Production records
  3. Menu
  4. Nutrition crediting information
  5. Onsite review documentation
1800—Seamless Summer Option (SSO)

The SSO permits SFAs participating in the NSLP and/or SBP to serve meals during summer and/or other school vacation periods using the same meal service rules and claiming procedures they use during the regular school year. More information on seamless summer is available here.

Documents Reviewed

  1. Site eligibility
  2. Meal counting and claiming
  3. Menu planning
  4. Advertisement
  5. Self-monitoring
  6. Civil rights
  7. Food safety
1900—Fresh Fruit and Vegetable Program (FFVP)

The FFVP aims to increase children's exposure to and consumption of a variety of fruits and vegetables. FNS intends the review of the program to ensure that participating schools are proper stewards of federal funds and operate the program as prescribed by FNS. More information on FFVP is available here.

Documents Reviewed

  1. Claim records with product documentation
  2. Serving calendar
  3. Educational enrichment information
  4. Documentation used to promote the program
  5. Cost documentation
2100—Special Provision Option (SPO)

To reduce administrative challenges, local educational agencies LEAs/SFAs with a high percentage of free and reduced-price certifications may elect to use an SPO. More information on special provisions and the Community Eligibility Provision (CEP) is available here.

Documents Reviewed

  1. CEP original Identified Student Percentage and DC student documentation
  2. Proof of the number of identified students
  3. Proof of the number of enrolled students