Counting, Claiming and CEP – The 3 C’s

SNT Pre review Workshops2014

MEAL COUNTING Eligibility Documentation Collection Procedures Point of Service Meal

Counts

ELIGIBILITY DOCUMENTATION

You must have documentation supporting the eligibility of each

student receiving free and reduced priced meals.

Free/reduced price meal household applicationDirect certification listPublic schools only – certified list of homeless,

migrant, foster or runaway

COLLECTION PROCEDURESSteps

◦ Receiving payments for meals from students◦ Issuing and collecting the medium of exchange◦ Policy for handling meal charges and unpaid accounts

Medium of exchange:

Cash Ticket

Token ID

Name Number

Collection ProceduresOvert Identification: Eligibility must never be publicized or used in such a way that students’ eligibility may be recognized by other students or staff. Must be prevented during issuing and collecting of the medium of exchange.

Overt Identification…What do you think?

When the reviewer visits your school he/she observes the following:

A. The computer, visible to students, shows how much a student is charged for meals.

◦ If students or faculty or others are able to see how much a student is charged for lunch this is overt ID.

B. Student check lists used by the teacher have free students highlighted in yellow and reduced students highlighted in green for easy identification.

◦ This would be considered overt ID. USDA requires that only those who have a direct need to know have access to the information.

C. A student comes up to the reviewer during the onsite visit and says loudly “I get free meals”

◦ This is called “self disclosure” and the school is not held responsible.

Point of Service Meal Count Systems

Electronic Debit◦Bar Codes◦Personal identification numbers (PIN)

TicketsCheck-off List

Point of Service (POS)The point where it can be determined that a student has received a reimbursable meal, after having been offered all of the required components.

(end of line)

Alternate to the Point of Service

Meal count is taken at the beginning of the line, with another adult at the end of the line monitoring the student’s tray to ensure that they have a reimbursable meal. The system must be able to verify that students receive a reimbursable meal. Non reimbursable meals must be subtracted from the day’s meal count.The online contract will specify the POS

POINT OF SERVICE MEAL COUNT

Procedures must guarantee that meals will:

Meet meal pattern requirements for the specific grade grouping and offer versus serve option indicated on Schedule A of the on-line contract for your agency/site.

Are served to eligible students (only one lunch per eligible student per meal service may be claimed for reimbursement).

Are counted daily by category (free, reduced price and paid).

Point of Service is Required for All Programs including…

Special Milk Program ½ day students who do not have access to

school breakfast or lunch.Wisconsin School Day Milk ProgramSchool Breakfast ProgramAfterschool Snack ProgramNational School Lunch ProgramSack lunches or meals served away from POS

POS -What Do You Think?During the onsite visit the reviewer observes the following…

A. Kindergarten children go through the line but the teacher already has the milk on the table at their place.

◦ All components must be available to students prior to the POS .

B. An aide comes to the cafeteria and hands a list of students to the foodservice and picks up food for the classroom.

◦ Meals must be counted at the time a student receives the meal. In this case a classroom checklist, completed in the classroom, would be necessary to ensure the student received a reimbursable meal.

C. A teacher brings all of the cards to be scanned to the cashier. The children go through the line and the bundle is scanned after lunch when it’s not so busy.

◦ Meals must be counted as students receive the meal.

D. A student tells the monitor that they will pick up a fruit or vegetable at the salad bar located in the middle of the cafeteria.

◦ All components must be available to students prior to the POS or alternate authority agreement monitor.

Meal Counts by School

◦ The number of “schools” or “sites” for your agency is based on the number of “schools” listed on Schedule A of your on-line contract.

◦ There may be more than one “school” within a building.

◦ You must be able to retrieve meal counts for each “school” serving meals.

◦ Individual School counts drive Severe Need breakfast eligibility.

UNACCEPTABLE MEAL COUNT SYSTEMS

Attendance counts:

using the number of students in attendance as a meal count

Tray or entrée counts:

counting the number of trays or entrees used during the meal service to obtain or validate the meal count

Classroom counts:

counting the number of students in class, prior to meal service, who intend to order and/or eat a meal

OTHER UNACCEPTABLE SYSTEMS

Counts taken anywhere other than the point of service.

Cash converted to meals:

using cash totals to determine the number of meals served

Category/cash back-out system:

one or more of the meal categories are calculated by subtracting the number of meals of one or more meal categories from the total meal count

Delivery counts of meals produced off-site:

the number of meals delivered to a school is not necessarily the number of meals that were actually served

Reimbursement Claims

Your reviewer will ask to see the most recent claims* and supporting documentation for each program your SFA participates in

*The reviewer may also ask to seeClaims from other claim periods.It is important to have the documentation assessable

All claims must be based on

Accurate daily Point of Service meal counts (free, reduced and paid) by school

Attendance adjusted edit check on each school’s daily meal counts

Accurate consolidation of meal counts

Accurate submission of monthly claim

electronically

Meal Counting and ClaimingCommon Findings

Counts are obtained using improper procedures Are not split out by school Incorrectly combined and consolidated Not completed daily Contain questionable patterns

All meal counting and claiming systems must:◦ consistently provide an accurate count◦ taken daily at the point of service by eligibility category◦ taken at each meal service◦ be monitored and checked for inaccuracy

REPORTS

Numbers of daily reimbursable meals, for each category (F,R,P) to eligible students are recorded for each site.

Recording method must ensure that correct counts by category are reported in a way that is easily read, edited and consolidated (if more than one site) into an accurate online monthly claim for reimbursement.

The SFA must be able to provide claims documentation for any time periods requested by the reviewer.

SFAs must maintain all program records for a period of 5 years

INTERNAL CONTROLS

Established to ensure that an accurate claim for reimbursement has been made

Protects schools from potential claiming errors

The Edit Check DocumentCompares meal count data to other information to

identify possible problems in the meal count system

Based on an attendance adjusted eligible/s factor

Meal counts that do not seem reasonable must be explained or investigated

The claim preparer is the responsible party

EDIT CHECKSThe reviewer will ask…

Most software systems have an edit check calculation in place

Schools must be able to access and examine the report for accuracy

Schools without software must use a manual edit check systemDPI prototype may be downloaded at: http://www.dpi.wi.gov/files/fns/doc/editcheck.doc

Edit Check Common Findings

Meal counts that exceed the number of eligible students in attendance

Meal counts that are the same every dayMeal counts where extremely high percentages of

eligible students eat every dayCounts that seem to repeat in patternsCounts that are the same as the number of meals

deliveredEdit Check delegated to FSMC rather than SFA

Monitoring – A Self Check (for SFAs with more than one serving site)

Must be completed prior to February 1

SFA’s self check to ensure that meal count reports are based on an approved counting system

SFA’s self check to ensure that their counting system yields an accurate count reimbursable free, reduced-price, and paid meals for each day of operation

Problems require corrective action and follow up by the SFA

May not be delegated to the FSMC

Finding the Forms Manual Edit Check

◦ http://www.dpi.wi.gov/files/fns/doc/editcheck.doc

On-site MonitoringSFA must use this form

◦ http://fns.dpi.wi.gov/files/fns/doc/on_site_mf_0311.doc

A new Alternative for 2014-2015…

Community Eligibility Provision (CEP)

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Who is Eligible to participate in CEP?

LEAs and schools must have an identified student percentage of 40% or greater. The 40% threshold can be determined by individual schools, groups of schools, or the entire LEA. RCCI’s are not eligible to participate in CEP

Identified Students

Students certified for free meals without the use of a household application

◦ Direct Certification ◦ Head Start, Even Start ◦ Foster Care, Runaway, Homeless, or Migrant◦ Students living in households participating in Food Share, Wisconsin

Works (W-2), or FDPIR Enrolled Students include:

Students who are enrolled in and attending schools participating in CEP and have access to at least one meal service daily.

Reimbursement under CEP

The ISP is multiplied by a factor (1.6) to obtain total meals served that will be reimbursed at the federal free rate. The remaining percentage of total meals is reimbursed at the Federal paid rate.Claiming percentages are guaranteed for 4 years. There is not a reduced category under CEP.Claiming percentages must be applied separately to SBP and NSLP.

Approved claiming percentages

Can be obtained:

On the most recent CEP approval letter sent to the LEAs authorized representative.

On the child nutrition program online contract.

Do not confuse the approved claiming percentages with the approved ISP.

BENEFITS

All Students eat meals free of charge

Participation may increase

Reduces paperwork

◦Applications

◦Verification

◦May decrease direct certification runs

CONSIDERATIONS

SFA’s will still be required to collect individual alternative household income data for other programs such as Title 1, SAGE and ISIS.

Schools without 100% free reimbursement may not use federal funds to cover the deficit

Funds from the non-profit school food service account cannot be used to distribute, process or determine eligibility of alternate applications

CEP and the Administrative Review

At least one CEP site will be reviewed.

The latest approved Identified Student Percentage (ISP) certification documents will be verified.

◦ direct certification lists◦ extension of benefits documentation ◦ homeless, migrant liaison lists

Claims will be monitored for accuracy with the claiming percentages.

Records Retention Retain any documentation used in the development of the ISP during the entire period CEP is in effect. ◦ initial approval year◦ year any updates are made◦ extensions or grace years

*Retain for an additional 5 years after the submission of the final claim for reimbursement for the last fiscal year of CEP.

CEP -What Do You Think?During the onsite visit the reviewer observes the following…

A. The number of meals claimed as free exceeds the maximum number of meals allowable under the CEP agreement.◦ The meals claimed must meet the percentages set up for the school

based on the online contract. This information is calculated and determined by DPI once the ISP is submitted.

B. Adult meals are being claimed for free student reimbursement. ◦ As always, schools must track and report non-reimbursable meals on

the monthly claim. Adult meals cannot be claimed for student reimbursement.

C. Meals for CEP are based on attendance records.◦ Meals claimed under CEP must still meet point of service

requirements that ensure students are receiving reimbursable meals.

Additional Materials & Resources:

School Nutrition Team website: http://fns.dpi.wi.gov/fns_cep ◦ CEP Monthly Reimbursement Estimator ◦ Frequently Asked Questions ◦ USDA memos on CEP◦ CEP Application◦ Alternative Household application

FRAC (Food Research and Action Center)

http://frac.org/federal-foodnutrition-programs/

First steps for a positive AR Experience?

Remember the C’s

Counts

Eligibility

Collection procedures

Claims

Point of Service

Internal Edits

CEP

Accurate ISP

Accurate Claims

The AR process is not intended to “get” schools who don’t comply.

It is intended to provide schools with the tools and guidance they need to operate a quality nutrition program.

Working Together We will meet that goal!

Remember…

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Feeding children Matters… Thank

You for all that you

do!

The U.S Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)

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