Presented by : Lisa Brown-Taylor, M.S., R.D., Consultant

Grants Coordination and School Support

School Nutrition Programs

August 2011

Coordinated Review Effort (CRE)

State agencies must conduct a Coordinated Review Effort (CRE) for all School Food Authorities (SFA) once every 3 years in accordance with the comprehensive review cycle.

During a CRE, only selected schools are reviewed; all of the schools in the SFA are not reviewed.

The CRE is conducted at two organizational levels – the SFA and schools.

The focus of the CRE is performance in two time periods, the Day of Review and the Review Period. Some findings may extend outside the review period.

Standard Review forms ensure that all critical and general areas are reviewed in the same way for all School Food Authorities.

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Coordinated Review Effort (CRE)There are two primary review components: Critical Areas of Review and General Areas of Review:In the Critical Area there are two Performance Standards.

Performance Standard 1 – Certification, Counting, and Claiming

Performance Standard 2 - Menu PlanningIn the General Area, the following areas are reviewed:

Free and Reduced Price Process Verification Food Quantities Civil Rights Monitoring Reporting and Recordkeeping Food Safety and Sanitation Procurement

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CRE Form SFA-1

Performance Standard 1All free, reduced price and paid meals claimed for reimbursement are served only to children eligible for free, reduced price or paid meals respectively; and are counted, recorded, consolidated and reported through a system that consistently yields correct claims.

Performance Standard 2It is all about menu compliance. The reimbursable meals contain food items/components as required by the regulations.

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CRE Form SFA-2

Review of Performance Standard 1 Certification

Determine if direct certification is used and review documentation.

Verify the SFA process for Claim Reimbursement.

Validate counts for review period by eligibility categories; free, reduce price, and paid.

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CREForm S-1: School Information

School information. Count of eligible students. Counts for day of review. Counts for the review period.

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CREForm S-2: Performance Standard 1Applications must be complete, accurate, and approved.Most common errors:All household members are not included (the adult that signed the application is not included as household member).

• Incomplete or incorrect food stamp numbers.• Income calculated incorrectly. Income must be annualized. All

household incomes must be reported even if there is “no income.”

• Incomplete application – not signed and/or dated by an adult household member.

• Incomplete application– the last 4 digits of the social security number (SSN) are missing or the box for “no SSN” is not checked.

• Administrative Applications – no supporting documentation provided to allow for administrative approval.

• Homeless, Migrant, and Runaway applications are not verified by the school liaison.

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CREForm S-2 continued

Have eligible students been Directly Certified? Were foster children approved as categorically

eligible? Were homeless, migrant, and runaway youth,

correctly certified? Were all applications approved correctly? Was the eligibility status on a timely basis? Were 10% of the names on the benefit issuance list

incorrect, resulting in a 5% or greater error rate?

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CREForm S-3: Day of Review PS 1 & PS 2

Does the serving line Point of Service (POS) provide an accurate count of meals served by category?

Were the meal counts correctly combined and recorded?

Menus – were all items available to the students according to the menu planning approach used?

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CREForm S-4: Review Period PS 1

Were lunch counts for the day of the review consistent with counts for the review period?

Were there days when free lunch counts exceeded number of eligible or attendance adjusted eligible?

Were there patterns in the free, reduced or paid lunch counts which appear questionable?

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Were the documents (menus, production records, etc.) for the review period complete and accurate?

Were all required items offered based on menu planning system?

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CREForm S-4: Review Period PS 2

CREForm S-5: Application/Benefit Issuance Errors

S-5 is the application error worksheet for recording certification and benefit issuance errors.

Note the types and duration of application errors: Start date, Missing Information, Miscategorized Eligibility, Benefit Issuance Errors, PS 1 Violation, Date Inactive or Corrected, Number of Days Application in Error.

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CREForm S-6: Meal Error Rate

Summarize the data from S-5. Meal error rate is determined.

Determine the percentage of incorrectly claimed meals contributing to Performance Standard 1 violation.

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CREForm S-7: Menu Planning Errors: Day and Month of Review

Evaluate menu on the day of review and for the review period.Record serving period observations to make sure all students have opportunity to take all 5 food items.Check menu for review period to make sure all 5 items offered on daily basis. Corroborate with production records.Potential fiscal action from missing menu items.

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CREForm S-8: All Other Potential Errors

Examine other meal claim errors identified during the review that have not been recorded.

Prior errors including meal components, application errors, etc. for months outside of the review period.

Errors found in the Breakfast Program or Special Milk Program, only if included in the scope of the administrative review.

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CREGeneral Review Areas

General review areas are at two levels:School Food AuthoritySchool Level

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CREGeneral Review Areas: G-1 SFA

Reporting and Recordkeeping: Keep documentation for 3 years plus current year or until resolution of any audits.Annual student/parent input.Most recent Nutrition Review.

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CREGeneral Review Areas: G-1 SFA

Monitoring Responsibilities:On-site review(s) must be completed by February 1st. If corrective action is necessary the follow up review must be completed within 45 days. Provide documentation for corrective action.

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CREGeneral Review Areas: G-1 SFA

Monitoring Responsibilities continued …Prior to submitting a claim, edit checks for attendance adjusted eligible students by category, (free, reduced price, and paid) must be compared to daily meal counts.The system must check out every day, but can be completed weekly or monthly.Daily counts that exceed the attendance adjusted eligible edit check must be evaluated prior to consolidation.

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CRE General Review Areas: G1-SFA

Establish a Local Wellness Policy and keep a copy on file.

Foods of Minimal Nutritional Value (FMNV):Sold in meal service area of any building

in the SFA during breakfast or lunch? Is the school food service paying for the

purchase of FMNV?

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CREGeneral Review Areas: G2-SFA

Students with special dietary needs are met as prescribed by the regulations.

Meal substitutions are accurately documented.

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CREGeneral Review Areas: G2-SFA

Free and Reduced Price Process:Verification must be completed on time and with the correct number of applications according to requirements.Follow required procedures for conducting confirmation.Complete verification summary sheet.Submit LEARS report on time.

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CREGeneral Review Areas: SFA Review

Forms completed by SFA prior to the CRE review:G-3 Food Safety and SanitationG-4 ProcurementG-5 Food Service Management CompanyG-6 USDA Foods

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CRE General Review Areas: G-7

Accountability:Advertise pre-payment.Point of Service system must prevent overt identification.Price school meals as a unit.Adult meal prices must follow equity for school lunch pricing guidelines.Reduced price charged does not exceed maximums.

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CRE General Review Areas: G-7

Meal Service:

All milk choices must be 1% fat content or less.

http://www.fns.usda.gov/cnd/Governance/Policy-Memos/2011/SP_29-2011-os.pdf

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CRE General Review Areas: G-7

Meal Service continued…Production records document menu items and quantities prepared, served, and leftover. Substitutions are accurately recorded on the production records.

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CRE General Review Areas: G-7

Meal Service continued…Menu planning approaches are accurately implemented:

Food BasedEnhanced food Based Nutrient Standard

Offer versus Serve (OVS) is properly implemented based on menu planning approach.

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CRE General Review Areas: G-8

Food Safety and Sanitation:Food safety plan is available on siteStandard Operating Procedures (SOPs)for:

Washing HandsCleaning and Sanitizing Food Contact SurfacesReceiving DeliveriesCooking Potentially Hazardous Foods

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Food Safety and Sanitation continued…HACCP Process Approaches for menu items:

• Process 1- No Cook• Process 2- Cook and Same Day Service• Process 3 – Complex Food Preparation

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CRE General Review Areas: G-8

CRE General Review Areas: G-8

Food Safety and Sanitation continued…Documentation/Logs for:

Thermometer CalibrationFood TemperaturesRefrigerator/Freezer Temperatures

Post the most recent food safety inspection in a publicly visible location

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CRE General Review Areas: G-8

School Breakfast Program:The breakfast menu must meet all regulatory requirements.There must be an accurate point of service for breakfast.

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CRE General Review Areas: G-8

After School Snack Program:Provide an organized, structured and supervised after school snack program.There must be an accurate point of service for the after school snack program.The snack menu and production sheets meet regulations.On-site reviews are required twice a year.

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Post Award Civil Rights Compliance Review

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CRE information @ www.michigan.gov/schoolnutrition

For more information about the Coordinated Review Effort :www.michigan.gov/schoolnutritionScroll down to Compliance Reviews Click on Coordinated Review Effort

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www.michigan.gov/schoolnutrition

To view a webcast:

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Questions?

School Nutrition Programs517-373-3347MDE-schoolnutrition@michigan.gov