SCN Record Keeping Requirements 2016 - Kentucky ...education.ky.gov/federal/SCN/Documents/SCN Record...

Record Keeping for School Meal ProgramsSFA’s must retain records and documentation concerning all aspects of operating a Child Nutrition Program. While it can be tedious and overwhelming, it is important that appropriate and adequate records are maintained.

SFA’s must retain documentation to support:

• Information/data reported to the State Agency

• Program operations are in compliance with regulations

• Demonstrate that policies and procedures are properly implemented

• Sound program operational decisions are made

Record Retention RequirementsThe general rule of thumb for record retention of program records is that they must be maintained for a period of three years after submission of the final Claim for Reimbursement for the fiscal year. However, if there are any audit findings and they have not been resolved, the three-year period is extended as long as required for resolution of audit issues.

There are three (3) main exceptions to this rule of thumb:

1. Temperature logs are required to be maintained for a period of six (6) months

2. Provision 2 – Base year records

3. CEP - ISP records

All Provision 2 and CEP records must be retained for three years after submission of the final claim for reimbursement. Records must continue to be retained if any audit findings from the period during which the records were in use remain outstanding. In any such case, records must be retained until all issues raised by the audit have been fully resolved.

The base year in Provision 2 establishes a claiming percentage that is utilized in subsequent years in the Provision 2 cycle. The base year records must be maintained for three years after the final claim for reimbursement that utilized the percentages established by the base year is filed.

Base year records for Provision 2 to maintain:

Student eligibility certification records

Verification Records

Claims

Meal Count Records

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The records demonstrating that the claiming percentages established by the base year are properly applied for the Provision 2 cycle and any approved extensions are:

Monthly claims for reimbursement

Meal count records used in claiming

For Community Eligibility Provision (CEP), SFA’s must retain those records used in the development of the Identified Student Percentage (ISP) (e.g., records for the initial approval year and all records from the year any updates are made to the ISP) during the entire period the CEP is in effect.

The SFA’s April reporting establishes the ISP that will be used in the CEP cycle. When establishing a base year for a CEP cycle, the April data reported in the school year prior to the base year is the information that must be maintained until the end of the cycle, plus three years after the last claim is filed.

If April reporting indicates that the ISP is higher than the established percentage currently used for claiming, SFA’s are encouraged to establish a new base year and start a new cycle. If the SFA does not elect to start a new cycle with the higher ISP, the records for the base year and the updated ISP must be maintained for three years after the last claim is filed for the CEP cycle.

The records used in the April reporting and used to establish an ISP must come from the Child

Nutrition Programs point of service system. The records that must be reported from and

maintained are:

The number of enrolled students on April 1st

The number of identified students (directly certified) on April 1st

The list of student names of the enrolled students

The list of student names of the identified (directly certified) students

SFA’s may need to maintain records longer than what is outlined in federal requirements if there are local policies in the districts/organizations that dictate records be maintained for a longer period of time. Local policies cannot be followed if the record retention is for a lesser period of time than the federal requirements.

Records and DocumentsThere are numerous recordkeeping requirements related to the operation of a child nutrition program. Some recordkeeping requirements have a required format or form that must be used. However, most required documentation is up to the SFA’s to determine how they will document and maintain theses records in their schools and districts. For example, SFA’s must use the “Onsite Monitoring Form” found on SCN’s website to document the onsite reviews they conduct. However, in verification there is not a required form or format that must be used when

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documenting information concerning follow up attempts with households who haven’t responded. In this instance the SFA has to determine how this recordkeeping requirement will be handled in their operation.

SFA’s at times will use their own record keeping documents to record information that is later transferred over to a required form or format. In these instances the SFA’s records that were used to create or develop the information that is transferred or used on the required form is considered the source documentation and must be maintained with the required form. For example, it is a common practice for production staff to record the number of servings prepared in notebooks or commonly called a “cooks’ book” in the kitchen while preparing meals so that they don’t have to write and erase on the actual production record. The manager then rewrites information from the notebook onto the production record after the meal service. In this instance the “cooks’ book” is the source documentation for the number of servings prepared and must be maintained with the production record in order to have the required documentation about the number of portions prepared for the meal service.

Adequately DocumentedWhen determining how a to document and record program operations the guiding principle of creating an auditable trail should be followed to ensure that operations are adequately documented. This criterion of “adequately documented” does not imply the existence of a one‐size‐fits‐all definition of “adequately.” It means, that the record of a school meal programs’ operation must be able to stand on its own without being dependent on further information, interpretation, or “spin” by the program operator.

For example, it should be self-evident from the review of meal counting records what students ate lunch on which days in the month that made up the number of lunch meals claimed for reimbursement.

Storage of RecordsSFA’s are encouraged to develop a system of document retention that allows them to be readily retrieved when needed. Electronic recordkeeping is an allowable form of record storage and is encouraged as an avenue to reduce the amount of paper SFA’s maintain. Districts/organizations may have policies related to electronic record keeping that SFA’s may need to include in their record keeping processes.

When storing records electronically, the records should be stored in a manner in which they are accessible to others within LEA when needed and in a secure manner. Any student identifying information should be in a locked cabinet or similar manner in which individuals outside of the Child Nutrition Program do not have access to the information. While it may be convenient to access records when they are stored locally on a computer, the records may easily be lost due to computer issues and will not be accessible to others if needed. It is highly recommended that electronic records are backed up to a secure server or saved a portable storage device that is then stored in a secure location.

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The charts below provide a brief overview of records SFA’s should maintain. This list is not meant to be all inclusive. Depending upon program operations within individual schools and organizations or

ongoing changes to policies and regulations there may be additional records that must be maintained. SFA’s should refer to guidance, policy and regulations for further information.

Meal Counting and Claiming

Record of Meals ServedSFA’s must maintain records of the number of meals served at a point of service in order to claim meals for reimbursement. These records must (1) Record the total number of reimbursable meals served by eligibility category and (2) create cumulative monthly reports.

Records Required for AR POS reports,

electronic record or manual records

Retention/Submission Per onsite record

retention policy

Frequency Daily Weekly Monthly

cumulative

Due Date/sn/a

Edit Checks Edit Checks are designed to be a tool for SFA’s to (1) check the accuracy of the number of meals claimed by eligibility category for a specific meal period and month of operation and (2) reduce the incidence of overclaims. SFA’s are required to perform Edit Checks daily and monthly on cumulative data prior to filing a claim for reimbursement..If more meals are served than anticipated, the SFA must investigate and document resulting action.

Records- Required for AR- POS software reports

or forms


retention policy

Frequency- Daily- Monthly

Due Date/s- Daily- Monthly

Provision 2SFA’s operating breakfast and/or lunch under the provision 2 option must maintain the documentation to support the establishment of the base year data and the application of the claiming percentages used in subsequent years.

Records Required for AR Base year eligibility

certification documents

Base year verification Base year claims Base year meal

counts


retention policy

Frequency Daily Monthly

Due Date/sn/a

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April Reporting/Identified Student Percentage – N/A to residential only RCCI’sSFA’s must report the number of identified students through direct certification and the total enrollment at each school site as of April 1st. This data is utilized to identify potential CEP eligibility and to establish the claiming percentage utilized by CEP schools. Reports must be generated by the SFA’s point of service system and not the school’s enrollment system.

Records- Required for AR- The number of

enrolled students and the number of directly certified student students on April 1st for each school.

- A list of all students enrolled in each school that makes up the enrollment numbers reported.

- A list of students in each school that are identified as D.C. that make up the number of Identified Students reported.

- Electronic direct certification March history file

Signed lists for homeless, runaway, migrant and Head start.


retention policy Submitted through

CNIPS.

Frequency Annually

Due Date/s Annually per SCN

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Free and Reduced Price Process

Public Media Release – N/A for residential only RCCI’sNear the beginning of each school year, the public must be notified that free and reduced price meals and free milk are available. This notice must include the eligibility criteria for free and reduced price meals or free milk or the schools participation in the Community Eligibility Provision. It must be provided to the local news media, the unemployment office, and any major employers who are contemplating large layoffs in the attendance area of the school. The media release must contain all informational elements outlined in the current year Eligibility Manual for School Meals.

Records Required for AR Content of the Public

Media Release must follow the guidelines outlined in the current years USDA Eligibility Manual for School Meals.


retention policy Must be submitted

to the SA and approved as part of the Policy Statement.

Frequency Updated annually

Due Date/s Required release at

or close to the beginning of the school year.

Required to be submitted for approval in the Policy Statement prior to use.

Household Application, Letter to Households and Instructions – N/A Full CEP and residential only RCCI’sSFA’s must (1) retain a copy of each household’s application and (2) record any information related to approval, denial, or termination of benefits on the application. As well as any updates during the program year. SFAs using electronic applications must have a way to record and retain the same information.

Records Required for AR- Must use the current

year prototype household application. State Agency approval required annually for use of any other form or format.


retention policy Must be submitted

to the SA and approved as part of the Policy Statement.

Frequency As needed- Updated annually

Due Date/s Required release

prior to or during the first week of school and as students enroll

- Required to be submitted for the Policy Statement prior to use.

Individual Determination Form – Used only for residential only children in RCCI’sRCCI’s must determine residential children’s eligibility status through the use of an Individual Determination Form in order to be reimbursed at the free rate for the meals served.

Records Required for AR- Use form on SCN’s

website.

Retention/Submission- Per onsite record

retention policy

Frequency As needed- Updated annually

Due Date/s- Annually- Ongoing

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Direct Certification Documents – N/A for residential only RCCI’sThe documents used to provide a student a directly certified eligibility status must be maintained. A designation due to SNAP benefits takes precedence for the reason for D.C. if more than one avenue to a D.C. status applies. Once the avenue for D.C. is identified as SNAP, this should remain constant for the rest of the program year regardless if other reasons for D.C. designation are identified.

Records Required for AR Electronic copies of

each monthly D.C. file and corresponding history file.

Signed lists from respective homeless, migrant, runaway and/or Headstart coordinator.


retention policy

Frequency Ongoing as

needed Each electronic

D.C. list must be saved on a monthly basis.

Due Date/s Electronic D.C.

downloads should be conducted on a monthly basis.

Ongoing for other forms of D.C.

Income Eligibility Guidelines (IEG) Chart – N/A Full CEP and residential only RCCI’sThe income eligibility guidelines are released annually from Congress to be used in determining the income guidelines to qualify for free or reduced meals. The income eligibility chart must be included in the public media release and the letter to households that accompanies the household application.

Records Required for AR Use format provided

in the current year prototype application packet.


retention policy

Frequency As needed Updated annually

Due Date/s Released annually

Appeals related to Student EligibilityWhen households appeal the eligibility determination of their household application, records of the appeals process must be maintained to demonstrate compliance with requirements.

Records Required for AR Any related Communications Timelines and

Outcome


retention policy

Frequency As needed

Due Date/s- Annually

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Letter to Household of Approval/Denial of Benefits – N/A for Full CEP and residential only RCCI’sThese letters are sent to parents or guardians to inform them that their children are approved or denied for free or reduced-price meals or free milk.

Records Required for AR Must use current year

prototype letter or have alternate approved by the SA each program year.


retention policy

Frequency As needed Updated annually

Due Date/s Upon eligibility

determination.

Letter of Eligibility—Direct Certification – N/A for Full CEP and residential only RCCI’sSFA’s must notify households that their children are Directly Certified to receive free meals without the submission of a household application.




retention policy

Frequency Ongoing

Due Date/s Upon certification

Confidentiality and DisclosureSFA’s are required to keep all information concerning student eligibility confidential and must maintain documentation that any disclosures to persons outside of the school meals program is in compliance with federal regulations.

Records Required for AR Disclosure

agreements Disclosure policy Requests for

information Signed

confidentiality agreements for all persons provided information.


retention policy

Frequency Ongoing

Due Date/s- Ongoing

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Effective Date of EligibilitySFA’s must be approved by the SA to establish the effective date of eligibility as the date in which an application or D.C. information was received instead of when the information is processed. Refer to the current year eligibility manual for all requirements related to this flexibility.

Records Required for AR SA approval of the

SFA’s procedures for implementing the flexibility date of eligibility (meal counting and claiming procedures)

SA approval of use in the sponsor application

Documentation of the date in which information was received in the district

Records demonstrating that any charges or money collected in the time period between being the information being received and when it was processed is forgiven or reimbursed to the household prior to claiming.


retention policy Approval

submitted through CNIPS during online application renewal.

Frequency As needed

Due Date/s Must be approved

annually Documentation of

time of receipt and forgiveness/reimbursement in place prior to claiming.

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Verification Activities and Verification for Cause

Verification Sample Size – N/A for Full CEP and residential only RCCI’sDocuments or reports utilized to determine the number of approved free and reduced household applications on file as of October 1st. Documents or reports should indicate the number of apps approved for free or reduced benefits by income or categorical eligibility.

Records should indicate the type of verification conducted the calculation of the number of applications to verify. (All SFA’s must conduct standard verification unless approved by the SA to use an alternate method in their sponsor application.)

Records Required for AR Use of these forms or

similar forms


retention policy

Frequency Annually

Due Date/s- October 1st

Confirmation Reviews – N/A for Full CEP and residential only RCCI’sAn individual other than the determining official must confirm that the original determination for free or reduced benefits was correctly determined.

Records Required for AR Document signature

and date of confirmation official per district protocol.


retention policy

Frequency- Annually

Due Date/s- Prior to notifying the

household of their selection for verification.

Replacement of selected application - N/A for Full CEP and residential only RCCI’sIf the SFA replaces a selected application for verification, a like application must be selected.

Records Required for AR- Document per district

protocol.


retention policy

Frequency Annually

Due Date/s Prior to notifying the

household of their selection for verification.

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Notification of Selection for Verification Letter - N/A for Full CEP and residential only RCCI’sThis letter informs households of the selection of their household application in the verification process.




retention policy

Frequency Annually

Due Date/s- Upon completion of

confirmation review.

Follow Up - N/A for Full CEP and residential only RCCI’sIf the households have not responded to their notice of verification, SFA’s are required to make at least 1 attempt to follow up with the household to try and obtain the necessary documents.

Records Required for AR Document per district

protocol.


retention policy

Frequency- Annually

Due Date/s- Prior to November 15th

(Best practice – 2 weeks after notification)

Household Documentation Submissions - N/A for Full CEP and residential only RCCI’sHouseholds must submit documentation to support all of the income information provided on their household application or documentation of any case number provided on a household application.

Records Required for AR- Maintain documents

and any related communication with households per district protocol.


retention policy

Frequency Annually

Due Date/s November 15th

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Results of Verification Notification Letter - N/A for Full CEP and residential only RCCI’sSFA’s must inform parents or guardians of households the results of the verification process.




retention policy

Frequency Annually

Due Date/s Upon completion

of validating a household application. All must be validated and letter sent by November 15th.

FNS-742/Verification Report – All schools including CEP and RCCI’s must report!The SFA’s must annually report information related to their verification activities (if applicable). Full CEP districts and RCCI’s report the number of schools/sites and the number of enrolled students as of October 1st. Most point of service electronic systems have the capability create a report to provide the information and data required for this reporting event.

Records Required for AR Entered into CNIPS.

SFA’s should maintain documents that support the submission.



CNIPS

Frequency Annually

Due Date/s Per SCN

announcement

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Onsite Monitoring

Onsite Monitor Review FormSFA’s with 2 or more schools are required to conduct an onsite review on the lunch meal counting and claiming procedures at each school site by February 1st. While not required, it is highly encouraged that SFA’s conduct a review on breakfast meals as well.

Records Required for AR Must use the onsite

monitoring form on the SCN website.


retention policy

Frequency Annually

Due Date/s- By February 1st

Follow up Review When problems are identified during the initial monitor review, SFA’s must identify and implement corrective action. A follow up review must be conducted within 45 days to ensure the corrective action is implemented and adequately addresses the issue(s) identified in the monitor review.

Records Required for AR Must use the



retention policy

Frequency As applicable

Due Date/s 45 days after

onsite monitor review.

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Community Outreach

Breakfast Outreach DocumentationSFAs must inform families of the availability of breakfast. Notification must be relayed just prior to or at the beginning of the school year. Families should be sent reminders regarding the availability of breakfast multiple times throughout the school year.

Records Copy of notification

to families.


retention policy

Frequency Annually Ongoing

throughout school year.

Due Date/s Required

notification prior to or at the beginning of school year.

Ongoing throughout the school year.

Summer Feeding Outreach DocumentationSFAs must inform eligible families of the availability and location of free meals for students offered by all summer feeding sponsors in the attendance areas of their school after the regular school year ends. Notification can be through any means normally used to communicate with the households of enrolled children.

Records Copy of notification

to families.


retention policy

Frequency Annually

Due Date/s At the end of the

school year.

Record of Student-Community-Parent InvolvementSFAs must document any involvement of students, community members and parents or guardians at sites operating a school nutrition program each school year.

Records Form is available on

SCN’s website.


retention policy

Frequency Ongoing annually

Due Date/s- Ongoing annually

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Resource Management

Capital Expenditure RequestSCN must grant prior approval of capital equipment purchases that exceed $5,000 for capital equipment not on the SCN pre-approved list.

Records Required form to

submit for approval is on SCN’s website.


retention policy Required to be

submitted to your approving consultant.

Frequency As needed

Due Date/s Prior to purchase

Equipment ManagementSFAs are required to maintain records of property with the serial or identification number, source of the property, who holds the title, acquisition date, cost, percentage of federal participation in the cost, the location use and condition and ultimate disposition data including the date of disposal and sale price. A physical inventory of equipment must be taken and reconciled with records at least once every two years.

Records Record per

district/organizational policy

Documentation of sales procedures if sold.


retention policy

Frequency Annually Inventory at least

once every two years.

Due Date/sn/a

Equipment DepreciationSFAs should document and determine the depreciation value of equipment with an original value of more than $1000.00.

Records Records per

district/organizational policy.


retention policy

Frequency Annually

Due Date/s n/a

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Financial ReportingSFAs must annually report information concerning the financial position of Child Nutrition funds to the State Agency.

Records Statement of

revenues, statement of expenses and balance sheet.



CNIPS

Frequency Annually

Due Date/s- Per SCN

announcement

Plan for Reducing Excessive Operating Food Service Fund BalanceSFAs must have an approved plan in place when financial reporting indicates the SFA has a greater than 3 month operating balance.

Records SA approved spend

down plan


retention policy Submitted to

Program Branch Manager

Frequency Annually if

applicable

Due Date/s- Upon notification

Statement of Program RevenuesSFAs must track all revenues specific to the Child Nutrition Program separately from all other revenues within the district/organization. SFAs are expected to record information daily and review cumulative weekly, monthly, and yearly reports. Financial statements should conform to all generally acceptable accounting practices. Supporting documentation for each entry must be maintained.

Records Munis (public

schools) Financial statement

records (non-public school sponsors)


retention policy

Frequency Daily Weekly

cumulative Monthly

cumulative Annually

cumulative

Due Date/s- n/a

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Statement of Program ExpendituresSFAs must track all expenditures specific to the Child Nutrition Program separately from all other expenditures within the district/organization. SFAs are expected to record information daily and review cumulative weekly, monthly, and yearly reports. Financial statements should conform to all generally acceptable accounting practices. Supporting documentation for each entry must be maintained to support that costs are allowable.


schools) Financial statement

records (non-public schools)


retention policy

Frequency Daily Weekly

cumulative Monthly

cumulativeAnnually cumulative

Due Date/sn/a

Balance Sheet (Statement of Net Position)SFAs should monitor the financial position of the Child Nutrition Program at the end of each accounting period by reviewing a balance sheet. The balance sheet should include information about the program’s assets, liabilities and fund balance.


schools)- Financial statement

records (non-public schools)


retention policy

Frequency Monthly Annually

cumulative

Due Date/s- n/a

Indirect CostSFAs must maintain documentation of the approved indirect cost rate, the makeup of the indirect cost base and documentation of how the rate is applied when indirect cost is collected.

Records Approved indirect

cost rate from federal cognizant agency (public schools – KDE website)

Indirect cost base used in the rate approval

Financial Records


retention policy

Frequency Monthly (if

collected) Annually

Due Date/s- n/a

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Paid Lunch Equity Tool (PLE Calculator) – N/A for full CEP districts and RCCIs who do not charge day students a paid meal price.The USDA excel workbook must be used by SFA’s to calculate any necessary increase in meal price in order to meet the PLE requirements. *RCCIs who do not sell meals or food items but provide food to adults who work outside of the child nutrition program may complete the calculator or maintain documents demonstrating that the Child Nutrition Account is reimbursed for the meals provided.

Records Must use USDA excel

workbook 2010-2011 weighted

average price Previous years PLE Paid lunch counts for

October of previous year.

Paid lunch prices charged to students

Financial documents if non-federal funds provided.

Increased lunch prices when applicable


retention policy Submit in CNIPS

during annual renewal.

Frequency Annually

Due Date/s- June

Paid Lunch Equity WaiverFNS annually decides whether or not to provide the SA the ability to grant waivers for raising paid lunch prices in accordance with the PLE. SFAs must submit for a waiver, maintain supporting documentation to demonstrate eligibility to request the waiver and, if approved, maintain a copy of the approval.

Records Copy of request to the

SA Supporting

documentation Copy of approval


retention policy Submit to SCN for

approval per SCN announcement

Frequency Annually if

applicable

Due Date/s- Per SCN

announcement

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Revenue from Nonprogram Food Tool – All SFA’sSFAs must annually determine if the proportion of revenues from selling or providing non-program food is equal to or greater than the proportion of costs used to produce them. SFAs must follow the procedures outlined in the SCN guidance in order to be considered compliant with this regulation. *RCCI’s must maintain documentation to demonstrate that the Child Nutrition Program is reimbursed for any meals provided to non-program adults and non-program meal services (dinner, snacks, etc.…)

Records Must use USDA tool Must use inTEAM

software to calculate average per meal cost.

Inventory Records Financial Statements Claiming Records Corrective action

when indicated


retention policy

Frequency Annually

Due Date/s- After June 30th but

prior to the start of classes for students.

Physical InventorySFAs must conduct a monthly physical inventory on all food and beverages. The value of the inventories must be calculated as well as the cost of the food used for the month. The value of USDA foods must be included when determining inventory values.

Records Required in order to

complete the revenue from non-program food calculator.


retention policy

Frequency Monthly


Meals Per Labor HourSFAs should complete an analysis of the meals per labor hour produced in order to assist in evaluating staffing levels.

Records Meals per labor hour

form available on SCN website.


retention policy

Frequency Annually


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Procurement

Procurement PlanSFAs should have a written procurement plan that includes the policies and procedures for conducting their procurement of goods and services that conform to local, state and federal laws. The plan should identify the procurement method used and identify awarded contracts currently in use. The written procurement plan should also reference applicable local board policies and procedures that relate to the district’s procurement procedure and written standards of conduct covering conflicts of interest as required by 2 CFR 200.318.

Records Copy of written

Procurement plan Awarded contracts

Retention/Submission SFA shall retain

records for at least a period of 3 years after submission of the final claim for reimbursement for the fiscal year unless there are audit findings. If there are unresolved audit findings, the records shall be retained as required for the resolution of issues raised by the audit. See 7 CFR 210.23.

Frequency Annually


Solicitation DocumentsSFAs must maintain copies of the documents utilized to solicit the procurement of the goods and services utilized in the operation of the Child Nutrition Program

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Records Copies of invitations

to bid and request for proposal.

Documentation of announcements



Frequency As needed

Due Date/sn/a

Small and Micro PurchasesSFAs must maintain copies of the documents utilized to procure goods and services utilizing small and micro purchase procedures to demonstrate that federal requirements were met.

Records Product specifications

used for small purchases

Documentation of price quotes received

Documentation of reason for award



Frequency- As needed

Due Date/sn/a

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ContractsThe SFA must maintain documentation of all records related to the execution and management of the contracts awarded from their solicitation activities that are utilized to purchase goods and services for the Child Nutrition Program with federal funds.

Records The bidding and

negotiation history including notes from evaluation if applicable.

Billing and payment records

A history of any contractor claims

A history of any contractor breaches

Fully executed contracts

Amendments



Vended meal contracts and Foodservice management Company (FSMC) contracts must be submitted and


Due Date/s- Upon contract

award- FSMC contracts

must be approved prior to implementation

Non-Competitive Proposals SFAs must obtain approval from the State Agency prior to awarding contracts or purchasing goods and services when there are mitigating factors that the SFA believes prohibits following their normal procurement processes or if an inadequate number of responses for goods and services is received when following the established procedures.

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Records Documents that

establish one of the following:- item is available from a single source;- emergency exists;- KDE has expressly authorized use of noncompetitive proposal; or- competition is deemed inadequate.

- Documents that establish: item name, dollar amount, vendor, justification for non-competitive proposal.



Submit request for approval to State Agency

Frequency As needed

Due Date/sn/a

Menu Compliance

Production Records SFAs must maintain production records to support the claiming of reimbursable meals. Documentation must support that the meal pattern requirements were met for the total number of meals offered and served and align with standardized recipes.

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Records Required to utilize the

paper SA production record or inTEAM production records.

All others require SA approval annually through the renewal application process.

Any other documentation recorded while producing meals and later transferred to the production record after service.


retention policy Required

submission to SCN for approval to use alternate to SA production record or inTEAM production records prior to use.

Frequency Daily for each

meal served.

Due Date/s Daily

Standardized RecipesSFAs must develop and utilize standardized recipes for any menu item with 2 or more ingredients. Recipes must provide a list and amount of ingredients used, instructions that include HACCP principles and the corresponding yield information.

Records Written recipe


retention policy Must be available

to production staff

Frequency Daily

Due Date/s- Daily

Food Usage SFAs should record the amounts of the food items removed from inventory to produce the meals they serve.

Records In combination with

production record Any other documents

used to record food usage


retention policy

Frequency Daily

Due Date/s- Daily

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Menu Worksheets for age/grade groups served – Breakfast and LunchSFAs must enter 1 week of breakfast and lunch into the inTEAM software for each age/grade group menu served using production record information to utilize the pre-cost feature to establish an average per meal price as well as to confirm that planned menus are in compliance. SFAs must enter one week of menus for each age/grade group served for both breakfast and lunch into the inTEAM menu compliance software for an administrative review for each school selected for review.

Records Required to utilize

inTEAM menu planning software

Production records Recipes Crediting information Cost information



submission through inTEAM menu compliance software for the AR.

Frequency Annually to pre-

cost Once every three

years as part of the AR

Due Date/s Prior to the end of

the school year. Per SCN AR

notification.

Planned Menus (Refrigerator Menus)SFAs must submit a copy of the planned menu that is provided to households as part of the administrative review process.

Records Retention/Submission Per onsite record


inTEAM menu compliance software

Frequency Once every three

years as part of the AR.

Due Date/s- Per SCN AR

notification.

Dietary Specification and Crediting DocumentationSFAs are required to maintain documentation to demonstrate how the menu items served contribute towards meeting the dietary specification and meal pattern requirements.

Records CN labels Manufacturer Product

Formulation Statements

Nutrition Facts labels USDA Foods fact

sheets


retention policy

Frequency Upon procurement

of food items used Upon

reformulation of food items used

Due Date/s- Prior to use

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Waiver for age/grade Group Requirements – RCCI’s OnlyRCCIs may apply for a waiver to adhere to requirements of separate age/grade group meal patterns when certain conditions apply to the population(s) they serve.

Records Copy of waiver

submission and the State Agency approval must be maintained.


retention policy Submitted to the

Program Branch Manager

Frequency Prior to

implementation

Due Date/s n/a

Reimbursable Meal SignageSFAs must display signage at or near the beginning of the serving line to communicate to students the menu items that makeup a reimbursable meal.

Records Post in schools at or

near the beginning of the serving line.


retention policy

Frequency Daily

Due Date/s- Daily

3/2016

Food Safety

Health Department InspectionsSFAs are required to obtain 2 health inspections annually for all production and service sites. If 2 or more inspections are not completed, SFAs are required to formally request inspections be completed. The most recent inspection should be posted where it is visible to the public. SFA’s must annually report to the SA the number of inspections at each site in the previous program year.

Records Health Department

inspection reports. Communication

requesting inspections be conducted.

Supporting documentation of reporting.


retention policy The number of

health inspections is reported to SCN through CNIPS

Frequency Twice annually Reported annually

Due Date/s Annually Reporting deadline

per SCN announcement

Site Level Food Safety PlansAll school/site locations under the SFAs jurisdiction are required to develop and implement a comprehensive food safety program based on HACCP principles that is applicable to all areas in which program food is prepared, served or stored.

Records SOPs identified

through an operational description

Menu items categorized into the appropriate Process Approach

CCPs for each process approach identified

Summary of record keeping, monitoring, corrective actions and verification activities.

The plan to review and revise as needed.

Retention/Submission Required to be

maintained at the site it pertains to and made available to all site level staff.

Per onsite record retention policy


Due Date/s Review and revise

annually or as needed.

Upon program approval.

3/2016

Food Safety Plan RecordsThe SOPs in a food safety plan identify what records will be maintained to document that the monitoring and corrective actions are followed as written. SOPs also identify what documentation will be maintained to demonstrate there is verification to ensure monitoring and corrective actions are followed by staff and properly documented on an ongoing basis.

Records All monitoring

records (temp logs, checklists, etc...) as identified in SOPs

All corrective actions records as identified in SOPs

All verification records as identified in SOPs


retention policy Temp logs must

be maintained for six (6) months.

Frequency Ongoing

Due Date/s Upon

implementation of SOPs.

Implementation of the Food Safety PlanSFAs must maintain documentation that the food safety plan is implemented as it is written and meets local, state and federal requirements.

Records Initial

implementation information.

Overall plan review and revision documents.

Dates of any updates or revisions (indicate on SOPs, process charts, operational descriptions, etc...)

Staff training records


retention policy

Frequency Ongoing

Due Date/s Upon

implementation of SOPs.

As indicated by changes in program offerings and operations

Staff training upon hire and as relevant duties are assigned

3/2016

Local Wellness Policy

Local Wellness PolicyLEAs are required to develop and implement a local wellness policy in each of the school/sites under their jurisdiction. A wellness committee should be formed to develop and implement wellness goals for the all schools within their jurisdiction. The LEA must annually evaluate goal achievement and update the policy as needed.

Records Updates to policy or

corresponding procedures.


retention policy

Frequency Review policy

annually Update as needed

Due Date/s: Annually Ongoing

Wellness Policy ImplementationLEAs must maintain documentation that the wellness policy is implemented as written and meets federal requirements.

Records- Public Notification of

the wellness policy- Documentation of

review and updates to the policy

- Method(s) of notifying stakeholders of their ability to participate in the development, review, update and implementation of policy.

- Assessment of implementation

- Method(s) of public notification of the assessment results.


retention policy

Frequency- Review annually- update as needed

Due Date/s: Annually- Ongoing

3/2016

Civil Rights

Civil Rights Complaint ProceduresSFAs must establish a procedure to process complaints alleging discrimination in accordance with FNS Instruction 113-1. This procedure will be different than the organization/district procedure.

Records Written policy/form Tracking system for

complaints per school year


retention policy

Frequency Review and

update as needed

Due Date/s Upon program

participation.

And Justice for All PostersSFAs are required to post the “And Justice for All” poster where program meals are served and should be posted in a location that is visible to participants.

Records Required for AR Poster


retention policy

Frequency Daily

Due Date/s n/a

Staff TrainingSFAs must annually train all persons involved in providing a meal service on the applicable civil rights requirements. Civil rights training is included in the Level 1 certification curriculum.

Records Agenda Sign in sheets of

attendees


retention policy

Frequency Annually- Ongoing as

needed


Services Provided to Limited English Proficiency HouseholdsSFAs must document any service or accommodation of households with limited English proficiency (LEP).

Records Application used in

alternate languages Any other supporting

documentation of services or accommodations provided.


retention policy

Frequency Annually Ongoing as

needed


3/2016

Accommodating Special Dietary Needs PolicySFAs should develop a policy with corresponding procedures to provide accommodations for special dietary needs. SFAs must be knowledgeable of the requirements and responsibilities related to accommodating disabling and non-disabling conditions and the documents that must be provided in order for the SFA to accommodate requests.

Records Written policy with

corresponding procedures.

Any forms utilized to implement policy


retention policy

Frequency Ongoing

Due Date/s Upon program

participation.

Documentation to provide AccommodationsThe documentation provided to the SFA to request an accommodation must be maintained to demonstrate that the required information was submitted in order to provide an accommodation and that the appropriate accommodation is/was provided.

Records Doctors statements Medical Authority

statements Parent notes (non-

disabling milk substitutions only)

Copies of IEP or 504 plan (if applicable)


retention policy


needed

Due Date/s Prior to providing

accommodations

Documentation of Accommodations ProvidedWhen special dietary needs are accommodated, SFAs must maintain documentation to support that appropriate accommodations were provided as required.

Records Production records Invoices Procurement records Food usage records Other


retention policy


needed.

Due Date/s- n/a

3/2016

Sponsor Approval and Participation

Permanent AgreementThe agreement and any applicable attachments define the roles and responsibilities of SCN and the LEA in administering a school nutrition program (SNP). The permanent agreement stays in effect as long as the LEA operates a child nutrition program that is funded by USDA and administered by SCN. This form is completed during the application process.

Records Required for program

participation SCN permanent

agreement must be used.



submission to SCN

Frequency With new

application As needed when

amended or when updates required.

Due Date/s Prior to program

participation Ongoing for

updates and amendments.

AuditPer The Office of Management and Budget Circular No. A-133, Audits of States, Local Governments, and Non-Profit Organizations - Lea’s that expend $500,000 or more a year in federal awards are required to have a single or program-specific audit conducted.

Records Use of standard

accounting procedures required.


retention policy

Frequency Annually

Due Date/s Within nine months

of end of the LEA’s accounting fiscal year

3/2016

Policy Statement for Free and Reduced-Price MealsEach LEA participating in the NSLP or SBP must have an approved free and reduced price policy statement on file at the State agency. If an LEA is just starting its participation in the NSLP or SBP, the policy statement must be submitted to the State agency for approval as part of the application process. Once approved, the policy statement becomes a permanent document, but must be amended when the LEA makes a substantive change in its free and reduced price policy or as directed by the SA. The requirements for the policy statement and amendments are outlined in the Eligibility Manual for School Meals.

Records Use of program

specific form required

Attachment documents

Copy of the SA approved policy

Copies of approved updates.



submission through CNIPS

Frequency Review annually

and submit changes

As part of program participation application process

Due Date/s Review at the

beginning of each school year to ensure accuracy of all application materials, public release, applicable policies and procedures.

Changes must be approved by October 1st.

Online Application/Application Renewal SFAs must complete an online application in order to be approved for program participation and then complete an online renewal application annually. The information provided in the online application and renewal application are electronically maintained by the SA and is accessible to SFAs after the end of the program year. SFAs are not required to print off or save information provided in the online application. Any updates after approval during the program year will be maintained provided that SFA’s do not overwrite previous checklist documents uploaded. Once approved SFAs should “add new” rather than “modify” a previous checklist item submission.

Records All required

information and documentation to be submitted per program year.

Source documentation of information provided in sponsor and site applications.



submission in CNIPS with sponsor application

Required update in CNIPS as appropriate

Frequency Update Annually Ongoing as

needed Upon approval for

program participation

Due Date/s Annually Ongoing Prior to approval

for program participation.

3/2016

Professional Standards and Level 1 Certification

Child Nutrition Director Credentials (If hired after July 1, 2015)Documentation should be maintained to support that the CND has the required education and work experience as outlined in federal regulations. All CND’s must have completed 8 hours of food safety training within 5 years of hire or within 30 days after hire.

Records Copies of transcripts

and resume. Copy of completion

of the required food safety training.


retention policy

Frequency As needed

Due Date/s Upon hire Proof of food

safety training within 30 days of hire if applicable.

Record of TrainingSFAs must maintain documentation of their compliance to the training requirements outlined in regulations and guidance. Records should clearly identify the name of employee, hire date, Title/position, a description of their duties/responsibilities, status (full time, part time, sub, etc.), and their professional standards category (Director, manager or staff). Documentation of training received should provide the informational elements provided on the USDA training tracker even if the USDA tracker is not utilized to record training related information.

Records Required for AR USDA training

tracker or alternate that provides the same information

List of all employees in SFA with corresponding information

Documentation of training received such as agendas, sign in sheets, certificates, etc.


retention policy


Due Date/s Annually Ongoing

3/2016

Level 1 CertificationIndividuals working in child nutrition programs are required to obtain level 1 certification within 30 days of hire.

Records Certificate of

completion List of new

employees certified (Form C) annually


retention policy Certificates

maintained with training tracker documentation

Form C submitted to the SA

Frequency Upon hire- Annually

Due Date/s- Within 30 days of

hire- Prior to the end of

the program year (Form C)

Level 2 Certification/ SNS CredentialThe Child Nutrition Director, or the individual identified as the menu planner for the LEA if not the Child Nutrition Director, must obtain SNA Level 2 Certification or SNS credential within three (3) years of hire.

Records Copy of certificate or

credential.


retention policy

Frequency Once

Due Date/s Within three (3)

years of hire.

Level 1 TrainerLevel 1 certification can only be provided by an individual certified as a Level 1 Trainer. SFA’s must maintain documentation that the Level 1 training was provided by a certified trainer.

Records Copy of the training

certificate from trainer


retention policy

Frequency Annually

Due Date/s Annually Ongoing

3/2016

Smart Snacks

Smart Snacks Calculator Compliance Reports with corresponding invoices and nutrition labels of a la carte items offered by the Child Nutrition ProgramSFAs must maintain documentation that the food and beverage items they sell a la carte meet smart snacks and competitive food requirements.

Records Alliance Smart

Snacks Calculator reports

Invoices Nutrition Labels Recipes


retention policy

Frequency Ongoing

Due Date/s Upon selling items

a la carte.

Smart Snacks Calculator Compliance Reports with corresponding invoices and nutrition labels for food items offered by others outside of the Child Nutrition ProgramLEAs must maintain documentation that the food and beverage items sold to students outside of the Child Nutrition Program meet smart snacks and competitive food requirements.

Records Alliance Smart

Snacks Calculator reports

Invoices Nutrition Labels Recipes


retention policy

Frequency Ongoing

Due Date/s Upon selling items

a la carte

3/2016

Other Records

WaiversFNS will allow SAs to approve waivers related to program requirements as they determine there is a need for flexibility. The availability and the submission and approval requirements for waivers will be announced through SCN’s communication channels. Documentation related to waivers approved by the State Agency must be maintained by the SFA. (Example: Whole Grain Rich Waiver)

Records Waiver approval

submission Supporting

documentation when approval based upon set criteria


retention policy Submit to the SA

as directed in announcement


Due Date/s- Per SCN

announcement

ReportingSFAs must maintain documentation to support any information or data reported to the State Agency. This applies to any of the established annual reporting requirements as well as any other instance in which SFAs are directed to provide information or data to the SA. (Example: Site enrollment)

Records Any supporting

documentation used to provide the information or data reported


retention policy Submit to the SA

as directed


Due Date/s- As applicable- Per SCN

announcement

3/2016

Afterschool Snack Program

Onsite Monitoring Form SFAs must conduct monitoring of the afterschool snack services to monitor compliance to program regulations and promote effective program management.

Records Must use the



retention policy

Frequency Twice annually

Due Date/s First four weeks

of operation and again before the program ends for the school year

Menu and Production RecordsSFAs must document that snacks are planned to meet meal pattern requirements. Production records must identify the food item, serving size, component contribution to the meal pattern and the quantities served to support the number of snacks claimed for reimbursement.

Records SA prototype

production record on the SCN website


retention policy

Frequency Each snack service

Due Date/s Each snack

service.

Meal Counting and Claiming RecordsMeal count records must be maintained for each snack service that identifies the number of reimbursable snacks served to eligible children claimed for reimbursement.

Records Rosters or tally sheets Consolidation records


retention policy

Frequency Per snack service Monthly

cumulative

Due Date/s- Per Snack service- Monthly

Documentation of Area Eligibility and Program EligibilitySFAs should maintain documentation of the data used to determine area eligibility of the location of the snack service and of the program in which the snack service is utilized.

Records October Qualifying

Data on SCN website Information to

support eligibility of the program associated with the snack service.


retention policy

Frequency- Ongoing annually


3/2016

Fresh Fruit and Vegetable Program

FFVP RecordsSFAs are required to maintain records related to the award of the grant, expenditure of funds and compliance with program requirements.

Records A copy of the

application and agreement

Monthly expenditure reports and supporting documentation (invoices, receipts, etc.…)

Purchasing/Procurement information

FFVP Production records on SCN website

Documentation of activities on the Calendar of events on SCN website

Financial tracking of grant funds

Documentation of staff training on the FFVP

FFVP Handbook Documentation of

community partner participation


retention policy Submit to SA

when directed

Frequency- Ongoing annually- Submit when

directed to SA

Due Date/s Annually apply for

grant and train staff.

Monthly submit expenditure reports

Ongoing documentation of program activities.

Outreach SFAs are required to widely publicize within the school the availability of free fresh fruits and vegetables.

Records Copies of

announcements Pictures of posters,

etc.


retention policy

Frequency Ongoing

Due Date/s Ongoing

3/2016

Seamless Summer Option

Site EligibilitySFAs must maintain documentation to determine a sites’ eligibility to operate as an open, closed enrolled or camp site in the SSO.

Records October Qualifying

data Census Data Documents used to

certify children’s eligibility status (non-area eligible and camps)


retention policy

Frequency Annually


Media ReleaseSFAs must notify households of the availability of meals. Information concerning the dates, location, meals and times should be included.

Records Copy of information

provided to media outlets

List of media outlets the information was provided to.


retention policy

Frequency Annually


Procurement DocumentationSFAs must maintain procurement related documentation for the food and supplies used in providing meals through the SSO.

Records As outlined in

approved procurement plan


retention policy

Frequency Ongoing

Due Date/s- Ongoing

3/2016

Daily Meal CountsSFAs must maintain a record of the number of meals served at each site for each approved service to support the number of reimbursable meals claimed.

Records SCN SSO Meal count

form


retention policy

Frequency Daily

Due Date/s- Daily

Monitoring FormsSFAs are required to monitor each site to ensure the meal service is provided in compliance with program requirements.

Records SCN SSO monitoring

Form


retention policy

Frequency Two times per site

operation

Due Date/s- 1st within 1st week,

2nd within 4 weeks of site operation.

Planned Menus and Production RecordsSFAs must maintain the planned menus and production records for the meals produced and served to demonstrate that meal pattern requirements are met for the number of meals claimed for reimbursement.

Records State Prototype

production record or SA approved alternate


retention policy

Frequency Daily

Due Date/s- Daily

Training RecordsSFAs must maintain documentation that SSO staff was trained on program requirements as it relates to their assigned duties and civil rights.

Records Agenda of training

provided Sign in sheets of

attendees Training materials

used


retention policy

Frequency- Annually

Due Date/s- Annually- Prior to start of

program

3/2016

Special Milk Program

Procurement, Inventory and Food Safety RecordsSFAs must maintain the invoices and inventory records of the milk served to children in the SMP. SFAs must also maintain food safety records to demonstrate safe handling of program milk.

Records Procurement

documentation Invoices P.O.’s Receipts Inventory records Temperature logs


retention policy Temp logs must

be maintained for six (6) months.

Frequency Ongoing

Due Date/s- n/a

Milk Count RecordsSFAs must maintain milk count records per meal service of the milks served to children and claimed for reimbursement.

Records Rosters Milk Count forms


retention policy

Frequency Daily

Due Date/s- Daily

Free and Reduced Price ProcessSFAs operating a Special Milk with Free Option must maintain documents related to the household applications, media release and verification activities. The procedures outlined in the most recent Eligibility Manual for School Meals must be followed.

Records Household

applications Media release List of media outlets

release was sent to Verification

documentation Household letters and

communications.


retention policy Submit media

release to media outlets

Frequency Annually

Due Date/s- Annually- Media release at

the beginning of or prior to start of school year

3/2016

Wellness PolicyLEAs are required to develop and implement a local wellness policy in each of the school/sites under their jurisdiction. A wellness committee should be formed to develop and implement wellness goals for the all schools within their jurisdiction. The LEA must annually evaluate goal achievement and update the policy as needed.

Records- Public Notification of

the wellness policy- Documentation of

review and updates to the policy

- Method(s) used to notify stakeholders of their ability to participate in the development, review, update and implementation of the policy.

- Assessment of implementation

Method(s) of public notification of the assessment results.


retention policy

Frequency Review of policy

yearly, update as needed


Staff TrainingStaff involved in the milk service must be provided training on program requirements including civil rights.

Records Agenda of training Sign in sheets Training materials

used


retention policy

Frequency Annually

Due Date/s- Prior to

involvement in meal service

3/2016

Financial ManagementSMP funds must be tracked separately from all other funds within an organization. SFAs must maintain documentation to demonstrate compliance to this requirement.

Records Statement of

Revenues with supporting documentation for each entry

Statement of Expenses with supporting documentation of each entry

Balance Sheet


retention policy

Frequency Ongoing

Due Date/s- n/a

Civil RightsSFAs must follow the federal civil rights requirements as outlined in FNS Instruction 113-1. This includes establishing a civil rights complaint policy and procedure, providing accommodations and services for LEP households, accommodating special dietary needs and displaying an “And Justice for All “ poster in areas where there is a milk service provided.

Records Complaint

policy/procedure with tracking system of complaints received.

Documentation of services or accommodations provided for households with limited English proficiency.

Documentation related to special dietary needs including the accommodation request, and documentation of the accommodation provided.


retention policy

Frequency Ongoing

Due Date/s- Upon approval to

participate in SMP- Ongoing

3/2016

Sponsor approval and participationThe permanent agreement and any applicable attachments must be maintained as well as any other records pertaining to program participation approval. SFA’s must complete an online application in order to be approved to participate in the SMP. An online renewal application is completed on an annual basis in order to continue participation. The information in the online application will be saved and accessible to SFA’s after the end of the program year.

Records Required for AR Permanent

Agreement Policy Statement

and any applicable attachments

Online application/renewal application

Retention/Submission Permanent

agreement submitted to the SA.

Policy Statement and online application/renewal application is submitted through CNIPS.

Frequency Upon approval Annually

Due Date/s- Approval by

December 31st or June 30th.

- Annual renewal by June 30th.

Independent Review of Applications

As part of an effort to decrease certification error during the eligibility determination process, section 304 of the HHFKA requires that certain local education agencies (LEAs) conduct a second, independent review of applications for free and reduced price meal benefits before eligibility determinations are made. LEAs that demonstrate high levels of, or a high risk for administrative error associated with certification and benefit issuance are required to conduct a second review of applications. Criteria 1: All LEAs with 10 percent or more of the certification /benefit issuances in error as determined by the State agency during an administrative review. Criteria 2: LEAs with greater than or equal to 5% benefit issuance errors and less than 10% benefit issuance errors as determined by the State agency during an administrative review.

Records All applications,

free, reduced, paid, denied as of October 31st.

Documentation and notes included with applications if further information was necessary to complete the application.

Retention/Submission 3 years plus

current year

Frequency Annually until

State Agency determines via Administrative Review that the benefit/issuance errors fall below 5%.

Due Date/s- SFA will be

notified they must do an Independent Review by July 1st.

- Report Form 874 due to State Agency by November 15th.

3/2016

“The U.S. Department of Agriculture (USDA) 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 if 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.)

If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at [email protected].

Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (in Spanish).

3/2016

mailto:[email protected]

http://www.ascr.usda.gov/complaint_filing_cust.html

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