Johnny Key

Commissioner of Education

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Administrative Review

Administrative Review - The Administrative Review provides a comprehensive evaluation of school meals programs by State Agencies of SFAs participating in the NSLP and SBP, and includes both Critical and General Areas of Review.  The scope of review has been expanded for both the Critical and General Areas to provide for a more robust review of program operations. This includes the implementation of the Healthy Hunger Free Kids Act program requirements and other Federal programs. FNS provides forms, instructions and guidance to standardize the review process.  The regulations governing the Administrative Review (7 CFR 210.18) reference two Critical Areas of performance, Performance Standard 1 and Performance Standard 2, as well as a number of General Areas of Review. These references do not signify a higher priority of one area of review over the other. While the regulations use the term “Critical Areas” to describe Performance Standards 1 and 2, compliance standards in the General Areas of Review are equally important. The regulations require fiscal action for the Critical Areas and provide the framework to allow State Agencies to take fiscal action or withhold payments for program noncompliance in the General Areas.  The Administrative Review is conducted on a 3 year cycle.  The objectives of the Administrative Review are to determine whether the SFA meets program requirements, provide technical assistance, secure any needed corrective action, and assess fiscal action, if applicable.
 
Section 207 of the HHFKA amended section 22 of the NSLA (42 U.S.C. 1769c) to require State agencies to report the final results of the administrative review to the public in an accessible, easily understood manner in accordance with guidelines promulgated by the Secretary. Regulations at 7 CFR 210.18(m) requires the State agency to post a summary of the most recent final administrative review results for each SFA on the State agency's publicly available website no later than 30 days after the SA provides the final results of the administrative review to the SFA. The SA must also make a copy of the final administrative review report available to the public upon request.
 
The review summary must cover access and reimbursement (including eligibility and certification review results), an SFA's compliance with the meal patterns and the nutritional quality of school meals, the results of the review of the school nutrition environment (including food safety, local school wellness policy, and competitive foods), compliance related to civil rights, and general program participation. At a minimum, this would include the written notification of review findings provided to the SFAs Superintendent or equivalent as required at 7 CFR 210.18(i)(3).
 
Observation at the time of the Administrative Review confirms the following Performance Standard 1, Performance Standard 2 and General Areas of Review: 
 
Meal Access and Reimbursement (Critical Area—Performance Standard 1)
  • Certification and Benefit Issuance—The School Food Authority (SFA) has an appropriate process to determine a student’s eligibility for free or reduced-price meal benefits and a method used to apply the correct meal benefit level for the student at the point of service.
  • Verification—The SFA is following regulation requirements to confirm income eligibility for free or reduced-price meal benefits from a valid sample of household applications. 
  • Meal Counting and Claiming—The system used by the SFA accurately counts, records, consolidates, and reports the number of reimbursable meals claimed, by category (free, reduced, or paid).  
 
Meal Pattern and Nutritional Quality (Critical Area—Performance Standard 2)
  • Meal Components and Quantities—Meals prepared, offered, and served to students meet the meal pattern requirements for the appropriate age/grade groups for each day and week served. 
  • Offer versus Serve—Students are allowed to decline a specific number of food components/items depending on the menu planning approach used. 
  • Dietary Specifications and Nutrient Analysis—Meals offered to students through the school meal programs are consistent with federal standards for calories, saturated fat, sodium, and trans-fat.  
 
General Areas of Review: 
1. Civil Rights—Program services and benefits are administered in accordance with all laws, regulations, instructions, policies, and guidance related to nondiscrimination in program delivery.
2. School Food Authority (SFA) On-Site Monitoring—On-site reviews of breakfast and lunch counting and claiming systems, along with the general areas of review have been completed by the SFA.
3. Local School Wellness Policy and School Meal Environment—The school district has established a Local School Wellness Policy to help play a critical role in promoting children’s health, preventing childhood obesity, and preventing diet-related chronic diseases. 
4. Smart Snacks in Schools—The school district meets all requirements and has the required documentation for all foods and beverages provided and sold to students outside the reimbursable meal. 
5. Professional Standards—The SFA meets all hiring and training requirements as outlined in the Professional Standards regulations in 7 CFR 210.30. 
6. Water—Water is available to students during breakfast and lunch meal services at no charge. 
7. Food Safety, Storage, and Buy American—The individual school(s) selected for review have an adequate written food safety plan for compliance with Hazard Analysis Critical Control Point (HACCP) program, have received two food safety inspections with the most recent inspection posted in the cafeteria, temperatures are being recorded on a consistent basis, food in storage facilities are properly date-marked and in good condition, and food labels indicate the country of origin is the United States or territories, as applicable. 
8. Reporting and Recordkeeping—The SFA has submitted reports as required and maintained Program records for a minimum of five (5) years after the final Claim for Reimbursement for the fiscal year. 
9. School Breakfast Program and Summer Food Service Program Outreach—SFA has informed families of the availability of breakfast and summer meals (if applicable). 
10. Other Federal Program Reviews (If Applicable)
  • Afterschool Snack Program—SFA serves students nutritionally-balanced snacks, provide appropriate activities, and count and claim snacks accurately.
  • Seamless Summer Option (SSO)—SFA is compliant with meal counting, claiming, menu planning, and food safety during summer meal service.
  • Fresh Fruit and Vegetable Program (FFVP)—SFA is following the FFVP program regulations and submitting an accurate Claim for Reimbursement each month. 
Administrative Review Findings Summary
 
RESOURCES:
Administrative Review Final Rule (PDF)
Administrative Review Off Site Review Tool (Instructions) (Form)
Administrative Review Three Year Cycle 2016-2019 REVISED September 2017 (EXCEL)
 
Corrective Action Resources:
Sample Findings Letter and Appropriate Corrective Action Response Letter – Rock – n – Roll School District (PDF)
Corrective Action Response Guide for the Administrative Review – Developed by the Colorado Department of Education (WORD)

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