THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234
Office of P-20 Education Policy
The National School Lunch Program (NSLP), School Breakfast Program (SBP) and the Healthy, Hunger-Free Kids Act of 2010 continue to place responsibility for the accuracy of meal counts used for claiming purposes on the School Food Authority (SFA). In accordance with 7 CFR 210.8 and 7 CFR 220.11, SFAs must conduct monthly edit checks, and if operating in more than one building, annual, by claim site, self-reviews. If the Child Nutrition Program is managed by a food service management company, SFA personnel must conduct the on-site self-review as compliance with this requirement is considered an SFA responsibility.
SFAs with more than one school must perform a minimum of one on-site self-review per building prior to February 1 of each school year to evaluate each school's counting and claiming system and the readily observable general areas of review cited under 210.18(h). The lunch program must be monitored annually at each building. As established in the “Administrative Reviews in the Child Nutrition Programs Final Rule”, published July 29, 2016, SFA’s must monitor the SBP at a minimum of 50% of the schools operating the SBP, with each school operating the SBP to be monitored at least once every two years. If problems are observed regarding the accuracy of the data, the source of the counts, meal pattern violations, etc. as a result of the review, the SFA must implement corrective action. In cases where corrective action has been identified, a second review of the site must be conducted and documented within 45 days to confirm that the corrective action taken resolved the problem(s). Although the final rule requires a minimum of 50% of schools operating the SBP be reviewed, SED strongly encourages SFA’s to monitor their SBPs at all sites annually to ensure program compliance.
After School Care Program (Snack) Self-Reviews
In addition, SFAs claiming snacks in the After School Care Program must conduct a review of each snack site twice per year: the first review must be conducted during the first four weeks of snack operation; a second review must be conducted later in the school year. All reviews must be adequately documented.
You may use either Form 1 or Form 2 (enclosed below) to perform the on-site self-review, create a form of your own, or use a narrative to document the findings of the self-review. A prototype snack review form can be found in Form 1 or you can use Attachment A or you may create your own. Regardless of the process used, neither the review form nor the results of your self-review are to be submitted to the State Agency. Instead, all documentation must be retained by the SFA and made available to reviewer(s) during the administrative review or any other review process.
Daily Claims Review- Monthly Responsibility
Section 210.8(a) of NSLP regulations and 220.11(d) of the SBP regulations require SFAs to establish internal controls which ensure the accuracy of meal counts prior to the submission of the monthly claim for reimbursement. At a minimum, these internal controls shall include reviewing the meal count data for each school under its jurisdiction to ensure that monthly claims include only the number of free, reduced price and paid meals served on any day of operation to children currently eligible for such meals.
Each on-site self-review should ensure that the school’s counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid lunches served for each day of operation.
Required Monthly Edit Check
SFAs shall compare each school building's “daily counts of free, reduced price and paid meals against the product of the number of children currently eligible for free, reduced price, and paid meals, respectively, times the school’s attendance factor" prior to the submission of a monthly claim for reimbursement.
Each month an edit check must be conducted prior to the submission of the claim for reimbursement. An edit check is a comparison between the daily count of meals served by building and the number of attendance adjusted eligibles for free, reduced price and paid meals. For example, if a building has an enrollment of 200, an attendance factor of 93 percent, and 100 eligible free and 25 eligible reduced price students, their lunch claim for any day should not routinely exceed 93 free (100 x .93), 23 reduced (25 x .93), and 70 paid lunches (200 - 125 free/reduced x .93). Statistically there will be some days when counts will be higher than the attendance factor and some that will be lower. However, average monthly counts should not exceed your adjusted eligibles without documentation to substantiate the higher counts. Explanations should be noted in your records for those days exceeding the attendance factor.
Information regarding this edit check is not to be included when you submit your monthly claim for reimbursement. Rather, it should be retained on file for examination by State personnel or auditors during a program review.
If you have any questions regarding the self-review, implementing edit checks, or the enclosed forms, please contact your respective Child Nutrition Program representative at 518-473-8781.