Module 9 Offer versus Serve, Special Dietary Needs, Administrative Review, and Professional Standards

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1 Mdule 9 Offer versus Serve, Special Dietary Needs, Administrative Review, and Prfessinal Standards Target Audience Child nutritin directr/executive directr Nutritinist r registered dietitian (if applicable) Fd prductin staff Estimated Time Required: 45 minutes Cntents 1. Offer Versus Serve (OVS) 2. Children with Special Dietary Needs 3. Milk Substitutins fr Nn-Disability 4. Lactse Intlerance 5. At-risk Afterschl Meals Prgram 6. Vegetarian Meals 7. Seamless Summer Feeding Optin (SSFO) 8. Administrative Review (AR) 9. Prfessinal Standards 10. Resurces Learning Objectives Explain the difference between the OVS requirement fr fd cmpnents fr lunch and fd items fr breakfast Understand when required t make a dietary accmmdatin Describe milk substitutin requirements Identify criteria t determine if eligible t participate in the at-risk afterschl meals prgram Explain the benefits f serving vegetarian plant-based meals Understand the rganizatin f the AR and the rle f the ff-site and n-site risk assessments Knw hw t apply the prfessinal standards rules n hiring and annual training Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 1 This institutin is an equal pprtunity prvider.

2 1. Offer versus Serve OVS is a cncept that applies t menu planning and the meal service. OVS allws students t decline sme f the fd ffered in a reimbursable lunch r breakfast. The gals f OVS are t reduce fd waste and t permit students t chse the fds they want t eat. Under OVS, schls must ffer all the required fd cmpnents in the required quantities fr lunch and all f the required fd cmpnents and fd items in the required quantities fr breakfast. Students are required t select at least three cmpnents in the Natinal Schl Lunch Prgram (NSLP) and at least three fd items in the Schl Breakfast Prgram (SBP) and ne f thse cmpnents/fd items must be ½ cup fruit and/r vegetable. Students, servers, and cashiers must be able t identify what cnstitutes a reimbursable meal. The NSLP SBP regulatin at Title 7, Cde f Federal Regulatins (7 CFR), sectins (a)(2) and 220.9(a)(2) requires that schls identify, near r at the beginning f serving lines, what fds cnstitute unit priced reimbursable meals. Schls using OVS must als identify what a student must select in rder t have a reimbursable meal under OVS. If chices within cmpnents are ffered, the menu planner must indicate what chices r cmbinatin f chices the student may select in rder t have a reimbursable meal. Fr example, fr grades ninth twelfth (9 12) at least ne cup f fruit must be ffered in a reimbursable lunch. Additinally, the menu planner may chse t ffer a variety f fruit. If ½ cup prtins f three different fruits are ffered, the menu planner wuld indicate that the student may select up t tw-½ cup servings. This prvides a variety f fd chices t the student and shws the student hw t select a reimbursable lunch. OVS is utilized in this example since the student may chse t take n fruit (as lng as ½ cup f vegetables is selected), ne-½ cup serving r tw-½ cup servings frm any f the three fruit chices ffered. Overview f OVS at Lunch Functin Requirement Implementatin f OVS Mandatry at the senir high level (grades 9 12) Optinal belw senir high schl level Reimbursable Meals Number f Fd Cmpnents/Fd Items Offered Required number f selectins fr OVS OVS and fruit and vegetable fd cmpnents/fd items Extra fds ffered Offer the five fd cmpnents in the minimum required quantity Number f fd cmpnents ffered varies but must ffer all required cmpnents At all grade levels, student must select at least three cmpnents, ne f which must be ½ cup f fruits r vegetables r cmbinatin Fruits and vegetables are tw separate cmpnents. Student must select at least a ½ cup f fruits r vegetables r a cmbined ttal f ½ cup f bth Nt credited fr OVS but must include in the dietary specificatins Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 2 This institutin is an equal pprtunity prvider.

3 Lunch Definitins A fd cmpnent is ne f five fd grups that cmprise reimbursable lunches. These are meat/meat alternates (M/MA), grains, fruits, vegetables, and fluid milk. Schls must always ffer all five fd cmpnents in at least the minimum required quantities. Under OVS fr lunch, a student must take at least three fd cmpnents in the required quantities. One selectin must be at least ½ cup (ttal) frm either the fruit r vegetable cmpnent r cmbinatin f fruit/vegetable. Depending n the planned menu, the student may need t select mre than ne menu item t have the minimum quantity needed fr a cmpnent t be credited. Students must select the ther fd cmpnents (grains, M/MAs, and milk) in the minimum daily quantity fr the grade grup. Fr example, fr kindergarten eighth (K 8), the M/MA and grains minimum daily quantity is 1 unch (z.) equivalent (eq.) The students in K 8 must take a minimum f 1 z. eq. f M/MAs r grains t cunt the fd cmpnent as selected fr OVS. Fr 9 12 students, the minimum is 2 z. eq. f M/MAs and grains. The 9 12 students must take a minimum f 2 z. eq. f M/MAs and grains t cunt the fd cmpnent as selected fr OVS. OVS fr lunch, all students, at any grade level, must select: At least three f the five fd cmpnents One f the chices selected must be at least a ½ cup serving f the fruit r vegetable r cmbinatin f fruit and vegetable. Under OVS, the ½ cup prtin f fruit/vegetable is nly used ne time. The remaining cmpnents selected by the student must be the full-required daily serving fr the meal t cunt as reimbursable. On page fur f this mdule, see the third bullet under Sample Lunch Nnreimbursable Meals under OVS fr an example. and Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 3 This institutin is an equal pprtunity prvider.

4 The lunch menu example belw shws a typical menu fr grades 9 12 that allws fr chices by students fr a reimbursable lunch. LUNCH MENU GRADES 9 12 EXAMPLE Chse 1: Chse up t 2: Chse up t 2: Chse 1: Hamburger n bun r turkey sandwich (2 z. eq. grains and 2 z. eq. M/MA each) Seasned crn, green beans, and ptat wedges (½ cup vegetables each) Orange slices, fruit ccktail, banana, and apple juice (½ cup fruit each) Nnfat unflavred milk r nnfat flavred milk (1 cup milk each) Using the lunch menu fr grades 9 12 example, belw are pssible reimbursable and nnreimbursable meals a student may select: Sample Lunch Reimbursable Meals under OVS Turkey sandwich, range slices (grain, M/MA, fruit = three fd cmpnents including ½ cup fruit/vegetable) Seasned crn, range slices, banana, milk (vegetable, fruit, milk = three fd cmpnents, including ½ cup vegetable and full quantity f fruit [1 cup] selected) Hamburger, apple juice, and milk (grain, M/MA, fruit, milk = fur fd cmpnents including ½ cup fruit/vegetable) Sample Lunch Nnreimbursable Meals under OVS Oranges slices and milk (fruit, milk = nly tw fd cmpnents) Turkey sandwich and milk (grain, M/MA, milk= three fd cmpnents but n fruit/vegetable) Seasned crn, range slices, milk (vegetable, fruit, milk = three fd cmpnents, but secnd fruit/vegetable selectin nt in the required minimum quantity [1 cup] fr grades This selectin wuld be k fr grades K 8). Review the OVS Fact Sheet and Quick Check with staff t help them identify reimbursable lunch meals. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 4 This institutin is an equal pprtunity prvider.

5 Overview OVS at Breakfast Functin Implementatin f OVS Number f fd cmpnents/fd items ffered fr reimbursable meals under OVS Required number f selectins fr OVS OVS and the fruit fd cmpnent OVS and fd items fr the fruit cmpnent Extra fds ffered Duble servings f cmpnents/fd items Requirement Optinal at all levels Three fd cmpnents ffered in minimum f fur fd items Student must select at least three fd items and ne selectin must be at least ½ cup f fruit Vegetables may be ffered t meet all r part f the fruit requirement The 1 cup required quantity may be ffered as tw fd items as ½ cup fruit is equal t ne fd item One selectin must be at least ½ cup f fruit (r vegetable r a cmbinatin f bth) Nt credited fr OVS but must be cunted in dietary specificatins Allwed fr fruit (r vegetable) and grains (r M/MAs) cmpnents Breakfast Definitins A fd cmpnent is ne f three fd grups that cmprise a reimbursable breakfast. These are fruits (r vegetables ffered as a substitute fr fruit), grains (r M/MA ffered as a substitute fr grains), and fluid milk. Schls must always ffer all three fd cmpnents in at least the minimum daily required quantities. A fd item is a specific fd ffered within the three fd cmpnents. Fr the purpses f OVS, a schl must ffer at least fur fd items frm the three required fd cmpnents (fruits, grains, milk). If nly three fd items are ffered, then this is nt cnsidered OVS and the student must take all that is ffered. 1 z. eq. grain = ne fd item ½ cup fruit = ne fd item 1 cup milk = ne fd item Under breakfast OVS: At least fur fd items must be ffered All students, at any grade level, must select at least three fd items If selected, grains (r M/MA ffered fr this cmpnent) and milk, must meet the daily minimum required amunt Fr the fruit cmpnent, the student must select at least ½ cup f fruits r vegetables Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 5 This institutin is an equal pprtunity prvider.

6 Fr example, the schl may ffer 1 z. eq. cereal; ½ cup f juice, ½ cup f berries and 8 fluid (fl.) z. f milk as the fur fd items. Under OVS, the student culd select cereal, milk, and ½ cup f juice fr a reimbursable breakfast. Again, if chices f fd items within the cmpnents are ffered, the menu planner must indicate what chices r cmbinatin f chices the student may select including any minimum r maximum number that may be taken. Fr example, if fur-½ cup servings are ffered fr the fruit cmpnent, the menu planner must allw the student t select a full cup, but must als indicate that at least ne-½ cup f fruit is required fr a reimbursable meal. Let us g thrugh sme examples f breakfast menus and hw t utilize OVS. Example 1: Oatmeal (½ cup/1 z. eq. grain) = ne fd item Apple slices (½ cup) = ne fd item Orange juice (½ cup) = ne fd item Milk (1 cup) = ne fd item (This is a fur fd item menu) S, students can select: Oatmeal, apple, and milk, r Oatmeal, range juice, and milk, r Apple, range juice, and milk, r Oatmeal, apple, range juice, milk This menu (example 1) shws hw a menu planner can ffer 1 cup f fruit but split int ½-cup servings t cunt as tw fd items. Therefre, in this example there are fur fd items being ffered: ½ cup atmeal, ½ cup apple slices, ½ cup range juice, and 1 cup milk. The student must select at least three f the fur fd items r they can select all items ffered and ne f thse items must be ½ cup fruit. Althugh this menu meets the requirements fr OVS, if this menu was ffered every day, it wuld nt meet the weekly minimum f 9 z. eq. grains requirement fr kindergarten twelfth (K 12) students. It wuld nly meet 5 z. eq. grains ver the week. T meet the weekly minimum grain requirements fr K 12 students yu wuld need t ffer 2 z. eq. grains fur days a week and 1 z. eq. grains ne day a week at breakfast. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 6 This institutin is an equal pprtunity prvider.

7 In this example (2), the muffin is a 2 z. eq. grain, s the menu planner has the discretin t cunt it as ne r tw fd items. In ur example, the menu planner cunted the muffin as tw fd items. Therefre, five fd items are being ffered t students under OVS. When five fd items are ffered, the student may take all five fd items r fur, r any three fd items. There are fur cmbinatins fr the student t walk away with three fd items. Remember that students must take ½ cup fruit fr a reimbursable meal. Therefre, students can take: All fd items, r Muffin and banana, r Muffin and apple juice, r Banana, apple juice, and milk In this example (3), the menu planner is ffering tw different 1 z. eq. grain items at breakfast and students are allwed t take multiple 1 z. eq. grains including tw f the same grain. It is at the discretin f the menu planner t allw duplicates fr the grains r duplicates f M/MA when substituted fr grains. Yu may als ffer duplicates f fruit. Hwever, yu may nt ffer duplicates f milk. The student can select: Tw tasts, ½ fruit, r Tw cereal, tw fruit (1 cup), r Cereal, fruit, milk Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 7 This institutin is an equal pprtunity prvider.

8 In this example (4), the schl sets up the breakfast as a chice f entrée, fruit, and milk. The entrée includes 2 z. eq. grains r cmbinatin f grains and M/MA t cunt as tw fd items and the student can chse t take ne entrée. There are multiple chices f fruit, ½ cup each, and students are allwed t take up t tw fruit items. Lastly, students can select milk. S, this is a five fd item menu under OVS. Since students must take a minimum f three fd items and ne item must be fruit, they can take: Entrée, ne fruit, milk r Entrée, tw fruits r Tw fruits, milk Review the OVS Fact Sheet and Quick Check with staff t help them identify reimbursable breakfast meals. Types f Meal Service Besides OVS type f meal service, there are a few different systems used by schls t ffer meals t students. Pre-plated meals must include all cmpnents in at least the daily minimum quantities under the applicable meal pattern. Fr senir high schls, if this is the nly system available fr the NSLP, OVS fr all r sme cmpnents must be implemented. Fr example, ffering a chice f milk and/r a bwl f fruit/vegetable that may be selected r declined. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 8 This institutin is an equal pprtunity prvider.

9 Family style service allws students t serve themselves. Over the week, ffered meals must meet all f the daily and weekly fd cmpnent/fd item requirements and the weekly dietary specificatins. The initial serving f a fd cmpnent/fd item may be less than the full required minimum quantity. The supervising adult shuld encurage additinal prtins and selectins t meet the full required minimum serving size prvided dietary specificatins are nt exceeded. The adult supervisr must ensure that each student selects at least ½ cup f fruit r vegetable r a cmbinatin f bth. Fd bars are encuraged as a way t ffer a wider variety f vegetables and fruits and t decrease plate waste. Menu planners must clearly identify the fd cmpnents/fd items prvided and the minimum serving size fr each fd cmpnent/fd item and indicate which fds and cmbinatins the student may chse t select a reimbursable meal under OVS. Offer versus Serve Activity Access the San Jse State University (SJSU) Califrnia Prfessinal Nutritin Educatin and Training (Cal-Pr-NET) Center OVS Activity Web page belw t view the lunch and breakfast OVS activity. Identify if the meal is reimbursable, and if nt, list suggestins t make it reimbursable. The answer key is lcated at the end f this mdule. Train yur staff t identify a reimbursable meal with this interactive activity. The answer key is lcated at the end f this mdule. Archived Webinars n OVS with breakfast and lunch are available n the Cal-Pr-NET Center University f Califrnia, Davis (UC Davis) Web page at Access the U.S. Department f Agriculture (USDA) updated OVS training manual Web dcument at In additin, the USDA has issued new Questins and Answers (Q&A) n breakfast fr , including infrmatin n OVS, lcated n the USDA Web dcument at Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 9 This institutin is an equal pprtunity prvider.

10 2. Children with Special Dietary Needs Definitin f a Recgnized Medical Authrity The USDA has expanded the list f acceptable medical prfessinals wh may sign a medical statement fr meal accmmdatins in the child nutritin prgrams (CNP) and recmmend alternate fds fr children whse disability restricts their diets. At the discretin f the state agency, a state licensed health care prfessinal wh is authrized t write medical prescriptins under state law may be permitted t cmplete and sign the medical statement. When are Schl Fd Authrities Required t Make Dietary Accmmdatins? Schl fd authrities (SFA) are required t make dietary accmmdatins fr students wh have a medically certified disability that is verified by a written medical statement. A licensed physician, a physician assistant, r a nurse practitiner must sign the written medical statement. Califrnia des nt recgnize ther medical authrities as authrized t sign a written medical statement t determine a child s diet. Definitin f Disability: Under Sectin 504 f the Rehabilitatin Act f 1973, and the Americans with Disabilities Act (ADA) f 1990, a persn with a disability means any persn with a physical r mental impairment that substantially limits ne r mre majr life activities, has a recrd f such impairment, r is regarded as having such impairment. See pages 3 and 4 in the USDA Guidance fr Accmmdating Children with Special Needs fr a partial list f diseases r cnditins, which fit physical r mental impairment, lcated n the USDA Web dcument at Nte: If a child has a fd allergy r intlerance but des nt have a disability as defined under Sectin 504, the schl fd service may, but is nt required, t make a fd substitutin. Hwever, fd allergies listed in a licensed physician s assessment, that result in severe, life-threatening (anaphylactic) reactins, wuld meet the definitin f disability, and the substitutins prescribed by the licensed physician must be prvided. Required Dcumentatin fr a Disability: The CDE Medical Statement frm r a written medical statement (i.e. prescriptin) is required fr each child that has a disability and must be cmpleted and signed by a licensed physician, a physician assistant, r a nurse practitiner. This written medical statement must clearly identify the child s: Disability Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 10 This institutin is an equal pprtunity prvider.

11 Majr life activity r bdily functin affected by the disability Diet prescriptin Fd r fds t be mitted frm his r her diet Fd r chice f fds that must be substituted in his r her meals A child with a disability must be prvided the fd substitutes nted in the written medical statement. The USDA des nt require meals fr a child with a disability that invlves dietary restrictins dcumented in the written medical statement t meet the current meal pattern. When d SFAs have the Discretin t Make Dietary Accmmdatins? At their discretin, SFAs may make dietary accmmdatins fr students wh are medically certified as having a special dietary need that d nt rise t the level f a disability. Such determinatins are made n a case-by-case basis. This prvisin cvers children wh have fd intlerances r allergies, but d nt have life-threatening reactins (anaphylactic reactins) when expsed t fd(s) in which they have prblems. When the schl fd service chses t make accmmdatins fr a special dietary need, a written medical statement explaining the fd substitutin is required. A recgnized medical authrity is defined as a licensed physician, a physician assistant, r a nurse practitiner. Submitted medical statements must clearly identify the child s: Medical r ther special dietary cnditin Diet accmmdatin requested Fd(s) t be mitted frm his r her diet Fd r chice f fds that must be substituted in his r her meals The Medical Statement frm is available n the CDE Web page at Optinal accmmdatins fr children with special dietary needs must be cnsistent with the new meal pattern and dietary specificatins. Schls may nt charge children with disabilities r with certified special dietary needs wh require fd substitutins r mdificatins mre than they charge ther children fr CNP meals r snacks. An agency s cafeteria fund, general fund, and ther funding surces may be used t cver additinal csts. Refer t pages in the USDA Accmmdating Children with Special Dietary Needs in the Schl Nutritin Prgram (SNP) guidance manual. Management Bulletin (MB) CNP is lcated n the CDE Web page at Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 11 This institutin is an equal pprtunity prvider.

12 3. Milk Substitutins (Nt a Disability) In September f 2008, the USDA issued a final rule prviding SFAs the ptin t ffer a fluid milk substitutin, such as symilk, fr students wh have medical r special dietary needs that d nt rise t the level f a disability. If yu want t ffer symilk t students with special dietary needs, please access MB USDA-CNP Final Rule: Fluid Milk Substitutins lcated n the CDE Web page at A reimbursable meal des nt have t include milk if the SFA implements OVS. 4. Lactse Intlerance Lactse-free milk is allwed as part f the reimbursable schl meal and SFAs may ffer it t children wh have lactse intlerance withut requiring dcumentatin. A statement signed by a recgnized medical authrity r parent is nt required fr lactse intlerance since lactse-free milk is an apprved milk alternate. 5. At-risk Afterschl Meals Prgram In rder t serve suppers in an afterschl care prgram, NSLP spnsrs must apply and be apprved fr the Child and Adult Care Fd Prgram (CACFP). Under the CACFP At-risk Afterschl Meals Prgram, yu can claim up t ne meal and ne snack. The CACFP applicatin prcess currently requires spnsrs t submit infrmatin t the Nutritin Services Divisin (NSD) t assess fr financial viability, administrative capability, and prgram accuntability (VCA). LEAs are nt required t meet the VCA criteria. Therefre, NSD has streamlined the applicatin prcess fr LEAs wh are successful in perating the NSLP. LEAs that want t participate in the CACFP At-risk Afterschl Meals Prgram t serve a snack and/r a supper must: Be lcated in a gegraphic area served by a schl in which 50 percent r mre f the participants enrlled are eligible fr free r reduced-priced meals Operate their prgram during after schl hurs, which may include weekends, and schl hlidays during the regular schl year Include enrichment activities r an educatinal cmpnent Prvide regularly scheduled activities in an rganized, structured, and supervised envirnment Meet the CACFP r NSLP meal pattern requirements Maintain separate resurce management Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 12 This institutin is an equal pprtunity prvider.

13 Are yu interested in serving meals t after schl students, but are unsure where t start? Watch this 10 minute nline vide t learn hw t apply fr the at-risk afterschl meal cmpnent f the CACFP. Whether yu are with a schl district r a cmmunity rganizatin, this shrt vide will walk yu thrugh the applicatin prcess fr the after schl meal cmpnent f the CACFP. Watch it nw n the Califrnia AfterSchl Netwrk (CAN) Hw t Apply t Serve Meals Web page at The USDA released Plicy Mem SP : Streamlining At-risk Meal Participatin fr Schl Fd Services Authrities lcated n the USDA Web dcument at Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 13 This institutin is an equal pprtunity prvider.

14 The NSD MB CACFP is lcated n the CDE Web page at The At-risk Afterschl Handbk is lcated n the USDA Web dcument at Fr additinal resurces, please visit the CAN Afterschl Meal Prgram Web page at The CACFP Unit develped an at-risk checklist which is a helpful tl t ensure yu are meeting the prgram requirements. This tl is lcated in the CACFP Mdule f the CNIPS in the Dwnlad Frms sectin and can be accessed at the fllwing link 6. Vegetarian Meals MB NSD SNP prvides infrmatin n Assembly Cncurrent Reslutin 16: Nutritin: Vegetarian Schl Lunches, Reslutin Chapter 62, Statutes f It encurages SFAs t ffer plant-centered vegetarian entrée ptins t meet the needs f their student ppulatin and prvides infrmatin n helpful resurces. The CDE recmmends that all SFAs phase in plant-centered and ther vegetarian entrees. The full cntent f this MB is available n the CDE Web page at 7. Seamless Summer Feeding Optin The SSFO allws SFAs t prvide free summer meals in lw-incme areas during the traditinal summer vacatin perids and, fr year-rund schls, during schl vacatin perids f at least 10 schl days. The SSFO is designed t encurage mre SFAs t prvide meals during summer and ther schl vacatin perids. This ptin cmbines features f the NSLP, SBP, and the Summer Fd Service Prgram (SFSP). SFAs ffering the SSFO must fllw the federal meal pattern requirements in schl year prir t the beginning f service f the SSFO. Fr example, a schl perating SSFO in the summer f 2016 wuld fllw the meal pattern requirements that became effective n July 1, With prir apprval, SFAs perating the SSFO may serve a single grade grup at pen r restricted pen sites. SFAs are expected t make every attempt t fllw the grade grup requirements. Hwever, SFAs having difficulty implementing the grade grup requirements may wrk with the NSD t make accmmdatins, which may include meeting the minimum meal pattern requirements fr the mst cmmn grade grup served. All ther SSFO sites serving an identified grup f students must fllw the grade grup requirements. Hwever, these sites can take advantage f the K 8 grade verlap fr lunch. Lunch menus fr K 8 and 9 12 grades can be very similar, with slight increases in fruits, vegetables, grains and M/MAs fr lder students. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 14 This institutin is an equal pprtunity prvider.

15 Certified SFAs perating the SSFO are eligible t receive the additinal six cents per lunch reimbursement fr SSFO lunches. When SFAs submit dcumentatin fr certificatin, they are attesting that what they are submitting is representative f nging NSLP and SBP meal service, which wuld include meals served under the SSFO. Fr mre infrmatin, see the CDE SSFO Web page at Yu can als access Plicy Mem SP editin f Q&A s fr the NSLP Seamless Summer Optin lcated n the USDA Web dcument at files/cn/sp s.pdf. 8. Administrative Review In accrdance with the Healthy, Hunger-Kids Act f 2010 (HHFKA), the USDA FNS has develped a new AR prcess. The prcess cmbines elements f the crdinated review effrt (CRE) and the schl meal initiative review, accunts fr the transitin t a three-year review cycle, and incrprates new requirements such as thse fr schl breakfast, the fresh fruit and vegetable prgram, afterschl snack prgram, special milk prgram, special prvisins, cntracting with fd service management cmpanies (FSMC), and dietary specificatins. The prcess ensures mre effective and efficient mnitring f the cmplex requirements within the schl meal prgrams and encurages cllabratin between SFAs and the CDE. The review prcess is structured t include bth prereview (ff-site) and n-site review cmpnents. Varius risk assessment tls were develped by USDA t facilitate the prereview (ff-site) prtin f the SNP AR. Prereview (ff-site) activities prvide flexibility fr the SFA t gather dcumentatin and fr the state agencies t review dcumentatin prir t the n-site review. The prereview (ff-site) cmpnent als prvides SFAs with mre time t frmulate written respnses t questins and allws time fr the fd service directr (FSD) t cnsult with thers within the SFA with ther areas f expertise. The USDA mandates that the resurce management prtin f the ff-site assessment tl questinnaire be submitted t the CDE at least fur weeks prir t yur scheduled review. Otherwise, the SFA will receive a mre cmprehensive review f all fur areas within resurce management sectin. The CDE asks SFAs t cmplete the entire ff-site assessment tl at least eight weeks prir t yur scheduled review, in rder t allw the CDE adequate time t prcess and evaluate respnses. It is highly recmmended that the FSD wrk clsely with the SFA staff persn respnsible fr the financial aspects f the CNP. Nte: The USDA will cntinue t refine their guidance n the AR prcess. Therefre, there may be sme changes t these sectins during the next year. Overview f the Administrative Review Structure There are five key cmpliance areas f the AR prcess categrized as either a critical area f perfrmance r a general area f review. The USDA requires the CDE t take regulatry fiscal actin fr nncmpliance in the critical areas; hwever, the USDA grants authrity t the CDE Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 15 This institutin is an equal pprtunity prvider.

16 t determine any fiscal actin in the general areas. The five key cmpliance areas are summarized belw in an accessible versin f: What is an ARWeb dcument at Meal Access and Reimbursement This cmpnent is identified as a Critical Area, Perfrmance Standard 1, and fcuses n the fllwing: Certificatin and Benefit Issuance (number series 100) Reviews the SFA s determinatin f a student s eligibility fr free, reduced-price, r paid meals and is the link t the SFA s meal cunting and claiming system Ensures that eligible children receive meals t which they are entitled and that reimbursement claims are valid Verificatin (200) Reviews the mandatry prcess used by the SFA t cnfirm selected students eligibility by verifying the incme listed n the riginal husehld applicatins Ensures that the SFA prperly cmpletes the verificatin prcess in the apprpriate timeframe Meal Cunting and Claiming (300) Reviews the SFA s meal cunting and claiming system that accurately cunts, recrds, cnslidates, and reprts the number f reimbursable meals claimed Ensures that reimbursement claims are accurate and adequate systems are in place t avid vert identificatin Meal Pattern and Nutritinal Quality This cmpnent is identified as a Critical Area, Perfrmance Standard 2, and fcuses n the fllwing: Meal Cmpnents and Quantities (400) Reviews the preparatin, ffering, and service f meals that meet the meal pattern requirements fr the apprpriate student grade grups n all reimbursable meal service lines OVS (500) Ensures that every reimbursable meal service line meets the daily and weekly meal pattern requirements fr the apprpriate grade grup served Reviews the SFA s implementatin f OVS, a prgram element that allws Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 16 This institutin is an equal pprtunity prvider.

17 students t decline sme f the fd items ffered that they d nt intend t eat, helping t reduce fd waste Ensures that the SFA prvides adequate amunts f all fd cmpnents, that the student selects sufficient cmpnents, and that the meals claimed fr reimbursement meet meal pattern requirements Dietary Specificatins and Nutrient Analysis (600) Reviews the amunt f calries, saturated fat, trans fat, and sdium in meals ffered t children thrugh the SNPs Ensures that the meals served are in cmpliance with dietary specificatin standards Resurce Management This cmpnent is identified as a general area and addresses the maintenance f the nnprfit schl fd service accunt (cafeteria fund), paid lunch equity (PLE), revenue frm nnprgram fds, and indirect csts. The risk assessment tl determines the depth f this area f review. Resurce Management (700) Reviews the fllwing fiscal-related areas: Maintenance f the nnprfit schl fd service accunt PLE Revenue frm nnprgram fds Indirect csts Ensures the verall financial health f the SFA s nnprfit schl fd service accunt General Prgram Cmpliance This cmpnent is identified as a general area and includes the fllwing review: Civil Rights (800) Laws, regulatins, instructins, plicies, and guidance related t nndiscriminatin in CNPs Ensures that the SFA has a written prcedure and cmplies with requirements SFA On-site Mnitring (900) Reviews the SFA s cmpletin f at least ne n-site review f the lunch cunting and claiming system in each schl fr SFAs with mre than ne schl under its jurisdictin Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 17 This institutin is an equal pprtunity prvider.

18 Reviews the SFA s cmpletin f 50 percent f breakfast sites annually, with 100 percent being mnitred bi-annually Lcal Schl Wellness Plicy (LSWP) (1000) Reviews the effectiveness f the SFA s LSWP in prmting children s health, preventing childhd besity, and preventing diet-related chrnic diseases by fstering a healthy schl envirnment Ensures that the LSWP cntains all mandated cmpnents including stakehlder engagement, implementatin, public ntificatin, and reprting Smart Snacks in Schl (1100) Reviews the requirements fr all fd and beverages sld t students, n schl campus, frm midnight thrugh 30 minutes after the end f the schl day, utside f the federally reimbursable meal prgram Ensures that SFAs meet the minimum requirements fr all fds and beverages sld in schl t increase cnsumptin f healthful fds during the schl day and supprt a healthy schl envirnment Prfessinal Standards (1200) Water (1300) Reviews cmpliance with USDA hiring and educatin requirements fr FSD Ensures dcumentatin f annual training fr all fd service staff Reviews the requirements that schls prvide ptable water t all students during lunch and t students served breakfast in the cafeteria Ensures that children have access t water during meal service times in meal service areas Fd Safety, Fd Strage, and Buy American (1400) Reviews the safe handling, strage, preparatin, and service f fd, as well as, the purchase f fds prduced and prcessed in the United States. This includes the review f ff-site fd strage facilities fr the sites selected fr review. Ensures that the SFA is cmpliant with state and federal fd safety requirements and the Buy American requirement Reprting and Recrdkeeping (1500) Reviews the SFA s submissin and maintenance f reprts and the pssessin Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 18 This institutin is an equal pprtunity prvider.

19 f recrds accrding t recrd retentin requirements Ensures that the SFA cmplies with reprting and recrdkeeping requirements SBP and SFSP Outreach (1600) Reviews the requirement f SFAs t infrm eligible husehlds f the availability f breakfast ffered under the SBP and meals ffered thrugh the SFSP Ensures that the SFA meets the required utreach activities t increase prgram participatin Other Federal Prgram Reviews This cmpnent is identified as a general and critical area and fcuses n the fllwing prgrams, if applicable: Afterschl Meal Supplements (Snacks) (1700) Reviews the SFA s ptin t serve NSLP snacks t students in structured afterschl prgrams that prvide educatinal r enrichment activities Ensure that participating schls serve nutritinally-balanced snacks that meet meal pattern requirements, prvide apprpriate activities, and cunt and claim snacks accurately SSFO (1800) Reviews the SFA s ptin t serve meals during summer r certain ther schl vacatin perids using the same meal service rules and claiming prcedures as the NSLP Ensures that the SFA cmplies with meal cunting, claiming, menu planning, and fd safety requirements Fresh Fruit and Vegetable Prgram (1900) Reviews the SFA s ability t increase elementary schl students expsure t and cnsumptin f a variety f fresh fruits and vegetables utside the NSLP Ensures that participating schls are perating the prgram in cmpliance with requirements utlined by the USDA and the CDE Special Milk Prgram (2000) Reviews the SFA s ffering f milk t eligible children in schls, residential child care institutins (RCCI), and eligible camps that d nt participate in ther federal CNPs Ensures that the SFA perates the prgram in accrdance with an apprved Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 19 This institutin is an equal pprtunity prvider.

20 agreement and federal regulatins Meal Cmpnents and Quantities The CDE r the SFA must cmplete the menu wrksheet prtin f a USDA-apprved Menu Planning Tl fr Certificatin fr Six Cent Reimbursement (referred t as Menu Wrksheet frm here n) fr each schl selected fr review fr a week frm the review perid fr bth breakfast and lunch. The wrksheet must be cmpleted using menu prductin recrds (MPR), menus, recipes, fd receipts, and any ther dcumentatin that shws meals cntained the required cmpnents r quantities. Menus, MPRs, prduct frmulatin statements (PFS), and standardized recipes are key cmpnents t determining cmpliance with the meal pattern during an AR. The CDE r SFA is nt required t cmplete the Simplified Nutrient Assessment prtin f the Menu Planning Tl. The Menu Planning Wrksheets are lcated n the USDA Web page at Fiscal Actin The CDE is required by the USDA t recver any verpayment made t an SFA fr claimed meals that did nt meet regulatins. Please access the USDA dcument that prvides a summary f fiscal actin that can be taken during an AR at Nte: The fiscal actin fr benefit issuance errrs are nw applied t all sites under the jurisdictin f the SFA. Previusly, the benefit issuance errrs required fiscal actin fr nly the sites selected fr the review. Dietary Specificatins and Nutrient Analysis The CDE must cmplete a risk assessment tl fr each site selected fr NSLP and SBP review. This tl, the Meal Cmpliance Risk Assessment Tl, identifies a single site, which is at highest risk f nncmpliance with the current meal pattern. This single site becmes the targeted site that then receives a targeted menu review that includes the review f menus, prductin recrds, recipes, and PFSs fr a selected week within the mnth f review. The CDE cmpletes anther risk assessment tl, the Dietary Specificatins Assessment Tl, in rder t identify if the site f targeted menu review is at lw r high risk fr nncmpliance with the current nutrient standards (i.e., saturated fat, calries, artificial trans-fat, and sdium). If the tl identifies the site is high risk f nncmpliance with the nutrient standards (i.e., calries, saturated fat, artificial trans-fat, and sdium), then the CDE must cnduct r validate an existing nutrient analysis fr bth breakfast and lunch. If the dietary specificatins assessment tl identifies the site as lw risk f nncmpliance, then the ff-site analysis f this area f the review is cmplete. Please nte: If the reviewer identifies significant risk f nncmpliance while n-site, then the ranking f nncmpliance may als change frm lw risk t high risk. If required, the nutrient analysis is cmpleted fr breakfast and lunch fr each grade grup fr Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 20 This institutin is an equal pprtunity prvider.

21 the site f the targeted menu review. The nutrient analysis calculates a weekly average f calries, saturated fat and sdium and the utcme is cmpared t the USDA nutrient requirements fr breakfast and lunch. The CDE will cllect r review yur dcumentatin t supprt the data entry in the nutrient analysis. Dcumentatin typically includes nutritin facts labels and/r PFSs, recipes, and MPRs. Please nte: The nutrient analysis must be a weighted nutrient analysis. A weighted analysis is based n the MPRs and the planned quantity. The list belw summarizes the characteristics f the required weighted analysis. Weighted Analysis Requirements Includes all fds ffered Is based n prtin sizes Analyzes a ne-week perid Is based n prjected number f servings If prjected servings f the tw fd items are actually 200 f ne and 100 f anther, then the weighted average wuld be based tw-thirds n the first fd item and ne-third n the secnd item Is based n prprtinate cntributin based n fds ffered n the menu Fd items ffered mre frequently cunt mre heavily FNS guidance fr nutrient analysis must be fllwed Is based n a schl week f three t seven days Weeks f less than three days are added t the previus r fllwing week In rder t have an accurate weighted analysis, spnsrs will need t cntinually adjust the prjected serving cunts accrding t participatin fr each item as recrded n the MPRs. Technical assistance (TA) and crrective actin plans (CAP) will be the key tls used by the CDE t seek cmpliance with the meal pattern and nutritin standard requirements. Transparency Requirement The Administrative Reviews in Schl Nutritin Prgrams final rule requires the CDE t reprt the final results f the administrative review t the public in an accessible, easily understd manner in accrdance with guidelines prmulgated by the Secretary. The final rule at 7 CFR (m) requires the State agency t pst a summary f the mst recent final administrative review results fr each SFA n the State agency's publicly available website, and allws the State agency t strngly encurage each SFA t pst a summary n the SFA's public website. The results summary must include access and reimbursement (including eligibility and certificatin review results), an SFA's cmpliance with the meal pattern and the nutritinal quality f schl meals, the results f the review f the schl nutritin envirnment (including Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 21 This institutin is an equal pprtunity prvider.

22 fd safety, lcal schl wellness plicy, and cmpetitive fds), cmpliance related t civil rights, and general prgram participatin. At a minimum, this summary wuld include the written ntificatin f review findings prvided t the SFAs Superintendent r equivalent as required at 7 CFR (i)(3). State agencies must pst this summary n later than 30 days after the State agency prvides the final results f the administrative review t the SFA. Mre infrmatin n this tpic is frthcming. 9. Prfessinal Standards The USDA established minimum prfessinal standards fr persnnel wh manage and perate the NSLP) and the SBP. These standards address Sectin 306 f the HHFKA by ensuring that schl nutritin persnnel have the knwledge, training, and tls needed t create nutritius, safe, and enjyable schl meals. The prfessinal standards fr persnnel in SNPs became effective July 1, T review the final rule, please visit the Federal Register Prfessinal Standards fr SNPs Web page at The final rule n the USDA prfessinal standards des the fllwing: Creates minimum hiring standards (i.e. educatin, experience) fr SFA directrs based n the lcal educatinal agency s (LEA) size by student enrllment Establishes minimum hiring standards fr state directrs f schl nutritin and state distributing agencies Requires minimum annual training fr all new and current schl nutritin prfessinals The standards apply t public, charter, private schls, and RCCIs that perate the NSLP r SBP. It als applies t FSMCs but nt vended meal prviders. Fcus n the Rle, nt the Title There are different requirements fr hiring and training, based n the persn s rle. Therefre, it is imprtant t understand the definitin fr each psitin. The final rule defines fd service persnnel as directr, manager, r staff depending n their rle in the schl nutritin peratins. The USDA acknwledges that titles and assciated duties vary widely acrss the SFAs and there can be cnfusin in determining wh the directr is and wh the manager is. The USDA recmmends that SFAs fcus n the rle f the emplyee and nt the title. T determine hw the training standards apply t yu and yur staff, lk at what each persn des, nt their title. Directr: Manages the day-t-day peratins f schl fd service fr all participating schls under the jurisdictin f the SFA. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 22 This institutin is an equal pprtunity prvider.

23 Manager: Manages the day-t-day peratins f schl fd service fr ne r mre participating schls, but nt all f the participating schls under the jurisdictin f the SFA. Staff: Has a nnmanagerial rle in the day-t-day peratins f the schl fd service. Hiring Standards fr Directrs The hiring standards are determined by the size (student enrllment) f the LEA: LEA Student Enrllment 2,499 r less 2,500 9,999 10,000 + Minimum Educatin Standard Bachelr s degree with a specific majr (such as fd and nutritin, fd service management, dietetics, family cnsumer sciences, nutritin educatin, culinary arts, business, r a related field) Or Bachelr s degree with any majr and ne year f SNP experience Or Assciates degree with a specific majr and ne year f SNP experience Or High Schl diplma r GED and three years f SNP experience Bachelr s degree with specific majr Or Bachelr s degree with any majr and tw years f SNP experience Or Assciate s degree with a specific majr and tw years f SNP experience Bachelr s degree with a specific majr Or Bachelr s degree with any majr and five years f experience in management f SNP Nte: Califrnia des nt have a state-recgnized certificate fr SNP directrs. Directrs, hired befre July 1, 2015, are grandfathered int their current psitins and they may mve t anther district with the same r smaller LEA size categry. This als applies t psitins advertised prir t July 1, Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 23 This institutin is an equal pprtunity prvider.

24 CDE Plicy: The CDE requires that new acting directrs expected t serve fr mre than 12 mnths t meet the hiring standards. CDE Plicy: LEAs under 500-student enrllment, can request apprval t hire a candidate with a high schl diplma with less than three years experience. Cmplete Frm ID SNP 07 Hiring Flexibility Request available in the Dwnlad Frms sectin in the SNP Mdule f the CNIPS Web site at New SFA directrs in all LEA size categries must have at least eight hurs f fd safety training within five years prir t the starting date, r cmpleted within 30 days f the starting date. CDE Plicy: The CDE requires all SFA directrs, regardless f starting date, t cmplete eight hurs f fd safety training every five years. Paying fr csts incurred by an individual t meet the hiring standards is nt an allwable use f the nnprfit schl fd serve accunt. Dcument cmpliance with the hiring standards and have dcumentatin available fr the AR. Hiring Standards Dcumentatin The directr must maintain dcumentatin f meeting all f the hiring standards fr review during the AR. Acceptable dcuments fr minimum educatin standards include a degree r diplma t validate the educatin level cmpleted and a resume t validate length f relevant SNP experience. When a degree is nt cmpleted, cllege transcripts are acceptable dcumentatin t validate equivalent educatinal experience. Dcumentatin f prir fd safety training may be a certificate f cmpletin f training r sign-in sheet that shws the date f training and a training agenda that includes the training title, tpic(s) cvered, and the instructin time. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 24 This institutin is an equal pprtunity prvider.

25 Training Standards Annual cntinuing educatin and training fr all schl nutritin persnnel is a requirement. The chart prvides the number f required training hurs per year per categry. Remember t fcus n the rle f the persn in the peratin and nt the title. Categry SY SFA directrs SFA managers SFA staff > 20 hurs/week Part-time staff <20 hurs/week 12 hurs 10 hurs 6 hurs 4 hurs If hired n January 1 r later (in any schl year), nly half f the required training hurs must be dne that year. Office staff wh wrk 20 hurs r mre per week during the schl year must cmplete 6 hurs f training and staff wrking less than 20 hurs per week must cmplete 4 hurs f annual training. Delivery emplyees and staff, wh mnitr refrigeratin, fd temperatures, etc., are expected t cmplete annual training n tpics such as prper handling, delivery, and strage f perishable fd prducts and s n. Annual civil rights training that addresses schl meal issues cunts tward the annual training standards. Attendance at a mtivatinal speaker r participatin in a sessin t discuss prgram issues r gather prgram infrmatin frm the district d nt cunt tward training standard. CDE Plicy: The CDE allws SFAs t demnstrate cmpliance with training standards ver a perid f tw schl years if sme training hurs are cmpleted each schl year. Prviding training is an allwable use f the nnprfit schl fd service accunt. SFAs are encuraged t utilize free r lw cst training material when pssible. Dcument cmpliance with the training standards and have dcumentatin available fr the AR. Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 25 This institutin is an equal pprtunity prvider.

26 CDE Plicy: Onging fd safety training r certificatin every five years fr directrs (7 CFR [b][1][v]): All directrs shall either maintain the fd safety certificatin r cmplete eight hurs f fd safety training every five years while emplyed in the SNP. In Califrnia, this requirement des nt apply t acting directrs in the psitin fr less than 12 mnths. The USDA suggested specified training tpics areas that include: Free and reduced-price eligibility Applicatin, certificatin, and verificatin prcedures Meal cunting and claiming prcedures Identificatin f reimbursable meals at the pint f service (POS) Nutritin, health and fd safety standards Any tpic required by the USDA Training may be prvided in a variety f frmats and frm a variety f surces including Web-based training r in-persn training. Surces f training include state-spnsred wrkshps, ther SFAs, in-huse training, the USDA, and the Institute f Child Nutritin (ICN), prfessinal assciatins such as Schl Nutritin Assciatin (SNA) and the Califrnia Schl Nutritin Assciatin (CSNA), and cmmercial vendrs. Training must be jb-specific and intended t help emplyees perfrm their duties. Fr mre n specific bjectives fr relevant schl nutritin training, visit the training tpics and bjectives dcument lcated n the USDA Prfessinal Standards Web dcument at The USDA created a cmprehensive Prfessinal Standards Web site that allws schl nutritin staff t search fr training that meets their learning needs in ne easy-t-use lcatin. The site includes infrmatin n Webinars, nline mdules, self-paced training, training materials, manuals, etc. Access these resurces n the USDA Prfessinal Standards Web site at The Prfessinal Standards Web site als has links fr a sample tracking tl, Frequently asked Questins, and the USDA summary flyer lcated n the USDA Prfessinal Standards Web page at Schl Nutritin Prgram (SNP) Mdule 9 SNP Online Training Page 26 This institutin is an equal pprtunity prvider.

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