Slide 1 Nutritional Monitoring Quality Area: and Performance Meal Pattern Standard 2 Administrative Review Critical Areas General Areas Performance Standard I Performance Standard II Meal Components & Quantities Dietary Specifications & Nutrient Analysis Offer vs Serve Welcome everyone! This training will cover Section 2 of the new Administrative Review process, Nutritional Quality and Meal Pattern. As you can see on the slide, there are 3 areas in Performance Standard 2: 1 Meal Components & Quantities Offer vs. Serve, and Dietary Specifications & Nutrient Analysis. Slide 2 2 Meal Components & Quantities Day of Review and Review Period: Sponsors must plan, prepare, and offer all meal components and food items in the required quantities All meal service lines must offer all meal components and food items to meet daily and weekly meal pattern requirements Records must document all meal components and food items served On the day of review all sites that are selected for review will be assessed for compliance with the meal pattern requirements for the age/grade group or groups that the site is serving. The Assigned Specialist will review the meal components and food quantities that are planned, prepared and then offered to students. The review of meal components and food quantities includes both the day of review and the review period. Typically, the review period is the most recent month for which a claim for reimbursement has been submitted. Sponsors must ensure that all sites operating NSLP and SBP: plan, prepare, offer and serve meals to students that meet the meal pattern requirements for the appropriate age/grade groups. Sponsors must also ensure that every meal service line meets the daily and weekly meal pattern requirements for the appropriate grade group being served. This
includes meeting the meal pattern requirements if more than one grade group is being served at a single site, and at self-service stations, including salad bars or variety bars. Finally, sponsors are responsible for maintaining the required menu planning documentation and have it readily available for review. Slide 3 3 Required Meal Pattern Documentation Requested 6 weeks prior to on-site review Menu planning documents for Breakfast and Lunch for each age/grade group: Menus for Breakfast and Lunch Menu Planner for Lunch only ODE Menu Planner (in excel format), or USDA approved software Menu Planner Production Records As with the other areas of review, your Assigned Specialist will request documentation prior to the on-site review visit. The following menu planning documentation will be requested for review 6 weeks prior to the on-site visit for the selected review week. 1. Posted menus for school breakfast and lunch; 2. A menu planner for lunch only, either the ODE Menu Planner or sponsors who use a USDA approved nutrient analysis software may use a weekly report in place of the ODE menu planner. The report should contain the same information as
the ODE menu planner. The report must document how the planned menu meets the weekly and daily minimum meal pattern requirements per age/grade group. And, also needed prior to the on-site visit are 3. Production records for breakfast and lunch meals for the same review week. Portion sizes for meal components will be evaluated as well as all the other meal pattern requirements. Menu planners are encouraged to make like substitutions to ensure meals meet the daily and weekly requirements, as originally planned. For example substituting a whole grain item with a another whole
grain product, or a legume vegetable subgroup with another legume in that subgroup. Substitutions should be properly recorded on the production record. If the review of menu planning documentatio n reveals errors such as missing components or insufficient quantities, the review of menu planning documentatio n may be expanded beyond the review week.
Slide 4 4 Meal Service Observation Prior to Meal Service: Meal preparation observed Standardized recipes in use Ensure all meal components are offered on each serving line Sponsors have the opportunity to correct missing components On the day of review, the Assigned Specialist will observe meal preparation prior to meal service for breakfast and lunch. The Assigned Specialist will observe if standardized recipes are in use and being followed when meals are prepared. If multiple grade groups are being served at one site, the Assigned Specialist will examine how staff are meeting each grade group s meal pattern requirements. Before meal service begins, the Assigned Specialist will review all meal service lines to ensure that all of the meal components and food items in the required minimum quantities are available on all reimbursable meal service lines. If quantities observed are not correct, the specialist will require the site to provide documentation demonstrating that required amounts of each meal component were available for each day of service in the month of review. If a missing meal component is identified prior to the beginning of the meal service, the specialist will notify sponsor staff to give them the opportunity to correct it prior to the meal service. Allowing for the missing meal component to be corrected ensures the meal pattern requirements are met, children receive a nutritionally balanced meal and that meals are able to be claimed for reimbursement. However, even if corrected prior to meal service, the missing component will still be reported in the corrective action provided at the exit conference.
Slide 5 5 Meal Service Observation During Meal Service: Students are being served and self selecting appropriate quantities for the age/grade group Students understand how to select all meal components Staff recognize reimbursable meals at each Point of Service station During the meal service the Assigned Specialist will observe: Students being served and selfselecting sufficient meal components and food quantities required for the age/grade groups; That students demonstrate knowledge of how to select all required meal components in the meal service area; Staff at each point of service (POS) station are recognizing complete and reimbursable meals. Slide 6 6 Alternate Meal Service Locations Alternate Meal Service Locations: Field Trips Classrooms Detention Halls School Buses Kiosks Menus must meet the daily and weekly meal pattern requirements, including offering milk variety. If noncompliance is observed all alternate meal locations will be reviewed. In the new Administrative Review process, alternate locations of meal services will be reviewed. This includes, but is not limited to: field trips, classrooms, detention halls, school buses, kiosks, any location NOT in the cafeteria area that is serving meals. Offer versus Serve is optional at alternate meal service locations. Menu planning documentation will be reviewed to ensure that all meal components are available in the correct
quantities and are planned for at alternate meal service locations. This includes the requirement that a variety of milks must be offered. Field trips will be reviewed if held on the day of review or during the review period. If noncompliance is observed, all other alternate meal locations are subject for review. Slide 7 Meal Pattern & Quantities Fiscal Action: Missing meal components Missing production records Fiscal action could result in meal component and quantities area of review for either missing meal components or missing production records. 7 An example of a missing meal component would be if no daily vegetable is offered at all for school lunch. Slide 8 8 Administrative Review Critical Areas General Areas Offer vs. Serve Performance Standard I Performance Standard II Meal Components & Quantities Dietary Specifications & Nutrient Analysis Offer vs Serve There will be no changes to the way that Offer Versus Serve is reviewed by Assigned Specialists. Offer versus Serve is a menu planning option which allows students to decline some of the meal components offered. Offer versus Serve is required at the High School level for lunch. Offer versus Serve is optional for lunch at grades K-8 and is also optional at all grade levels for breakfast. Residential Child Care Institutions (RCCIs) are not
required to do participate in Offer versus Serve. Slide 9 9 Offer Versus Serve - Key Areas Menu Planning Sponsor prepares & offers all required components in the correct portion size for the age/grade group(s) served Determination of Reimbursable Meals Student selects food items and Point of Service staff assess if minimum number of components are selected in the correct quantity There are two key areas that apply to Offer Versus Serve: menu planning essentially did the sponsor make enough food and the determination of reimbursable meals, or in other words, did the students take enough food Offer versus Serve starts in menu planning. This is where the sponsor ensures that enough food is prepared and is offered in the correct quantities to meet the meal pattern requirements to be able to select a reimbursable meal. Equally as important, the sponsor staff must determine at the Point of Service that students are being served and selecting at least 3 meal components in the correct quantities to be determined a reimbursable meal. This is including the new requirement at lunch only, that students take at least ½ cup of fruits and/or vegetables.
Slide 10 Offer Versus Serve Requirements Offer enough food on all meal service lines Signage is posted near the beginning of the service line(s) Students select the minimum number of components for reimbursable meals Staff accurately judge quantities/portion size on self-serve bars Point of Service staff are trained and can recognize a reimbursable meal including appropriate quantities. USDA Policy Memo SP 45-2013: 10 http://www.fns.usda.gov/cnd/governance/policy-memos/2013/sp45-2013a.pdf When determining OVS compliance, your assigned specialist will look for the following: The school is offering all meal components on all reimbursable meal service lines; Signage is posted at or near the beginning of the service line that will assist students in easily identifying a reimbursable meal; Students are selecting enough components/items in the proper quantities to make a reimbursable meal; Food service staff members are accurately judging quantities on self-serve bars in order to recognize what is a reimbursable meal; and POS staff members at the point of service are trained and can accurately recognize a reimbursable meal, including appropriate quantities. For purposes of this webinar we will not go into any further depth with OVS regulations. Please review the new OVS Manual at the web address listed on the slide or review our annual trainings on ilearn for more information.
Slide 11 11 On-site: Required Signage Signage is a requirement for Lunch and Breakfast. Here are examples of what some Oregon Sponsors are doing to meet this requirement. Please ensure that this is in place at all serving lines at all sites for both breakfast and lunch. Sponsors may post reimbursable meal guidelines and/or nutrition messages. Slide 12 Offer Versus Serve Findings Missing Meal Components Insufficient quantities of fruits/vegetables (less than ½ cup taken by the student) Incorrect Implementation Untrained Staff No Signage Possible findings could be related to: missing meal components, insufficient quantities of fruits/vegetables (requirement is ½ cup) implementation, staff training, and required signage. 12 All corrective actions, whether taken immediately or at a later date, will be documented at the exit conference. Slide 13 13 Offer Versus Serve Fiscal Action Missing Meal Components Lunch Example: No fruit or vegetable offered Insufficient fruit/vegetable quantity Less than ½ cup fruit or vegetable taken = LUNCH only In Offer Versus Service Fiscal Action could occur for the following reasons: Missing Meal Component Fiscal action may occur when a meal component is missing from the minimum required 3 components for lunch, or 3 food items for breakfast and is not part of the reimbursable meal at the Point of Service. For example, if there is no fruit or vegetable is offered for Lunch, the meal is missing two components.
Insufficient Fruit/Vegetable Quantity If meals contain a fruit or vegetable, but the serving taken by the student is less than the required ½ cup - for lunch only the meal is will be determined to be an incomplete meal. Fiscal Action will occur if students repeatedly take meals with insufficient quantities of fruits and/or vegetables. These meals will be disallowed. Slide 14 Dietary Specifications & Nutrient Analysis Administrative Review Critical Areas General Areas Performance Standard I Performance Standard II Meal Components & Quantities Dietary Specifications & Nutrient Analysis Offer vs Serve The final section of this presentation is Dietary Specifications and Nutrient Analysis. This is a new review process, and will have a Risk-Based Approach. 14 Slide 15 15 Dietary Specifications Determine if Sponsor is serving reimbursable meals according to Dietary Specifications Calories Saturated Fat Trans Fat The Assigned Specialist will determine if the Sponsor is serving reimbursable meals according to the Dietary Specifications Calories Saturated Fat Trans Fat as well as determine if a one week weighted nutrient analysis is required for each USDA established age/grade group and menu type offered at lunch and breakfast for ONE site within the Sponsor.
Slide 16 Dietary Specifications & Nutrient Analysis 16 Meal Compliance Risk Assessment for Site Selection o 1 targeted site for in-depth menu review Dietary Specifications Assessment Off-Site and On-Site o Meal Pattern Compliance Required o Authentication of menu documentation Off-site = On-Site Nutrient Analysis Conducted, if necessary For the Dietary Specifications & Nutrient Analysis review the process begins prior to the on-site review. A Dietary specifications assessment will be conducted by the your assigned specialist to determine if the sponsor will require a nutrient analysis. The dietary specifications assessment will be conducted both off-site or prior to review, and on-site the day of review. Confirmation of the menu documentation provided by the sponsor off-site must demonstrate the documentation is accurate and consistent with the same on-site. To appropriately assess the dietary specifications, and before the nutrient analysis can be performed, the targeted menu review site must be in compliance with the meal pattern for both lunch and breakfast for each age/grade group and distinct menu served. If the meal pattern requirements are not met, immediate technical assistance and corrective action must take place during the onsite visit to bring the Sponsor into compliance.
Just as important, the menu documentation required for the lunch and breakfast nutrient analyzes must be accurate and verified on-site. During the on-site review the reviewer will assess : Are Production Records completed accurately? Are Standardized Recipes utilized and maintained? Are Nutrition Fact Labels available? Slide 17 17 Menu Certification not completed prior to Administrative Review Off-site Dietary Specification Assessment On-Site Dietary Specification Assessment On-Site Performance Standard 2 noncompliance Nutrient Analysis Required Nutrient Analysis There are 4 possible scenarios when the sponsor s targeted site would require a nutrient analysis. One, for those sponsors who have not completed the menu certification process and been approved prior to the on-site review. 2 & 3 will be based on the results of the Dietary Specifications Assessments your Assigned Specialist will conduct either during the off-site portion of the assessment or once on-site it is determined a Nutrient Analysis is required. Finally 4, if Performance Standard 2 noncompliance issues are identified during the on-site review, the site is automatically required to have a
nutrient analysis completed. For the nutrient analysis to be completed, the review week s menu must met the meal pattern first. And the analysis MUST reflect current practice at the time of the on-site review and therefore meet the minimum meal pattern requirements. Therefore any corrective action would have to be applied to the week submitted for the Nutrient Analysis. The analysis will be conducted on the menu offered to students served, not based on planned amounts. Slide 18 18 Corrective Action Immediate Corrections Agreed upon timeline No further action needed Documented and reported at Exit Conference If Corrective Action is completed immediately in collaboration with the Assigned Specialist for an agreed upon due date or timeline, further action will not be required. However, even if the item that is out of compliance is corrected immediately, all corrective action determined during the review process, will be documented and reported at exit conference.
Slide 19 19 List of Resource Links Administrative Review (AR) Process Webinar Series: http://www.ode.state.or.us/search/page/?id=3172 Grade Grid Quick Reference: http://www.ode.state.or.us/search/page/?id=3707 New Meal Pattern Resources: http://www.ode.state.or.us/search/page/?id=3653 2013-2014 Breakfast Production Record: http://www.ode.state.or.us/search/page/?id=1999 Offer Versus Serve Manual http://www.fns.usda.gov/cnd/governance/policy-memos/2013/sp45-2013a.pdf This is the list of resource links referenced throughout this presentation. This handout will be posted along with the PowerPoint slides on the ODE website on the Administrative Review resources page. Slide 20 Questions? This completes Section 2 presentation. If you have any questions please contact your assigned specialist. 20 Slide 21 The U.S. Department of Agriculture 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 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 complain 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 program.intake@usda.gov 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 (Spanish). USDA is an equal opportunity provider and employer.