CRE-SMI Overview Please turn on your speakers or headphones!

CRE-SMI OverviewPlease turn on your speakers or headphones!

What is CRE-SMI?What is CRE-SMI?

CRE/SMI: Two different reviews

CRE=Coordinated Review Effort Performance Standard 1-Meal Counting and

Claiming/Eligibility Performance Standard 2- Meal Components General Review Areas State Agency (ODE) Specific Areas

SMI=School Meals Initiative Comprehensive nutritional review of School Food

Authority’s (SFA) selected menu planning option

CRE review cycle and scheduleCRE review cycle and schedule

SFA’s must be reviewed at least once every 5 year cycle.

SFA’s are notified in August that they will be reviewed.

Confirmation letter sent at least 30 days prior to review.

Hint: Always be prepared!

Review Period and Number of Review Period and Number of Sites to be ReviewedSites to be Reviewed

CRE includes: Day of review (the day we

are on-site) Review period

Review period= most recent month for which a claim for reimbursement was submitted.

When selecting school(s) to be reviewed, ODE must use USDA required procedures.

# of Schools in SFA Minimum # of School to Review

1-5 1

6-10 2

11-20 3

21-40 4

41-60 6

61-80 8

81-100 10

101 or more 12 plus 5% of the numbers of schools over 100

School selection cont.School selection cont.

School Selection Worksheet.

Schools w/free ADP of 100 or more and 100% or more free participation must be reviewed. Additional schools that must be reviewed:

Elementary schools (pre-K, K-8) w/free ADP of 100 or more and 97% free participation.

Combination schools (K-12, 7-9, 7-12, etc.) w/free ADP of 100 or more and 87% free participation.

Secondary schools (9-12) w/free ADP of 100 or more and 77% free participation.

If none of these criteria are met, then optional criteria can be used.

Program areas to be reviewedProgram areas to be reviewed

Performance Standard 1=Meal Counting and Claiming/Eligibility

Performance Standard 2=Meal Components

General Areas= Wide variety of subjects and ODE specific subjects

The Review ProcessThe Review Process

1. CRE announcement letter sent to SFA in August. 2. ODE will contact SFA to set exact date for review.3. Second CRE announcement letter sent to SFA

approximately 30 days before review date. 4. ODE reviewers will conduct entrance conference with the

superintendent and/or their designee(s). ODE reviewers may review breakfast service prior to the entrance conference.

5. ODE reviewers will conduct an exit conference with the superintendent and/or their designee(s) to discuss the review findings. ODE reviewers will issue a Document of Administrative Findings (DAF) outlining the Corrective Action required by the SFA.

6. The SFA has 30 days to adequately respond to all findings noted in the DAF. Should the DAF be incomplete or past due, the SFA’s claims will be placed on “HOLD” until all review findings are corrected.

7. If there are no findings or the DAF has been adequately addressed, ODE will issue a closure letter for the review.

The First ReviewThe First Review

Breakfast and Lunch will be reviewed.

What will ODE reviewers be looking at:

Applications/Benefit Issuance Process Applications should be sorted by review school and

Benefits Issuance Document. 100 Percent of applications will be reviewed (ODE

retains right to review less). Temporary and denied applications. Approved eligible student counts vs. reviewer’s count. Applications will be checked for correct approval on

income and family size. Determine if questionable applications were

researched before a determination was made.

The First Review Cont.The First Review Cont.

Direct Certification (DC) Official ODE downloaded DC list. DC list updated regularly? Predetermined Eligibility letter for DC sent to

households? Are siblings of directly certified students included in

the eligibility benefits following new USDA guidelines? Is DC list only used for first 30 operating days of the

school year? Head Start Documentation

Are Head Start students enrolled in the school district in an academic program?

Is a statement of low income provided by an authorized Head Start employee? OR

A list of income eligible Head Start students. Is the list new for each school year? Was predetermined eligibility letter sent to

households?


Even Start Program Documentation Approved Even Start application, or Statement of enrollment in Even Start; or a list of

children in Even Start must be on file. Confirmation of pre-kindergarten status. Re-certify each year.

Runaway Youth Documentation To document a child’s runaway status and eligibility for

free meal benefits, the school must obtain a list with each child’s name and the signature of the local runaway coordinator.

Homeless Youth Documentation To document a child’s homeless status and eligibility

for free meal benefits, the school must obtain a list with each child’s name and the signature of the local homeless coordinator.


Migrant Youth Documentation To document a child’s migrant status and eligibility for

free meal benefits, the school must obtain a list with each child’s name and the signature of the local migrant coordinator.

Master List/Roster Is there a listing of all students and their approved

categories by school? The list/roster should include:

Child’s name Approved status Date approved Date noting a change must be on roster or application

School master list will be compared to all F/R applications, DC list, runaway, homeless, migrant, Head Start/Even Start.

Denied (paid) applications will be checked for correct approval and student’s status will be checked on roster to make sure student is receiving proper benefits.

The First Review Cont.The First Review Cont. Documentation of any Changes

Any change on the master list/roster or the application must be initialed and dated by the person making the change.

Verification Process Is the correct sample size based on October 1 count of applications? Is the district summary sheet completed? Did the district document by application? Was verification completed by November 15? Were an adequate number of applications selected? Were required income and SSN documentation obtained? Is the Verification Record completed? Were correct letters sent to households Were changes to the master list/roster made if verification results

changed eligibility? Meal Count/Collection Procedures

Is the counting, recording, and claiming of the number of meals served to students by category accurate?

Is there adequate documentation to support the claim? Is the medium of exchange used correctly? No overt identification? Is

the collection procedure observed the same as approved by ODE? Is there equal access for all students?


Point-of-Service Count Is the system used providing an accurate point-of

service count of reimbursable meals served (one per eligible student per day) by category (free, reduced and paid) each day without overtly identifying students’ eligibility?

Consolidation of Claims Are the edit checks conducted to prevent claiming

more students than in attendance? Are edit checks performed daily (compare each

school’s daily claim against the number of students approved for free and reduced-price lunches, the school’s average daily attendance and the school’s enrollment?

Are on site reviews completely annually for an SFA with more than one feeding site?


Menu Requirements for all meal patterns Are all required components/food items available in correct

portion sizes on reimbursable meal serving lines on day of review?

Are all items offered before the point-of-service count? Are food production records complete and adequate to

support claims? Do the Month of Review menus meet meal pattern

requirements? Are CN labels available for food based menus, product data

sheets for Nutrient Standard menus? General Record Keeping Policies

Are records kept for 3 years plus current operating year? Are approved applications (date approved, level of benefits,

signature or initials of reviewing official) kept? Is supporting information, such as dates of transfers,

withdraws and changes in eligibility, maintained?


Records to maintain daily Is the daily record of Reimbursable Meals maintained? Is the daily record of Income updated? Are food production records completed by the end of

each day? Is the system that notes transfers, withdrawals, etc.

updated as needed? Are edit checks conducted daily?

Records to maintain monthly Is the consolidation of school meal counts by category

correct? Is the reimbursement claim submitted electronically

via CNPweb no later than 60 days following the completion of the claim month?


Financial Records Are financial records, purchasing procedures, and meal

pricing available for review? Is the fund balance from last year carried forward (positive

or negative)? Is the net cash balance less than three months’ operating

expenditures? Is all interest posted to Child Nutrition Program account? Does payroll account for only Child Nutrition personnel? Are meals priced as a unit? Do reduced-price charges exceed maximum allowed? (40

cents for lunch and 30 cents for breakfast, public schools must have zero charge for reduced-price breakfasts due to Oregon law)

Are adult meals prices at least the free reimbursement rate plus commodity entitlement rate?

Is there a bidding process in place? Is district purchasing awarded items?

Are state matching funds deposited in the CN account?

The First Review Cont.The First Review Cont. Policy Statement

Is the district following all attachments to their free/reduced policy statement?

Civil Rights Are disabled children receiving accommodations for

feeding? Nondiscrimination poster posted? Is the nondiscrimination statement printed on

correspondence? How is the district handling complaints of

discrimination? Is the district providing/using foreign language

translation applications, if needed? Is there separation by race, color, national origin, sex,

age or disability in the eating periods, seating arrangements, serving lines or eating areas?

Is there overt identification?


Procurement Process Do you know what the Federal procurement

regulations are? If not review 7 CFR 3016. Do you know what your local small bid threshold is? If

not are you using Oregon small bid threshold of $5,000?

If you are purchasing below the small bid threshold are you obtaining at least 3 quotes?

If you are purchasing above small bid threshold are you using an Invitation for Bid or Request for Proposal?

Are all purchases being procured competitively with no restrictive requirements?

Is the Buy American provision being followed? Is child nutrition required to purchase off an exclusive

school beverage contract?

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Competitive FoodsDoes the SFA have a board policy

allowing foods to be sold in competition with school meals?

Foods of Minimal Nutritional ValueIs serving/purchasing of Foods of Minimal

Nutritional Value (FMNV) in foodservice area or with CNP funds observed?


Provision 2 Base Year Is there a notification document to parent/guardian on file

including media release? Meals being provided at no charge to students? Meals being counted and claimed by eligibility category of

student? All other eligibility rules still apply.

Provision 2 Non-Base Year Is documentation of public announcement regarding

Provision 2 on file? Meals being provided at no charge to students? Is the percentage of free/reduced/paid established in the

base year being applied to monthly count correctly? Are base year free/reduced applications still available for

review?


Food Service Management Company Operations (if applicable)

Is the contract being followed? Is the SFA monitoring the management company

operations? SFA employee completing yearly on-site reviews? Is SFA filing monthly claim for reimbursement,

establishing meal pricing, and retaining signature authority?

Is SFA monitoring free/reduced applications and verification process if management company is completing? Is this agreement in contract?

Does the SFA have an advisory board composed of parents, teachers, and students to assist in menu planning? Documentation of attendance on file?

Is FSMC following all applicable rules regarding commodities and rebates?


After School Snacks (if applicable) Documentation of education or enrichment activity Attendance records Snack Production Records Roster/tally sheet of daily count of snack Two afterschool on-site reviews per year

Fresh Fruit and Vegetable Program (if applicable) Invoices and time and effort document Month of Review

FFVP claim Adequate amount of produce to serve the enrolled

number of students in the school Sponsor/school is serving a variety of fruits and

vegetables Sponsor/school following the Implementation Plan Sponsor/school completing two yearly self-reviews


Commodities Is the district storing foods properly:

Off floor, away from walls? Cleaning supplies stored separately? Old, excessive or damaged commodities utilized or

removed? Annual Commodity Storage Evaluation completed?

Health Inspections/Food Safety Has the school been inspected twice within the last 12

months? Most recent inspection posted? Have violations been addressed, if noted on

inspection? Is HAACP food safety plan available at every

production, serving site in SFA?

Follow-up ReviewFollow-up Review

Review Threshold Review threshold or degree of error in a critical

area of review is exceeded and triggers a follow-up review

Review Findings classified as either: Non-systemic

Unusual factors contributed to the error Systemic

An error is built into a system and would likely re-occur if no changes to system.

Clerical Means the error may or may not be non-systemic or

systemic.

Fiscal ActionFiscal Action

If an over-claim is noted during a review, fiscal action could occur= we take money back!

ODE has option to disregard any over-claim of $600 or less per program.

Month of review claim (and possibly others) will be adjusted by ODE. Eligibility errors normally go back to beginning of month

of review to date of correction. Reviewer retains discretion.

Meal counting/meal component errors normally go back to the beginning of the school year to date of correction. Reviewer retains discretion.

ODE has discretion to go into previous fiscal years depending on severity of the situation.

Lack of Response or Documented Lack of Response or Documented Administrative Findings (DAF) Plan Past dueAdministrative Findings (DAF) Plan Past due

No responseClaims put on hold until DAF received

Response past dueClaims put on hold until DAF received

Appeals ProcedureAvailable when fiscal action is assessed. Cannot appeal findings.

Scope and Timeline for Follow-Scope and Timeline for Follow-up Reviewup Review

If Follow-up review has been triggered: Problem areas addressed All other Child Nutrition Programs reviewed

Follow-up review must be conducted before December 31 of the following year.

If a second follow-up review is required, ODE can place a “HOLD” on program funds. Eliminate possibility for follow-up reviews Program termination?

School Meals Initiative (SMI)

Comprehensive Comprehensive evaluation of districts evaluation of districts lunch menu to ensure lunch menu to ensure compliance with the compliance with the

Dietary Guidelines for Dietary Guidelines for Americans.Americans.

Required Nutrient LevelsTraditional Food Based Menu Planning

Required Grade Nutrient Standards Recommended Dietary Allowances (RDAs)

1/4 - RDA for breakfast 1/3 - RDA for lunch

Age appropriate calorie & nutrient goals Breakfast

Grades K-12 Calories 554 Total Fat Not to exceed

30% of calories Saturated Fat Less than

10% of calories Protein 10 g Calcium 257 mg Iron 3.0 mg Vitamin A 197 RE

Req

uire

d

Vitamin C 13 mg *Cholesterol <75mg *Fiber >1g/100 calories

*Sodium <800 mg

Lunch Grades K-3 Grades 4-12 Calories 633 785 Total Fat Not to exceed

30% of calories

Not to exceed 30% of calories

Saturated Fat

Less than 10% of calories


Protein 9 g 15 g Calcium 267 mg 370 mg Iron 3.3 mg 4.2 mg Vitamin A 200 RE 285 RE

Req

uire

d

Vitamin C 15 mg 17 mg *Cholesterol <100 mg <100 mg *Fiber >1g/100

calories >1g/100 calories

*Sodium <1200 mg <1200 mg

* Recommendations

Enhanced Food Based Menu Planning Required Age/grade Standards Recommended Dietary Allowances (RDAs)

1/4 - RDA for breakfast 1/3 - RDA for lunch


Grades K-12 Calories 554 Total Fat Not to exceed

30% of calories Saturated Fat Less than


Req

uire

d


*Sodium <800 mg

Lunch Grades

K-6 Grades

7-12 Calories 664 825 Total Fat Not to exceed

30% of calories Not to exceed

30% of calories Saturated

Fat Less than

10% of calories Less than

10% of calories

Protein 10 g 16 g Calcium 286 mg 400 mg

Iron 3.5 mg 4.5 mg Vitamin A 224 RE 300 RE

Req

uire

d

Vitamin C 15 mg 18 mg *Cholesterol

<100 mg <100 mg

*Fiber >1g/100 calories

>1g/100 calories

*Sodium <1200 mg <1200 mg *Recommendations

Nutrient Standard Menu Planning Required Age/Grade Nutrient Standards

Recommended Dietary Allowances (RDAs) 1/4 - RDA for breakfast 1/3 - RDA for lunch


Grades K-12 Calories 554 Total Fat Not to exceed 30% of

calories Saturated Fat Less than


Req

uire

d


*Sodium <800 mg

Lunch Grades K-6 Grades 7-12

Calories 664 825 Total Fat Not to exceed

30% of calories

Not to exceed 30% of calories

Saturated Fat



Protein 10 g 16 g Calcium 286 mg 400 mg

Iron 3.5 mg 4.5 mg Vitamin A 224 RE 300 RE

Req

uire

d

Vitamin C 15 mg 18 mg *Cholesterol <100 mg <100 mg *Fiber >1g/100

calories >1g/100 calories

*Sodium <1200 mg <1200 mg *Recommendations

What must sponsors do?

Traditional Food Based Menu Traditional Food Based Menu Planning (TFBP)Planning (TFBP)

After the on-site visit by ODE during After the on-site visit by ODE during the week of review, you will send us:the week of review, you will send us: Printed MenuPrinted Menu Production Records for SMI week of Production Records for SMI week of

reviewreview Standardized recipes usedStandardized recipes used Nutrition Fact Labels for non-single food Nutrition Fact Labels for non-single food

items.items. Condiment recording formCondiment recording form

What must sponsors do?Nutrient Standard Menu Planning (NSMP)Nutrient Standard Menu Planning (NSMP) Prior to the on-site visit by ODE, you will send us:Prior to the on-site visit by ODE, you will send us:

Printed Menu for SMI week of reviewPrinted Menu for SMI week of review Menu spreadsheet detail report using portion valuesMenu spreadsheet detail report using portion values Recipe audit reportRecipe audit report Nutrition facts labels for products usedNutrition facts labels for products used Data entry for local ingredientsData entry for local ingredients

During on-site visit, ODE will evaluate:During on-site visit, ODE will evaluate: Production Records are being completedProduction Records are being completed Adjustments made to servings planned from production recordsAdjustments made to servings planned from production records Data entry for local ingredientsData entry for local ingredients Portion sizes used in analysis are the same as on-site day of Portion sizes used in analysis are the same as on-site day of

reviewreview Use of standardized recipes in analysis and productionUse of standardized recipes in analysis and production Verify ingredients used in analysis and those used in productionVerify ingredients used in analysis and those used in production

After on-site visit, you will send ODE:After on-site visit, you will send ODE: Completed production records for the week of reviewCompleted production records for the week of review

Compliance or Corrective Action

Whether on NSMP or TFBP, if any of Whether on NSMP or TFBP, if any of the 8 required Federal nutrient the 8 required Federal nutrient levels are inadequate, a levels are inadequate, a improvement plan will be issued.improvement plan will be issued.

If any of the 3 recommended state If any of the 3 recommended state nutrient levels are inadequate, a nutrient levels are inadequate, a improvement plan will only be improvement plan will only be necessary if at least 1 federal necessary if at least 1 federal nutrient level is inadequate.nutrient level is inadequate.

If you meet all requirements you If you meet all requirements you will receive a congratulations letter.will receive a congratulations letter.

Lack of response or Corrective Action Plan Past

Due

No response to information No response to information requestedrequested Claims put on hold until information Claims put on hold until information

receivedreceived Corrective Action past dueCorrective Action past due

Claims put on hold until corrective Claims put on hold until corrective action receivedaction received

We are here to help. If you need any assistance in the operation of your child nutrition program, please call or e-mail your assigned child nutrition specialist.

The whole point of the CRE-SMI review is to ensure that

money is being spent appropriately and you are

providing nutritious meals to children that meet Federal

requirements.

CRE-SMI Overview Please turn on your speakers or headphones!

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