School Nutrition Programs Compliance Handbook
CHAPTER 1- SCHOOL AGREEMENTS AND POLICY REQUIREMENTS
PROGRAM ELIGIBILITY
Public and private non-profits School Food Authorities (SFA) can receive federal assistance for serving nutritious meals. SFAs can receive assistance for lunch, breakfast, after school snacks, and milk. Private nonprofit schools and private nonprofit Residential Child Care Institutions (RCCI) apply with the Oklahoma of Human Services (OKDHS) School Nutrition Programs.
To Apply Contact |
OKDHS School Nutrition Programs: |
Public schools and RCCIs can contact the Oklahoma State Department of Education (SDE) for participation. The contact number for the OSDE Child Nutrition Programs is 405-521-3327.
To receive program assistance, an SFA must adhere to program requirements set forth by federal regulations. This handbook is intended only for SFAs that contract with the School Nutrition Programs at OKDHS. Public SFAs must consult with SDE for guidance. Table 1 contains the criteria for participation for private nonprofit schools and RCCIs.
Table 1: Criteria for Participation with OKDHS |
To participate with DHS-SFAs must meet the following criteria:
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EQUAL OPPORTUNITY FOR RELIGIOUS ORGANIZATIONS
Federal regulation [7 CFR Part 16] eliminates unwarranted barriers to the participation of faith-based organizations in USDA programs. Organizations are eligible to participate in USDA programs without regard to their religious character or affiliation. OKDHS School Nutrition Programs (SNP) cannot exclude School Food Authorities (SFA) from competition for direct USDA assistance simply because of religious affiliations. Religious organizations are eligible to compete for USDA assistance on the same basis, and under the same eligibility requirements as all other non-profit organizations. USDA, as well as state and local governments administering USDA programs, cannot discriminate against organizations based on religion, religious belief, or religious character in the administration or distribution of USDA assistance, including grants and commodities.
GETTING APPROVAL
The first step to participation is getting approval. School Food Authorities (SFA) must complete a program application and sign an agreement with OKDHS. OKDHS SNP staff will review the application and adopted policies prior to approving the SFA’s participation in a program. Once approved (see table 2 for the criteria for approval), SFAs are required to renew program participation annually to remain on the program.
Table 2: Criteria for a SFA Receiving Approval |
To get approval:
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OVERVIEW OF FORMS FOR PARTICIPATION
Annually, School Food Authorities (SFA) must renew their application and supporting documentation. SFAs must keep these records on file along with annual updates and any revisions made to the procedures and policy statements listed in this section.
Below are documents required during the initial application process. For participation, these forms must be approved by the OKDHS School Nutrition Programs office. Contact OKDHS School Nutrition Programs for forms.
Table 3: Forms for Participation in USDA Child Nutrition Programs |
The following forms must be completed to participate in USDA Child Nutrition Programs through OKDHS:
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Description of Forms
School Nutrition Programs Agreement: This agreement lists federal and state requirements for each program administered by OKDHS School Nutrition Programs (SNP). By signing, School Food Authorities (SFA) agree to comply with federal requirements set forth by USDA, Child Nutrition Programs. This is not an all-inclusive contract and SFAs may be required to follow additional program requirements set forth by federal and state law.
Application for Participation: The application gathers specific information regarding the SFA’s school foodservice program and local school data. Because school data changes periodically, SFAs must complete this form annually.
Civil Rights Pre-award: The pre-award gathers information about student eligibility for free and reduced-priced lunches according to ethnicity and race. It also determines whether any discrimination issues exist prior to participation in USDA Child Nutrition Programs.
Free and Reduced Price Policy Statement or the Nonpricing Policy Statement: The policy statement lists the requirements for administering meals to children eligible for free and reduced priced meals. This policy demonstrates the integrity of the program to feed children without discrimination and without improper use of program funds. SFAs that charge students for meals must complete the Free and Reduced Policy Statement. SFAs that do not charge students for their meals must complete a Nonpricing Policy Statement.
Meal Counting and Collection Procedures: This form gathers information regarding the School Food Authority’s (SFA) meal counting procedures and type of service. The data collected includes;
- Age of students participating in the meal service
- Type of meal service
- Point of service procedures
- Counting procedures.
Nonprofit Statement (501 (c) 3: SFAs must have a 501 (c) (3) letter from the IRS granting the entity nonprofit status. In addition, SFAs are required to administer a nonprofit food service program. The nonprofit status must be current.
Letter of Accreditation (for private schools) or OKDHS Residential Child Care Institution License: Private schools must submit a current copy of their Accreditation Certificate or submit a letter of recognition provided by the Oklahoma Department of Education; not all private schools are eligible to participate. Residential Child Care Institutions (RCCI) must be licensed either by OKDHS or another State Agency recognized by OKDHS School Nutrition Programs. Contact OKDHS School Nutrition Programs for eligibility requirements.
Attestation for New Meal Patterns: Beginning with Program year 2012-2013, School Food Authorities (SFA) must attest to compliance with the new meal pattern requirements as required by the Healthy Hunger-Free Kids Act of 2010. Special meal patterns are required to ensure that children are receiving healthy and balanced meals. See Chapter 2 for more information on meal patterns.
After School Snack Program Application: SFAs participating in the National School Lunch Program (NSLP) can receive additional assistance when participating in the After School Snack Program. SFAs must serve snacks to children during an afterschool program. The program must provide children with regularly scheduled activities in a structured organized and supervised environment. The program must include educational or enrichment activities (e.g., mentoring or tutoring programs). Competitive interscholastic sports are not an eligible afterschool activity. However, programs that include supervised
athletic activity along with education or enrichment activities may participate. SFAs must also provide nutritious snacks in compliance with the federal requirements. See Chapter 13 for more information on the Afterschool Snack Program.
Special Milk Program Application: School Food Authorities (SFA) can participate in the Special Milk Program (SMP) upon request, if students participating in the milk program do not participate in the National School Lunch Program (NSLP) or School Breakfast Program (SBP). This includes schools that participate in the NSLP, but do not offer it to the children attending split-session kindergarten programs. SFAs participating in the SMP may elect to serve milk: at a paid price; not charge for milk; or charge for milk and serve it free to children eligible for free milk. See Chapter 14 for more information on the SMP.
ADDITIONAL POLICY AND PROCEDURES
In addition to the forms listed above, SFAs are required to develop and implement other program policies and procedures, prior to approval. Descriptions of these policies are addressed in later chapters of this handbook.
OKDHS School Nutrition Programs will send out additional information through email as policy updates and reminders. Table 4 contains a list of these documents.
Table 4: Policy Updates and Reminders |
Contained on this table is a list of typical policy and documentation OKDHS School Nutrition Programs will send out emails regarding:
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Descriptions of Additional Policies
Civil Rights Policy information is found in Chapter 3. This policy is specific to school food service and civil rights complaints cannot be handled as part of an existing grievance policy. This policy allows program participants to file a complaint if they feel discriminated against in the food service program. The complaint process must go directly to USDA or to OKDHS School Nutrition Programs (SNP) and cannot be held up by the SFA.
Local Wellness Policy is adopted by site [each site within a School Food Authority (SFA) must have a local wellness policy] and must contain all required goals set forth by USDA. The school must create objectives to achieve each goal. A development and review committee must be organized to assist in the creation of the policy and policy updates. A designated official must also be assigned to monitor and evaluate the program and notify committee members and the public of evaluations and policy changes. Contact OKDHS School Nutrition Programs for more information on local wellness policies. For more information regarding the requirements for local wellness policies see chapter 11.
HACCP plan is a comprehensive food safety food plan that must be implemented by each food service site. The plan follows the HACCP procedures to determine critical control points in production and cooking processes. The plan must have standard operating procedures for addressing all areas of food safety. The plan must be available to food service staff and procedures must be reviewed monthly. Contact OKDHS School Nutrition Programs for a prototype plan. For more information on food safety see chapter 10.
Menus Compliant with Federal Regulations
Prior to filing a first claim for reimbursement, School Food Authorities (SFA) must demonstrate compliance with the meal patterns for the programs the SFA is going to operate (see Chapter 2). SFAs must submit a four-week menu for the programs the SFA wants to operate to OKDHS School Nutrition Programs (SNP). OKDHS SNP will review the menus and complete the computerized menu assessment and dietary specification form to determine if the meals comply with meal pattern requirements.
Procurement Procedures are found in Chapter 7. SFAs must set up a system for the procurement of food, products, and equipment. The process must comply with federal requirements. SFAs must compare prices and buy the lowest and best. For more information regarding procurement requirements see Chapter 7.
Resource Management procedures are found in Chapter 4. SFAs must maintain a separate nonprofit account from other agency funds. All funds are to be used directly by the school food service program requirements affect how the money may be spent on nonprogram foods and other items directly or indirectly related to the school food service account. For more information regarding resource management see Chapter 4.
All other policies as required by USDA
School Food Authorities (SFA) should be aware that policies and federal requirements routinely change. When an SFA signs the program agreement, the organization agrees to comply with all federal requirements. OKDHS School Nutrition Programs (SNP) will keep SFAs updated on changes and provide technical assistance and training as needed.
RECORDKEEPING REQUIREMENTS
Both the School Food Authority (SFA) level and the site level must keep accurate records pertaining to the school food service program activities. Accurate records serve as a basis for filing a claim for reimbursement and demonstrate program compliance. Failure to retain documentation that supports claim reimbursement, eligible students, and reimbursable meals can result in the withholding of program funds or fiscal action.
Table 5.1 contains documentation required to be maintained on file for three years after the last reimbursement claim has been received for the school year.
Table 5.1: Documentation Required to be Maintained on File for Three Years After the last reimbursement Claim has Been Received for the School Year |
The records contained in this table are required to be maintained for three years after the last reimbursement claim has been received for the school year: · Afterschool Snack Program self-monitoring checklists · Annual civil rights training documentation · Annual procurement training documentation for staff members with procurement duties for the school food services program · Civil Rights worksheets · Direct certification documentation (including notification of direct certification matches to the SFA and notification letters to households of matches) · Documentation of compliance with annual training hour requirements for the school year. · Documentation of the assessment of the local wellness policy (triennial wellness assessment report) · Documentation of on-site self-reviews for multi-site SFAs · Documentation of the verification process · Health Department inspection reports · Household applications for the school year including notification letters to households. · Local wellness policy (past version) · Procurement documentation (contracts, invoices, documentation of the procurement process, etc.) · Production records · Public release · Menus · Child Nutrition (CN) labels and product formulation statements · Temperature logs · Resource Management – Revenue and expense report for the school year. |
Documentation may be retained electronically. |
Table 5.2 contains the documentation required to be maintained on file for seven years after the last reimbursement claim has been received for the school year.
Table 5.2: Documentation Required to be Maintained on File for Seven Years After the Last Reimbursement Claim has Been Received for the School Year |
The documentation contained in this table are required to be maintained for seven years after the last reimbursement claim has been received for the school year: · Edit checks · Edit check reports for electronic counting systems · Electronic meal rosters (for electronic counting systems) · Meal rosters · Reimbursement claims |
Documentation may be retained electronically. |
Table 5.3 contains the documentation that must be maintained permanently.
Table 5.3: Permanent Documentation |
The documentation contained in this table are permanent documents and must not be discarded: · School nutrition programs Agreement with OKDHS · Civil rights pre-award · Free and reduced policy statement (for pricing programs), or the nonpricing policy statement (for nonpricing programs) · Meal collection and counting procedures · Nonprofit statement [501 (c) (3)] · Letter of accreditation (for private schools), or OKDHS RCCI License, or license from recognized state agency for the RCCI. · Attestation to follow meal patterns · Afterschool Snack Program Application (if applicable) · Special Milk Program (SMP) · Procurement plan · Code of conduct for procurement · Procedure for handling civil rights complaints · HACCP food safety plan · Local wellness policy (the most recent version. This policy is required to be assessed at least once every three years) |
In addition to retaining paperwork, SFAs are responsible for submitting monthly claims, annual and periodical reports, and additional information as requested by the State Agency. Our office recommends that SFAs create a system for completing and tracking paperwork. For a list of required records, see School Nutrition Programs Summary of Reporting Dates and Recordkeeping Requirements at the end of this chapter.
POLICY CHANGES
School Food authorities (SFA) must follow the policies as approved by OKDHS School Nutrition Programs (SNP). OKDHS SNP will review these policies during administrative reviews, procurement reviews and reporting deadlines. SFAs must demonstrate compliance with approved policies. At times, SFAs may need to modify existing policies to match changes at the school level. When this occurs, SFAs must also notify OKDHS SNP to request modifications to required forms and approved policies. There are times when changes won’t comply with federal regulations, or there is a requirement for the State Agency (OKDHS SNP) to have it on file, therefore approval must be granted. To change the policy agreements, seek consultation and approval from OKDHS SNP.
ORGANIZATIONAL AND ADDRESS CHANGES
If personnel, organizational name, or address changes during the year, School Food Authorities (SFA) must complete forms to update current and correct information. For personnel changes, complete the Change of Personnel form (23CD005). If the organization’s name or address changes, SFAs must complete the Vendor Information Change form. Contact OKDHS School Nutrition Programs for required forms.
PUBLIC NOTIFICATION AND OUTREACH
School Food Authorities (SFA) are required to inform households and the public that it is providing reimbursable meals to children. Program notification can be posted on websites and bulletin boards, allowing all low-income children access to free meals or reduced-priced meals. To notify families, SFAs may use telephone and email notification systems. Additionally, SFAs with pricing programs must submit a press release annually to the local media, grassroots organizations, unemployment offices, and church affiliations.
SFAs participating in the School Breakfast Program (SBP) must inform families of the availability of breakfasts. A notification of the availability of breakfast must be provided just prior to or at the beginning of the school year in the informational packets that are sent to each household with free meals and reduced-priced meal applications for the new school year. In addition, SFAs should send reminders regarding the availability of the SBP multiple times throughout the school year. SFAs can provide reminders to children through their public address systems in schools or through means normally used to communicate with the households of enrolled children. Other acceptable outreach activities may include developing or disseminating printed or electronic material to families and school children.
Other notifications include the notice and posting of the local wellness plan and changes, and health inspections. Agency websites and bulletins are good resources for public postings.
Note: If information on USDA Child Nutrition Programs is posted on the SFA’s website, then the USDA approved nondiscrimination statement is required to be posted on the website [as required by USDA FNS Instruction 113-1]. |
NOTE TO THE ADMINSTRATOR (CEO, DIRECTOR, SUPERINTENDENT)
To have a successful school food service program, staff must ensure they have the support of the agency administrators and other school staff (or other agency staff in the case of RCCIs).
For this program, the administrator is known as the School Food Authority (SFA) official. This official is usually the person who can make decisions for the organization, not just the food service program. It may be the Superintendent, a principal, the financial officer, pastor, or board member. This person often has the authority to sign contracts and agreements. This person makes the decision to implement the program and then assigns duties to staff members responsible for each aspect of the program.
Prior to participating in USDA Child Nutrition Programs through OKDHS School Nutrition Programs (SNP), the administrator needs to make informed decisions regarding the program and implementation. The administrator needs to understand how the program may affect other requirements for the agency or school and affect staff in the food service program, the office staff, and faculty. Although food service staff implements program requirements, the administrator is ultimately responsible for the program. In many cases, the program requirements may conflict with other agency or school procedures. If you are receiving funding (other than the federal funding) for the USDA Child Nutrition Programs your organization is operating, federal regulations supersede all other requirements.
OKDHS SNP has concluded from experience that if the administrator is not involved in the program or does not ensure oversight, compliance in the program will not be successful. In many situations, school food service staff have a desire to comply with program requirements but has little support to implement program requirements effectively. Noncompliance can result in added paperwork and corrective action, loss of funds, repayment of funds, or termination of the program.
One observation seen over the years is that the administrator will often make decisions for the school food service staff without consideration of program requirements. Again, noncompliance can result in fiscal action. Gaining an understanding of the program requirements can ensure compliance.
Table 6.1: Things to Remember |
Things to remember: · This is a federal program. Federal programs have rules and regulations that supersede state and local policies. · Documentation is required to support compliance and reimbursement claims. Participating agencies receive funding for following program requirements; therefore, paperwork must support compliance. · When a rule doesn’t make sense, contact OKDHS School Nutrition Programs to discuss the requirement rather than disregard it. · OKDHS School Nutrition Programs provides funding to the schools for following procedures. Failure to comply with regulations may result in a loss of funding or repayment of funds already spent. |
In some agencies, the food service manager and staff can’t do it all. They either do not have the time, experience, or the authority to get it completed. Table 6.2 contains areas often outside of the scope of food services
Table 6.2: Areas Often Outside the Scope of Food Services |
Often outside the scope of food service · Application process/intake records- food service staff may not have time to review applications and update intake or master list. Front office staff may have the data or means. · Local Wellness Policy – Food service staff may not have authority over education and physical education programs and may not have the time to review/evaluate these programs for compliance. · Resource management – Although food service staff may collect money on the service line, they may not have the experience or time to keep financial records for the school food service account. · Procurement – Depending on the size of the agency or school, staff may not have the responsibility of ordering food, products, and equipment for the food service program. Procurement officers need to work with food service staff to order products that comply with food service program. Procurement officers also need to understand federal requirements. For more on procurement requirements see chapter 7. |
Chapter One Resources
The resources listed in table 7.1 are available upon request to Oklahoma Human Services School Nutrition Programs by email at AFS.School.Nutrition.Programs@okdhs.org.
Table 7.1: Chapter One Resources |
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OKDHS School Nutrition Programs various prototype documents (civil rights documents, food safety documents, procurement documents, etc.) |
OKDHS School Nutrition Programs Training Documents and Forms Handout Book for the current school year. |
The resources listed below in table 7.2 are available online.
Table 7.2: Chapter One Online Resources |
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OKDHS School Nutrition Programs: |
USDA National School Lunch Program (NSLP): |
USDA School Breakfast Program (SBP): |
USDA Afterschool Snack Program: |
USDA Special Milk Program (SMP): |
OKDHS School Nutrition Programs Compliance Handbook: https://oklahoma.gov/okdhs/services/cd/schoolnutrhandbook.html |
SCHOOL NUTRITION PROGRAMS
Summary of Reporting Dates and Recordkeeping Requirements
REPORTS TO MAINTAIN AT LOCAL AGENCY or SFA:
DAILY
- Meal Counts (meal rosters, scan cards and tickets)
- Edit Checks
- Food Production Records
- Temperature logs
MONTHLY
- Revenue/Expenditure Records, including income cost and income from nonprogram foods.
- Menus and standardized recipes and supporting documentation
- Food Safety Checklist
- Food Service Program Receipts
ROUTINELY
· Benefit Issuance Document (Application for Free and Reduced Price Meals or Free and Reduced Price Eligibility Document for RCCIs)
· Master List ( for schools)
· Health inspection (min.2x year)
· Nutrition Facts Labels
· CN Labels and Product Information Sheets
· Training Documentation- keep log of participants and material
· Purchasing Bids/Quotations
· Accountability Procedures
· Public and family notification for Civil rights, free and reduced price programs and local wellness, and breakfast program
· Afterschool Snack checklist- if applicable, must be complete first 4 weeks of school year and 2nd half of the end year.
· Local Wellness and HACCP plans: must be available, followed and updated
ANNUALLY (review and revise as necessary)
- Food Safety Plan (HACCP)- staff training
- Local Wellness Plan- local wellness official to evaluate and update
- Procurement Policy and documentation
- Civil Rights Policy- annual training required
- Civil Rights worksheet
- Income Applications
- Verification (complete by November 15th)-both schools and RCCIs
- Multiple Site Reviews of Counting and Claiming Procedures (for multiple sites)
- Public Release to media- agencies that provide household applications- prior to school year
- Contract, Policies, and Agreements
- Attendance Factor for October
REPORTS TO SUBMIT TO OKDHS (always keep a copy):
MONTHLY
- Reimbursement Claim (10th day following reporting month)
ANNUALLY
- Program Application or Information Update forms (due June 1)
- FSMC Contract or Addendum, Catering/Vendor Contract (if applicable)
- Verification Reports (Complete by Nov 15, due by Nov 30) for both RCCIs and Schools
· Multiple Site Review for SFAs with multiple school sites (due Feb.15)
· Health Inspections report (Sept 1)
· Attendance Factor Calculation Sheet (November 30)
· Price Equity Worksheet (November 30)
AS NEEDED
· Corrective Action Plan as a response to an Administrative Review, Procurement Review, and other administrative findings.
· FSMC Invitation to Bid/Request or Request for Proposal (if applicable)
· Modifications School Nutrition Program policies and procedures as stated in application packet
· Direct certification for SFAs that accept lunch applications (due July 30, Oct 30, Jan 30)
· All other information as requested by USDA or OKDHS
· Change of personnel and organizational changes
· Forms for on-line claiming
REVIEWS AND ON-SITE VISITS
- All paperwork requested for Administrative and Procurement Reviews
List of Permanent Documents
The following is list of permanent documents that should be file separate from records for school years. Permanent documents included:
- School Nutrition Programs Agreement.
- Application for Participation (renewed annually)
- Civil Rights Pre-award
- Free and Reduced Price Policy Statement (for pricing schools), or the Nonpricing Policy Statement (for nonpricing schools and RCCIs)
- Meal Counting and Collection Procedures
- Nonprofit Statement (501(c)3)
- Letter of Accreditation (for private schools), or DHS Residential Child Care Institution License or license from recognized State Agency(for RCCIs)
- Attestation to follow meal patterns
- After School Snack Program Application (if applicable)
- Special Milk Program Application and policy statement (if applicable)
- Written Procedure for Handling Civil Rights Complaints (formally known as the Civil Rights Policy)
- HACCP Plan
- Code of Conduct for Procurement
- Procurement Plan
