training content review

ladies and gentlemen, thank you for standingby and welcome to the administrative review training general program requirements andspecial milk program conference call. at this time all participants are in a listen-onlymode. later, we will conduct a question and answer period. instructions will be givenat that time. if you should require assistance during today's conference call, please press* followed by zero. and as a reminder, today's conference call is being recorded. i wouldnow like to turn the conference over to your host, mr. eric lai. please go ahead. thankyou, and hi, everyone and welcome to today's administrative review training webinar. myname is eric lai and i'm with the child nutrition division at usda's food and nutrition service,and also the school meals administrative review

reinvention team, or smarrt. i'm joined heretoday by heather hopwood, who also is on the smarrt team. today's webinar will focus onthe monitoring areas we didn't have time to cover during our in-person training sessions.the topics we'll be covering today are listed on the screen. they are: sfa on-site monitoring,water, outreach for the school breakfast program and the summer food service program, the specialmilk program, and competitive food services. these areas fall under the general programcompliance section of the guidance, with the exception of special milk, which falls underother federal program reviews. this webinar is a supplemental resource to the administrativereview guidance manual, which we will assume that today's audience has already reviewed.for each of these areas that we address today

we will cover the goals of monitoring thatarea during the administrative review, the review procedures, technical assistance, andcorrective action requirements and whether any fiscal action is required for non-compliance.just as a note, you can access the slides for this presentation in the upper right handcorner of your screen, there's a little hand out icon that you can click, and from thereyou can download the slides for this presentation. now, before we get started we want to takea quick poll of the audience. we know that this webinar, as i mentioned, is a supplementalresource for the guidance manual and we're expecting that all of you will have some understandingof the material in that guidance and also an understanding of the school meals programrequirements as a whole. this past spring

the food and nutrition service agency hostedfive national trainings on the new administrative review process, and we thought it would behelpful and interesting to see how many of you had the opportunity to participate inone of these national trainings. so we'll switch the screen over really quick to thepoll and let you share your responses. so go ahead and click "yes," or, "no, but you'vereviewed the guidance manual." all right, so it looks like most folks onthe call did get a chance to attend our in-person training, which is fantastic. and for thoseof you who haven't had that opportunity, we hope that you've at least had a chance toeither read the guidance or you're planning on reading the guidance soon, as that's reallyyour go-to resource for learning more about

the administrative review process. all right,so with that done let's move on with our slides, and i'm going to turn this over now to heatherto take us into our next section. heather? thanks, eric. good afternoon, everyone, andthanks, again, for joining us for the first of a series of webinars that we're offeringto complement the in-person trainings. let's begin with today's first topic, the sfa on-sitemonitoring. within the administrative review process the sfa's on-site monitoring is reviewedunder the general program compliance section, and this is section v of the administrativereview guidance manual. the regulations require sfas to establish internal controls that ensurethe accuracy of lunch counts before submitting monthly claims for reimbursement. the internalcontrols must include an on-site review of

the lunch counting and claiming system usedby each sfa school that's approved to participate in the national school lunch program. sfaswith only one school are not required to conduct on-site reviews. however, fns highly encouragesthose sfas to conduct a self-assessment in the form of an on-site review to ensure integrityand accountability of the program. each sfa with more than one school has to perform atleast on-site review by february 1st of each year. the goal or purpose of monitoring thesfas on-site monitoring requirements is to ensure that the sfa is conducting their self-assessmentof their own counting and claiming practices and to make sure that the self-assessmentis completed and documented by february 1st each year. the administrative review formquestions that are related to this sfa on-site

monitoring requirement are questions 900 to902 on the off-site assessment tool, and question 903 on the on-site assessment tool. so we'lljust take a minute and look at these questions now. as you can see on the slide, the off-siteassessment tool questions assess whether the sfa monitors the lunch counting and claimingsystem in each site by february 1st, and if the sfa did not meet the february 1st deadlinewas an extension requested, approved, and then the activities completed by the extendeddeadline. the questions also identify if findings have corrective actions and if correctiveactions sufficiently addresses the problems, and if a follow-up is conducted within 45days to validate that corrective action was implemented. if an administrative review ofthe sfa is conducted before february 1st the

sfa may not have completed their on-site monitoringreviews, and in this case the reviewer should determine whether the sfa is on track to meetingthe february 1st deadline. if not, then the reviewer should review the sfa's on-site monitoringactivity from the prior school year to determine whether the sfa effectively schedules theiron-site monitoring to meet the february 1st deadline, or if the problem is more of a trend.if the administrative review of the sfa is conducted after february 1st, the reviewershould examine only the documentation for the current program year's activities anddetermine if the sfa completed their on-site monitoring and documentation by february 1st,or by the approved extended deadline. if the deadline was not met, then the reviewer should,again, examine the prior year's on-site monitoring

documentation to determine if this is a trendor just a one-time occurrence. during the on-site review procedures of the administrativereview, the reviewer must complete the off-site assessment tool if it wasn't completed duringthe off-site review procedures, follow up with the sfa staff if the off-site assessmenttool shows potential problems in meeting the on-site monitoring requirements, and interviewsfa staff to determine if the on-site monitoring requirements are fully understood and whetherthe sfa is in compliance with the requirements. the reviewer should review any documentationavailable on-site and complete question 903 on the on-site assessment tool. question 903addresses the following: were areas requiring corrective action identified and was correctiveaction completed within 45 days? and does

the sfa's documentation indicate that correctiveaction was successful? to answer these questions the reviewer must have completed the questionswe just talked about on the off-site assessment tool, questions 900 to 902. the intent ofthis webinar is not to cover all the regulatory requirements that an sfa must follow, so ifyou want more information about this requirement you can find it in the code of federal regulations,section 210.18. and also we have a policy memo, sp 14-2011, referenced on the slidehere that offers additional guidance materials and technical assistance. it also includesa prototype check list that sfas can use to conduct their on-site monitoring. so whendeficiencies are identified by a reviewer, the state agency must provide technical assistance,address any deficiencies through corrective

action, record deficiencies on the on-siteassessment tool, and include deficiencies in any subsequent corrective actions in thecorrective action plan that's provided to the sfa at the exit conference at the endof the administrative review. corrective action is considered appropriate and sufficient whenthe action permanently corrects the deficiency and brings the sfa into compliance. the reviewershould determine the appropriate corrective action, but some examples may include thesfa requesting an extension through the state agency from the regional office to completereviews in the current school year if the reviewer finds that activities are not ontrack to be completed by february 1st; developing procedures and a schedule for conducting theon-site reviews if they're not completed by

deadlines; and/or training the sfa staff sothat they're familiar with and understand their on-site monitoring requirements. aswe mentioned earlier, on-site monitoring is part of the general program compliance areaof the administrative review and due to this fiscal action is not required. however, fnsencourages state agencies to consider withholding program payments in whole or in part to anysfa for repeated or egregious violations that are not corrected. and you can find some additionalinformation on withholding program payments in the fiscal action module of the administrativereview guidance manual. there's a section on withholding payments. so that's it forsfa on-site monitoring. does anybody have any questions on this monitoring area? and,ladies and gentlemen, if you would like to

ask a question at this time, please press* 1 on your phone. our next question is from liz solomon, andshe's with the ohio department of education. please go ahead. hi there. i noticed on question900 that there was just a space after the question. are we supposed to comment in thatsection? yes. sorry about that. i had to paste a few things together that spanned pages,and i think i accidently cut out the word "comments" from the top of that box. okay,thank you. sure. we'll make sure that on the form it says "comments" there, which i'm prettysure it does. and what are you looking for there, besides what the questions ask? i guessjust a brief summary of the sfa on-site monitoring and how they make sure that their countingand claiming meets requirements, just a sentence

or two.okay, thank you. sure. our next question comes from regina madrid, and she's with the studentnutrition bureau. yes, i joined a little late, so i may have missed some of the beginningpart of the discussion, but i want to make sure i have this right, each sfa is requiredto complete the on-site monitoring form and send it the state agency by february 1st.is that correct? they have to document that they've performed an on-site visit to eachof their schools to ensure the accuracy of their meal counting and claiming systems.so they can document it in different ways. we provide a prototype check list in the memothat was referenced on one of the slides that ... and so the state agency would, duringthe review, complete the on-site and off-site

assessment tools in coordination with thesfa, and part of it would be reviewing that sfa's documentation to show that they've donetheir on-site reviews. okay, perfect. thank you. sure.and so what is it that's due to ... by february 1st? well, you just need to make sure thatthey've completed their reviews by february 1st, so i'm sure some states may have theirown forms, or you may have them submit that check list, or some other type of documentationto show that they've done it. okay, thank you. sure. and we have a question from barbarasimmons, and she is with the oklahoma department of education. please go ahead. we have hadour question answered. you answered our question. thank you. and there are no further questionsin queue at this time. okay, we'll go ahead

and move on to the next topic then, and i'llturn it back over to eric to talk about the water requirements. all right, thank you,heather. moving on to water, the healthy hunger-free kids act of 2010 established a requirementfor making water available at no charge to children in the national school lunch program.and this in turn meant that compliance under this requirement would be assessed duringthe administrative review process. one second. i'm trying to get this slide to stay still.all right, so within the administrative review process water is reviewed under the generalprogram compliance section, which is section v of the administrative review guidance manual.now, as it is mentioned, the law requires water to be available during lunch. duringbreakfast the availability of water is encouraged

as well. as part of general program compliancethe goal and purpose of monitoring water requirements under the school meal programs is to ensurethat children have access to water during the lunch service. the question pertainingto the water requirement can be found in question 1300 of the on-site assessment tool. duringthe day of review's lunch meal service observation the reviewer must determine whether free,potable water is available at each site selected for review. now, while on-site at the reviewedschool the reviewers must ensure that the school has offered potable water to studentsduring that lunch meal period. some examples of how that water may be offered to studentsinclude: offering water pitchers and cups at lunch tables, providing access to a waterfountain adjacent to where meals are served,

and/or providing access to a faucet that allowsstudents to fill their own bottles or cups with drinking water. any school that doesnot make free water available or restrict access during the lunch meal period, is outof compliance, and i'll discuss what that means in a moment. the intent of this webinar,again, is not to cover the regulatory requirements that sfa must follow, but if you do need moreinformation about these requirements please refer to the fns policy memo sp 28-2011, "childnutrition reauthorization 2010: water availability during national school lunch program mealservice." now, in terms of technical systems and corrective action, when deficiencies areidentified by the reviewer, meaning the school does not make free water available or it restrictsaccess during the lunch meal period, the state

agency must provide technical assistance,address the deficiency through corrective actions, record all deficiencies in the on-siteassessment tool, and include the deficiencies and corrective actions in the corrective actionplan provided to the sfa at the exit conference. corrective action is considered appropriateand sufficient when the action permanently corrects the deficiency and brings the sfainto compliance. now, in terms of fiscal action, as we've discussed a little bit already, wateris part of the general program compliance section, and again, under that section fiscalaction is not required. but that being said, fns does encourage state agencies to considerwithholding program payments in whole or in part, to any school food authority for repeatedor egregious violations that are not corrected.

now, for additional information on withholdingprogram payments, please refer to the module on withholding payments in section viii ofthe administrative review guidance manual. and that's it for water. let's see if anyof you have questions on this area. again if you have questions, please press *1. andwe have a question from andrew mccloskey with tennessee department. i've always had a questionabout what is "readily available," because i was in a school earlier this year and ithad a huge cafeteria, and when the pre-k and k kids came in they were forced to sit onone end of the cafeteria and i walked it off and the water fountain was over 100 feet awayand it was an adult water fountain that none of those kids could have reached up and gotwater out of anyway. so could you help define

what "readily available" means?well, in our guidance manual we don't provide a specific definition in terms of a specificdistance or anything like that. we really just encourage you as reviewers to use yourbest judgment. this is a requirement that has been carried over from the cre process,so a lot of this, i think, again, comes down to judgment and then also just your best assessmentbased on what you've done historically and then what you see in the school. and there'ssome discretion and latitude that you have in terms of interpreting "readily available"and how that applies in a school. does that help, andrew? yes. when i was there i wroteunder ta that they need to provide future water in cups, but i was just wondering ifwe go back for a follow up and it's the same

situation if it would be time for fiscal action.yeah. because the water fountain was unusable by the pre-k and k kids. right. so it soundslike, at least for that segment of the population it wasn't "readily accessible." right. yes,we just encourage you to use your best judgment, and it sounds like you provided some technicalassistance, so yes, but you could think about withholding payments if it's a continued problem.ok, thank you. sure. any other questions on water? and we have a question from louisecasillas with california. i'm wondering about water availability on field trips. must theyprovide water? that's a good question. we'll look into that, and we'll get back to youon that through a future q&a. because i don't know, of course the lunch meal period requirement,i'm not sure to what extent that applies to

field trips, but we'll look into that foryou. thank you. thanks. and we have a question from brenda hildebrand with the usda. well,actually, i want to do a few clarifications. water is not required on a field trip. it'sencouraged. and it's in the memo that went out that explains about potable water. yes,it says that, "field trips may be exempted from the water requirement." yes, yes, correct.and the other thing is, regina ... as far as the fsa conducting an on-site review ofall their sites to determine ... that is a form that you provide to them with the memoand ... the school district level of the one who does the monitoring in the central office,and you would look at that when you do your on-site reviews. you don't have to have ... . andi do have a question on water, the question

is ... location. now that is just for theones that you review, because it just ..., for example, if you went into a ... and you only... one out of ten, you ... . yes, this part of the review is conducted during the on-site,so it would only be at the schools that are selected for review. is that the question?yes. the question was kind of open-ended when you say at each ..., i guess it says the guidanceat the ..., right? right, so it would be at the schools selected for review. okay, thankyou. and there are no further questions in queue at this time. okay. great, thank you.all right, i'll turn it back over to heather for our next section. our next topic is outreachfor the school breakfast program and the summer food service program. as a way to increaseparticipation and reach children in need,

section 112 of the healthy hunger-free kidsact required sfas participating in the national school lunch program to cooperate with participatingsummer food service program institutions to distribute materials to inform families ofthe availability and the location of summer food service and school breakfast meals. aspart of the general program compliance the goal of monitoring the sfa's school breakfastprogram and summer food service program outreach is to determine if an sfa conducts the requiredoutreach activities to increase participation in the school breakfast program and the summerfood service program. the administrative review form questions related to the outreach requirementare questions 1600 and 1601 in the off-site assessment tool, and question 1602 on theon-site assessment tool. the materials and

documentation of the sfas' outreach activitiesmust be reviewed for the current school year to determine if their efforts are consistentwith program requirements. this is an area where the reviewer may monitor the area entirelyoff-site with no additional field work. so let's take a closer look at what the reviewermust consider. first, we'll take a look at question 1600, which asks about the schoolbreakfast program. for the school breakfast program the reviewer must determine if theinformation provided by the sfa through the off-site assessment tool and any supportingdocumentation indicates that the sfa conducted the required school breakfast program outreach,and that includes schools participating in the school breakfast program must inform familiesof the availability of breakfast meals at

the beginning of the school year via the informationalpackets that are sent to each household with free and reduced-price meal applications.in addition, schools should send reminders regarding the availability of the school breakfastprogram multiple times throughout the school year. if the school has not done either ofthese, they're out of compliance with this requirement. so we'll talk about how to addressnon-compliance in just a few slides. so, for the summer food service program, question1601 asks about the outreach efforts for summer food service. and like the breakfast outreach,the reviewer must determine if the information provided by the sfa indicates that the sfaconducted the required summer food service outreach. fns requires sfas to conduct outreachbefore the end of the school year to ensure

that eligible families are informed of theavailability and location of summer food service program meals. if the summer food serviceprogram is administered by a different state agency, the two state agencies must work cooperativelyto inform families of the availability and location of summer food service program meals.if the school has not completed this, they are out of compliance with this requirement.for school breakfast and summer food service outreach, some acceptable outreach methodsinclude providing outreach to children through public address systems, or through means normallyused to communicate with the households of enrolled children, or by developing or disseminatingprinted or electronic materials to families and school children. question 1602 of theon-site assessment tool addresses both school

breakfast and summer food service programs.it summarizes the off-site work into one question. and if the information is collected off-siteto the satisfaction of the reviewer, no additional on-site field work is necessary. if you needmore information about these requirements, please reference the two memos listed on thisslide, sp 15-2011 and sp 40-2011. when deficiencies are identified by the reviewer, meaning thatthe sfa has not conducted the school breakfast or summer food service program outreach accordingto the requirements, like other areas, the state agency must provide technical assistance,address any deficiencies through corrective action, record all deficiencies on the off-siteassessment tool, and include deficiencies and corrective actions in the corrective actionplan that's provided to the sfa at the exit

conference. and again, corrective action isconsidered appropriate and sufficient when it permanently corrects the problem and bringsthe sfa into compliance. with the other areas that we've talked today, school breakfastand summer food service program outreach is part of the general program compliance requirementsand fiscal action isn't required. but again if you find repeat or egregious violationsthen fns encourages you to consider withholding program payments. and that's it for the schoolbreakfast and summer food service outreach. any questions on this area? again, for questionspress *1. we do have a question coming from the line of jacqueline quarry. please go ahead.your line is open. i'm sorry about that. i'm just wondering asfar as summer food or the outreach, if we

are reviewing a school toward the beginningof the school year would it be acceptable to look at their plans for providing outreachlater on in the school year, or could we look at the previous year's efforts? i would sayif you don't have anything to look at for the current year, then looking at what theyplan to do and what they did the previous year would be a good way to assess compliance.that would make sense. thank you. sure. there are no further questions.okay. i'll turn it back over to eric, and we'll talk about the next topic, which isthe special milk program. alright, thank you, heather. we'll start off again with the nextslide. the special milk program provides milk to children in schools, residential childcareinstitutions, and also eligible camps that

do not participate in other federal childnutrition meal service programs. the special milk program reimburses schools and institutionsfor the milk served to eligible children. now, schools participating in the nationalschool lunch program, or the school breakfast program may also participate in the specialmilk program to provide milk to children in half-day, pre-kindergarten and kindergartenprograms where children do not have access to school meal programs. the intent of thiswebinar is not to cover the regulatory requirements, once again, that an sfa must follow. we areassuming that those participating understand the requirements, but if you need more informationon special milk requirements i encourage you to refer to the regulations in 7 cfr 215.the intent of monitoring the special milk

program is to determine whether the sfa isoperating the program in compliance with the regulatory requirements and in accordancewith a state agency approved agreement. if a school selected for administrative reviewdoes not operate in the special milk program, the state agency does not conduct this portionof the administrative review. the review questions pertaining to the special milk program areincluded in the supplemental form entitled special milk program and administrative reviewform. the reviewer must use this form to complete the special milk program review. now, thequestions within the supplemental special milk program administrative review form maybe completed either off-site through telephone contact or e-mail, or on-site. for each schoolselected for administrative review that operates

in the special milk program the reviewer mustexamine the special milk program documentation for that school. the on-site observation ofthe special milk program is only required if issues are discovered during the documentationreview, or with the milk counting and/or claiming in the national school lunch program or schoolbreakfast program. there is one reference to the special milk review on the administrativereview's on-site assessment tool, and that is in question 2000, and that also must becompleted. what must a reviewer evaluate? as you see on this slide, in order to evaluatethe school's compliance with the special milk program requirements the review must includereviewing the pricing policy, a confirmation that the sfa is operating at the approvedsnp option, it must make sure that counting

and claiming procedures yield accurate claims,and there must be a determination that records are retained for three years or until theresolution of audits. the reviewer must also ensure that the school prices milk in accordancewith fns policy, the school or sfa maintains documentation that supports the number ofmilks it serves daily and claims for reimbursement, that milk orders and delivery records supportthe number of milks that are claimed for reimbursement, and also that the sfa retains records forthree years or until the resolution of audits. a few more items, the reviewer must also ensurethat the purchase price of milk on the most recent claim for reimbursement matches thepurchase price reflected on invoices. the sfa must provide an accurate count of milkserved each month at each school to the state

agency by the established due date for themonthly reimbursement claim. and finally, the sfa transfers the eligibility status ofeach student accurately to the roster. the state agency may look at this by comparingthe point of service milk counts by student or benefit category to the benefit issuanceroster to ensure that students receiving free milk are listed as eligible on the benefitissuance roster. as i mentioned earlier, the on-site observation of the special milk programis only required if issues are discovered during the special milk program documentationreview, or with meal counting and/or claiming of the national school lunch program or schoolbreakfast program. if an on-site review is conducted, the reviewer must verify the informationobtained during the documentation review.

a reviewer must also ensure that the schooltakes a point of service milk count and records milk correctly, and that milk counts by categoryfor the day of review do not vary unreasonably in comparison to the previous five days. andagain, as i mentioned earlier, the reviewer must complete that supplemental special milkprogram and administrative review form. when deficiencies of these requirements are identifiedby the reviewer, the state agency must provide technical assistance, address deficienciesthrough corrective actions, record all deficiencies in the supplemental special milk and administrativereview form, and also question 2000 of the on-site assessment tool, and include deficiencyand corrective action information in the corrective action plan provided to the sfa at the exitconference. now, corrective action is considered

appropriate and sufficient when the actionpermanently corrects the deficiency and brings the sfa into compliance. now, again, the stateagency must take fiscal action for any claim for reimbursement that is not properly payable.fns requires fiscal action for all certification and counting and claiming errors in snp. thestate agency must record counting and claiming errors on form s2, other meal claim errors,and they must record fiscal action on the fiscal action workbook, forms fa1, fa2, andfa3, if necessary. more information on fiscal action procedures can be found in sectionviii of the administrative review guidance manual. and that's it for the special milkprogram. are there any questions on this area? once again, if there are any questions, hit*1. and we do have a question coming from

the line of laurie strickland. please go ahead.yes, we're just curious, if the school is only on special milk, it looks like they willnever get reviewed because they would not be up for an ar because they're not on nationalschool lunch. is that my understanding? yes, that's a question that's come in online too,and we're going to do a webinar with q&as and i think we'll have to address that onethere. okay, thank you. that's a good question, though, yes. and wedo have another question coming from the line of julie maxwell. hi, yes, i had the samequestion, so thank you. okay. any other questions on milk? you have a question coming from theline of sharon welborn. i need to go back to the summer food service and school breakfastoutreach question. is that okay if i digress

to that real quick? sure. the question inthe on-site basically says, it refers them back to the off-site assessment and it saysis the off-site assessment correct. what are the monitors doing on-site to answer the on-sitequestion? let me pull those up real quick. let me get back to that area. i'm pullingup the questions here without going back in the slide. could you just ask the questionone more time now that we have the questions in front of us? sure. i'm looking at the on-sitequestion for the outreach for the school breakfast and summer food service programs, and thequestion itself basically says are the responses from the off-site tool in compliance. andi'm just curious as to what the monitor is doing on-site to answer that question. right.this is an area where if you feel that the

off-site assessment sufficiently gauges theircompliance, you don't have to do any on-site work. but if you have questions after completingthe on-site, maybe when you're on-site you want to see the flier that got sent home orsome other kind of documentation on-site, so you would only be required to do any on-siteactivities if you had some questions after completing the off-site portion. okay, thankyou. sure. thank you. and we do have another question coming from the line of wendy barclay.please go ahead. wendy, your line is open. wendy, do you have your mute button on? ourquestion's been answered. thank you. okay. all right, we have no further questions atthis time. all right, thank you, everybody. now i'm going to turn it back over to heatherto take us through our final topic for this

webinar, which is competitive food services.great. thanks, eric. before i begin, most of you probably know that earlier this yearusda published a proposed rule related to competitive foods, so right now we're currentlyreviewing the public comments that we received in response to that rule and developing animplementing rule. during the webinar we will only be reviewing the current requirementswhich will apply to administrative reviews in the coming school year, in 2013-14. we'llmodify the administrative review process to accommodate any new requirements that mayresult from an implementing rule. competitive foods are defined in the code of federal regulations,210.11 and 220.12, as any food item that is sold in competition to the reimbursable schoolmeal, and includes foods of minimal nutritional

value. foods of minimal nutritional valueare foods that fit into specific categories defined in the competitive food services regulations,and are further categorized in things such as candies, ice water, and chewing gums inappendix b to parts 210 and 220. so for the purposes of this webinar i'm not going togo into the details about the definitions of competitive foods or foods of minimal nutritionalvalue. we're assuming that you have a basic knowledge and understanding of the requirements.but you can reference these sections of the federal regulations if you want more additionalinformation. within the administrative review process competitive foods are reviewed, again,like all these areas, under the general program compliance section, which is section v inyour administrative review guidance manual.

it's prohibited to sell foods of minimal nutritionalvalue in food service areas during meal periods. the term "food service areas" is anywhereschool meals are being served or consumed, including classrooms and multi-purpose roomsthat double as cafeterias during meal periods. this applies to all school meal programs,not just lunch. as part of the general program compliance the goal or purpose of monitoringthe competitive foods requirement is to ensure schools properly restrict the sale of foodsof minimal nutritional value during the meal service. the administrative review form questionsthat relate to competitive foods is question 1100 on the on-site assessment tool. so asyou can see from the question on the slide, the reviewer must, during the day of review'smeal service observation, this includes breakfast

and lunch meal service observations, determineif competitive foods or foods of minimal nutritional value are offered in any area where reimbursablemeals are served and/or consumed during the meal periods. so while on-site and duringthe meal service, the reviewers must ensure that the school does not offer foods of minimalnutritional value as a competitive food item in any area where the meals are served andconsumed. and this doesn't only include the meal service line, but also, as i mentioned,classroom and multi-purpose rooms that might double as cafeterias. vending machines turnedon in areas where reimbursable meals are served or consumed must also be checked for foodsof minimal nutritional value, and at each site selected for review. there are some exceptionsto the requirement, and the exception applies

to foods that fns has exempted from the foodsof minimal nutritional value category. and the exemption means that the foods are nolonger considered foods of minimal nutritional value. exempted foods may be sold as a lacarte competitive foods in food service areas during meal periods. fns maintains a listof exempted foods online. the resource which is called "exemptions" under the competitivefood services regulation is available on the fns partnerweb. reviewers should use the mostcurrent exemption list as a resource when uncertainty exists regarding whether a competitivefood is exempted. as with the other areas we've talked about, when deficiencies areidentified by our reviewer, in this case it means that foods of minimal nutritional valueare sold in the food service area during a

meal period and the state agency must providetechnical assistance, address deficiencies through corrective actions, record deficiencieson the on-site assessment tool, and then include deficiencies and corrective actions in thecorrective action plan that is provided to the sfa at the exit conference. as we've mentioned,corrective action is sufficient when the action permanently corrects the problem and bringsthe sfa into compliance. in instances of non-compliance the state agency must require, at a minimum,that the school no longer sell the items in question during meal services in areas wherereimbursable meals are served and/or consumed. as we've discussed today, competitive foodsis part of the general program compliance area of the administrative review, and sofiscal action is not required. but again,

if you have a repeated problem or willfulnon-compliance, then we encourage you to consider withholding program payments. one thing wejust want to mention too, many states may have more restrictive rules pertaining tocompetitive foods, and withholding federal program payments for violations of state requirementsis not allowable. as i mentioned, the proposed rule related to competitive foods was publishedon february 8th of this year, and the title of that was "national school lunch and schoolbreakfast programs nutrition standards for all food sold in schools," as required bythe healthy hunger-free kids act. we are currently reviewing the almost 250,000 public commentsthat we received in response to the rule, and once an implementing rule is publishedit may impact the monitoring requirements

in this area. and just like any forthcomingpolicy, fns will have to evaluate the administrative review process to determine if any changesare needed, and of course notify state agencies of any modified requirements. and that's itfor competitive food. does anybody have any questions in this area?and, again, at this time, if you'd like to ask a question, please press *1. and we haveandrew mccloskey, and he's with tennessee. please go ahead. yes, we talk about vendingmachines a lot, and i go in a lot of school cafeterias that have coke machines and snackmachines plugged up and running during meal service times. and the only thing that i havebeen told when i go in there is that they tell the kids that they're not allowed togo to them during meal service. now, that

may just be the day we're there, but whatare we discussing when we're talking about working vending machines in a meal servicearea in a situation like that? they really aren't supposed to even be turned on or befunctional. i suppose if it's not possible to turn them off, if they have a staff personthat is there making sure that the students can't access them, but the vending machinesshould really be turned off so that they're not at all accessible to the students.that's the way i understood it. i just wanted to clarify. yes. thank you. sure. and thereare no further questions in queue at this time. okay, does anybody have any questionson anything that we've discussed today? we can open it up to all the topics if thereare any questions before we wrap up. and we

have a question from jill dawson with thestate of alaska. please go ahead. jill dawson, your line is open for a question. sorry, ihad it on mute. i had a question going back to the special milk program. i understandthat the on-site is only required if there are problems, issues discovered during thedocumentation review. does that mean the off-site review? because i didn't see other documentsthat we would be reviewing to make that determination. the other review form for special milk isthe supplemental special milk administrative review form, and that form, let me make surei've got this right, is to be completed either off-site, on the phone, or through e-mail,or you could also complete that form on-site as well. but you can complete that supplementalspecial milk form off-site. okay, so my question

is it states in here that you complete thatform during the on-site review, and so i was just trying to determine what the documentationreview entails, if that was the off-site review form or if there were other documents thatusda is considering for that documentation review. one second. i'm just pulling up theform. in the form itself, on that supplemental review form, there are a number of questionsthat cover documentation. so for example, question four: "does the sfa properly retainall ... records for three years after the final claim for reimbursement for the fiscalyear, or until resolution of any audits?" that's question four from that form. and thenthe reviewer indicates "yes" or "no" and then provides any needed comments. when you'relooking at a documentation review, i would

want to say that you can just find most ofthat material and content in that supplemental form. okay, thank you. sure. you're welcome.thank you. our next question comes from wendy barclay, and she's the washington superintendent.please go ahead. actually, this is angela from washington state. my question has todo with one of the very first slides that was on the on-site monitoring, and the slidewas something to the effect about just picking one site. can you either go back to that slideor explain what that meant? is the state agency only has to visit one site with the specialmilk program? i was a little confused by that. sorry, are you referring to the special milkor are you referring to on-site monitoring? on-site monitoring, one of the very firstslides that we saw. let me say what i think

you might be referring to, and if not letme know. but if the sfa only has one site in the sfa, they're not required to conductthe on-site monitoring. i understand that. we encourage it, but it's not a requirementif there's only one meal service site in the sfa. is that what your question was referringto? no. okay. keep going, scroll another slide or two down, keep going. no, no, that's notit. i'm sorry. i know if the sfa only has one site they don't have to do them, but itwas something else to the effect about visiting only one site that i thought i saw and i didn'tunderstand that. i'm not seeing that slide come up now. all right, well we'll just lookat that again when these slides are published for us to review. okay, they actually arein the handout section. okay, great. up in

the upper right hand corner, it's those threelittle pieces of paper. okay. all right, thank you. yes, if you can find it there and comeback on, we'll try to figure it out for you. okay, thank you. sure. and, if there are anyfurther questions at this time, please press *1. there are no further questions in queue.we have had a couple of questions come in online that we'll go ahead and answer realquick. one is about school breakfast outreach, and the question is: "would it be acceptablefor the school to list the breakfast times on the september menu that goes home to theparents and then on other menus throughout the year, or does the school breakfast programflier have to go out in the beginning of the school year?" and the intent is that a schoolbreakfast flier would go out with the same

materials that families are provided, thefree and reduced price applications. the menu could be used to meet the multiple outreachthroughout the year requirement if the menu is generally a way that the schools communicatewith the households. that might meet that requirement. but the flier should go withthe application materials to the family at the beginning of the year. another questionthat came in that we talked about earlier are the special milk program only sfas, andwe'll get an answer for that and try to include it in the next webinar, which is july 10th,it's going to be q&as, so we'll try to come back with an answer at that one. the nextquestion: "is there any guidance on appropriate pricing of competitive foods? for example,reimbursable items are also a la carte items

but priced lower than the complete unitizedmeal. is that seen as competitive foods, a school competing reimbursable with a la carte?"i haven't seen any guidance on the appropriate pricing of competitive foods, but again, we'lltry to get some more information on that and include it in the q&a webinar. and we do havea question online. okay. and the question is from sharon welborn, and she's with thetexas department of agriculture. hey, you guys, it's sharon. thanks for doing this.my question has to do with the school breakfast and summer food service program outreach.we have many school districts that use online or web-based applications, so the only informationthey may send to the household is a letter to the household. is that the expectationthat you guys have is that it will go with

a letter to the household, because they'renot sending applications to every household. yes, however they would normally transmitthat material, if that's electronically or if it's with the letter letting them knowabout their benefit status, sometime at the beginning of the year, just so the householdis aware that school breakfast is available. does that help? yes, that's great. thank youvery much. sure. we have another question that came in online. "with on-site monitoringfor the sfas, does the sa review the on-site monitoring form for the sites of review, orall the sites in the district?" and you would just be looking at the sites that are selectedfor review, as a sampling to represent the sfas. another question that came in online:"is it acceptable for the breakfast promotion

to just use electronic format, or does ithave to be a hard copy?" again, the intent is to make sure that all of the families inthe sfa are aware that breakfast is available, and i don't know, if that's the standard waythat the school communicates with families and that's the only way that the school communicateswith families, that might be acceptable. even though we are in the electronic age my guessis that not all families access electronics in the same way, and that may exclude a portionof the population. so again, this is another area where you have to exercise your judgmentand determine if the activities that they've conducted have really made all families awareof the availability of school breakfast. and there are no questions on the phone linesat this time. okay, and actually someone wrote

in to answer a question that had been asked.she writes -- thanks, liz solomon: "i believe the a la carte pricing guidelines are includedin the paid lunch equity memo. a la carte foods must generate the same percent in revenueas they cost." so hopefully that helps. thanks, liz. and there are no further questions inqueue. okay, well this concludes our webinar. again, anything that we were not able to answertoday we'll include in one of our upcoming q&a webinars, which are going to take placejuly 10th and july 17th. we want to thank you all very much for participating. we arein the process of updating all of the administrative review materials based on your feedback thatwe received at the in-person trainings. we expect to post a revised set of materialssometime in july. so thank you again for your

participation today, and if you have any additionalquestions after today's webinar you can send them to the following e-mail address and wewill issue answers to the questions in an upcoming webinar. thank you very much. ladiesand gentlemen, that does conclude our conference for today. thank you for your participation.you may now disconnect.