Section I. Administrative and Monitoring Process
A. AGREEMENT/SCHEDULE A & POLICY STATEMENT FOR CURRENT YEAR
1) Agreement - A Renewal of the Agreement between the School Food Authority (SFA) and the Arkansas Department of Education (ADE) with Menu Planning Options, is mailed to all school districts in May of each year. The school district’s approved copy of the Renewal of the Agreement should be maintained in the current Child Nutrition files with the Original 2001-02 Agreement Between the SFA and ADE (Word Doc / pdf format)
Schedule A - Changes in the number of schools participating in the lunch, breakfast, and after-school snack programs, as well as changes in meal prices, personnel, and school names or grade levels should be indicated on this form. Please notify this office if there are any changes in Schedule A during the school year.
2) Policy Statement – A Renewal of the Policy Statement for Free and Reduced Price Meals, is mailed to all districts along with the Agreement. An approved copy of the Renewal of the Policy Statement should be maintained in the current Child Nutrition files with the Original 2001- 02 Policy Statement for Free and Reduced Price Meals. The Civil Rights/Section 504 of the Rehabilitation Act of 1973 (Appendix H), Collection Procedure (Appendix J) and the Procurement Procedure (Appendix I) for the school district are considered a part of both the Policy Statement and Agreement, any changes to the original plan and/or procedures need to be submitted to this office for approval before implementation.
B. PROGRAMS ADMINISTERED BY CHILD NUTRITION UNIT, ADE
1) AFTERSCHOOL SNACK PROGRAM
Public Law 105-336, the Child Nutrition Reauthorization Act of 1998 authorized reimbursement for Afterschool Snacks served to children through age 18, when they participate in programs organized to provide after school care. In order to receive reimbursement from USDA, the Afterschool Snack Programs must be operated by a school currently operating a National School Lunch Program. The school(s) must also provide education or enrichment activities for the children participating in the program. If a school(s) within the district decides to participate in the Afterschool Snack Program, call the Child Nutrition Executive Secretary at (501) 324-9502 for the most recent start-up instructions. Afterschool Snacks should not be served and claimed for Reimbursement until all of the required paperwork is completed.
2) BREAKFAST PROGRAM - State Mandate
Ark. Code Ann. 6-18-705 requires schools with more than 20% of students eligible for free or reduced price meals on October 1 of the preceding school year to implement the school breakfast program. One-year waivers may be requested.
3) LUNCH PROGRAM
Public Law 105-394 (1998), the National School Lunch Act of 1946, provides an opportunity for schools to serve lunches to students. Lunches served to students meet at least one-third of the student’s recommended dietary allowance for the day. The school district must have an annual agreement with the Arkansas Department of Education in order to receive reimbursements that subsidize the school lunch program for all students.
To receive free or reduced-priced meals the student’s parent/guardian must submit an income application or receive notice of direct certification of the benefit. Determination of the payment status of a student also applies to the breakfast and/or afterschool snack program.
4) SPECIAL MILK PROGRAM
The Special Milk Program, is only available for schools without lunch or breakfast and to students in split session kindergartens who do not have access to lunch or breakfast. The special milk program provides reimbursement to subsidize the cost of one-half pint of milk for paid students and provides reimbursement for the average cost of a half pint of milk for a student eligible for free milk.
5) REGULAR SUMMER FEEDING OR EXTENDED SESSIONS OF SCHOOL PROGRAMS
a) Summer Feeding Programs - Schools can serve breakfasts, lunches and after school snacks under their current School Food Authority Agreement with the Arkansas Department of Education during the summer. The same regulations and records are required during the summer as during the regular school term. Reimbursement rates for summer meals served during the month of June will be the same as the current school year. New reimbursement rates, released during the first week of July for the next school year, will be applicable in July and August. Districts are reminded to use the new claim forms reflecting the new rate changes.
Schools may also participate in the ADE Seamless Summer Program. In order to participate, sites must have 50% or more Free and Reduced Price Eligibles. All students participating at an ADE Seamless Summer Program will eat at no charge, regardless of income status, thus all meals at the site will be claimed at the free reimbursement rate. In this program the district will serve one or two meals per student at no charge, including breakfast, lunch, snack, or supper. However, the District will not claim both lunch and supper meals for a student at the same site on the same day. These sites do not require an educational program, but summer school, remedial or regular education can be part of the ADE SEAMLESS Summer Program. For additional information, refer to Director’s Memo No. IA-03-053.
b) Extended Sessions or School Program Expansion- Students in public or nonprofit, pre-primary classes are eligible to participate in school meal programs if the program is recognized as part of the educational system in the state and if they are conducted in a school having classes of primary or higher grades.
When an educational co-op arranges preschool classes for several schools, the meals may be claimed by the school that operates the classes as part of its educational program. Applications for free and reduced price meals should be maintained at the school operating the Child Nutrition program. Records must be kept to explain Average Daily Attendance (ADA) variances with meal counts when students are counted for ADA in their “home” school.
When a district is not the sponsor or school food authority, but provides contracted meals for programs such as Headstart, summer food service or other non-public school programs, full cost of the meals must be recovered. The full cost must include the portion of salaries and benefits for foodservice director and other staff that contribute to the contracted services as well as any food or supplies used from current CN inventory, trash pick-up, janitorial services, etc. Reimbursement may not be claimed through ADE for these meals.
If your district’s educational programs include students less than one year of age, please contact this office for the infant meal pattern.
Students enrolled in GED programs or literacy classes, which operate during regular school hours, as part of the school’s educational program are eligible to participate in the Child Nutrition Programs. Students enrolled in GED or literacy classes that are not part of the school’s educational program are not eligible for meal benefits.
C. PROGRAMS ADMINISTERED BY ARKANSAS DEPARTMENT OF HUMAN SERVICES
1) COMMODITIES (USDA Donated Foods)
The United States Department of Agriculture (USDA) interprets policies regarding the use and sale of commodities in schools. USDA expects participating schools and institutions to use any donated food or processed end product containing donated food in the preparation of required food items or side dishes of the reimbursable lunch. In addition, they may be used in the preparation of the school breakfast program, afterschool snacks, or a la carte sales.
A la Carte items sold in conjunction with the National School Lunch Program are individual serving items intended to be consumed on the premises. For example, using commodities to prepare hamburgers and buns to be sold in the a la carte line during meal service would be an acceptable use of commodities. Using commodities to bake loaves of bread for sale in the a la carte line or cinnamon rolls for fund raising would not be a proper use of commodities.
Commodities may be used in teaching Family & Consumer Sciences, the Nifty Nutrition With Skill Integration Activities Curricula, and other Child Nutrition Unit, ADE approved nutrition education programs.
Remember that perpetual inventories must be maintained at every location where commodities are received and stored, e.g., at district central warehouse and at each school that receives from the central warehouse.
Commodity inventory and request for basic items are due in the Commodity Office by the 15th of each month.
2) SUMMER FEEDING PROGRAM
School districts who sponsor or provide contract meals in the Arkansas Department of Human Services (DHS) summer feeding program are reminded:
a) National School Lunch or Breakfast Program funds or resources cannot be used to provide meals or operational costs for the DHS summer feeding program. Cost accounting records, to justify meal costs of the DHS program, must be maintained separate from the CN, ADE required records.
b) Unlike the regular school meal programs, the DHS summer feeding program feeds all children ages 1-18 that live in the community or geographic area and wish to participate in the program. Based on regulation changes effective December 1999, school districts that sponsor a summer program may request a waiver to limit the serving site to a specific age group if there is sufficient documentation to justify the exclusion of certain age children. Contact DHS for more information regarding this change
c) The local school district is responsible for any expenses incurred for litigation regarding the operation of the DHS summer feeding program.
D. MONITORING
1) School District Responsibility
a) All school districts are required to complete for the NSLP and SBP
i) Edit Check #1 (Excel worksheet / pdf format) – Compares the maximum number of students eligible for free and reduced-price meals with the number of free and reduced-price meals served daily. The number of free and reduced-price meals cannot exceed the number of free eligibles and reduced-price eligibles. See Sample Edit Check #1 Daily Record Form and Cash Management Worksheet (Excel worksheet / pdf format) in the Appendices.
ii) Edit Check #2 (Excel worksheet / pdf format) – Compares an attendance adjusted number of free and reduced-price eligible students to the number of meals claimed for the month. See Sample Edit Check #2 Form in the Appendices.
iii) On-site Review - Districts with more than one school are required to make an on-site review by February 1st to monitor the lunch counting and claiming system for each school in the district. See On-site Review Form in the Appendices.
b) All school districts participating in the Afterschool Snack Program:
i) Each afterschool care program must be reviewed by the school food authority two-times per year. The school food authority must make the first review during the first four weeks of snack service each school year.
ii) The reviews must assess each site’s compliance with counting and claiming.
iii) The on-site review form used for NSLP and SBP may be adapted for the site review.
IF YOUR SCHOOL DISTRICT IS NOT PARTICIPATING IN THE AFTERSCHOOL SNACK PROGRAM AND YOU ARE PROVIDING SNACKS, THE COST OF THE SNACKS MUST BE FUNDED BY SOME OTHER SOURCE THAN FOODSERVICE FUNDS.
c) All school districts participating in the Seamless Summer Program:
i) The school district will review the meal counting, claiming, and meal pattern compliance for each site within three weeks of the start of operations. The on-site review form used for NSLP and SBP may be adapted for the review.
ii) If the school district has a CRE conducted during the school year, the records for the Seamless Summer Program will be part of the CRE process.
2) State Agency Responsibility
a) Coordinated Review Effort (CRE)
Federal regulations require the state agency to conduct a Coordinated Review Effort (CRE) in every district once every five years. The CRE consists of critical and general areas.
i) Critical Areas
Performance Standard (1) Certification, Counting and Claiming – All free, reduced price and paid lunches claimed for reimbursement are served only to children eligible for free, reduced price and paid lunches, respectively; and counted, recorded, consolidated and reported through a system which consistently yields correct claims.
Performance Standard (2) Meal Components – Lunches claimed for reimbursement within the school food authority contain food items/components as required by program regulations.
ii) General Areas
1. Free and reduced price programs/verification
2. Meal pattern
3. Civil rights
4. On-site review/edit check
5. Reporting/record keeping
b) SCHOOL MEALS INITIATIVE (SMI)
The state agency will conduct a nutrient analysis during the CRE review process. Menus, standardized recipes, production records and nutrient information for prepared products must be available.
E. RECORD RETENTION
USDA requires school food authority records for the school lunch and school breakfast program to be retained for a period of three federal fiscal years after submission of the final Claim for Reimbursement for that year. After September 30, 2003, records for school year 1999-00 and prior years may be discarded unless auditors require the retention of the records for a longer period of time. Refer to the following information before discarding records:
After September 30, 2003, discard records for school year 1999-00 and prior years.
After September 30, 2004, discard records for school year 2000-01 and prior years.
After September 30, 2005, discard records for school year 2001-02 and prior years.
After September 30, 2006, discard records for school year 2002-03 and prior years.
School districts, participating in the Provision 2 option, must retain all base year records until three years after the establishment of a new base year.