ATTENTION CO-OP DIRECTORS AND CHILD
NUTRITION DIRECTORS
This memorandum provides guidance and
assistance to School Food Authorities (SFAs) by providing a revised On-Site Review form based on United States
Department of Agriculture (USDA) Policy Memo SP 14-2011. In addition to the
review requirements already in place at 7 CFR Part 210.8(a)(1) for an annual
SFA on-site review of the National School Lunch Program (NSLP), the final rule
adds this review requirement for the School Breakfast Program (SBP) at 7 CFR
Part 220.11(d)(1). Every school year (as defined in 7 CFR Part 210.2, July 1 to
June 30), each SFA with more than one school must perform no less than one
on-site review of the meal counting and claiming system and the readily
observable general areas of review identified under 7 CFR 210.18(h) in each
school operating the NSLP and 50% of schools operating the SBP administered by
the SFA.
THE DEADLINE FOR PERFORMING ON-SITE
REVIEWS FOR ALL SCHOOLS IS FEBRUARY 1 EACH YEAR. It is suggested the On-Site Review for
breakfast and lunch be performed as early as possible during the school year to
resolve any corrective action needed for counting and claiming meals as early
in the school year as possible.
If the SFA provides summer meals through
the Seamless Summer Option, an On-Site Review is required at least one time
during summer meal service.
Please see Commissioner’s Memo CNU-17-02:
After School Snack Program: Availability, Requirements and On-site Review Form
(revised) for the On-Site Review Form for the After School Snack Program.
SFAs are required to establish internal
controls which ensure the accuracy of meal counts prior to the submission of
the monthly Claim for Reimbursement. The internal controls must include an
on-site review of the readily observable general areas of review identified
under 7 CFR 210.18(h) and the meal counting and claiming system employed by
each school (as defined in 7 CFR Part 210.2) approved to participate in the
NSLP and at 50% of the schools approved to participate in the SBP within the
jurisdiction of the SFA. While the annual requirement is to complete 50% of the
schools approved to participate in the SBP in the SFA’s jurisdiction, each
school approved to participate in the SBP must be reviewed at least once every
two years.
SFAs with only one school (LEA) are not
required to conduct such On-Site Reviews for the approved school. However, both the Arkansas Department of
Education, Child Nutrition Unit (ADE/CNU) and USDA Food and Nutrition Services
(FNS) highly encourage ALL SFAs to conduct a self-assessment in the form of an
On-Site Review to ensure integrity and accountability of the Child Nutrition
Program.
If the review discloses problems with a school’s (LEA’s) meal
counting and claiming procedures, the SFA must ensure that the school
implements corrective action, and within 45 days of the review, conduct a
follow-up On-Site Review of the effective program(s) to determine that the
corrective action implemented resolved the problems.
Each On-Site Review must ensure the school’s claim is based
on the counting system, as implemented, and yields the actual number of
reimbursable free, reduced price and paid lunches, respectively, served for
each day of operation.
The completed On-Site Review form (and any corrective action
follow up) for each school (LEA) must be kept on file by the SFA for monitoring
purposes. The On-Site Review requirement is monitored by ADE/CNU as part of the
Administrative Review (AR) conducted at each SFA.
If the SFA has completed the On-Site Review prior to the date
of this memo then the prior form will be accepted for the 2016-17 school year
only. All On-Site Reviews completed
after the date of this memo must use the revised form dated 2016–2017. All SFAs with only one serving site but more
than one school (LEA) must complete the On-Site Review form for breakfast and
lunch school year for each school (LEA) prior to February 1, 2017. For example: If one cafeteria serves three
schools (elementary, middle and high school) then three (3) On-Site Reviews
will be required for breakfast and lunch beginning this school year.
Any questions regarding the On-Site Review requirement should
be directed to the Area Specialist assigned for the SFA as indicated on the Specialists
Assignment Map.