Okaloosa County BOCC — February 11, 2013 — 01-0303 Okaloosa Co BOCC — reading text

any child receiving free or reduced-price meals, snacks, or free milk, the LEA will adopt one or more of the counting methods provided in the site information on the Child Nutrition Program (CNP) system or in state or federal policy. . Agrees to accurately account for the number of free, reduced-price, and full-price meals/snacks served or the number of half-pints of free and full-price milk served at the point of service except in the operation of the SSO. A count of meals, snacks, or milk must be made at the point of service. There must be verbal identification of all students unless the child’s picture is displayed and confirmed on a computer screen or identification card. Use of attendance records or other methods of counting meals and/or snacks is not acceptable. To ensure that there is no overt identification of any child receiving free or reduced-price meals, snacks, or free milk, the LEA will adopt one or more of the counting methods provided in the site information on the CNP system or in state or federal policy. DACS-01716 01/12 Page 15 of 26 O. Agrees to allow children eligible for free and reduced-price meals, snacks, or free milk to have the same choice of meals, snacks, or milk, at no additional charge, that is available to children who pay the full price for meals, snacks, or milk. P. Agrees to develop a method that complies with civil rights requirements for the collection and reporting of racial and ethnic data for children applying for free and reduced-price meals, snacks, or free milk. Q. Understands that after failing to comply with regulations in regards to critical areas (ie., Performance Standards | and 2) the following will be implemented: 1. Failing Critical Areas on Original Administrative Review - Zero percentage of future claims will be withheld. A follow-up review will be required. 2. Failing Critical Areas on First Follow-up Administrative Review — 40 percent of future claims will be withheld until the sponsor passes the critical areas. A follow-up review will be required. 3, Failing Critical Areas on Second Follow-up Administrative Review — 60 percent of future claims will be withheld until the sponsor passes the critical areas. A follow-up review will be required. 4, Failing Critical Areas on Third Follow-up Administrative Review ~ 100 percent of future claims will be withheld until the sponsor passes the critical areas. A follow-up review will be required. 5. Failing Critical Areas on Fourth Follow-up Administrative Review — The DACS will have the discretion for terminating the sponsor. COLLECTION/COUNTING METHODS In collecting payments for meals, milk, or snacks, and in distributing tickets, tokens, etc., school officials must ensure that there is no overt identification of recipients of free or reduced-price meals or snacks. Therefore, the distribution and collection for all categories of students must be done in the same location and at the same general time. The same care must be taken to prevent identification when the ticket or token is collected. Any collection system shall be designed to record the exact numbers of full-price, reduced-price, and free meals, snacks, or milk served daily. Recording and retaining these counts is a regulatory requirement. The coding used on the tickets and tokens to develop these counts must not overtly identify the children receiving free and reduced-price benefits. The claim for reimbursement must contain only the number of reimbursable meals, snacks, or milk served during the calendar month. Prior to the submission of a monthly claim for reimbursement, each LEA shall compare each school's daily claim against data that will assist in the identification of errors in the claim for reimbursement. At a minimum, the LEA shall perform two edit checks: (1) compare the number of reimbursable free, reduced-price, and paid lunches served daily to the respective number of eligible and nonparticipating recipients; and (2) compare each school's daily counts of free, reduced-price, and paid lunches to the respective numbers of children in that school currently eligible for free lunches, eligible for reduced-price lunches, and nonparticipants times an attendance factor. Claims may also be compared against other data available to the LEA that adequately meets the objective of identifying lunch counts that exceed the number of lunches served daily to children currently eligible for free and reduced-price lunches and nonparticipants. DACS-01716 01/12 Page 16 of 26 If the prototype edit-check worksheet provided by DACS is not used, the method used must be preapproved by the DACS. OPTIONAL PROVISIONS An LEA must notify the DACS by amending its online agreement during the annual renewal process if it intends to implement an optional provision. Provision 2 Option requires that the school serve meals to participating children at no charge but reduces application burdens to once every four years and simplifies meal counting and claiming procedures by allowing a school to receive meal reimbursement based on claiming percentages. Additional four-year extensions to Provision 2 are possible when certain conditions are met. A school participating in Provision 2 must serve NSLP and/or SBP meals to all participating children at no charge for up to four consecutive years. In return, Provision 2 offers schools a reduction in some administrative burdens associated with the distribution of free and reduced- price meal applications and the determination of household eligibility and eliminates meal counts by type for all but the base year of Provision 2. Households are not required to complete the free and reduced-price application or pay for meals. Provision 2 operates on a four-year cycle. During the first year, known as the base year of Provision 2, there is no change in traditional procedures and administrative burden. The school distributes free and reduced-price meal applications and makes eligibility determinations for participating children; takes daily meal counts by type (free, reduced-price, and paid) at the point of service or approved alternate; reports these counts for claiming meal reimbursement; and receives federal reimbursement based on these counts as it normally does. However, regardless of the children’s free, reduced-price, or paid classification, all children are served meals at no charge. During years two, three, and four of the cycle, known as nonbase years of Provision 2, the school makes no new eligibility determinations and continues to serve all children meals at no charge (this would continue to be the case as long as the school operates under the provision). The school counts only the total number of reimbursable meals served each day, instead of counting meals by type. Reimbursement during these years is determined by applying the percentages of free, reduced-price, and paid meals served during the base year to the total meal count for the claiming period in subsequent years. Federal reimbursement is based on these percentages and the meals are reimbursed at the free, reduced-price, and paid rates. Because all meals are served at no charge to children in Provision 2 schools, the school is no longer receiving payment from households that would normally be paying the reduced price and full price for meals. Therefore, the school must make up the difference between federal reimbursement and meal costs. When the overall nonprofit school food service account activity is insufficient to cover program costs, the school food authority (SFA) of a school participating in Provision 2 must pay the difference from nonfederal sources. A school considering Provision 2 must evaluate whether the savings in administrative costs associated with reducing application burdens and simplifying meal counting and claiming procedures under Provision 2 offset the costs of providing meals to all children at no charge. There is no requirement under Provision 2 that a minimum percentage of children enrolled be eligible for free or reduced-price meals. Provision 2 may be a good alternative for schools in the LEA with a very high percentage of children eligible for free and reduced-price meals. DACS-01716 01/112 Page 17 of 26 Schools may go back to standard procedures at any time but must first notify the DACS. Also, the school may request a four-year extension of Provision 2 if the income level of the school’s population has remained the same or improved only negligibly. Universal Meals Option requires that the school serve meals to participating children at no charge but meals still be claimed according to each child’s classification (free, reduced-price, or paid). Schools may go back to standard procedures at any time but must first notify the DACS, the families, and the general public. INTERNAL CONTROLS OF NSLP, SBP, ASSP, PROVISION 2, AND UNIVERSAL OPTION The authorized signer of the monthly claim for reimbursement shall be responsible for reviewing and analyzing meal, milk, and snack counts to ensure accuracy, as specified in 7 CFR 210.8, governing claims for reimbursement. The LEA acknowledges that failure to submit accurate claims will result in the recovery of an overclaim and may result in the withholding of payments, suspension, or termination of the program, as specified in 7 CFR 210.24. The LEA acknowledges that if failure to submit accurate claims reflects embezzlement, willful misapplication, theft, or fraudulent activity of any funds, assets, or property provided under child nutrition programs, or retains funds, assets, or property for its own use or gain, whether received directly or indirectly from the DACS, the penalties specified in 7 CFR Parts 210.25 and 245.12(a) shall apply. These may include, but are not necessarily limited to, suspension or termination of participation in child nutrition programs and/or fines and imprisonment. Each LEA with more than one school shall perform no fewer than one on-site review of each school under its jurisdiction prior to February | of each school year (see 7 CFR 210.8(a)(1)). Each LEA participating in the ASSP shall perform two site reviews per year (see 7 CFR 210.9(c)), the first of which must be during the first four weeks that the snack program is in operation. RCCI A. In all RCCIs, whether there is parental support or not, the residential child always is considered to be a family of one. Classification (paid, free, or reduced-price) is based on the child's personal-use income. B. The child does not necessarily have zero income. Income from regular part-time jobs, allowances, etc. (i.e., money the child receives for his or her personal use) must be considered. C. The LEA will keep current records of the money-in-hand received by each child. D. Day students in RCCIs must have free or reduced-price meal applications on file if the institution is claiming free or reduced-price meals for the students. If a day student's family income is above the eligibility limit, the institution must claim the student in the paid category. This is done even if the institution does not actually charge the student for the DACS-01716 01/12 Page 18 of 26 meal. E. Verification must be completed on Free and Reduced-Price Meal Applications submitted for day students in RCCls if the LEA is claiming free or reduced-price reimbursement for the students’ meals. SMP An LEA approved for the SMP may, at its option, make free milk available to all eligible children. An LEA electing to serve free milk to eligible children must announce such availability and reflect this in its policies. The LEA agrees to set milk charges for paying children so that the maximum use of reimbursement is made to reduce the charge to the child. An LEA participating in the SMP agrees that in the operation of the SMP, no child shall be discriminated against because of race, color, sex, age, disability, or national origin. The LEA agrees to count milk served at the point of service using