State and Local Burden

Attachment T10. Resource Management Risk Indicator Tool

This information is being collected from State agencies, school food authorities, schools. This is a revision of a
currently approved information collection. The Richard B. Russell National School Lunch Act (NSLA) 42
U.S.C. § 1758, as amended, authorizes the National School Lunch Program (NSLP). This information is
required to administer and operate this program in accordance with the NSLA. Under the Privacy Act of
1974, any personally identifying information obtained will be kept private to the extent of the law. According
to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required
to respond to, a collection of information unless it displays a valid OMB control number. The valid OMB
control number for this information collection is 0584-0006. The time required to complete this information
collection is estimated to average 47.5 hours of reporting burden per response. The burden consists of the
time it takes for the State agency to conduct the off-site portion of the review which includes scheduling of
the review and the completion of the Off-site Assessment, Resource Management Risk Indicator, and Site
Selection Tools. Send comments regarding this burden estimate or any other aspect of this collection of
information, including suggestions for reducing this burden, to: U.S. Department of Agriculture, Food and
Nutrition Services, Office of Policy Support, 3101 Park Center Drive, Room 1014, Alexandria, VA 22302,
ATTN: PRA (0584-0006). Do not return the completed form to this address.

OMB #0584-0006
Expiration Date xx/xx/20xx

Resource Management Risk Indicator Tool Instructions
This tool is used to assess risk indicators to determine whether a comprehensive resource management review will be required.
The risk level is based on the responses provided by the SFA and/or interview with the SFA contact. For all resource management
review areas, the State agency has discretion to determine if the Resource Management Review Period will be the SFA’s most
recently completed school year or last audited year. State agencies may choose to review the current school year when assessing
risk under the Paid Lunch Equity and/or Revenue from Nonprogram Foods if sufficient data is available. Refer to the Resource
Management Off-site Assessment Module for additional information regarding the questions. Please note: SA reviewers may not
provide the RM Risk Indicator Tool to an SFA for completion; the Tool must be completed based on the answers and any
additional information provided by the SFA as part of the Off-site Assessment Tool.

The State agency must indicate the time frame it is using (previous school year/last audited school year/current school year) to
review each resource management area underneath the applicable RM review area.  This information should also be noted in the
Off-site Assessment Tool. Please note: the current school year may only be used when reviewing the Paid Lunch Equity and/or
Revenue from Nonprogram Foods. 

Legend (Note: conditional formatting is used for the Fill format in column C (e.g. "Risk Flag" = red, "No Flag" equals light blue)
Risk Level:

If a "Risk Flag " is identified, this indicates the SFA is at risk for noncompliance with the resource
management requirements in this area. The SA must conduct a comprehensive review of each resource
management area in which risk flags are assessed.

= Risk Flag

If "No Flag " is identifed, no comprehensive review is needed of this resource management area.

= No Flag

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Resource Management Risk Indicator Tool
This tool assesses the need for a comprehensive review of the four resource management areas, Maintenance of the Nonprofit School Food Service Account, Paid Lunch Equity, Revenue from Nonprogram foods, and
Indirect Costs. The SA should use the SFA's answers included in the Off-site Assessment Tool and consider any additional clarification provided by the SFA in the Off-site Assessment Tool comments, to complete this
tool using the drop down answer options, as applicable. States may also use other information, such as SFA financial data collected by the State, audits, etc., to validate SFA answers provided in the Off-site
Assessment Tool. If one or more resource management risk indicators is assessed in one of the resource management areas, the SA must conduct a comprehensive review of the resource management area in which
the risk indicator was assessed. Comprehensive reviews must be conducted only in those resource management areas in which a risk indicator is assessed; however, State agencies are encouraged to conduct
comprehensive reviews of any/all sections at any time if there are concerns or questions about the SFA's financial management of the nonprofit school food service account. This tool is for SA use only and should
never be sent to the SFA for completion.

Risk Indicator
Maintenance of the Nonprofit School Food Service Account
Review Period Selected by State agency:
Did the SFA have the ability to accurately track all revenues and expenditures for the nonprofit school food service separately from all
other transactions?

-- SELECT VALUE --

Comments
At the end of the SFA’s RM review period, did the food service have net cash resources that exceeded three months' average
expenditures?

-- SELECT VALUE --

Comments:
Did the SFA transfer funds other than approved indirect costs out of the food service account to support general school district expenses
or non-food service-related activities?

-- SELECT VALUE --

Comments:
Excluding the purchase of equipment using equipment grant funds, if the SFA used food service funds to buy equipment during the school
year under review, did it receive prior approval from the State agency either directly or via the State’s pre-approved equipment list?

-- SELECT VALUE --

Comments:

Did the SFA have any financial findings related to unallowable costs or financial mismanagement in the child nutrition programs on a
previous administrative review or as part of an audit (for example, OIG, Single Audit (previously called A-133 audits), other state audits)
within the past three years?
Comments:

Did the SFA have internal control procedures in place to ensure that only allowable costs were charged to the nonprofit school food
service account?

-- SELECT VALUE --

-- SELECT VALUE --

Comments:
Is a comprehensive review of this area needed?

No flag

Paid Lunch Equity
Review Period Selected by State agency:
Did the SFA use the USDA Paid Lunch Equity Tool or a comparable mechanism to evaluate its need to raise its paid lunch prices?

-- SELECT VALUE --

Comments:
Did the SFA receive a transfer of non-Federal funds into the food service account to reduce or eliminate the need to raise paid lunch
prices?

-- SELECT VALUE --

Comments:
Did the SFA adjust its paid lunch prices for the RM Review Period at the level at or above what was required by the USDA Paid Lunch
Equity tool or comparable mechanism?

-- SELECT VALUE --

Comments:
Is a comprehensive review of this area needed?

No Flag

Revenue from Nonprogram Foods
Review Period Selected by State agency:
With the exception of milk, did the SFA sell Smart Snacks, second entrees, and/or catering (e.g., foods/beverages for school board
meetings; foods for outside entities and programs)?

-- SELECT VALUE --

Comments:
If the SFA provided adult meals for teachers and/or parents, did it obtain full payment from the adults receiving the meals and/or
recover the cost of those meals by some other means (general fund transfer, etc.)?

-- SELECT VALUE --

Comments:
If the SFA charged for adult meals, were the meal prices sufficient to cover the overall cost of the meals in compliance with FNS
Instruction 782-5, Rev. 1?

-- SELECT VALUE --

Comments:
Is a comprehensive review of this area needed?

No Flag

Indirect Costs
Review Period Selected by State agency:
Were indirect costs charged to the SFA’s nonprofit school food service account?

-- SELECT VALUE --

Comments:

Is a comprehensive review of this area needed?

No Flag

If a risk indicator is assessed in any of the four Resource Management review areas, a comprehensive review of that review area must occur. 

Comment Box:

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The Resource Management Risk Indicator Tool must be used to calculate automatically whether a RM comprehensive review is required.
1)   Maintenance of the Nonprofit School Food Service Account
Risk Indicators : The SFA will receive a risk indicator(s) if it:
·         did not have the ability to clearly and accurately track nonprofit school food service revenues and expenses;
·         had more than three months' average operating expenses;
·        transferred funds, other than for approved indirect costs, out of the nonprofit school food service account to support the General Fund and/or other non food service-related expenses;
•

did not receive prior approval from the State agency prior to purchasing equipment costing at or below the SFA's capitalization threshold or $5,000 or above, whichever is lower;

·       did not have sufficient internal controls to ensure that only allowable costs were charged to the nonprofit school food service account.

2)   Paid Lunch Equity
Risk Indicators : The SFA will receive a risk indicator(s) if it:
•     did not use the USDA Paid Lunch Equity Tool or a comparable substitute to evaluate its paid lunch price and charged less than the average weighted average at all sitess;
•

used non-Federal funds to support its paid lunch prices, 

•

did not increase its paid lunch prices if the Paid Lunch Equity Tool indicated an increase in its paid lunch prices was required.

3)   Revenue from Nonprogram Foods
Risk Indicators : The SFA catered meals, sold Smart Snacks (excluding milk), and second meals; did not recoup the cost associated with adult meals; or did not charge their adult meals in
compliance with FNS Instruction 782-5, Rev.1.

4)   Indirect Costs
Risk Indicator :
•         The nonprofit school food service account was charged indirect costs.

September 2017