Attachment N2. On-site Assessment Tool

Attachment N2. On-site Assessment 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.

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

SECTION II: MEAL ACCESS AND REIMBURSEMENT
SCHOOL FOOD AUTHORITY LEVEL
OFF-SITE ASSESSMENT TOOL VALIDATION
In the areas of Certification and Benefit Issuance, Verification, Meal Counting and Claiming,
Civil Rights, Local School Wellness Policy, Smart Snacks, SBP and SFSP Outreach, and Special
Provision Options address discrepancies between a SFA’s responses to specific areas of the
Off-site Assessment Tool and the SFA’s current practices as observed on-site. Explain any
technical assistance provided and/or corrective action required to address discrepancies.
CERTIFICATION AND BENEFIT ISSUANCE
Any Certification or Benefit Issuance Error is a Performance Standard (PS) 1 violation and must
be corrected.
If the SFA is implementing CEP SFA wide skip questions 124-215 and proceed to question 314.
124.

a. Determine if the SFA conducted an independent review of applications according to
FNS requirements.
b. Determine if the SFA completed and submitted the FNS-874 (Local Educational
Agency Second Review of Applications Report) according to FNS requirements.
If NO, explain in the Comments section.

125.

If the SFA is an RCCI without day students, verify that the SFA has the correct eligibility
documentation for each student. Record all discrepancies on the Eligibility Certification
and Benefit Issuance Error Worksheet (SFA-1). Skip questions 126 – 215 and proceed to
question 314.
If the RCCI has day students, proceed with standard certification review as described (see
Certification and Benefit Issuance Module).
If not an RCCI mark N/A and proceed to the next question.

126.

Indicate whether all certifications or a statistically valid sample of certifications are
reviewed. If using a statistically valid sample, indicate the confidence level, the universe,
and the sample.
Based on the selected students (see Certification and Benefit Issuance Module), review
and evaluate eligibility determinations for completeness and accuracy. Indicate whether
the application approval process is implemented correctly. Answer YES if all
applications are approved correctly. If any errors are noted, answer NO and explain in
the Comments section. Record the Count of Reviewed Students by category (even if
doing a 100% review) and all discrepancies on the Eligibility Certification and Benefit

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Issuance Error Worksheet (SFA-1) and/or the Other Eligibility Certification and Benefit
Issuance Error Worksheet (SFA-2).
127.

Determine whether the SFA is using the current year Income Eligibility Guidelines to
process applications for free and reduced price meal benefits.

128.

Determine whether the SFA is using the correct conversion factors when processing
applications that indicate more than one income frequency. Correct conversion factors
are:
weekly – times 52; bi-weekly – times 26; twice per month – 24; and monthly – times 12.

129.

Determine whether households were notified of the student’s eligibility according to
regulations. If NO, explain in the Comments section.

130.

Determine whether denied households were notified of: reason for denial of benefits;
right to appeal; instructions on how to appeal; and statement that household may reapply
at any time during the school year.

131.

Review a minimum of 10 denied applications. Determine whether benefits were denied
correctly. Record students incorrectly denied benefits on the Other Eligibility
Certification and Benefit Issuance Errors Worksheet (SFA-2).

132.

Determine whether the direct certification list utilized by the SFA contains all required
information and is provided by the proper agency. If NO, explain in the Comments
section.

133.

Based on the selected students (see Certification and Benefit Issuance Module), review
and evaluate the direct certification documentation for completeness and accuracy.
Indicate if students directly certified for free meals were certified correctly. Answer YES
if certified correctly. If any errors are noted, answer NO and explain in the Comments
section. Record all discrepancies on the Eligibility Certification and Benefit Issuance
Error Worksheet (SFA-1).

134.

Determine whether the SFA performs direct certification matches with the State agency
according to regulations. If NO, indicate how often matches are conducted by the SFA.

135.

Indicate whether direct certification documentation is kept on file at the SFA. If NO,
explain.

136.

a. Observe and evaluate, where possible, that the benefit issuance document(s) is
safeguarded to ensure that there is no overt identification of free and reduced price
meal eligible students during the meal service or any other time. If NO, explain in the
Comments section.
b. Confirm through observation and dialogue with the SFA that free and reduced price
eligible students are not required to work for their meals. If YES, explain in the
Comments section.

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137.

Based on the selected students (see Certification and Benefit Issuance Module), test the
system of benefit issuance — e.g., tickets, rosters, tokens — by comparing the benefit
issuance documentation to the eligibility determinations. Answer YES if certified
eligibility was transferred correctly. If any errors are noted, answer NO and explain in
the Comments section. Record all discrepancies on the Eligibility Certification and
Benefit Issuance Error Worksheet (SFA-1).

138.

Based on the selected students (see Certification and Benefit Issuance Module),
determine whether there were changes in eligibility as a result of verification, resubmitted
applications, new students, transferred students, or withdrawn students during the review
period. If changes were required and made within the required timeframes, answer YES.
If changes were required and not made within the required timeframes, answer NO and
explain in the Comments section. If there were no changes, select N/A. Record all
discrepancies on the Eligibility Certification and Benefit Issuance Error Worksheet
(SFA-1).

139.

Based on the selected students (see Certification and Benefit Issuance Module),
determine whether the SFA’s manual system documents the changes in a student’s
eligibility/enrollment. If the SFA is utilizing an electronic system, indicate N/A. If NO,
explain in the Comments section. Record all discrepancies on the Eligibility Certification
and Benefit Issuance Error Worksheet (SFA-1).

140.

Based on the selected students (see Certification and Benefit Issuance Module),
determine whether the SFA made timely and accurate updates for direct certification as
applicable. If NO, explain in the Comments section and record all discrepancies on the
Eligibility Certification and Benefit Issuance Error Worksheet (SFA-1).

141.

Based on the selected students (see Certification and Benefit Issuance Module),
determine whether the SFA extends free meal benefits to all students living in households
that have either: been directly certified for SNAP, FDPIR, or TANF; or submitted
applications with case numbers for these programs. If NO, explain in the Comments
section and record all discrepancies on the Eligibility Certification and Benefit Issuance
Error Worksheet (SFA-1). Select N/A if none of the selected students were certified for
free meals through this method.

142.

Based on the selected students (see Certification and Benefit Issuance Module),
determine whether the SFA changed the eligibility category of households requesting a
lower level of benefits and reflected this request on the Benefit Issuance document. If
NO, explain in the Comments section. Select N/A if none of the selected student’s
households requested a lower level of benefits.

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VERIFICATION
207.

Count the number of verified applications on file for the most recently submitted FNS742. Confirm that verified applications on file match the number reported on the most
recently submitted FNS-742 (see Question 200 on Off-site Assessment Tool). Record
any discrepancies in the Comments section.

208.

a. Determine how the SFA conducted confirmation reviews and whether documentation
is available demonstrating that they occurred.
b. If a confirmation review did not validate the initial determination, determine whether
the SFA followed appropriate procedures.
If NO to a. or b., explain in the Comments section.

209.

The Verification Review must be completed according to the following guidelines:
• If the review is scheduled for a timeframe prior to the completion of verification
and the submission of the verification collection report (FNS-742) for the current
year:
 Use the previous year’s verified applications
 Verified students selected in the Certification and Benefit Issuance review
will not count toward the verification review requirements
• If the review is scheduled for a timeframe that falls before the verification
collection report (FNS-742) has been submitted to the State Agency for the
current year, but after verification has been completed by the SFA:
 Use current year verified applications. Verified students selected in the
Certification and Benefit Issuance review can count toward the
verification review requirements.
• If the review is scheduled for a timeframe after the current school year
verification collection has been submitted:
 Use current year verified applications. Verified students selected in the
Certification and Benefit Issuance review can count toward the
verification review requirements.
Select 10% of the verified applications (but not fewer than 3, if available, and no more
than 30 verified applications) to determine whether verification was completed correctly.
If a verified application was selected as part of the Certification and Benefit Issuance
review, the application may contribute toward the 10% verification sample size. Record
all verification errors on the Other Eligibility Certification and Benefit Issuance Errors
Worksheet (SFA-2) unless the student was selected as part of the Certification and
Benefit Issuance review. Record verification errors found for students in the
Certification and Benefit Issuance review on the Eligibility Certification and Benefit
Issuance Error Worksheet (SFA-1). Any other student(s) appearing on the verified
application selected as part of the Certification and Benefit Issuance review will be
recorded on the SFA-2 and require corrective action ONLY. If a verified application is
selected as part of the 10% verification sample and was not part of the Certification and

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Benefit Issuance review, any discrepancies will be recorded on the SFA-2 and require
corrective action ONLY.
a. Determine whether the applications selected for verification were appropriate for the
sample size option used.
b. Determine whether the SFA replaced applications selected for verification, the
replacement was selected based on the same criterion and the replacements were
limited to 5% of the applications selected. If NO, explain in the Comment section.
c. Evaluate whether the post verification determinations for the applications selected for
review were correct.
If NO to a. or b., explain in the Comments section.
210.

Identify whether the SFA directly verified selected applications. If YES, determine
whether requirements were met. If NO, explain in the Comments section.

211.

Determine whether the SFA’s verification notification letter includes the required
information. If NO, explain in the Comments section.

212.

Determine whether the SFA met the follow-up requirements for households failing to
respond to the verification request. If NO, explain in the Comments section.

213.

Determine whether the SFA’s notice of adverse action contained all the required
information, including notification of appeal rights. If NO, explain in the Comments
section.

214.

a. Determine whether the SFA updated the eligibility status on the benefit issuance
document(s) for students whose eligibility changed due to verification according to
regulations. If NO, explain in the Comments section and record discrepancies
according to the instructions under question 209.
b. If a student’s eligibility status changed due to verification, determine whether benefits
were increased no later than 3 calendar days or decreased no later than 10 calendar
days from the final verification decision. If NO, explain in the Comments section.

215.

a. Determine whether the SFA completed verification by November 15th. Answer for
the current school year unless review occurs prior to November 15. In that instance,
answer for the previous school year.
b. If not, indicate whether the SFA was approved by the State agency for an extension
until December 15th. If NO, explain in the Comments section.

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MEAL COUNTING AND CLAIMING
Any Meal Counting and Claiming Error is a Performance Standard (PS) 1 violation and must be
corrected.
314.

Determine whether the SFA is following their approved SA-SFA Agreement/application,
including POS.

315.

If each school submits a Claim for Reimbursement directly to the State, answer no. If the
SFA submits one Claim for Reimbursement for all schools, answer yes and complete
question 316.

316.

a. Record the SFA’s claim and the SA’s validated counts by category for all schools for
the review period on the chart provided.
b. If there are no differences between the SFA’s claim and the SA’s validated counts
for lunch and/or breakfast by category for all schools for the review period, answer
YES. If there are differences between the SFA’s claim and the SA’s validated counts
for lunch and/or breakfast by category for any schools for the review period, answer
NO and explain the problem and determine whether the cause(s) are non-systemic or
systemic.

SECTION IV: RESOURCE MANAGEMENT
SCHOOL FOOD AUTHORITY LEVEL
RESOURCE MANAGMENT
SFAs receiving one or more risk indicators under the Resource Management Risk Indicator Tool will
receive a Resource Management (RM) comprehensive review for each RM area receiving a risk
indicator. See supplemental form, Resource Management Comprehensive Review Form. SAs are
required to provide SFAs technical assistance and/or corrective action for all risk indicators assessed
in the Resource Management Risk Indicator Tool and document any technical assistance/corrective
action provided in the Resource Management Comprehensive Review Form
New SFAs in their first year of operation should not receive a risk assessment. Instead, the SA must
determine on-site if the new SFA has a sound financial accounting system and sufficient procedures
in place to ensure compliance with resource management requirements. The SA must document the
SFA’s resource management processes and procedures and any technical assistance/corrective action
provided in the On-site Assessment Tool.

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SECTION V: GENERAL PROGRAM COMPLIANCE
SCHOOL FOOD AUTHORITY LEVEL
CIVIL RIGHTS
Civil Rights requirements are outlined in FNS Instruction 113-1, Civil Rights Compliance and
Enforcement – Nutrition Programs and Activities, dated November 8, 2005.
809.

a. Determine whether a disproportionate number of the denied applications reviewed in
question 131 were submitted by minority households.
b. If YES, determine whether these applications were denied for any reason other than
the applications being incomplete or the household being ineligible based on income
or other program requirements. If NO, explain in the Comments Section.

810. Determine if the appropriate Program materials use the non-discrimination statement.
Professional Standards
1210. Review employee list for the day of review and verify that the SFA’s information
matches the current (day of review) employee list. If personnel count does not match, list
any employees that are no longer employed with the SFA in the comments. If any new
personnel have been hired, see question 1220.
1211. If the SFA hired a new director on or after July 1, 2015, review hiring information. If a new
director was not hired select NA and proceed to question 1216. If hiring requirements were
not met, explain in the comments section and review any flexibility allowed for LEAs with
less than 500 students.
1212. If a new director was hired, validate that he/she obtained food safety certification within the
last 5 years. If no new director select NA and proceed to 1216.
1213-1215.
Validate the responses on the Off-site Assessment Tool. If school nutrition program staff
have not met annual training requirements at the time, review documentation of
scheduled/planned trainings for the remainder of the school year or next school year if the
State agency allows the SFA the flexibility for training requirements to be met across two
years. Determine if school nutrition program staff is expected to meet annual training
requirements.
1216. Does the SFA training tracking method meet requirements?
a. Describe the frequency (i.e. annually, quarterly, monthly etc.) in which training hours are
being tracked and which mechanism is being used. b. Does the tracking methods contain all
of the required fields?

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1217. The SA must determine if any employees hired between the completion of the Off-site
and On-site Assessment Tools met annual training requirements. If there are
non-compliant employees, list their names, titles/positions, and the number of training
hours currently completed.
1218. Review employee lists and functions and assess whether any other employees outside of the
school nutrition program whose responsibilities include duties related to the operation of the
programs have not yet received applicable training.
FOOD SAFETY, STORAGE, AND BUY AMERICAN
1400. a. Review documentation to determine whether a food safety plan is in place and
complies with the HACCP program criteria found in 7 CFR 210.13(c). Describe any
missing elements in the Comments section. For additional information, refer to
Guidance for School Food Authorities: Developing a Food Safety Program Based on
the Process Approach to HACCP. Principles, United States Department of
Agriculture, Food and Nutrition Service, June 2005.
b. Determine whether a copy of the written food safety plan is available at each school.
If NO, explain in the Comments section.
1401. If conducted as part of the Administrative Review, determine whether the SFA has any
contracted or self-operated warehouses and, if so, the SA must determine whether all foods
(commercial and USDA) are being stored properly. If no, explain in the comments section.
1402. Determine if agricultural food commodities and products are domestic as required by the Buy
American provision in 7 CFR 210.21(d). On-site reviews will be conducted as follows:
•

The number of agricultural food components to review will be determined based on the SFA
storage facility practices used:
o if the majority of agricultural food components used are located at individual schools
only, the SA will review at each reviewed school 2-3 items in each agricultural food
component category below;
o if the majority of agricultural food components used are located at an SFA’s off-site
storage facility only, the SA will review at the SFA’s off-site storage facility 2-3
items in each agricultural food component category below; or
o if agricultural food components used are located at a combination of places both onsite at schools and at the SFA’s off-site storage facilities, the SA will review 1-2
items in each agricultural food components category below for each school reviewed
and 1-2 items in each agricultural food component category below at the SFA’s offsite storage facilities.

•

Agriculture Food Component categories include:
o Bakery, pasta, and miscellaneous (grain components delivered ready to serve; or
wheat flour, cornmeal, or other grain flours, used to prepare grain components, pasta,
bread, etc.)
o Canned fruit and fruit juice

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o
o
o
o
o
•

Canned vegetables and vegetable juice
Frozen fruit and fruit juice
Frozen vegetables and vegetables juice
Frozen meat/entrée items
Refrigerated foods (produce; dairy such as cheese, yogurt, milk; and food
components that may be thawing for future meal service, etc.)

If any noncompliant food items are observed list in the comments section.

1403. Determine whether observations indicate any violations of the Buy American
provision as found in 7 CFR 210.21(d) either during review of foods on-site at reviewed
schools or at off-site storage facilities as applicable. If there are violations, obtain
documentation to determine if an exception was granted by the SFA because:
• The agricultural food component is not produced or manufactured in the U.S. in
sufficient and reasonably available quantities of a satisfactory quality; or
• Competitive bids reveal the costs of domestic agricultural food components are
significantly higher than the non-domestic ones.
Identify the noncompliant food in the comments section. Inform SA staff conducting the
procurement review of this finding in order for them to identify if the Buy American
provision is in the SFA’s solicitation and contract documents. Note: documented USDA
Foods are presumed to be domestic; however, processed end products that contain USDA
Foods must meet the over 51% domestic requirement, by weight or volume.

REPORTING AND RECORDKEEPING
1500. Determine whether the SFA prepares and submits reports as required. If NO, explain in
the Comments section. (See 7 CFR 210.20 for reporting and recordkeeping requirements
and Module: Reporting and Recordkeeping.)
1501. Determine whether the SFA is retaining the appropriate records regarding program
management for 3 years after the final Claim for Reimbursement for the fiscal year or
until resolution of any audits. If NO, explain on in the Comments section (see Module:
Reporting and Recordkeeping.

SECTION VII: SPECIAL PROVISION OPTIONS
SCHOOL FOOD AUTHORITY LEVEL*
*NOTE: Some of these activities may be assessed at the site level. If some or any of these
activities occur at the site level, record the activities below in the School Food Authority Level
area.
2113. Obtain the total meal counts and applicable claiming percentages and/or funding levels
established during the Base Year and ensure that they were calculated correctly (i.e.,
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appropriate rounding was used; SFA/site meal counting and claiming system results in
reliable daily and monthly total meal counts and meal counts by category, consolidating
meal counting and claiming data appropriately). The SA must ensure claiming
percentages and/or funding levels established during the Base Year were calculated
correctly for, at a minimum, the Review Period and Month of On-site Review. Record
any errors for NSLP and SBP separately on the SFA-1A.
2114. Obtain the total meal counts and applicable claiming percentages and/or funding levels
and ensure they equal what was established in the Base Year calculations or latest
approval for Community Eligibility Provision. (If adjustments were made to the funding
levels based on enrollment, number of operating days, and/or inflation, reviewer must
ensure that the adjustment was calculated correctly as specified in 7 CFR 245.9 d (4).
The SA must ensure claiming percentages and/or funding levels established during the
Base Year are being applied correctly to, at a minimum, the Review Period and Month of
On-Site Review. If errors are identified, every Non-Base Year SPO site must show
documentation that the correct claiming percentages and/or funding levels are applied
correctly for every closed claim period from the current SY. Record any errors for NSLP
and SBP separately on the SFA-1A.
2115. The SA must validate the accuracy of Identified Student Percentage (ISP) and the
claiming percentages calculated for free and paid meals (complete the SFA-2A). The SA
will obtain the certification documentation used to determine the ISP and claiming
percentages that were submitted for the latest approval to operate CEP. The certification
documentation may include direct certification lists, documentation for extension of
eligibility, and lists from homeless/migrant liaisons). The certification documentation
review must include obtaining the list of all students used to derive the free claiming
percentage and selecting 10 student names at random to verify that those students can be
found on source documentation that certifies free eligibility. If more than 20% of the 10
randomly selected students cannot be properly verified on source documentation, the
SFA must be required, as part of their corrective action plan, to provide source
documentation for every student used to establish the free claiming percentage. Record
any errors for NSLP and SBP separately on SFA-2A.
2116. The SA should verify whether the SFA has distributed Free and Reduced Price meal
applications for sites operating Provision 2 or3 in Non-Base Years. If so, ascertain
whether the SFA’s distribution of the applications and use of the data obtained is
appropriate. List the reasoning in the comments section. If the SFA has distributed meal
applications in a Provision 2 or 3 Non-Base Year, they must use the information provided
by families to develop claiming percentages (by conducting an entire new Base Year), or
return to standard counting and claiming procedures. The only exception would be for a
school taking new applications in the last year of a cycle in order to develop
socioeconomic data of the school's population for purposes of requesting an extension.
2117. For Provision 1 sites only: The SA should review the meal counting and claiming system
to ensure that meal counts are recording the number of meals served by type.

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SECTION II: MEAL ACCESS AND REIMBURSEMENT
SCHOOL LEVEL
MEAL COUNTING AND CLAIMING
Any Meal Counting and Claiming error is a Performance Standard (PS) 1 violation and must be
corrected.
School Level – Day of Review
317.

a. Observe and indicate whether the meal counting system as implemented prevents
overt identification of students receiving free or reduced–price meals. If NO, explain
in the Comments section.
b. Observe and indicate whether the school has separate dining areas, meal service
times, or serving lines based on a student’s eligibility status. If YES, explain in the
Comments section.
c. Observe and indicate whether the school limits choice of reimbursable meals based
on a student’s eligibility status. If YES, explain in the Comments section.
d. Observe and indicate whether the school uses different mediums of exchange based
on a student’s eligibility status. If YES, explain in the Comments section.

318.

Observe and indicate whether an accurate count of reimbursable meals by eligibility
category is taken at the point of service or an approved alternate. FNS suggests that
reviewers observe 5% to 25% of meals served on each reimbursable meal service line.
To answer YES, the system must be based on an actual count of students served by
category and must consistently yield correct results. A NO answer is needed when an
accurate count of meals by category is not observed.
If NO, describe the problem and determine whether the problem is nonsystemic or
systemic. If second meals or meals served to ineligibles were observed, list the total in
the comments section. Combine this total with errors identified in #321 and record in S1, Line 10.

319.

a. If an electronic point of service system is used, determine whether excessive
overrides to the meal counting system occurred during the meal service.
b. If excessive overrides do occur, investigate and document the reasons for the
excessive overrides.
c. Determine if the use of the excessive overrides is reasonable and supports the school
having an accurate meal count. If the answer in c. is NO, describe the problem and
determine whether the problem is nonsystemic or systemic.

320.

Observe how the meal count totals by category are obtained from each point of service
and combined for the total meal count by category for the school. Record the School’s
Combined Counts for the Day of Review, Reviewer's Counts for the Day of Review, and
any differences on the S-1, Line 13. If there were differences between the school's
combined counts and the reviewer's combined counts, answer NO and describe the
problem and determine whether the causes are nonsystemic or systemic.

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321.

a. Obtain a copy of the meal counts by category for each serving day of the review
period and compare it to the day of review count. Record the school’s meal counts by
category for the day of review and for the lowest day and the highest day during the
Review Period in the chart in the Comments section. This comparison should be
made to the number of meals reported by the school, prior to any daily meal
adjustments which may have been made by the SFA as a result of edit checks, etc.
However, if a nonsystemic error occurred in the school's day of review count, the
validated counts on the day of review may be used. Evaluate the counts and indicate
whether unreasonable shifts occurred in the counts by category from the review
month to the day of review.
b. If NO to a, obtain the school’s explanation and record in the Comments section.
c. Determine whether the explanation describes an acceptable meal count system.
d. If NO, list the total number of second meals and meals served to ineligibles in the
comments section. Combine this total with errors identified in #318 and record on
the S-1, Line 10.

School Level – Review Period
322. a. Determine whether the school claimed more free, reduced-price, or paid meals on any
day of the review period than the number of students eligible for free or reducedpriced meals. Record by category the dates in the review period where the eligible
counts were exceeded. This determination should be made using the number of meals
reported by the school, prior to any daily meal adjustments that may have been made
by the SFA as a result of edit checks, etc.
b. If YES, determine whether there was an acceptable explanation for each day the
number of free, reduced-priced, or paid meals claimed was greater than the number of
eligible by category. Indicate N/A if there were no days where the meal counts by
category exceeded the number of students eligible by category.
c. If no acceptable explanation is available, list the number of ineligible meals by
Program in the Comments section. Combine this total with errors identified in #323
and #324 and record on the S-1, Line 14.
323.

a. Determine whether there were any days in the review month where the free lunch
count exceeded the attendance adjusted free eligible count; or the reduced priced
lunch count exceeded the attendance adjusted reduced eligible count; or the paid
lunch count exceeded the attendance adjusted paid eligible count. To determine this,
multiply the number of students eligible for free meals or reduced price meals by the
attendance factor in S-1, Line 5. Round to the nearest whole number. Compare the
number of free, reduced price, and paid lunches claimed each day of the review
period to the number of attendance adjusted free, reduced price, and paid eligible
students.
b. If YES, indicate whether there were 50% or more of the serving days in the review
period when free lunches exceeded the number of attendance adjusted free eligible
students; or reduced-price lunches exceeded the number of attendance adjusted
reduced-price eligible students; or paid lunches exceeded the number of attendance
adjusted paid eligible students.

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c. If YES, determine whether there was an acceptable explanation for each day the free
lunch count was greater than the number of attendance adjusted free eligible students;
or the reduced-price lunch count was greater than the number of attendance adjusted
reduced-price eligible students; or the paid lunch count was greater than the number
of attendance adjusted paid eligible students.
d. If NO, explain in the Comments section. List the number of ineligible lunches in the
Comments section. Combine this total with errors identified by Program in #322 and
#324 and record on the S-1, Line 14.
324.

a. Examine the patterns of the reported counts of free, reduced, and paid meals for the
review period and indicate whether the counts are questionable for the population of
students participating in the observed meal program.
b. If YES, obtain and record the school’s explanation.
c. If the explanation provided is acceptable, answer NO. If the explanation provided is
not acceptable, answer YES and explain in the Comments section. List the number of
ineligible meals by Program in the Comments section. Combine this total with errors
identified in #322 and #323 and record on the S-1, Line 14.

325.

a. Record the school’s meal count by category for the review period, the SFA’s count by
category for the review period for the Claim for Reimbursement, and the State agency
count on the S-1, Line 17. If the school submits one monthly claim period report,
validate the entire month by summing the daily totals by category. If the school
submits for timeframes other than a monthly claim period report, validate one of the
school's report submissions, e.g., daily, weekly, or bi-weekly. Combine the validated
count with the other reports for the review period and record the results in State
agency count. If the validated count is different than the school reported count,
investigate and determine whether the SFA correctly claimed meal counts for the
school. If the validated count is different from the SFA claim for this school, record
the difference.
b. Answer YES if the validated count matches the SFA's claim for this school. If the
validated meal counts did not match the SFA's claimed counts, answer NO and
describe the problem.
c. If NO, explain and determine whether the causes are nonsystemic or systemic.
Record differences on the S-1, Line 17.

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SECTION III: NUTRITIONAL QUALITY AND MEAL PATTERN
SCHOOL LEVEL
MEAL COMPONENTS AND QUANTITIES
All meals missing required meal components are Performance Standard (PS) 2 violations and
must be corrected.
When multiple meal pattern violations are identified for a meal, list all violations in the
appropriate comments section. Record meals with multiple violations on the S-1 under only one
meal violation category to ensure that fiscal action is applied only once. If multiple violations
include meals served with missing meal components, record the meal under the missing meal
component category. For all other multiple meal pattern error violations, record repeated
vegetable sub-group or milk type violations before all other violations. For all other multiple
meal pattern violations, use discretion and record the most egregious violation for fiscal action.
Day of Review
Record menu observed the day of review.
400.

a. Prior to the beginning of meal services, identify whether all required meal
components are available on every reimbursable meal service line. If NO, explain all
errors identified and the technical assistance provided. The school should be advised
and given the opportunity to add any missing meal component(s) before the meal
service begins. If the missing meal component(s) is added, answer YES but record
the error and technical assistance that was provided in the Comments section. If the
deficiency was not corrected prior to the beginning of meal service, list the number of
meals served from the applicable meal service line that were missing required meal
components in the comments section.
b. During the meal service, observe that all required meal components are available on
every reimbursable meal service line throughout the entire meal service. If NO,
explain all errors identified and the technical assistance provided. If deficiencies are
identified, list the number of meals served from the applicable meal service line
missing required meal components in the comments section. Combine the total in the
comments section with errors identified in #401 and record on the S-1, Line 11.

401.

During the meal service, observe a significant number of program meals counted as
reimbursable on every reimbursable meal service line. FNS suggests observing 5% to
25% of meals served on each reimbursable meal service line. Meals should be observed
at the beginning, middle, and end of the meal service. During meal service observation,
determine whether the meals selected by students as they exit the POS contain the meal
components and food quantities required for the age/grade group being served. If NO,
explain all errors identified and the technical assistance provided. If deficiencies are
identified, record the number of meals observed missing required meal components,
which includes the requirement for at least ½ cup of fruits/vegetables under OVS, in the
comments section. Combine this total with errors identified in #400 and record on the
S-1, Line 11.

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402.

Evaluate whether the portion sizes of meal components from the planned menu and
served on the day of review meet the minimum meal pattern requirements for the
age/grade group(s) being served. If NO, explain all errors identified and the technical
assistance provided. Indicate whether the violations identified were repeat violations for
the SFA. Record only the number of incomplete meals counted for reimbursement that
will be subject to fiscal action in the appropriate field on the S-1, Line 12. (Refer to
7 CFR 210.10 for more guidance.)

403. a.
Determine whether at least two required milk varieties are available throughout
the serving period on all meal service lines. If SFA/school is offering 1% flavored milk, check
that approved waiver from State Agency is on file.
b. If substitutions are made, evaluate whether the substitutions were allowable per 7
CFR Part 210.10. If NO, explain all errors identified and the technical assistance
provided. Indicate whether the violations identified were repeat violations for the
SFA.
Record only the number of incomplete meals counted for reimbursement that will be
subject to fiscal action in the appropriate field on the S-1, Line 12.
404.

a.-b. Determine whether what constitutes a reimbursable meal is identified near or at the
beginning of the meal service line(s) for both breakfast and lunch. (See 7 CFR
210.10(a) (2))
c. Ensure that program operators do not promote or offer water or any other beverage
as an alternative selection to fluid milk throughout the food service area.

405.

If the school reviewed serves meals Family Style, the reviewer must evaluate whether the
meal service is acceptable per FNS Instruction 783-9. If NO, explain all errors identified
and the technical assistance provided.

406.

If a school is serving multiple menus and/or age/grade groups, the reviewer must evaluate
how the school has structured the meal service to meet the specific meal pattern
requirements for each menu type and/or age/ grade group being served. List all errors
identified and the technical assistance provided.

407.

Obtain a copy of the planned menu for the day of review and compare it to what was
actually offered on the meal service line. While substitutions are allowed, the reviewer
must ensure that the daily meal pattern minimums for each meal service line, menu type,
and age/grade group are still met. If NO, explain all errors identified and the technical
assistance provided. Record only the number of incomplete meals counted for
reimbursement that will be subject to fiscal action in the appropriate field on the S-1,
Line 12.

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408.

If any finding cited for the day of review resulted in the turning off of the PerformanceBased Reimbursement, answer YES and record on S-1, Line 18. Identify the issues in the
comments section.

OFFER VS. SERVE
Day of Review
500. Evaluate whether the cashier demonstrates a clear understanding of OVS and its
requirements. Meals missing a required meal component to include the ½ cup F/V
requirement under OVS are recorded under Question 401. For any instances where meals
were claimed for reimbursement that were incomplete due to required meal components
being selected in insufficient portion sizes, not to include the requirement for at least ½
cup of fruits/vegetables, record only those meals claimed for reimbursement that will be
subject to fiscal action in the appropriate field on the S-1, Line 12. For instances where a
student has selected a reimbursable meal, but is made to select an additional item(s),
record the error(s) in the comments section and provide technical assistance to ensure
Offer vs. Serve is properly implemented in the future.
501.

Obtain sufficient information demonstrating that the cafeteria staff has been trained on
Offer vs. Serve requirements for both NSLP and SBP. If NO, explain the technical
assistance provided.

502.

Determine if signage regarding what constitutes a reimbursable meal includes the
requirement that students must select at least ½ cup fruit or vegetable. (See 7 CFR
210.10(a) (2))

MEAL COMPONENTS AND QUANTITIES
All meals missing required meal components are Performance Standard (PS) 2 violations and
must be corrected.
When multiple meal pattern violations are identified for a meal, list all violations in the
appropriate comments section. Record meals with multiple violations on the S-1 under only one
meal violation category to ensure that fiscal action is applied only once. If multiple violations
include meals served with missing meal components, record the meal under the missing meal
component category. For all other multiple meal pattern error violations, record repeated
vegetable sub-group or milk type violations before all other violations. For all other multiple
meal pattern violations, use discretion and record the most egregious violation for fiscal action.
Review Period
409. Reviewer must examine production records for a week from the review period. The
minimum number of school days in the week reviewed is three (3), and the maximum is
seven (7). All must be consecutive days. Reviewer may examine any food crediting
documentation, including but not limited to food labels, product formulation statements,
CN labels, and bid documentation to ensure meal pattern compliance. Evaluate whether
the meals served meet the appropriate daily and weekly meal pattern requirements for the
age/grade group(s) being served. If critical issues are identified from the initial
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documentation review, the reviewer must expand the scope of review to the entire review
period. If NO, explain all errors identified and the technical assistance provided. Indicate
whether the violations identified were repeat violations for the SFA. Record the number
of meals missing required meal components on the S-1, Line 15. Record only the
number of incomplete meals claimed for reimbursement that will be subject to fiscal
action in the appropriate field on the S-1, Line 16.
410.

Evaluate productions records to determine whether the portion sizes of meal components
from the planned menu and served during the review period meet the minimum meal
pattern requirements for the age/grade group(s) being served. If NO, explain all errors
identified and the technical assistance provided. Indicate whether the violations
identified were repeat violations for the SFA. Record only the number of incomplete
meals claimed for reimbursement that will be subject to fiscal action in the appropriate
field on the S-1, Line 16. (Refer to 7 CFR 210.10 for more guidance.)

411.

Obtain a copy of the planned menu for the review period and compare it to a week (3-7
days) of production records from the review period. While substitutions are allowed,
ensure that the daily meal pattern minimums for each meal service line, menu type, and
age/grade group are still met. If NO, explain all errors identified and the technical
assistance provided. Indicate whether the violations identified were repeat violations for
the SFA. Record the number of meals observed missing required meal components on
the S-1, Line 15. Record only the number of incomplete meals claimed for
reimbursement that will be subject to fiscal action in the appropriate field on the S-1,
Line 16.

412.

If any finding cited for the review period resulted in the turning off of the PerformanceBased Reimbursement, answer YES and record on the S-1, Line 18. Identify the issues in
the comments section.

DIETARY SPECIFICATIONS AND NUTRIENT ANALYSIS
603. Determine whether any applicable off-site Dietary Specifications and Nutrient Analysis
activities resulted in areas being identified that required technical assistance or corrective
action prior to the beginning of the on-site portion of the review. If technical assistance
or corrective action was necessary, explain in the comments section.
604.

If Option 1 is selected to complete the targeted menu review, indicate the on-site
validation risk determination (see Dietary Specifications and Nutrient Analysis Module).

605.

If a nutrient analysis was not conducted due to a validated low risk score from the
Dietary Specifications Assessment Tool, check the low risk box. If a nutrient analysis was
conducted by the State agency (due to a high risk score from the Dietary Specifications
Assessment Tool or the State agency selected Option 3) or the SFA conducted a nutrient
analysis that was validated by the State agency, and not all the Dietary Specifications
were met for the established age/grade group and menu type, record which method was
used and which Program was deficient in the comments section and answer NO.

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If a nutrient analysis was conducted or validated, follow the Nutrient Analysis and
Validation Checklist for properly completing this question. If the State agency elects to
use a different method when conducting Nutrient Analysis activities required for
answering this question, the method must address at a minimum the information
contained within this checklist. Explain all errors identified and the technical assistance
provided. Indicate whether the violations identified were repeat violations for the SFA.
Record only the number of meals counted for reimbursement that will be subject to fiscal
action on the S-1, 16A.

SECTION V: GENERAL PROGRAM COMPLIANCE
SCHOOL LEVEL
CIVIL RIGHTS
Civil Rights requirements are outlined in FNS Instruction 113-1, Civil Rights Compliance and
Enforcement – Nutrition Programs and Activities, dated November 8, 2005.
811.

Verify whether the approved “And Justice for All” poster is posted in a prominent
location and visible to all program participants.

812.

Ensure that program meals were made available to all students without discrimination.

SFA ON-SITE MONITORING
901. Examine the documentation of the on-site review of the reviewed school to determine
whether the SFA had monitored the reviewed school’s counting and claiming procedures
and the general areas of review that are readily observable by February 1. Please note that
documentation may be kept on file at the SFA rather than site. If documentation is not
available or the on-site review occurred after February 1 without SA approval, answer
NO and explain in the Comments section.
902.

a. Determine whether there were errors in the meal counting and claiming procedures
for the reviewed school that required corrective action. If corrective action was
required but did not occur, or corrective action was insufficient, answer NO and
explain in the Comments section. Select N/A if corrective action from SFA On-site
monitoring was not required.
b. If corrective action occurred but was insufficient to address the problem identified,
answer NO and explain in the comments section.
c. Determine, regardless of corrective action sufficiency, whether an on-site follow-up
review was conducted within 45 days to ensure that corrective action was
implemented. If an on-site follow-up review did not occur within 45 days, answer
NO and explain in the Comments section. Select N/A if a follow-up review was not
required.

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903.

Review documented corrective action to determine whether deficiencies cited were
successfully corrected. If NO, explain in the Comments section. Select N/A if corrective
action resulting from SFA On-site Monitoring was not required.

SMART SNACKS IN SCHOOL
1104. Complete the table in the On-site tool where food and beverages are sold during the
school day.
1105.

a. Review documentation for 10% of the food and beverage items sold during the review
month. Obtain the time when foods and beverages are sold to students during the school
day (defined as 12 am on a day of instruction to 30 minutes after the end of the official
school day). This includes a la carte foods and beverages sold during meal services.
b. If the school enrollment includes mixed grades, (e.g., K-12, K-8, 6-12, etc.) determine
if the beverages meet the requirements for students in the youngest age/grade group.

1106.

Review the food sales policies (off-site tool) to determine if schools hold fundraisers. If
yes, determine if the schools observe the State-defined limit on fundraisers. For
non-exempt fundraisers, determine if these meet the Smart Snack standards. (Note that
fundraisers on weekends, off-site, or during non-school hours are also exempt.)

1107.

Obtain copies of production records to determine if exempt leftover NSLP entrees are
only sold the same day, or the day after, they are initially offered.

WATER
1300. Confirm that free potable water is available to all students for lunch (in each location
where lunches are served during the meal service) and for breakfast (when breakfast is
served in the cafeteria). The location of the potable water must be in the meal service
area or immediately adjacent to the meal service area.

FOOD SAFETY, STORAGE, AND BUY AMERICAN
1404. Confirm that a copy of the written food safety plan is available.
1405. a. Examine documentation from food safety inspections. Record the dates of the
inspections in the Comments section.
b. If the school has received two food safety inspections in the current school year,
answer YES and move to question 1406. If less than two food safety inspections are
available for the current school year, answer NO and move to c.
c. If the school received two food safety inspections in the previous school year, answer
YES and move to question 1406. If the school did not receive two food safety
inspections in the previous school year, answer NO and move to d.
d. Determine whether the SFA has documentation to indicate that the SFA requested
two food safety inspections in the current school year from the applicable agency. If
no documentation is available, explain in the Comments section.
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1406. Determine whether the most recent food safety inspection report (see Food Safety
Module) is posted in a publicly visible location. If NO, explain in the Comments section.
1407. Determine whether observations on the day of review indicate compliance with the
SFA’s written food safety plan. If NO, explain. Proper HACCP principles include, but
are not limited to: proper personal hygiene is evident (e.g., hairnets, gloved hands,
appropriate hand washing); cross contamination is prevented; food temperatures are
monitored; refrigerator and freezer temperatures are monitored; food preparation and
service areas are clean; clean utensils and equipment are used for food preparation and
meal service; and no obvious evidence of pests is present.
1408. Confirm that selected temperature logs were available for review. If YES, record the
dates of the selected temperature logs in the Comments section. If NO, specify which
document(s) were unavailable and explain in the Comments section.
1409. Determine whether observations on the day of the review indicate any on-site or off-site
storage violations. If YES, explain in the Comments section. Proper storage practices
include, but are not limited to: temperature is appropriate for the applicable equipment
(e.g., freezer, refrigerator, milk cooler); food is stored 6 inches off the floor; the food
storage facility is clean and neat; canned goods are free from bulges, leaks, and dents;
chemicals are clearly labeled and stored away from food and food-related supplies; open
bags of food are stored in containers with tight fitting lids; the FIFO (First In, First Out)
method of inventory management is used; and no obvious evidence of pests is present.
1410. Determine if agricultural food commodities and products are domestic as required by the
Buy American provision in 7 CFR 210.21(d). On-site reviews will be conducted as
follows:
•

The number of agricultural food components to be reviewed will be determined based on
the SFA storage facility practices used:
o If the majority of agricultural food components used are located at individual schools
only, the SA will review at each reviewed school 2-3 items in each agricultural food
component category below;
o If the majority of agricultural food components used are located at an SFA’s off-site
storage facility only, the SA will review at the SFA’s off-site storage facility 2-3 items in
each agricultural food component category below; or
o If agricultural food components used are located at a combination of places both on-site
at schools and at the SFA’s off-site storage facilities, the SA will review 1-2 items in
each agricultural food components category below for each school reviewed and 1-2
items in each agricultural food component category below at the SFA’s off-site storage
facilities.

•

Agricultural food component categories include:

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o Bakery, pasta, and miscellaneous (grain components delivered ready to serve; or wheat
flour, cornmeal, or other grain flours, used to prepare grain components, pasta, bread,
etc.)
o Canned fruit and fruit juice
o Canned vegetables and vegetable juice
o Frozen fruit and fruit juice
o Frozen vegetables and vegetables juice
o Frozen meat/entrée items
o Refrigerated foods (produce; dairy such as cheese, yogurt, milk; and food components
that may be thawing for future meal service, etc.)
•

Noncompliant food items will be listed in the comments section.

1411. Observations will be made to determine any violations of the Buy American provision as
found in 7 CFR 210.21(d) either during review of foods on-site at reviewed schools or at
off-site storage facilities as applicable. If there are non-domestic agricultural food
components, documentation will be obtained to determine if any exceptions were granted
by the SFA where:
o The agricultural food component is not produced or manufactured in the U.S. in
sufficient and reasonably available quantities of a satisfactory quality; or
o Competitive bids reveal the costs of domestic agricultural food components are
significantly higher than the non-domestic ones.
•

Noncompliant foods will be identified in the comments section and this information will
be shared with the SA staff conducting the procurement review in order for them to
identify if the Buy American provision is in solicitation and contract documents. Note
that documented USDA foods are presumed to be domestic; however, processed end
products that contain USDA Foods must meet the over 51% domestic requirement, by
weight or volume.

For 1410 and 1411, corrective action may include:
•
Requiring review of food deliveries for contractor compliance;
•
Monitoring to ensure the correct domestic food components contracted for are delivered;
and/or
•
Prior to accepting foods, ensuring that an alternative domestic food component, or an
exception to purchase non-domestic foods, has been approved for delivery.

REPORTING AND RECORDKEEPING
1502. Determine whether the school is retaining the appropriate records regarding program
management for 3 years after the final Claim for Reimbursement for the fiscal year or
until resolution of any audits. If NO, describe the reason in the Comments section (see
Module: Reporting and Recordkeeping).

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SECTION VI: OTHER FEDERAL PROGRAM REVIEWS
SCHOOL LEVEL
AFTERSCHOOL SNACK PROGRAM
1700. Identify areas that required technical assistance and/or corrective action from the
Afterschool Snack Program Administrative Review Form.
FRESH FRUIT AND VEGETABLE PROGRAM
Review Period
1900. Determine whether the school is on track to spend no more than 10% of its total grant on
administrative costs. If NO, explain in the Comments section.
1901. Review the school’s Fresh Fruit and Vegetable Program cost documentation provided to
support the selected month’s Claim for Reimbursement. Compare the total cost claimed
for reimbursement against the total cost established by the supporting documentation. If
the cost documentation supports the Claim for Reimbursement, answer YES. If the cost
documentation does not support the Claim for Reimbursement, answer NO. Record any
unsupported Program costs in the Comments section. Combine amount with any
applicable amount in 1902 and record on the S-1, Line 21. Additionally, review the cost
documentation to ensure that all costs were allowable. If the cost documentation supports
the claim for reimbursement and all costs are allowable, then the claim is validated. If
the cost documentation does not support the claim for reimbursement or contained
unallowable costs, the claim cannot be validated. Fiscal action may be necessary.
1902. Review the school’s Fresh Fruit and Vegetable Program cost documentation provided to
support the selected month’s Claim for Reimbursement. Determine whether the cost
documentation provided is for allowable Program costs. If the cost documentation is for
allowable Program costs, answer YES. If any cost documentation is for an unallowable
Program costs, answer NO. Record any unallowable Program costs in the Comments
section. Combine amount with any applicable amount in 1901 and record on the S-1,
Line 21.
Day of Review
1903. Determine whether the Fresh Fruit and Vegetable Program is available to all enrolled
children at no cost. If NO, explain in the Comments section.
1904. Determine whether the Fresh Fruit and Vegetable Program is offered during the school
day, but outside the meal service times of the NSLP and/or SBP. If NO, explain in the
Comments section.
1905. Determine whether the Fresh Fruit and Vegetable Program is widely publicized within
the school. If NO, explain in the Comments section.

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1906. Determine whether any of the following unallowable products were offered to children
during the Fresh Fruit and Vegetable Program meal service: frozen, canned, and other
types of processed fruits/vegetables; fruit/vegetable juice, nuts, cottage cheese, trail mix,
fruit/vegetable pizza, smoothies, fruit strips, fruit drops, fruit leather, jellied fruit, or
carbonated fruit. If YES, explain in the Comments section.
1907. a. Determine whether dip was offered with the day’s Fresh Fruit and Vegetable Program
offering.
b. If YES, determine whether the dip was fat-free or low-fat, no greater than 2
Tablespoons, and provided for vegetables only. If NO, explain in the Comments
section.
1908. a. Determine whether a cooked vegetable is the day’s Fresh Fruit and Vegetable
offering.
If YES, answer b and c.
b. Determine whether the cooked vegetable is included as part of a nutrition education
lesson.
c. Determine whether today is the only offering of a cooked vegetable this week.
If NO to b or c, explain in the Comments section.
1909. If adults are provided fresh fruits and vegetables during the Fresh Fruit and Vegetable
Program meal service, determine whether the adults are teachers who are in the
classroom with students during the Fresh Fruit and Vegetable meal service. If NO,
explain in the Comments section.
1910. Determine whether the Fresh Fruit and Vegetable Program meal service followed
HACCP principles and applicable sanitation and health standards, including the handling
of any left overs. If NO, explain. See Food Safety module for HACCP principle
compliance requirements.

SPECIAL MILK PROGRAM
2000. Identify areas that required technical assistance and/or corrective action from the Special
Milk Program Administrative Review Form.

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SFA Level Questions
SFA Name_______________________________
Date of Review________________
Off-Site Assessment Tool Validation
For each question on the Off-site Assessment Tool, do the responses provided
demonstrate compliance with FNS requirements and reflect current practices? If NO,
explain technical assistance and/or corrective action provided.

YES

NO

Comments:

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SFA Level Questions
SFA Name_______________________________
Date of Review________________

Section II: Meal Access and Reimbursement
Module: Certification and Benefit Issuance
124.

If the SFA is implementing CEP SFA wide skip questions 124-215 and proceed to
question 314.
a.

YES

NO

N/A

YES

NO

N/A

Was the SFA required to conduct an independent review of applications in
the previous or current school year according to FNS requirements?

If yes, please identify in the comments section who is responsible for the second
review of applications.
If NO, explain in comments.
b. Did the SFA complete and submit the FNS-874 (Local Educational Agency
Second Review of Applications Report) according to FNS requirements?
If NO, explain.
Comments:
a. (Names and/or position titles):

b.

125.

For RCCIs with NO day students and no applications on file, does the SFA have the
correct eligibility documentation available for residential students? Skip questions
126 – 215 and proceed to question 314.
For all other RCCIs, proceed with the standard certification review. Record errors
on the SFA-1.
If not an RCCI mark N/A and proceed to the next question.

Comments:

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SFA Level Questions
SFA Name_______________________________
Date of Review________________
126.

Certification and Benefit Issuance Review Method:

YES

NO

YES

NO

YES

NO

YES

NO

____100% of students determined to be eligible for free and reduced price
benefits; or
____Statistically Valid Sample of students determined to be eligible for free and
reduced price benefits
Confidence Level: 95%____ 99%____
Universe:_________ Sample Size________
Were all selected applications correctly approved?
If NO, explain. Record the Count of Reviewed Students by category and any errors
on the SFA-1 and/or SFA-2.
Comments:

127.

Are the correct income eligibility guidelines used to certify applications?
If NO, explain.

Comments:

128.

Are the correct conversion factors used when processing applications that indicate
more than one income frequency?
If NO, explain.

Comments:

129.

Is household notification of eligibility consistent with the responses provided on
the Off-site Assessment Tool?
If NO, explain.

Comments:

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SFA Name_______________________________
Date of Review________________

130.

Is household notification of denied benefits consistent with FNS requirements?

YES

NO

YES

NO

YES

NO

YES

NO

If NO, explain.

Comments:

131.

Are any applications denied incorrectly?
If YES, record student names on the SFA-2.

Comments:

132.

Does the direct certification list utilized by the SFA:
a)

Contain the correct information for direct certification?

b) Come from the proper agency (SNAP, TANF, FDPIR, foster, homeless,
runaway, migrant, Head Start)?
If NO, explain.
Comments:
a.
b.

133.

Were all direct certifications (SNAP, TANF, FDPIR, foster, homeless, runaway,
migrant, and/or Head Start) correctly certified?
If NO, explain.
Record errors on the Certification and Benefit Issuance Error Worksheet, SFA-1.

Comments:

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SFA Level Questions
SFA Name_______________________________
Date of Review________________

134.

Does the SFA perform Direct Certification matches according to the required
timeframes?

YES

NO

YES

NO

YES

NO

YES

NO

If NO, how often are matches conducted?
Comments:

135.

Are the Direct Certification lists retained on file by the SFA?
If NO, explain.

Comments:

136.

a. Are free and reduced price benefits provided to students in a manner that
assures confidentiality and prevents overt identification during meal service or at
any other time in accordance with regulations and FNS Policy Memos.?
If NO, explain.
b. Are free and reduced price eligible students required to work for their meals?
If YES, explain.

Comments:
a.
b.
137.

Did the SFA accurately transfer the correct benefit from the eligibility
determination document to the Point of Service benefit issuance document?
If NO, explain.
Record errors on the SFA-1.

Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 5

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________

138.

Did the SFA update the benefit issuance document(s) accurately and in a timely
manner, including those students that are new, transferred, or withdrawn?

YES

NO

N/A

YES

NO

N/A

If NO, explain.
Record errors on the SFA-1.
Comments:

139.

For Manual Systems: If number sheets and coded rosters are used, did the
SFA/school document changes in student eligibility/enrollment throughout the
month?
If NO, explain.
Record errors on the SFA-1.

Comments:

140.

Did the SFA update benefit issuance documents accurately and in a timely manner
upon receipt of Direct Certification updates?

YES

NO

If NO, explain.
Record errors on the SFA-1.
Comments:

141.

Does the SFA account for benefits that have been extended to students living in a
household that is receiving SNAP, TANF or FDPIR benefits?

YES

NO

N/A

If NO, explain.
Record errors on the SFA-1.
Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 6

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________

142.

If any family declined or requested a lower level of benefits, were benefits changed
on the Benefit Issuance document?

YES

NO

N/A

If NO, explain.
Comments:

Module: Verification
YES

207.

NO

N/A

a. Did the SFA complete verification?

b. Do the verified applications on file match the number reported on the most
recent FNS-742 as reviewed in Question 200 of the Off-site Assessment Tool?
Record any discrepancies in the Comments section.
Comments:
a.
b.
208.

YES

When a confirmation review was conducted:
a.

Is documentation demonstrating that a confirmation review took
place on file at the SFA?

b.

Did the SFA follow the required procedures if the confirmation review
did not validate the original determination?

NO

N/A

If NO to a or b, explain in comments.
Comments:
a.
b.

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 7

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________

209.

YES

Based on the review of verified applications:
a.

Were the applications subject to verification properly selected in
accordance with the sample size option used (e.g., error prone)?

b.

If the SFA chose to replace applications selected for verification, was
it done correctly and limited to 5% of the applications selected?

c.

Were all applications selected for review verified correctly?

NO

N/A

If NO to a, b, or c, explain.
Comments:
a.
b.
c.

210.

YES

NO

N/A

YES

NO

N/A

a. Did the SFA attempt to directly verify selected applications?

b. If YES, were the requirements met?
If NO to b, explain in comments.
Comments:
b.

211.

Does the SFA’s verification notification letter include all required information?
If NO, explain.

Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 8

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________

212.

Did the SFA meet the follow-up requirements if the household failed to
respond to the request for verification?

YES

NO

N/A

YES

NO

N/A

If NO, explain.
Comments:

213.

If applicable, did the SFA’s notice of adverse action contain all required
information, including notification of appeal rights?
If NO, explain.

Comments:

214.

YES

If a student’s eligibility changed due to verification:

NO

N/A

a. Did the SFA make updates to the eligibility status to benefit issuance list?
b.

Were benefits increased no later than 3 calendar days?

c. Were households for whom benefits were to be reduced or terminated
given 10 calendar days' written advance notice of the change? to a, b, or c
explain.
Comments:
a.
b.
YES

215.

NO

N/A

a. Did the SFA complete verification by November 15?

b. If not, did the SFA get SA approval for an extension until December 15?
If NO to a or b, explain.
Comments:
a.

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 9

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
b.

Module: Meal Counting and Claiming
314.

Is the SFA following their approved SFA-SA Agreement/application (including
POS)?

YES

NO

YES

NO

If NO, explain.
Comments:

315.

Does the SFA consolidate the Claim for Reimbursement?
If YES, complete question 316.

Comments:
316.

a. Complete the chart below for all schools for the review
period.

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

b. Were the counts for all schools for the review period
correctly consolidated and claimed by the SFA?
If NO, explain and indicate whether the problem was nonsystemic or systemic. If there are differences refer to the
instructions to this question for further guidance.
NSLP

SFA Claim

SA Count

Diff +/-

SBP

Free

Free

Reduced

Reduced

Paid

Paid

Comments:

SFA Claim

SA Count

Diff +/-

NSLP:
Non-systemic
Systemic
SBP:
Non-systemic

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 10

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
Systemic

Section IV: Resource Management
TO BE COMPLETED ONLY FOR SFAs IN FIRST YEAR OF OPERATION
Module: Maintenance of the Nonprofit School Food Service Account
Does the new SFA have processes and procedures for ensuring compliance with
FNS requirements concerning Maintenance of the Nonprofit School Food Service
Account, including compliance with allowable costs? (7 CFR 210.14/2 CFR 200
Subpart E)

YES

NO

YES

NO

YES

NO

Document any technical assistance provided/corrective action necessary
Comments:
Module: Paid Lunch Equity
Does the new SFA have processes and procedures for ensuring compliance with
FNS requirements concerning the Paid Lunch Equity? (7 CFR 210.14(e))
Document any technical assistance provided/corrective action necessary
Comments:

Module: Revenue from Nonprogram Foods
Does the new SFA have processes and procedures for ensuring compliance with
FNS requirements concerning Revenue from Nonprogram Foods? (7 CFR 210.14(f))
and FNS Policy Memo SP 20-2016.)
Document any technical assistance provided/corrective action necessary
Comments:

Module: Indirect Costs

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 11

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
Does the new SFA have processes and procedures for ensuring compliance with
FNS requirements concerning Indirect Costs? (2 CFR 225 and SP 41-2011)

YES

NO

Document any technical assistance provided/corrective action necessary
Comments:

Section V: General Program Compliance

Module: Civil Rights
809.

a. Are denied applications disproportionately submitted by minority
households?

YES

NO

YES

NO

b. If YES, were they denied correctly?
If NO, explain.
Comments:

810.

Review, program materials, do appropriate Program materials use the nondiscrimination statement?

Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 12

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
Module: Professional Standards
YES

NO

1210.

Does the LEA’s enrollment match the enrollment level described on the
off-site assessment tool? i.e. 2,499 or less, 2,500 – 9,999, or 10,000 or
more.

1211.

Review an employee list for the day of the review and verify that the SFA’s information from the
Off-site matches the current (day of review) employee list. If personnel count does not match,
list any employees that are no longer employed with the SFA in the comments. If any new
personnel have been hired, see question 1220.
SFA Count Offsite Tool

SA Count Day
of Review

SFA Count Offsite Tool

Directors

Managers

Full-Time
Nutrition Staff

Part-Time
Nutrition Staff

Personnel hired
after January 1
of the School
Year being
reviewed, if
applicable.
Otherwise list
NA.

Non-school
nutrition staff
that have
responsibilities
that include
duties related to
the program

SA Count Day
of Review

Comments:

1212.

a) After review of documentation, if the SFA hired any new directors on
or after July 1, 2015 were hiring requirements met? If no new directors
were hired mark NA and proceed to question 1216.

YES

NO

NA

b) If yes, validate that the SFA has documentation to substantiate hiring
requirements on file? If no, for LEAs with student enrollment less than
500 students did the SFA receive approval prior to hiring? For LEAs with
more than 500 students explain in the comments section.
Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 13

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
1213.

Verify the SFA’s response to Question 1203 on the Off-site Assessment
Tool.

YES

NO

NA

Validate that a previous food safety certification was obtained in the
last 5 years or that the newly hired School Nutrition Program Director
completed food safety training at the time of the on-site review? If yes,
list date of certification in the comments
Comments:

1214.

Validate the SFA’s response to Question 1204 on the Off-site
Assessment Tool.

YES

NO

YES

NO

If the School Nutrition Program Director has not met the training
requirements, review documentation of the scheduled/planned
trainings for the remainder of the school year and determine if the
School Nutrition Program Director is expected to meet annual training
requirements.
List current completed training hours and expected/planned training
hours in the comments.

Comments:

1215.

Validate the SFA’s response to Question 1205 on the Off-site
Assessment Tool, if applicable.
If the School Nutrition Program Manager has not met the training
requirement, review documentation of the scheduled/planned trainings
for the remainder of the school year and determine if the School
Nutrition Program Manager is expected to meet annual training
requirements.

List current completed training hours and expected/planned training
hours in the comments.
Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 14

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
1216.

Validate the SFA’s response to Question 1206 on the Off-site
Assessment Tool, if applicable.

YES

NO

List current completed training hours and expected/planned training
hours in the comments.
Comments:
1217.

a. Please describe the frequency (i.e. annually, quarterly, monthly etc.) in which training hours
are being tracked. i.e. entered into a tracking mechanism
b. Does the SFA use the USDA Professional Standards Training Tracking Tool? If not, please
describe in the comments section what is being used and if the SFA’s process clearly documents
the required fields listed in the Professional Standards Module.

Comments:
a.

b.
1218.

Are there any employees that were hired in the time between
completion of the Off-site and On-site Assessment Tools? If yes, did
they meet the training requirements?

YES

NO

If no, explain in comments below. Please list non-compliant employee’s
name(s), title/position and training hours completed.

Comments:

YES
1219.

a.

Are there additional employees outside of the School Nutrition
Program whose responsibilities include duties related to the
operation of the School Nutrition Program?

b.

If yes, have these employees received the required applicable
training?

Administrative Review On-site Assessment Tool

NO

School Year 2018-2019 SFA Questions- 15

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
Comments:

Module: Food Safety, Storage and Buy American
1400.

YES

NO

YES

NO

a. Does the written food safety plan contain the required elements?
If NO, identify which elements are missing in comments section.
b. Is a copy of the written food safety plan available at each school?
If NO, explain in comments section.
Comments:

1401.

If conducted as part of the Administrative Review, are SFA contracted and selfoperated warehouses, storing all foods (commercial and USDA) properly? If
no, explain.

Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 16

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________

1402.

The number of agricultural food components to review will be determined
based on the SFA storage facility practices used.
Does the SFA store a majority of the agricultural food
components used at each school reviewed? If yes, skip the next
section as the review of Buy American compliance will occur at
the school-level review.
Does the SFA store a majority of agricultural food components
used at an off-site storage facility? If yes, review 2-3 items in each
food component listed in the instructions at each reviewed offsite storage facility.

YES

NO

YES

NO

Does the SFA store agricultural food components used at both
individual schools and off- site storage facilities? If yes, review 1-2
items in each agricultural food component category listed in the
instructions at each site reviewed.
In the comments section list any noncompliant food components that
are observed.
Comments:

1403.

a.

Did a review of agricultural food components indicate violations of the
Buy American provision (7 CFR 210.21(d)) either during review of
products on-site at reviewed schools or at off-site storage facilities as
applicable? If yes, proceed to b, if no proceed to next section.

b.

Is there documentation to determine if domestic alternatives were
considered and if an exception was granted by the SFA because:
•
The agricultural food component is not produced or
manufactured in the U.S. in sufficient and reasonably available
quantities of a satisfactory quality; or
•
Competitive bids reveal the costs of domestic agricultural
food components are significantly higher than the non-domestic ones.
The exception was related to the domestic food as prohibitively costly
or limited quantity availability.

•

(Inform the SA staff conducting the procurement review of any
findings in this area in order to identify if the Buy American provision
is in the SFA solicitation, contract, and/or bid specifications.)

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 17

Administrative Review On-site Assessment Tool
SFA Level Questions
SFA Name_______________________________
Date of Review________________
Comments:

Module: Reporting and Recordkeeping
1500.

Are reports submitted to the State agency as required?

YES

NO

YES

NO

If NO, explain.
Comments:

1501.

Are records retained for 3 years after the final Claim for Reimbursement for
the fiscal year or until resolution of any audits?
If NO, explain.

Comments:

Section VI: Other Federal Program Reviews

Module: Seamless Summer Option
Check box if SFA operates SSO
*If a review of SSO is required, complete Supplemental Seamless Summer Option Administrative Review Form.
Module: Afterschool Care Snack Program
Check box if SFA operates Afterschool Snack Care Program
* If a review of Afterschool Care Snack Program is required, complete Supplemental Afterschool Care Snack
Program Administrative Review Form.

Administrative Review On-site Assessment Tool

School Year 2018-2019 SFA Questions- 18

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________

Section VII: Special Provision Options – SFA Level*
SCHOOL NAME: _____________________________________________________________
*Note: Some of these activities may be assessed at the site level. If some or any of these activities occur at
the site level, record the activities here.

Module: Special Provisions Options
2113.

Were the claiming percentages and/or funding levels established during the
Base Year for Provision 2 and 3 SFAs/sites calculated correctly?

YES

NO

N/A

YES

NO

N/A

YES

NO

N/A

If NO, explain.
Comments:

2114.

Are the claiming percentages and/or funding levels established during the Base
Year for Special Provision Option SFAs/sites being applied correctly to Non-Base
Year claims for reimbursement?

If NO, explain.

Comments:

2115.

Does the SFA documentation support the Identified Student Percentages and
claiming percentages at time of latest CEP approval?

If NO, explain.
Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 1

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
Are Free and Reduced-price Meal Applications being distributed in sites
operating Provision 2/3 in Non-Base Years?

2116.

YES

NO

If yes, is the SFA’s distribution of applications and use of information
acceptable as specified in the USDA Provision 2 Guidance: Free and Reduced
Price Applications? Explain in the Comments section.
Comments:

2117.

For Provision 1 sites only: Are daily meal counts by type used as the basis for
calculating claims for reimbursement?

YES

NO

N/A

Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 2

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________

Section II: Meal Access and Reimbursement
Module: Meal Counting and Claiming
DAY OF REVIEW
317.

NSLP

a. Based on meal observation, does the meal counting
system as implemented prevent overt identification of
students receiving free and reduced price benefits?

YES

SBP
NO

N/A

YES

NO

N/A

NO

N/A

If NO, explain.
b. Does the school have separate dining areas, meal service
times, or serving lines based on a student’s eligibility
status?
c. Does the school limit choice of reimbursable meals based
on a student’s eligibility status?

d. Does the school use different mediums of exchange
based on eligibility status?
If YES to b, c, or d, explain.

Comments:
318.

At the selected school(s), does each type of meal service
line as observed on the day of review provide an accurate
count by eligibility category at the point of service (or
approved alternate)?

NSLP
YES

SBP
NO

N/A

YES

If NO, describe the problem and indicate whether the
problem was non-systemic or systemic. If second meals or
meals served to ineligibles were observed, list the total in
the Comments section. Combine this total with errors
identified in #321 and record in S-1, 10.
Comments:

NSLP:
Non-systemic
Systemic
SBP:
Non-systemic
Systemic

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 3

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
319.

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

a. Electronic Systems Only: On the day of review, are
excessive overrides used at the POS? If yes, for what
purposes? Explain in comments.
b. Is the use/purpose of the overrides reasonable?
If NO to c, describe the problem and indicate whether the
problem was non-systemic or systemic.
Comments:

NSLP:
Non-systemic
Systemic
SBP:
Non-systemic
Systemic

320.

Are meal count totals by category combined and recorded
correctly?

NSLP

If NO, describe the problem and indicate whether the
problem is systemic or non-systemic. Record any differences
on the S-1, 13.

YES

SBP
NO

N/A

YES

NO

N/A

Comments:

NSLP:
Non-systemic
Systemic
SBP:
Non-systemic
Systemic

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 4

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
NSLP

321.

YES

SBP
NO

N/A

YES

NO

N/A

a. Are total meal counts by category for the review period
reasonable compared to meal counts for the day of review?
b. If NO, obtain the school’s explanation and record in the
Comments section.

c. Does the explanation describe an acceptable meal count
system?
d. If NO, explain and list total number of second meals and
meals served to ineligibles in the Comments section.
Combine this total with errors identified in #318 and record
in S-1, 10.
NSLP - Day of Review Meal Counts

SBP - Day of Review Meal Counts

Free

Free

Reduced

Reduced

Paid

Paid

Total

________

Total

________

NSLP Review Period Meal Counts Lowest to Highest

SBP - Review Period Meal Counts Lowest to Highest

Free

to

_

Free

to

_

Reduced

to

_

Reduced

to

_

Paid

to

_

Paid

to

_

_

Total

Total

______to

______to

_

Comments:

Module: Meal Counting and Claiming
REVIEW PERIOD
322.

a. Were there any days when the free, reduced price, or
paid meal counts exceeded the number of free, reduced
price, or paid eligible students?

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

b. If YES to a, indicate which dates and determine whether
there was an acceptable explanation available for each day.
If NO to a, skip to question 323.

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 5

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
c. If no acceptable explanation is available, explain and list
the number of ineligible meals in the Comments section.
Combine this total with errors identified in #323-324 and
record in S-1, 14.

NSLP

SBP

School Free Eligible
Count

School Free Eligible
Count

School Reduced-Price
Eligible Count

School Reduced-price
Eligible Count

School Paid Eligible
Count

School Paid Eligible
Count

Dates Exceeding Eligible Students

Dates Exceeding Eligible Students

Free

Free

Reduced

Reduced

Paid

Paid

Comments:

YES

323.

NO

a. Were there any days when the free, reduced price, or paid lunch counts exceeded the
number of attendance adjusted eligible students?
b. If YES to a, was it 50% or more of the serving days?
c. If YES to b, was there an acceptable explanation?
d. If NO to c, explain and list the number of ineligible lunches in the Comments section.
Combine this total with errors identified by Program in #322 and #324, and record in S-1,
14.

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 6

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
NSLP
Dates Exceeding Attendance Adjusted Eligible Students
Free:
Reduced:
Paid:
Comments:

NSLP

324.

YES

SBP
NO

N/A

YES

NO

N/A

NO

N/A

a. Were there patterns in the free, reduced, or paid meal
counts which appear questionable?
b. If YES, obtain the school’s explanation and record in the
Comments section.
c. After consideration of this explanation, do the patterns
indicate questionable meal count practices?
If YES to c, explain and list the number of ineligible meals by
Program in Comments section. Combine this total with
errors identified in #322 and #323 and record on the S-1,
14.
Comments:

325.

a. For the review period, complete S-1, 17.
b. Were the counts by category correctly used in the Claim
for Reimbursement?

NSLP
YES

SBP
NO

N/A

YES

c. If NO, explain and indicate whether the problem was
non-systemic or systemic. List the number of ineligible
meals by Program in the Comments section. Record
differences on the S-1, 17.
Comments:

NSLP:
Non-systemic
Systemic

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 7

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
SBP:
Non-systemic
Systemic

Section III: Nutritional Quality and Meal Pattern
Module: Meal Components and Quantities
DAY OF REVIEW
NSLP MENU:

400.

SBP MENU:

Were all required meal components available on every
reimbursable meal service line to all participating students

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

a. Prior to the beginning of meal service?

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 8

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________

b. During the meal service?
If NO to a or b, explain all errors identified and the
technical assistance provided in the Comments section.
If the error was not corrected prior to the beginning of the
meal service, or if the meal service line did not offer all
required meal components throughout the meal service,
list the number of meals served from the applicable meal
service line missing the required meal components in the
Comments section. Combine this total with errors
identified in #401 and record on the S-1, 11.
Comments:

401.

Did all meals observed and counted for reimbursement
for the day of review contain all of the required meal
components?
If NO, explain any errors identified and the technical
assistance provided in the Comments section.

NSLP

YES

SBP

NO

N/A

YES

NO

N/A

Record the number of meals observed missing required
meal components, which includes the requirement for at
least ½ cup of fruits/vegetables under OVS, in the
Comments section. Combine this total with errors
identified in #400 and record on the S-1, 11.
Comments:

402.

Are the minimum daily quantity requirements met for the
age/grade group being offered?

NSLP

If NO, list all the errors identified and the technical
assistance provided. Indicate whether the violations
identified were repeat violations in the SFA. Record only
the number of incomplete meals counted for
reimbursement that will be subject to fiscal action in the
appropriate field on the S-1, 12.

YES

Administrative Review On-site Assessment Tool

SBP
NO

N/A

YES

NO

N/A

School Year 2018-2019 School- 9

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
NSLP

SBP
Indicate Quantity
Offered

Indicate Quantity Offered

Meat/meat alternate

Grains/Breads

Fruits

Fruits

Vegetables

Milk

Grains/Breads
Milk
Comments:

NSLP

403.

YES

SBP
NO

N/A

YES

NO

N/A

a. Was fluid milk available in at least the two required
varieties throughout the serving period on all meal service
lines? If SFA/school is offering 1% flavored milk, check that
approved waiver from State Agency is on file.
b. If milk substitutions are made, are they allowable?
If NO to a or b, list all the errors identified and the
technical assistance provided. Indicate whether the
violations identified were repeat violations for the SFA.
Record only the number of incomplete meals counted for
reimbursement that will be subject to fiscal action in the
appropriate field on the S-1, 12.
Comments:

Administrative Review On-site Assessment Tool

School Year 2018-2019 School- 10

Administrative Review On-site Assessment Tool
School Level Questions
School_______________________________
Date of Review________________
YES

404.

NO

a. Is there signage explaining what constitutes a reimbursable breakfast to students
for all applicable grade groups?

b. Is there signage explaining what constitutes a reimbursable lunch to students for
all applicable grade groups?

c. Does signage promote water or any other beverage as an alternative selection to
fluid milk throughout the food service area?
If NO to a, b, or YES to c, explain and list the technical assistance provided in the
comments.
Comments:
a.
b.
c.

405.

If the school has elected to serve meals using the Family
Style Method, is the school implementing method as
specified in FNS Instruction 783-9?
If NO, list the issues identified and the technical assistance
provided.

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

NO

N/A

Comments:

406.

If the school is serving multiple menus and/or age/grade
groups, is the meal service structured to comply with the
required age/grade group meal pattern requirements?
Describe the structure in the Comments section.

NSLP
YES

SBP
NO

N/A

YES

List any errors identified and the technical assistance
provided.
Comments:

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School Level Questions
School_______________________________
Date of Review________________

407.

a. Has the school offered the planned menu for the day of
review?

NSLP

b. If changes are being made to the planned menu, are
the changes acceptable substitutions?

YES

SBP
NO

N/A

YES

NO

N/A

YES

NO

N/A

If NO to a or b, list all errors identified and the technical
assistance provided. Record only the number of
incomplete meals counted for reimbursement that will be
subject to fiscal action in the appropriate field on the S-1,
12.
Comments:

408.

Did any findings noted in Questions 400 - 407 result in the turning off of the
Performance- Based Reimbursement?
If YES, record on the S-1, 18 and identify the issues in the Comments section.

Comments:

Module: Offer versus Serve
DAY OF REVIEW
500.

Is Offer vs. Serve being implemented properly by the reviewed
school?

NSLP

If the reviewed school does not utilize Offer vs, Serve check N/A
and skip 501-502.

YES

SBP
NO

N/A

YES

NO

N/A

If NO, list all errors identified and the technical assistance
provided in the Comments section. Meals missing a required
meal component, which includes the requirement for at least ½
cup of fruits/vegetables, are recorded under Question 401.
Record only the number of incomplete meals due to insufficient
quantities (not to include the requirement for at least ½ cup of
fruits/vegetables) claimed for reimbursement that will be
subject to fiscal action in the appropriate field on S-1, 12.

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School Level Questions
School_______________________________
Date of Review________________
Comments:

NSLP

501.
Has the cafeteria staff been trained on Offer vs. Serve?
If NO, explain and list the technical assistance provided.

YES

SBP
NO

YES

NO

Comments:

502.

YES

Does signage explaining what constitutes a reimbursable meal to students include the
requirement to select at least ½ cup fruit or vegetable?

NO

If NO, explain and list the technical assistance provided.
Comments:

Module: Meal Components and Quantities
REVIEW PERIOD
409.

Review production records and other supporting
documentation, did all reviewed meals during the review
period indicate that all of the required meal components per
weekly meal pattern requirements were offered and served
to students?

NSLP
YES

SBP
NO

N/A

YES

NO

N/A

If NO, explain any errors identified and the technical
assistance provided. Indicate whether the violations
identified were repeat violations for the SFA.
Record the number of meals observed missing required meal
components on the S-1, 15. Record only the number of
incomplete meals claimed for reimbursement that will be
subject to fiscal action in the appropriate field on S-1, 16.
Comments:

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School Level Questions
School_______________________________
Date of Review________________

NSLP

410.

a. Do planned menu quantities meet meal pattern
requirements for the review period?

YES

SBP

NO

N/A

YES

NO

N/
A

b. If NO to a, do production records and/or other
supporting documentation for the review period
indicate that the required quantities of food were
available?
c. If NO to a or b, list all the errors identified and the
technical assistance provided. Indicate whether the
violations identified were repeat violations for the
SFA.
Record only the number of incomplete meals claimed for
reimbursement that will be subject to fiscal action in the
appropriate field on S-1, 16.
Comments:

NSLP

411.

YES

SBP
NO

N/A

YES

NO

N/A

a. Did the school comply with the planned menu for the
review period?
b. If changes are being made to the planned menu, are
the changes acceptable substitutions?
c. If NO to a or b, list all the errors identified and the
technical assistance provided. Record the number
of meals observed missing required meal
components on the S-1, 15. Record only the
number of incomplete meals claimed for
reimbursement that will be subject to fiscal action in
the appropriate field on S-1, 16.
Comments:

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School Level Questions
School_______________________________
Date of Review________________

412.

Did any findings noted in Questions 409 - 411 result in the turning off of the
Performance- Based Reimbursement?

YES

NO

N/A

If YES, record on S-1, 18 and identify the issues in the Comments section.
Comments:

[ ] N/A - THIS SITE WAS NOT SELECTED FOR THE TARGETED MENU REVIEW
Module: Dietary Specifications and Nutrient Analysis
This section is completed at only the site selected for targeted menu review for Review Period.
(To complete this Module of the Administrative Review, reference the following addendums within the
Administrative Review Manual: Meal Compliance Risk Assessment Tool, Dietary Specifications Assessment Tool,
and Nutrient Analysis and Validation Checklist.)
REVIEW PERIOD:

[ ] ON-SITE PORTION OF DIETARY SPECIFICATIONS ASSESSMENT TOOL COMPLETED
603.

Were any areas identified during the off-site review requiring
technical assistance or corrective action prior to the beginning of
the on-site portion of the review?

NSLP
YES

SBP
NO

YES

NO

N/A

If so, explain.
Comments:

604.

If Option 1 is selected to complete the targeted menu review (i.e.
completed the off-site portion of the Dietary Specifications
Assessment Tool), what was the on-site validation of the risk
determination?

Low-Risk

High-Risk

N/A

Comments:

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School Level Questions
School_______________________________
Date of Review________________
605.

Based on the Nutrient Analysis, did the school meet the Dietary
Specifications (Calories, Saturated Fat, Sodium, and Trans Fat) for
the appropriate age/grade group being served?
If NO, list all the errors identified and the technical assistance
provided. Indicate whether the violations identified were repeat
violations for the SFA. Record only the number of meals counted
for reimbursement that will be subject to fiscal action on the S-1,
16A.

IF LOW RISK, CHECK HERE [ ]
NSLP
YES

SBP
NO

YES

NO

N/A

Comments:

Section V: General Program Compliance

Module: Civil Rights
811.

Is the USDA “And Justice for All” poster displayed in a prominent location and visible to
recipients of benefits?

YES

NO

YES

NO

If NO, describe reason.
Comments:

812.

Do meal service observations on the day of review indicate that program benefits were
made available to all children without discrimination?
If NO, explain.

Comments:

Module: SFA On-site Monitoring
YES

901.
a.

NO

N/A

Was the on-site review of the lunch counting and claiming
procedure completed prior to February 1?

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School Level Questions
School_______________________________
Date of Review________________
b.

If NO, was an extension requested and approved by the State
agency?

c.

Was the on-site review of the breakfast counting and claiming
procedure completed prior to February 1?

d.

If NO, was an extension requested and approved by the State
agency?

e.

If NO, explain in comments.

Comments:

902.

a. Was corrective action of the meal counting and claiming procedure
required?

YES

NO

N/A

b. If YES, was corrective action sufficient?
c. Was a follow-up review conducted within 45 days to ensure that the
school implemented corrective action?
If NO to a, b, or c, explain.
Comments:
a.
b.
c.
903.

Does documentation indicate that corrective action was successful?

YES

NO

N/A

YES

NO

N/A

If NO, explain.
Comments:

904.

Was corrective action in the general areas of review that are readily
observable required?

Comments:

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School Level Questions
School_______________________________
Date of Review________________

Module: Smart Snacks in School
1104.

Check below if
foods/beverages
are sold to
students

[ ] N/A

Where are students able to purchase foods during the school day?

Location

If applicable, check below if
foods/beverages sold to students
meet Smart Snacks standards
YES

NO

N/A

Entity Responsible

SFA

LEA

If LEA, contact
name

Cafeteria
Vending
machines
School
store(s)
Snack/coffee
bar
Concession
Stand
Fundraisers
Other
(please
specify)(e.g.,
booster club,
football
coach)

Comments:

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School Level Questions
School_______________________________
Date of Review________________

1105.

a.

Review 10% of the food and beverages sold during the review
month. Do foods and beverages sold to students during the
school day (defined as 12 am on a day of instruction to 30
minutes after the end of the official school day), including a la
carte foods and beverages sold during meal services, meet
Smart Snacks standards? (Includes food items sold during nonexempt fundraisers)

YES

NO

N/A

YES

NO

N/A

YES

NO

N/A

If NO, explain.

b.

If mixed grades, do beverages meet requirements for the
youngest age?

If NO, explain.

Comments:
a.
b.
1106.

a. Does the school hold fundraisers during the school
day where students may purchase food or beverages? If
yes, indicate whether or not the items are Smart Snacks
compliant.
b. If the items are not Smart Snacks compliant, did the school
observe the State-defined limit on fundraisers?

Comments:

1107.

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School Level Questions
School_______________________________
Date of Review________________
Are exempt SBP and NSLP leftover entrees only sold the same day,
or the day after, they are initially offered?
If NO, explain.
Comments:

Module: Water
1300.

Is free potable water available to all students for
lunch (in each location where lunches are served
during the meal service) and for breakfast (when
breakfast is served in the cafeteria)?

NSLP
YES

SBP
NO

YES

NO

N/A

Comments:

Module: Food Safety, Storage and Buy American
1404.

YES

NO

NO

N/A

Is a copy of the written food safety plan site specific and available at each school?

Comments:

YES

1405.
a. In the comments section, list the dates of the two (2) most recent food
safety inspections
b. Are both inspections from the current school year? If YES, move to
Question 1404. If NO, go to c.
c. Were two inspections received in the previous school year? If NO, go to d.
d. Does the SFA have documentation to indicate that the SFA requested two
(2) inspections in the current school year from the applicable agency?

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School Level Questions
School_______________________________
Date of Review________________
If NO to d, explain.
Comments:
a.

Date(s) of two (2) most recent safety inspections:
_____

c.
d.
1406.

Is the most recent food safety inspection report posted in a publicly visible location?

YES

NO

YES

NO

YES

NO

YES

NO

If NO, explain.
Comments:

1407.

Was the SFA’s written food safety plan implemented?
If NO, explain.

Comments:

1408.

Were the selected relevant temperature logs available for review?
If YES, specify which date was selected.
If NO, explain.

Comments:

Date(s) of selected temperature logs: ___________
1409.
Were on-site (or off-site, if observed) storage violations observed? If YES, explain.

Comments:

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School Level Questions
School_______________________________
Date of Review________________

14010.

The number of agricultural food components to review will be determined based on
the SFA storage facility practices used.

YES

NO

YES

NO

a. Does the SFA store a majority of food products used at each school? If yes, review
2-3 items in each food category listed in the instructions at each school reviewed.

b. Does the SFA store agricultural food components used at both individual schools
and off- site storage facilities? If yes, review 1-2 items in each agricultural food
component category listed in the instructions at each site reviewed..
In the comments section list any noncompliant food items that are observed.
Comments:

1411.
a. Did a review of agricultural food components indicate violations of the Buy
American provision (7 CFR 210.21(d)) either during review of products on-site at
reviewed schools or at off-site storage facilities as applicable? If yes, proceed to b, if
no proceed to next question.
b. Is there documentation to determine if domestic alternatives were considered
and if an exception was granted by the SFA because:
The agricultural food component is not produced or manufactured in the U.S. in
sufficient and reasonably available quantities of a satisfactory quality; or
• Competitive bids reveal the costs of domestic agricultural food components
are significantly higher than the non-domestic ones.
The exception was related to the domestic food as prohibitively costly or limited
quantity availability. (Inform the SA staff conducting the procurement review of
any findings to identify if the Buy American provision is in the SFA solicitation,
contract, and/or bid specifications.
Comments:

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School Level Questions
School_______________________________
Date of Review________________
Module: Reporting and Recordkeeping
1502.

Are records retained for 3 years after the final Claim for Reimbursement for the fiscal
year or until resolution of any audits? If NO, describe reason.

YES

NO

Comments:

Section VI: Other Federal Program Reviews
Module: Afterschool Snack Program

[ ] N/A

*See Supplemental Afterschool Snack Program Administrative Review Form.
1700.

Were any areas identified requiring technical assistance or corrective action?

YES

NO

If YES, explain.

Comments:

Module: Seamless Summer Option

[ ] N/A

*If a review of SSO is required, complete Supplemental Seamless Summer Option Administrative Review Form

Module: Fresh Fruit and Vegetable Program

[ ] N/A

Review Period
1900.

Is the school on track to spend no more than 10% of its total grant on administrative
costs?

YES

NO

If NO, explain.
Comments:

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School Level Questions
School_______________________________
Date of Review________________
1901.

Did the cost documentation provided support the school’s FFVP claim for
reimbursement?

YES

NO

YES

NO

If NO, explain. Record any unsupported Program costs in the Comments section.
Combine amount with any applicable amount in 1902 and record on the S-1, 21.
Unsupported costs and/or unallowable costs must be recorded on the Fiscal Action
Workbook.
Comments:

1902.

Is the cost documentation for allowable FFVP costs?
If NO, explain. Record any unallowable Program costs in the Comments section.
Combine amount with any applicable amount in 1901 and record on the S-1, 21.
Unsupported costs and/or unallowable costs must be recorded on the Fiscal Action
Workbook.

Comments:

Module: Fresh Fruit and Vegetable Program

[ ] N/A

Day of Review
1903.

Is the FFVP available to all enrolled children at no cost?

YES

NO

YES

NO

YES

NO

If NO, explain.

Comments:

1904.

Is the FFVP offered during the school day, but outside the meal service times of the
NSLP and/or SBP?
If NO, explain.

Comments:

1905.

Is the FFVP widely publicized within the school?
If NO, explain.

Comments:

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School Level Questions
School_______________________________
Date of Review________________

1906.

Were any of the following unallowable products offered during the FFVP meal service:
frozen, canned, and other types of processed fruits/vegetables; fruit/vegetable juice,
nuts, cottage cheese, trail mix, fruit/vegetable pizza, smoothies, fruit strips, fruit drops,
fruit leather, jellied fruit, or carbonated fruit?

YES

NO

YES

NO

YES

NO

YES

NO

If YES, explain.
Comments:

1907.

a. Did the school choose to offer dip with the day’s offering?

b. If YES, was it fat-free or low-fat, no greater than 2 tablespoons, and provided for
vegetables only?
If NO, explain.
Comments:

1908.

a. Is a cooked vegetable offered today?
If YES, answer b and c.
b. Is it included as part of a nutrition education lesson?
c. Is this the only offering of a cooked vegetable this week?
If NO to b or c, explain.

Comments:

1909.

Are teachers who are in the classroom with students during the FFVP meal service the
only adults provided with fresh fruits and vegetables?
If NO, explain.

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School Level Questions
School_______________________________
Date of Review________________
Comments:

1910.

Did the FFVP meal service follow HACCP principles and applicable sanitation and health
standards, including the handling of any left overs?

YES

NO

If NO, explain.
Comments:

Module: Special Milk Program

[ ] N/A

*See Supplemental Special Milk Program Administrative Review Form.
2000.

Were any areas identified requiring technical assistance or corrective action?

YES

NO

If YES, explain.

Comments:

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