Meal Counting and ClaimingNuts and Bolts of School NutritionAugust 5, 2015

Presented by:Doreen Iovanna, M.Ed., LDN, DT

Office for Nutrition, Health & Safety

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What is the Purpose of an Accurate Meal Counting and

Claiming System? To ensure the validity of the School Food

Authority’s (SFAs) monthly claim for reimbursement

To prevent a Performance Standard I Violation

But most importantly…..

To Avoid Fiscal Action

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Performance Standard I7 CFR 210.18 (2)i

All free, reduced price and paid lunches claimed for reimbursement are served only to students eligible for free, reduced price and paid lunches, respectively

Lunches are counted ,recorded, consolidated and reported through a system which consistently yield correct claims

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What are the Components of a Successful Meal Counting and

Claiming System?

Eligibility Documentation

Point of Service (POS) Meal Counts

Collection Procedure

s

Reports

Internal Controls• Edit

Checks• Monitoring

Claim for Reimbursement

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Video 1 – Making it CountDeveloping Acceptable Meal Counting and

Collection Procedures

http://www.makingitcount.info/training/module-7

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Income eligibility documentation must be on file

for each student receiving a free or reduced- price meal

Provides the number of eligible students in each category (free, reduced and full price)

Accurately reported on the medium of exchange at the point of service

Supports your claim for Federal reimbursement of meals

Eligibility Documentation

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What are Point of Service (POS) Meal Counts?

Meal counts must be taken at the point of service (POS) The point at which staff determines that a

reimbursable meal has been served to an eligible child or student

Common POS locations are school cafeterias Alternate POS include classrooms and hallways

Count: Reimbursable meals By category Each day

Prevent Overt Identification

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What is Overt Identification?

Overt identification is when a child is openly or physically identified as receiving a free or reduced meal

Some examples are: Separate meal service lines for students who are eligible for

free, reduced-price and paid meals Color-coded tickets for free/reduced eligible students Serving different meals Simple roster coding methods, such as F,R,P; or 1,2,3

A casual observation of your point of service should never be able to tell who is free, reduced, or paid

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When Are Point of Service Meal Counts Required?

Breakfast Lunch After School Snack At Risk Snack & Supper

All meal counts must be conducted without overt identification

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Coded RostersAcceptable Coding Examples:

Coding by series: (1000 sequence for free, 2000 sequence for reduced and 3000 sequence for paid)

Coding by student ID number: Using the last digit in a student’s ID number to indicate the appropriate eligibility category (0 for free, odd number for reduced and even number for paid)

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What is a Medium of Exchange? The medium of exchange includes any type

of ticket, token, I.D. , name or number that is issued to the students for obtaining the meals

Should allow for updates on a daily basis (noting transfers, withdrawals and changes in status due to verification, etc.)

The meal count/collection system selected must ensure that the medium of exchange prevents overt identification of free and reduced-price meal recipients in the coding, distribution and collection processes

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1. Verbal Identifier/Roster

2. Coded ticket/token

3. Coded I.D. cards

4. Cash Register Code System

5. Prepaid List

6. Computerized Bar Code

7. I.D. Cards

Acceptable Mediums of Exchange Systems:

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Verbal Identifier/Roster

Advantages Disadvantages

•Cannot be stolen, lost or destroyed•Documentation of meal count is produced during meal service as names/numbers are checked off on a roster or number sheet. If used with a number sheet, may be a fast method

•Can be used by another student or twice by the same student if more than one serving line.•Coded roster sheet is time consuming for cashiers using manual system.

Examples include: name checklist, class list, number list

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Examples of Rosters

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Coded Ticket/TokenAdvantages Disadvantages

•When collected at point-of-service, provides a means of physically counting meals by category.•When used in small to medium schools, counts by category can be completed quickly after the meal service

•Can be destroyed, transferred, lost, stolen or sold.•In large schools, too cumbersome to collect and count all tickets or tokens by category after the meal service.•If not coded properly, may result in overt identification.

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Automated PIN PadAdvantages Disadvantages

•Provides accurate count and saves time; compiles meal count by category at the same time the students are counted•Students do not have to be in the line by classroom; lines moves at the same pace whether the cashier knows all of the students names or not•Prevents overt identification on the line•Provides automated reports

•Students may forget their numbers, thus slowing the line•Start-up and operating costs may be high• If more than one service line, there may be two meals claimed if the electronic machines are not linked

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Coded Bar LineAdvantages Disadvantages

•Provides accurate count and saves time; compiles meal count by category at the same time the students are counted.•Students do not have to be in the line by classroom; lines moves at the same pace whether the cashier knows all of the students names or not•Prevents overt identification on the line.•Provides automated reports.

•Can be lost, destroyed or transferred.•Start-up and operating costs may be high.•If more than one service line, there may be two meal claimed if the electronic machines are not linked.

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Activity 1:Acceptable Meal Counting Systems are?

YES NO 1. Claims based only on meal counts taken in the morning in the classroomor at any other location before the meal is served?

 YES NO 2. Claims based on attendance records? YES NO 3. Meal counts based on the number of tickets or tokens sold and distributed or the number of meals paid in

advance?

YES NO 4. The number of free and reduced-price meals claimed based on the numberof students eligible to receive such meals?

 YES NO 5. Meal counts by category taken at the beginning of the serving line without

checking that the meals served are reimbursable?

YES NO 6. Meal counts by category based on visual identification of students withno backup system available for persons not familiar with the students; e.g.,checklists?

 YES NO 7. Meal counts based on tray or plate counts? YES NO 8. Back-out systems used that subtract one number (e.g., number of free and

reduced-price meals) from the total count to get another number (e.g., thenumber of full-price meals)?

 YES NO 9. The students who are eligible for meal benefits overtly identified? YES NO 10. A system that does NOT yield a reliable, accurate count of meals served by category?

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Unacceptable Meal Count Systems

Meal count systems that are not acceptable because they do not provide a

daily count at the point-of-service of reimbursable meals, byCategory include: Attendance countsTray, plate or entree countsClassroom counting Prepaid/charged meals counted on day paid Second meals claimed for reimbursement Ineligible persons claimed for reimbursement Cash converted to meals A la carte items claimed for reimbursement Category/cash back-out system Delivery counts of meals produced off-site Visual identification without backup

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Determine which type of meal counting system is best for each site. It may vary from site to site. It may also vary from breakfast to lunch.

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Eligibility Documentationand

Meal Counts

Residential students only – RCCI-1 Form: Record of enrollment for free eligible students based on household of one

Day students – Eligibility Roster: Indicating free, reduced and paid eligibility based on meal benefit applications or direct certification

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Meal Count Roster

Meal Count Roster- must be used when claiming day students as free, reduced, or paid. Counts must be totaled daily across eligibility category. Eligibility code prevents overt identification at POS.

Example:

2149,

5315

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RCCI-1 Enrollment Form

RCCI-1 form for each residential facility/site Update as residents enter and or withdraw Maintain separate RCCI-1 for each Fiscal Year

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What are Meal Counting and Claiming Collection Procedures?

Collection procedures refers to all the steps within the meal count system involved in paying for meals and issuing and collecting the medium of exchange.

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Meal Counting and Collection Procedures Self Assessment :

What are your current meal counting method(s) used for breakfast and lunch?

Are meal counts conducted at POS? Are all staff members following them? Are they accurate for each site? Policy for adult or visitor meals? Procedure to count field trips? Procedure to count student workers’ meals? Procedure for handling/counting of second

meals?

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How is the medium of exchange non-overtly coded for free, reduced price and full price?

What safeguards are used to prevent your medium of exchange from being duplicated, used by an unauthorized person, or used twice in one meal service?

Who distributes the medium of exchange? Where and when?

How is the medium of exchange collected at point of service? Include who collects and at what place in the serving line. Who insures that tickets, if used, are not used twice?

How is overt identification avoided for reduced price eligible students who choose to pay in the line?

Meal Counting and Collection Procedures Self Assessment :

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Meal Counting and Collection ProceduresImplementation Brainstorm

Current Challenge:

Future Expectations:

Implementation BrainstormWhoWhatWhenWhereHow

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Video 2 – Making it CountConsolidation and Reporting

http://www.makingitcount.info/training/module-8a/

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Meal Count Consolidation Reports

•Daily Potential Income Sheet•FP-9 form

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Daily Potential Income Sheet Daily Cash/Cash Reconciliation Sheet

Tracks daily sales by category Free, reduced, paid Breakfast, lunch, snack, special milk A la carte Adult sales (including meals tax) Pre-payments Cash reconciliation

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Daily Potential Income Sheet

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FP-9 Meal Count Sheet

FP-9 for every school site Record meals by eligibility Edit checks- A,B,C and D Signature of site/facility representative Monthly submission to person consolidating

claim

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Reference: ESE Document and Reference Library – NSLP National School Lunch Program - FP-9

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Activity 2Complete the following:

Part A: Attendance Factor

Part C: February 28, 2011 F = 80 R= 15 P =175

Part D: Average Daily Participation

Part B: Edit Checks Do free counts exceed

approved free applications on file?

Do reduced counts exceed approved reduced applications on file?

.944

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Meal Count Consolidation Self Assessment

Meal count consolidation form(s) and procedures which include staff responsibilities for the tasks identified:

Daily Potential Income FP-9

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Meal Count ConsolidationImplementation Brainstorm

Current Challenge:

Future Expectations:

Implementation BrainstormWhoWhatWhenWhereHow

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Internal Controls The SFA must establish internal controls

to ensure that an accurate claim for reimbursement has been made by: Completing daily edit checks Monitoring

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Edit Checks The purpose of the edit check procedure

is to identify errors in the schools’ lunch counts and/or problems with the meal counting and claiming procedures so that necessary corrections are made

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Edit Checks

USDA regulations require SFAs to complete an edit check for each of its schools that participate in the NSLP prior to consolidation of the daily lunch counts for the monthly reimbursement claim

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Edits Checks USDA’S REQUIRED EDIT CHECK PROCEDURES FOR EACH SCHOOL

1. Obtain and record the highest number of students in each category

2. Compute the attendance factor3. Multiply the number of enrolled children approved in each

meal category (free, reduced-price and paid) by the monthly attendance factor

4. Compare these numbers; know as attendance adjusted eligible figures to the daily free counts of free, reduced-price and paid meals

5. Provide written justification next to the day where any category count exceeds the attendance-adjusted number. (Sample justification could be meal participation increased due to a pizza day or special promotion.)

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Highest # of Student Attendance Factor Highest # of Lunches

Approved in Month (average daily attendance Expected for Any

÷ school enrollment) Serving Day

 Free ________________ X ______________ = ________________ Reduced-Price ________________ X ______________ = ________________

Paid ________________ X ______________ = ________________

Edit Check:Attendance Adjusted Eligible

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Highest # of Student Attendance Factor Highest # of Lunches

Approved in Month (average daily attendance Expected for Any

÷ school enrollment) Serving Day

 Free ______112_______ X _____.944_________ = __105.7 or

106___ Reduced-Price _______25_______ X _____.944_________ = ___23.6 or

24__ Paid ______403______ X _____.944_________ = _380.4 or

380__

Edit Check:Attendance Adjusted Eligible•School’s highest number of students approved for free meal benefits during the month: 112•School’s highest number of students approved for reduced price benefits during the month: 25•School’s highest daily enrollment for students with access to the lunch program: 540•School’s highest number of students in the paid category: 540 – 137 = 403•School’s average daily attendance: 510 School’s attendance factor: 510 ÷ 540 = .944

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Other Edit Checks Patterns or repetition of numbers Counts which equal the number of eligible's Counts equal to the number of meals

delivered Identical counts on certain days (like every

Monday or at breakfast and lunch) All of these are red flags which may tell

you that you need to investigate further

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Monthly Edits Check Meal counts on the Claim for

Reimbursement must also not exceed the number of children approved in any eligibility category multiplied by the operating days within the month

Example (FP-9 activity):112 Free x 15 operating days = 1680 max meals

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Activity 3– Making it CountMaking the F-9 Count

http://www.makingitcount.info/training/module-8a/activity/

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Self Assessment Edits Checks

Procedures for conducting edits checks of daily meal counts, including staff responsibilities and when these checks are completed?

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Edit Check ProceduresImplementation Brainstorm

Current Challenge:

Future Expectations:

Implementation BrainstormWhoWhatWhenWhereHow

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Video 3 – Making it CountAccuclaim Monitoring Report

http://www.makingitcount.info/training/module-8b/

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Site MonitoringAccuclaim: (Accurate Claim) SFAs must monitor the lunch service at all

sites to evaluate meal counting procedures by February 1 each year. Monitoring of breakfast is also recommended

SFAs participating in the After School Snack Program must monitor snacks twice per year

( the beginning the first 4 weeks of school and one other during the year)

SFAs should record monitoring activities on required forms located in the document library

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Site MonitoringMonitors should ensure that sites do not claim the following meals/food: Adult Meals Second meals eaten by eligible students Suppers or dinners (third meal of the day) unless

the SFA participates in the Child and Adult Care Food Program (CACFP) At-risk Afterschool Program

Snacks served on ineligible days Meals not meeting the meal pattern Meals served outside the required meal periods,

unless otherwise approved A la carte items

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Reference: ESE Document and Reference Library – NSLP National School Lunch Program

Accuclaim On-site Review Checklist

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After School Snack Monitoring Form On-Site School Review Form for Snacks In After School Care Programs

 To be used for required self review/NOT to be submitted to any agency.Review must be completed for each school twice each school year.The first review must be conducted within the first four weeks of operation.  __________________________________ ________________________ SCHOOL DATE

Please check one: ____ The after school snack counting and claiming system was reviewed and found to be IN COMPLIANCE with 7 CFR 210.9(c) of the regulations of the USDA Food and Nutrition Service. The snack menus met the meal pattern regulations correct claims for reimbursement.  ________________________________________ Reviewer ---------------------------------------------------------------------------------------------  ____ The after school snack counting and claiming system was reviewed and found to be in NON-COMPLIANCE with 7 CFR 210.9(c) of the Regulations of the USDA Food and Nutrition Service. Please describe the corrective action taken. __________________________________________________________________ __________________________________________________________________ __________________________________________________________________

__________________________________________________________________

__________________________________________Reviewer  

Reference: ESE Document and Reference Library – NSLP National School Lunch Program

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Staff Training & Professional Development

All SFAs should have a training plan for meal counting procedures. The plan should include: Annual training for staff in key positions Ongoing training for new staff with

identified problems Annual review of all meal counting

procedures Maintain agenda and sign-in sheets

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Professional Standard Final Rule Effective July 15, 2015

Training information can be found at:

http://professionalstandards.nal.usda.gov

Professional standard information can be found at:

http://healthymeals.nal.usda.gov/hsmrs/ProfStandards/profstandards_flyer.pdf

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Monitoring and Training Self Assessment

What are your current procedures for conducting site monitoring?

Current training practices? Who conducts trainings? Who needs to attend?

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Monitoring & TrainingImplementation Brainstorm

Current Challenge:

Future Expectations:

Implementation BrainstormWhoWhatWhenWhereHow

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Take A Final Look Before Hitting Submit

Make sure edit checks have been conducted on each school’s counts

Consolidate daily meal counts to monthly site totals by meal

Once you’ve completed the edit, conducted your comparisons, found no problems, you can submit your claim

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School Site Information For All Schools IncludingRCCI’s with Both Day and Residential Students

Input counts by site (under school selection)

Information from site FP-9 is used to fill out the claim for reimbursement

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Remember:Meal Counts Records Retention SFAs must retain original meal count records

for the current day and month by site

SFAs must retain all meal counts records, including rosters and site monitoring reports for three (3) years after the submission of the final claim for reimbursement for the fiscal year, plus the current fiscal year’s records.

If there is an open audit for any fiscal year, all records must be retained until closure notification of the audit.

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Sometimes You Just Have To Put Your Hand On Your Hip…

To make sure it’s right!

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For All You Do!

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Questions

Created in Partnership: 2014 Meal Counting, Claiming and Reimbursement-A. Chisholm and K. Kefalas