For New Child Nutrition Directors
A publication of ESC Region 11 Child Nutrition • October 2021
WHAT IS ONSITE MONITORING?
The Accuclaim regulations require that each Contracting Entity (CE) with more than one feeding site perform an onsite review of the meal counting and recording procedures in each site serving lunch prior to February 1 of each school year, and 50% of sites operating a School Breakfast Program (every site must be reviewed every other year). TDA has developed a prototype monitoring form for CEs to utilize. A CE is expected to fully complete the onsite monitoring form and take action to improve its program based on the information reported on the self-monitoring form.
CEs that operate more than one site are required to conduct onsite reviews, which include ensuring that the following requirements are met:
- The counting system is consistent with the CE’s policy statement included in its approved Policy Statement for Free and Reduced-Price Meals, Attachment B: Meal Count/Collection Procedure(s).
- The counting system, as implemented, yields the actual number of reimbursable free, reduced-price, or paid meals served for each day of operation.
- The counting system prevents overt identification of students receiving free and reduced-price meals.
The system provides for adequate monitoring to ensure that only one reimbursable meal per eligible student per meal service are counted. If the review discloses problems with a site’s meal counting or claiming procedures, the CE must ensure that the feeding site develops and implements a corrective action plan (CAP). The plan should be in writing and developed jointly by the school nutrition program (SNP) director and the CE’s foodservice supervisor, director, or whoever performed the review. It should detail the corrective action necessary to bring the feeding site into compliance and assign responsibility for implementing the plan. The CE must conduct a follow-up onsite review within 45 calendar days of the onsite monitoring review to determine if the corrective action resolved the problems and take additional actions as necessary to correct the issue.
ONSITE MONITORING SPECIAL PROVISIONS
Onsite Monitoring Form | Provision 2 (P2), Year 2 and Following Years: This form is to be completed by the CE for sites in the second, third, and fourth year of P2 operation annually by February 1st of each year for each P2 school operating NSLP and at least 50% of the sites operating SBP. CEs must review the breakfast operation at every site at least once every two years for sites operating SBP in the second, third, and fourth year of P2 operation.
P2 year one, you will use the regular NSLP Onsite Monitoring form.
ONSITE MONITORING AFTERSCHOOL SNACK PROGRAM
CEs that administer ASCP are required to use the ASCP form and process.
- The first monitoring or review must occur during the first four weeks of snack service.
- The next onsite monitoring review must occur before the school year is completed.
- The onsite monitoring review should be completed by a food service staff member.
- The onsite monitoring review records must be retained and made available for USDA and/or TDA review.
At-Risk CEs that administer CACFP At-Risk must use the CACFP At-Risk form and process to meet this requirement.
- The CE must monitor or review CACFP At-Risk sites at least three times each year with no more than six months between reviews.
- The first monitoring review must occur within the first four weeks of operation.
- The CE must conduct at least two of the three monitoring reviews unannounced.
- The CE’s monitor or reviewer must include the observation of meal/snack service in one of the unannounced reviews.
- The CE’s monitor or reviewer must vary the timing of the unannounced reviews so that review times are unpredictable.
- The onsite monitoring records must be retained and made available for USDA and/or TDA review.
ONSITE MONITORING SUMMER
Onsite Review SFSP regulations include additional review requirements, such as an onsite review during the first week of operation. For CEs that also operate NSLP/SBP, the onsite review during the first week of operation is waived if the CE is a returning CE in good standing. A CE that is in compliance with all program requirements is considered to be in good standing. If a CE’s funds are on hold, it is not in good standing.
ONSITE MONITORING FSMC
The CE must monitor the FSMC’s operation of the program on a routine basis. This includes onsite monitoring of the counting and claiming system as well as monitoring the overall operation of the program. TDA has developed the Food Service Management Company (FSMC) Monitoring Form for this purpose; however, the CE may use its own form as long as it includes all of the same information as the TDA form.
CEs with more than one school must conduct an annual onsite review of each school prior to February 1st of each school year to observe the school’s counting and claiming procedures. This includes any schools where an FSMC operates; CE staff must conduct the required onsite reviews.
If review identifies a problem with a school’s meal counting or claiming procedure, the CE must take the following actions:
- Implementation of corrective action
- Follow-up onsite reviews within 45 days of the review to determine if the corrective action resolved the problem(s).
NEW! CEs must complete FSMC onsite monitoring form for one site, once a quarter. In addition, the regular onsite monitoring forms need to also be completed for every site annually.
CE must monitor the following areas of program operation:
- Competitive Food Nutritional Standards
- Documentation for meal service, including, but not limited to, menus, standardized recipes, production records, reimbursable meal service
- Documentation supporting reporting
- Engagement of advisory committee
- Financial and accounting practices, including, but not limited to, credits, rebates, discounts, and USDA Foods values
- Health and sanitation
- Implementation of the CE’s Policy Statement for Free and Reduced Price Meals Attachment B: Meal Count/Collection Procedure(s)
- Menus, meal pattern, dietary specifications, and food service
- Nonprogram revenues and expenses
- Paid lunch equity calculations, if applicable
- Records retention
- Terms and conditions of the contract
- Use of USDA Foods
ONSITE MONITORING SCHEDULE
CEs are required to conduct onsite monitoring reviews of serving sites on the following schedule:
National School Lunch Program
Standard Counting and Claiming Required: At least once annually prior to February 1st of each school year
Form: Onsite Monitoring Form—National School Lunch Program (NSLP)
National School Lunch Program Community Eligibility Provision (CEP)
Required: At least once annually prior to February 1st of each school year
Form: Onsite Monitoring Form | Community Eligibility Provision (CEP)
National School Lunch Program | Provision 2 (P2)
Required: At least once annually prior to February 1st of each school year
Form: Onsite Monitoring Form | Provision 2 (P2)
School Breakfast Program
Required: At least once prior to February 1st of each school year for 50% of the sites operating SBP each year (i.e., every site is reviewed every other year)
Form: Onsite Monitoring Form | School Breakfast Program (SBP)
Afterschool Care Program (ASCP) and Child and Adult Care Food Program At-Risk (CACFP At-Risk)
Required: For ASCP, within the first four weeks of starting snack service each school year and a second time before the end of the school year; for CACFP At-risk, at least three times each year with no more than six months between reviews
Form: Onsite Monitoring Form | Afterschool Care Program (ASCP) and Child and Adult Care Food Program At-Risk (CACFP At-Risk)
Seamless Summer Operation
Required: At least once annually during operation
Form: Onsite Monitoring Form | National School Lunch Program (NSLP)
Required: One site, once a quarter.
Form: Onsite Monitoring Form | Food Service Management Company (FSMC)
- Food and Nutrition Agreement — A CE’s Food and Nutrition Agreement (Agreement) and all Agreement amendments must be retained for the duration of the agreement between TDA and the CE. When there is a termination of the Agreement, the Agreement and all Agreement amendments must be retained for five years after the Agreement has been terminated for public and charter schools or three years for private schools, RCCIs, and other organizations.
- Certificate of Authority — All valid Certificates of Authority (FND-101) or (FND-135) must be retained for the duration of the agreement between TDA and the CE. Any Certificate of Authority that has been rescinded or terminated must be retained for five years for public and charter schools or three years for private schools, RCCIs, and other organizations after it has been rescinded or terminated.
- Administrative Review Findings — If a CE has audit or administrative review (AR) findings, unresolved corrective action documents/plans, or other required response for corrective action required by TDA, any records related to these events must be maintained until the resolution of the issue(s). In these cases, the records must be retained beyond the number of years required.
- Documentation Supporting Approval to Operate under a Special Provision — When a CE uses data to establish base year percentages for eligibility categories or to demonstrate that there has been no change in the economic situation of the student population, the CE must retain records demonstrating the accuracy of this information for as long as the site operates the special provision program, plus an additional five years if the site is a public or charter school or an additional three years if the site is a private school or RCCI.
Teachers can also hand out treats outside of the cafeteria if given for free and it does not have to be smart snack complaint. For more information, read section 22 ARM.
Food and/or Beverages Given to Students
If a student is given food and/or beverage items at no charge (no form of payment, donation, or other contribution exchanged for the item), these items are not subject to the Competitive Food Nutrition Standards.
Be sure to follow local wellness policy guidance for your district and campus accordingly.
In case you missed it:
17 New Directors' Q&A for verification and all things Child Nutrition (virtual)
26 OVS/Food Buying Guide/MENU Module (in-person & virtual)
2 Meal Patterns/Menu Planning (in-person & virtual)
11 The Monthly Rewind (virtual)
12 The Dispatch: Wellness Policy
6-8 Food Safety for Child Nutrition (Servsafe)
9 The Monthly Rewind (virtual)
14 The Dispatch: Meal Pattern & Buy American
This newsletter is funded by the USDA/TDA. This institution is an equal opportunity provider.