2018 School Meal Programs Annual Updates Webinar
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2018 School Meal Programs Annual Updates Webinar


Okay. So thank you for attending to hear annual updates to the school meal programs. My name is Wendy Barkley, I’m the supervisor for school meal programs at OSPI Child Nutrition Services. I’m going to be joined for a portion of the presentation by our interim director Leanne Eko and we’ll both get started then with the presentation. So this presentation is a compilation of new guidance received during school year 17-18, and program changes for the 18-19 school year. We hope you’ve enjoyed our annual training mini conference for basic training for school meal programs today. We’re trying something new with our annual update training this year. While the crowd in the room is attending in person, we also have sponsors attending remotely as a webinar. And, this training is being recorded so that information can be shared with sponsors unable to attend today. As a result, we have a few housekeeping items to cover. Our plan is to present the slides to you. There are ninety one slides. So I’m estimating about an hour and a half for the slides. When we finish the slides we’ll stop recording. Then we will answer questions and discuss topics in more detail. Those attending in person have a copy I think of our slides, okay. Write your questions down as we go and we’ll take those questions after we’re finished. And sponsors participating as a webinar received copies of the slides and will be able to ask questions using the Q&A feature. We will review the questions on the Q&A periodically and answer those questions too at the end of the slide session. You received an additional handout to help with House Bill 2610. And we’ll talk about how to use the handout after the recording too. For those in the audience, the presentation will be very scripted. I’ll be reading from my speaker notes. And again, thank you for attending and let’s get started. Our main objective for the presentation today is to explain changes to school meal programs. Sometimes change is difficult and sometimes change makes what we do easier. Although, altogether change is the only constant in life. So what are the changes? There were twenty one school policy memorandums issued by USDA Food and Nutrition Service during school year 17-18. USDA uses school policy memorandums to provide guidance about meeting federal regulations and announcing new regulations. Child Nutrition Services communicates these policies to you in the form of CNS updates via our GovDelivery mail system. In addition to the Federal policy- er, Federal level policy memorandums there were two new state laws passed during the 2018 legislative session. It’s been at least ten years since our school meal programs were affected by a new state law, and the last state law passed was to provide state monies- Meals for Kids Grants -which are funding for the reduced price state co-pay, breakfast assistance, and the meals for kids breakfast and summer food grants. As there are federal and state changes, there are also local level changes. At the end of our session today, we’ll cover some local Child Nutrition Services changes. And so today we’re going to start with the state level changes. The state legislative season brought two new laws for school meal programs. Both new laws have a direct effect on the programs operated in public schools on a daily basis. Keep in mind that these state laws do not affect a couple of our sponsor categories. Private schools, non-tribal compact schools, and residential childcare institutions. House Bill 2610 was passed and may commonly be referred to as a law to prevent a meal shaming. House Bill 1508 was passed and may be commonly referred to as BAB or Breakfast after the Bell. Both are impactful and will change your school food service operations. Both seek to improve access to school meals and better outcomes educationally for students in Washington State. So I think we’ll check off House Bill 1508 first. House Bill 1508 is Breakfast after the Bell, and Breakfast after the Bell is designed to promote student health and readiness through meal and nutrition programs. Predominantly breakfast for school meal programs, there are a few other parts of the bill that touch a school through encouragement of school gardens and farm to school programs. This bill has been introduced in the legislature for about the past four years. Each year that it didn’t pass it was changed a little bit and re-introduced, finally passing in the 2018 legislative season. School meals provide many benefits for students and these benefits cross over into educational success for students. A breakfast for students every day can help. Beginning school year 19-20, public schools with 70% or more of the enrollment eligible for free or reduced-price meals will be required to implement a Breakfast after the Bell program. Keep in mind that the Breakfast after the Bell is for a school building or school site. For a district, it’s quite possible only some schools will be required to implement Breakfast after the Bell. October building data will be used as the marker for 70% or more free and reduced price eligible students. Implementation of BAB for school year 19-20 will be based on October 2018 building data. The other areas of the bill include giving preference to foods that are local and grown in Washington. Breakfast after the Bell means a breakfast that is offered to students after the beginning of the school day and may include grab-n-go, second chance breakfast, and breakfast in the classroom. Schools required to implement Breakfast after the Bell may choose any model described above for any grade level. Schools should choose the model that best fits their needs, and schools may still offer breakfast before the bell. The period of time designated for students to participate in Breakfast after the Bell may be considered instructional hours if students are provided the opportunity to engage in an educational activity. The bill also designates requirements for OSPI Child Nutrition Services to develop and distribute best practices, provide technical assistance to help local education agencies identify breakfast foods that are lower in sugar for school breakfast menus. Also the legislature appropriated 1.2 million dollars for start-up grants. These grant funds are non-competitive. Child Nutrition Services will be hiring a full-time program specialist to implement Breakfast after the Bell, distribute grants, and conduct other duties outlined in the bill. Once this position has been hired and trained more information will be communicated to include the grant applications. Look for more information later in the school year. A little more about our plans: Training and technical assistance as well as best practices for systems including point of service meal counting and offer versus serve in classroom settings will be a focus. After October building data has been submitted, finalized, and posted, we’ll be able to identify schools that will be required to implement a Breakfast after the Bell program. October data is finalized and posted no later than February 15th of each year. However, since October data is reported on the October claim for reimbursement, schools will know as early as October who may be required to participate. The grant application and guidelines will take some time for us to develop. We will be consulting stakeholders in the development of the grant, dispersing money to schools to help with start-up costs in a manner that is fair and equitable and uses the grant dollars best possible ways. The grant will be non-competitive and will be available in the iGrant system. Grant funding can be used for equipment purchases, training, additional staff costs, as well as custodial services and supplies. We’ll have to follow state fiscal year guidelines for spending state dollars, and schools will need to follow proper procurement procedures when purchasing equipment. And now we’re going to shift gears to the House Bill 2610. As Wendy mentioned, this bill was called the Hunger-free Student Bill of Rights, more commonly known as the anti-shaming bill. So at the heart of the bill is ensuring access to meals for all students and preventing overt identification of students not able to pay for meals. So you got in your handout a reference sheet that is regarding the Hunger-free student Bill of Rights. We will be posting it also on our web pages shortly. So if we could take a minute to go through the reference sheet. So under the requirements section the first one is we want to remind you that although the state law is in effect that we also still fund- follow- fall under the purview of USDA rules, which continue to require you to have a meal charge policy and make sure that you clearly communicate that charge policy with your families. The requirement of the state law includes direct distributing meal applications annually. That is encompassed in what you normally do in distributing application materials to all families. The second requirement is that you should- shall submit meal applications for students that are likely eligible. We wanted to remind you that that is also a USDA requirement and that you should follow the regulations of USDA about when it’s appropriate to do so. The state law does require that you conduct direct certification monthly. That is a change from federal requirements of three times a year so please do plan to start doing that this school year. Again you must conduct direct certifications monthly. The next requirement is really at the heart of the bill, and it’s that students may not be overtly identified. This requirement will include training your frontline staff and how they respond to students and how they inform students of low meal balances. So the requirements of the state law do say that you may not notify students under the age of 15. You’re not allowed to remove trays or identify students with negative balances, and know that if you do provide an alternate meal that you must do so in a way that does not overtly identify a student. Lastly the bill identifies that you must implement measures to ensure eligible students receive meal benefits, including setting up internal processes to track and monitor notification efforts and utilizing your point of meal service counting systems to track charged meals. We’d also like to point out it’s incredibly important to get the support and direction of your administration and your legal team at your school district when you’re deciding how to implement the state law. Again you have an additional handout that we’ll be talking about during the question and answer period. As a reminder what can you do about this law? First of all again meet with your administration, your school board, your legal counsel to make sure that they’re aware of the law and what processes you will take and set up in your district. Make sure and train your staff about the overt identification, and again that they cannot notify students under the age of 15 of a negative meal balance. Make sure and track your meal charges. It will be incredibly important for us to have this data and for you to be able to share that again with your school board and your state legislature about the effects of this bill. It’s also important to track the total number of free and reduced price meal applications. Again this will help tell the story and it will help us show if there’s been an impact to this. And they- again we’ll discuss more of this but it’s important to present what you find and the impact of this bill to your state legislature. Okay now we’ll move on to the federal program updates. Did you know you could begin verification before October 1st? USDA has provided guidance on this topic and school policy memorandum 42-2017. Let’s take a brief look at the guidance. Beginning verification before October 1st allows local education agencies (LEAs) to begin verification with the application approval process at the start of the school year. This could be a time saver, as the verification tasks are distributed over a longer period of time. It’s best for LEAs with a large verification sample size. The same requirements apply to rolling verification whether using 3% Focused, 3% Random, or 1 plus 1/2 percent sample. As well, all other requirements for verification apply like providing the household with a follow-up notice changing benefits within the required timelines etc. Notice the last bullet point. Our review of the guidance has prompted us to let you know that if you’re interested in conducting rolling verification, please consult your program specialist. It can be tricky and we want to be sure you can accurately carry out the rolling process. Being organized in your approach is key, and a well thought out a process before you begin is a recipe for success. Resources are available on our website for both the standard verification process and getting verification before October 1st. Please use our materials and consult your program specialist before beginning rolling verification This past year USDA released a verification toolkit to help local education agencies improve response rates. The toolkit contains resources to not only help improve non-response rates but also to improve efficiency of the process. This toolkit may be a useful reser- resource for your verification process. The US Department of Agriculture’s School Meal Programs aim to provide all participating children, regardless of background, with the nutritious meals and snacks they need to be healthy. Consistent with federal law and program regulation, this includes ensuring children with disabilities have an equal opportunity to participate and benefit from the National School Lunch Program (NSLP), the School Breakfast Program (SBP), the Fresh Fruit and Vegetable Program (FFVP), the Special Milk Program (SMP), and the afterschool snack component of the NSLP. Beginning last year with update training, Child Nutrition Services started training on new guidance for accommodating children with special dietary needs. In addition USDA released the 2017 Edition of Accommodating Children with Disabilities in the School Meal Programs. The next few slides are a review of the topic. Section 504 of the Rehabilitation Act of 1973 is the federal law that protects students from discrimination based on disability, ensuring equal access to participate in and benefit from the programs. ADA Amendments Act of 2008 expanded and clarified the definition of disability. The major change is the emphasis on providing reasonable modifications instead of proving there is a disability. For review, a disability is defined as: A physical or mental impairment that substantially limits one or more major life activities of such individuals. A record of such an impairment or being regarded as having such an impairment. Major life activities include caring for oneself, performing manual tasks, seeing, hearing, eating, sleeping, walking, standing, lifting, bending, speaking, breathing, learning, reading, concentrating, thinking, communicating, and working. After passage of the ADA Amendments Act, most physical and mental impairments constitute a disability. General health concerns like lifestyle and religious preferences are not disabilities and do not require modification. Past USDA guidance directed schools to focus on distinguishing between students with a documented medical need and students without a documented medical need. Accommodation was not always required. New- all disabilities must be accommodated by the school. New USDA guidance reflects the ADA Amendment Act of 2008 and our forms available on our web page have been changed to reflect the new guidance. We only have one form now. Instead of focusing on whether or not a student has a disability, focus is on a process to collaboratively work with families to ensure students have an equal opportunity to participate in school meal programs and receive program benefits. Local education agencies must make reasonable modifications to meals to accommodate disabilities restricting a child’s diet. This is done on a case-by-case basis and meals are provided at no additional charge. Keep in mind that accommodating a request is required but should not include brand specific items or modifications that fundamentally alter the program. Accommodation requests should be reasonable, and lifestyle or religious preferences are not disabilities and do not require accommodation. What is reasonable? Although reasonable is not defined let’s review a few key points that address reasonable. Requests are reviewed by a team rather than an individual. Outcome of requests and accommodations are consistently applied to all students. We have a duty to review and negotiate requests. Simply saying no is almost never appropriate. Our primary objective is to provide appropriate modifications, not to determine whether the student has a disability or not. The modification requested should be related to the student’s limitations and needs. The modification requested does not have to be the modification provided. You must still accommodate even when the parent or guardian believes more should be done. Consider cost, resources, and age of child. Stereotypes regarding certain conditions or individuals cannot drive decisions. Decisions must be based on facts. Meal accommodations do not need to mirror the meal or meal item substituted. The LEA’s responsibility is to serve the child a safe meal that accommodates their disability. Accommodation can go beyond meals. Accommodation also means ensuring food service areas are accessible and auxiliary aids and services are available as needed. Accommodating students in the least restrictive environment is the goal, and balancing safety vs. stigma is important. Oftentimes special dietary needs forms are completed by a recognized medical authority and may not be clear and complete. A modification should not be delayed unnecessarily. Work as quickly as possible to obtain clarification. Nutrition Services staff and directors cannot request student medical records. The special dietary needs forms you receive have no expiration date and students are accommodated from the year to year. It is a best practice to ensure information is up-to-date. Let’s review the list of recognized medical authorities in Washington State. There are some specific requirements such as developing a process to request an accom- request an accommodation, notifying families of the process and training on procedures. Let’s further break these requirements down into steps. Most effective teams will include a mix of people listed on the slide. Building a team ensures procedures developed are consistently applied and families receive consistent information. Per one of the CFR’s and the question and answers on the ADA Amendments Act of 2008 for students with disabilities, if a student has a medically diagnosed problem that requires a meal accommodation under Section 504, the school should refer to this- refer the student for a Section 504 evaluation to determine whether any special education or related needs and services including modifications because of a disability. As part of general school related responsibilities, the Section 504 or ADA coordinator may also be responsible for ensuring compliance with disability requirements related to meal modifications and meal service. Working with a team is important and communication is equally important. Communication makes the process as transparent as possible and can even help you negotiate reasonable accommodations and resolve concerns. Parents and guardians need to know how to request a modification and how to resolve disputes. Develop a hearing process to address grievances- to address grievances allows an opportunity for the parent or guardian to be represented and heard. The new Child and Adult Care Food (CACFP) program meal patterns were implemented in school districts and in school year 17-18. Throughout the year USDA released clarifications and questions and answers memorandums. Let’s take a look at the CACFP meal patterns as they apply to the school setting. The new CACFP meal patterns implemented in school settings change meals service to preschool students. Schools must follow the CACFP meal patterns for preschool students when preschool students are provided meal service separate from the K-12 population. This is important because there are new restrictions on items such as yogurt and cereal – items that you service students K-5 and older may not be suitable for Pre-K students under the new guidance. There are some nuances regarding the Offer versus Serve requirement in school meals for preschoolers that we will talk about, and there are differences when you have co-mingled versus non co-mingled preschoolers that you are feeding. This will provide you with base knowledge necessary to discuss preschool meals and production record maintenance. The new meal pattern requires that yogurt served contain no more than 23 grams of sugar per 6 ounces. Cereal may have no more than 6 grams of sugar per dry ounce. You may find that some of the items served to the older students may not meet these requirements and may require a substitution. Preschool children’s tastes and preferences are still developing – they should be exposed to a wide variety of food. Offer versus serve is not allowed for preschool students. Instead, Family-Style meal service should be followed. Ok, so now I’m going to talk about co-mingled preschool. Some schools serve meals to preschoolers and grades K-5 students in the same service area at the same time. These co-mingled situations may create counting and claiming issues, as it’s challenging to determine during a meal service is if- if a child is in preschool or kindergarten. And the meal pattern requirements for preschoolers and the K-5 students are slightly different. Children may arrive on the same bus and enter the cafeteria for breakfast together. In this situation, it’s difficult for food service staff to determine which children are in preschool or K-5. Schools that serve meals to preschoolers and K-5 students in the same service area at the same time may choose to follow the grade appropriate meal pattern for each grade group, or serve the K-5 meal pattern to both grade groups. We encourage schools to find ways to serve grade appropriate meals to all students to best address their nutrition needs prior to using any single menu flexibilities. For instance, innovative breakfast models for older students like Grab and Go, Breakfast in the Classroom, may be helpful in preventing co-mingling of preschoolers with middle and high school age children at breakfast. So if you have a site serving K-8 or even K-12 students and you have a co-mingled preschool, for breakfast in situations where preschoolers are co-mingled with K-12 students at breakfast, schools can serve the K-5 or K-12 meal pattern for all grade groups. For lunch, there’s an overlap in the meal pattern requirements for grades K-5 and grades 6-8. Since there is overlap, a single lunch menu can be used to meet the needs of K-8 students. Therefore in situations where preschoolers are co-mingled with K-8 students, schools can serve the K-5 meal pattern to all grade groups. This flexibility for lunch cannot extend to accommodate co-mingling situations between preschoolers and K-12 because the differences in meal pattern requirements are too great to be met by one single menu. The meal patterns for school meal programs do not allow for K-12 or a 6-12 grade grouping during the lunch meal service. In situations where preschoolers may not be co-mingled with the older students. In this case preschoolers are served meals in a different area or at a different time than K-5 students. Schools must follow the CACFP meal pattern. Ok let’s cover production record maintenance and preschool meals. When it comes to preschool meals it is a requirement that separate production records or preschool menu items are clearly listed or indicated on the production record used for the NSLP. Here we’re going to move on to a Food Distribution Policy Memorandum that was- that was released this past year and it replaces Food Distribution Policy Memorandum 107 with a date of June 9 2010. Product dates can have a variety of definitions. Product dating is voluntary in some cases and is meant to help consumers and retailers decide when food is of best quality, but these dates are not an indicator of wholesomeness or food safety. FD 107 clarifies guidance on policies and procedures for donated food storage and distribution as they relate to product dating. Products are affected by length of time and temperature of the distribution and storage process. Characteristics of the food and food packaging play a major role. Recall issues with USDA brown rice in school year 16-17. Program operators need to forecast before ordering and use good menu planning practices to both gauge how much of a food product they need and how to move food once it arrives on site through their inventory systems. Inventory levels should not exceed what can be used in a six month period. Anticipated demands should be based on historical data and consider shifts in participation, seasonality, and distribution logistics. Cycle menus are really important and aid in the forecasting process. Accurate production records can help predict amounts of food to order in the future. Knowing the capacity of storage areas allows for ordering appropriate amounts of food and organized storage for a first-in first-out process helps greatly. Any of these dates could appear on retail or donated foods and remember, they’re not related to food safety. Proper handling is key. Best if used by and best if used before dates indicate when a product will be of best flavor or quality. And use by date is the last date the manufacturer recommends using the product while at peak quality. And a sell-by date is also a product quality indicator and is the date by which the manufacturer recommends in a store sell the food product for inventory management purposes. If handled properly, that donated food could still be wholesome and safe to consume beyond these dates until the food exhibits signs of spoilage such as changes in odor, flavor, or texture. Handled improperly, the food could lose quality prior to the date marked on the package. A pack code and date of pack, or manufacturing date is a series of letters and/or numbers that indicates when the product was packaged, processed, or manufactured. For example, some donated food such as canned items may contain manufacturing dates which indicate when the products were manufactured. Certain donated fruits and vegetables such as canned or frozen peaches, pears, green beans, and corn may contain pack code dates or a date of pack instead. Food with pack codes or a date of pack are packed shortly after harvest and may be delivered throughout the following year or until the next harvest season. Packing or manufacturing date should not be interpreted the same as best if used by or best if used before dates. They may help determine the age of a product. These codes do not necessarily provide useful information or product wholesomeness for nutrition value. As described above for products that only have packing or manufacturing dates rather than best if used by dates, distributing and recipient agencies should maintain records when products are received. Out of condition foods are foods that are no longer fit for human consumption as a result of spoilage, contamination, or infestation. Out of condition donated foods should not be consumed nor distributed regardless of product dates or when the food was received. Certain types of donated food such as dried fruits, grain products, and string cheese are more sensitive to storage conditions. If handled improperly, they may go out of condition prior to the dates voluntarily marked on cases or containers. Okay now we’re going to move on to federal update for Market Basket Analysis. And so procurement of goods and services has been a focus of school meal programs for the past couple years. USDA now requires a review of local agency procurement practices. And we are receiving policy memorandums pertaining to procurement. Let’s review the Market Basket Analysis concept for preparing goods and modifying contract product lists. A market basket analysis is a procurement practice. Bids and proposals for a solicitation are evaluated based on a market basket. Key words evaluation of the lowest price a vendor can offer for a representative sample of goods. The analysis of the market basket is the basis for awarding a contract to a successful vendor. When using a market basket analysis approach to procuring goods, there are a few things the LEA must do to prepare for the procurement process. First, prepare procedures for how the analysis will be done. Procedures are important for two reasons. Procedures ensure the process is carried out correctly and consistently each time a market basket analysis is used. And procedures also back up the contract award- awarded in case of questions or grievances. Use of market basket analysis must also be noted in the LEA procurement plan. Second, in order to even use a market basket analysis, the solicitation invitation to bid or request for proposal must include language that a market basket analysis will be used and give details of the analysis including the list of food items that will be evaluated in the market basket. Third, be able to estimate the value of the contract. This is done by reviewing purchase history to understand how much of an item in the market basket was purchased in a prior year and predict how much will be needed during the contract year. The market basket is a representative sample of goods defined as 75% or more of the estimated value of the contract to be awarded. The solicitation must list all goods to be purchased under the contract and prior to awarding the contract the LEA must obtain pricing for the food products that were not included in the market basket. Maintain your records. USDA provided a new weighted average price and calculator tool for school year 18-19 Paid Lunch Equity Provision. In addition, USDA also introduced a new flexibility for the Paid Lunch Equity. This flexibility was for the 18-19 school year only, and USDA typically provides us guidance each year and addresses flexibilities that may be allowed annually. The weighted average price for equity for 18-19 is $2.92. This is the difference between 17-18 federal reimbursement for free meals and federal reimbursement for paid meals. As reimbursement rates increase annually so does the equity requirement. This provision applies to pricing programs only. When the weighted average paid lunch price was less than $2.92, there are three options for compliance with the provision. LEAs may increase lunch prices, contribute non-federal funds to the school food service account, or a combination price increase and non-federal fund contribution is an option. The paid lunch equity tool issued by the USDA is used to meet the PLE requirements. The tool must be on file and data in the prior year tool is used for the upcoming year tool. Accuracy is important. Prior year tools cannot be used for current year calculations. Okay, special flexibility- I’m sorry, here we go- Special flexibility for school year 18-19 allows local education agencies with a positive or break-even balance of as of January 31st 2018 to request an exemption of rais- raising prices or contributing non-federal funds. Permission is required, and this flexibility is for one year only. LEAs must maintain documentation to support their request for administrative reviews and/or review by the State Auditor’s office. A CNS update was sent and provided instructions for requesting the flexibility. Okay. USDA announced a fiscal year 2018 equipment assistance grant, so 30 million dollars has been allocated and Washington State will receive $471,623. The grant would be available in the OSPI iGrant system in November. And the grant is competitive with priority to schools 50% free and reduced. These federal funds allow schools to purchase equipment needed to serve healthier school meals, improve safety, and expand access to school meals. Again, look for the grant in the iGrants system around November. So OSPI offers two additional competitive state funded grants. The Meals for Kids Breakfast grant is available each year, and also the Healthy Kids, Healthy Schools grant was appropriated this past legislative season. Please note the due date for the grant application is September 27th by 4 pm. The application is available in iGrants, and more information can be found on OSPI facilities webpage. Child Nutrition Services will send a CNS update information when the Meals for Kids Breakfast grant application is available. Okay, USDA introduced an interim final rule for some additional meal pattern flexibilities. Since this is an interim final rule, the flexibilities can be implemented for school year 18-19. So these flexibilities include providing operators the option to offer flavored, low-fat (1%) milk for school meal programs and extends Child Nutrition Services option to allow LEAs to include grains that are not whole-grain rich in the weekly menu offered for the National School Lunch Program and School Breakfast Program. So please note that whole grain waiver requests are still required and Child Nutrition Services approves requests on a case-by-case basis. Finally, local education agencies that meet Sodium Target 1 are considered compliant with the sodium requirement. And we’re expecting a final rule sometime this year that would be effective for the 19-20 school year. There was a proposed rule for professional standards released also, mainly for the hiring flexibility. So USDA proposed a change in rule for the Professional Standards rule- hiring standards for food service directors. USDA is proposing that food service directors and local education agencies with enrollment of 2,499 or less have relevant food service experience versus relevant school nutrition program experience. And, also proposing this experience can be volunteered or unpaid work experience. The rule also proposes changes for local education agencies with enrollment of 500 or less. The current rule requires an associate’s degree and at least one year of relevant school nutrition program experience or a high school diploma and at least three years of relevant school nutrition program experience. The proposed rule would allow LEAs to accept less than the required years of food service experience when a new director has a minimum required education for an enrollment of 500 or less. So currently local education agencies with enrollment at 500 or less must still request an- an exemption from the hiring standards and we’ll wait to see what the outcome of the fin- the final rule is. Here’s something really important coming for 18-19 school year is area eligible after-school snack programs and how we have in the past determined eligibility for a snack program. So we are sharing this information about changes for area eligible in after-school snack program. Child Nutrition Services has operated- operated off of a feeder school concept in past years. Non area eligible schools could qualify an area eligible snack program site using an area eligible feeder school. For example, Anywhere Middle School has a free and reduced-price percentage of 48%. Anywhere Middle School would like to operate the after-school snack program and an area eligible program. Anywhere Elementary School has a free and reduced-price percentage of 56%. The students from Anywhere Elementary School end up attending Anywhere Middle School. They feed into the middle school. And so Anywhere Middle School can be approved as an area eligible snack light- site no longer. Okay, so that was our old past practice. Beginning school year 18-19 a non-area eligible site may only qualify when it sits in the attendance area of an area eligible school. New too, sites no longer need to qualify each year. Instead, will qualify for a period of five years. So it may be that some programs that we have approved in the past will no longer be able to be approved this year. So we’ll be taking a close look at that. I think that’s what this slide says. Here why don’t we talk a little bit about our direct certification system and some best practices for the student search function? The student search function continues to be cumbersome to use. Some best practices include searching on basic food or TANF numbers, even a Medicaid number if you have it. State student ID can work and we recommend the name search using last name and first initial of the first name. Search by only one of the points on the slide at a time. Giving the system too much information is not good. The more general detail may return a number of possible matches for which to choose from and we continue to work on the student search function. Starting with school year 18-19, Direct Certification must be performed monthly throughout the school year. And this is because it’s required of House Bill 2610. So you need to do Direct Certification every month to comply with the new state law. In school year 17-18 we released Direct Certification using Medicaid data. It’s currently at the federal level of pilot project and this means that it’s not available in all states yet. It’s a great thing to participate in a pilot project. Improving access to school meals and having access to additional data for community eligibility provision is really important. For the project, OSPI partnered with Health Care Authority (HCA). Health Care Authority are keepers of the Medicaid programs in Washington State. Okay, let’s take a look at the key policies of Direct Certification using Medicaid. These policies are important and will help you gain the concept of directly certifying students using Medicaid data. We’ll go from each policy. So students are certified for both free and reduced-priced meals. That- this is a key difference between Direct Certification and Direct Certification Medicaid. Directly Certified means that the child is eligible and does not need to turn in a meal application to receive benefits. Students directly certified using Medicaid data are not subject to verification, and households directly certified for Medicaid for reduced-price meals need to be notified that they may turn in a meal application for approval based on house size- household size and income for free meals if they feel they are higher- eligible for the higher benefit level. Applications with Medicaid numbers cannot be accepted. This is different than Direct Certification because we can accept a basic food or TANF case number at face value and approve for free meals. So let me emphasize that we cannot approve an application with a Medicaid case number. The only way a Medicaid household is eligible for free or reduced-price meals is through the direct certification Medicaid list in the Education Data System. Okay so this is a screenshot of the direct cert Medicaid list and it should look pretty familiar to you. I’d like to draw your attention to circle one on the top right hand corner. We’ll continue to have the file download options, however please note that the option to download the list with CEDARS codes is no longer available. All download options will automatically contain the CEDARS codes. Now, look at circle two on the left. The date eligible column is available for LEAs that have been approved to use the flexibility in eligibility status for direct certification. Please note that for their- (inaudible) Circle three on the right. Reason qualified is Medicaid. And circle four, also on the right. Associated CEDARS code. Code six for free and code twelve for reduced. Here are some common questions about direct certification using Medicaid data. And here are some more. And I’m not going to discuss answers to these questions in this particular presentation. They are all answered on our direct certification Medicaid reference sheet. The answers to the questions are available on our webpage in two resources. A reference sheet, or you can take our recorded training that lasts about fifteen minutes. You’ll get all those questions answered. Always save your lists. They’re your source documents and are proof of eligibility for free, or in the case of Medicaid, reduced-priced meals. You may save either an electronic or printed copy. And we’ll move and talk to- move into talking about the administrative review and procurement review process. So we have a new process at Child Nutrition Services. We decided to bundle the AR and PR together. Some processes will change and LEAS will need to submit some additional documents with the Offsite Tool. These include the completed procurement tool, pyramid plan, code of conduct, and vendor paid list. The questions on the offsite tool have been reduced, and this process could take more time to complete. However, overall, provide for fewer contacts for information by- to you by Child Nutrition Services. The notification letters will be combined together and the AR will still be conducted on site and the PR will be conducted offsite. They’re conducted by different specialists, and final review letters will be separate too. Local education agencies selected for an AR and PR for school year 18-19 have been posted to the OSPI CNS webpage. The offsite tool was sent August 3rd with a return date of September 14th and if you’ve not heard from your program specialists already you should be soon. They’re in the process of scheduling reviews. Let’s look at some changes to the administrative review. The adjustment factor for meal application errors determines fiscal action and it’s usually behind the scenes that affects fisc- fiscal action when there are application errors. There were some changes to resource management questions revised on the off-site tool to be clear for you all when you’re filling out the form and helps us better determine risk for the resource management areas of review. So this was new for school seven- school year 17-18 but definitely worth repeating. Fiscal action for the benefit issuance errors is expanded when the error rate is 3% or greater. It’s expanded district-wide for all meals claimed during the review period and the month of on site review. So I guess the message here is to ensure that people are well trained on applications and determining eligibility for free or reduced-price meals. There were no changes at the federal level for now for the procurement review and thank you to those who’ve had a review for your patience as we implemented this new review. (Prolonged pause) It’s okay to have non-American, but did you know? The Buy American provision requires sponsors of the school meal programs to purchase domestic commodities and products. Buy American language must be in the following: your procurement plan, solicitations/specifications, and contract. Once the contract has been awarded, Buy American is enforced with continuous contract monitoring. Contract monitoring ensures that food items arrive on site according to the products bid for. If Buy American was in the specifications or solicitation, there’s a good chance some of the food items were priced accordingly. Make sure you get what you bid and what you paid for. Limited exceptions to Buy American are possible. The local education agency must decide when it will buy non-domestic products. Some reasons might include cost or products not available domestically or only during some seasons of the year. Plan exceptions and keep justification on file with your procurement plan. Just to review a few requirements for Buy American. Sponsors must purchase to the maximum extent practicable, domestic commodities and products for the National School Lunch Program and School Breakfast Program. Focus is on products that count towards the meal components or meal pattern contribution. A domestic commodity or product is an agricultural commodity produced in the United States and a food product that is processed in the United States using substantial agricultural commodities. USDA defines substantial as 51% of the final product. The procurement plan must include the Buy American provision. And the Buy American provision must be included in all solicitations. Remember the Buy American provision applies to food and beverages. Not equipment. When food comes on site, it is important to monitor your contract. Determine country of origin. Focus on meal components. Seasonality of menus will help you comply with Buying American provision. So DoD Fresh program participants must also monitor contracts. DoD solicitations at the national level are for American grown produce. Vendors are aware of this yet in many cases continue to send products that don’t comply. When foreign produce arrives on site, return if you can based on your food on hand and menu requirements. Whether you keep- whether you decide to return it or keep it on site, call our food distribution team. USDA holds the contract and states play a role in contract monitoring so we like to hear from you if that’s happening. So just recently the Office of Management and Budget or OMB released a memo increasing the federal micro-purchase threshold and simplified acquisition threshold for purchases made with federal dollars. Contracts bid for school year 18-19 and purchases conducted outside existing contracts and new thresholds apply. So please know the state small- small purchase threshold is $40,000 to $74,999. It’s more restrictive than the federal threshold so no impact with the change. So here are those- those new levels here. See the new thresholds in bold on the slide. These new thresholds are federal- they’re not state. We’ll follow the new threshold for micro purchase, and we won’t make any changes for the small purchase threshold because the state threshold is more restrictive. Again this is effective immediately. Okay so now I’m ready to- we’re moving on to Child Nutrition Updates, so it is the last part of the presentation. So we have some local changes. There are several within Child Nutrition Services. So in May, Leanne Eko became our interim director of Child Nutrition Services. We welcomed Marlon Hopkins, our food distribution program supervisor in June. And Mayahuel Weisser, our program administrative assistant. A new position, school meal program lead program specialist will be filled by Rachel Floyd who arrives in September. Child Nutrition Services mission is to assist program operators in implementing successful Child Nutrition Programs and we’re here and happy to help you. Alright so we’re going to stop the recording now. Okay and so we’ll have- take an opportunity to- for you to ask questions and also for our folks on the webinar to ask questions too.

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