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Ohio Department of Education, Office for Child Nutrition Update

Good afternoon! The Ohio Department of Education, Office for Child Nutrition shares with you the following items of interest for September 10, 2015:

  • Direct Certification: School food authorities who process free and reduced price meal applications are required to run a direct certification match at least three times per school year. Direct certification is accessed through the .NET Claims Reimbursement and Reporting System (CRRS). After logging in, click on Applications, then select Direct Certification/Direct Verification.
  • Fall Food Service Directors Conference: The Office for Child Nutrition will host a Fall Food Service Directors Conference in October. The main conference, scheduled for October 22, will be followed by individual training sessions on October 23. Agenda and registration instructions will be available soon.
  • 2016 Application and System Upgrade: The Office for Child Nutrition upgraded its Claims Reimbursement and Reporting System (CRRS) this summer. The new system, CRRS.NET, will be used by school food authorities to complete all program applications and claims, beginning with the 2015-2016 school year. The direct link to CRRS.NET is https://oh.cnpus.com/crrs/Splash.aspx Save it to your favorites bar for easy access.
    • CRRS.NET Training: A recorded CRRS.NET application training webinar is availablehere. Click here for the CRRS.NET application user manual.
    • CRRS.NET Application FAQ: The Office for Child Nutrition has compiled a list of frequently asked questions and answers, which is available here.
    • Submitting CRRS.NET Applications for Approval: Your School Meal Program Specialist will not review the CRRS.NET application for approval unless the application is in “submitted for approval” status. The status of the application is viewed in the upper right hand corner of the application packet screen.
    • CRRS.NET Claim, Non-Needy Student Workers: Schools should include the count of meals served to non-needy student workers in the count of paid student meals when entering the claim for reimbursement in CRRS.NET.
    • After School Care Snack Program (ASCS), Site Application Section: The technical issue affecting the ASCS section of the Site Application is resolved, except for schools on the Community Eligibility Provision (CEP). This section of the Site Application can now be completed by schools not on CEP. The Office will keep CEP schools updated when the ASCS Site Application is fixed.
    • Certificate of Authority: New users to the CRRS.NET system (i.e. you are unable to log into CRRS.NET by following the directions above) must complete a certificate of authority form and email the form to your School Meal Program Specialist. Click here for the form. Click here for a list of the School Meal Program Specialists.

Reminders:

Certification of Standards Governing Types of Foods and Beverages Sold on School Premises, School Year 2014 – 2015 Report

State law in Ohio requires each school district board of education and each chartered nonpublic school board or governing authority to adopt and enforce nutrition standards governing the types of food and beverages available for sale on school premises and report compliance annually to the Ohio Department of Education. Schools are asked to file this report by September 30. Click here for the survey.

Professional Standards Education Hours Feature Publication:

As a reminder, the Office received approval from USDA to offer education credits toward the Professional Standards requirements through this weekly email. Below is this week’s highlight publication. To count the education credits, the reader will need to keep an electronic or printed copy of the email with the questions answered. The Office will publish the answers in next week’s email and will highlight another policy memo or guidance document. This process will repeat in each weekly email throughout the year. Each weekly email review will count as 30 minutes toward the Professional Standards requirements.

This week’s featured publication is the Eligibility Manual for School Meals, July 2015 edition. Click herefor the manual. The Professional Standards topic code is 3000 Administration, 3100 Free and Reduced Price Meal Benefits, 3110 Eligibility.

This edition replaces the manual issued in August 2014. USDA’s goal is to issue annual guidance to ensure that all Child Nutrition Program agencies will have current policy information to begin the application and certification process at the start of each school year.

This manual explains the basic requirements that must be addressed by State and local agencies to review applications, and properly determine and confirm eligibility. The information provides practical guidance to assist State and local agencies in establishing free and reduced price school meal and free milk policies and procedures that are effective, increase Program integrity, and reduce administrative burden, without compromising access for families in need.

The chapters of this manual highlight:

  • Application design and processing,
  • Determining income eligibility,
  • Determining categorical eligibility,
  • Direct certification methods,
  • Verification procedures and sources,
  • Confidentiality and disclosure, and
  • Recordkeeping.

USDA published a new free and reduced price meal application this year. The Office for Child Nutrition published the new prototype and the old format for schools to choose from for the 2015-16 school year. Click here for the meal application prototypes. The new USDA prototype does not currently include a fee waiver section. Schools opting to use the new USDA prototype and use the application information to approve instructional fee waivers must collect parent consent for use of the application by distributing a “disclosure form for sharing information with other programs”, also available on the website with the application prototypes. Page 20 of the manual details features of the new USDA application prototype.

As with any PDF document, an easy way to search for a particular section or word is to use the CTRL+F function on your keyboard. For example, if you want to see each place in the document that the term “foster child” appears, you would click somewhere in the document, hold down the control (CTRL) button and the letter F on your keyboard at the same time, and a search bar will appear on your screen. Type in the words “foster child” and click Enter. The computer will detect where the first occurrence of that phrase is and go to that location in the document. To go to the next occurrence of the phrase, you will click on the “next” button in the Find window.

The following questions require review of the manual. Answers will be shared in next week’s email:

Question 1: School Food Authorities must obtain parental consent to use the information from the free and reduced meal application for determining eligibility for a local education program, such as fee waivers. How often must parent consent be obtained? Can consent be extended from one school year to the next

Question 2: How long does a child’s eligibility status from the previous school year carry over into the next school year? What day of the school year does this carry over begin? Can an LEA establish a shorter carryover period than what USDA requires?

Question 3: If a Supplemental Nutrition Assistance Program (SNAP) or Ohio Works First (OWF) case number on a free and reduced application seems incorrect, what steps should a school official take in regards to that application?

Question 4: What eligibility categories are included under the “Other Source Categorically Eligible” designation? What must these categories be confirmed through prior to certifying the children for free meals? What is the exception to this rule?

Question 5: What must application request in terms of reporting no income? What is no longer required of applicants with no income? If no income is provided for any of the adult household members, in what status is the application considered to be?

Question 6: How does direct verification differ from direct certification? Is direct verification required? Who would a LEA contact to conduct direct verification?

Question 7: (Fill in the blanks) Households must be notified either in ________ or ________ of their eligibility status as approved for free or reduced benefits. The LEA may _______ the notification of the household’s approval for meal benefits to the adult household member who signed the application.

Question 8: A non-custodial parent wants the eligibility status of their child. An attorney has requested this information of the school. Is this sufficient justification for the release of the application data?

Question 9: What is the definition of emancipated child for the purposes of the school meal program? Who must sign an application for an emancipated child?

Question 10: Should overtime pay be included/ factored in when reviewing household documentation for the verification process?

The following questions and answers are from last week’s email, discussing USDA policy memo SP 10-2012 (Version 9), Questions & Answers on the Final Rule, “Nutrition Standards in the National School Lunch and School Breakfast Programs.”:

Question 1: Does the new meal patterns impact meals for children with disabilities?

ANSWER: The meal accommodations under the Child Nutrition Programs for children whose medical disability restricts their diet are not affected by the changes to the meal patterns and dietary specifications. These meal accommodations continue to be based on a medical statement from a licensed physician. At the discretion of a State agency, the meal accommodations can also be based on a medical statement from other State recognized medical authorities and must include recommended alternate foods as set forth in the program guidance listed below. A State recognized medical authority for this purpose is a State licensed health care professional who is authorized to write medical prescriptions under State law. If a licensed doctor or State recognized medical authority determines that a child has a disability that restricts their diet (such as a milk allergy), then the meal prescribed is reimbursable even though it may not meet the meal pattern (page 5).

Question 2: Do grain products have to be 100% whole grain to meet the whole grain-rich criteria?

ANSWER: No; the requirement is to offer only whole grain-rich products. Whole grain-rich products contain at least 50% whole grains and the remaining grain, if any, must be enriched. FNS has granted a temporary flexibility that remains in effect in SY 2015-16. State agencies have the option to grant an exemption from the whole grain-rich requirement to school food authorities that demonstrate significant challenges in procuring and serving whole grain-rich products, provided that at least half of the grains offered weekly are whole grain-rich (page 17). Click here for the whole grain-rich waiver application.

Question 3: Can water be offered in place of milk?

ANSWER: No. While water must be made available to students during meal service, program operators are not to promote or offer water or any other beverage as an alternative selection to fluid milk throughout the food service area. Milk is a required component in the meal patterns. However, water must be available in the food service area, as discussed in the memorandum SP–28–2011 Revised Child Nutrition Reauthorization 2010: Water Availability during National School Lunch Program Meal Service, dated July 12, 2011, and can be available on the service line (page 25).

Question 4: May a school offer extra, free beverages (100% juice, iced tea, etc.) after the Point of Service (POS)?

ANSWER: Yes, a school may offer extra beverages after the POS, but these must be considered when analyzing the calorie, saturated fat, and sodium levels associated with the reimbursable meal. The menu planner must be very cautious not to exceed the maximum limits for calories, saturated fat and sodium by offering extra beverages after the POS. Full-strength juice offered after POS counts toward the weekly juice limit established for the reimbursable meal (no more than half of the total fruit or vegetable offerings over the week may be in the form of juice). Therefore, offering juice after the POS would limit the opportunity to include juice as part of the reimbursable school meal. It could also discourage students’ consumption of fluid milk, which must be offered with the meal. Additionally, SFAs are reminded that potable water must be made available at no charge to students in the place where lunch meals are served during the meal service (page 35).

Question 5: When does the next three-year administrative review (formerly known as CRE) cycle begin?

ANSWER: The next three-year administrative review cycle begins school year 2016-2017 (page 47). The current 3-year administrative review cycle began in school year 2013-2014 and concludes in 2015-2016.

Question 6: How can schools minimize plate waste while requiring students to take a fruit or a vegetable as part of the meal?

ANSWER: Schools may use several strategies to minimize plate waste. The Offer versus Serve (OVS) policy allows students to take smaller portions of the fruits and vegetables components, if desired. Under OVS, students can select only ½ cup daily of the fruits or the vegetables components as part of the reimbursable lunch or breakfast, even if larger portions are offered. Other strategies to reduce plate waste include: tasting tests before introducing foods on the menu, creative marketing/presentation of foods, and self-service salad bars. It is also important that schools produce only the amount of food needed to serve students based on past selection history, and allow students enough time to eat their meals. For additional tips, see:

Question 7: Why does the lunch meal pattern have a weekly maximum for the meat/meat alternate and grains components?

ANSWER: The lunch meal pattern established by Federal regulation includes weekly ranges (minimum and maximum levels) for the meat/meat alternate and grains components to help the menu planners offer age-appropriate and well-balanced meals. However, the weekly maximums for these food components are not enforced and State agencies determine compliance based on the required daily and weekly minimum quantities (page 15).

Question 8: How do I use a sherbet with a CN Label?

ANSWER: Sherbet and gelatin containing fruit juice do not credit in the NSLP because the child is not consuming a 100% full-strength juice (e.g., it is diluted with water, sugar, milk). There will continue to be a CN Label on some products not creditable in the NSLP, such as sherbet and juice drinks, as they can currently still credit in other CN programs. Fruit pieces in gelatin are creditable based on volume as served (page 53).

Question 9: May food ingredients that are unrecognizable contribute to meal pattern requirements (for example, carrots pureed in a sauce for Macaroni and Cheese)?

ANSWER: Yes, pureed foods such as fruits or vegetables may contribute to meal pattern requirements, provided that the dish that contains them also provides an adequate amount of recognizable, creditable fruits or vegetables.

For example, if a macaroni and cheese dish contains the minimum recognizable amount of vegetables (e.g., ⅛ cup of diced squash), the volume of unrecognizable vegetables (e.g., 1/8 cup of pureed carrots) may also be credited. In this example, the dish would provide a total of ¼ cup red/orange vegetables. This is the same concept that has historically allowed soy flour (Alternate Protein Product) in a pizza crust to contribute as a meat alternate — there is a recognizable amount of cheese and/or meat included in pizza as topping.

However, if the dish does not contain at least ⅛ cup of a recognizable component (in the above examples, vegetables) then the blended foods do not contribute to the meal requirements. The nutrition education aspect of the School Meal Programs is important and one of the goals of these Programs is to help children easily recognize the key food groups that contribute to a healthy meal (page 54).

Question 10: What is the sodium requirement and when will schools have to meet it?

ANSWER: Target I of the sodium limits became effective July 1, 2014. Implementation of the second and final targets is subject to USDA’s review of data on the relationship between sodium intake and human health, as required by the FY 2012 Agriculture Appropriations Act (page 26).