SSO and SFSP Program Integrity Questions - Nutrition (CA ...



Seamless Summer Option Under Waiver #85 Integrity Plan for School Year 2021–22Program operators are required to maintain written procedures that outline plans to ensure program integrity to avoid duplication of meals served to a child in their meal service distribution during the COVID19 pandemic. The purpose for this document is to assist program operators in the development of their standard operating procedures (Integrity Plan) for implementing the nationwide waivers. This document lists some of the required documents program operators must collect and maintain to meet the Seamless Summer Option (SSO) while implementing the nationwide waivers. This document also provides prompting questions program operators should consider and answer when developing their Integrity Plan to avoid duplication of meals served to children in their SSO meal service. Created by the CA Department of Education, last updated October 2021.WaiverAgency Procedures and Documentation RequirementsIntegrity Planning Prompting QuestionsCOVID-19: Child Nutrition Response#85 for SSONationwide Waiver to Allow the SSO through School Year (SY) 2021–22Food and Nutrition Service (FNS) is allowing SSO operations to continue when school is open during the regular school year regardless of its location or the type of SSO site it is operating.Expires: June 30, 2022Requirements:For school food authorities (SFA) to opt into this waiver, must complete survey for California Department of Education (CDE) approval: 2021–22 Child Nutrition Information and Payment System (CNIPS) application before the first claim is submittedUpdate Meal Counting and Claiming Procedures (MCCP) for current operations Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Is CNIPS updated to reflect current operations?Are all sites approved in CNIPS?Are meal types approved in CNIPS?Are claims submitted in CNIPS under SSO?Are the updated MCCPs for current operations on file?Is there a system to prevent duplicate meals?Is there a system to ensure meals are only claimed for eligible children?Are all needy children offered one nutritionally adequate meal?COVID-19: Child Nutrition Response#86 for SSONationwide Waiver to Allow Summer Food Service Program (SFSP) Reimbursement Rates in SY 2021–22Allows SFAs to claim National School Lunch Program (NSLP) SSO meals and snacks at the SFSP reimbursement ratesExpires: June 30, 2022Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: 2021–22 CNIPS application before the first claim is submittedUpdate MCCPs for current operations Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Is CNIPS updated to reflect current operations?Are all sites approved in CNIPS?Are meal types approved in CNIPS?Are claims submitted in CNIPS under SSO?Are the updated MCCPs for current operations on file?Is there a system to prevent duplicate meals?Is there a system to ensure meals are only claimed for eligible children?Are all needy children offered one nutritionally adequate meal?COVID-19: Child Nutrition Response #87 for SSO Nationwide Waiver to Allow Noncongregate Meal Service for SY 2021–22Allows for consumption of meals offsite and outside of group settings. This allows for serving models like grab-n-go, curbside pick-up, mobile and bus routes, and home delivery.Expires: June 30, 2022To support access to nutritious meals while minimizing potential exposure, Child Nutrition Program Operators can choose to serve meals outside of group settings like grab-n-go, curbside pick-up, mobile/bus routes, home delivery, etc. SSO Closed Enrolled:When using any of these options, update procedures to demonstrate that the meal service style ensures meals are claimed only for enrolled children by site and prevents duplicate meals.SSO Open:Are meals available on all days in which students receive instruction whether in-person or distance learning?Does the SFA have records to show where the meals were distributed and are able to show that they were accurately counted and claimed?Are families provided with menus and directions on how to separate items into reimbursable meals with minimum portion sizes, including heating and food safety information?Is there a system to accurately record meals served for meal service types (i.e., grab-n-go, curbside pickup, bulk pickup, and home delivery)?COVID-19: Child Nutrition Response #87 for SSO (Continued)Nationwide Waiver to Allow Noncongregate Meal Service for SY 2021–22Allows for consumption of meals offsite and outside of group settings. This allows for serving models like grab-n-go, curbside pick-up, mobile and bus routes, and home delivery.Expires: June 30, 2022When using any of these options, update MCCPs to demonstrate that the meal service style ensures meals are claimed for eligible children and prevents duplicate meals.Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: MCCPs for current operations Procedures to provide special diets to students as a result of medical disabilityProvide food safety information to families when multiple meals are served and not intended for immediate consumption. Provide instructions on portions and food safety. Ensure food items can be easily separated into meals with minimal preparation.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.What is the process to prevent duplicate meals from being distributed or claimed?What is the meal count source document used at the point of service (POS)? Is the source document maintained to support the claim for reimbursement? Did the SFA update the food and safety plans to make sure food is handled and served safely at the distribution sites?Are the SFA and distribution sites following the local level health department guidelines?Are there any students that require a special diet with a medical disability? What is the process to provide children special diets? Do the procedures include bulk pick-up or delivery of meals to not exceed five days?Do the bulk meals provided require minimal preparation and consider the families refrigeration and storage space?Is the And Justice for All poster visible to participants at all meal service locations? Not required for home deliveries.COVID-19: Child Nutrition Response #87 for SSO (Continued)Nationwide Waiver to Allow Noncongregate Meal Service for SY 2021–22Allows for consumption of meals offsite and outside of group settings. This allows for serving models like grab-n-go, curbside pick-up, mobile and bus routes, and home delivery.Expires: June 30, 2022Update Hazard Analysis and Critical Control Points (HACCP) standard operating procedures to include state and local COVID-19 requirements (i.e., wearing masks, gloves, staying at least six feet apart, and social distancing). May provide multiple meals, not to exceed five days at a time.And Justice for All posters must be visible at meal service facilities and locations. Paper copies and 2015 poster may be used. (Best practice—display poster for all mobile routes.)Grab-n-go, curbside pick-up, bulk pick–up, or mobile/bus routes and home delivery: System for recording meals served Source documents for meal counts Transport records by route (includes date of delivery and foods and number of meals delivered)Menu production records (MPR) For Home Delivery Only: Prior to implementing home delivery, parent and/or guardian written consent permitting home delivery of meals must be documented; a food safety procedure is required for delivering meals when household member is not present to receive meal(s).Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Are MPRs and transport records maintained to document the amount of food prepared to support the number of meals claimed for reimbursement?Is there documentation with student names and the number of meals served by meal type for mobile or bus and home delivery?Is a household’s written consent on file for home meal delivery to students prior to implementing home delivery service?For households that consent to receive food when no one is home, is only shelf-stable food delivered?Is there a mechanism to track who the parent or guardian has authorized to pick up meals on behalf of their children? The U.S. Department of Agriculture (USDA) required that this waiver be used only to the extent needed until in-person can be resumed safely. COVID-19: Child Nutrition Response #88 for SSO Nationwide Waiver of Meal Times Requirements for SY 2021–?22 Waives federal rule on the time between meal start times, and the duration of a meal service, and meal service time parameters.Expires: June 30, 2022Program operators must establish meal service times or delivery times and serve meals at the locations and times entered in the CNIPS and approved by the CDE.Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: and update meal service times in the CNIPS.Update MCCPs for current operations.If serving multiple meals and snacks together at the same time, meal counts must be recorded for each meal type.Note: Claim only meal types allowed by regulations or through waivers and approved in the CNIPS.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Is the CNIPS updated to reflect current operations for operating sites, serving days, meal times, and meal types?Are the updated MCCPs for current operations on file?Does the MCCPs for SSO include all POS for all approved meal types claimed?Is there a communication system in place that informs students and parents the serving days, meal times, and distribution locations?The USDA required that this waiver be used only to the extent needed until in-person can be resumed safely. COVID-19: Child Nutrition Response #89 for SSO Nationwide Waiver to Allow Parents and Guardians to Pick Up Meals for Children Allows parents or guardians to pick up meals for their child.Expires: June 30, 2022When distribution of meals occurs without a child present, procedures must reflect the process by which program accountability and integrity are maintained. Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: MCCPs for current operations. Meals are only distributed to parents or guardians of enrolled children (i.e., parents have children’s school identification cards) (SSO Closed Enrolled).Duplicate meals are not distributed or claimed.Meal counts are recorded at the POS where distribution occurs and must be claimed by site for enrolled participants only (SSO Closed Enrolled).Meal counts are recorded at the POS where distribution occurs and must be claimed by site.Note: Refer to requirements listed in the noncongregate feeding grabngo, curbside pick-up, and bulk pick-up meal service model for more information.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.For meals picked up without eligible participants present, is there a process to indicate that meals picked up are only for enrolled children? (SSO Closed Enrolled)For meals picked up without eligible participants present, is there a process to indicate that meals picked up are only for eligible children? (SSO Open)What is the process to prevent distribution or claiming of duplicate meals?Are meal counts recorded at the POS where distribution occurs and are they claimed by site?Are MCCPs updated to reflect all meal service models that the SFA implements?The USDA required that this waiver be used only to the extent needed until in-person can be resumed safely. COVID-19: Child Nutrition Response #90 for SSONationwide Waiver Specific School Meal Pattern Flexibility for SY 2021–22Flexibilities will be utilized only as needed, and that program operators will seek to meet the meal pattern requirements to the greatest extent possible. Program operators must demonstrate meals served and claimed meet meal pattern requirements unless approved waivers for specific areas of deviations are obtained. Additional deviations from the meal pattern is allowed in the CDE Meal Pattern Waiver Application.Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: pattern waivers require additional justification for specific meal pattern deviations/flexibilities waiver approval in agency file for reporting and recordkeeping.Waiver must include type(s) of specific areas of meal pattern deviations/flexibilities and justification:Deviations/flexibilities—sodium, whole grain-rich (preschoolers at least one serving per day), offer a variety of vegetables from the vegetable subgroups, at least two different fluid milk options, low-fat milk must be unflavored, following specific age/grade group menu requirements Is there an approved CDE opt in waiver application?Is there an approved waiver from the CDE for each specific area of meal pattern deviation/flexibility?Is all documentation maintained to support meal pattern requirements (i.e., MPRs, menus, transport records, substitutions to planned menus, medical statements)?Do the procedures describe how staff identifies, counts, and records reimbursable meals served?Is the staff trained on meal pattern and meal service requirements if and when there is a meal pattern deviation/flexibility?The USDA required that this waiver be used only to the extent needed until in-person can be resumed safely.COVID-19:Child Nutrition Response#90 for SSO (Continued)Nationwide Waiver Specific School Meal Pattern Flexibility for SY 2021–22Flexibilities will be utilized only as needed, and that program operators will seek to meet the meal pattern requirements to the greatest extent possible. Expires: June 30, 2022Justifications—COVID related issues, increased food or operational costs, staff shortages, vendor closures, supply chain issues, etc.Maintain all documentation (i.e., menus, MPRs, transport records, etc.) for all meals served and claimed.Describe in the MCCPs how staff identifies, counts, and records reimbursable meals.6) Train staff on meal pattern and meal service requirements prior to the start of the meal service.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.COVID-19:Child Nutrition Response #92 for SSONationwide Waiver to Allow Offer Versus Serve Flexibilities for Senior High Schools in SY 2021–?22Waives the limitation on the use of offer versus serve (OVS) to SFAs. Expires: June 30, 2022Requirements:For SFAs to opt into this waiver, must complete survey for CDE approval: CNIPS site application(s)Update MCCPs for current operations Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Do the procedures include serving all required meal components, if waiving OVS?Is the CNIPS site application updated to indicate the site is waiving OVS?If prepacked meals are provided, are all required components in the minimum amounts offered? If not, is there a waiver on file for missing or component shortages?COVID-19: Child Nutrition Response #94 for SSONationwide Waiver of On-site Monitoring Requirements in the School Meal Programs – Revised – Extension 3Waives the on-site monitoring requirement for state agencies and SFAs and the requirement to complete the on-site portion of an administrative review within the same school year that the review was begun.Expires: 30 days after the end of the public health emergencyRequirements:For SFAs to opt into this waiver, must complete survey for CDE approval: with multiple sites are required to review each SSO site at least once during its operation.The SFA must annually review 100 percent of lunch sites and 50 percent of breakfast sites.This waiver does not waive the monitoring requirement. In lieu of the in-person site visit, a desk audit is required. Desk audit review documentation may include, but is not limited to: Scanned copyPictureVideoReview and verify records that have been texted, emailed, or otherwise provided, or through virtual observation, for example, by using video.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.Was at least one lunch monitoring for all sites completed prior to or by February 1?Was at least one breakfast monitoring for 50 percent of sites completed prior to or by February 1?Does each site have written MCCPs and are they following them?Does the meal served meet the menu plan requirements, if not is there an approved waiver?Does the system accurately count meals by category at the POS?Are food safety, sanitation, and HACCP guidelines being followed?Are a la carte items, adult, second, and unpaid meals being accurately accounted for?Are all civil rights guidelines being followed?Is there a system in place to prevent duplicate meal counts?Note: When using technology such as video or photos, SFAs should follow any federal and state laws related to technology use and privacy. Information that contains Personally Identifiable Information (PII), such as applications or benefit status, should be protected. Information shared by program operators should be password protected or sent by other secure methods to ensure privacy.The USDA required that this waiver be used only to the extent needed until in-person can be resumed safely.COVID-19: Child Nutrition Response #100Nationwide Waiver to Allow Fiscal Action Flexibility for Meal Pattern Violations Related to COVID-19 Supply Chain Disruptions Impacting School Meals in SY 2021–22Waives the requirements to take fiscal action during the public health emergency for meal pattern violations related to COVID-19 supply chain disruptions.Expires: June 30, 2022Requirements for Supply Chain Distributions:Maintain documentation indicating a supply chain disruption occurred to avoid fiscal action for missing or shortage of meal componentsCancelled deliveriesCommunication from vendors indicating shipment delays, cancellations, substitutionsCancelled or amended contractsUpdate menu and MPRs to reflect what was actually offeredIs there documentation kept on file to support a supply chain disruption resulting in a missing meal pattern component or shortage?Note: SFAs may conduct emergency noncompetitive procurement(s) when an urgent need or emergency arises, such as the need to replace missing foods or paper goods with alternative sources or products quickly. Emergency noncompetitive procurement methods are a standing flexibility and do not require a waiver. For additional questions and technical assistance on emergency noncompetitive procurements, contact?SFSCONTRACTS@cde..Fresh Fruit and Vegetable Program (FFVP) Operations for SY 2021–22 during COVID-19Requirements for FFVP:For FFVP waiver approval: An email is to be sent to?FFVP@cde.?to opt-in. Was an FFVP opt in email submitted for approval?Is the FFVP opt in waiver completed?USDA Policy Memo SP 19-2021 FFVP Operations for SY 2021–22 during COVID-19: This memorandum provides clarification on questions related to the operation of the FFVP during COVID-19.FFVP Parent Pick-Up Waiver: This waiver allows SFAs participating in the FFVP to distribute FFVP snacks to a parent or guardian on behalf of their eligible child(ren) without the child(ren) being present.Serving FFVP at Alternate Sites Waiver: This waiver allows SFAs participating in the FFVP to offer FFVP snacks to elementary school children at nonFFVP school sites (elementary, middle, or high schools) if the FFVP school is closed or does not have meal service.Expires: June 30, 2022For SFAs to opt-in, to implement the FFVP Parent Pickup Waiver or the Serving FFVP at Alternate Sites Waiver for?SY 2021–22, please refer to . Noncongregate: Schools operating FFVP may serve fresh fruits and vegetables in a noncongregate setting, including through home delivery. See Noncongregate waiver requirements, including home delivery. Meal service times: Elementary schools operating FFVP may provide FFVP service alongside other Child Nutrition Program meals.Bulk pick-up: Elementary schools operating FFVP that are providing multiple days of meals at one time also may provide multiple servings of FFVP foods at one time. See Noncongregate waiver requirements, including home delivery.Education: Elementary schools operating the FFVP are encouraged to provide a nutrition education lesson with FFVP service, however not required. FNS recognizes that a nutrition education lesson may not be practical during this public health emergency.Eligible Participants: Elementary schools operating an SSO open site, FFVP foods may be provided to any children attending the site.Are the FFVP procedures updated to reflect current operations?How are FFVP accounted for at distribution sites?For noncongregate, home delivery are there consent forms signed and dated by the household prior to meal delivery service?Does the FFVP serving for a week reflect what would be served to an individual student during a school week?For meals picked up without eligible participants present, is there a process to indicate that meals picked up are only for eligible children?Is there documentation to support the claim (i.e., menu records, meal counts, invoices, etc.)? Fresh Fruit and Vegetable Program (FFVP) Operations for SY 2021–22 during COVID-19 (Continued)USDA Policy Memo SP 19-2021 FFVP Operations for SY 2021–22 during COVID-19: This memorandum provides clarification on questions related to the operation of the FFVP during COVID-19.FFVP Parent Pick-Up Waiver: This waiver allows SFAs participating in the FFVP to distribute FFVP snacks to a parent or guardian on behalf of their eligible child(ren) without the child(ren) being present.Serving FFVP at Alternate Sites Waiver: This waiver allows SFAs participating in the FFVP to offer FFVP snacks to elementary school children at nonFFVP school sites (elementary, middle, or high schools) if the FFVP school is closed or does not have meal service.Expires: June 30, 2022Parent Pick Up: SFAs operating the FFVP may distribute FFVP foods to a parent or guardian to take home to their children. See Parent Pick Up waiver requirements. Alternate Sites: SFAs operating the FFVP may serve FFVP foods at all sites under the SFA’s jurisdiction. Update FFVP procedures.Note: You may opt into this waiver at any time during the SY. Once selected, this waiver does not require periodic confirmation and will be valid for the entire 2021–22 SY.In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race,?color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. ?Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (state or local) where they applied for benefits. ?Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at 800-877-8339. ?Additionally, program information may be made available in languages other than English.To file a program complaint of discrimination, complete the?USDA Program Discrimination Complaint Form (AD-3027) found online at , and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:?Mail: U.S. Department of AgricultureOffice of the Assistant Secretary for Civil Rights1400 Independence Avenue, SWWashington, D.C. 20250-9410;?Fax: 202-690-7442; or?Email:?program.intake@.This institution is an equal opportunity provider. ................
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