Do the words “administrative review” induce anxiety? Does sweat start beading on your forehead when you start thinking about the state coming in to access your meal program? Take a deep breath, grab a towel, and relax. . As long as you’re organized, well prepared, and know what to expect, your heart rate will stay in check and your review will be smooth sailing.
Every three years, reviewers from the Department of Education pay a visit to each school district that participates in the National School Lunch Program or School Breakfast Program to conduct an administrative review (AR). Their mission? To make sure everything is operating as it should be and to ensure federal dollars funding meal programs are being used appropriately.
Each Administrative Review component has specific requirements you must comply with, but we’re going to give you the nitty gritty on Meal Pattern and Nutritional Quality. This AR component requires schools to provide documentation for the items used on their menu. The state is looking to make sure all items meet nutritional and meal pattern standards and that the overall menu is suitable for service in K-12 schools. This means that dietary specs, meal component information, and nutrient analysis will be under their microscope. Their scrutiny is nothing to fear, as long as you have your documentation in order. And that means knowing what you need and how to get it.
Before you go rifling through piles of papers, you need to know that every Administrative Review is slightly different. Schools that are deemed “high risk”—unlikely to meet nutrient or meal pattern standards—could be asked to provide more documentation than schools who are deemed low-risk. Either way, there are two types of items that you should keep on file in case you are asked to provide them during an AR:
1. Child Nutrition Labeled items
2. Processed items that contribute to the meal pattern but are not CN labeled
Acceptable and valid documentation for CN labeled items includes:
If the original CN Label from the product carton, or the valid photograph or photocopy of the original CN label is not available, program operators may provide the Bill of Lading (invoice) containing the product name and:
Processed items that contribute to the meal pattern but are not CN labeled require a Product Formulation Statement (PFS). A PFS is a signed statement on manufacturer’s letterhead that demonstrates how the product contributes to meal pattern requirements.
Good news: you’re not required to obtain documentation for every single item on your menu. If the item does not contribute to the meal pattern (as is the case with condiments, bacon, pudding, and gelatin, to name a few) no documentation is needed. And no documentation is needed if the food is an unprocessed item with a standard meal pattern contribution; examples include fresh fruits, vegetables, milk, cheese, rice, pasta, and whole cuts of meat. For these items, the USDA Food Buying Guide should be used to determine how they contribute to the meal pattern.
Please keep in mind that even though you don’t need to keep documentation of file for every item, you do need to note all items and portion sizes on your production records.
The State Department of Education will contact your school district 4-6 weeks prior to your Administrative Review. This is the perfect time to collect documentation for your menu items. If you collect your documents right ahead of your AR, you can be sure the information is accurate and up-to-date. Some schools choose to collect documentation at the beginning of the school year or throughout the year, but product formulations can change at any time, which may affect the nutrition, ingredients, and meal pattern information for the item.
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