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School Nutrition Programs Administrative Review

Includes information, regulations, procedures, and updates on the School Nutrition Programs (SNP) administrative review (AR).

The Nutrition Services Division (NSD) performs an AR of all school food authorities (SFA) participating in the National School Lunch Program (NSLP) and/or School Breakfast Program (SBP) over a three-year cycle. The term SFA refers to the governing body responsible for school food service operations and includes any agency participating in the SNP. This web page is a resource for SFAs and answers questions about the AR.

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Overview

Section 207 of the Healthy, Hunger-Free Kids Act of 2010 amended Section 22 of the Richard B. Russell National School Lunch Act, Title 42, U.S. Code 1769c, to require the implementation of a more robust and unified accountability system. After a thorough assessment of review requirements in Title 7, Code of Federal Regulations, Section 210.18, the U.S. Department of Agriculture (USDA) established a new process for reviews of SNPs, referred to as the AR.

Implementation of the Administrative Review

Before School Year (SY) 2013–14, the California Department of Education (CDE) conducted reviews using the Coordinated Review Effort. The new AR process implements the following changes:

  • New Off-site Assessment Tool

  • Increased focus on the overall financial health of an SFA’s nonprofit school food service account (cafeteria fund) in a new Resource Management section. An assessment of the need for a comprehensive SNP AR using the Resource Management Risk Indicator Tool

  • A comprehensive review of the SBP and other federal SNPs (i.e., Afterschool Meal Supplements [snacks], Seamless Summer Option, Special Milk Program, and Fresh Fruit and Vegetable Program)

  • Elimination of follow-up review thresholds

On July 29, 2016, the USDA released the final rule titled ARs in the SNPs. The final rule became effective September 27, 2016, and establishes a unified accountability system in the SNPs by revising the state agency’s review process for the NSLP and SBP. Since the CDE already implemented the updated SNP AR process, many of the changes included in the final rule are currently in place. Some key changes that are new to California include:

  • Modification to the CDE’s authority to limit fiscal action for specific critical area violations when corrective action is completed

  • Identification of the scope and duration of fiscal action for repeated violations related to vegetable subgroups, milk type, food quantities, whole grain-rich foods, and dietary specifications. This will be effective beginning in SY 2017–18 in California due to a special waiver that added a fourth year to the first review cycle

  • Clarification of the SFAs’ responsibilities with regard to indirect costs and donated foods

  • Expansion of the SFA on-site review requirements to include the SBP and readily observable general areas of review. An SFA claims review process requirement is also included for the SBP

  • Inclusion for the use of email or fax in addition to traditional methods to send specific documents. These documents include notices to the SFA regarding claim denials or withholding payment, documented corrective action, SFA requests for appeal, and notice of the time, date, and place of hearings

  • Requirement for the CDE to review at least one school from each Local Education Agency (LEA) for SFAs that consist of more than one LEA

The final rule is available on the Federal Register ARs on the SNPs web page External link opens in new window or tab..

On May 17, 2017, the USDA released Policy Memorandum SP 31-2017: Clarifications for Fiscal Action School Food Authority-Wide for Administrative Reviews in School Year 2016–2017 External link opens in new window or tab.. This policy memo provides two options for the CDE to implement fiscal action SFA-wide beginning in SY 2016–17. The CDE has opted to follow option two: State agency discretion to trigger fiscal action SFA-wide using a 3 percent error threshold.

Review Objectives

The CDE and the SFA collaborate to complete the AR to ensure program integrity and increase overall compliance, with the following objectives:

  • Determine if the SFA is meeting all federal and state SNP requirements

  • Provide focused technical assistance (TA) to assist the SFA with correcting any findings

  • Secure necessary corrective action documentation demonstrating the SFA’s permanent corrections

  • Assess fiscal action and, when applicable, recover improperly paid funds

It is the CDE’s priority to provide clear and consistent communication, ample TA, and excellent customer service during the transition to the new review process.

In an effort to streamline the AR process, the NSD will implement a multiprogram review approach and review both the NSLP and the CACFP during the same review period if an SFA operates both programs. Federal guidance encourages this streamlined approach to lessen the burden on SFAs. This guidance comes from USDA policy memorandums SP 09-2013 and CACFP 04-2013.

Review Process Phases

The AR process consists of four phases: prereview, on-site review, off-site review, and post-review. The Administrative Review Process from the School Food Authority Perspective (DOC) flowchart provides a high-level overview of the procedures associated with each of the phases. An accessible description of the phases is available in Management Bulletin SNP-23-2015 under Administrative Review Process. Subsequent tabs provide further detail for each of the phases: Prereview, Off-site Review, On-site Review, and Post-review.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Wednesday, June 26, 2024
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