Record Keeping for School Meal Programs
SFAs must retain records and documentation concerning all aspects of operating a Child Nutrition Program. While it can be tedious and overwhelming, it is important that appropriate and adequate records are maintained.
SFAs must retain documentation to support:
•Information/data reported to the State Agency
•Program operations are in compliance with regulations
•Demonstrate that policies and procedures are properly implemented
•Sound program operational decisions are made
Record Retention Requirements
The general rule of thumb for record retention of program records is that they must be maintained foraperiod of three yearsaftersubmission of thefinal Claim for Reimbursement forthe fiscal year. However, if there are any audit findings and they have not been resolved, the three-yearperiod isextended aslong as requiredfor resolutionofauditissues.
There are three (3) main exceptions to this rule of thumb:
- Temperature logs are required to be maintained for a period of six (6) months
- Provision 2 – Base year records
- CEP - ISP records
AllProvision2andCEPrecordsmustberetainedfor threeyearsaftersubmissionofthefinalclaimforreimbursement.Recordsmustcontinuetoberetained if anyauditfindingsfromthe period duringwhich therecordswere in useremainoutstanding.Inanysuch case,recordsmustberetained untilall issuesraisedbytheaudithavebeenfullyresolved.
The base year in Provision 2 establishes a claiming percentage that is utilized in subsequent years in the Provision 2 cycle. The base year records must be maintained for three years after the final claim for reimbursement that utilized the percentages established by the base year is filed.
BaseyearrecordsforProvision2 to maintain:
- Student eligibility certification records
- Verification Records
- Claims
- Meal Count Records
The records demonstrating that the claiming percentages established by the base year are properly applied for the Provision 2 cycle and any approved extensions are:
- Monthly claims for reimbursement
- Meal count records used in claiming
ForCommunityEligibilityProvision (CEP),SFAsmustretainthose recordsusedinthedevelopmentoftheIdentifiedStudentPercentage(ISP)(e.g.,recordsfortheinitialapprovalyearand allrecordsfromthe yearanyupdatesare made totheISP)duringthe entire periodtheCEP isineffect.
The SFAs April reporting establishes the ISP that will be used in the CEP cycle. When establishing a base year for a CEP cycle, the April data reported in the school year prior to the base year is the information that must be maintained until the end of the cycle, plus three years after the last claim is filed.
If April reporting indicates that the ISP is higher than the established percentage currently used for claiming, SFAs are encouraged to establish a new base year and start a new cycle. If the SFA does not elect to start a new cycle with the higher ISP, the records for the base year and the updated ISP must be maintained for three years after the last claim is filed for the CEP cycle.
The records used in the April reporting and used to establish an ISP must come from the Child Nutrition Programs point of service system. The records that must be reported from and maintained are:
- The number of enrolled students on April 1st
- The number of identified students (directly certified) on April 1st
- The list of student names of the enrolled students
- The list of student names of the identified (directly certified) students
SFAs may need to maintain records longer than what is outlined in federal requirements if there are local policies in the districts/organizations that dictate records be maintained for a longer period of time. Local policies cannot be followed if the record retention is for a lesser period of time than the federal requirements.
Records and Documents
There are numerous recordkeeping requirements related to the operation of a child nutrition program. Some recordkeeping requirements have a required format or form that must be used. However, most required documentation is up to the SFAs to determine how they will document and maintain theses records in their schools and districts. For example, SFAs must use the “Onsite Monitoring Form” found on SCN’s website to document the onsite reviews they conduct. However, in verification there is not a required form or format that must be used when documenting information concerning follow up attempts with households who haven’t responded. In this instance the SFA has to determine how this recordkeeping requirement will be handled in their operation.
SFAs at times will use their own record keeping documents to record information that is later transferred over to a required form or format. In these instances the SFA’s records that were used to create or develop the information that is transferred or used on the required form is considered the source documentation and must be maintained with the required form. For example, it is a common practice for production staff to record the number of servings prepared in notebooks or commonly called a “cooks’ book” in the kitchen while preparing meals so that they don’t have to write and erase on the actual production record. The manager then rewrites information from the notebook onto the production record after the meal service. In this instance the “cooks’ book” is the source documentation for the number of servings prepared and must be maintained with the production record in order to have the required documentation about the number of portions prepared for the meal service.
Adequately Documented
When determining how a to document and record program operations the guiding principle of creating an auditable trail should be followed to ensure that operations are adequately documented. This criterion of “adequately documented” does not imply the existence of a one‐size‐fits‐all definition of “adequately.” It means, that the record of a school meal programs’ operation must be able to stand on its own without being dependent on further information, interpretation, or “spin” by the program operator.
For example, it should be self-evident from the review of meal counting records what students ate lunch on which days in the month that made up the number of lunch meals claimed for reimbursement.
Storage of Records
SFAs are encouraged to develop a system of document retention that allows them to be readily retrieved when needed. Electronicrecordkeeping is anallowableformof record storage and is encouraged as an avenue to reduce the amount of paper SFAs maintain. Districts/organizations may have policies related to electronic record keeping that SFA’s may need to include in their record keeping processes.
When storing records electronically, the records should be stored in a manner in which they are accessible to others within LEA when needed and in a secure manner. Any student identifying information should be in a locked cabinet or similar manner in which individuals outside of the Child Nutrition Program do not have access to the information. While it may be convenient to access records when they are stored locally on a computer, the records may easily be lost due to computer issues and will not be accessible to others if needed. It is highly recommended that electronic records are backed up to a secure server or saved a portable storage device that is then stored in a secure location.
Record Keeping Charts
The charts below provide a brief overview of records SFA’s should maintain. This list is not meant to be all inclusive. Depending upon program operations within individual schools and organizations or ongoing changes to policies and regulations there may be additional records that must be maintained. SFA’s should refer to guidance, policy and regulations for further information.
Meal Counting and Claiming
Record of Meals ServedSFAs must maintain records of the number of meals served at a point of service in order to claim meals for reimbursement. These records must(1)Record thetotalnumberofreimbursablemealsservedbyeligibilitycategoryand(2)createcumulativemonthlyreports.
Records
POS reports, electronic record or manual records. / Retention/Submission
Per onsite record retention policy. / Frequency
Daily
Monthlycumulative / Due Date/s
-n/a
Edit Checks
Edit Checks are designed to be a tool for SFAs to (1) check the accuracy of the number of meals claimed by eligibility category for a specific meal period and month of operation and (2) reduce the incidence of over claims. SFAs are required to perform Edit Checks daily and monthly on cumulative data prior to filing a claim for reimbursement..
If more meals are served than anticipated, the SFA must investigate and document resulting action.
Records
-POS software reports or forms / Retention/Submission
Per onsite record retention policy. / Frequency
-Daily
-Monthly / Due Date/s
-Daily
-Monthly
Provision 2
SFAs operating breakfast and/or lunch under the provision 2 option must maintain the documentation to support the establishment of the base year data and the application of the claiming percentages used in subsequent years.
Records
Required for AR
Base year eligibility certification documents
Base year verification
Base year claims
Base year meal counts / Retention/Submission
Per onsite record retention policy. / Frequency
Daily
Monthly / Due Date/s
-n/a
April Reporting/Identified Student Percentage – N/A to residential only RCCI’s
SFAs must report the number of identified students through direct certification and the total enrollment at each school site as of April 1st. This data is utilized to identify potential CEP eligibility and to establish the claiming percentage utilized by CEP schools. Reports must be generated by the SFAs point of service system and not the school’s enrollment system.
Records
-The number of enrolled students and the number of directly certified student students on April 1st for each school.
-A list of all students enrolled in each school that makes up the enrollment numbers reported.
-A list of students in each school that are identified as D.C. that make up the number of Identified Students reported.
-Electronic direct certification March history file
Signed lists for homeless, runaway, migrant and Head start.
Documentation of the makeup of households to support extended studenteligibility. / Retention/Submission
Per onsite record retention policy.
Submitted through CNIPS. / Frequency
Annually / DueDate/s
Annually per SCN.
Free and Reduced Price Process
Public Media Release – N/A for residentialRCCIsNear the beginning of each school year, the public must be notified that free and reduced price meals and free milk are available. This notice must include the eligibility criteria for free and reduced price meals or free milk or the schools participation in the Community Eligibility Provision. It must be provided to the local news media, the unemployment office, and any major employers who are contemplating large layoffs in the attendance area of the school. The media release must contain all informational elements outlined in the current year Eligibility Manual for School Meals.
Records
Content of the Public Media Release must follow the guidelines outlined in the current years USDA Eligibility Manual for School Meals. / Retention/Submission
Per onsite record retention policy.
Must be submitted to the SA and approved as part of the Policy Statement. / Frequency
Updatedannually / DueDate/s
Required release at or close to the beginning of the school year.
Required to be submitted for approval in the Policy Statement prior to use.
Household Application, Letter to Households and Instructions – N/A Full CEP and residential only RCCIs
SFAs must(1)retainacopyofeachhousehold’sapplicationand(2)recordanyinformationrelatedtoapproval,denial,orterminationofbenefitsontheapplication. As well as any updates during the program year. SFAsusingelectronicapplicationsmusthaveawaytorecordandretainthesameinformation.
Records
-Must use the current year prototype household application. State Agency approval required annually for use of any other form or format. / Retention/Submission
Per onsite record retention policy.
Must be submitted to the SA and approved as part of the Policy Statement. / Frequency
Asneeded
-Updatedannually / DueDate/s
Requiredreleasepriorto or during the firstweek of schoolandasstudentsenroll
-Required to be submitted for the Policy Statement prior to use.
Individual Determination Form – Used only for residential only children in RCCIs
RCCIs must determine residential children’s eligibility status through the use of an Individual Determination Form in order to be reimbursed at the free rate for the meals served.
Records
Use form on SCN’s website. / Retention/Submission
Per onsite record retention policy. / Frequency
As Needed
Updatedannually / DueDate/s
Annually
Ongoing
Direct Certification Documents – N/A for residential only RCCIs
The documents used to provide a student a directly certified eligibility status must be maintained. A designation due to SNAP benefits takes precedence for the reason for D.C. if more than one avenue to a D.C. status applies. Once the avenue for D.C. is identified as SNAP, this should remain constant for the rest of the program year regardless if other reasons for D.C. designation are identified.
Records
-Electronic copies of each monthly D.C. file and corresponding history file.
-Signed lists from respective homeless, migrant, runaway and/or Head Start coordinator.
-Documentation of the makeup of households to support extended student eligibility. / Retention/Submission
Per onsite record retention policy. / Frequency
-Ongoing as needed
-Each electronic D.C. list must be saved on a monthly basis. / DueDate/s
-Electronic D.C. downloads should be conducted on a monthly basis.
-Ongoing for other forms of D.C.
Income Eligibility Guidelines (IEG) Chart – N/A Full CEP and residential only RCCIs
The income eligibility guidelines are released annually from Congress to be used in determining the income guidelines to qualify for free or reduced meals. The income eligibility chart must be included in the public media release and the letter to households that accompanies the household application.
Records
Use format provided in the current year prototype application packet. / Retention/Submission
Per onsite record retention policy. / Frequency
As needed
Updated annually / Due Date/s
Released annually
Appeals related to Student Eligibility
When households appeal the eligibility determination of their household application, records of the appeals process must be maintained to demonstrate compliance with requirements.
Records
Any related
Communications
Timelines and Outcome / Retention/Submission
-Per onsite record retention policy / Frequency
As needed / Due Date/s
-Annually
LettertoHouseholdofApproval/DenialofBenefits – N/A for Full CEP and residential only RCCIs
Theselettersaresenttoparentsorguardianstoinformthemthattheirchildrenareapproved ordeniedforfreeorreduced-pricemealsorfreemilk.
Records
-Must use current year prototype letter or have alternate approved by the SA each program year. / Retention/Submission
Per onsite record retention policy. / Frequency
Asneeded
Updated annually / DueDate/s
-Upon eligibility determination.
LetterofEligibility—DirectCertification – N/A for Full CEP and residential only RCCIs
SFAs must notify households thattheirchildrenareDirectly Certified to receive free meals without the submission of a household application.
Records
Must use current year prototype letter or have alternate approved by the SA each program year. / Retention/Submission
Per onsite record retention policy. / Frequency
Ongoing / DueDate/s
Upon certification
Confidentiality and Disclosure
SFAs are required to keep all information concerning student eligibility confidential and must maintain documentation that any disclosures to persons outside of the school meals program is in compliance with federal regulations.
Records
Disclosure agreements
Disclosure policy
Requests for information
Signed confidentiality agreements for all persons provided information. / Retention/Submission
-Per onsite record retention policy. / Frequency
Ongoing / DueDate/s
-Ongoing
Effective Date of Eligibility
SFAs must be approved by the SA to establish the effective date of eligibility as the date in which an application or D.C. information was received instead of when the information is processed. Refer to the current year eligibility manual for all requirements related to this flexibility.
Records
SA approval of the SFAs procedures for implementing the flexibility date of eligibility (meal counting and claiming procedures)
SA approval of use in the sponsor application
Documentation of the date in which information was received in the district
Records demonstrating that any charges or money collected in the time period between being the information being received and when it was processed is forgiven or reimbursed to the household prior to claiming. / Retention/Submission
Per onsite record retention policy.
Approval submitted through CNIPS during online application renewal. / Frequency
As needed / DueDate/s
Must be approved annually
Documentation of time of receipt and forgiveness/reimbursement in place prior to claiming.
Independent Review of Applications
As part of an effort to decrease certification error during the eligibility determination process, section 304 of the HHFKA requires that certain local education agencies (LEAs) conduct a second, independent review of applications for free and reduced price meal benefits before eligibility determinations are made. LEAs that demonstrate high levels of, or a high risk for administrative error associated with certification and benefit issuance are required to conduct a second review of applications. Criteria 1: All LEAs with 10 percent or more of the certification /benefit issuances in error as determined by the State agency during an administrative review. Criteria 2: LEAs with greater than or equal to 5% benefit issuance errors and less than 10% benefit issuance errors as determined by the State agency during an administrative review.
Records
All applications, free, reduced, paid, denied as of October 31st.
Documentation and notes included with applications if further information was necessary to complete the application.
Report form 874. / Retention/Submission
Per onsite record retention policy. / Frequency
Annually until State Agency determines via Administrative Review that the benefit/issuance errors fall below 5%. / DueDate/s
-SFA will be notified they must do an Independent Review by July 1st.
-Report Form 874 due to State Agency by November 15th.
Verification Activities and Verification for Cause
Verification Sample Size – N/A for Full CEP and residential only RCCIsDocuments or reports utilized to determine the number of approved free and reduced household applications on file as of October 1st. Documents or reports should indicate the number of apps approved for free or reduced benefits by income or categorical eligibility.
Records should indicate the type of verification conducted the calculation of the number of applications to verify. (All SFAs must conduct standard verification unless approved by the SA to use an alternate method in their sponsor application.)
Records
Useoftheseformsorsimilarforms / Retention/Submission
Per onsite record retention policy. / Frequency
Annually / DueDate/s
-October 1st
Confirmation Reviews – N/A for Full CEP and residential only RCCIs
An individual other than the determining official must confirm that the original determination for free or reduced benefits was correctly determined.
Records
Document signature and date of confirmation official per district protocol. / Retention/Submission
-Per onsite record retention policy. / Frequency
-Annually / DueDate/s
-Prior to notifying the household of their selection for verification.
Replacement of selected application - N/A for Full CEP and residential only RCCIs
If the SFA replaces a selected application for verification, a like application must be selected.
Records
Document per district protocol. / Retention/Submission
Per onsite record retention policy. / Frequency
Annually / DueDate/s
-Prior to notifying household of their selection for verification.
Notification of Selection for Verification Letter - N/A for Full CEP and residential only RCCIs
SFAs must informhouseholds of their selection of their household application in the verification process.
Records
Must use current year prototype letter or have alternate approved by the SA each program year. / Retention/Submission
-Per onsite record retention policy. / Frequency
-Annually / DueDate/s
-Upon completion of the confirmation review.
Follow Up - N/A for Full CEP and residential only RCCIs
If the households have not responded to their notice of verification, SFAs are required to make at least 1 attempt to follow up with the household to try and obtain the necessary documents.
Records
-Document per district protocol. / Retention/Submission
Per onsite record retention policy. / Frequency
Annually / DueDate/s
Prior to November 15th (Best practice – 2 weeks after notification).
Household Documentation Submissions - N/A for Full CEP and residential only RCCIs
Households must submit documentation to support all of the income information provided on their household application or documentation of any case number provided on a household application. If the determination for the household was based upon the income information provided, proof of income in the allowable timeframe must be submitted to support the income reported. If the determination was made based upon a case number on the application, the household must provide documentation of receiving SNAP or KTAP benefits.
Records
-Maintain documents and any related communication with households per district protocol. / Retention/Submission
-Per onsite record retention policy. / Frequency
-Annually / DueDate/s
-November 15th
Results of Verification Notification Letter - N/A for Full CEP and residential only RCCIs
SFAs must informparentsorguardians of households theresultsoftheverificationprocess. Prototype letters are released annually with the application packet that includes all of the required content of a letter to inform households as outlined in the most recent USDA Eligibility Manual for School Meals guidance.
Records
-Must use current year prototype letter or have alternate approved by the SA each program year. / Retention/Submission
Per onsite record retention policy. / Frequency
Annually / DueDate/s
Upon completion of validating a household application. All must be validated and letter sent by November 15th.
FNS-742/Verification Report – All schools including CEP and RCCIs must report!
The SFAsmust annuallyreportinformation related to their verification activities (if applicable). Full CEP districts and RCCIs report the number of schools/sites and the number of enrolled students as of October 1st. Most point of service electronic systems have the capability create a report to provide the information and data required for this reporting event.
Records
Entered into CNIPS. SFA’s should maintain documents that support the submission. / Retention/Submission
Per onsite record retention policy.
Submitted through CNIPS / Frequency
Annually / DueDate/s
Per SCN announcement
Onsite Monitoring - When there are two or more Schools