Record Keeping for School Meal Programs

SFA’s 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.

SFA’s 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 recordsis 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:

  1. Temperature logs are required to be maintained for a period of six (6) months
  2. Provision 2 – Base year records
  3. 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 yearsin the Provision 2 cycle. The base year records must be maintained for three years after the final claim for reimbursement that utilized the percentagesestablished 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),SFA’smustretainthose recordsusedinthedevelopmentoftheIdentifiedStudentPercentage(ISP)(e.g.,recordsfortheinitialapprovalyearand allrecordsfromthe yearanyupdatesare made totheISP)duringthe entire periodtheCEP isineffect.

The SFA’s 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, SFA’s 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

SFA’s 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 SFA’s to determine how they will document and maintain theses records in their schools and districts. For example, SFA’s 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.

SFA’s 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 instancesthe 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 innotebooks 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 operationsthe 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

SFA’s 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 SFA’s 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.

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 regulationsthere 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 Served
SFA’s 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
RequiredforAR
POS reports, electronic record or manual records / Retention/Submission
Per onsite record retention policy / Frequency
Daily
Weekly
Monthlycumulative / Due Date/s
n/a
Edit Checks
Edit Checks are designed to be a tool for SFA’s 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 overclaims. SFA’s 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
-Required for AR
-POS software reports or forms / Retention/Submission
Per onsite record retention policy / Frequency
-Daily
-Monthly / Due Date/s
-Daily
-Monthly
Provision 2
SFA’s 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
SFA’s 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 SFA’s point of service system and not the school’s enrollment system.
Records
-Required for AR
-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 Headstart. / 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 residential only RCCI’s
Near 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
Required for AR
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 RCCI’s
SFA’s must(1)retainacopyofeachhousehold’sapplicationand(2)recordanyinformationrelatedtoapproval,denial,orterminationofbenefitsontheapplication. As well as any updates during the program year. SFAsusingelectronicapplicationsmusthaveawaytorecordandretainthesameinformation.
Records
RequiredforAR
-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 RCCI’s
RCCI’s 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
Required for AR
-Use form on SCN’s website. / Retention/Submission
-Per onsite record retention policy / Frequency
Asneeded
-Updatedannually / DueDate/s
-Annually
-Ongoing
Direct Certification Documents – N/A for residential only RCCI’s
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
Required for AR
Electronic copies of each monthly D.C. file and corresponding history file.
Signed lists from respective homeless, migrant, runaway and/or Headstart coordinator. / Retention/Submission
Per onsite record retention policy / Frequency
Ongoing as needed
Each electronic D.C. list must be saved on a monthly basis. / Due Date/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 RCCI’s
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
Required for AR
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
Required for AR
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 RCCI’s
Theselettersaresenttoparentsorguardianstoinformthemthattheirchildrenareapproved ordeniedforfreeorreduced-pricemealsorfreemilk.
Records
RequiredforAR
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
Updatedannually / DueDate/s
Upon eligibility determination.
LetterofEligibility—DirectCertification – N/A for Full CEP and residential only RCCI’s
SFA’s must notify households thattheirchildrenareDirectly Certified to receive free meals without the submission of a household application.
Records
RequiredforAR
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
SFA’s 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
RequiredforAR
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
SFA’s 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
RequiredforAR
SA approval of the SFA’s 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.

Verification Activities and Verification for Cause

Verification Sample Size – N/A for Full CEP and residential only RCCI’s
Documents 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 conductedthe calculation of the number of applications to verify. (All SFA’s must conduct standard verification unless approved by the SA to use an alternate method in their sponsor application.)
Records
RequiredforAR
Useoftheseformsorsimilarforms / Retention/Submission
Per onsite record retention policy / Frequency
Annually / DueDate/s
-October 1st
Confirmation Reviews – N/A for Full CEP and residential only RCCI’s
An individual other than the determining official must confirm that the original determination for free or reduced benefits was correctly determined.
Records
Required for AR
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 RCCI’s
If the SFA replaces a selected application for verification, a like application must be selected.
Records
Required for AR
-Document per district protocol. / Retention/Submission
Per onsite record retention policy / Frequency
Annually / DueDate/s
Prior to notifying the household of their selection for verification.
Notification of Selection for Verification Letter - N/A for Full CEP and residential only RCCI’s
Thisletterinforms households of the selection of their household application in the verification process.
Records
Required for AR
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 confirmation review.
Follow Up - N/A for Full CEP and residential only RCCI’s
If the households have not responded to their notice of verification, SFA’s are required to make at least 1 attempt to follow up with the household to try and obtain the necessary documents.
Records
RequiredforAR
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 RCCI’s
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.
Records
Requiredfor AR
-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 RCCI’s
SFA’s must informparentsorguardiansof households theresultsoftheverificationprocess.
Records
RequiredforAR
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 RCCI’s must report!
The SFA’smust annuallyreportinformation related to their verification activities (if applicable). Full CEP districts and RCCI’s 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
Required for AR
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