K-12 Nutrition Program Compliance Insight from a Former State Agency Program Consultant

When it comes to school nutrition and the USDA Foods in Schools programs, compliance is key. The better school nutrition programs are at remaining compliant, the more reimbursement funds they’ll receive, and the better their overall program will perform. The best way to stay in compliance is for K-12 school nutrition directors to have a good working relationship with their state nutrition agency. We asked a former state agency program consultant, Samantha Murillo, to share her thoughts on maintaining that good relationship and best practices for staying in compliance and running a successful school nutrition program. 

Samantha is the Nutrition Product Marketing Manager at LINQ. She has nearly four years’ experience at a state agency administering child nutrition programs, over five years’ experience at state agencies, and a Master of Public Administration from Ohio State. 

Establishing a Good Working Relationship with Your State Agency

Let’s start by establishing the relationship between K-12 nutrition directors and state agencies. What leads to a successful working relationship?

State agencies are in charge of managing child nutrition programs on behalf of the federal government, the USDA, for all the districts in their state. They help make sure that the districts are operating correctly so that they can provide them the maximum reimbursement possible. District food service directors want to work closely with their state agencies to make sure they are compliant and understand all of the requirements that are outlined in the regulations. State agencies can provide support and assistance to make sure that K-12 nutrition teams are compliant.

So what would be an example of a good working relationship between a state agency and a school nutrition director?

A good relationship would be monthly calls to check in where the state agency could answer any questions the school food service director might have and provide guidance. I have seen some districts hold monthly calls with all the stakeholders in their state. This brings food service directors together from different districts and they can get a sense of what works for other districts and help each other that way. Of course, if your state agency doesn’t hold those kinds of monthly calls, you can always reach out to your state agency representative. They are always more than happy to help because, if you’re reaching out for help, that means you want to stay in compliance and they want to help you be successful. Their goal is to have a smooth administrative review.

Avoiding Common Mistakes and Keeping Your School Nutrition Program in Compliance

Speaking of compliance, what are the main categories of foods that need to be included in a meal to make sure it’s reimbursable? 

You have to have fruit, a vegetable, grains, meat or meat alternate, and milk. 

Are there any exceptions made for students who don’t want to take a certain item or who need a substitution due to a food allergy?

In high schools, school nutrition programs can implement what’s called Offer vs. Serve. In this case, students have to take three of the five items required in order for the meal to be considered reimbursable. With regard to food allergies, as long as the allergy is documented, the school should make every possible effort to offer an alternative. That alternative would still be considered reimbursable. 

We are in the midst of verification season (October 1 – November 15). What are some things that school nutrition directors should know about income verification for free and reduced meals? 

One thing to note is that any family that receives food benefits like SNAP is categorically eligible to receive free and reduced meals. They don’t need to provide proof of income. Other income that can be counted, in addition to employment income, are social security, pensions, retirement, rental income, and any unemployment or disability benefits. In those scenarios, families do need to provide proof of income. 

Another thing to note is that free and reduced meal applications are not needed in school communities that meet the Community Eligibility Provision. In this case, at least 60% of the school population would qualify for free or reduced meals and the school is able to offer universal free meals. Schools that choose to do this need to verify their continued eligibility every three years. 

One issue that many school nutrition programs commonly have is “leaving money on the table,” or not taking full advantage of their Planned Assistance Level. In your experience, have you found that to be the case with many districts? 

It is something that’s common with USDA Food Distribution Programs. The reason is because many school food service directors don’t know how to use the programs and maximize their benefits. Especially now with ongoing supply chain and other challenges, it’s important to try to find more ways to offset your costs. One of the best ways to do that is to maximize your PAL

How can school nutrition directors ensure that they’re running a financially sound program?

School nutrition accounts are classified as non-profit food service accounts, so they aren’t intended to generate a profit. They should, however, aim to keep their costs as low as possible to generate as much revenue as is being spent. In other words, their goal is to break even. Some ways to keep costs low are to serve as many reimbursable meals as possible, buy ingredients in bulk to be used in multiple meals, and even using reusable plastic trays instead of disposable ones that need to continue to be repurchased. 

Using the Right Software to Manage Your School Nutrition Program Documentation

What can school nutrition directors do to avoid common documentation mistakes and ensure a smooth administrative review? 

The most important thing is to maintain accurate records. Everything needs to be documented and the most efficient way to do that is to keep your records online. Having things like your menu plans, production records and nutrition guidelines readily available will make the state agency’s job much easier. There are software programs that allow you to run reports, including an administrative review report, that you can hand to your state agency representative. It makes the entire process much easier and much more accurate. 

Get More USDA Foods Tips & Tricks

For more tips on how to best utilize USDA Foods in Schools, updates on reimbursement changes and bonus foods, check out this LINQ webinar. In it, LINQ nutrition experts, including Samantha Murillo, share advice from their own experience in the K-12 industry. 

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