Snack Program Compliance

1. PROGRAM COMPLIANCE
AFTERSCHOOL SNACK PROGRAM, FRESH FRUIT AND VEGETABLE PROGRAM,
AND THE SPECIAL MILK PROGRAM
PRESENTED BY: EDWARD COLEMAN
FEBRUARY 18, 2016
EDUCATION CODES: 3000 ADMINISTRATION, 3110 ELIGIBILITY, 3200 PROGRAM MANAGEMENT, 3310 MEAL
COUNTING AND CLAIMING, AND 3320 COMPLIANCE WITH REGULATIONS

2. WEBINAR OUTLINE
• Afterschool Snack Program (ASP)
• Fresh Fruit and Vegetable Program (FFVP)
• The Special Milk Program (SMP)

3. THE AFTERSCHOOL SNACK PROGRAM (ASP)
The Afterschool Snack Program allows participating schools to serve students nutritionally balanced snacks
while also providing appropriate activities.
• School Eligibility
• Program Documentation
• Counting and Claiming System
• Snacks Nutritional Requirements
• Educational or Enrichment Activity
• Food Safety and Civil Rights

4. SCHOOL ELIGIBILITY
I. Area Eligible Sites: These are locations within the geographical area of a school in which at least 50%
of enrolled students are certified for free or reduced priced meals. Snacks under this option are
served free to all children and reimbursed at the free rate for snacks.
II. Non- Area Eligible Sites: The snacks at these sites are served at the free, reduced, or paid rates for
snacks. The rate each child pays is based on approved eligibility such as income applications, direct
certifications, etc.
As a note Non- Area Eligible Sites must maintain the documentation used to establish a child's eligibility as
this documentation would be reviewed as part of an Administrative Review.

5. AFTERSCHOOL SNACK
PROGRAM
DOCUMENTATION
The SFA/RCCI must maintain
documentation that substantiates its
claims for reimbursement appropriate
documentation includes but is not
limited to the following;
• Daily Production Records
• Daily Count Sheets/Rosters
• Consolidated Count Sheets
• Delivery Invoices
• Benefits Issuance Roster with
correct eligibility determinations for
each child
• http://nutrition.nv.gov/layouts/Page
_Style_1.aspx?id=8674

6. COUNTING AND CLAIMING
The counting and claiming system that SFA’s and RCCI’s have in place must ensure that snacks are counted,
recorded, consolidated and reported through a system that consistently yields correct claims. This system
should ensure the following;
• Each eligible child only receives one reimbursable snack per snack service.
• The reimbursable snack is only counted when it is served to the child at the point of service.
• Children are able to participate in this program until they turn 18 or until the end of the school year if
they turned 19 during the current school year.
• NOTE: Children determined to have mental or physical disability are not subject to the age limit requirement.
• Adult snacks including snack served to children because of age limits are counted separately since they
are not reimbursable.

7. SNACK NUTRITIONAL
REQUIREMENTS
A reimbursable snack consists of two of the following four
components
1. Milk (flavored or unflavored fat free or unflavored low
fat)
2. Fruit or Vegetable
3. Grains
4. Meat/ Meat Alternate
Daily Production Records should indicate the quantities offered
to each age/grade group (See page I-15 of the Food Buying
Guide)
The Snack menu for the month should be posted
Examples of Allowable Snacks: Whole Wheat Gold Fish and Fat
Free Flavored Milk, String Cheese and Apples or A Whole Grain
Hot Pocket

8. EDUCATIONAL OR ENRICHMENT ACTIVITY
As part of the Afterschool Snack Program, SFA’s that offer the program must also offer an educational/
enrichment activity along with the snack. The activity should meet the following guidelines;
• It must be a structured and organized event
• It must be educational or enriching in nature
• It cannot be a purely athletic pursuit (like a little league team, organized athletic events such as baseball
games or basketball games)
Examples: arts/music activities, homework assistance, reading room/library, mentoring, life skills,
counseling, study hall

9. AFTERSCHOOL SNACK
PROGRAM SELF
MONITORING
Federal regulations require that the
Afterschool Snack Program be
monitored two times per year.
The first time the program must be
monitored is within the first four
weeks that the Afterschool Snack
Program begins each year.
The second time it must be
monitored is before the end of the
school year.
For SFA’s that have school year
round, the program would begin with
each new fiscal year.

10. FOOD SAFETY AND CIVIL RIGHTS
The Afterschool Snack Program must adhere to the following Food Safety requirements
• HAACP principles in handling food must be followed;
• http://sop.nfsmi.org/sop_list.php
• Most Recent Food Safety Inspection must be posted
• A system to handle special diets
• Up to date Temperature Logs
The Afterschool Snack Program must adhere to the following Civil Rights requirements:
• Have a policy for collecting ethnic and racial data
• “And Justice for All” posters must be prominently displayed
• A Civil Rights policy that meets standard program requirements
• Annual Civil Rights training;
• http://nvcnp.doe.nv.gov/frameManager.aspx

11. THE FRESH FRUIT AND VEGETABLE PROGRAM (FFVP)
The Fresh Fruit and Vegetable Program (FFVP) seeks to increase children's exposure to and consumption of
a variety of fruits and vegetables.
• Claim Documentation
• Claim Validation
• Buy American Provision
• Program Guidelines for the FFVP
• Food Guidelines for FFVP
• The Nutritional Education Component
Resources: http://www.fns.usda.gov/ffvp/fns-resources,
http://www.fns.usda.gov/sites/default/files/handbook.pdf

12. CLAIM DOCUMENTATION
The following documentation can be used to substantiate the claims for reimbursement;
• Invoices for produce
• Invoices for products used in the food service (napkins, utensils, etc.)
• Clear documentation of worker time spent in the program
• Clear documentation of the year to date administrative costs charged to the program
• Documentation supporting the costs of equipment bought for the program

13. CLAIM VALIDATION
General Guidelines; for more in depth information please see our webinar;
http://www.slideshare.net/NevadaAgriculture/fresh-fruit-and-vegetable-program-webinar-from-
the-nevada-department-of-agriculture-2014

14. THE BUY AMERICAN PROVISION
SFA’s that participate in the FFVP must also adhere to the Buy American Provision. The Provision, CFR 210.21
(d)(1) through (d)(2)(ii), describes the criteria of what constitutes a domestic commodity or product.
• An agricultural commodity that is produced in the US
• A food product that is processed in the US substantially using agricultural commodities that are produced in
the US.
1. To qualify as domestic over 51% of the final processed product consists of agricultural commodities that were
grown domestically.
Exceptions to the Buy American Provision
• The product is not produced or manufactured in the US in sufficient and reasonably available quantities of a
satisfactory quality
• Competitive bid reveals the costs of a US product is significantly higher than a foreign product

15. PROGRAM GUIDELINES FOR FFVP
The following guidelines are specific to the Fresh Fruit and Vegetable Program;
• The program must occur at least 2 times a week for all students
• The program must offer a variety of fruits and vegetables
• REPEAT OFFERINGS ALLOWED
• THINK SEASONAL AND LOCAL WHEN POSSIBLE
• Servings do not have to be full portions

16. FOOD GUIDELINES FOR FFVP
The foods served during the FFVP must adhere to the following guidelines;
• The following foods are not allowed as part of the FFVP; frozen, canned, dried, and other types of
processed fruits, fruit/vegetable juice, nuts, cottage cheese, trail mix, fruit or vegetable pizza,
smoothies, fruit strips, drops, or leather.
• Cooked vegetables may not be offered more than once per week and only when included as part of a
nutrition education lesson
• Dip may be provided for vegetables but it must be low fat or fat free and no larger that 2 tablespoons

17. THE NUTRITIONAL EDUCATION COMPONENT
This nutritional educational component must be a part of every FFVP service. The link below provides
additional information in general on the FFVP.
Resources
• USDA toolkit
• http://www.fns.usda.gov/ffvp/ffvp-toolkit
• Harvest of the Month—Fruit and Veggie info sheets
• http://harvestofthemonth.cdph.ca.gov/Pages/Downloads.aspx
• http://www.massfarmtoschool.org/programs/harvest-of-the-month/
• http://idahopreferred.com/farm-to-school/posters/
• http://www.sdharvestofthemonth.org/

18. THE SPECIAL MILK PROGRAM (SMP)
The Special Milk Program provides milk to children in schools, nonprofit RCCI’s, and eligible camps that do
not participate in other Federal child nutrition meal service programs.
• The Public Release
• The Pricing Policy
• SMP Options
• Counting and Claiming
• Program Compliance
• Recordkeeping

19. THE PUBLIC RELEASE
• Must be announced near the beginning of
the school year
• Must include the eligibility criteria for free
milk
• Must contain the Income Eligibility
guidelines for Free Milk Only
• Must be provided to local media, the
unemployment office, and employers
contemplating large layoffs

20. THE PRICING POLICY
SFA’s operating the SMP must price their milk in accordance with Food and Nutrition Services policy.
• The school or institution may elect to have a pricing or non- pricing program.
• The milk service must be nonprofit and under no circumstances can SMP income be used to subsidize
other meals or programs
• Excess funds from the SMP can be used for program improvement and/or to reduce the cost of milk for
participants in the SMP

21. SPECIAL MILK PROGRAM OPTIONS
Sponsors must choose and operate one of the following SMP Options in their program
Non Pricing Programs
• Option I- Milk is provided to all children participating in this program free of charge. The cost of milk
beyond the federal reimbursement rate is born by the school or institution.
Pricing Programs
• Option II- All children are charged a predetermined price established by the sponsor. The price paid by
the children = Cost of Milk - Federal Reimbursement Rate + up to $0.05 (maximum) Administrative fee.
• Option III- Milk is served free to eligible students and sold to others at a reduced rate. The price for milk
paid by the children who receive the reduced rate = Cost of Milk – Federal Reimbursement Rate.

22. COUNTING AND CLAIMING- DOCUMENTATION
The following documentation must be maintained to help substantiate your claims for reimbursement in
the Special Milk Program;
• Records supporting the number of milks served daily and claimed for reimbursement
1. daily count sheets for milk served
2. milk used in cooking, spoiled, and served to adults/non program eligible participants
• Daily Attendance rosters for participants in this program
• Milk order documentation such as invoices and delivery records
• Certification documentation for participants in this program where necessary

23. COUNTING AND CLAIMING-
SYSTEM
The counting and claiming system
should follow the guidelines listed
below;
• The milk may only be counted
when it is given to the child at the
point of service.
• The eligibility status of each child
is transferred accurately to the
roster

24. PROGRAM COMPLIANCE
The Special Milk Program must also meet the following
program specific federal regulations;
• Civil Rights
• “And Justice for All” Posters must be prominently
displayed
• System for collecting racial and ethnic data for
participants in this program
• Civil rights complaint system
• Food Safety
• HAACP Manual with SMP specific SOPs
• Log of weekly milk refrigerator/storage cleaning
• Temperature log for milk refrigerator/storage units

25. QUESTIONS?

26. EDUCATIONAL CODES FOR PROFESSIONAL
STANDARDS
• Education Codes: 3000 Administration, 3110 Eligibility, 3200
Program management, 3310 Meal counting and claiming, and
3320 Compliance with Regulations