Exhibit A

Internal Control Requirements
Excerpt From the National School Lunch Program Regulations
(7 CFR Part 210)

Sec. 210.8 Claims for reimbursement.

(a) Internal controls. The school food authority shall establish internal controls which ensure the accuracy of lunch counts prior to the submission of the monthly Claim for Reimbursement. At a minimum, these internal controls shall include: an on-site review of the lunch counting and claiming system employed by each school within the jurisdiction of the school food authority; comparisons of daily free, reduced price and paid lunch counts against data which will assist in the identification of lunch counts in excess of the number of free, reduced price and paid lunches served each day to children eligible for such lunches; and a system for following up on those lunch counts which suggest the likelihood of lunch counting problems.

(1) On-site reviews. Every school year, each school food authority with more than one school shall perform no less than one on-site review of the lunch counting and claiming system employed by each school under its jurisdiction. The on-site review shall take place prior to February 1 of each school year. Further, if the review discloses problems with a school’s meal counting or claiming procedures, the school food authority shall: ensure that the school implements corrective action; and, within 45 days of the review, conduct a follow-up on-site review to determine that the corrective action resolved the problems. Each on-site review shall ensure that the school’s claim is based on the counting system authorized by the State agency under Sec. 210.7(c) of this part and that the counting system, as implemented, yields the actual number of reimbursable free, reduced price and paid lunches, respectively, served for each day of operation.

(2) School food authority claims review process. Prior to the submission of a monthly Claim for Reimbursement, each school food authority shall review the lunch count data for each school under its jurisdiction to ensure the accuracy of the monthly Claim for Reimbursement. The objective of this review is to ensure that monthly claims include only the number of free, reduced price and paid lunches served on any day of operation to children currently eligible for such lunches.

(i) Any school food authority that was found by its most recent administrative review conducted in accordance with Sec. 210.18, to have no meal counting and claiming violations may:

(A) Develop internal control procedures that ensure accurate meal counts. The school food authority shall submit any internal controls developed in accordance with this paragraph to the State agency for approval and, in the absence of specific disapproval from the State agency, shall implement such internal controls. The State agency shall establish procedures to promptly notify school food authorities of any modifications needed to their proposed internal controls or of denial of unacceptable submissions. If the State agency disapproves the proposed internal controls of any school food authority, it reserves the right to require the school food authority to comply with the Provisions of paragraph (a)(3) of this section; or

(B) Comply with the requirements of paragraph (a)(3) of this section.

(ii) Any school food authority that was identified in the most recent administrative review conducted in accordance with Sec. 210.18, or in any other oversight activity, as having meal counting and claiming violations shall comply with the requirements in paragraph (a)(3) of this section.

(3) Edit checks.

(i) The following procedure shall be followed for school food authorities identified in paragraph (a)(2)(ii) of this section, by other school food authorities at State agency option, or, at their own option, by school food authorities identified in paragraph (a)(2)(i) of this section: the school food authority shall compare each school’s daily counts of free, reduced price and paid lunches against the product of the number of children in that school currently eligible for free, reduced price and paid lunches, respectively, times an attendance factor.

(ii) School food authorities that are identified in subsequent administrative reviews conducted in accordance with Sec. 210.18 as not having meal counting and claiming violations and that are correctly complying with the procedures in paragraph (a)(3)(i) of this section have the option of developing internal controls in accordance with paragraph (a)(2)(i) of this section.

(4) Follow-up activity. The school food authority shall promptly follow up through phone contact, on-site visits or other means when the internal controls used by schools in accordance with paragraph (a)(2)(i) of this section or the claims review process used by schools in accordance with paragraphs (a)(2)(ii) and (a)(3) of this section suggest the likelihood of lunch count problems. When problems or errors are identified, the lunch counts shall be corrected prior to submission of the monthly Claim for Reimbursement. Improvements to the lunch count system shall also be made to ensure that the lunch counting system consistently results in lunch counts of the actual number of reimbursable free, reduced price and paid lunches served for each day of operation.

(5) Recordkeeping. School food authorities shall maintain on file, each month’s Claim for Reimbursement and all data used in the claims review process, by school. Records shall be retained as specified in Sec. 210.23(c) of this part. School food authorities shall make this information available to the Department and the State agency upon request.

Exhibit B

SAMPLE PUBLIC RELEASE TEMPLATE

Instructions:

Reproduce the following text on your letterhead. Date, sign, and send to the local media at the beginning of each school year requesting that the release be published at no charge as a public service to the community. It is up to the local media to decide whether to publish the release as a public service at no charge. A School Food Authority (SFA) is not required to get the release published nor are local media required to publish it.

Retain a copy of the release for your files. The media release must be dated and state the name of the media outlet to which it was sent.

FOR IMMEDIATE RELEASE

[NAME OF SCHOOL FOOD AUTHORITY] today announced an amendment to its policy for serving meals to students under the [National School Lunch / School Breakfast Programs] for the [yyyy-yyyy] school year.

All students will be served [breakfast / lunch] at no charge at the following site(s): [site names]

For additional information please contact:[Name of School District], Attention:[Name, Title],[Department/Division], [Address], [City, State ZIP], [Telephone Number], [E-mail Address].

The U.S. Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.)

If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, DC 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.

Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish).

Exhibit C

EXAMPLE OF CLAIMING PERCENTAGES

Monthly Claiming Percentages:

For each Provision 2 school, the meal count, taken by type (free, reduced price, and paid) at the point of service in April 2000 (base year) was as follows:

Free Meals Claimed for April 2000 = 22,500
Reduced Price Meals Claimed for April 2000 = 5,000
Paid Meals Claimed for April 2000 = 2,500

The sum of daily meal counts at the point of service is a total of 30,000 total student meals served during the claiming period (one month).

Free Meals = 75.0% of total student meals (22,500 ÷ 30,000)
Reduced Price Meals = 16.7% of total student meals (5,000 ÷ 30,000)
Paid Meals = 8.3% of total student meals (2,500 ÷ 30,000)

The total meal count for April 2001 (non-base year) was 32,125 reimbursable meals.

Free Meal Claim for April 2001: 32,125 x 75% (.750) = 24,093.75 free meals, rounded to 24,094.1
Reduced Price Meal Claim for April 2001: 32,125 x 16.7% (.167) = 5,364.875 reduced price meals rounded to 5,365.
Paid Meal Claim for April 2001: 32,125 x 8.3% (.083) = 2,666.375 paid meals rounded to 2,666.

Confirm Total Meal Count: 24,094 free + 5,365 reduced price + 2,666 paid = 32,125 meals. If this confirmation step does not equal the total, recheck calculation and rounding. If these are correct, and the rounded totals by type, do not equal total meals (due to rounding, rather than math error), make adjustments in the paid category in order that the sum of the free, reduced price and paid meals claimed equals the total.

Repeat above procedures for each month (claiming period) of the school year. The claiming percentages for each category will vary from month to month.

Annual Claiming Percentages:

For each Provision 2 school, the daily meal count is taken by type (free, reduced price, and paid) at the point of service for each day in the base year. The base year meals are added together, by type (with the exception of the first claiming period if approved for delayed implementation). Do not add monthly claiming percentages together to obtain annual claiming percentages.

1. Meal claims must be made in whole numbers. When the free, reduced price or paid meal calculations result in fractions, use standard rounding procedures (five and above round up, four and below round down), as applied to the first digit after the decimal.

Note: If delayed implementation is approved by the state agency, the first claiming period of the school year is not considered to be a part of the base year. While a standard categorical count is taken at the point of service (or approved alternate) for each claiming period of the school year, a monthly claiming percentage is not calculated for the delayed implementation period. For the claiming period of each non-base year corresponding to the delayed implementation period of the base year, an annual claiming percentage must be calculated, derived from all months of the base year except the first claiming period of the school year. Monthly percentages may be used for the remaining months.

Convert the meals to annual claiming percentages by type:

Total meals claimed for the year:
Each month’s total meal count added together = 250,000 meals

Free claiming percentage calculation for the year:
Total free meal counts for the year 175,250
175,250 free meals ÷ 250,000 total meals = .701 or 70.10%

Reduced price claiming percentage calculation for the year:
Total reduced price meal counts for the year 45,500
45,500 reduced price meals ÷ 250,000 total meals = .182 or 18.20%

Paid claiming percentage calculation for the year:
Total paid meal counts for the year 29,250
29,250 paid meals ÷ 250,000 total meals = .117 or 11.70%

Confirm the claiming percentages: 70.10% + 18.20% + 11.70% = 100%
If the total does not equal 100%, make an adjustment to the paid claiming percentage to make the total equal 100%.

Apply these claiming percentages to each month’s total meal count during the non-base years of the cycle and approved extensions.