Training & Record Keeping
In this section we will discuss civil rights, program training, and record keeping requirements.
No child or family may be denied access to the Food Program and it's benefits due to race, color, national origin, age, sex, or disibility. Discrimination is defined as different treatment, either intentionally or unintentionally. One of the program requirements is that you must display an "And Justice for All..." poster at your sites. You must also provide the non-discrimination statement on any program related materials distributed to the public. Sponsors should have a written complaint procedure on file. Our office has a sample procedure you can sign and adopt. This must be kept as part of your permanent records and will be examined during each review.
Here is what the "And Justice For All" poster looks like. You are required to post the full sized poster, just as you receive it from our office. If you need additional posters, contact our office and we will mail them to you.
Each year and for camps each session racial ethnic data must be documented. If parents do not enroll children into the program like at a closed enrolled, migrant, or camp site, program staff may simply make determinations based on visual cues. A racial and ethnic report form and instruction can be found in the attachment section of the USDA Summer Admin Guide. It is important to note that each child will be assigned a racial category, and then also assigned an ethnic category of either Hispanic or Non-Hispanic.
Each year State Agencies are required to offer Training. At this training, sponsors receive guidance on Program and regulatory aspects of SFSP administration, including, at minimum: An overview of the Program’s purpose, A review of the sponsor’s responsibilities, An overview of Civil Rights requirements, A review of the site supervisor’s responsibilities, Tips on how to identify a reimbursable meal, An overview of the site/sponsor agreement. A Program administrator and key staff member(s) from each new sponsoring organization are required to attend State agency training in order for the organization to be eligible to participate in the Program. Annual training may be offered in-person or completed on-line.
We’ll next go over the training requirements Sponsors must give their staff. All program staff to include volunteers must complete Civil Rights Training at least annually. All new hires must receive Civil rights training as well as food program training related to the scope of their responsibilities prior to executing those responsibilities. You’re welcome to use USDA and State Agency training materials to fulfill these requirements. Our office has an on-line video that can be used to meet the civil rights training requirement. In the USDA Summer Administrator’s Guide there are training checklists for Administrative Staff, Monitors, and Site Staff.
As with everything else on the food program, if you didn’t write it down, it didn’t happen. You’ll need to document that you’ve completed the training that you give to your staff. You will need to show that you trained new staff upon hire and for the annual training, you’ll need to keep a dated agenda, the list of topics trained on and an attendance sheet for those who attended.
Now we’ll move on to how long you need to keep all of the paperwork that’s been discussed in this and other trainings. All program records must be kept for three years plus the current year and must be kept in a secure location, whether electronic or hard copy. This refers to all paperwork. Training documentation, receipts, meal counts, menu records, everything. At any time, our office could request any records from within this period of time. Once the timeframe of the 3 years plus the current year is past, these records may be discarded unless they are part of an ongoing review or audit, or part of an investigation. Please make sure to shred the paperwork with sensitive information on it.
There are five or six documents that must be kept permanently depending on your situation. Your agreement with our office when you initially come onto the food program. The Free/reduced price policy statement. The outside employment policy. The civil rights complaint procedure policy. Written code of conduct for employees engaged in procurement. Purchasing policy if you’re operating under any purchasing thresholds other than the state thresholds. We’ll discuss this more in the procurement training. We’ll ask to see these records when we come and do reviews. If you’re already on the program, take a moment to make sure that you have these documents and can locate them easily. If you can’t find them, contact your specialist and they’ll may be able to send you a copy for your records. These records can be kept electronically or in hard copy form.
For many new sponsors our office must conduct a pre-approval visit to your facility. We do this to first make sure your are a real location, and second we will go over program basics with you to make sure things get started off correctly. There is no grace period for compliance. Sponsors are expected to be compliant with program requirements from the beginning. Pre-approval visits also allow us to give one-on-one training and on-site technical assistance specific to your operation. You will receive a review during your first year of operation an then reviews are conducted on a three year cycle. State Agencies may conduct unannounced reviews. Be sure to have program documentation available for reviewers upon request. Our office is here to assist you year round so do not hesitate to request additional training or contact our office with questions. Please do not hold questions until we come do a review. This can be costly in both time and funding. Program reviews will typically be conducted by our office, but may be conducted by staff from the USDA Regional Office, National office or other government auditing organization. While sponsors must be reviewed every three years there are certain risk factors that may cause a sponsor to receive additional reviews. The larges risk factor is a history of non-compliance.
There are a lot of regulations relating to the food program and these regulations get updated and changed as needed. One of our responsibilities as a state agency is to make sure that you have access to the most current regulations. It’s very important that we have an email address for the individual over the food program at your facility. It’s also very important that the individual checks this email and reads through the information that we send. You’ll receive both memos and bulletins from our office. Bulletins are new or updated regulations. Memos are clarifications or reminders. They’re both very important. Please read through and understand the correspondence that you receive from our office. You need to be able to show that you can access the bulletins. Showing us that you’ve saved all of the emails or that you look them up on-line is sufficient for that requirement. There are also handbooks that have been put together by the USDA that can be very helpful in operating the food program. Please use the resources available to you in operating the food program.
If you have any questions or would like information on where to find additional training on any of the topics discussed in this section please contact our office.
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