Worker and Family Assistance:

Observations on the National School Lunch Program's Assessment, Improvement, and Monitoring System

Published: Sep 7, 1983. Publicly Released: Sep 7, 1983.

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GAO conducted a survey to obtain information on the operation of the Food and Nutrition Service's (FNS) Assessment, Improvement, and Monitoring System (AIMS), which it implemented under interim regulations which established four standards to improve the management of the National School Lunch Program and ensure correct claims for federal program reimbursement. These standards provide that: (1) applications must be correctly approved or denied; (2) the number of meals claimed by each school must be no more than the number of children correctly approved in each school; (3) school recording systems must yield correct claims for reimbursement; and (4) meals must provide the required food components.

In the four states which GAO visited, GAO found that the local school food authorities failed to meet the first performance standard because they had more than the 10-percent error tolerance level allowed for invalid applications. In addition, GAO found that the follow-up review requirements for schools found to be not in compliance may be too lenient. Schools may fail to meet a performance standard and not be subject to another review for years. GAO found that none of the four states elected to require restitution for inaccurate meal counts on the basis of initial reviews, even though restitution was required. GAO found the second performance standard to be overly lenient as a measure of whether free and reduced-price lunch counts were excessive. In addition, GAO found that the third standard was not consistently applied. Furthermore, GAO found that the fourth performance standard does not ensure that the quantities served to each student comply with the regulations. Finally, GAO found that there is a need for a performance standard covering verification of information on applications, since ineligible children receive free meals because of inaccurate reporting of family income or size.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Draft guidance was prepared, but final guidance has been postponed indefinitely.

    Recommendation: The Administrator, FNS, should require that the needed guidance for monitoring the requirement that minimum quantities of various types of food be served to qualify for federal reimbursement be developed and provided to the states as long as FNS regulations continue the requirement, and that compliance with the requirement be made a part of AIMS.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  2. Status: Closed - Implemented

    Comments: FNS uses attendance and participation factors to compare schools claims and determine which schools should receive an AIMS review. This practice satisfies this recommendation.

    Recommendation: The Administrator, FNS, should consider requiring states to test meal counts under the National School Lunch Program's third performance standard to provide a better degree of assurance that school food authority reimbursement claims are accurate. In addition, the Administrator should provide states additional guidance on what amount of restitution should be required when schools do not have, or use, an approved system for counting meals served.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  3. Status: Closed - Not Implemented

    Comments: FNS stated that it elected not to make this change because the current procedure is practicable and workable.

    Recommendation: The Administrator, FNS, should require that efforts be made to develop better ways to judge whether meal counts are excessive.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  4. Status: Closed - Implemented

    Comments: FNS supports the concept of assessing claims based on the severity and longevity of problems. As a result, FNS has begun requiring restitution for severe and longstanding problems in FY 1987.

    Recommendation: The Administrator, FNS, should consider requiring restitution from school food authorities that do not meet Assessment, Improvement, and Monitoring System standards on an initial review.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  5. Status: Closed - Not Implemented

    Comments: FNS stated that it lacks the resources to increase its level of review and, therefore, is not going to implement this recommendation.

    Recommendation: The Administrator, FNS, should reexamine the adequacy of the 25-percent requirement for follow-up reviews.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  6. Status: Closed - Not Implemented

    Comments: FNS has been analyzing data on the number of school food authorities exceeding the 10-percent tolerance for FY 1987. Based on these data, FNS was to examine the appropriateness of the 10-percent tolerance level. However, actual implementation is very uncertain.

    Recommendation: The Administrator, FNS, should consider setting a lower tolerance for the National School Lunch Program's first performance standard, because the 10-percent tolerance seems high compared with error-rate tolerances established for the Food Stamp Program.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  7. Status: Closed - Not Implemented

    Comments: FNS has been analyzing data on the incidence of invalid applications for fiscal year (FY) 1988. Although it has indicated that it will consider options for implementing this recommendation, actual implementation is very uncertain.

    Recommendation: The Administrator, FNS, should consider requiring states to take financial action against school food authorities that do not meet the first performance standard that applications for free and reduced-price meals must be correctly approved or denied, perhaps based on a sliding scale depending upon the extent to which the percent or number of invalid applications exceeds the tolerance set.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

  8. Status: Closed - Implemented

    Comments: Final regulations require SFA to verify 3 percent, or 3,000, whichever is less, of SFA approval applications for free or reduced price school meals. FNS is periodically monitoring SFA compliance with this regulatory requirement.

    Recommendation: The Administrator, FNS, should develop an additional AIMS standard for monitoring school food authority (SFA) compliance with the new program requirement that state agencies verify 3 percent or 3,000, whichever is less, of SFA-approved applications for free or reduced-price school meals.

    Agency Affected: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service

 

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