FCMAT
Lost Hills Union School District Report
food services department review
Read the report at Lost Hills Union School District ↗
Lost Hills Union School District
Food Services Review
January 7, 2016
Joel D. Montero
Chief Executive Officer
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January 7, 2016
Harrison Favereaux, Chief Administrative Officer
Lost Hills Union School District
20951 Pavilion Way
Lost Hills, CA 93249
Dear Chief Administrative Officer Favereaux:
In September 2015, the Lost Hills Union School District and the Fiscal Crisis and Management
Assistance Team (FCMAT) entered into an agreement for management assistance. Specifically, the
agreement states that FCMAT will perform the following:
1. Examine the food service department’s procedures and practices for managing all
operations with regard to efficiency and reducing the encroachment on the unre-
stricted general fund. FCMAT will evaluate the current workflow and distribution
of management and leadership functions in the department, which shall include
but not be limited to food preparation, ordering, inventory, cash and resource
management, staffing, policies and procedures, federal and state compliance,
menu planning, warehousing and food storage, purchasing and facilities, and will
make recommendations for improved efficiency, if any. The review will include
any constraints to productive management by evaluating systems, structures and
employee responsibilities in relationship to the district’s goals.
FCMAT will review documentation, including board policies and administrative
regulations and job descriptions, and will gather data regarding current practices
and procedures. Additionally, the study team may interview other department or
site staff to determine the efficiency and effectiveness of services delivered.
2. Review training and professional development programs for employees and
managers and make recommendations.
This report contains the study team’s findings and recommendations.
FCMAT appreciates the opportunity to serve the Lost Hills Union School District and extends
thanks to its staff for their cooperation and assistance during this review.
Sincerely,
Joel D. Montero
Chief Executive Officer
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TABLE OF CONTENTS
Table of Contents
About FCMAT .........................................................................................iii
Introduction ............................................................................................1
Executive Summary ..............................................................................3
Findings and Recommendations .....................................................5
Budget .................................................................................................5
Staffing and Meals Per Labor Hour ............................................9
Menus and Meal Service ............................................................17
Provision 2 ........................................................................................21
Nonprogram Food Revenue ......................................................23
Paid Lunch Equity and Meal Charges .....................................25
Food Handling and Food Safety ..............................................27
Wellness Policy ................................................................................29
Food Costs and Purchasing ........................................................31
Facilities and Equipment .............................................................33
State Administrative Review ......................................................35
Staff Training ....................................................................................37
Appendices ...........................................................................................39
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ABOUT FCMAT
About FCMAT
FCMAT’s primary mission is to assist California’s local K-14 educational agencies to identify,
prevent, and resolve financial, human resources and data management challenges. FCMAT
provides fiscal and data management assistance, professional development training, product
development and other related school business and data services. FCMAT’s fiscal and manage-
ment assistance services are used not just to help avert fiscal crisis, but to promote sound financial
practices, support the training and development of chief business officials and help to create
efficient organizational operations. FCMAT’s data management services are used to help local
educational agencies (LEAs) meet state reporting responsibilities, improve data quality, and
inform instructional program decisions.
FCMAT may be requested to provide fiscal crisis or management assistance by a school district,
charter school, community college, county office of education, the state Superintendent of Public
Instruction, or the Legislature.
When a request or assignment is received, FCMAT assembles a study team that works closely
with the LEA to define the scope of work, conduct on-site fieldwork and provide a written report
with findings and recommendations to help resolve issues, overcome challenges and plan for the
future.
FCMAT has continued to make adjustments in the types of support provided based on the changing
dynamics of K-14 LEAs and the implementation of major educational reforms.
Studies by Fiscal Year
90
80
70
60
50
40
30
20
10
0
92/93 93/94 94/95 95/96 96/97 97/98 98/99 99/00 00/01 01/02 02/03 03/04 04/05 05/06 06/07 07/08 08/09 09/10 10/11 11/12 12/13 13/14 14/15
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FCMAT also develops and provides numerous publications, software tools, workshops and
professional development opportunities to help LEAs operate more effectively and fulfill their fiscal
oversight and data management responsibilities. The California School Information Services (CSIS)
division of FCMAT assists the California Department of Education with the implementation
of the California Longitudinal Pupil Achievement Data System (CALPADS) and also maintains
DataGate, the FCMAT/CSIS software LEAs use for CSIS services. FCMAT was created by
Assembly Bill (AB) 1200 in 1992 to assist LEAs to meet and sustain their financial obligations.
AB 107 in 1997 charged FCMAT with responsibility for CSIS and its statewide data management
work. AB 1115 in 1999 codified CSIS’ mission.
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ABOUT FCMAT
AB 1200 is also a statewide plan for county offices of education and school districts to work
together locally to improve fiscal procedures and accountability standards. AB 2756 (2004)
provides specific responsibilities to FCMAT with regard to districts that have received emergency
state loans.
In January 2006, Senate Bill 430 (charter schools) and AB 1366 (community colleges) became
law and expanded FCMAT’s services to those types of LEAs.
Since 1992, FCMAT has been engaged to perform more than 1,000 reviews for LEAs, including
school districts, county offices of education, charter schools and community colleges. The Kern
County Superintendent of Schools is the administrative agent for FCMAT. The team is led by
Joel D. Montero, Chief Executive Officer, with funding derived through appropriations in the
state budget and a modest fee schedule for charges to requesting agencies.
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INTRODUCTION
Introduction
Background
Located in Kern County, the Lost Hills Union School District has a five-member governing
board, and served approximately 574 K-8 students at one elementary and one middle school
in 2014-15. District administration estimates an enrollment of 570 in 2015-16. According to
data from the California Department of Education (CDE), student enrollment has remained
relatively flat for the past several years after reaching a high of 598 students in 2008-09.
The district participates in the National School Lunch and Breakfast programs at its two schools,
which are located next to each other and share the food service facility. The district serves a
high-needs population, and CDE records indicate that free and reduced-price meal eligibility
districtwide was 93.6% in October 2014. The district’s October 2015 reimbursement claim
shows an eligibility of 94.7%.
In September 2015, the Lost Hills Union School District and the Fiscal Crisis and Management
Assistance Team (FCMAT) entered into an agreement for management assistance to review the
operations of the district’s Food Service Department.
Study and Report Guidelines
FCMAT visited the district on October 20-21, 2015 to conduct interviews, collect data, observe
the food service operations and facilities, and begin reviewing documents. This report is the result
of those activities and is divided into the following sections:
• Executive Summary
• Budget
• Staffing and Meals Per Labor Hour
• Menus and Meal Service
• Provision 2
• Nonprogram Food Revenue
• Paid Lunch Equity and Meal Charges
• Food Handling and Food Safety
• Wellness Policy
• Food Costs and Purchasing
• Facilities and Equipment
• State Administrative Review
• Staff Training
• Appendices
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INTRODUCTION
In writing its reports, FCMAT uses the Associated Press Stylebook, a comprehensive guide to
usage and accepted style that emphasizes conciseness and clarity. In addition, this guide empha-
sizes plain language, discourages the use of jargon and capitalizes relatively few terms.
Study Team
The study team was composed of the following members:
Diane Branham Judy Stephens
FCMAT Chief Management Analyst FCMAT Consultant
Bakersfield, CA Nipomo, CA
Leonel Martínez
FCMAT Technical Writer
Bakersfield, CA
Each team member reviewed the draft report to confirm its accuracy and to achieve consensus
on the final recommendations.
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EXECUTIVE SUMMARY
Executive Summary
The Food Service Department has six employees, including a full-time food service manager. At
the time of FCMAT’s fieldwork, the manager had been on leave since August 2015, and a food
service consultant was working with the district part-time to provide managerial and oversight
functions for the program.
According to the California Department of Education (CDE) records, the district’s free and
reduced-price meal eligibility was 93.6% in October 2014. The October 2015 reimbursement
claim shows eligibility of 94.7%. However, the student enrollment on this document does not
match that reported by district administration; therefore, it is likely that the eligibility is inaccu-
rate. This indicates that the district’s student information system is not routinely reconciled with
the food service software system. It is critical that the student information in the food service
software system is accurate because federal and state free and reduced-price meal reimbursements
are the main sources of revenue for the program. Students who qualify for free and reduced-price
meals are also those most likely to participate in the program.
One of the district’s primary concerns with the Food Service Department is ongoing deficit
spending and the annual contributions from the unrestricted general fund. A review of the
district’s cafeteria fund budget from 2011-12 through 2015-16 shows that expenses have
exceeded revenues in each year, and indirect costs have not been charged to the fund. Beginning
in 2013-14, transfers were made from the unrestricted general fund to the cafeteria fund for
cash flow purposes. However, these funds were transferred permanently instead of temporarily,
resulting in contributions from the unrestricted general fund. Without the contributions, the
cafeteria fund balance would have been depleted in 2014-15.
Food and labor costs are the major portion of a food service expense budget. Based on the team’s
experience, the goal for these expenses should be 40-45% each as a percentage of revenue. The
district’s food costs have exceeded these percentages each year since 2013-14 and labor costs have
exceeded these percentages in each year reviewed since 2011-12.
Meals per labor hour (MPLH) is an industry standard formula used to measure staff efficiency
and help determine the appropriate staffing levels in a food service operation. In school food
service, best practice standards are 30 MPLH. FCMAT’s analysis for the district shows an average
of 20 MPLH which indicates overstaffing.
MPLH ratios can be improved by increasing student participation or reducing staff, and it often
requires some of each. To increase participation, the district should consider the provisional
meal option, which allows all students to eat for no charge. Breakfast participation is low relative
to lunch, and the district should consider options such as a grab-and-go breakfast, sack meal,
second chance breakfast served later in the morning for middle school students, and breakfast in
the classroom to increase participation.
The district should reduce labor hours if student participation is not significantly increased. At
the time of FCMAT’s fieldwork, the dishwasher/cook position was vacant. The district should
leave the position vacant or eliminate it, and review all future vacancies as they occur to deter-
mine if they can be eliminated or reduced in hours.
The National School Meal Program has undergone some significant regulation changes in the
past several years, mandating much stricter nutrition guidelines. The required menu certification
that was supposed to occur in the 2011-12 school year was not completed timely by the district.
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EXECUTIVE SUMMARY
As a result, the menus were not in compliance, and the district did not receive the additional
reimbursement of six cents per lunch served that was provided to compliant districts. This issue
was discovered in spring 2015, and menu compliance was completed by a staff member in the
business office before the state review.
The Food Service Department had a state administrative review in March 2015. These are
routine reviews that are conducted every three years to ensure compliance to program regula-
tions. The review found many areas out of compliance that required corrective actions by the
district and/or technical assistance by the state reviewer.
Staff training is essential to help resolve the district’s food service program and budget issues.
Additionally, the USDA has established minimum education and training requirements for food
service personnel. These requirements became effective on July 1, 2015, and mandate profes-
sional standards and annual training requirements. Areas that require immediate training for the
food service manager and staff include food safety practices and program requirements such as
portion sizes and meal components. The district should also consider sending the food service
manager and staff to other school districts to observe food service operations. Staff members
should also be cross-trained so they can perform all food service tasks efficiently, including oper-
ating the point-of-sale system.
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BUDGET
Findings and Recommendations
Budget
A district food service program should ideally be self-sustaining. Revenue should be able to fund
department expenses including indirect costs, with appropriate reserves maintained. However, a
review of the district’s cafeteria fund budget from 2011-12 through 2015-16 shows that expenses
have exceeded revenues each year, also known as deficit spending. Additionally, indirect costs
have not been charged to the fund in any of the years reviewed.
The 2011-12 beginning fund balance was $248,007, but because of deficit spending, the fund
balance has been reduced each year. The 2015-16 projected ending fund balance is $38,865.
Cafeteria fund revenues have been fairly stable during this time, with a one-time increase of
approximately $30,000 in 2013-14. Expenses have increased 17% from 2011-12 to 2015-16, with
a large increase in 2012-13. District administration indicated that one-time expenses were made in
2012-13 to reduce the fund balance based on a finding by the state administrative review, which
indicated the fund balance was larger than allowed by federal regulations. This significantly reduced
the ending fund balance, and beginning in 2013-14, transfers were made from the unrestricted
general fund to the cafeteria fund for cash flow purposes. However, these funds were transferred
permanently instead of temporarily, resulting in contributions from the unrestricted general fund.
Without the contributions, the cafeteria fund balance would have been depleted in 2014-15.
Cafeteria Budget Comparison
2011-12 2012-13 2013-14 2014-15 2015-16*
Unaudited Unaudited Unaudited Unaudited Projected
Actuals Actuals Actuals Actuals Budget
Beginning Fund Balance $248,007 $239,367 $115,530 $112,774 $78,819
Total Revenues 451,798 451,350 480,147 449,123 449,123
Salaries 127,037 125,409 135,625 136,766 143,816
Benefits 74,823 69,449 87,851 88,729 93,961
Total Salaries and Benefits 201,860 194,858 223,476 225,495 237,777
Salaries/Benefits % of Revenue 45% 43% 47% 50% 53%
Food and Supplies 217,783 248,488 275,168 252,344 252,375
Food/Supplies % of Revenue 48% 55% 57% 56% 56%
Services and Other Operating 40,795 131,840 24,259 45,240 48,925
Capital Outlay 0 0 0 0 0
Indirect Costs 0 0 0 0 0
Total Expenditures 460,439 575,186 522,903 523,079 539,077
Excess (Deficiency) (8,641) (123,836) (42,756) (73,956) (89,954)
Interfund Transfers In 0 0 40,000 40,000 50,000
Ending Fund Balance $239,367 $115,530 $112,774 $78,819 $38,865
Source: Unaudited actuals reports.
*2015-16 projected budget information taken from 2014-15 unaudited actuals report because it included most current budget
projections.
Rounding used in calculations.
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BUDGET
Food and labor costs are the major portion of a food service expense budget. Based on the team’s
experience, to manage the program effectively the goal for these expenses should be 40-45%
each as a percentage of revenue. Lost Hills Union’s expenses in these areas have been higher
throughout the period reviewed. Labor costs were within acceptable levels in 2011-12 and 2012-
13, but began to increase in 2013-14 and are projected at 53% of revenue for 2015-16. This
can indicate excessive staffing, which correlates to observations made by the study team and is
supported by the meals per labor hour calculations discussed later in this report.
Food costs have been higher than desirable for all of the years reviewed. They were 48% of
revenue in 2011-12, the year prior to the federally mandated menu changes, and have increased
to 56% in the 2015-16 budget projections. However, the district has implemented some positive
purchasing changes this year that may reduce food costs.
The district has not charged the cafeteria fund indirect costs. Indirect costs consist of business
and administrative expenses such as budget, payroll, accounts payable, human resources, and data
processing services provided to all programs. The true program cost is not shown if indirect costs
are not budgeted and charged to the cafeteria fund. The California School Accounting Manual
provides guidelines for allowable indirect cost amounts and how to calculate them.
A food service program with high free and reduced-price meal eligibility should be able to fund
itself. Federal revenue from these meals is the primary source of income to the program. As
discussed in further detail in the Staffing and Meals Per Labor Hour section of this report, the
district has a high percentage of students who are eligible for free and reduced-priced meals.
Student participation at lunch is high and has been fairly steady for the past several years, but
breakfast participation has been relatively low. A provisional meal option is available that allows
all district students to eat at no charge regardless of eligibility. This could help maximize student
participation and revenue and will be discussed further in the Provision 2 section of this report.
The federal menu regulations that became effective in the 2012-13 school year have had a negative
effect on many districts’ budgets because of the increased cost of some food items and the types of
food that must be offered. The increased requirements for fruits and vegetables have often caused
more waste. These factors also appear to have played a role in the district’s increased food costs.
Some districts have also experienced lower student participation because of the stricter nutri-
tional standards. Interviews with staff indicated that the 2012-13 standards were not completely
implemented until this year, and the October 2015 meal reimbursement claim shows a decline of
approximately 65 lunches per day since October 2014. Although it is too early to know whether
this will have a lasting impact at Lost Hills Union, participation should be monitored closely to
determine if this decrease continues.
A lack of timely compliance with the state’s menu certification process also cost the district
revenue. Once certified, districts are eligible for an additional six cents per meal for all lunches
served. The district served an average of 565 lunches per day from 2012-13 through 2014-15.
The extra reimbursement for those lunches would have been approximately $6,100 per year.
Although this may not be a high amount, every attempt should be made to maximize revenue.
Lack of necessary attention in menu planning and in obtaining best prices for food and supplies
can also increase costs. Staff reported that menus were often not followed, and last minute substi-
tutions were made because of lack of necessary products. In addition, some staff members’ lack
of understanding regarding portion and meal component requirements can increase food costs
by causing them to prepare and serve more food than necessary. These issues will be discussed in
further detail throughout this report.
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BUDGET
Based on interviews and the documentation, the Food Service Department has not implemented
some regulations timely and has not closely monitored the food service budget. This should be a
high priority for the food service manager and an expectation from district administration.
Recommendations
The district should:
1. Reduce its food and labor costs to align with best practices.
2. Charge the full allowable indirect cost rate to the cafeteria fund.
3. Maximize free and reduced-price meal eligibility and student participation.
4. Ensure that the food service manager closely monitors and makes adjustments
as necessary to maximize student participation.
5. Ensure that the Food Service Department implements regulations timely.
6. Ensure that the food service manager takes an active role in budget develop-
ment and is assigned the responsibility of managing the budget.
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BUDGET
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STAFFING AND MEALS PER LABOR HOUR
Staffing and Meals Per Labor Hour
Because labor is generally one of the highest expenses in a food service operation, it is important
to ensure that staffing ratios are adequate to meet the needs of the program without being exces-
sive.
The Food Service Department consists of the following employees:
Food service manager 8 hours
Baker/cook 8 hours
Dishwasher/cook 7 hours
Cafeteria helper 7 hours
Cafeteria helper 4 hours
Cafeteria clerk 7 hours
TOTAL 41 hours
The district’s elementary and middle schools are located next to each other and share the food
service facility. Students have staggered lunch periods by grade level. A program with one kitchen
and one cafeteria should provide for an efficient meal service. All employees are in one place and all
food deliveries, storage, preparation, service and cleanup happen centrally. This should require fewer
employees and fewer labor hours than a district with many sites to staff and food to transport.
The study team observed breakfast and lunch service during its site visit. The kitchen and
cafeteria facilities are spacious and efficiently designed. The serving area is set up efficiently and
provides for a fast flow of customers, with serving lines moving quickly.
Meals per labor hour (MPLH) is an industry standard formula used to measure staff efficiency
and help determine the appropriate staffing levels in a food service operation. Generally, only
labor hours for food preparation, cleanup and meal service are included in this calculation
because it is a measure of the amount of labor used to prepare and serve the meals at sites.
Management and clerical time are not normally included. However, because many duties are
shared, and there is no clear separation of duties in the district’s food service program, all food
service hours were included in the calculation.
A meals per labor hour analysis was completed for district schools that analyzed the meals served
in October 2015. October is the cut-off for prior year free and reduced-price meal eligibility and
new application processing, so the month normally provides an accurate snapshot of student
participation.
MPLH is calculated in many ways, and it is important to be consistent in the method used.
Breakfast is sometimes counted as a fraction of a meal equivalent because it is simpler to prepare
and serve. The district’s breakfast menus include many ready-to-serve items, but some items are
also cooked on site; therefore, breakfasts were each counted as one meal in this analysis. If the
district had a la carte food sales, they would be converted into meal equivalents by dividing the
total dollar of the sales by an average of breakfast and lunch prices. This would be added to meal
counts. However, the district does not have a la carte sales except for a few adult meals, so this
was not included. The district serves meals and/or after-school snacks to the Wonderful Preschool
and Head Start students, so these were included in the meal analysis. The snacks were counted as
one-third of a meal equivalent because they consist of only two items, which are prepackaged and
require little labor.
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STAFFING AND MEALS PER LABOR HOUR
The analysis was completed for the district as a whole rather than by school because all of the
food is prepared in the same kitchen and served by the same staff. In school food service, best
practice standards is 30 MPLH. The district has an average of 20 MPLH, indicating overstaffing.
Meals Per Labor Hour, October 2015
Wonderful Elementary &
Preschool Head Start Middle Schools Totals
Breakfasts per Month 366 0 5,039 5,405
Breakfasts per Day 17 0 229 246
Lunches per Month 373 402 11,305 12,080
Lunches per Day 17 18 514 549
Total Meals per Month 739 402 16,344 17,485
Total Meals per Day 34 18 743 795
PM Snacks per Month 368 0 0 368
PM Snacks per Day 17 0 0 17
Snack Equivalents 6 0 0 6
Total Meal Equivalents 39 18 743 800
Labor Hours 41
Meals per Labor Hour (MPLH) 20
Sources: October 2015 reimbursement claim, Head Start meal count form and district staff schedule.
Rounding used in calculations.
The average number of meals served per day in October 2015-16 was also compared to participa-
tion in school years 2011-12 through 2014-15. This timeframe was chosen because the new nutri-
tional standards became effective in 2012-13 and provides a comparison of meals served before and
after the new requirements should have been implemented. There was a reduction in the average
number of lunches served in three of the four comparison years; however, the largest reduction
occurred from 2014-15 to 2015-16, with a decline of 65 meals (11%). The average number of
breakfasts was higher in the first year of the new regulations but has declined since then.
As discussed later in this report, 2015-16 is the first year the district has fully implemented the
nutrition standards and menu requirements. Therefore, changes in meal counts and participation
should be closely monitored to determine if menu changes have a significant impact.
Meal Comparisons, October of Each School Year
2011-12 2012-13 2013-14 2014-15 2015-16*
Daily Averages
Breakfast 252 331 282 245 229
Lunch 587 562 555 579 514
Source: October reimbursement claims (counts do not include Head Start meals).
*2015-16 counts do not include Wonderful Preschool meals.
Rounding used in calculations.
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STAFFING AND MEALS PER LABOR HOUR
According to CDE records, student enrollment changed little up to 2014-15, but free and
reduced-price meal eligibility has fluctuated between 93.6% and 98.6%. Eligibility is an
important factor in meal participation. However, the district’s free and reduced-price meal
eligibility is unknown because the enrollment on the October 2015 reimbursement claim appears
to be incorrect. It does not match enrollment numbers from the district’s student information
system. This indicates that the district student information system and food service software
systems are not regularly reconciled. If the food service system has inaccurate enrollment, the
percentages of free and reduced-price eligible students will also be incorrect. This needs to be
corrected, and the two systems should be reconciled regularly to ensure the data is accurate.
Student Enrollment & Meal Eligibility
2011-12 2012-13 2013-14 2014-15 2015-16*
Enrollment 581 573 568 574 628
Free and Reduced-Price Meal Eligible
Students 573 549 558 537 595
Percentage of Students Eligible 98.6% 95.8% 98.2% 93.6% 94.7%
Sources: http://www.cde.ca.gov/ds/sd/sd/filessp.asp and October 2015
reimbursement claim.
*October 2015 reimbursement claim appears to have errors because administration indicated enrollment is 570.
Rounding used in calculations.
MPLH ratios can be improved in two basic ways: increase student participation or reduce staff,
and it often requires some of each. The most positive way to improve MPLH is to increase
participation. As discussed later in this report, the district should consider pursuing a Provision
2 alternative for its meal program. This allows all students to eat at no charge and simplifies meal
counting and claiming procedures. The district is an ideal candidate for this program because
of its high free and reduced-price meal eligibility. The fact that all children can eat for free with
the Provision 2 alternative will attract paid and reduced-price students who currently may not
participate in the program.
The high free and reduced-price meal eligibility and the small campus with an accessible cafeteria
should make it relatively easy for the district to have a high participation rate. This is the case
at lunch when on average 514 meals are served to elementary and middle school students in a
district with an enrollment of 570 students (according to district enrollment figures). This is a
90% participation rate. However, at breakfast only about 40% of the students participate. This
rate is better than many districts, but still leaves much room for improvement. Because most
of the district’s students are bused to school, their breakfast accessibility largely depends on bus
schedules. If they arrive too late, there may not be sufficient time to eat breakfast. The district
should consider other breakfast alternatives to capture the maximum participation. A simpler
breakfast could be served as a grab-and-go meal that includes individually packaged items that
don’t require assistance from staff, or a sack meal could be served that students could retrieve
more quickly than with the current tray service.
A method that would essentially ensure that 100% of students in attendance participate is
serving breakfast in the classroom. This would work best with the Provision 2 alternative so all
students could eat at no charge. The main complaints about this method of service are messes
in the classroom and time taken away from teaching. These concerns have been overcome in
districts that have successfully implemented this type of service. Packaged, ready-to-eat entrées
such as cereal bars, muffins and breakfast sandwiches could be served along with dried fruit,
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STAFFING AND MEALS PER LABOR HOUR
juice and milk. Students can eat at their desks while teachers make morning announcements and
take attendance. Breakfast counts can be completed when taking attendance. Some teachers use
this time to give nutrition or health lessons, which can help fulfill the wellness requirements for
nutrition education in the classroom.
Another breakfast alternative for middle school students is to offer a second chance breakfast at
the morning break. The Food Service Department could consider serving grab-and-go breakfasts
in the middle school quad area rather than having the students come to the cafeteria. This is
often a better alternative for this age group because they frequently are not hungry first thing in
the morning. This may not be a viable option for elementary students because their lunch periods
are much earlier, and scheduling a mid-morning breakfast would be difficult.
Making sure students have breakfast provides them with nutritional benefits, helps increase
academic achievement, and could increase cafeteria revenue and balance the food service budget.
Because of the district’s high free and reduced-price meal eligibility, providing breakfast to all or
most of the students as described above could generate significantly more revenue. The October
2015 reimbursement claim includes revenue of $10,946, an average of $89,559 per year with a
40% participation rate. If participation were doubled, revenue could be increased by approxi-
mately $90,000 per year. Although food costs would increase, labor costs should not because the
current number of labor hours could accommodate an increase in student participation.
The Food Service Department has six employees. One cafeteria helper works four hours per day
in the food service program and works as a custodian for the remainder of the day. The remaining
employees work seven to eight hours a day. This is unusual in a school cafeteria setting. It is
common for a manager to work eight hours, and a lead may often work six or more hours per
day. However, most other staff members typically work six or less hours with many working three
or four hours per day. The current staffing pattern is expensive, particularly because of statutory
and health and welfare benefit costs, and it requires scheduling lunch breaks for all employees.
Interviews with administration indicated that the district has had difficulty in attracting part-
time staff because of its remote location.
The review team’s observations indicated that staffing is excessive, with too many employees for
the tasks being performed. During the team’s on-site visit, staff members worked at an unhurried
pace and each had very specific duties rather than sharing tasks. This sometimes left individuals
with nothing to do until food needed to be replenished on the serving line.
The cafeteria serving area is designed for very efficient service, with two separate lines entering
the serving area on opposite sides of the counter and ending at the same cashier near the entrance
to the eating area. Each line has its own key pad for entering student identification numbers.
During the meal service, two cafeteria workers were stationed at the serving counter on each line
to put entrées on the students’ trays and/or replenish food items. This is not the most efficient
process.
On the first day the study team observed lunch, the menu included hot dogs on a whole wheat
bun, oven-baked fries, tossed salad, canned apples, beans and milk. Everything except the hot
dogs was portioned for self-service. The two staff members on each line were portioning the hot
dogs in the buns as students came through the line, with one person opening small bags of buns
one at a time while the other person placed the hot dog on it and handed it to the students. If
the hot dogs and buns were assembled shortly before serving and kept on trays in the warming
carts, serving students would take only one person per line. On the second day, the entrée was
sliced pizza that was preportioned on trays and kept in warmers. However, two staff members
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still stood in each line, one serving and the other standing by to retrieve more pizza or side dishes
as needed. The backup entrées and side dishes are kept in carts very close to the serving area. One
person per line would be sufficient to serve these entrées and retrieve more food from carts as
needed.
Between lunch periods, food service staff prepared more food, cleaned the serving lines and
washed trays and pans. A cafeteria helper also wiped the tables and swept the floors. The different
grade levels have three lunch periods, and each period has about 170 to 180 students. The first
two periods are for transitional kindergarten through fifth grade students and are scheduled
to start 45 minutes apart. The students get through the serving lines in about 20 minutes per
period. The third period is for middle school students, and their lunch period is scheduled to
begin 70 minutes after the start of the second line. They also get through the line in about 20
minutes. This increases the workday for food service staff. If the lunch periods were scheduled
closer together, the staff schedules could be shortened. After the lunch period, food service staff
take a 45-minute break, which includes a one-half hour lunch and the 15-minute afternoon
break. The staff then cleans the kitchen and begins preparing food for the next day. If some staff
were assigned fewer hours, a lunch break would not be required, and those employees could leave
after the serving period.
Breakfast meal set-up is similar, but with one employee on each serving line and the clerk at the
point-of-sale computer. Other staff members wash dishes or prep food for lunch. Breakfast meals
are fairly simple with mostly self-serve foods. One staff person could serve both lines if the hot
entrées were placed in the center of the serving counter instead of on the end. The flow of the
breakfast lines depends on the bus arrival schedules, with various groups coming in from 7 a.m.
to 8 a.m.
Instead of disposable trays, the department uses reusable plastic trays that require numerous
hours per day to wash. The department has a seven-hour dishwasher/cook, but according to
staff, most of the position’s time is spent washing dishes. This position washes all the trays as
well as cooking pans and utensils. At the time of FCMAT’s fieldwork, the position was vacant
and a substitute performed dishwashing duties. If the district used disposable serving trays, this
position could be eliminated. The other department job descriptions list cleanup or other related
duties as assigned, and these positions could split the remaining dishwashing tasks.
Many food service employees have worked for the department for several years and are accus-
tomed to performing tasks as they have been performed in the past. Changes such as eliminating
positions, reducing hours or changing duties to require more crossover of responsibilities may
be difficult for some staff. The best method of dealing with a staffing reduction is often by
eliminating vacant positions. Staff should be informed about the department’s financial issues,
such as deficit spending and the contribution from the unrestricted general fund, and the former
lack of compliance issues so that they understand why changes are necessary. A team effort will be
necessary to improve the food service program, and staff are more likely to accept changes if they
understand the reasons.
Job descriptions for cafeteria staff are vague and outdated, ranging in approval dates from 1978
through 2000. The job descriptions do not include the minimum weightlifting and repetitive
duty requirements necessary for compliance with the Americans with Disabilities Act (ADA)
and do not list essential job functions. As written, the district could not use some of its job
descriptions as evidence of essential duties in accommodation cases, nor should it use them
when making employment decisions related to an applicant’s ability to perform essential duties.
Reviewing and revising job descriptions to ensure that duties are correctly identified as essential
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STAFFING AND MEALS PER LABOR HOUR
will help protect the district from disability discrimination claims by applicants and/or employees
who may be eligible for reasonable accommodations under the ADA.
Several descriptions have overlapping duties; however, some staff members indicated they believe
they are responsible for specific tasks and should not be required to perform others for the
current salary.
The food service manager job description lists mainly administrative duties but also includes
food preparation, cleanup and other food service worker duties. Some staff members indicated
that they believe the position is supposed to play a major role in daily food preparation as well
as perform all management duties. Prior individuals in the position reportedly worked most of
the day in the kitchen, but this is not the case with the current food service manager. Some staff
members voiced frustration with having to perform duties they believe are the manager’s respon-
sibilities.
If the district switches to the Provision 2 status, the clerk’s duties will be greatly changed and
simplified. This position could be part of a cafeteria worker position and participate more in food
preparation and cleanup as well as clerical responsibilities.
The district could have three cafeteria classifications: a food service worker, a food service lead
(or food service worker 2) and the food service manager. The food service manager position job
description should include all the managerial duties and backup in the kitchen as needed, but the
position should not be a primary participant in daily food preparation and cleanup. A baker/cook
position is unnecessary because complex cooking and baking duties are no longer performed
on-site. This position could be reclassified to food service worker 2 or a food service lead posi-
tion. The clerk and helper positions could be reclassified to food service worker positions, and the
dishwasher/cook position could be eliminated.
Recommendations
The district should:
1. Closely monitor changes in meal counts and student participation.
2. Establish a procedure to regularly reconcile the food service software system
and the student information system to ensure that the food service system
includes accurate information.
3. Make increased student participation a priority, and consider the following
options:
• Pursue Provision 2 program status.
• Provide breakfast alternatives such as grab-and-go or sack meals, breakfast in the
classroom and/or and a second chance breakfast.
• Encourage students to participate in the program.
• Educate staff on the importance of student participation in the food service
program.
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4. Reduce labor hours if student participation is not significantly increased.
Review all vacancies as they occur to determine if they can be eliminated or
reduced in hours.
5. Leave the current dishwasher/cook position unfilled or eliminate it.
6. Ensure that staff know why labor hours must be reduced.
7. Simplify cooking and serving methods to improve efficiency, including the
following:
• Switch to disposable serving trays.
• Predish as many foods as possible to reduce the number of staff needed on serving
lines.
8. Work with its classified employee bargaining unit as necessary to update job
descriptions and consider including fewer classifications when revising them.
Ensure that the descriptions include overlapping duties to improve skills and
department efficiency; continue to include other related duties as assigned
and comply with the ADA.
9. Consider completing a salary comparison for food service positions in similar
districts to determine if they need to be at a higher range on the district’s
salary schedule.
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MENUS AND MEAL SERVICE
Menus and Meal Service
Nutritional Requirements
The district participates in the National School Lunch and Breakfast programs, which are regu-
lated by the United States Department of Agriculture (USDA) and the California Department of
Education. Regulations were updated in 2010 during the federal reauthorization of the program.
These were the most comprehensive changes to the program in 15 years. Initial guidelines
became effective in the 2012-13 school year and have continued to become stricter.
Section 9(a)(4) of the Richard B. Russell National School Lunch Act (NSLA) requires that school
meals reflect the latest Dietary Guidelines for Americans (Title 42 United States Code Section
1758(a)(4)). In addition, Section 201 of the Healthy, Hunger-Free Kids Act of 2010 amended
Section 4(b) of the NSLA to require the USDA to issue regulations to update the meal patterns
and nutrition standards for school lunches and breakfasts based on the recommendations issued
by the Food and Nutrition Board of the National Research Council of the National Academy of
Sciences (Title 42 United States Code Section 1753(b)). The following websites contain addi-
tional information regarding these issues:
http://www.fns.usda.gov/sites/default/files/NSLA.pdf http://www.fns.usda.gov/sites/
default/files/HealthyHungerFreeKidsActof2010.pdf.
The new regulations seek to increase the availability of fruits, vegetables, whole grains, and
fat-free and low-fat fluid milk on school menus; reduce the levels of sodium, saturated fat and
trans fat in school meals; and meet the nutritional needs of school children within specified
calorie requirements. The intent is to provide meals that are high in nutrients and low in calories,
which better meets students’ dietary needs and protects their health.
In addition to higher fruit and vegetable requirements, districts must offer a wider variety of
vegetables, including specified weekly amounts of vegetable subgroups. These subgroups include
dark green, red/orange, starchy, and legumes. While this is nutritionally beneficial, it has compli-
cated menu planning and to some extent, student acceptance. A full cup of fruit must be offered
at breakfast, and one-half cup of fruit and three-quarters cup of vegetables must be offered to
K-8 students at lunch. Students must take at least one-half cup of fruit or vegetable with both
breakfast and lunch whether or not they plan to eat it. Districts have experienced an increase in
waste because of this requirement.
Offer versus serve is a meal planning option that allows students to decline some of the food
offered in a reimbursable meal. The goal is to reduce food waste and extra expense and permit
students to choose the foods they want to eat. At least five items must be offered at lunch and
four at breakfast, and students may take all of the items offered; however, they are required to
take only three items at each meal. Other than the requirement that one of the items must be
a fruit or vegetable, students may choose or refuse whatever they want. Offer versus serve is
required by regulations at the high school level and highly encouraged at other grade levels.
Lost Hills Union uses offer versus serve, but it is not implemented properly. Observations and
discussions with staff indicated a lack of understanding regarding portion sizes and components
required to constitute a complete reimbursable meal. For example, every student was required
to take a fruit. The menu included two fruit choices at breakfast, and two fruit and two or three
vegetable choices at lunch. The minimum requirement is for the students to take a one-half cup
serving of a fruit or a vegetable. Forcing the students to take a fruit resulted in many servings
being discarded. This also adds to food costs and labor costs spent preparing the food. It would
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MENUS AND MEAL SERVICE
be beneficial for students and staff to be informed about what constitutes a complete meal. This
could be accomplished in several ways; for example, the food service manager could visit class-
rooms at the beginning of each school year and give a short lesson on this subject, especially to
kindergarten students, or provide information to teachers so they can share it with students.
Federal regulations require signage at the breakfast and lunch serving lines to inform students
of what food items they must take. This can be accomplished with words as well as pictures
to simplify the signs, particularly in a bilingual setting. Signage needs to be placed in a visible
location at or near the beginning of the serving line and must indicate what foods are part of the
reimbursable meal so students can easily choose all the required food items in the appropriate
quantities. The signage should include the number of choices of fruits or grains the student may
select and the minimum requirements for offer versus serve. These can be simple and generic or
include the actual foods served on the daily menu. Generally, simple signage is the best option,
and signs are available for sale commercially. The required signage was not used during the review
team’s site visit. Further information regarding the requirements can be found on the following
websites:
http://www.cde.ca.gov/ls/nu/ed/documents/mlptrnchg.ppt
http://www.fns.usda.gov/sites/default/files/cn/SP41_2015a.pdf
Some of the fruit and vegetable portion sizes offered by the district are incorrect and further indi-
cate the food service staff members’ lack of understanding of the requirements. The production
records for lunch show portions of three-quarter cup and two to three choices. Although the
regulations state that three-quarters cup must be offered, students need to take only one-half cup.
If all servings were one-half cup and at least two one-half cup items were offered, requirements
would be met, the portion size would be more appropriate for students, and costs would be
reduced. Students with bigger appetites can take more menu items. The production records
provided to FCMAT show that a few items are incorrectly planned. For example, green salad
is listed as either one-half or three-quarter cup. However, all leafy greens must be in one-cup
portions to equal the one-half cup nutritional equivalent. Another exception is dried fruit, which
requires a one-quarter cup portion to meet requirements. The regulations regarding portion sizes
for fruits and vegetables are confusing and often misinterpreted; however, the state looks for
compliance during on-site reviews, and the district was cited for an error in this regulation during
its last state review.
Menus
As described in the federal nutritional requirements, the new regulations have made menu plan-
ning more complicated. Trying to include the amount and variety of fruits, vegetables and whole
grains within calorie maximums creates a difficult task, and students sometimes do not prefer the
foods. A review of a sampling of 2014-15 menus and production records indicates that menus
did not comply with federal regulations. Additionally, many menu items were unnecessarily
time-consuming to prepare. Examples include the following:
Bulk concentrated juices that needed to be mixed in pitchers and poured into individual cups.
Homemade yeast breads prepared by the food service staff.
Raw ground beef purchased in 80 pound cases, which had to be thawed, cooked and crumbled
for dishes such as chili and spaghetti.
Peeling and cutting items such as carrots, jicama and apples.
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MENUS AND MEAL SERVICE
Preparing salad dressing from scratch with staff topping salads on the serving line.
These types of products and processes are rarely used in quantity food production because they
are not cost-effective.
The district’s food service consultant has rewritten menus and has begun to simplify many food
items, including the purchase of individual cartons of juice, premade bread items, precooked
crumbled ground beef, precut and individually packaged fruits and vegetables, and individual
salad dressing packets. These types of changes save time, reduce potential employee injuries,
and decrease waste. Interviews with staff indicated that they are pleased with the changes, and
students like the food.
During the study team’s visit, the foods appeared fresh and appealing, and students appeared to
enjoy the meals. A few individuals indicated they would like more Hispanic foods on the menu
because of the district’s large Hispanic population and more homemade items; however, the
students indicated they were happy with the present choices during the study team’s visit. Placing
more ethnic and homemade foods on the menus could be difficult because the federal nutritional
requirements for whole grains, less fat and salt and limited calories would likely make these
foods not taste the same as those the students receive at home. Conducting a survey of students
and families to determine the food items they want on the menus that also comply with federal
requirements could be helpful in menu planning.
Production Records and Standardized Recipes
Federal regulations require the use of production records and standardized recipes to ensure that
the food served to students meets the nutritional guidelines for a complete reimbursable meal.
Menu production records are meant to document the types and amounts of food served to
students and adults. This is to ensure compliance with regulations and can help plan the amounts
of food needed in future menu cycles. It helps prevent under- or overproduction of meals.
Many different formats are used for production records. Several examples are provided on the
CDE website, but use of a particular form is not required. As long as all the required information
is recorded, the district may use any form it chooses. A list of required information is included
in the appendix section of this report. It basically includes the number of meals planned, the
number of meals served, and the nutritional component each item meets, serving sizes, recipe
numbers or product codes, and leftovers or substitutions. The forms must be kept for three years
and are a part of state food service reviews. Additional information is provided on the CDE
website http://www.cde.ca.gov/ls/nu/he/menuprorecords.asp.
The Food Service Department has been trying to use production records, but the forms used
do not contain all required fields, and staff do not fully understand how to use them. The food
service consultant recently introduced a new form and is working with staff to ensure they are
completed correctly. The new form contains most of the required fields, but is missing a column
for adult servings and includes an unnecessary column entitled “number times the recipe.”
The Food Service Department does not use standardized recipes, which is a requirement of the
program. The department does not have a recipe file or book. As a result, many items are made
without recipes or with personal recipes.
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MENUS AND MEAL SERVICE
Standardized recipes follow a particular format. They should include the name of the item,
cooking instructions, cooking time, cooking temperature, ingredients, portion size, and yield.
Hazard Analysis and Critical Control Point (HACCP) safety precautions also need to be written
in the recipe. Using a standardized format has numerous advantages: they are consistent, easy to
follow, and control the end product. Sample template forms are available on the CDE website
http://www.cde.ca.gov/ls/nu/he/documents/recipe.doc.
Products that are prepackaged and only require heating are also required to have a recipe for each
menu item, and those recipes must be kept on site.
Recommendations
The district should:
1. Ensure nutritional requirements are met in menu planning and service and
change portions to correct amounts as necessary.
2. Teach staff and students the component and portion size requirements for a
complete meal.
3. Purchase or create and install signage to show students what constitutes a
complete meal.
4. Ensure menus comply with federal regulations and consider ease in prepara-
tion, cost and student preferences.
5. Survey students and families to determine if there are food choices that
could increase satisfaction and participation and also meet federal nutritional
requirements.
6. Ensure that the menu production record forms include all the required fields,
staff complete them properly, and that they are maintained for the required
period of time.
7. Use production records to help project amounts of food needed for purchase
and production.
8. Develop standardized recipes for all menu items and ensure that staff follows
them.
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PROVISION 2
Provision 2
Provisional status is an alternative method to the usual process of collecting and processing
applications annually to qualify students for the free and reduced-price meal program. A district
with high eligibility is a perfect candidate for provisional status because even though all students
eat at no charge, reimbursements are paid based on the percentages of free, reduced and paid
students during the base year. During the first year, or base year, the school makes eligibility
determinations using the normal application process and takes meal counts by type of eligibility.
During the next three years, the school makes no new eligibility determinations and counts only
the total number of reimbursable meals served each day. Reimbursement during these years is
determined by applying the percentages of free, reduced-price and paid meals served during the
corresponding month of the base year to the total meal count for the claiming month. Schools
must serve meals to all participating children at no charge for four years, including the base year.
At the end of each four-year period, the state may approve four-year extensions if the income
level of the school’s population remains stable.
Schools electing the Provision 2 alternative must pay the difference between federal reimburse-
ment and the cost of providing all meals at no charge. The money to pay for this difference must
be from sources other than federal funds. However, Provision 2 reduces the time necessary to
process free and reduced-price meal applications and simplifies meal counting and claiming
procedures. It is important during the base year to widely market the program and encourage
all families to complete applications because future reimbursements will be determined by the
base year eligibilities. If the district chooses to participate in the Provision 2 alternative, it should
collect as many applications as possible and ensure that all students are listed on family applica-
tions so that they are included in the base year calculation. It is also vital to encourage maximum
student participation during the base year. The Provision 2 Guidance Manual is located on the
USDA website http://www.fns.usda.gov/sites/default/files/prov2guidance.pdf.
Because future revenue under the provisional program will depend on the eligibility established
in the base year, it is imperative for the district to have accurate data. The previously discussed
issues regarding inaccurate enrollment data in the food service software system must be corrected
so accurate eligibility and participation can be reported during the base year.
The provisional alternative should help increase student participation in the food service
program, and after the base year, will simplify the meal counting and claiming process. It does
not require students to enter individual identification numbers in the point-of-sale system;
simple meal counts can be taken at the end of the serving line. The only data necessary is the
total number of breakfasts and lunches served for reimbursement claims. Some districts opt to
continue using the point-of-sale system, but it is not required.
Recommendations
The district should:
1. Consider applying for Provision 2 status for the 2016-17 school year.
Planning should include providing information to all families, teachers and
staff, and the plan should be widely marketed to capture the highest possible
eligibility and maximize student participation in the base year.
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PROVISION 2
2. Before it pursues Provision 2 status, develop a system to regularly reconcile
the information in the food service software system with the student informa-
tion system.
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NONPROGRAM FOOD REVENUE
Nonprogram Food Revenue
Nonprogram foods are food and beverage items, other than reimbursable meals and meal supple-
ments, which are sold on a school campus. This includes a la carte and other food items that are
sold in competition with the reimbursable meal program and are purchased with cafeteria funds.
All foods sold in a school and purchased with funds from the nonprofit school food service
account, other than meals and meal supplements reimbursed by the USDA, must generate
revenue at least equal to the cost of such foods. The USDA requires that the sales of nonprogram
foods generate at least the same percentage of revenue as they contribute to total food costs. The
main reason for this requirement is to ensure that the revenue from reimbursable meals does not
fund foods sold in competition with the meal program.
Food service programs must calculate their nonprogram food revenues and costs and provide
documentation of the calculations to the CDE upon request and during CDE administrative
reviews. To help complete the required calculations, the CDE has provided guidance and a link
to the USDA Nonprogram Food Tool on its website http://www.cde.ca.gov/ls/nu/sn/mbus-
dasnp362012.asp.
During the 2015 administrative review, the state found that the district had not prepared the
required calculations and issued a corrective action to complete and submit them. The district
sells a few adult meals to staff, but does not sell any a la carte items; therefore, this should be a
relatively simple calculation for the district to complete.
Recommendation
The district should:
1. Track all nonprogram food costs and revenues, complete the required calcula-
tions annually, and provide them to the CDE upon request.
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NONPROGRAM FOOD REVENUE
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PAID LUNCH EQUITY AND MEAL CHARGES
Paid Lunch Equity and Meal Charges
The USDA and state have addressed the issue of prices charged to students that do not qualify for
free or reduced-price meals. The Healthy, Hunger-Free Kids Act of 2010, Public Law 111-296,
specifies that meals for nonneedy students are not subsidized by federal reimbursements for meals
of needy students. This law became effective July 1, 2011.
Basically, it states that a district’s average meal prices should at least equal the difference between
the federal subsidies for free meals and those for paid meals. The 2015-16 federal reimburse-
ment for free lunch is $3.15 and 37 cents for paid lunch. The difference is $2.78, which is the
minimum the district should charge for paid lunches. The district’s 2014-15 paid lunch prices
were $1. This finding was included in the 2014-15 CDE administrative review, and the district
was required to describe in writing how much and how often the price will be increased until it
meets the paid lunch equity requirement. The price was increased to $1.80 this year, but it is still
too low, and it will need to be increased annually until it meets the criteria.
If the district elects the Provision 2 option as discussed earlier in this report, this would no longer
apply because all students would eat at no charge. The provisional status would negate this issue
and would likely increase participation among paid students and those eligible for reduced-price
meals. Price increases in an economically needy area can be especially difficult because meals may
become unaffordable and discourage participation.
The paid lunch equity calculation does not apply to breakfast; however, sound financial manage-
ment practices would ensure that district prices for paid meals cover the cost of those meals.
Federal breakfast reimbursements this year are $1.99 for free and 29 cents for paid meals. The
district’s paid breakfast price is $1.
More information on meal price equity and a calculation tool can be found at http://www.fns.
usda.gov/paid-lunch-equity-school-year-2015-16-calculations-and-tool.
The district does not have consistent procedures on negative student account balances. The
2011-12 meal count procedure includes a $10 limit for charges, and indicates that an alternate
meal will be given until the balance is paid. Administrative Regulation 3551, which was approved
in March 2014, states that whenever a student’s account balance is zero, parents will be notified.
If the unpaid balance is $50 or more, parents/guardians will be notified in writing that full
payment is due within seven school days from the date of the notice. Neither of these guidelines
appears to be followed. Negative account balance reports dated October 21, 2015 show total
charges of $583.20 that consists of 40 students with negative balances. Of those students, 19
exceeded $10, 12 of the 19 exceeded $20 and one owed $79.20.
The district also allows adults to charge meals. The October 21, 2015 report for adult meal
charges shows 34 adults with negative balances that total $798.60. Thirteen individuals had
charges totaling over $25, and the highest charge was $85.20.
Student meal charges should be kept to a minimum, and negative account balances should be
communicated to families regularly through letters home and/or phone calls. The district’s auto-
mated calling system can be configured with the department point-of-sale system to make phone
calls to those student families with negative account balances. Student charges would not be an
issue if provisional status was implemented.
Adults should be encouraged to prepay for their meals and prohibited from charging unless this
occurs only occasionally and is repaid quickly.
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PAID LUNCH EQUITY AND MEAL CHARGES
Account balances that are unpaid at the end of the fiscal year are considered bad debt and cannot
be absorbed by the federally funded cafeteria program or carried over to the next school year.
The charges must be paid by the unrestricted general fund while the district continues to pursue
payment from the individual students and adults. More information regarding this issue is avail-
able at http://www.cde.ca.gov/ls/nu/sn/cafefundfaqgen.asp.
Recommendations
The district should:
1. Perform the annual paid lunch equity calculation.
2. Increase paid lunch prices each year to ensure federal and state requirements
have been met. This will not be necessary if the district obtains Provision 2
status.
3. Increase paid breakfast prices to ensure they cover meals costs. This will not
be necessary if the district obtains Provision 2 status.
4. Review and revise student meal charge policies and procedures as needed to
ensure consistency.
5. Ensure negative student account balances do not exceed its policies and
procedures.
6. Prohibit adult meal charges except for occasional emergencies.
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FOOD HANDLING AND FOOD SAFETY
Food Handling and Food Safety
Proper food handling is essential for any food service operation to maintain fresh foods and avoid
food-borne illness. The food service operation must follow all local and state health regulations,
and school districts participating in the federal meal program must follow a specific format in
their food safety plan, the Hazard Analysis and Critical Control Point (HACCP). All food safety
policies and procedures must be outlined in HACCP-based standard operating procedures. The
HACCP has been required since 2005 and is a comprehensive food safety plan that includes a
detailed and specific format and complex methods for ensuring food safety.
The district does not have a HACCP plan specific to its operation. The documents provided
to FCMAT are a generic version of the plan from the USDA HACCP manual. The district is
required to have a written HACCP plan that is outlined in a specific format and implemented
in daily food handling procedures, such as taking and recording food and refrigeration tempera-
tures.
Interviews indicated that all the district’s food service employees have food safety certifications,
but improvement may be needed in some food safety practices. For example, food, refrigerator
and freezer temperatures are not properly recorded.
In accordance with USDA guidance issued in June 2005, a school food safety program must
include documented standard operating procedures and a written plan at each school food
preparation and service site for applying HACCP principles. The written plan must include
methods for documenting menu items in the appropriate HACCP process category; docu-
menting critical control points of food production; monitoring; establishing and documenting
corrective actions; record keeping; and reviewing and revising the overall food safety program.
Additional details can be found at http://www.cde.ca.gov/ls/nu/sn/gis15.asp. A copy of the
USDA HACCP guidance manual can be found at http://www.fns.usda.gov/sites/default/files/
Food_Safety_HACCPGuidance.pdf.
The National Food Service Management Institute has developed HACCP-based standard
operating procedures in conjunction with the USDA and the Food and Drug Administration.
Templates are available at http://www.nfsmi.org/ResourceOverview.aspx?ID=75. Use of these
templates can help simplify the development of policies and procedures; however, the district will
need to individualize them to fit its food service program.
Recommendations
The district should:
1. Ensure that the Food Service Department creates a HACCP plan specific to
its operation based on the USDA guidelines. This should be completed before
the next CDE administrative review.
2. Ensure that the food service manager monitors food safety practices and
trains staff as needed to ensure that proper procedures are followed.
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FOOD HANDLING AND FOOD SAFETY
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WELLNESS POLICY
Wellness Policy
Wellness policies have been required for school districts participating in the National School
Lunch Program since 2006. This requirement was part of the federal Child Nutrition
Reauthorization Act of 2004.
The Healthy, Hunger-Free Kids Act of 2010 specified new requirements for wellness policies,
including:
1. Designate one or more school officials to ensure that the school complies with
the policy.
2. Include goals for nutrition promotion.
3. Expand the committee members to include physical education teachers and
school health professionals.
4. Inform and update the public about the content and implementation of the
policy.
The district has a generic wellness policy, Board Policy 5030 Student Wellness, which includes
the original requirements. However, it does not have an active wellness committee, and the
implementation, monitoring and reporting issues in the 2010 federal requirements have not
been addressed. This was also cited in the 2014-15 CDE administrative review. Interviews with
staff indicated that the district is in the process of revising its policy and forming a wellness
committee.
More information about the requirements of a district wellness policy and suggestions for imple-
menting one are available on the CDE website http://www.cde.ca.gov/ls/nu/he/wellness.asp.
Recommendations
The district should:
1. When revising its wellness policy, ensure that all the federal requirements are
met, specifically the implementation, monitoring and reporting requirements.
2. Continue with its plan to form a wellness committee.
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WELLNESS POLICY
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FOOD COSTS AND PURCHASING
Food Costs and Purchasing
As discussed in the Budget section of this report, food costs have been exceedingly high. Based on
the team’s experience, they should be 40-45% of revenue, but have increased over the past four
years and are projected at 56% of revenue for 2015-16. Although the Food Service Department
has used state-provided commodities, it has not been part of any formal bidding or informal
request for quotes process for food or food service supplies.
The study team reviewed prices from a sample of vendor invoices provided by the district
and found that a few prices were reasonable such as milk at 24 cents per eight-ounce carton.
However, most prices were high. For example, cereal prices ranged from 18 cents to 43 cents per
individual package from one vendor and 41 cents to 48 cents from another. Individual packages
of granola were 61 cents. Cereal should be an inexpensive product to purchase, and given the low
breakfast reimbursement rates per meal, costs need to be closely monitored. In the study team’s
experience, 18 cents for individual cereal packages is appropriate.
Another example of high-priced food items was canned applesauce. The 2014-15 invoices
included purchases at $43.75 per case, which is approximately 30 cents per serving plus a few
cents for a serving cup. On the same invoice, individual four-ounce cups of applesauce were
purchased for 47 cents a serving. Commodity applesauce is usually available at $3.15 per case,
which is approximately 2 cents per serving plus a few cents for a plastic serving cup. This indi-
cates that the price of food service items receives insufficient attention.
The district has purchased products from some reputable companies that participate with schools
through a bid process. However, without the use of a bid process, prices can be extremely high.
Interviews indicated that the food service manager was directed to complete the process necessary
to become a member of the Partners in Nutrition Cooperative (PinCo), a food purchasing
cooperative, but the process was not finished and membership was temporarily suspended. The
district’s food service consultant has assisted in getting PinCo membership reinstated. This is one
of the largest school purchasing cooperatives in the state and can negotiate competitive prices.
PinCo coordinates commodity products as well as non-commodity and paper goods. The food
service consultant has negotiated competitive prices with other vendors for produce, milk and
bread products, but invoices from these vendors were not available for review at the time of
FCMAT’s fieldwork.
Interviews with staff indicated that the ordering process is disorganized. Inventories are not
kept up to date, and some items were over ordered. Menu items were often overlooked and not
ordered when needed, causing chaotic last-minute changes in menus. Inventories need to be
completed regularly so stock on hand is known, and menus must be carefully planned to ensure
that all necessary items are in stock when needed. The food service manager should specify
particular products, and purchasing guides should be created for all vendors.
Recommendations
The district should:
1. Continue its membership in the purchasing cooperative.
2. Seek bids, requests for quotes, or negotiate prices with its other food service
vendors to ensure competitive prices.
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FOOD COSTS AND PURCHASING
3. Ensure that the food service inventory is kept current.
4. Create order guides that dictate specific products to use and the vendors to
procure them from.
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FACILITIES AND EQUIPMENT
Facilities and Equipment
The district has modern kitchen and cafeteria facilities. The kitchen is large and well designed
with plenty of workspace and large storage areas for dry and perishable foods. The cafeteria eating
area is large and can accommodate many children.
The serving area is well designed for easy student access and an organized and efficient flow. The
serving counter by the student lines has easy access to carts of hot and cold food. The facility also
includes an office space for manager and clerical duties.
Replacing a few pieces of outdated equipment could be a significant improvement. The food
service consultant is investigating the possibility of applying for USDA equipment grants to
purchase some new equipment. These grants fund capital equipment and priority is given to
districts with high free and reduced-price meal eligibility. A bulletin describing the grant process
can be found at the CDE website http://www.cde.ca.gov/ls/nu/sn/mbsnp292015.asp.
Equipment that has been identified for replacement includes a large steam kettle that is used for
items such as spaghetti and chili, an old deck oven (similar to a pizza oven), and an old single
stack oven (which is two ovens stacked together). Staff indicated that the steam kettle it is too
big and difficult to clean since scrubbing it requires standing on a step stool and leaning in. The
district is considering the purchase of a tilt skillet, which is shallower and has a pour spout that
can be tilted to transfer food to serving pans. When using the tilt skillet, staff would have to
prepare the food in bulk and then transfer it to serving pans. This is an extra step and requires
cleaning the tilt skillet as well as the pans. Another alternative would be to purchase a new
double-stack oven (which is four ovens) to replace the current ovens and the large steam kettle.
All the foods prepared in the kettle can be prepared in steam table pans in the ovens. Most menu
items are prepared in the oven on sheet pans and do not require a kettle or tilt skillet, and more
oven space would assist staff in all food preparation.
Small equipment purchases can typically be made with the food service budget. Simple additions
can make a big difference to efficiency and staff morale. For example, an orange slicer was
recently purchased that is more efficient and safer than slicing oranges with a knife, and staff
indicated that they are pleased with it.
Recommendations
The district should:
1. Carefully assess the equipment needs of the Food Service Department and
pursue the USDA equipment grant to fund capital purchases.
2. Assess current small equipment, obtain staff input regarding their needs and
update equipment as necessary.
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STATE ADMINISTRATIVE REVIEW
State Administrative Review
In March 2015 the district had a state administrative review, a routine program review that
normally occurs every three years. This resulted in many findings that required corrective action.
The state also determined that technical assistance was needed in several areas, and the state
reviewer provided the necessary assistance to the district. Following is a summary of the state’s
findings:
1. Migrant-eligible students were not given full year free meal status as allowed.
Corrective action – The district was to give these students free status and
create a roster to verify this for CDE.
2. One student was qualified as reduced-price meal eligible rather than denied.
Corrective action – The district needed to change eligibility and submit a
roster to CDE verifying the change.
3. Benefits were not extended to all students living in a household receiving
assistance under the Supplemental Nutrition Assistance Program (SNAP),
Food Distribution Program on Indian Reservations (FDPIR) or Temporary
Assistance for Needy Families (TANF). Corrective action – The district
needed to correct this and submit it in writing to the state, including the staff
position responsible for this action.
4. Verification requirements were not met because the sample size was too large;
34 applications were verified rather than one. Corrective action – The district
was to complete the Worksheet to Determine Verification Sample Size and
submit it to the state.
5. Meal counting and claiming requirements were not met. The district was
giving new students free rather than paid eligibility status while waiting for
applications to be turned in. Corrective action – The district was to submit
written procedure to the state, including the staff member’s name and posi-
tion responsible for this action.
6. Wellness policy implementation and reporting were not completed as
required. Corrective action – The district was to provide a written plan to
the CDE describing the action taken to assess the policy and submit the staff
member’s name and position responsible for the action.
7. Nonprogram foods tool was not completed to ensure that nonprogram
revenue equaled or exceeded the food costs. Corrective action – The district
was required to complete and submit the nonprogram foods tool.
8. Paid lunch equity (PLE) tool was not completed and the student lunch price
of $1 was out of compliance. Corrective action – The district was required to
describe in writing how much the price will be increased and how often the
increase will occur to meet the PLE tool’s calculation.
9. Meal components and quantities for breakfast were not met in three areas:
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STATE ADMINISTRATIVE REVIEW
• The recipe for bread rolls did not document they were made with whole-wheat flour.
Corrective action – The district needed to provide a recipe that verified whole-wheat
flour is used in the rolls.
• The cereal did not meet the whole-wheat requirements, and the first ingredient was not
whole wheat. Corrective action – The district had to provide food specifications verifying
that whole-wheat breakfast cereal that meets requirements is now served.
• The fresh orange did not meet the required one-half cup portion size. This was corrected
before meal service so no meals were disqualified. Corrective action – The district had to
put in writing that one-half cup fruit requirement will be served.
10. Meal components and quantities at lunch were not met. The portion of
salad was listed on the production record as one cup but a six-ounce portion
was served. Corrective action – The district needed to verify in writing that
the proper size salad cup would be used and provide the state with a recipe
confirming that.
Based on the number and type of findings, the food service manager and/or department
employees apparently either did not understand the regulations or were unable or unwilling to
fully implement them to ensure compliance.
Interviews indicated that a district business office staff member attended trainings and modified
many areas in the Food Service Department before the state administrative review. The findings
and resulting financial consequences of the review could have been significantly worse if this had
not occurred.
Recommendations
The district should:
1. Ensure strong, effective leadership in the Food Service Department.
2. Ensure that Food Service Department staff members are properly trained and
follow federal and state regulations.
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STAFF TRAINING
Staff Training
Food service staff members need to receive training regularly to be able to understand and
perform their jobs. While some training has been provided, more is needed. For example, inter-
views indicated that food temperatures are checked, but not recorded as required by the HACCP
food safety plan.
As discussed previously, the study team observed and interviews indicated that staff members are
confused about required food components and portions and do not correctly follow the offer
versus serve regulations. Observations and interviews with staff also indicated that some food
service staff members are not clear on their job duties and the need for teamwork.
Interviews with administration indicated that the food service manager has attended all
mandated trainings. However, as indicated in the State Administrative Review section of this
report, several program regulations are not implemented properly. It is essential for a department
manager to thoroughly understand and implement program regulations and train staff in neces-
sary requirements.
The food service manager and staff would also benefit from visiting other school districts’ food
service departments and observing their meal service. Networking is important in helping
provide new ideas as well as information about efficiencies and cost-saving measures. When
staff members have worked in only one environment, they often cannot visualize other ways to
perform their duties. Observing other food service operations can help stimulate new ideas for
menu offerings, production and meal service.
Training is essential, and the USDA has established minimum education and training require-
ments for food service personnel. These requirements became effective on July 1, 2015, and
mandate professional standards and annual training requirements for child nutrition directors,
managers and staff. The requirements vary with the position. Training needs to be documented
and will be evaluated during state administrative reviews. Information about this mandate and
training resources can be found in the appendix of this report and at the website http://profes-
sionalstandards.nal.usda.gov/.
Recommendations
The district should:
1. Identify areas that require immediate training for the food service manager
and staff and ensure that it is provided. This is particularly urgent in food
safety practices and program requirements such as portion sizes and meal
components.
2. Consider sending the food service manager and staff to other school districts
to observe food service operations.
3. Ensure that the USDA’s training and education requirements are met.
4. Schedule regular training sessions for food service staff. These can be provided
within the department, through online webinars, and at conferences.
5. Provide additional program training for the food service manager and require
implementation of all regulations.
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STAFF TRAINING
6. Ensure that the food service manager provides staff members with informa-
tion regarding regulations and changes to regulations.
7. Train and cross-train staff so they can perform all food service tasks efficiently,
including operating the point-of-sale system.
8. Document all trainings and retain the records of such for each staff member.
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APPENDDRICAEFST
Appendices
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Appendix A
Menu Planning
Menu Planning for Breakfast
Amount of Food Per Week (Minimum Per Day)
Meal Pattern Grades K–12 Grades K–5 Grades K–8 Grades 6–8 Grades 6–12 Grades 9–12
Fruits (cups)b, 2013-14 2 1/2 (1/2) 2 1/2 (1/2) 2 1/2 (1/2) 2 1/2 (1/2) 2 1/2 (1/2) 2 1/2 (1/2)
Fruits (cups)b,c 2014-15 5 (1) 5 (1) 5 (1) 5 (1) 5 (1) 5 (1)
Vegetables (cups)b, c 0 0 0 0 0 0
Grain Minimums (oz eq)d 9-10 (1)* 7-10 (1)* 8-10 (1)* 8-10 (1)* 9-10 (1)* 9-10 (1)*
Meat/Meat Alternate
Minimums (oz eq)e 0 0 0 0 0 0
Fluid Milk (Cups)f 5 (1) 5 (1) 5 (1) 5 (1) 5 (1) 5 (1)
Other Specifications: Daily Amount Based on the Average for a 5-Day Week
Meal Pattern Grades K–12 Grades K–5 Grades K–8 Grades 6–8 Grades 6–12 Grades 9–12
Min-max calories
(kcal)g,h 450–500 350–500 400–500 400–550 450–550 450–600
Saturated fat <10% of <10% of <10% of <10% of <10% of
(% of calories)h calories calories calories calories calories <10% of calories
Sodium
Target 1 (mg)h,I 2014-15 SY ≤ 540 mg ≤ 540 mg ≤ 540 mg ≤600 mg ≤ 600 mg ≤ 640 mg
Reference Only
Sodium
Target 2 (mg)h,I 2017-18 ≤485 mg ≤ 485 mg ≤ 485 mg ≤ 535 mg ≤ 535 mg ≤ 570 mg
SY
Trans fath-Nutrition label or manufacturer specifications must indicate zero grams of trans fat (< 0.5 grams) per serving
*U.S. Department of Agriculture has lifted the weekly maximums for grains. The daily and weekly minimums for grains and
the weekly calorie ranges still apply.The maximums are used as a guide for menu planning purposes only.
a Food items included in each group and subgroup and amount equivalents. Minimum creditable serving is ⅛ cup.
b One quarter-cup of dried fruit counts as ½ cup of fruit; 1 cup of leafy greens counts as ½ cup of vegetables. All juice must be
100% full-strength. Frozen 100% juice without added sugar can be used.
c Vegetables may be substituted for fruits, but the first two cups per week of any such substitution must be from the dark
green, red/orange, beans and peas (legumes) or ""Other vegetables"" subgroups, as defined in 210.10(c)(2)(iii).
d All grains must be whole grain-rich. Schools may substitute 1 oz. eq. of meat/meat alternate for 1 oz. eq. of grains after the
minimum daily grains requirement is met. Meat/meat alternates may be offered as extra food items that do not count toward
the grain component or as food items for OVS. These extra food items need to be included in the weekly calories, sodium, and
saturated fat.
e There is no meat/meat alternate requirement.
f All fluid milk must be low-fat (1 percent milk fat or less, unflavored) or fat- free (unflavored or flavored).
g The average daily calories for a 5-day school week must be within the range (at least the minimum and no more than the
maximum values).
h Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the specifications
for calories, saturated fat, trans fat, and sodium. Foods of minimal nutritional value and fluid milk with fat content greater than 1
percent milk fat are not allowed.
i Final sodium targets must be met no later than July 1, 2022 (SY 2022–23). The first intermediate target must be met no later
than SY 2014–2015 and the second intermediate target must be met no later than SY 2017–18. See required intermediate
specifications in § 220.8(f)(3).
Note: For offer versus serve, every student must take either ½ cup fruit (or substituted vegetable) or a combination of both to
count as a reimbursable meal
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Menu Planning for Lunch
Amount of Food per Week (Minimum per Day)
Meal Pattern Grades K–5 Grades K–8 Grades 6–8 Grades 9–12
Fruits (cups)b 2½ (½) 2½ (½) 2½ (½) 5 (1)
Vegetables (cups)b 3¾ (¾) 3¾ (¾) 3¾ (¾) 5 (1)
Dark Greenc ½ ½ ½ ½
Red/Orangec ¾ ¾ ¾ 1¼
Beans and Peas (legumes)c ½ ½ ½ ½
Starchyc ½ ½ ½ ½
Other c,d ½ ½ ½ ¾
Additional Veg to Reach Totale 1e 1e 1e 1½e
Grain Minimums (oz eq)f 8-9 (1)* 8-9 (1)* 8-10 (1)* 10-12 (2)*
Meats/Meat Alternate Minimums (oz eq) 8-10 (1)* 9-10 (1)* 9-10 (1)* 10-12 (2)*
Fluid Milk (Cups)g 5 (1) 5 (1) 5 (1) 5 (1)
Other Specifications: Daily Amount Based on the Average for a 5-Day Week
Meal Pattern Grades K–5 Grades K–8 Grades 6–8 Grades 9–12
Min-max calories (kcal)h 550–650 600–650 600–700 750–850
Saturated fat (% of calories)h < 10 < 10 < 10 < 10
Sodium Target 1 (mg)h,l 2014-15 SY ≤ 1,230 ≤ 1,230 ≤ 1,360 ≤ 1,420
Reference Only Sodium Target 2 (mg)h,l 2017-18 SY ≤935 ≤ 935 ≤ 1,035 ≤ 1,080
Trans Fath: Nutrition label or manufacturer specifications must indicate zero grams of trans fat per serving.
*U.S. Department of Agriculture has lifted the weekly maximums for grain and meat/meat alternates. The daily and
weekly minimums for grains and meat/meat alternates still apply. The maximum are used as a guide for menu
planning purposes only.
a. Food items included in each group and subgroup and amount equivalents. Minimum creditable serving is ⅛ cup.
b. One quarter-cup of dried fruit counts as ½ cup of fruit; 1 cup of leafy greens counts as ½ cup of vegetables. No
more than half of the fruit or vegetable offerings may be in the form of juice. All juice must be 100% full-strength.
c. Larger amounts of these vegetables may be served.
d. This category consists of “Other vegetables” as defined in §210.10(c)(2)(iii)(E) . For
the purposes of the National School Lunch Program, the “Other vegetables” requirement may be met with any
additional amounts from the dark green, red/orange, and
beans/peas (legumes) vegetable subgroups as defined in §210.10(c)(2)(iii).
e. Any vegetable subgroup may be offered to meet the total weekly vegetable requirement.
f. All grains must be whole grain-rich.
g. All fluid milk must be low-fat (1 percent or less, unflavored) or fat-free (unflavored or flavored).
h. Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if within the
specifications for calories, saturated fat, trans fat, and sodium. Foods of minimal nutritional value and fluid milk with
fat content greater than 1 percent are not allowed.
i. Final sodium targets must be met no later than July 1, 2022 (2022–23 SY). The first intermediate target must be
met no later than SY 2014–15 and the second intermediate target must be met no later than 2017–18 SY. See
required intermediate specifications in § 210.10(f)(3).
Note: For offer versus serve, every student must take 1/2 cup fruit and/or vegetable or combination of both to count
as a reimbursable meal.
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Information Required on a Meal Production Record (MPR)
Production Record Description
Date and Site(s) The date the menu was served and the site or
sites where it was served
Menu or food items All planned items, including all choices,
types of milk, dessert, and substitutions;
listed menu shows that all food components
are present
Offer versus Serve: Yes or No Indicate whether offer versus serve is in
effect for this MPR
Recipes and/or products Specific recipes and food products; name of
the food and form; recipe number if USDA;
if processed, brand name and code number
Age group or grade of students served The age group or grade being served.
Adjusted portion sizes for age group or
grade specified must be shown for menu
items, recipes, and products
Portions or serving sizes, both planned and Portion size served must be the same as
served planned. If portion size is adjusted for age, a
separate line must be used
Contribution to the meal pattern The contribution to the meal pattern for
each food
Total projected servings Forecasted or predicted approximate
number of servings needed for each menu
item
Amount of food used Verifies that the planned menu was actually
prepared and served and must be recorded
in common units of measure, e.g., number,
size, weight or volume and be traceable to
itemized receipts with the purchase unit
such as #10 can or pound
Actual servings A separate record of the number of servings
of each item served to students, adults, and
as a la carte sales
Leftovers A record of leftovers and how the leftovers
will be used or discarded
Condiments or Extras All condiments served as part of the
reimbursable meal, including gravy, butter,
margarine, mayonnaise, relish, ketchup,
mustard, and salad dressing
Menu Production Records (MPRs)
USDA requires sponsors to maintain MPRs documenting that the meals as planned, prepared, and
served meet the meal pattern requirements. Must be kept for 3 years.
http://www.cde.ca.gov/ls/nu/he/menuprorecords.asp
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Appendix B
Professional Standards
United States Department of Agriculture
Professional Standards for All School Nutrition Program Employees
Summary of the Final Rule Effective July 1, 2015
USDA has established minimum professional standards requirements for school nutrition professionals who manage and operate the
National School Lunch and School Breakfast Programs.
The standards, another key provision of the Healthy, Hunger-Free Kids Act of 2010 (HHFKA), aim to institute minimum education
standards for new State and local school nutrition directors as well as annual training standards for all school nutrition professionals.
These new standards will ensure school nutrition personnel have the knowledge, training, and tools they need to plan, prepare, and
purchase healthy products to create nutritious, safe, and enjoyable school meals. This final rule will:
• Create minimum hiring standards for new school food authority (SFA) directors based
on a school district’s size;
• Establish minimum hiring standards for new State directors of school nutrition programs
and State directors of distributing agencies; and
• Require minimum annual training for all new and current school nutrition professionals.
A comprehensive Professional Standards Web site provides a database of training options. School nutrition staff can search for training
that meets their learning needs in one easy-to-use location: http://professionalstandards.nal.usda.gov/
Training Standards for All School Nutrition Program Employees (All Local Educational Agency Sizes)
All Directors For School Year 2015-2016 ONLY: at least 8 hours of annual continuing education/training.
Beginning school year 2016-2017: at least 12 hours of annual continuing education/training. This
required continuing education/training is in addition to the food safety training required in the first year
of employment.
All Managers For School Year 2015-2016 ONLY: at least 6 hours of annual continuing education/training.
Beginning school year 2016-2017: at least 10 hours of annual continuing education/training.
All Other Staff For School Year 2015-2016 ONLY: at least 4 hours of annual continuing education/training.
Other than the Director Beginning school year 2016-2017: at least 6 hours of annual continuing education/training.
or Manager who works
an average of at least
20 hours per week
Part-Time Staff Each year, at least 4 hours of annual continuing education/training, regardless of the number of
Work <20 hours part-time hours worked.
per week
Note: If hired January 1 or later, an employee must only complete half of the above required training hours.
Training Requirements for All State Agency Directors
State Director of School Nutrition Programs State Director of Distributing Agencies
Each year, at least 15 hours of annual continuing education/training. Each year, at least 15 hours of annual continuing education/
training.
Must PROVIDE, or ensure that State agency staff receives,
annual continuing education/training. Must PROVIDE, or ensure that State food distribution staff
receives, annual continuing education/training.*
Must also PROVIDE a minimum of 18 hours of training to
SFAs each year.*
*Training is an approved use of State Administrative Expenses (SAE) funds and a variety of training formats are allowed.
States may use contractors or partner with other organizations (School Nutrition Association and National Food Service
Management Institute, etc.) to provide training.
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Hiring Standards for New School Nutrition Program Directors
New directors — those hired on or after July 1, 2015 — are subject to the new education requirements below. Existing directors
will be grandfathered in their current positions as well as in the Student Enrollment category where they currently are working.
(School Nutrition Program Directors are the individuals responsible for the operation of school nutriton programs for all schools
under the local educational agency (LEA).)
Minimum Student Enrollment Student Enrollment Student Enrollment
Requirements for
Directors 2,499 or less 2,500-9,999 10,000 or more
Minimum Education Bachelor’s degree, or equivalent Bachelor’s degree, or equivalent Bachelor’s degree, or
Standards educational experience, with educational experience, with equivalent educational
academic major in specific areas;* academic major in specific areas;* experience, with academic
OR OR major in specific areas;*
See the final rule for Bachelor’s degree in any academic Bachelor’s degree in any academic OR
additional preferred major, and State-recognized major, and State-recognized Bachelor’s degree in any
educational standards certificate for school nutrition certificate for school nutrition academic major, and State-
for new directors directors; directors; recognized certificate for
OR OR school nutrition directors;
Bachelor’s degree in any academic Bachelor’s degree in any academic OR
major, and at least 1 year year of major and at least 2 years of Bachelor’s degree in any
relevant school nutrition programs relevant school nutrition programs academic major and at least
experience; experience; 5 years experience in
OR OR management of school
Associate’s degree or equivalent Associate’s degree or equivalent nutrition programs.
educational experience, with educational experience, with
academic major in specific areas,* academic major in specific *
Specific majors/areas of
and at least 1 year of relevant school areas,* and at least 2 years of
nutrition programs experience; relevant school nutrition programs concentration: food and
OR experience. nutrition, food service
High school diploma (or GED) and at management, dietetics,
least 3 years of relevant experience family and consumer
in school nutrition programs. sciences, nutrition
(For an LEA with less than 500 education, culinary arts,
students, the State agency may business, or a related field.
approve a candidate who meets
the educational standards but has
less than the required 3 years
experience.)
Minimum Prior At least 8 hours of food safety training is required either not more than 5 years prior to their starting date or
Training Standards completed within 30 days of the employee’s start date.
Hiring Standards for New State Directors
State Director of School Nutrition Programs State Director of Distributing Agencies
Education Bachelor’s degree with an academic major in areas
including food and nutrition, food service management,
Bachelor’s degree with any major.
dietetics, family and consumer sciences, nutrition
education, culinary arts, business, or a related field.
Knowledge & Experience Extensive relevant knowledge and experience in areas such as institutional food service operations,
management, business, and/or nutrition education.
Skills & Abilities Additional abilities and skills needed to lead, manage, and supervise people to support the mission
of school nutrition programs.
Food and Nutrition Service | FNS-486 | May 2015 USDA is an equal opportunity provider and employer.
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Appendix C
Study Agreement
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