Minimum Requirements for School Food Authorities (SFAs)
Each SFA is legally responsible for the conduct of the school food service program to ensure
compliance with the rules and regulations of the CDE Office of School Nutrition (OSN) and the USDA.
The following summarizes many of the responsibilities of the SFA in order to participate in the USDA
School Nutrition Programs.
1. Control and overall financial responsibility of the non-profit school food service account.
a. Use Child Nutrition Program (CNP) funds only for CNP purposes. CNP funds may
not be used to purchase land or construct buildings.
b. Maintain a financial management system as prescribed by CDE OSN and in
accordance with federal requirements
c. Maintain full and accurate records of operations and retain such records for a period
of four years plus the current (or until audit resolution). Records of revenue and
expenditures must be maintained in such a manner as to reflect the nonprofit status
of the food service.
d. Limit the current operating resources of the nonprofit school food service to an
amount that does not exceed limits established by 1CCR 301-3 and 7 CFR Part 210.
(Net cash resources should not exceed 3 months’ average expenditures.)
e. Conduct an independent audit of the program operations as outlined on OMB circular
A-133 and in accordance with the Single Audit Act of 1984 (P.L. 98-502) and the
Single Audit Act Amendments of 1996 (P.L. 104-156) and ensure that CDE is sent a
copy of the audit.
2. Signature authority and accountability on
a. Application/agreement to participate in the Child Nutrition Programs including
i. Free and reduced price policy statement.
ii. On-line claim system.
iii. Resolution of all program review and audit findings.
3. Monthly claim for reimbursement
a. Count the number of free, reduced price, and paid meals served to eligible children
at the point of service as approved by the CDE OSN.
b. Review to ensure accuracy of meal counts prior to the claim submission.
c. Edit check worksheets that compare daily lunch counts by eligibility category. Free
and reduced-price meals may not be claimed in excess of the number of students
approved for such benefits.
d. Submit claims for reimbursement in accordance with procedures established by the
CDE/CNP. Claims for reimbursement not filed within 60 calendar days following the
claiming month shall be disallowed. The SFA acknowledges that if failure to submit
accurate claims reflects embezzlement, willful misapplication of funds, theft, or
fraudulent activity, penalties shall apply.
4. Free and Reduced price meal process
a. Develop, distribute, and collect the parent letter and application for free and reduced
price meals and free milk.
b. Determine and verify applications for free/reduced price meals. Conduct any
hearings related to such determinations.
c. Maintain files of correctly approved and denied free and reduced price applications.
Retain records for 4 years plus the current (or until audit resolution).
d. Comply with the requirements regarding confidentiality, specifically limitations and
prohibitions regarding the release of student names for non-program purposes.
e. All children who are determined eligible for free or reduced priced meals:
i. Receive meals without charge or at a reduced price.
ii. There is no discrimination against any child eligible for free or reduced price
meals.
f.
SFAs will not overtly identify students based upon their eligibility status.
g. Complete direct certification at least three times per school year.
5. Menus and food service
a. Serve meals or milk that comply with USDA nutrient standards and requirements.
b. Follow the CO Healthy Beverage Rules – beverages sold to students on school
grounds during regular/extended school day must meet nutritional standards.
c. Maintain adequate and safe facilities for handling, storing, preparing, and serving
food.
d. The lunch period must be between 10:00 a.m. – 2:00 p.m.
6. Food safety / HACCP plan
a. Develop a written food safety plan following USDA guidance.
b. Maintain required health certification to assure that all state and local regulations are
met by the food service operation preparing or serving meals at the SFA facilities.
c. Post most recent health inspection in a visible location for the public.
7. Establish all prices
a. Submit all prices for food items served under the nonprofit school food service
account (e.g., reimbursable meals, a la carte service, and adult meals).
b. Price the lunch as a unit. A single reimbursable meal has only one price, thus
charges for reimbursable meals cannot be assessed based upon individual
components.
8. Competitive food policy
Establish rules to control the sale of foods in competition with meals served under the
program so as to meet the requirements of Colorado State Board Rules and USDA.
9. USDA donated foods (Commodities)
Accept and use in as large quantities as can be efficiently utilized the foods offered as a
donation by the USDA (commodities).
10. Civil Rights
a. The SFA agrees that no person shall, on the grounds of race, color, national origin,
age, sex, or disability, be excluded from participation in, be denied benefits of, or
otherwise be subjected to discrimination under any program or activity for which the
SFA receives federal financial assistance.
b. Display the “And Justice For All” Poster in a location visible to the students and the
public.
c. Ensure that all forms of communication and printed program information include the
following elements:
i. The statement that program benefits and services are available to all children
without regard to race, color, sex, disability, age or national origin, and
ii. The procedure for filing a complaint.
d. Inform parents or guardians of students in schools participating in school nutrition
programs, as well as local minority and grassroots organizations, of the availability of
program benefits and services, the nondiscrimination policy and all significant
changes in existing requirements that pertain to program eligibility and benefits.
11. Wellness Policy
Establish and implement a Local Wellness Policy.
12. Procurement
Comply with the requirements of the CDE OSN and USDA regulations regarding all CNP
procurement (7CFR Part 3016).
13. On-site inspections: (For multi-site and/or SFAs with Food Service Management Co.)
a. Monitor the food service operation in all sites through periodic visits to ensure
compliance with Program regulations.
b. Conduct on-site reviews of the lunch counting/claiming system by school.
c. Follow-up on any lunch counts which show counting discrepancies.