Attendance Factor and Required Edit Checks

This Management Bulletin (MB) supersedes MB USDA-SNP-19-2011 and reaffirms that the USDA has not changed the average daily Attendance Factor for National School Lunch Program (NSLP) sponsors since the 2011–12 school year.

Background

The USDA requires NSLP sponsors to perform daily meal count edit checks by multiplying an annual attendance factor (i.e., percentage) by the number of children enrolled in school prior to filing a monthly claim for reimbursement.

Title 7, Code of Federal Regulations (7 CFR), Section 210.2 defines the attendance factor as “a percentage developed no less than once each school year which accounts for the difference between enrollment and attendance” (i.e., the average percentage of enrolled students typically attending school on any given day).

In addition, 7 CFR, Section 210.8(a)(3) requires NSLP sponsors to perform daily meal count edit checks by multiplying the number of enrolled children approved in each meal eligibility category (free, reduced-price, and paid) by the annual attendance factor. The results, referred to as attendance-adjusted eligible figures, are to be documented by comparing the daily counts of free, reduced-price, and paid lunches served. Recorded daily meal counts should not exceed the attendance-adjusted eligible figures in any meal eligibility category on any school day without a simple written justification to explain the overage (e.g., popular menu item, special promotion, visiting students, etc.).

In addition, school meal counts reported on a monthly reimbursement claim must not exceed the number of children approved in any meal eligibility category when multiplied by the number of operating days within the month.

Attendance Factor

The USDA is continuing to use an attendance factor of 93.8 percent. Therefore, NSLP sponsors must use the 93.8 percent attendance factor for each of their site’s daily meal count edits or develop their own attendance factors using data that applies district or agency-wide, or to individual sites, prior to the submission of their monthly reimbursement claims.

In order to develop your district/agency’s actual attendance factor, you will need to determine your student population rate of attendance each month or each year by site or agency-wide. To do this, calculate the percentage of average attendance by dividing the average number of students who attended school each month or each year by the average number of students enrolled in school each month or each year (but do not include excused absences in the average attendance figure). This process will give you an actual attendance factor by month or by year. Keep records to demonstrate how you calculated your average attendance factor.

All schools on Provision 2 or the Community Eligibility Provision (CEP) must also complete daily meal count edit checks. School food authorities (SFA) must compare each school’s total daily meal counts to the school’s total enrollment, multiplied by the attendance factor or have a system in place for oversight.

Residential Child Care Institutions

Please note that residential child care institutions (RCCI) must also complete daily meal count edit checks. Daily meal counts cannot exceed the number of residents enrolled each day. The attendance factor for RCCIs without day students is 100 percent. RCCIs with day students must use the current national attendance factor of 93.8 percent (or their own actual site or agency-wide attendance factor).

Sample Meal Count Edit Checks

Sample meal count edit check worksheets for traditional or year round school sites, schools on Provision 2 or CEP, and RCCIs are available for download at the California Department of Education (CDE) School Nutrition Meal Count Forms web page at http://www.cde.ca.gov/ls/nu/sn/mealcount.asp.

While the use of these sample worksheets is optional, documentation of your edit checks is required. All edit check forms must incorporate the data requested on the sample worksheets posted on the web page.

Below is a list of available meal counting and edit check worksheets.

For traditional or year-round school sites operating standard counting and claiming:

• The Meal Count Worksheet assists schools in computing daily meal count edit checks.
  
  
• The Meal Count Worksheet for School with Tracks assists schools with multiple tracks in computing daily meal count edit checks.
  
  
• The Meal Count Edit Check – Monthly Worksheet assists schools in computing monthly meal count edit checks.

For schools participating in CEP or Provision 2 in a non-base year:

The CEP and Provision 2 Meal Count Edit Check Worksheet should be used. This form is located in the Child Nutrition Information and Payment System (CNIPS), Download Forms (Form ID SNP-17b Provisions).

For RCCIs:

• The Meal Count Sheet assists RCCIs in computing daily meal count edit checks when all clients are on the same school calendar.
  
  
• The Site Daily Meal Count and Meal Count Edit Worksheet assists RCCIs in computing daily meal count edit checks when clients are on different school calendars.
  
  
• The Daily Meal Count Sheet assists RCCIs in computing monthly meal count edit checks and recording changes to client enrollment.

Compliance

As part of the NSLP Administrative Review, the CDE will verify that SFAs are conducting edit checks and applying the correct attendance factor percentage when doing so.

Contact Information

If you have any questions regarding this subject, please contact your School Nutrition Program (SNP) Specialist. A list of SNP Specialists is available in the Download Forms section of the CNIPS, Form ID Caseload. You can also contact the SNP Unit by email at SNPInfo@cde.ca.gov to be directed to your SNP Specialist.