USDA Organizational Chart
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1
FEDERAL CHILD NUTRITION
PROGRAMS
February 2014
SCHOOL PROGRAMS BRANCH
U.S. Department of Agriculture Food and Nutrition Service
Child Nutrition Division
Objectives
2
Provide an overview of the Federal Child Nutrition Programs, their
administration and structure
Clarify what is expected of those operating the Child Nutrition
Programs
Introduce you to new policies currently being implemented under the
Child Nutrition Programs
Answer questions about the operation of the Child Nutrition
Programs
Provide a tutorial on how to access online information resources
3
Structure and Administration of Child
Nutrition Programs
www.fns.usda.gov/cnd
4
Organizational Structure
5
Secretary of Agriculture
Under Secretary for Food,
Nutrition and Consumer Services
Center for Nutrition and Policy
Promotion
Food and Nutrition Service
Regional
Offices
OPS
ROS
SNAP
CGA
MTF
CNP
SNAS
FNS Regional Offices
Mountain Plains
Region
Midwest
Region
Northeast
Region
Western
Region
Mid Atlantic
Region
Southeast
Region
Southwest
Region
6
Administrative Flow
7
FNS Headquarters
Alexandria, VA
FNS Regions - 7
State Agencies - 56
School Food Authorities – nearly 21,000
Schools – more than 100,000
Respective Duties
8
Headquarters
Legislation
Write regulations
Develop national
policy
Regional Offices
Implement regulations
Technical assistance
Program oversight
Management
evaluations
Child Nutrition Programs
9
National School Lunch Program (NSLP)
Afterschool
Snack Service
Seamless Summer Option
School Breakfast Program (SBP)
Special Milk Program for Children (SMP)
Child and Adult Care Food Program (CACFP)
At-Risk
Afterschool Meals
Summer Food Service Program (SFSP)
Fresh Fruit and Vegetable Program (FFVP)
Child Nutrition Programs FY12
10
ADP
NSLP
SBP
SFSP
CACFP
31.6 million
12.9 million
2.3 million
3.5 million
About 100,000 schools in NSLP
About 91,000 schools in SBP
Federal appropriations for NSLP/SBP in FY12 were
over 13.4 billion
Legislative Authority
11
The National School Lunch Act
National School Lunch Program
Fresh Fruit and Vegetable Program
Child and Adult Care Food Program
Summer Food Service Program
The Child Nutrition Act of 1966
School Breakfast Program
Special Milk Program
12
The Regulatory Process
Regulatory Process
13
Proposed Rule
published
for comments, not to be implemented
Evaluate comments
read/consider
Final or Interim Regulation
implemented;
comments
comments taken on Interim Regulation
Notices
announce
routine updates
Your Role in the Regulatory Process
14
In order for the regulatory process to work, we
need your help!
Your comments help FNS write rules
www.regulations.gov
15
The National School Lunch Program
Regulations
7 CFR 210
7 CFR Part 210
16
National School Lunch Program regulations
Title 7 of the Code of Federal Regulations, Part
210
17
18
19
National School Lunch Program Operations
SFA vs. LEA
20
School Food Authority
SFA – School Food
Authority
Governing body
responsible for the
administration of one
or more schools
Has legal authority to
operate a Program
Local Educational Agency
LEA – Local
Educational Agency
Governing body
responsible for
certifying and
verifying F/RP school
meal eligibility
Non-Profit Food Service
21
Observe limitations on:
service revenues
210.14(a)
Competitive foods
210.11(b)
Maintain financial
management system
and account for all
revenue and
expenditures 210.14
food
Money must be used
for the meal program
Profits from
competitive food must
go to food service
account
Meals Priced as a Unit
22
A single reimbursable meal is priced as a unit
charges
for reimbursable meals cannot be assessed
based on individual components
Different prices may be charged depending on the
total cost of producing each meal
Some
entrées are more expensive to purchase and/or
prepare
Point of Service Meal Counts
23
Count the number of
reimbursable meals
served by type at the
point of service or
through another system
approved by the State
Count meals where
you can accurately
determine:
if
the meal meets
component
requirements
the eligibility status of
the child
Meal Service
24
The lunch period:
10:00 a.m. - 2:00 p.m.
Meals must meet
nutrition requirements
Schools must display
signage telling
students what
constitutes a
reimbursable meal
Overt Identification
25
Make no discrimination
against any child
because of his or her
eligibility for F/RP
meals in accordance
with the approved
policy statement
SFA will not overtly
identify students
based upon their
eligibility status
SP-45-2012 clarified
the prohibition on
overt identification
Sanitation and Health
26
Obtain two food safety inspections per year
Report number of inspections to State Agency
Develop food safety program/HACCP
http://www.fns.usda.gov/food-safety/food-safetyresources#Nutrition
Recordkeeping Requirements
27
Upon request, make all accounts and records
pertaining to school food service available to the
State and FNS
Keep records for 3 (+) years
Records must be available for audit or review at a
reasonable time and place
Claims for Reimbursement
28
Monthly unless combined with short months
By benefit category--free, reduced-price, paid
File claims within 60 calendar days or by State’s
due date
Report number of children approved for free or
reduced price meals and the total enrollment on last
operating day of October
Equity in School Lunch
Pricing/Nonprogram Foods Revenue
29
Seeks to ensure that sufficient funds are provided to
the food service account for paid lunches
Must be calculated annually
Paid Lunch Equity Tool updated annually
Non-program Revenue Tool
FNS Policy Memo SP 15-2014 provides guidance,
calculations and flexibilities for SY 2014-15
National Average Payment Factors
30
The average per lunch rates for reimbursement
of free, reduced price and paid meals
Adjusted annually – the rates of reimbursement
change every year
New rates become effective every July 1
6-Cents Performance Based
Reimbursement
31
The HHFKA provides performance-based
reimbursement for SFAs that demonstrate
compliance with the meal patterns for both lunch
and breakfast
Additional 6 cents paid only for lunches claimed
86% of SFAs in the country are certified
The 6-Cents Certification Process in SY
2013-14
32
Certification
during Administrative Review: SP 51-2013
If SFA has not submitted certification materials, State
agency will assess certification during an admin review
SFAs may still submit certification documentation to
State agency
Ongoing compliance with the meal pattern
requirements is monitored during administrative reviews
FNS continues to work with State agencies to ensure
that all SFAs meet certification requirement
6-Cents Cont’d
33
Some aspects of the meal pattern are phased in
over several years
SFAs must demonstrate compliance with those
requirements in effect at time of certification
SFAs must demonstrate compliance with both
breakfast and lunch if SFA offers breakfast
Coordinated Review Effort (CRE)
34
Now defunct---new
Administrative Review
process recently
developed
New Administrative
Review designed to be
streamlined and more
comprehensive
State agency conducts
reviews with
occasional help from
FNS staff
3-year review cycle
began SY2013-14
New Administrative Review Process
35
Extensive guidance and
resources available on FNS
website:
http://www.fns.usda.gov/c
nd/guidance/adminreview.
htm
Also refer to FNS policy
memo SP 12-2013
[email protected]
36
NSLP Meal Pattern Requirements
Updated Meal Requirements
37
The Healthy, Hunger-Free Kids Act of 2010 (HHFKA)
directed USDA to implement the most significant
update of nutrition standards for the school meal
programs in over three decades
Changes were effective:
July 1, 2012 (SY 2012/13) for lunches
July 1, 2013 (SY 2013/14) for breakfasts
Upcoming Targets
38
To ease the transition to the new meal patterns for State agencies and SFAs,
many of the HHFKA’s requirements are phased in over time
For SY 2013-14:
Upcoming targets for SY 2014-15:
Implementation of new breakfast meal pattern
100% of grains to be “whole-grain rich”
First sodium reduction target
Breakfast fruit serving increases to 1 cup per day
Future Targets:
Second sodium target: SY 2017-18
Final sodium target: SY 2022-23
Proposed Rule: Local School Wellness Policy
Implementation under the Healthy, Hunger-Free
Kids Act
The proposed rule would strengthen the requirements for
the local school wellness policies and put more emphasis
on policy implementation, periodic review, and updates.
LWP must permit certain groups to participate in LWP
development, implementation, reviewing and updates:
LWPs must include policies that would permit the
marketing of only those foods and beverages that are
consistent with the Smart Snacks standards.
Local Wellness Policy
40
LWP must consider evidence-based strategies and
techniques addressing:
Nutrition
promotion and education
Physical activity and;
Other school based activities
Community involvement
Local school wellness policy must include nutrition
standards for all other foods available on campus.
41
Smart Snacks in Schools
Healthy, Hunger-Free Kids Act
42
Provided USDA authority to establish nutrition
standards for all foods and beverages sold outside
of the Federal child nutrition programs in schools.
The law specifies that the nutrition standards shall
apply to all foods sold:
outside
the school meal programs;
on the school campus; and
at any time during the school day.
The School Nutrition Environment
43
Improving the nutritional profile of all foods sold in
school is critical to:
•
•
•
improving diet and overall health of American children;
ensuring children from all income levels adopt healthful
eating habits that will enable them to live productive
lives; and
helping children make healthier choices and reduce
their risk of obesity.
Applicability
44
Including:
•
•
•
•
•
a la carte in the cafeteria
in school stores
snack bars
vending machines
other venues
Where do the standards apply?
45
School campus: all areas of the property under
the jurisdiction of the school that are accessible
to students during the school day.
When do the standards apply?
46
School day is the period from the midnight
before, to 30 minutes after the end of the
official school day.
Interim Final Rule
47
Title: Nutrition Standards for All Foods Sold in
School
Published: June 28, 2013
Formal 120-day Comment period: June 28,
2013 to October 28, 2013
Implementation
48
Implementation date: beginning July 1, 2014
Provide feedback to USDA during implementation
49
Free and Reduced Price Meals
Eligibility
50
Two processes for determining:
Household Application
Income
eligibility
Categorical eligibility
Direct certification
Categorical Eligibility
51
Receipt of SNAP, TANF or FDPIR benefits
Eligibility
“Other Source” status such as foster child or
enrolled in Head Start
Individual
extended to all children in household
eligibility
May be determined by application or direct
certification
A Comparison of Application Types
52
Income Application
Last four digits of the
SSN of signing adult
Current income
Frequency of income
Source of the income
Household members,
including child
Signature of adult
household member
Categorical Application
Child’s name
Case number or
indication of status
Signature of adult
household member
Income Eligibility Guidelines (IEGs)
53
Used to determine eligibility for free or reduced
price meals based on the family’s income
FNS makes these calculations based upon the
Federal poverty guidelines
Issued in the Spring each year
Income for Eligibility
54
Children from families whose income equals 130
percent of poverty or less are eligible for free
meals
Children from families whose income is more than
130 but less than 185 percent of poverty are
eligible for reduced price meals
Children from families whose household income is
above 185 percent of poverty pay full price for
their meals
IEGs SY 2014-2015
55
Household
Size
Reduced Price Meals
(185 Percent)
Free Meals
(130 Percent)
Annual
Month
Week
Annual
Month
Week
1
21,590
1,800
416
15,171
1,265
292
2
29,101
2,426
560
20,449
1,705
394
3
36,612
3,051
705
25,727
2,144
495
4
44,123
3,677
849
31,005
2,584
597
5
51,634
4,303
993
36,283
3,024
698
6
59,145
4,929
1,138
41,561
3,464
800
7
66,656
5,555
1,282
46,839
3,904
901
8
74,167
6,161
1,427
52,117
4,344
1,003
For Each
Additional
Person, Add
+7,511
+626
+145
+5,278
+440
+102
Income and Households
56
Income
before
any deductions (such as taxes, Social Security
taxes, insurance premiums, charitable contributions and
bonds)
Household
a
group of related or non-related people living under
one roof as one economic unit
Migrant, Runaway, or Homeless
Children
57
Migrant children in the Migrant Education Program
Runaways in the programs under Runaway and
Homeless Youth Act
Homeless children under the McKinney-Vento Act
Foster Children & Head Start
58
Foster Children
Any child whose care and placement is the responsibility of
the State
Any child who is formally placed by a court with a
caretaker household
Head Start
All children enrolled in Head Start are categorically eligible
Mandatory Direct Certification
59
Requires the LEA to conduct direct certification with
SNAP at least three times per year
All children in the household certified for free meals
if any child or adult in the household receives SNAP
State agency enters into an agreement with their
SNAP agency establishing direct certification
procedures
Discretionary Direct Certification
60
An LEA may certify a child for free meals without
further application by directly communicating with
officials to determine if the child is:
a
TANF family member
homeless
served by certain runaway or homeless youth programs
a migrant
a Head Start enrollee
In foster care
Documentation for Direct Certification
61
SNAP or TANF officials provide documentation to
schools that a child is certified
Name
of child
A certifying statement
Identifiers (e.g., SSN and Date of Birth)
Signature of SNAP/TANF official
Date
Confidentiality
62
Individual children’s eligibility status and
information protected by NSLA
Law allows limited disclosures
Any direct certification system or data exchange
must ensure limited disclosure within statutory
requirements
Eligibility Manual
63
Available on our website
Incorporates all memos and changes regarding
F/RP policies
Updated annually
Recipient of Information
What May be Disclosed
Requirements
Programs under the National School Lunch Act or Child
Nutrition Act
All eligibility information
Prior notice and consent not
required
Federal/State or local means tested nutrition programs with
eligibility standards comparable to the NSLP
Eligibility status only
Prior notice and consent not
required
Federal education programs
Eligibility status only
Prior notice and consent not
required
State education programs administered by a State agency or local Eligibility status only
education agency
Prior notice and consent not
required
Local education programs
Parental consent
NO eligibility information, unless
parental consent is obtained
Medicaid or the State Children’s Health Insurance Programs
All eligibility information unless parents
(SCHIP), administered by a State or local agency authorized
elect not to have information disclosed
under titles XIX or XXI of the Social Security Act to identify and
enroll eligible children
Must give prior notice to
parents and opportunity for
parents to decline to have
their information disclosed
State health programs other than Medicaid/SCHIP, administered Eligibility status only
by a State agency or local education agency
Prior consent not required
Federal health programs other than Medicaid/SCHIP
NO eligibility information, unless
parental consent is obtained
Parental consent
Local health program
NO eligibility information, unless
parental consent is obtained
Parental consent
Comptroller General of the United States for purposes of audit
and examination
All eligibility information
Prior notice and consent not
required
Federal, State, or local law enforcement officials investigating
alleged violations of any of the programs under the NSLA and
CNA or investigating violations of any of the programs that are
authorized
to have access to names and eligibility status
64
All eligibility information
Prior notice and consent not
required
65
The Verification Process
Verification
66
Local responsibility, though the State may conduct
the process
Use number of applications approved as of
October 1 as the pool
LEAs must verify the required number of
applications by November 15 every year
Standard Sample Size
67
3% or 3000, whichever is less, of error prone
applications
Error prone means income within $100 per month
($1200 per year) of the threshold established
through the IEG.
The Verification Process
68
Confirmation Review
Made
by someone other than the person who made the
initial determination to check for errors if no data
system is used in the initial determination
Notifying Household
Request
documentation
Provide contact information
Completing Verification
69
With non-respondents, one follow-up attempt is
required
LEA
should document the follow-up attempt, perhaps on
the application
If benefits reduced or terminated, inform household
in writing and provide appeal rights
Unless appealed, change the child’s eligibility status
within 10 days
Verification Collection Report
70
FNS-742, Verification Collection Report
LEA
submits annually to SA, by March 1
SA consolidates reports and submits to FNS by
April 15
Electronic
submission available
71
Special Provision Options:
Provisions 1, 2, and 3
Community Eligibility Provision
Provision 1: Simplified Applications
72
Free certifications for 2 year period
> 80% enrolled students eligible for free or
reduced-price meals
All other households provided meal application and
allowed to apply for benefits each year
Schools record daily meal counts by eligibility
category as basis for Claims for Reimbursement
Provision 2:
Simplified Counting and Claiming
73
Schools make eligibility determinations and count
meals by type (F/RP/P) in the first year (Base Year)
Use claiming percentages from base year in nonbase years, take total meal counts only.
Schools certify children for F/RP meals for up to 4
school years
All students receive meals at no charge
Provision 2: Base Year
74
September 2012:
80 free meals
15 reduced price meals
+ 5 paid meals
= 100 total meals per day
80/100 = 80% Free
15/100 = 15% Reduced
5/100 = 5% Paid
Provision 2: Non-Base Year Example
75
September 2013
Total meal count for the month: 150
Claim for Reimbursement:
.80 x 150 = 120 free rate
.15 x 150 = 23 reduced price rate
.05 x 150 =
7 paid rate
Provision 3:
Simplified Counting and Claiming
76
Schools follow procedures similar to those under
Provision 2
Schools receive the same level of federal cash and
commodity assistance each year, with some
adjustments, for a 4-year period
Provision 3: Base Year
77
Base Year
Outside
of the 4-year cycle
Offer meals either at no charge, or charge students
eligible for RP/P meals
Make eligibility determinations and count daily meals
by type
Establish base year socioeconomic data
Claim reimbursement from these counts
Provision 3: Non- Base Year
78
Non-Base Years
Offer
all meals at no charge
Count total meals
Claim reimbursement according to Base Year numbers
adjusted for:
Inflation
Change
in enrollment
Change in number of operating days
Extensions
79
Provisions 2 and 3 can be extended for 4-years if
the income level of the school’s population:
Remained
stable
Declined
Had
negligible improvement (5% or less)
7CFR
245.9(c)(1)(ii) and 7CFR245.9(e)(1)(ii)
Community Eligibility Provision (CEP)
80
Section 104 (a) of the Healthy, Hunger Free Kids Act
of 2010.
An alternative to collecting household applications for
free and reduced price meals in high poverty local
educational agencies (LEA) and schools.
Eligible LEAs/schools agree to serve all students free
lunches and breakfasts for 4 successive school years.
LEA Eligibility for CEP
81
LEAs may elect the CEP for the entire district,
individual schools, or a group of schools.
To be eligible; the LEA, individual school, or group of
schools must have an identified student percentage of
at least 40%.
Identified students are those certified for free meals
that are NOT subject to verification. (example:
directly certified through SNAP).
How Does the CEP Work?
82
The identified student percentage multiplied by a
factor of 1.6 equals the percentage of total meals
served reimbursed at the Federal free rate.
The remaining percentage of total meals is
reimbursed at the Federal paid rate.
Any meal costs in excess of the total Federal
reimbursement must be covered through nonFederal sources.
How Does the CEP Work?
83
LEA and schools run direct certification matches no later than
April 1st of each year to obtain current counts of SNAP, TANF,
and FDPIR participants.
Homeless, migrant youth, and foster children lists are matched
no later than April 1st of each year to include in the identified
student percentage.
Each year of the 4-year cycle, LEAs or schools may use the
identified student percentage from the year prior to the first
year or an updated identified student percentage from the
prior year, whichever is higher.
When is the CEP Available?
84
FNS selected three states for SY 2011-12, four
states for SY 2012-13, and four states for SY
2013-14.
LEAs and schools in
SY 2011-12: Illinois, Kentucky, and Michigan
SY2012-13: the District of Columbia, New York,
West Virginia
SY
Ohio, and
2013-14: Florida, Georgia, Maryland, and
Massachusetts
Available nationwide starting in SY 2014-15.
For more information, see CEP webpage
85
The School Breakfast Program
7 CFR Part 220
How to Participate
86
Amend NSLP agreement with State agency
Serve complete breakfasts at the beginning of the
child's school day (in the a.m.)
Count and claim meals by category
Outreach to Households
Breakfast/Lunch Similarities
87
Use the same eligibility determinations
Take point of service meal counts by type
Consolidate and claim reimbursements
Use the same nonprofit account
Severe Need Schools
88
Schools receive higher reimbursement in SBP if at
least 40% of lunches served in the 2nd preceding
year were free or reduced price
Schools without 2nd preceding year history may be
eligible
School Breakfast Expansion
89
Serving breakfast at school helps to ensure that all students have an
opportunity to enjoy a morning meal
5.5% participation growth in previous school year
Alternative serving methods increase access to breakfast
Grab and Go
Breakfast in the Classroom (BIC)
Provision 2/3 SBP Service
Breakfast After 1st Period
Breakfast on the Bus
Initiatives like Let’s Move! and the NFL’s Fuel up to Play 60 complement SBP
expansion
Updated SBP Toolkit
90
A collection of digital resources to assist in the
launch or expansion of the SBP
Toolkit designed primarily for school food service
directors
State agencies use to supplement their materials
Not
intended to replace/duplicate policy or technical
assistance documents
Accessible to stakeholders at all levels
Where is it located?
91
Featured on:
http://www.fns.usda.gov/healthierschoolday
Also accessible through:
http://www.fns.usda.gov/sbp
92
Fresh Fruit and Vegetable Program
FFVP School Selection Criteria
93
Must be an elementary school
Must operate the NSLP
Must submit an application
Must have at least 50% F/RP
Priority
given to schools with the highest % of lowincome students
Total enrollment of all schools must result in a perstudent allocation of $50-$75
Outreach to Low Income Schools
94
SAs must inform elementary schools with the highest
proportion of F/RP enrollment, including Native
American schools, of eligibility for participation in
the FFVP
This
includes the likelihood that they will be chosen to
participate due to high F/RP eligibles
General Program Parameters
95
Addendum to Federal/State agreement
Properly executed State/Local agreements
School applications taken every year
State operates program on monthly reimbursement
basis
Available during the school day in one or more
areas of the school
Provided apart from lunch or breakfast
Widely publicize availability in school
96
Snacks Under the NSLP
Afterschool Snack Service
97
Sponsored or operated by the school district
Located in a district where at least one school
participates in the NSLP
All snacks are served free at area eligible schools
(where 50% or more of students qualify for F/RP
meals)
Free, reduced price, and paid snacks at all other
schools (non-area eligible schools)
Children must be age 18, or under, at start of school
year
Served on regular school days
Afterschool Snack Reimbursement
Claims
98
One afterschool snack per child per day
Meal pattern (2 of 4 items):
Milk
Vegetable
or fruit
Grains/bread
Meat/meat alternate
School must keep records
99
The Child and Adult Care Food Program and
Summer Food Service Program
7 CFR 226
What Does the Child And Care Food
Program (CACFP) Do?
100
Provides reimbursements for:
Nutritious meals to eligible children
12 years and under* in non-residential child care
Afterschool meals and snacks to children 18 and under in
low-income areas
Meals in emergency shelters to residents 18 and under
Meals for eligible adults in
non-residential day care centers
Operates year-round
At-Risk Afterschool Meals
101
Reimbursable supper, or another meal, and snack
Located in low-income areas
All suppers and snacks served free
Children age18, or under, at start of school year
After school, weekends, and holidays
The Summer Food Service Program
(SFSP)
102
Provides reimbursement for nutritious meals and
snacks during the summer months and other
extended school breaks in areas of economic need
Draws children to supervised activities that are safe,
fun, healthy and educational
Fills the nutritional gap for children who rely on free
and reduced price school meals
Schools can be sponsor sites when not in session
SFSP Advantages
103
Receive maximum rates of reimbursement
Pay for any allowable cost, whether operating or
administrative
Plan and budget more reliably
Waive review of experienced school sponsors’
budgets
SFSP vs. Seamless Summer Option (SSO)
How Can Schools Participate in SFSP?
104
Become a SPONSOR: organize meal services for
children at local schools, as well as recreation centers,
playgrounds, parks, and camps
Host a SITE: supervise children’s meals at a local
school
Be a VENDOR: prepare and sell meals to another
sponsor
Seamless Summer Option (SSO)
105
Combines NSLP, SFSP, SBP, but operates much like NSLP
Same recordkeeping/claim/documentation as NSLP/SBP
Receive NSLP/SBP rates
Available to SFAs in any State
Serve all meals free to children
May be used over long breaks in year round schools
Goal is to encourage schools to provide summer meals
106
Team Nutrition Overview and Online
Resources
Team Nutrition (TN)
107
GOAL: To improve children’s lifelong eating and
physical activity habits by using the principles
of the Dietary Guidelines for Americans
OBJECTIVES:
Provide
Foodservice Training and Technical Assistance
Provide Nutrition Education and Promotion Materials
Involve School and Community Partners in Promoting
Healthy Eating and Physical Activity
Why Be a Team Nutrition School?
108
Encourages partnerships between teachers, school
foodservice staff, principals and parents
Receive notification FIRST of new materials
Receive materials given ONLY to TN Schools
It’s easy and free
Team Nutrition Resources
109
Resources for schools
MyPlate
Resources
Eat Smart. Play Hard.TM Resources
Power of Choice
Empowering Youth
Nutrition Essentials
HealthierUS School Challenge
110
Voluntary initiative
Schools must meet specified criteria
Recently
revised to reflect updated meal patterns
Certified for 4 years
Local and National recognition
To date, 6,521 elementary and secondary schools
in 49 States are currently certified as Bronze, Silver,
Gold, or Gold of Distinction awardees
QUESTIONS?
111
Thank You!
112