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Page 1: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

This document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board, to comply with the requirements for a school wellness policy. [Section 9A(a) of the National School Lunch Act (NSLA), 42 U.S.C. 1758b]

Federal law requires that certain stakeholders be involved in the development, implementation, and periodic review and update of the wellness policy. The District has chosen to use the local school health advisory council (SHAC) to work on behalf of the District to review and consider evidence-based strategies and techniques in order to develop and implement nutrition guidelines and wellness goals as required by federal law. The SHAC will permit the follow-ing persons to work with the SHAC on the District’s wellness policy and plan: parents, students, the District’s food service provider, physical education teachers, school health professionals, Board members, administrators, and members of the public. The SHAC will solicit involvement and input of these other interested persons by:

1. Publishing requests for volunteer membership in Student Handbook

2. Personal invitation to prospective members

Each campus principal is responsible for the implementation of FFA(LOCAL) and this wellness plan at his or her campus, including the submission of necessary information to the SHAC for evalua-tion.

The Superintendent is the District official responsible for the overall implementation of FFA(LOCAL), including the development of this wellness plan and any other appropriate administrative procedures, and ensuring that each campus complies with the policy and plan.

In accordance with law, the District will periodically measure and make available to the public an assessment of the implementation of the District’s wellness policy, the extent to which each campus is compliant with the wellness policy, a description of the progress made in attaining the goals of the wellness policy, and the extent to which the wellness policy compares with any state- or federally designated model wellness policies. Absent federal regulations to the contrary, the District commits to the evaluation activities de-scribed below.

At least annually, the SHAC will prepare a report on the wellness policy and this plan by gathering information from each principal and appropriate District administrators. The SHAC will assess the District’s and each campus’s progress toward meeting the goals of

Adopted 2/20/2017 1 of 16

WELLNESS PLAN STRATEGIES TO SOLICIT INVOLVEMENTIMPLEMENTATIONEVALUATION

Page 2: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

the policy and plan by reviewing Dis-trict- and campus-level activities and events tied to the wellness program.

The SHAC may use any of the following tools for that analysis:

Relevant portions of the WellSAT 2.0 (www.wellsat.org)

Relevant portions of the Center for Disease Control’s School Health Index (http://www.cdc.gov/healthyschools/shi/in-dex.htm.)

A District-developed self-assessment

To comply with the legal requirement to inform and update the pub-lic about the content and implementation of the local wellness pol-icy, the District will create a wellness page on its website to docu-ment information and activity related to the school wellness policy, including:

1. A copy of the wellness policy [FFA(LOCAL)];

2. A copy of this wellness plan, with dated revisions;

3. Notice of any Board revisions to policy FFA(LOCAL);

4. Notice of any SHAC meeting at which the wellness policy or corresponding documents are scheduled to be discussed;

5. The SHAC’s annual report on the District’s wellness policy and plan; and

6. Any other relevant information.

The District will also publish the above information in appropriate District or campus publications.

Records regarding the District’s wellness policy will be retained in accordance with law and the District’s records management pro-gram. Questions may be directed to the Superintendent the Dis-trict’s designated records management officer.

The following provisions describe the District’s nutrition guidelines and activities and objectives chosen by the SHAC to implement the Board-adopted wellness goals in policy FFA(LOCAL).

All District campuses participate in the United States Department of Agriculture’s (USDA’s) child nutrition programs, including the Na-tional School Lunch Program (NSLP) and the School Breakfast Program (SBP). Federal law requires that the District establish nu-trition guidelines for foods made available on each campus that are

Adopted 2/20/2017 2 of 16

PUBLIC NOTIFICATIONRECORDS RETENTIONGUIDELINES AND GOALS

NUTRITION GUIDELINES

Page 3: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

consistent with the federal stan-dards and that promote student health and reduce childhood obe-sity.

The District’s nutrition guidelines are to ensure all foods and bever-ages sold, otherwise made available, or marketed to students dur-ing the school day adhere to all federal regulations and guidance and are designed to promote student health and reduce childhood obesity.

The District will comply with federal requirements for reimbursable meals. For other foods and beverages sold to students during the school day, the District will comply with the federal requirements for competitive foods. Competitive foods and beverages are not part of the regular meal programs and occur through sales such as a la carte options or vending machines. For purposes of this plan, these requirements will be referred to as “Smart Snacks” standards or requirements. The following websites have information regard-ing meal and Smart Snacks requirements:

http://www.fns.usda.gov/school-meals/nutrition-standards- school-meals

http://www.fns.usda.gov/healthierschoolday/tools-schools-fo - cusing-smart-snacks

http://www.squaremeals.org/Publications/Handbooks.aspx

State rules adopted by the Texas Department of Agriculture (TDA) allow an exemption to the Smart Snacks requirements for up to six days per year per campus when a food or beverage is sold as part of a District fundraiser. [See CO(LEGAL)]

The District will not allow exempted fundraisers; all fundraisers will include non-food items, foods that meet the Smart Snacks stan-dards, or foods that are not intended to be consumed at school.

There are currently no federal requirements for foods or beverages made available to students during the school day. The District will comply with state law, which allows a parent or grandparent to pro-vide a food product of his or her choice to classmates of the per-son’s child or grandchild on the occasion of the student’s birthday or to children at a school-designated function. [See CO(LEGAL)]

The District will measure compliance with the nutrition guidelines by reviewing meal reimbursement submissions from the child nutri-tion department to the TDA, reviewing foods and beverages that are sold in competition with the regular school meals, reviewing

Adopted 2/20/2017 3 of 16

FOODS SOLDEXCEPTION—FUNDRAISERSFOODS MADE AVAILABLEMEASURING COMPLIANCE

Page 4: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

items sold as part of approved District fundraisers, and monitoring the types of foods and beverages made available to students dur-ing the school day.

Federal law requires that the District establish goals for nutrition promotion in its wellness policy. The District’s nutrition promotion activities will encourage participation in the National School Lunch Program, the School Breakfast Program, and any supplemental food and nutrition programs offered by the District.

In accordance with FFA(LOCAL), the District has established the following goal(s) for nutrition promotion.

GOAL: The District’s food service staff, teachers, and other District personnel shall con-sistently promote healthy nutrition messages in cafeterias, classrooms, and other appropri-ate settings.

Objective 1: District participation in federal child nutrition program will increase by 2% by the end of each school year.

Action Steps Methods for Measuring Implementation

Information about the school food service program will be distributed in back-to-school packets at the Back to School night and sent home with students who did not attend the event. Parents will be contacted by the school secretary if no response is received.

Baseline or benchmark data points: Analysis/comparison of participation

rates in nutrition program at beginning, middle, and end of year.

Resources needed: Staff Preparation of information packets Time to contact parents who don’t re-

turn applicationsObstacles: Parent attitude about participation Successfully getting information home Negative attitudes about school meals

Objective 2: By May of each school year, the food service program will score at least a “bronze” level on the Smarter Lunchroom Scorecard (www.smarterlunch-room-self-assessment-score-card).

Action Steps Methods for Measuring Implementation

Distribute scorecard to all food service em-ployees, at least 6 parents, 3 teachers, and 5 students to score in October and May.

Baseline or benchmark data points: Scores on the assessment in October

and May.

Adopted 2/20/2017 4 of 16

NUTRITION PROMOTION

Page 5: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Resources needed: Office staff or principal to print off and

distribute scorecard to stakeholders. Stakeholders to complete scorecard Paper and copierObstacles: Training provided for scorecard Time for scorecard completion and

analysis

GOAL: The District shall share educational nutrition information with families and the gen-eral public to promote healthy nutrition choices and positively influence the health of stu-dents.

Objective 1: District will distribute quarterly “Parental Involvement Connection” from ESC 16 to parents and post on district website which contains information on physical activity and the importance of eating healthy.

Action Steps Methods for Measuring Implementation

Quarterly editions of the Parental Involve-ment Connection are printed and distributed to parents and made available on the school website when published by ESC 16 each quarter.

Baseline or benchmark data points: Confirmation of publication made avail-

able each quarterResources needed: Paper, copier Time for printing and distribution PersonnelObstacles: Time for printing and distribution Parental buy-in of value of information

provided in the publication

Objective 2: Consistently publish monthly breakfast and lunch menus and post them on District website.

Action Steps Methods for Measuring Implementation

Monthly lunch and breakfast menus will be printed and sent home with all PK-7 stu-dents (PK-3 will be sent home in student folders) and made available on entry tables in Elementary building and High School building as well as on District website.

Baseline or benchmark data points: Verification of menus distributed, avail-

able in entries, and on district website.Resources needed: Food service manager to compile

Adopted 2/20/2017 5 of 16

Page 6: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

monthly menus meeting nutrition guidelines.

Personnel to make copies of menus for distribution

Personnel to post menus on District Website

Obstacles: Time to print and post menus 4th-12th grade students getting home

with menus

GOAL: The District shall ensure that food and beverage advertisements accessible to stu-dents during the school day depict only products that meet the federal guidelines for meals and competitive foods.

Objective 1: Food advertisements will not be posted outside the cafeteria and 100% of those posted within the cafeteria will promote healthy eating habits.

Action Steps Methods for Measuring Implementation

Elementary and High School administrators will be responsible for monitoring any and all advertisements to assure that no food advertisements are posted throughout cam-pus buildings.

Baseline or benchmark data points: Campus administrators will verify non-

existence of food advertisements within their buildings in August and May each year.

Resources needed: Administrators and time.Obstacles: Administrators remembering to do the

checks

Federal law requires that the District establish goals for nutrition education in its wellness policy. State law also requires that the District implement a coordinated health program with a nutrition services and health education component at the elementary and middle school levels. [See EHAA]

The District will implement the nutrition services and health educa-tion component through instruction of the essential knowledge and skills related to nutrition and health and the CATCH program, a program approved by the Texas Education Agency, in the District’s physical education, health education, and science courses.

Adopted 2/20/2017 6 of 16

NUTRITION EDUCATION

Page 7: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

In accordance with FFA(LOCAL), the District has established the following goal(s) for nutrition education.

GOAL: The District shall deliver nutrition education that fosters the adoption and mainte-nance of healthy eating behaviors.

Objective 1: Health will be encouraged as a default elective for high school stu-dents.

Action Steps Methods for Measuring Implementation

Inform counselor and high school adminis-trator to promote Health as an elective.

Baseline or benchmark data points: Percentage of four-year cohort who

successfully complete health as an elective.

Resources needed: Access to TxVSN or Odyssey to pro-

vide the Health course Graduation plansObstacles: Student attitude/interest in taking a

health course

Objective 2: Students in grades 6-8 will take one semester of health prior to enter-ing high school.

Action Steps Methods for Measuring Implementation

Administrator assignment of health class to qualified 6-8 teacher for one semester

Baseline or benchmark data points: Documentation of 6-8 students en-

rolled and successfully completing health course

Resources needed: Teacher Class resources—textbooks, internet

access…Obstacles: Student interest in course

Adopted 2/20/2017 7 of 16

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Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

GOAL: The District shall make nutrition education a District-wide priority and shall inte-grate nutrition education into other areas of the curriculum, as appropriate.

Objective 1: Health and wellness will be included as frequently as possible at all grade levels in as many subject areas as feasible throughout the school year.

Action Steps Methods for Measuring Implementation

All self-contained elementary teachers will include health and wellness topics at least twice yearly.

Health will be taught for a minimum of one semester to students during the 6, 7, or 8th grade years.

At least one Consumer Science course each year will include health and wellness within its curriculum.

Baseline or benchmark data points: Inclusion of health and wellness topics

documented in lesson plans. Master schedule reflecting one semes-

ter of health taught in 6-8th each school year.

Consumer Science lesson plans reflect health and wellness topics included in curriculum.

Resources needed: Health and wellness instructional ma-

terials Teachers to deliver instructionObstacles: Time is limited to include additional

topics in subject areas due the re-straints resulting from the state as-sessment demands

Objective 2: All students will have access to drinking water at all times throughout the school day.

Action Steps Methods for Measuring Implementation

Back-to-School enrollment packets will in-clude NOTICE that students are allowed to have a personally owned water bottle at all times.

Water is always available to students during breakfast and lunch at no cost.

Baseline or benchmark data points: Confirmation of information included in

packets Documentation from Food Service

Manager that water is/was available as required by federal standards and stu-dents were informed about water bottle policy

Resources needed: Water provided in cafeteria Accessible water fountains Provide water bottles for students who

Adopted 2/20/2017 8 of 16

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Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

do not have oneObstacles: None

GOAL: The District shall provide professional development so that teachers and other staff responsible for the nutrition education program are adequately prepared to effectively deliver the program.

Objective 1: Food Service personnel, physical education teachers, coaches, and classroom teachers will be encouraged and in some positions, required, to acquire professional development which will adequately prepare them for effective delivery of the nutrition education program.

Action Steps Methods for Measuring Implementation

Food Service manager and food service as-sistant will attend required professional de-velopment provided by ESC 12.

Baseline or benchmark data points: Registration in required professional

development opportunities Certificates on fileResources needed: Professional development budgetedObstacles: Time and willingness of employees to

attend professional development

Objective 2: Provide information about professional development related to nutri-tion and wellness available to all employees

Action Steps Methods for Measuring Implementation

Development of professional development plan which includes nutrition and wellness opportunities.

Baseline or benchmark data points: At least twice yearly, administrators will

disseminate professional development information to employees as docu-mented in emails or by filed certificates of completion by employees.

Resources needed: Administrators Computers TimeObstacles: Time for administrators to research

Adopted 2/20/2017 9 of 16

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Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

professional opportunities available and to disseminate.

The District will implement, in accordance with law, a coordinated health program with physical education and physical activity com-ponents and will offer at least the required amount of physical ac-tivity for all grades. [See BDF, EHAA, EHAB, and EHAC]

Federal law requires that the District establish goals for physical activity in its wellness policy.

In accordance with FFA(LOCAL), the District has established the following goal(s) for physical activity.

GOAL: The District shall provide an environment that fosters safe, enjoyable, and devel-opmentally appropriate fitness activities for all students, including those who are not partici-pating in physical education classes or competitive sports.

Objective 1: All PK-3 teachers will provide at least one recess period during the day outside if weather permits.

Action Steps Methods for Measuring Implementation

Elementary principal will review class schedules to insure that students are receiv-ing at least one recess during the day in grades PK-3

Baseline or benchmark data points: Teachers’ class schedules reflect re-

cess scheduled Principal observation confirm existence

of recessResources needed: Class schedules Principal TimeObstacles: Time

Objective 2: Physical Education Classes will be offered for a minimum of 45 min-utes each day for all students PK-12 throughout each school year.

Action Steps Methods for Measuring Implementation

Development of master schedule reflecting excess minutes of Physical Education classes at all grade levels PK-12 taught by qualified instructors.

Baseline or benchmark data points: Master schedule developed prior to be-

ginning of school year with

Adopted 2/20/2017 10 of 16

PHYSICAL ACTIVITY

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Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Resources needed: Administrators to develop master

schedule. Time for schedule development Qualified PE instructorsObstacles: None

GOAL: The District shall provide appropriate staff development and encourage teachers to integrate physical activity into the academic curriculum where appropriate.

Objective 1: After receiving appropriate staff development, at least 50% of teachers’ daily class schedules will reflect physical activity breaks are regularly incorporated into their lessons not including PE class.

Action Steps Methods for Measuring Implementation

Identify and provide appropriate staff devel-opment related to incorporation of physical activity breaks into daily schedules.

Baseline or benchmark data points: Daily class schedules and lesson plans

on file which reflect time for physical activity breaks

Resources needed: Time for planning Time for activity breaksObstacles: Scheduling time to break away from

teaching to allow time for physical ac-tivity

GOAL: The District shall make appropriate before-school and after-school physical activity programs available and shall encourage students to participate.

Objective 1: At least once a year, the district will offer a after school physical activ-ity open to the community, students, and faculty at no cost.

Action Steps Methods for Measuring Implementation

District administrators will offer a physical activity, normally in the spring semester in the school gym open to all interested partici-pants. (Example: Zumba or step aerobics)

Baseline or benchmark data points: Spring advertisements posted and visi-

ble at school and in the community. Designated administrator will docu-

ment number and type of participants

Adopted 2/20/2017 11 of 16

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STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Resources needed: Personnel to conduct the activity Administrator to oversee implementa-

tion Participants Time Facility and materialsObstacles: Time, willing personnel, and attendees

GOAL: The District shall make appropriate training and other activities available to District employees in order to promote enjoyable, life-long physical activity for District employees and students.

Objective 1: The District will offer a free or low-cost health assessment to employ-ees at least once per year.

Action Steps Methods for Measuring Implementation

Research possible providers for such a ser-vice on behalf of the District.

Contract with the entity to provide the ser-vices.

Baseline or benchmark data points: Documentation of participation will be

kept on file in main office. Resources needed: Service Provider Production of publications to advertise

the serviceObstacles: Participation Locating a service provider

GOAL: The District shall encourage parents to support their children’s participation, to be active role models, and to include physical activity in family events.

Objective 1: Parents and students will be encouraged to participate in the annual spring physical activity provided by the District after school in the gymnasium.

Action Steps Methods for Measuring Implementation

Plan and publicize annual spring physical activity provided for all stakeholders during after school hours.

Baseline or benchmark data points: Documentation of participants kept on

file in main office.

Adopted 2/20/2017 12 of 16

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Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Selection of administrator to oversee imple-mentation and planning of activity.

Resources needed: Administrator to oversee Publications to advertise activity Time Facility Personnel to conduct activityObstacles: Time for conducting Availability of willing students and par-

ents to participate

GOAL: The District shall encourage students, parents, staff, and community members to use local recreational facilities, such as tracks, playgrounds, and the like, that are available for use outside of the school day.

Objective 1: District will plan at least one outdoor activity during the year at the City Park to encourage interest in use of the playground, baseball park, and walking trail available to all stakeholders in the District.

Action Steps Methods for Measuring Implementation

Plan annual activity at the City Park.

Assign administrators to implement and over see activity.

Baseline or benchmark data points: By the end of each school year, one

outside activity will have been planned and held at the City Park for students, parents, staff and community to attend and enjoy.

Resources needed: Time for planning and conducting ac-

tivity. Materials to develop and publish ad-

vertisement of activity. Personnel to conduct activityObstacles: Lack of interest in physical activity

Federal law requires that the District establish goals for other school-based activities in its wellness policy to promote student wellness.

Adopted 2/20/2017 13 of 16

SCHOOL-BASED ACTIVITIES

Page 14: Wellness Plan Template · Web viewThis document, referred to as the “wellness plan”(the plan), is intended to implement policy FFA(LOCAL), which has been adopted by the Board,

Wellness Plan

STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

In accordance with FFA(LOCAL), the District has established the following goal(s) as part of its student wellness policy to create an environment conducive to healthful eating and physical activity and to promote and express a consistent wellness message.

GOAL: The District shall allow sufficient time for students to eat meals in cafeteria facili-ties that are clean, safe, and comfortable.

Objective 1: All students PK-12 will have at least 10 minutes to eat breakfast and 20 minutes to eat lunch after receiving a tray and being seated.

Action Steps Methods for Measuring Implementation

Create master schedule which allows suffi-cient time for consumption of meals.

Administrators will work collaboratively on the schedules to make any adjustments needed to allow sufficient time for meals.

Baseline or benchmark data points: Evaluation of master schedule at the

beginning of the school year to con-firm that students have sufficient meal time.

Resources needed: Administrators Time to develop, evaluate, and adjust

master schedulesObstacles: Balancing all the lunch schedules

within the master schedule

GOAL: The District shall promote wellness for students and their families at suitable Dis-trict and campus activities.

Objective 1: At school sponsored athletic events, the concession stand will provide at least one food and one beverage that meets the Smart Snack standards.

Action Steps Methods for Measuring Implementation

Communicate this objective to appropriate organizations and booster clubs responsible for concession sales in the District.

Baseline or benchmark data points: District Food Service Manager will

monitor concession stands for inclu-sion of qualified items at events throughout the year.

Resources needed: Time for meeting with concession

stand purchasers to insure compliance

Adopted 2/20/2017 14 of 16

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STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Obstacles: Willing attitudes of organizations to

comply with Smart Snack Standards

Objective 2: All classroom or campus celebrations will include at least one item that is Smart Snacks compliant.

Action Steps Methods for Measuring Implementation

Create and distribute to parents and teach-ers a list of Smart Snack compliant foods and beverages for class or campus celebra-tions throughout the year.

Keep this same list available in the entries of each campus building.

Baseline or benchmark data points: Distribution of the list in Back-to-

School packets to families and to fac-ulty in orientation meetings at the be-ginning of school year.

Teachers self-report compliance in classroom celebrations.

Resources needed: Time and materials to develop and

produce the Smart Snack list for distri-bution

Personnel to create and publish the list.

Obstacles: Willingness and positive attitude to

comply with this objective by parents and faculty.

GOAL: The District shall promote employee wellness activities and involvement at suit-able District and campus activities.

Objective 1: All employees will be encouraged to participate in the spring physical activity sponsored after school in the school gym.

Action Steps Methods for Measuring Implementation

In the Spring semester each year, the Dis-trict will offer to all stakeholders a physical activity after school in the school gym. (ex. Zumba, Step aerobics…)

Baseline or benchmark data points: Documentation kept on file in school

office of participation in the physical activity.

Administrator will identify/assign appro-priate personnel to conduct the activity

Resources needed: Personnel to conduct activity

Adopted 2/20/2017 15 of 16

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STUDENT WELFARE FFAWELLNESS AND HEALTH SERVICES (REGULATION)

Development, publication, and distribu-tion of advertisements for the activity

Obstacles: Lack of interested attendees possible

after school

Objective 2: The District will utilize its health insurance provider to encourage well-ness by communicating the preventive services covered at 100 percent during each enrollment period

Action Steps Methods for Measuring Implementation

Work with District health insurance provider to determine what services are covered at 100 percent. Develop materials and identify methods to share information about services with em-ployees.

Baseline or benchmark data points: Documentation of when and how infor-

mation was shared with employees. General reports from health insurance

provider showing use of services.Resources needed: A list of preventive services covered at

100 percentObstacles: Coverage is subject to change Participation rates may be minimal

Adopted 2/20/2017 16 of 16