Name of Agency: Marie Detty Youth and Family Services Date of off-site review: 12-09-16
Reviewer: Matthew Smith Date of on-site review: 01-10-17
Persons interviewed: Rita Colomb and Date of exit conference: 01-10-17
This School Food Authority (SFA) operates the National School Lunch Program, the School Breakfast Program, and the After School Snack Program.
Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted December 9, 2016:
Civil Rights: At the time of the Off-Site portion of this Administrative Review Marie Detty Youth and Family Services (MDYFS) did not have a tool to document the collection ethnicity data for each student as required by FNS Instruction 113-1. MDYFS' intake document did gather data on race. Prior to the On-Site portion of the AR, MDYFS added a question regarding residents' ethnicity to their intake and enrollment paperwork.
No Further action is required regarding the tool for the collection of data of students' ethnicity.
Local Wellness Policy: At the time of the Off-Site review the assessment and update to the local wellness policy had not been completed. Also, your agency did not provide documentation of the last update to the local wellness policy. Your agency's local wellness policy needs to have the following added, 7CFR Part 210.30:
- The agency's local wellness policy does not have a time frame for the when the policy is to be assessed and updated.
When changes to the local wellness policy occur review them with the committee and post the policy changes where you publicly post the policy. Once you review and update your policy, consider the policy updated for this program year. An evaluation of program requirements must occur once during a 3-year cycle and any other time the agency or committee identifies the need for updating. All policy updates need to be documented.
This documentation should include; mention the policy was assessed, state briefly what changes were made, who was present at the committee meeting, and the date of the meeting.
Prior to the On-Site your agency provided the documentation of the update to the local wellness policy. Your agency also provided an updated copy of your local wellness policy which reflects the documentation provided above.
No further action is required regarding the local wellness policy.
Meal Patterns: A review of 11/14/16 through 11/20/16 indicated some insufficient portion sizes at lunch.
The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes; 2 oz. by weight meat/meat alternate daily and 14-17 oz. per week, 2oz. by weight bread/grain daily and 14-17 oz. per week, 1 cup fruit daily and 7 cups per week, 1 cup vegetables daily (dark green subgroup ½ cup/week, red/orange subgroup 1 ¼ cup/week, legumes subgroup ½ cup/per week, starchy subgroup ½ cup/week, and other subgroup ¾ cup/week) 7 cups/week, and 1 cup fluid milk daily, 7 cups weekly, offered as a choice between 1% and fat free.
- On 11/14/16, the apple cup served only credits at ½ cup of fruit.
- On 11/15/16, ½ cup of brown rice was served. A serving of ½ cup of brown rice credits at 1 ounce toward the bread/grain component.
- On 11/18/16, a banana was served to meet the fruit component of the meal. Bananas credit at ½ cup toward the fruit component.
The State Agency (SA) is exercising its discretion to not apply fiscal action for the above insufficient quantities as allowed for under 7 CFR Part 210.18 (g) (2).
It is very important for your staff to carefully review planned menus, product labels and recipes to ensure, the meal pattern requirements are met for every meal claimed for reimbursement. It is critical that your staff document everything that is served as part of a reimbursable meal.
To demonstrate compliance with Meal Patterns:
- Review your menus for compliance with the meal patterns for grades 9-12.
- Bring all insufficient serving sizes and missing components in compliance with the meal patterns for grades 9-12.
- Submit your plan for corrective action to demonstrate understanding and compliance.
Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of October 19 through 23, 2015; your agency did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at lunch and the Afterschool Snack Program, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv). For the lunch the percentage for meeting the whole grain rich requirement was at 81%.
- 11/2/16 and 11/14/16, at lunch the meal was served with garlic bread that was not WGR.
- 11/18/16, at lunch the meal was served with tortillas that were not WGR.
- 11/2/16, 11/9/16, and 11/23/16, the production records for the after school snack documented a cookie was served that was not WGR.
In order for an item to be WGR it must contain 50% whole grains by weight. The easiest way to tell is to look at the ingredients on the label. If the first ingredient is a Whole Wheat Flour or a Whole Grain, you're good. If a Whole Grain product is not listed first, you need to choose a different product that lists the correct grain first. The key is the word Whole.
Note: Findings for the whole grain-rich requirement may result in fiscal action for repeat violations on future reviews.
To demonstrate compliance with Whole Grain Rich Bread/Grain Requirements:
- Evaluate your products to determine if they meet the whole grain rich requirement. Replace any products you determine don't meet the WGR requirement.
- Provide a copy of your corrective action plan to demonstrate understanding and compliance.
Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted January 10, 2017:
Recordkeeping: The review revealed missing production records during the month of review. The following days had missing production records:
- The production record for breakfast on 11/3/16
- The production records for breakfast and lunch for 11/4/16 through 11/8/16
The State Agency (SA) reviewer was able to reconstruct the meals to certify reimbursable meals served during these days. This was done through the SFA's monthly menu and the SFA's cycle menu.
It is the responsibility of all School Food Authorities to ensure that program requirements are followed and that proper documentation exists prior to submission of a claim for reimbursement. 7 CFR Part 210.10 (a) (3), and 7 CFR Part 220.08 (a) (3) require each SFA to keep production records to document the reimbursable meals served. "These records must show how the meals offered contribute to the required food components and food quantities for each age/grade group every day [CFR Part 210.10 (a) (3)]."
All schools must keep accurate records pertaining to the school food service program activities. Accurate records serve as a basis for filing a claim for reimbursement and demonstrate program compliance. Failure to retain documentation that supports claim reimbursement, eligible students, and reimbursable meals can result in the withholding of program funds or fiscal action.
All records, including: meal counts, production records, and other required program documentation must be retained for three years from the day that the SFA's final allowable payment under the contract has been recorded as required by 7 CFR Part 210.23 (c).
To demonstrate compliance with Recordkeeping requirements:
- Create a plan to collect and review all the month's daily records prior to submitting the claim.
- Provide a corrective action plan to demonstrate understanding and compliance.
Reviewer's Comments: Overall the staff members who work with Marie Detty Youth and Family Services (MDYFS) are doing an excellent job. All Administrative Reviews have findings. The school nutrition program at MDYFS did very well during this review. I would like to commend Kerstin Swanson and Rita Colomb for doing an excellent job with MDYFS' school nutrition program. It became apparent to this reviewer MDYFS' school nutrition program's success is largely due to both of these staff members.