Name of Agency: St John Christian Heritage Academy Date of off-site review: 01-12-17
Reviewer: Matthew Smith Date of on-site review: 02-21-17
Persons interviewed: Orlene Grant-Chaney and Date of exit conference: 12-15-15
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 January 12, 2017:
Civil Rights: The School Food Authority (SFA) did not have a policy for handling civil rights complaints, FNS Instruction 113-1. Prior to the On-Site portion of this Administrative Review (AR) the SFA, provided a copy to the State Agency (SA) of their policy for handling civil rights complaints.
No further action is required regarding the policy for handling civil rights complaints.
Local Wellness Policy: At the time of the Off-Site review documentation of the assessment and update to the local wellness policy was not provided. This is required under 7 CFR Part 210.30 (E) (2). Also, your local wellness policy needs to have the following added:
- The name and title of the person(s) designated to assess the SFA's local wellness policy and to ensure the policy's implementation. It is recommended no more than two people assess the policy. This is required to meet the requirements under 7 CFR Part 210.30 (c) (4) and 7 CFR Part 210.30 (e) (1).
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. This documentation should be posted publicly with the local wellness policy.
To demonstrate compliance with the local wellness policy:
- Add the name of the person designated to assess the local wellness policy and to ensure the policy is implemented.
- Provide a copy of the documentation of the most recent assessment and update to the SFA's local wellness policy.
- Provide a copy of the updated local wellness policy with the required changes listed above.
- Provide the above requested documentation along your plan for corrective action to demonstrate compliance and understanding.
Procurement: At the time of the Off-Site portion of this AR the SFA did not have a procurement policy that meets program requirements. The SFA's procurement plan lists the small purchase threshold at $150. The SFA informed the SA reviewer that this was a typo and should have been $150,000. This will need to be corrected and a new copy provided to the SA.
Each SFA must have a written procurement plan on file, 7 CFR Part 210.21(c) and 7 CFR Part 220.16 (c). The plan must specify procurements procedures used by the SFA. All procedures must adhere to the federal requirements for procurement. The procurement plan identifies the agency's purchasing periods for the goods, equipment, and services related to the School Nutrition Programs and the various methods procurement being practiced.
The procurement plan provides an explanation for using certain procurement methods to obtain items used in the school food service program. Agencies can determine the extent of the plan. A new procurement plan does not need to be developed every year.
The procurement plan must include steps the SFA takes to assure that small, minority and women's businesses enterprises, and labor surplus firms when possible as required under 2 CFR Part 200.321. The procurement plan that was provided to the SA during the On-Site portion of the AR did not address this requirement. Also the procurement plan did not address the SFA performing a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold (the US government sets this at $150,000) including contract modifications [2 CFR Part 200.323 (a)].
To demonstrate compliance with the procurement requirements:
- Provide a copy of your agency's updated procurement plan to include the above correction and the above required areas.
- Provide the above along with your corrective action plan demonstrate understanding and compliance.
Year-end income and expense review: The SFA did not properly document the management of the school food service funds. Staff did not conduct a year-end (school year) review of total revenues and expenses to document and verify the school food service account's nonprofit status as required by 7 CFR Part 210.14 (a), 7 CFR Part 210.14 (b), and 7 CFR Part 210.19 (a) (1). This review allows the SFA to ensure costs incurred to the account are necessary, reasonable, and allowable. This caused the SA reviewer to conduct a comprehensive resource management review.
Prior to the On-Site portion of this AR, the SFA completed a review of the school's revenue and expenses for the previous year. The revenue and expense documentation you provided indicated cash resources did not exceed three months' average operating costs [7 CFR Part 210.14 (b)]. The year-end report indicated the SFA had an excess of $6,764.13. The SFA's three months average operating expenses is $21,799.12.
To demonstrate compliance with year-end income and expense review of the School Food Service Account requirement:
- Provide a plan for the annual review of account and the proper maintenance of cash balances to demonstrate understanding and compliance.
Meal Patterns: A review of 12/05/16 through 12/09/16 indicated some insufficient portion sizes at breakfast and lunch.
The breakfast meal pattern 7 CFR Part 220.8 (c) requires the following minimum serving sizes; 1oz. by weight bread/grain daily and 7-10 oz. per week, 1 cup Fruit and 5 cups weekly, and 1 cup fluid milk and 5 cups weekly, offered as a choice between 1% and fat free. No more than 50% of the fruit components for a menu week can be met with 100% fruit juice.
- 12/05/16 each meal was served with a banana. The USDA Food Buying Guide credits bananas at ½ cup for each banana served.
- The weekly fruit serving size was not met as a result of the above insufficient fruit serving size.
- The above insufficient serving sizes were determined to be non-systemic.
The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes; 1 oz. by weight meat/meat alternate daily and 8-10 oz. per week, 1 oz. by weight bread/grain daily and 8-9 oz. per week, ½ cup fruit daily and 2 ½ cups per week, ¾ of a cup of vegetables daily (dark green subgroup ½ cup/week, red/orange subgroup ¾ cup/week, legumes subgroup ½ cup/per week, starchy subgroup ½ cup/week, and other subgroup ½ cup/week) 3 ¾ cups/week, and 1 cup fluid milk daily, 5 cups weekly, offered as a choice between 1% and fat free.
- 12/06/16 each meal was served with one package of Whole Grain-Rich (WGR) crackers that only credits at 0.50 oz.
- 12/09/16 each meal was served with a grilled cheese that only credits at 0.50 oz. towards the meat/meat alternative component.
- The weekly meat/meat alternative was not met due to the insufficient meat/meat alternative serving size. During the week only 7.50 oz. was served toward the weekly meat/meat alternative weekly serving size.
- The above insufficient serving sizes were determined to be non-systemic.
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 K-5.
- Bring all insufficient serving sizes and missing components in compliance with the meal patterns for grades K-5.
- Submit your plan for corrective action to demonstrate understanding and compliance.
Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of August 15 through 21, 2016; your agency did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at breakfast, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv). The percentage for meeting the whole grain rich requirement was 70%.
The following items were determined not to be WGR:
- The rice served with the breakfast meal on 12/05/16
- The Danish served with breakfast on 12/08/16
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 On-Site Portion of the Review Conducted February 21, 2017:
Eligibility Certification: During review it was determined that one application was certified in error. The error resulted in one child receiving free meals when eligible for reduced price meals. The errors were due to miss-categorizing the households' income in the wrong benefits category (7 CFR Part 245.6). This error resulted in a Performance Standard I (PSI) Violations.
During the On-Site portion of the AR the SFA the application with the error was brought to the SFA's attention. 7CFR Part 245.6 (c) (3) (iii) requires the SFA to send notification to the households in writing, and allow 10 calendar days for a possible hearing request.
The school-reviewing official must review each incoming application to ensure that the household submitted a complete application. If the application is complete, the official must then determine whether the household is categorically eligible or income eligible for benefits. It is recommended that someone come behind the determining official and double check the math and benefit category. A space is provided on the application for a second person to sign off on the determination.
This is a Performance Standard 1 (PS 1) violation which requires fiscal action, 7 CFR Part 210.18 (g) (1).
To demonstrate compliance with eligibility certification requirements:
- Inform the households in writing of their change in benefits status, allow 10 days for a possible hearing request
- Once the 10 calendar day timeframe has past, change the benefits status from free to reduced meal eligibility.
- Provide copies of the letters sent, date changes were made and your written corrective action plan to demonstrate understanding and compliance.
Reviewer's Comments: Overall, your school is doing a good job with its school nutrition programs. The breakfast and lunch meal preparation and meal service operate smoothly and appear to work well for the operation of school. All of the staff members working in the program should be commended on a job well done.