Name of Agency: All Saints Catholic School Date of review: 02/27/17
Reviewer: Chet Center Persons interviewed: Jerry Lang
This School Food Authority (SFA) participates in the Special Milk Program.
Findings and Recommendations Identified During the Review:
Civil Rights: During the review All Saints' civil rights policy could not be located. A written civil rights policy gives students, parents, and staff a clear understanding that discrimination is not tolerated and how to handle any complaints alleging discrimination should they arise.
Remember all Civil Rights complaints against the special milk program must be filed with the USDA, either through our office or directly.
A prototype civil rights policy was emailed to your office on 03/01/17. This policy can be slightly modified to include your school's information, then signed and adopted. I also recommend you to start a Civil Rights file. The file should contain a copy of the policy, collected racial and ethnic data, copies of the Civil Rights Complaint form, yearly training documentation and the Civil Right Worksheets.
To demonstrate compliance with the Civil Rights requirements:
- Adopt the provided prototype policy.
- Provide a copy of your newly signed policy along with your corrective action plan to demonstrate understanding and compliance.
Local Wellness: The Wellness Policy provided needs a few small modifications to bring it up to current requirements and standards. On 02/23/17 I emailed you a wellness policy template. You should be able to compare your policy to the provided template and identify any needed changes. After review the policy provided below are a few recommended changes.
- I would remove your "Goals" section and replace it with goals organized by the required type like in the template.
- I would completely remove the first bullet under "To accomplish these goals: All Saints will: (You just may not do this anymore, if you do leave it in.)
- I would completely remove the first bullet under Nutrition Guidelines for all food on campus. (The guidelines have to be already established.)
- I would add the entire Implementation and Review Section from the template.
You should review your policy and make the changes suggested above. 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 [as required by 7 CFR Part 210.30 (e) (2)] and any other time the agency or committee identifies the need for updating. Document all policy updates. 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.
7 CFR Part 210.30 (d) (2) and 7 CFR Part 210.30 (d) (3) requires each school to post their local wellness policy publicly. SFAs are also required to publicly post the assessment and update to their local wellness policy. Your website currently has a link set up for the wellness policy. You should post your newly updated policy there and reactivate the link.
To demonstrate compliance with the local wellness policy:
- Your local wellness policy needs to be assessed and updated.
- Post your updated wellness policy and documentation of the assessment and changes to your website.
- Provide an updated copy of your revised policy, documentation of the assessment and updates, along with your corrective action to demonstrate compliance and understanding.
Procurement: Your School didn't have a procurement policy available or code of conduct available for review. A sample procurement plan and code of conduct was emailed to you on 03/01/17.
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 school's purchasing periods for the goods, equipment, and services related to the School Nutrition Programs and the various methods procurement being practiced.
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.
Each SFA is required to maintain a written code of conduct governing the employees engaged in the award and administration of contracts supported by program funds, 7 CFR Part 210.21(c) and 7 CFR Part 220.16 (c). This written code will eliminate any conflict of interests that might arise during the procurement process.
To demonstrate compliance with the procurement requirements:
- Provide a copy of your school's procurement plan and code of conduct
- Provide the above along with your corrective action plan demonstrate understanding and compliance.