Name of Agency: NW Oklahoma Juvenile Detention Center Date of off-site review: 03-07-17
Reviewer: Matthew Smith Date of on-site review: 12-14-15
Persons interviewed: April Travis Date of exit conference: 12-15-15
This School Food Authority (SFA) operates the National School Lunch Program and the School Breakfast Program.
Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted March 7, 2017:
Civil Rights: The School Food Authority (SFA) did not have a policy for handling civil rights complaints, FNS Instruction 113-1. During the On-Site portion of this Administrative Review (AR) the SFA, adopted a policy for handling civil rights complaints and provided the State Agency (SA) with a copy.
No further action is required regarding the policy for handling civil rights complaints.
At the time of the Off-Site visit the SFA could not provide a documentation of the SFA's staff members' attendance for the annual civil rights training which was conducted on October 26, 2016. FNS Instruction 113-1 requires civil rights training to be conducted annually. SFA's are must document their staff member's attendance to show compliance with this requirement. During the On-Site portion of this AR the SFA provided this documentation.
No further action is required regarding the documentation of the SFA's staff members' attendance of the SFA's annual civil rights training.
Procurement: At the time of the off-site portion of the AR both the code of conduct and the SFA procurement policy were not provided. The 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.
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.
The procurement plan provides an explanation for using certain procurement methods to obtain items used in the school food service program. The school district can determine the extent of the plan. An SFA may implement a plan that applies to all schools under its jurisdiction, or allow each school to implement an individual 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.
At the time of the On-Site visit the SFA provided their code of conduct and their procurement plan. No further action required regarding the SFA's code of conduct and the SFA's procurement plan.
Record Keeping: The benefit issuance document was not provided at the time of the Off-Site. 7 CFR Part 245.6 (e) and the USDA Administrative Review Manual requires each SFA to have a benefit issuance document. This document allows you to track student eligibility for claiming purposes and for yearly verification reporting.
At the time of the On-Site visit the SFA provided a copy of their benefit issuance document. No further action is required regarding record keeping.
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 a balance of $190.48.
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.
Findings and Recommendations Identified During the On-Site Portion of the Review Conducted April 12, 2017:
Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of February 5 through February 11, 2017; your agency meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at breakfast and lunch, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv). During the On-Site visit it was determined that the 2 ounce rolls being served for lunch on April 12, 2017, were 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.
Reviewer's Comments: I would like to commend the staff members who work in the SFA's school food service program. They are doing an excellent job administering the National School Lunch Program and the School Breakfast Program.