Name of Agency: Integris Bass Baptist Health Center Date of off-site review: 10-04-16
Reviewer: Matthew Smith Date of on-site review: 11-08-15
Persons interviewed: Rhonda Fullerton Date of exit conference: 11-08-15
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 November 10, 2015:
Civil Rights: Integris Bass Baptist Health Center (IBBHC) did not have a policy for handling civil rights complaints, as required by FNS Instruction 113-1. Prior to the On-Site portion of this Administrative Review (AR), IBBHC provided a copy of their policy for handling civil rights complaints.
No further action is required regarding IBBHC's policy for handling civil rights complaints.
IBBHC also did not provide documentation on how data on race and ethnicity is collected for all residents as required by FNS Instruction 113-1. Prior to the On-Site portion of the AR, IBBHC provided documentation on how data on residents' race and ethnicity is collected.
No further action is required regarding racial and ethnic data collection.
Meal Patterns: A review of the menu week of 09/11/16 through 09/17/16 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.
- The Sara Lee 100% whole wheat bread only credits at 1.75 oz. for two slices. The sandwich served on 09/12/16, used this bread.
- The orange served with the lunch meal on 09/17/16, only credits at 5/8 cup of fruit according to the USDA's Food Buying Guide. This is 3/8 cup short of the 1 cup daily requirement.
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 in compliance with the meal patterns for grades 9-12.
- Submit your plan for corrective action to demonstrate understanding and compliance.
Procurement: At the time of the off-site portion of the AR both the code of conduct and the School Food Authority's (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.
Prior to the On-Site the SFA provided their code of conduct. No further action required regarding the SFA's code of conduct.
During the procurement review the State Agency (SA) determined the SFA only received one price quotation for the procurement of food and supplies for the school year (2015-2016). The procurements fell under the small purchase procedure. When using the small purchase procedure to procure goods and services under $150,000, 2 CFR Part 200.320 (b) and 7 CFR Part 3016.36 (d) (1) requires SFA's to obtain quotations from an adequate number of sources (more than one).
To demonstrate compliance with Procurement:
- Write and approve a procurement plan. This plan must include the steps taken to ensure that small, minority, and women's businesses, as well as labor surplus firms are used when possible (2 CFR Part 200.321).
- Provide your plan to ensure that price quotations from an adequate number of sources are obtained [2 CFR Part 200.320 (b) and 7 CFR Part 3016.36 (d) (1)].
- Provide copies of the above along with your plan for corrective action to demonstrate understanding and compliance.