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Administrative Review Summary Report

Date:  04-06-20

Name of Agency:  Rosary Catholic School

                                                                                    Date of off-site review: 02-04-20

Reviewer:  Matthew Smith                                     Date of on-site review: 03-12-20

Persons interviewed:  Becky Hardin                      Date of exit conference: 03-12-20

This School Food Authority (SFA) operates the National School Lunch Program and the School Breakfast Program.

The following areas were corrected prior to the On-Site Portion of this Administrative Review (AR):

  • Civil Rights:Rosary Catholic School's (RCS) cafeteria's web site does not have the current USDA approved non-discrimination statement posted on the site [FNS Instruction 113-1]. Prior to the completion of the Off-Site portion of this review RCS posted the current USDA approved non-discrimination statement. 
  • Local Wellness Policy: The policy posted publicly on RCS' website was not the most recent version of the policy [7 CFR Part 210.31 (d) (2)].  Prior to the completion of the Off-Site the SFA posted the most recent version of their local wellness policy

RCS also failed to provide documentation of their most recent assessment and update to their policy, and this documentation was not posted publicly [7 CFR Part 210.31 (e) (2)].  Prior to the completion of the Off-Site portion of this review, RCS posted publicly the most recent assessment and update to their policy (triennial wellness assessment report) on their website, and provided a copy of their triennial wellness assessment report.

Corrective action for the above was made prior to the On-Site portion of this AR.  No further action is required for the above

There were no additional findings for the Off-Site portion of the AR.
 
Findings and Recommendations Identified During the On-Site Portion of the Review Conducted March 12, 2020:

Buy American Provision: During the On-Site visit, food products were found that were not domestically produced.  7 CFR Part 210.21 (d), USDA Memo SP02-2017, and USDA Memo SP38-2017 require School Food Authorities (SFA) when possible to buy domestically produced food products.  Limited exceptions to the requirements to procure domestically produced food products are permitted.  USDA memo SP-24-2016 documents the following exceptions to this requirement:

  • The food product is not produced or manufactured within the United States
  • The food product is not produced or manufactured domestically in sufficient quantities.
  • The food product is not produced or manufactured domestically in satisfactory quality.
  • The costs of domestically produced or manufactured food products are significantly higher in cost than non-domestic products.

If a School Food Authority (SFA) is going to use one of the above exceptions they must keep documentation justifying the exception.

The following food products were found during the On-Site portion of this AR that were not domestically produced or manufactured:
 

  • The canned pineapple tidbits was a product of Thailand
  • The canned fruit salad was a product of Thailand

RCS did not have documentation justifying the use of these products under one of the permitted exceptions.  SFAs must work with their vendors to ensure the products used in their programs are compliant with the buy American provision.  When it is determined it is necessary to use one of the permitted exceptions, make sure to keep documentation to justify its use.  

To demonstrate compliance with the Buy American Provision:

  • Review the products that are used in RCS' nutrition program for compliance with the buy American provision. 
  • Provide RCS' corrective action plan to demonstrate understanding and compliance.

Civil Rights:  The notification letter for eligibility determinations sent out to by RCS to households did not contain the non-discrimination statement.  FNS Instruction 113-1 requires SFAs to include the non-discrimination statement on program materials such as the eligibility determination notification letter.  RCS was provided with the prototype application and verification letters (Word file) containing the current USDA approved full non-discrimination statement on March 9, 2020.

To demonstrate compliance with civil rights requirements:

  • Provide RCS' corrective action plan to demonstrate understanding and compliance.

Eligibility Certification:  During review it was determined that one application was denied in error. The error resulted in two children receiving paid meals when eligible for free meals. This error was due to the application being determined on household income and not by the children being categorically eligible due to being foster children (two students were listed as foster children on the application, 7 CFR Part 245.2).  This error resulted in a Performance Standard I (PSI) Violation.  During the On-Site portion of the AR the SFA the application with the error was brought to the SFA's attention.   

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 to double check the application, 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.
  • Provide copies of the letters sent, date changes were made and RCS' written corrective action plan to demonstrate understanding and compliance with eligibility certification requirements.

Incomplete Household Applications:  During the On-Site portion of this review the State Agency (SA) Reviewer discovered three household applications that did not have the last four digits of the primary wage earner for the household, or have the box checked indicating this person does not have a social security number.  Federal regulation, 7 CFR Part 245.2 requires household applications to have the primary wage earner's last four digits of their social security number on the application, or the box checked indicating the primary wage earner does not have a social security number.  These applications are considered incomplete.

During the On-Site visit, the SA reviewer provided RCS with notification of the three household applications that were incomplete due to not having the social security portion of the application completed.  Technical assistance was given during the On-Site visit on the topic of complete household applications.

To demonstrate compliance with having complete household application requirements:

  • Review household applications to ensure they are complete prior to determining eligibility.
  • Contact the households that have the incomplete applications to complete these applications.
  • Provide RCS' corrective action plan demonstrate understanding and compliance with complete household application requirements.

Verification:   Each year, School Food Authorities (SFAs) must confirm the eligibility of students receiving free and reduced price meals [7 CFR Part 245.6a (c) (1)]. 

The application selected for verification for this school year was determined to be eligible for reduced priced meals based on the documentation provided by the household, when it should have been denied (there was only one student listed on the application being verified).  The documented income was over the income guidelines for the household size (7 CFR Part 245.6).   This error resulted in a PSI violation which requires fiscal action, 7 CFR Part 210.18 (g) (1). 

RCS will need to send notification of the reduction in benefits to the household and the household must be given 10 calendar days in which to appeal prior to the household's benefit being reduced [as required by 7 CFR Part 245.6a (j)].

To demonstrate compliance with verification requirements:

  • Review the verification process used for this school year to find out where breakdown in the verification process occurred.
  • Send a letter notifying the household of the reduction of benefits.
  • Wait 10 calendar days prior to reducing the household benefits.
  • Provide a copy of the letter sent to the household that provided notification of the reduction of benefits.
  • Provide a copy of the above documentation along with RCS' corrective action plan to demonstrate your understanding and compliance with the verification requirement.

Meal Patterns: On the day of review, 03/12/20, one the SA reviewer observed one meal that was incomplete.

The breakfast meal pattern 7 CFR Part 220.8 (c) requires the following minimum serving sizes for grades K-8; 1oz. by weight bread/grain daily and 8-10 oz. per week, 1 cup Fruit and 5 cups per week, and 1 cup fluid milk and 5 cups per week, 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.

Missing Meal Components

  • One breakfast meal was observed for a child that was in one of the offer versus serve grades that did not have at least ½ cup of fruit [as required for a reimbursable meal under offer versus serve by 7 CFR Part 220.8 (e)].

Technical assistance was given to RCS recommending changing the direction of the meal service line, or moving the 100% fruit juice onto the serving line instead of the in the milk cooler area of the service line. Both recommendations provide the staff member working the service line to ensure a reimbursable meal has been provided to each student.

To demonstrate compliance with Meal Patterns:

  • Submit RCS' plan for corrective action to demonstrate understanding and compliance with meal patter requirements.    

Offer vs. Serve signage: During the On-Site portion of this Administrative Review it was discovered there was no signage assisting students in selecting a reimbursable breakfast meal.  7 CFR Part 220.8 (a) (2) requires signage explaining to students what constitutes a reimbursable breakfast meal.  The signage should direct students to select at least three meal components one of which must be at least ½ cup of fruit.

To demonstrate compliance with Offer vs. Serve Signage requirements:

  • Post signage explaining offer vs. serve for breakfast meals at the point of service.
  • Provide a copy of RCS' corrective action plan to demonstrate understanding and compliance.

Reviewer's Comments:  I want to commend Becky Hardin and her staff on a job well done on the administration of RCS' school nutrition programs.  The findings contained in this report do not reflect on the job that Ms. Hardin and her staff are doing, these programs have lots of requirements, and all programs, even our best ones, have findings.   Ms. Hardin has consistently continued to operate a fine program, keep up the good work. 

Procurement Review Summary Report

Date:  04-06-20

Name of Agency:  Rosary Catholic School

                                                                                    Date of AR off-site review: 02-04-20

Reviewer:  Matthew Smith                                    Date of AR on-site review: 03-12-20

Persons interviewed:  Becky Hardin                     Date of exit conference: 03-12-20

This School Food Authority (SFA) operates the National School Lunch Program and the School Breakfast Program.

Buy American Provision: During the On-Site visit, food products were found that were not domestically produced.  7 CFR Part 210.21 (d), USDA Memo SP02-2017, and USDA Memo SP38-2017 require School Food Authorities (SFA) when possible to buy domestically produced food products.  Limited exceptions to the requirements to procure domestically produced food products are permitted.  USDA memo SP-24-2016 documents the following exceptions to this requirement:

  • The food product is not produced or manufactured within the United States
  • The food product is not produced or manufactured domestically in sufficient quantities.
  • The food product is not produced or manufactured domestically in satisfactory quality.
  • The costs of domestically produced or manufactured food products are significantly higher in cost than non-domestic products.

If a SFA is going to use one of the above exceptions they must keep documentation justifying the exception.
 
The following food products were found during the Off-Site portion of this AR that were not domestically produced or manufactured:
 

  • The canned pineapple tidbits was a product of Thailand
  • The canned fruit salad was a product of Thailand

RCS did not have documentation justifying the use of these products under one of the permitted exceptions.  SFAs must work with their vendors to ensure the products used in their programs are compliant with the buy American provision.  When it is determined it is necessary to use one of the permitted exceptions, make sure to keep documentation to justify its use.    

To demonstrate compliance with the buy American provision:

  • Review the products that are used in Rosary Catholic School's (RCS) school nutrition program for compliance with the buy American provision. 
  • Provide RCS' corrective action plan to demonstrate understanding and compliance.

      

Reviewer's Comments:  I want to commend RCS on compliance with the regulations regarding procurement in school nutrition programs.  Keep up the good work

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