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Administrative Review Summary Report


Date:  04-29-21
 

Name of Agency:  Genesis Project                                            Date of off-site review: 01-14-21

Reviewer:  Matthew Smith                                                       Date of on-site review: 02-25-21

Persons interviewed:  James Williams                                    Date of exit conference: 04-22-21

                                               

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

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

  • Local Wellness Policy:  The local wellness policy provided at the time of the off-site did not have the following:
    • a description of the assessment of the local wellness policy [7 CFR Part 210.31 (c) (5)]
    • Designation of personnel responsible for the assessment of the policy [7 CFR Part 210.31 (e)].
    • A description of how the public are provided with the opportunity to participate in the local wellness policy process [7 CFR Part 210.31 (c) (5)].
    • The guidelines and standards for the marketing of food and beverages [7 CFR Part 210.31 (c) (3) (iii)]. 

Prior to the completion of the on-site portion of this AR, Genesis Project took corrective action providing an updated copy of their policy that includes all the required areas.

  • Failure to provide records:  Genesis Project failed to provide the following records during the off-site portion of this AR [7 CFR Part 210.9 (b) (17) and the agreement Genesis Project has with OKDHS School Nutrition Programs]: The training records for the employee with part-time duties within the Genesis Project’s school food services program. Prior to the completion of the on-site portion of this AR, Genesis Project provided the requested records.

You have taken corrective action for the above prior to the On-Site portion of this AR.  No further action is required

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted January 14, 2021:

Meal Patterns: A review of 12/13/20 through 12/19/20 indicated some insufficient portion sizes at breakfast and lunch.  During the day of review, insufficient serving sizes were found for both the breakfast and lunch menus.

The breakfast meal pattern 7 CFR Part 220.8 (c) requires the following min. serving sizes for grades K-5:

  • 1oz. by weight bread/grain daily and 10-14 oz. per week
  • 1 cup Fruit and 7 cups per week, No more than 50% of the fruit components for a menu week can be met with 100% fruit juice.
  • 1 cup fluid milk (7 cups per week), offered as a choice between 1% (unflavored) and fat free (flavored or unflavored).  

 

Insufficient quantities

  • For the breakfast menu served on 02/25/21 (the day of review) the minimum daily bread grain serving was not met.  The slice of bread used to make the toast only weighed 26 grams crediting at 0.75 oz.

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes for the grades K-5 meal pattern;

  • 1 oz. by weight meat/meat alternate daily and 11-14 oz. per week
  • 1oz. by weight bread/grain daily and 11-12.5 oz. per week
  • ½ cup fruit daily and 3 ½ cups per week
  • ¾ cup vegetables daily and 5 ¾ cups/week
    • Vegetable Subgroup Servings:
      • 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
    • 1 cup fluid milk daily, 7 cups weekly, offered as a choice between 1% (unflavored) and fat free (flavored or unflavored).

 

Insufficient quantities

  • The lunch menu served on 12/13/20, the daily vegetable component serving was insufficient.  Only ½ cup of vegetables could be credited toward the daily vegetable serving.
  • For the lunch menu on 12/18/20, the daily bread/grain component serving was insufficient.  Only 0.75 oz. could be credited toward the daily bread/grain component.
  • For the week of 12/13/20 – 12/19/20 the weekly minimum serving for the vegetable component was not met.  Only 5 cups of vegetables could be credited toward the weekly vegetable component serving.
  • For the lunch menu served on 2/25/21 (the day of review) the daily minimum bread/grain component serving was not met.  The slice of bread served with the meal only credited at 0.75 oz.

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 your staff 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 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 and missing components in compliance with the meal patterns for grades 9-12.
  • Submit Genesis Project’s plan for corrective action to demonstrate understanding and compliance.

Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of December 13 through 19, 2020; your agency did not 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).  

Your breakfast whole grain rich percentage was 63%.  For lunch, your whole grain rich percentage was 27.1%.

  • The following breakfast menus were served with bread that was not WGR that were served on: 12/13/20, 12/14/20, 12/16/20, 12/18/20, and 12/19/20. 
  • The lunch menus served on 12/14/20 and 12/16/20 were served with bread that was not WGR.
  • The lunch menu served on 12/15/20 was served with pasta that was not WGR.
  • The lunch menu served on 12/17/20 was served with pasta that was not WGR.
  • The lunch menu served on 12/18/20 was served with taco shells that 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 are 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 WGR requirement may result in fiscal action for repeat violations on future reviews. 

To demonstrate compliance with Whole Grain Rich Bread/Grain Requirements:

  • Evaluate products to determine if they meet the whole grain rich requirement. Replace any products determined not to meet the WGR requirement. 
  • Provide a copy of Genesis Project’s corrective action plan to demonstrate understanding and compliance.

Professional Standards – Eight Hour Food Safety Training:  At the time of the off-site portion of this AR the school food services director (James Williams) had not completed eight hours of food safety training.  Federal regulation [7 CFR Part 210.30 (b) (2)] requires school food services director must completed eight hours of food safety training within 30 days of starting as director, or within five years of the date the director assumed their position.

The Institute of Child Nutrition’s (ICN) eLearning Portal has free online self-paced trainings on food safety topics to meet the eight-hour food safety-training requirement.  Our office recommends the ICN training titled “Food Safety in Schools (eight hours)”.  On 02/18/21, our office emailed James Williams information on how to set up an account on ICN’s eLearning Portal.

To demonstrate compliance with Professional Standards-Eight Hour Food Safety Training Requirement:

  • The school food services director, James Williams will need to complete eight hours of food safety training.
  • Provide a copy of the documentation showing Mr. Williams completed the safety training along with your corrective action plan to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted February 25, 2021:

Counting and Claiming: A review of the counting system demonstrates a counting error for the review period (December 2020) for Genesis Project’s Afterschool Snack Program.  The error resulted in an under claim for the Afterschool Snack Program for the month of December 2020, which caused a Performance Standard Violation I (PSI), 7 CFR Part 210.18 (g) (1) (ii).   

The error in the December Afterschool Snack Program claim appears to be due to a data entry error when entering the claim into the online claiming system.

Below are the differences, our reviewer identified, in Genesis Project’s December 2020 Afterschool Snack Program count:

: Genesis Project OKDHS Difference

Free

195

210

15

Free snacks were under claimed by 15 snacks.

7 CFR Part 210.8 (a) (2) requires each SFA to review their claims for accuracy prior to submitting them to the State Agency (SA).

To demonstrate compliance with counting and claiming:

  • Review the counting and claiming system and create a plan to insure accurate daily meal counts are taken and recorded.
  • Provide copies of the following: your Genesis Project’s edit check for the snacks claimed for April 2021, and the snack rosters for April 2021.

Provide the above copies, along with Genesis Project’s corrective action plan to demonstrate understanding and compliance. 

Procurement Review Summary Report

Date:  04-29-21

 

Name of Agency:  Genesis Project                                            Date of AR off-site review: 01-14-21

Reviewer:  Matthew Smith                                                       Date of AR on-site review: 02-25-21

Persons interviewed:  James Williams                                     Date of exit conference: 04-22-21              

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

The following areas were corrected during the Procurement Review (PR):

  • Failure to provide records:  Genesis Project failed to provide the following records during the off-site portion of this AR [7 CFR Part 210.9 (b) (17) and the agreement Genesis Project has with OKDHS School Nutrition Programs]: The vendor list for school year 2019 – 2020.  Prior to the completion of this AR, Genesis Project provided the requested vendor list.

Corrective action for the above was made during the PR.  No further action is required for the above.

There were no further findings for the procurement review.

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