Date: 04-14-26

Name of Agency: St. James Catholic School                                Date of off-site review: 01-08-26

Reviewer: Matthew Smith                                                        Date of on-site review: 02-17-26

Fiscal Action: Yes.  Fiscal action for this Administrative Review (AR), specifically the day of review (02-17-26) was addressed by the St. James Catholic School (SJCS) prior to the February 2926 claim being submitted to Oklahoma Human Services (OKDHS).  SJCS did this by reducing their daily meal count by the amount of disallowed lunch meals prior to it being put through the provision two claiming worksheet.  This reduced to overall monthly claim by the lunches disallowed by the OKDHS reviewer, which sufficiently addressed the required fiscal action.  There was no other fiscal action required for this AR.

Selected for Independent Review: No                                                               

Persons interviewed:  Alicia Vazquez                              Date of exit conference: 04-10-26

Programs Operated by the School Food Authority (SFA): This 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):

·       Adult Meal Charges: At the time the AR was opened, St. James Catholic School (SJCS) had adult meal charges for breakfast and lunches that were insufficient to meet the requirement to be at least the free reimbursement rate plus the value of USDA Foods [as required by USDA FNS Instruction 728-5 Rev. 1].  Prior to the completion of the off-site portion of the AR, SJCS increased their adult meal charges to be compliant to be at least the free reimbursement rate plus the value of USDA Foods.

No further action is required for the above. 

 

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted January 8, 2026:

Local Wellness Policy: The local wellness policy provided during the off-site portion of this AR did not contain the local wellness committee membership listed as required by federal regulations [7 CFR Part 210.31 (c) (5) and 7 CFR Part 210.31 (d) (1)]. The local wellness policy must be updated to include the local wellness committee membership.

To demonstrate compliance with local wellness policy requirements:

• Provide a copy of the updated local wellness policy compliant with federal requirements for local wellness policies.
• Provide a copy of the updated local wellness policy along with St. James Catholic School’s (SJCS) plan for corrective action to demonstrate understanding and compliance.

 

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted February 17, 2026:

Conting and Claiming – Missing meal Component: During the lunch meal observation on the day of review (02/17/26), the SA reviewer observed 28 students who were counted as receiving reimbursable lunch meals who did not take a milk.  Federal regulations [7CFR Part 210.9 (b) (5) and 7 CFR Part 210.18 (g) (2)] require meals being claimed for reimbursement to be compliant with the meal patterns to be claimed for reimbursement.  Being SJCS is serve site, the students at lunch must take the five required meal components, bread/grain component, fruit component, meat/meat alternate component, the milk component, and the vegetable component [as required by federal regulation 7 CFR Part 210.10 (c)].  At breakfast the students must take the three required meal components, fruit component, grains & meats/meat alternates component, and the milk component [as required by federal regulation 7 CFR Part 220.8 (c)].

The lunch meals missing the milk component are a performance standard 2 violation [per federal regulation 7 CFR Part 18 (g) (2) (2)] requiring fiscal action.  SJCS reduced their meal count for the day of review (02/17/26) by 28 lunch meals prior to the monthly meal count being entered into the provision 2 spreadsheet used to calculate the monthly free, reduced, and paid meal counts.  This action by SJCS took care of the required fiscal action.

Top demonstrate compliance with counting and claiming requirements:

·       Provide SJCS’ plan for corrective action to demonstrate understanding and compliance.

Food Safety – Temperature Logs: During the on-site portion of this AR a five-day gap was discovered for the December 2025 cold food storage temperature logs where temperature logs were not recorded (12/24/25 – 12/28/25).  The HACCP food safety plan and federal regulation [7 CFR Part 210.13 (c)] require temperature logs to be maintained with no more than a three-day gap for cold storage temperature logs.  The participation of SJCS in the USDA Foods Program through OKDHS Food Distribution Program reduces the allowable cold food storage temperature log gap to two days.

To demonstrate compliance with cold food storage temperature log requirements:

·       Provide SJCS’ plan for corrective action to demonstrate understanding and compliance.

Meal Patterns:  During the menu week assessed 12/08/25 – 12/12/25 there were some insufficient serving sizes for the lunch menus served. 

The lunch meal pattern [as required by federal regulation 7 CFR 210.10 (c)] requires the following minimum serving sizes for the grades K-8 meal pattern:

Meal Component	Required Serving
Bread/Grain	1 oz. by weight daily and 8 – 9 oz. per week

*At least 80% of the weekly bread/grain component serving must be Whole Grain-Rich (WGR).

Fruit

½ cup daily and 2 ½  cups per week

*Up to half of the weekly serving can be met with the use of 100% fruit juice.

Meat/Meat Alternative	1 oz. by weight daily and 9 – 10 oz. per week
Milk	1 cup daily and 5 cups per week

*Students must be given a choice of milk from fat free unflavored, fat free flavored, and 1% unflavored. **One of the choices must be unflavored.
Vegetable	¾ cup daily and 3 ¾ cups per week
Vegetable Subgroups to be offered throughout the week
-Dark Green ½ cup     -Red/Orange ¾ cup     -Legume ½ cup per week -Starchy ½ cup           -Other ½ cup

Insufficient Quantities for the Menu Week 12/08/25 – 12/12/25

§  The menu served on 12/09/25 had an insufficient daily serving size for the vegetable component.  Only 3/8 cups of vegetables could be credited toward this component’s daily serving.

§  The required minimum weekly serving for the other vegetable subgroup was not met.  Only 3/8 cups of vegetables could be credited toward the weekly serving for the other vegetable subgroup.

The above insufficient serving sizes were determined to be non-systemic in nature.

The State Agency (SA) is exercising its discretion to not apply fiscal action for the above insufficient quantities as permitted under federal regulation [7 CFR Part 210.18 (l) (2) (iii)].

To demonstrate compliance with Meal Patterns:

• Review your menus for compliance with the meal patterns.
• Bring all insufficient serving sizes and missing components in compliance with the meal patterns.
• Submit SJCS’ plan for corrective action to demonstrate understanding and compliance.

Meal Patterns – Added Sugar Limits for Yogurt: During the menu week assessment (conducted for the breakfast and lunch menus for the week of 12/08/25 – 12/12/25) a yogurt product served with the breakfast on 12/12/25 was discovered exceeding the permitted added sugar limits for the meal patterns for the School Breakfast Program (SBP).  Federal regulations [7 CFR Part 210.10 (c) (2) (iv) (C) and 7 CFR Part 220.8 (c) (2) (iv) (C)] established an added sugar limit for yogurts of no more than12 grams per 6 oz.  Yogurt products exceeding this added sugar limit must either be replaced with a compliant yogurt product or be removed from the menu.

To demonstrate compliance with added sugar limit requirements for yogurts:

·       Ethier replace the non-compliant yogurt product with a yogurt product compliant with the meal pattern added sugar limit requirement or remove the added yogurt from the breakfast menu for 12/12/25.

·       Provide SJCS’ plan for corrective action to demonstrate understanding and compliance.

Production Records: The production records provided as part of the menu week assessment of the lunch menus for 12/08/25 – 12/12/25, had the following issues:

·       The production records did not have the total amount of each item prepared filled out in the body of the production records.

·       Some of the breakfast production records did not have the 100% fruit juice being served for some of the breakfast menus where it was served during the week.

Federal regulation [7 CFR Part 210.10 (a) (3)] requires SFAs to maintain production records for the meal being claimed for reimbursement.  Each item served with reimbursable meals The production records are required to document how the meals produced contribute toward the meal patterns.

To demonstrate compliance with production record requirements:

·       Provide a copy of one complete breakfast production record.

·       Provide a copy of one complete lunch production record.

·       Provide the above along with SJCS’ plan for corrective action to demonstrate understanding and compliance.

Procurement Review Summary Report

Date: 04-14-26

Name of Agency: St. James Catholic School                                Date of AR off-site review: 01-08-26

Reviewer: Matthew Smith                                                               Date of AR on-site review: 02-17-26

Persons interviewed: Alicia Vazquez                                           Date of exit conference: 04-10-2 

Programs Operated by the School Food Authority (SFA): This SFA operates the National School Lunch Program and the School Breakfast Program.

Findings for the Procurement Review (PR)

Procurement Plan: The procurement plan in place at the time of the PR was opened did not address the use of the micro-purchase method of procurement.  Federal regulation [2 CFR Part 200.318 (a)] requires School Food Authorities (SFA) to maintain and use written procedures for procurement transactions using funds from the Nonprofit School Food Services Account (NSFSA).

To demonstrate compliance with procurement plan requirements:

• Revise or amend the procurement plan to address the use of the micro-purchase method of procurement.
• Provide an amendment to the current procurement plan or provide an revised procurement plan updated to address the use of the micro-purchase method of procurement.
• Provide the above along with SJCS’ plan for corrective action to demonstrate understanding and compliance.