Date:  04-05-22

Name of Agency:  St. James Catholic School                                Date of off-site review: 12-06-21

Reviewer:  Matthew Smith                                                              Date of on-site review: 01-27-22

Persons interviewed:  Alicia Vazquez                                          Date of exit conference: 03-30-22

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):

·       Adult Meal Charge:  At the time of the off-site St. James Catholic School (SJCS) was not charging enough for school breakfast meals [FNS Instruction 782-5 Rev. 1].  Prior to the completion of the off-site SJCS took corrective action by raising their adult meal charge for breakfast meals above the minimum required charge.

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

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted December 6, 2021:

Civil Rights – Procedure for Handling Civil Rights Complaints:  SJCS’ written procedure for handling civil rights complaints had incorrect contact information on where to send civil rights complaints.  FNS Instruction 113-1 requires School Food Authorities to use the current contact information for the USDA on where to send civil rights complaints.

To demonstrate compliance with requirements for the written procedure for handling civil rights complaints:

·       Update SJCS’ written procedure to include the current contact information for the USDA on where to send civil rights complaints.

·       Provide SJCS’ updated written procedure for handling civil rights complaints along with SJCS’ plan for corrective action demonstrating compliance and understanding.

Local Wellness Policy: SJCS’s local wellness policy did not contain the local wellness committee membership along with each member’s relationship with SJCS as required by federal regulation [7 CFR Part 210.31 (c) (5) and 7 CFR Part 210.31 (d) (1)].

To demonstrate compliance with local wellness policy requirements:

·       Update SJCS’ local wellness policy to include the local wellness committee membership and their relationship to SJCS.

·       Provide an updated copy of SJCS’ local wellness policy along with SJCS’ plan for corrective action demonstrating compliance and understanding.

Meal Patterns:  During the menu week assessed 11/08/21 – 11/12/21 there were some insufficient serving sizes for the lunch menus served.  For the day of review, 01/27/22 an insufficient daily serving size was also discovered.

The lunch meal pattern 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

*All items used to meet the daily and weekly bread/grain servings must be Whole Grain-Rich.

Fruit

½ cup daily and 5 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 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 11/08/21 – 11/12/21

§  The menu served on 11/09/21 had an insufficient daily serving size for the bread/grain component.  The taco shells only credited 0.75 oz. toward this component’s daily serving.

§  The menu served on 11/10/21 had an insufficient daily serving size for the vegetable component.  Only ½ cup (pinto beans) of vegetables could be credited toward this component’s daily serving.

§  The menu served on 11/12/21 had an insufficient daily serving size for the vegetable component.  Only 5/8 cup of vegetables (1/2 cup of carrots and 1/8 cup pizza sauce) could be credited toward this component’s daily serving.

§  The minimum required weekly bread/grain component serving was not met.  Only 7.75 oz. could be credited toward this required weekly serving.

§  The minimum required weekly vegetable component serving was not met.  Only 3 5/8 cup of vegetables could be credited toward this required weekly serving.

Insufficient Quantities for the Day of Review – 01/27/22

§  The menu had an insufficient serving size for the vegetable component.  Only ½ cup of vegetables were served.

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 allowed for under 7 CFR Part 210.18 (g) (2).

To demonstrate compliance with Meal Patterns:

• Review your menus for compliance with the meal patterns for grades K-8.
• Bring all insufficient serving sizes and missing components in compliance with the meal patterns for grades K-8.
• Submit SJCS’ plan for corrective action to demonstrate understanding and compliance.  

The school served non-creditable food items as part of the meal component.  During the menu assessment, for the week of 11/09/21 through 11/12/21 it was determined your school is serving a non-creditable item.  This was due to the product not having a Child Nutrition (CN) label issued by the USDA, or a product formulation statement issued by the manufacturer [as required by Appendix C to 7 CFR Part 210].

• The Kolache product served with the breakfast menu served with the breakfast menu served on 11/09/21.

To demonstrate compliance with the CN label/product specification requirement:

• Provide a CN label or product formulation statement for the product. 
• If product formulation statement(s) or CN labeling is not available, the product will have to be replaced.  If this is the case, please provide a copy of the replacement creditable item’s labels. If the replacement is produced from a recipe, please provide the recipe.
• Provide a copy of the above documentation, along with SJCS’ plan for corrective action to demonstrate compliance and understanding.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted January 27, 2022:

Counting and Claiming: A review of the counting system demonstrates systemic counting and claiming errors for the review period, November 2021, which results in a Performance Standard

Violation I (PSI), 7 CFR Part 210.18 (g) (1) (ii).  The error was systemic in nature and was found for breakfast and lunch monthly counts. 

Below are the differences, our reviewer identified, in SJCS’ November Lunch counts, when comparing the meal roster to the meals listed on SJCS’ claim:

	SJCS Roster Counts	SJCS November Claim	OKDHS School Nutrition Programs Count	Difference
Free	2265	2225	2268	-43

Free lunch meals were under claimed by 43 meals.

Below are the differences, our reviewer identified, in SJCS’ November breakfast counts, when comparing the meal roster to the meals listed on SJCS’ claim:

	SJCS Roster Counts	SJCS November Claim	OKDHS School Nutrition Programs Count	Difference
Free	625	611	631	-20

Free breakfast meals were under claimed by 20 meals.

The errors for the daily and monthly meal counts appear to be from calculation errors.  The difference between SJCS roster counts and the meals claimed for November appear to be data entry errors. 

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 requirements:

• 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: meal rosters for March 2022, edit check forms for March 2022.
• Provide the above copies, along with SJCS’ plan for corrective action to demonstrate understanding and compliance.   

Procurement Review Summary Report

Date:  04-05-22

Name of Agency:  St. James Catholic School                                Date of AR off-site review: 12-06-22

Reviewer:  Matthew Smith                                                              Date of AR on-site review: 01-27-22

Persons interviewed:  Alicia Vazquez                                          Date of exit conference: 03-30-22

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

There were no findings for the procurement review.