Administrative Review Summary Report

Date: 01-31-23

Name of Agency: Crossover Preparatory Academy Date of off-site review: 10-13-22

Reviewer: Matthew Smith Date of on-site review: 11-29-22

and 12-08-22

Persons interviewed: Mark Cruz and Date of exit conference: 01-24-23

Hayes Lewis

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):

· Civil Rights – Public Release: Crossover Preparatory Academy (CPA) did not send their public release to a local media outlet as required by USDA FNS Instruction 113-1. Prior to the completion of the off-site portion of this AR, CPA sent their public release to a local media outlet.

No further action is required for the above.

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted October 13, 2022:

Afterschool Snack Program – Self-Monitoring On-Site Review: The first self-monitoring on-site review was not conducted within the first four weeks of school starting as required by federal regulation [7 CFR Part 210.9 (c) (7)]. CPA conducted the first review on 09/21/22, which was not within the first four weeks of school starting (school started on 08/11/22).

To demonstrate compliance with Afterschool Snack Program requirements:

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

Buy American Provision: During the menu week assessment conducted for breakfast and lunch menus for the week of 09/19/22 through 09/23/22, food products were found that were not domestically produced. Federal regulations [7 CFR Part 210.21 (d) and 7 CFR Part 220.16 (d)] require School Food Authorities (SFA) to the maximum extent practicable to buy domestically produced food products.

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

· The Dole peach cup product served with the following menus was a product of Thailand:

- Breakfast and lunch menus served on 09/19/22.
- Breakfast menu served on 09/22/22

· The mango product served with the following menus was a product of Thailand:

- Breakfast menu served on 09/21/22
- Lunch menu served on 09/22/22

· The pear cup product served with the following menus was a product of Thailand:

- Breakfast and lunch menus served on 09/23/2

To demonstrate compliance with Buy American Provision requirements:

· Review the products used in your school nutrition program for compliance with the buy American provision.

· Provide CPA corrective action plan to demonstrate understanding and compliance.

Civil Rights – Nondiscrimination Statement: During the off-site portion of the AR CPA’s website had program documents posted, but did not have the current USDA approved nondiscrimination statement posted on the website. USDA FNS Instruction 113-1, requires School Food Authorities (SFA) to have the current USDA approved nondiscrimination statement posted on the website if there are program documents and program information posted on the website.

To demonstrate compliance with civil rights requirements:

· Post the current USDA approved nondiscrimination statement on CPA’s website.

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

Local Wellness Policy: Documentation of the most recent assessment and update (the triennial wellness assessment report) to the local wellness policy was not posted publicly at the time of the off-site portion of this AR. Federal regulation [7 CFR Part 210.30 (e) (2)] requires documentation of the most recent assessment and update to the local wellness policy to be posted publicly.

To demonstrate compliance with local wellness policy requirements:

Publicly post documentation of the most recent assessment and update to the local wellness policy (the triennial wellness assessment report).
Provide CPA’s plan for corrective action to demonstrate understanding and compliance.

Meal Patterns: During the menu week assessed 09/19/22 – 09/23/22 there were some insufficient serving sizes for the lunch menus served.

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes for the grades 6-8 and grades 9 -12 meal patterns:

Meal Component

Required Serving

Bread/Grain

Grades 6-8: 1 oz. by weight daily and 8-10 oz. per week

Grades 9-12: 2 oz. by weight daily and 10-12 oz. per week

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

Fruit

Grades 6-8: ½ cup daily and 2 ½ cups per week

Grades 9-12: 1 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

Grades 6-8: 1 oz. by weight daily and 9-10 oz. per week

Grades 9-12: 2 oz. by weight daily and 10-12 oz. per week

Milk

All Grades: 1 cup daily and 5 cups per week

*Students must be given a choice of milk from fat free unflavored, fat free flavored, 1% flavored, and 1% unflavored.

**One of the choices must be unflavored.

Vegetable

Grades 6-8: ¾ cup daily and 3 ¾ cups per week

Grades 9-12: 1 cup daily and 5 cups per week

Vegetable Subgroups to be offered throughout the week

Grades 6-8

-Dark Green ½ cup -Red/Orange ¾ cup -Legume ½ cup per week

-Starchy ½ cup -Other ½ cup

Grades 9 -12

-Dark Green ½ cup -Red/Orange 1 ¼ cup -Legume ½ cup per week

-Starchy ½ cup -Other ¾ cup

Insufficient Quantities

§ Insufficient daily serving for the bread/grain component for grades 9-12, for the menu served on 09/20/22. Only 1 oz. credited toward this component.

§ The weekly serving size for the red/orange vegetable subgroup for grades 6-8 was not met. The menus for the week only credited ½ cup toward this subgroup.

§ The weekly serving size for the red/orange vegetable subgroup for grades 9-12 was not met. The menus on credited ½ cup.

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

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted November 29, 2022 and December 8, 2022:

Menu Signage: CPA’s second site (the girl’s school) did not have signage for what constituted reimbursable breakfasts and lunches posted in the meal service area, as required by federal regulations [7 CFR Part 210.10 (a) (2) and 7 CFR Part 220.8 (a) (2)].

To demonstrate compliance with menu signage requirements:

At the second site post signage for what constitutes reimbursable breakfast and lunches.
Provide CPA’s plan for corrective action to demonstrate understanding and compliance.

Offer versus Serve – Incomplete Breakfast Meals: During the day of review (11/29/22), the State Agency (SA) reviewer witnessed six students during breakfast meal service that did not take at least ½ cup of fruit with their breakfast meal. These meals were counted by CPA. Federal regulation [7 CFR Part 220.8 (e)] requires breakfast at least four items from the required meal components to be offered, students may decline one and take three of the offered items. Students are required to take at least ½ cup of fruit as part of three items.

This is a Performance Standard 2 (PS 2) violation. Federal regulation [7 CFR 210.18 (a) (2)] requires fiscal action for PS 2 violations.

To demonstrate compliance with offer versus serve requirements:

Provide CPA’s plan for corrective action to demonstrate understanding and compliance.

Offer versus Serve – Signage: CPA’s second site (girl’s school) did not have Offer versus Serve (OVS) signage at the time of the on-site visit conducted on 12/08/22. Federal regulation [7 CFR Part 210.10 (a) (2) and 7 CFR Part 220.8 (a) (2)] require signage for OVS in the meal service area to include:

Breakfast: Students are required to take at least three items, one of which must be at least ½ cup of fruit.
Lunch: Students are required to take at least three items, one of which must be at least ½ cup of fruit, or ½ cup of vegetables.

To demonstrate compliance with OVS signage requirements:

Post OVS signage in the meal service area at CPA’s second site.
Provide CPA’s plan for corrective action to demonstrate understanding and compliance.

Reviewer’s Comments: I want to commend CPA’s personnel who work with the school food services program for all of the hard work they do to ensure students are being served nutritious meals. Keep up the good work.

Procurement Review Summary Report

Date: 01-31-23

Name of Agency: Crossover Preparatory Academy Date of AR off-site review: 10-13-22

Reviewer: Matthew Smith Date of AR on-site review: 11-29-22

and 12-08-22

Persons interviewed: Mark Cruz and Date of exit conference: 01-24-23

Hayes Lewis

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

The following food products were not domestically produced or manufactured:

· The Dole peach cup product served with the following menus was a product of Thailand:

- Breakfast and lunch menus served on 09/19/22.
- Breakfast menu served on 09/22/22

· The mango product served with the following menus was a product of Thailand:

- Breakfast menu served on 09/21/22
- Lunch menu served on 09/22/22

· The pear cup product served with the following menus was a product of Thailand:

- Breakfast and lunch menus served on 09/23/2

To demonstrate compliance with Buy American Provision requirements:

· Review the products used in your school nutrition program for compliance with the buy American provision.

· Provide Crossover Preparatory Academy’s (CPA) corrective action plan to demonstrate understanding and compliance.

Small Purchase - Written Specifications: During school year 2021 – 2022, CPA contacted potential vendors to request a price list. CPA’s procurement plan requires written specifications of the goods and, or services to be procured to be sent to each potential vendor. CPA failed to follow their procurement plan. Federal regulation [2 CFR Part 200.319 (d) (1)] requires SFAs to have and follow a written plan for procurement. Having written specifications also supports free and open competition [as required by federal regulation 2 CFR Part 200.319 (a].

To demonstrate compliance with written specification requirements:

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