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.

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 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 09/23/22 

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.

The following are errors for CPA’s claims for the School Breakfast Program (SBP) for the months of January through February:

The errors appear to be from double entries into CPA’s electronic Point of Service (POS) system, as well as data entry errors when the SFA entered the claims into the SA’s online claiming system. 

According to CPA’s principal, the staff members who entered the POS meal counts into the electronic system (TeacherEase) neglected to change the meal service from breakfast to lunch before entering the counts.  Apparently, the TeacherEase program automatically defaults to the breakfast meal service when the POS option is selected. 

You must retrain your staff, who enter the meal counts at the POS, on the electronic POS and recognizing a reimbursable meal.     

Prior to entering the monthly reimbursement claim into the SA online claiming system, review the documentation for the monthly claim (the meal rosters, the edit checks, and the CEP claiming worksheet) to ensure the claim is accurate as required by federal regulation [7 CFR Part 210.8 (a) (2)].

To demonstrate compliance with counting and claiming:

• Review the counting and claiming system and create a plan to ensure accurate recording of daily meal counts.
• Provide the copies of the following: CPA’s meal rosters for April 2021 and CPA’s edit checks for April 2021.
• Proved the above copies along with CPA’s corrective action plan to demonstrate compliance and understanding.

HAACP Food Safety Plan:  At the time of the on-site visit, CPA could not locate their HACCP (Hazard Analysis Critical Control Points) food safety plan.  Federal regulation [7 CFR Part 210.13 (c)] requires each SFA to have a HACCP food safety plan.  CPA will need to develop and implement a comprehensive HACCP food safety plan.  The plan should include all the appropriate forms and documentation for monitoring and review.

A HACCP food safety plan template was emailed to CPA on 04/01/21.  This template contains everything needed to develop a HACCP food safety plan.

Keeping food safe is a vital part of healthy eating.  When properly implemented, a HACCP-based food safety program helps to ensure the safety of all meals.  SFAs must routinely monitor and document food safety procedures.

To demonstrate compliance with HACCP food safety plan requirements:

• Use the sample HACCP plan provided as a guide to develop CPA’s HACCP food safety plan.
• Provide an electronic copy of your HACCP plan’s cover sheet and table contents.
• Provide the above along with CPA’s corrective action plan to demonstrate compliance and understanding.

HACCP – Temperature Logs:  At the time of the on-site visit it was discovered, CPA was not keeping temperature logs for the cold food storage units.  Federal regulations [7 CFR Part 210.13 (c) and 7 CFR Part 210.13 (d)] requires SFAs to keep temperature logs for the SFA’s cold food storage units. 

Keeping temperature logs for the cold food storage units ensures the units are operating properly, and can alert the SFA to possible mechanical issues causing the units not being able to maintain temperatures to ensure the food is usable.  Ensuring food is keep at the proper temperatures helps to ensure the safety for all meals.

To demonstrate compliance with temperature logs:

• Begin keeping temperature logs for all cold food storage units.
• Provide copies of the most recent temperature logs for the cold food storage units.
• Provide the above along with CPA’s corrective action plan to demonstrate compliance and understanding.

Nutrient Analysis: The following errors, requiring corrective action, are based on the analysis conducted on the menu week (breakfast and lunch) previously assessed, January 25 through 29, 2021.

Lunch:

For grades 6-8, the nutrient analysis found the weekly calorie average to be 589 calories, which is 11 calories short of the meal pattern average calorie range.  Federal regulation [7 CFR Part 210.10 (f) (1)] establishes an average calorie range of 600-700 calories for the grades 6-8 meal pattern.

For grades 9-10, the nutrient analysis found the weekly sodium average to exceed sodium target 2.  The weekly average for the menus served during the week analyzed was 1407 mg. for the high school grades.  Federal regulation [7 CFR Part 210.10 (f) (3)] establishes sodium target 2 as 1080 mg. or less for the grades 9-12 meal pattern.

To demonstrate compliance with Saturated fat Nutrient target:

• Submit a plan to correct the calorie short fall for grades 6-8 for the week.
• Submit a plan to correct the average sodium levels exceeding sodium target 2 for high school menus for the week.
• Review the rest of your menus for compliance with the meal patterns.
• Submit the above along with your plan for corrective action to demonstrate understanding and compliance.     

Date:  04-28-21

Name of Agency:  Crossover Preparatory Academy           Date of AR off-site review: 02-04-21

Reviewer:  Matthew Smith                                                       Date of AR on-site review: 03-31-21

 

Persons interviewed:  Dr. John Lepine Sr. and                      Date of exit conference: 04-21-21
                                      Hayes Lewis

This School Food Authority (SFA) operates the National School Lunch Program, the School Breakfast Program, and the After School Snack Program (the snack program is currently suspended due to the COVID-19 outbreak).

Failure to Provide Requested Records:  CPA failed to provide documentation as required by their State Agency (SA) agreement and federal regulation [7 CFR Part 210.9 (b) (17)].  This federal regulation requires School Food Authorities (SFA) to:

“Upon request make all accounts and records pertaining to its school food service program available to the SA, and to the USDA Food and Nutrition Service (FNS).”

The SA reviewer made requests to CPA to provide the following records that were not provided:

• A list of vendors used during school year 2019-2020.  This was provided prior to the on-site portion of this AR.
• Invoices/receipts for the school year 2019-2020 for the following vendors:
  • Church’s Chicken.
  • Mazios
  • Oklahoma Style BBQ

To demonstrate compliance with the requirement to provide requested records:

• Provide the above documentation along with CPA’s plan for corrective action to demonstrate compliance and understanding.

Procurement Plan:  The procurement plan provided during the off-site portion of Crossover Preparatory Academy’s (CPA) Administrative Review (AR) did not include the required price analysis language for procurements above the small purchase threshold (CPA’s small purchase threshold is currently set at $150,000) as required by federal regulation [2 CFR Part 200.323 (a)].  Procurement plans are required to document a cost or price analysis for procurement activities above the small purchase threshold.

To demonstrate compliance with procurement plan requirements:

• Provide a copy of a procurement plan that contains the required language.
• Provide the above along with CPA’s plan for corrective action to demonstrate compliance and understanding.