Skip to main content

Administrative Review Summary Report

​Date:  03-30-18

Name of Agency:  Youth Services of Tulsa County              Date of off-site review: 02-12-18

Reviewer:  Matthew Smith                                                    Date of on-site review: 03-21-18

Persons interviewed:  Sonia Brown and                                 Date of exit conference: 03-21-18

                                    Claudia Green

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 School Food Authority (SFA) did not provide a copy of their local wellness policy, as well as not providing the documentation of the most recent assessment and update of the local wellness policy (as required 7 CFR Part 210.31).  Prior to the completion of the Off-Site portion of this AR the SFA provided their local wellness policy and a triennial wellness assessment report (as required by USDA Memo SP24-2017).  Both documents meet federal requirements (7 CFR Part 210.31) and were posted publicly on a bulletin board at the SFA's only site as required by 7 CFR Part 210.31 (e) (2).

Corrective action for the above was made prior to the completion of 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 February 12, 2018:

Recordkeeping: The review revealed missing production records for breakfast and lunch meals during the month of review.  There were no production records for the month of review except for the menu week of breakfast and lunch meals (01/21/18—01/27/18, these are the productions records for the menu week that was assessed as part of this AR).

The State Agency (SA) reviewer was able to reconstruct the meals to certify reimbursable meals served during the days without production records.  This was done through the School Food Authority's (SFA) monthly menu and the SFA's cycle menu.

It is the responsibility of all SFAs to ensure that program requirements are followed and that proper documentation exists prior to submission of a claim for reimbursement.  7 CFR Part 210.10 (a) (3), and 7 CFR Part 220.08 (a) (3) require each SFA to keep production records to document the reimbursable meals served.  "These records must show how the meals offered contribute to the required food components and food quantities for each age/grade group every day [7 CFR Part 210.10 (a) (3)]."

All SFAs must keep accurate records pertaining to the school food service program activities.  Accurate records serve as a basis for filing a claim for reimbursement and demonstrate program compliance.  Failure to retain documentation that supports claim reimbursement, eligible students, and reimbursable meals can result in the withholding of program funds or fiscal action. 
All records, including: meal counts, production records, and other required program documentation must be retained for three years from the day that the SFA's final allowable payment under the contract has been recorded as required by 7 CFR Part 210.23 (c).

To demonstrate compliance with Recordkeeping requirements:

  • Create a plan to collect and review all the month's daily records prior to submitting the claim.
  • Have available for the SA reviewer production records from the month of the On-Site visit (March 2018) for review at the time of the Technical Assistance (TA) visit scheduled for April 18, 2018.
  • Provide one completed production record for breakfast and one completed production record for lunch
  • Provide a corrective action plan to demonstrate understanding and compliance.     

Findings and Recommendations Identified During the On-Site Portion of the Review
Conducted March 21, 2018

Civil Rights: During the On-Site portion of this AR it was discovered the nondiscrimination statement was not included on appropriate program material as required by FNS Instruction 113-1.  FNS Instruction 113-1 directs SFA's to include on appropriate program materials to include the following nondiscrimination statement:

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.  

Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits.  Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339.  Additionally, program information may be made available in languages other than English.

To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:


(1)           mail: U.S. Department of Agriculture

Office of the Assistant Secretary for Civil Rights

1400 Independence Avenue, SW

Washington, D.C. 20250-9410;

(2)           fax: (202) 690-7442; or

(3)           email: program.intake@usda.gov.

FNS Instruction 113-1 allows for the following abbreviated nondiscrimination statement to be used if space is limited: "this institution is an equal opportunity provider."

To demonstrate compliance with civil rights requirements:

  • Add the nondiscrimination statement or the approved abbreviated nondiscrimination statement to appropriate program materials.
  • Provide a corrective action plan to demonstrate understanding and compliance.

Meal Patterns:A review of 01/21/18 through 01/27/18 indicated some insufficient portion sizes at lunch. 

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes; 2 oz. by weight meat/meat alternate daily and 14-17 oz. per week, 2oz. by weight bread/grain daily and 14-17 oz. per week, 1 cup fruit daily and 7 cups per week, 1 cup vegetables daily (dark green subgroup ½ cup/week, red/orange subgroup 1 ¼ cup/week, legumes subgroup ½ cup/per week, starchy subgroup ½ cup/week, and other subgroup ¾ cup/week) 7 cups/week, and 1 cup fluid milk daily, 7 cups weekly, offered as a choice between 1% and fat free.

Insufficient quantities

  • On 01/21/18, insufficient daily serving size for the bread/grain component.  The hamburger bun served as part of the meal only credits at 1.75 oz. toward the bread/grain component.
  • On 01/22/18, insufficient daily serving size for the bread/grain component.  The roll served with this meal only credited at 1.25 oz. toward the bread/grain component.
  • On 01/24/18, insufficient daily serving size for the bread/grain component.  The roll served with this meal only credited at 1.25 oz. toward the bread/grain component.
  • On 02/27/18, insufficient daily serving size for the fruit component.   One fresh tangerine was served with this meal, when combined with ½ cup of 100% apple juice the total serving size of 7/8 of a cup.
  • During the week being assessed the SFA failed to serve any vegetables that could be credited to the legume vegetable subgroup (this is a first vegetable subgroup finding for the SFA).

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).

It is very important for your staff to 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 that is 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 your plan for corrective action to demonstrate understanding and compliance.    

Administrative Review Summary Report
Page 4
March 30, 2018

Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of 01/21/18—01/27/18; your agency did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at lunch and the Afterschool Snack Program, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv).  For the lunch the percentage for meeting the whole grain rich requirement was at 65.7%.
 

  • 01/22/18, 01/23/18, 01/24/18, and 01/27/18, at lunch the meals were served with rolls that were not WGR.
  • 01/27/18, at lunch the meal was served with spaghetti noodles 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're 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 whole grain-rich requirement may result in fiscal action for repeat violations on future reviews. 

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

  • Evaluate your products to determine if they meet the whole grain rich requirement. Replace any products you determine don't meet the WGR requirement. 
  • Provide a copy of your corrective action plan to demonstrate understanding and compliance.

Reviewer's Comments:  The SFA's employees with duties within its school nutrition program were attentive to the Technical Assistance (TA) provided during this AR.   


Procurement Review Summary Report


 

Date:  03-30-18

Name of Agency:  Youth Services of Tulsa County              Date of off-site review: 02-12-18

Reviewer:  Matthew Smith                                                      Date of on-site review: 03-21-18

Persons interviewed:  Sonia Brown and                                Date of exit conference: 03-21-18
                                       Gaylen Simmons 


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):

 

  • Procurement: At the time of the PR was commenced, your agency did not provide a procurement plan and the code of conduct provided did not meet federal requirements [7 CFR Part 210.21(c) and 7 CFR Part 220.16 (c), 7 CFR Part 210.21(c), and 7 CFR Part 220.16 (c)].  During the PR your agency provide copies of both documents that were compliance with federal regulations.

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

There were no additional findings for the PR.

Reviewer's Comments:  I want to commend your agency on compliance with the regulations regarding procurement in school nutrition programs.

Back to Top