Date: 03-06-26                                                                         

Name of Agency: Drexel Academy                                             Date of off-site review: 10-07-26

Reviewer: Matthew Smith                                                         Date of on-site review: 11-13-25,                                               12/09/25, and 02-10-26

Fiscal Action: No, Drexel Academy filed an amended claim for October 2025, the month where                                       counting and claiming errors were discovered.  These errors resulted in                                                      performance standard 1 violation [per federal regulation 7 CFR Part 210.18 (g) (1) (ii)].

Selected for Independent Review: No                                                               

Persons interviewed:  Dr. Reubin McIntosh and                          Date of exit conference: 03-02-26

                                    Eboni Knauls

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):

·       Benefit Issuance Document (BID): During this review it was discovered Drexel Academy was not maintaining a BID for the current school year as required by federal regulation [7 CFR Part 245.6 (e)] and the USDA FNS Administrative Review Manual.  Prior to the completion of the on-site portion of this AR, Drexel Academy (DA) provided a BID for the current school year,

·       Civil Rights: At the time that the AR was opened, DA could not located documentation demonstrating the public release process was completed [as required by pertinent civil rights and nondiscrimination laws[1] and regulations[2]].  Prior to the completion of the off-site portion of the AR, DA took corrective action by completing the public release process and providing OKDHS School Nutrition Programs (SNP) with documentation of the process.

·       Direct Certification Notification: During this review AR did not provide the letter used to inform households of being eligible for free meals through direct certification [7 CFR Part 245.6 (b)].  Prior to the completion of the on-site portion of this AR, a direct certification notification letter was provided and DA indicated they would be notifying households eligible for free meals through direct certification.

·       Local Wellness Policy Content: The local wellness policy provided at the time this AR was opened did not have guidelines and standards for food served but not sold on campus during the school day [as required by federal regulation 7 CFR Part 210.31 (c) (2)].  Prior to the completion of the off-site portion of this AR, DA took corrective action to add guidelines and standards food served but not sold on campus during the school day.

·       Local Wellness Policy – Assessment: DA had not assessed their initial policy in over three years.  Federal regulation [7 CFR Part 210.31 (e) (2)] requires the local wellness policy to assess at least once every three years.  Prior to the on-site portion of the AR, DA took correct action by assessing their policy and providing OKDHS with a copy of the documentation of the assessment of their policy (triennial wellness assessment report form.

·       Professional Standards – Eight Hour Food Safety Training: At the time of the off-site portion of this AR the school food services director had not completed eight hours of training

within 30 days of being hired, or within five years of starting in the position [as required by federal regulation 7 CFR Part 210.30 (b) (1) (v)].  Prior to the completion of the on-site portion of this on-site the director completed an eight-hour food safety training.

 

No further action is required for the above. 

 

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted October 7, 2025:

Civil Rights: During the off-site portion of the AR, Drexel Academy (DA) failed to provide the method for how data of ethnicity and race for each student is gathered.  The USDA requires [as required by pertinent civil rights and nondiscrimination laws[3] and regulations[4]] School Food Authorities (SFA) to gather data for ethnicity and race for program participants (students) using a two-question format (one question for ethnicity and one for race).

To demonstrate compliance with civil rights requirements:

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

Production Records: The production records submitted as part of the menu week assessment were not being filled out properly.  Federal regulation [7 CFR Part 210.10 (a) (3) and 7 CFR Part 220.8 (a) (3)] require production records be kept for the meals being produced for reimbursement, as well as to document how the meals contribute to the meal patterns.  The production records reviewed as part of the menu week assessment of breakfast and lunch meals for the week of 09/15/25 – 09/19/25 had the following issues with documenting the meals being served:

·       The production records did not document the meals served.

·       The production records did not document leftover meals.

·       The production records did not document the varieties of milk being served.

·       The type of fruit was not always specified on the production records.

·       For some of the menus the production records do not document everything being served with the meals.   For example, for lunch served on 09/19/25, salsa was served with the meal, but it was not documented in the body of the production record.

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 documentation along with Drexel Academy’s (DA) plan for corrective action to demonstrate understanding and compliance.

Professional Standards – Training Tracking: During the off-site portion of this AR, DA failed to provide documentation demonstrating the tracking of training hours for employees with duties within the school food services program.  Federal regulation [7 CFR Part 210.30 (h)] requires School Food Authorities (SFA) to certify the school food services director, as well as employees with duties within the school food services program complete sufficient training hours to be compliant

with training hour requirements for each school year. SFAs must have documentation of the training hours completed to support the certification of the completion of training hour requirements.

To demonstrate compliance with training tracking requirements:

·       Begin to track the completion of training hours crediting toward the annual training hours on a training tracking tool.

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

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted November 13, 2025, December 9, 2025, and February 10, 2026:

Counting and Claiming: A review of the counting and claiming system demonstrates systemic claiming errors for the review period (October 2025), which is a Performance Standard I (PSI) Violation [per federal regulation 7 CFR Part 210.18 (g) (1) (ii)] requiring fiscal action. These systemic errors were found for both the breakfast and lunch monthly meal counts.

The errors appear to have occurred when the wrong higher meal counts for monthly breakfast and lunch were entered into Drexel Academy’s (DA) provision 2 claiming worksheet for October.   This caused over claims for all eligibility categories for the National School Lunch Program Claim and the School Breakfast Program claim.

Below are the differences Oklahoma Human Services School Nutrition Programs (OKHS SNP) has identified in Drexel Academy (DA) lunch meal counts claimed for October 2025:

	OKHS SNP Count	Drexel Academy Meal Roster Count	Drexel Academy Claim	Difference
Free	384	384	462	+78
Reduced	55	55	66	+11
Paid	296	296	355	+59

Lunch meals for all eligibility determination categories were over claimed:

·       Free lunches meals were over claimed by 78 meals. 

·       Reduced priced lunch meals were over claimed by 11 meals.

·       Paid lunch meals were over claimed by 59 meals.

Below are the differences OKHS SNP has identified in DA breakfast meal counts claimed for October 2025:

	OKHS SNP Count	Drexel Academy’s Meal Roster Count	Drexel Academy’s Claim	Difference
Free	318	311	346	+28
Reduced	39	38	42	+3
Paid	241	235	262	+21

Breakfast meals for all eligibility determination categories were over claimed:

• Free breakfast meals were over claimed by 28 meals.
• Reduced priced breakfast meals were over claimed by three meals.
• Paid breakfast meal were over claimed by 21meals.

DA filed an amended claim for October 2025 with the corrected meal counts.

Federal regulation [7 CFR Part 2108 (a) (2)] requires each SFA to review their claims for accuracy prior to submitting them to the State Agency (SA).

These are serious systemic errors in the counting and claiming system.

To demonstrate compliance with counting and claiming requirements:

• Review the counting and claiming system and create a plan to ensure accurate meal counts are claimed.
• Complete the edit check process for breakfast and lunch meals daily.
• Provide copies of the of the following: meal rosters for February 2026 for breakfast and lunch, as well as the edit checks for breakfast and lunch for February 2026.
• Provide the above along with DA’s plan for corrective action to demonstrate understanding and compliance.

Edit Checks: During the review of the reimbursement claim for October of 2025, it was discovered DA did not complete the daily edit checks process for breakfast and lunch daily meal counts as required by federal regulations [7 CFR Part 210.8 (a) (3) and 7 CFR Part 220.11 (d)].

To demonstrate compliance with edit check process requirements:

·       Complete the edit check process for breakfast and lunch meals daily.

·       Provide documentation of the edit check process for breakfast and lunch meal counts for the month of February 2026.

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

Failure to Provide Requested Records: During the AR, DA failed to provide Oklahoma Human Services (OKDHS) School Nutrition Programs with requested records in a timely fashion.  Federal regulation [7 CRR Part 210.9 (b) (17)] and Drexel Academy’s contract with OKDHS requires Drexel Academy to provide requested records in a timely fashion.  DA failed to provide the following records, some of which were later determined to be unlocatable by DA:

·       Financial records to include the revenue and expense report for school year 2024 – 2025.  Determined to be unlocatable by DA.

·       The Benefit Issuance Document.  Provided prior to the end of the on-site portion of this AR.

·       The letter used to provide households notification of direct certification. Provided prior to the end of the on-site portion of this AR.

·       Documentation of the training hours for employees with duties within the school food services program for the prior school years.  Determined to be unlocatable by DA.

·       Documentation of how data for program participants’ ethnicity and race is gathered.

To demonstrate compliance with requirements to provide records:

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

Food Safety Inspections: DA could not locate documentation of their food safety inspections.  For school year 2025 – 2026, DA has yet to receive a food safety inspection.  Federal regulation [7 CFR Part 210.13 (b)] requires each site a SFA operates to receive at least two inspections per school year. The State of Oklahoma requires documentation such as food safety inspections to

be retained for seven years after payment for the last reimbursement claim has been received for the school year. 

Federal regulation [7 CFR Part 210.13 (b)] requires the most recent food safety for each site inspection received from the local health department to be posted publicly.

To demonstrate compliance with food safety inspection requirements:

·       Contact the local health department to request a first food safety inspection.

·       Begin to retain food safety inspection documentation for seven years after payment is received for the last reimbursement claim for the school year.

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

Food Safety – Temperature Logs: During the on-site portion of this AR it was discovered DA was not maintaining temperature logs for cold storage units containing program food as required by their HACCP food safety plan and federal regulation [7 CFR Part 210.13 (c)]. 

To demonstrate compliance with temperature log requirements:

·       Begin maintaining temperature logs.

·       Provide copies of the temperature logs for the cold storage units at DA for February 2026.

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

 

Record Keeping: During the AR, Drexel Academy (DA) was unable to locate requested records.  Prior to and at the beginning of the school year, DA had several staff members including the SFA director leaving employment with DA.  This caused the DA to be unable to locate records to include the following records:

·       Financial records to include the revenue and expense report for school year 2024 – 2025.

·       The letter used to provide households notification of direct certification.

·       Training records including documentation of the training hours for employees with duties within the school food services program for prior school years.

·       Documentation of how data for program participants’ ethnicity and race is gathered.

The State of Oklahoma requires program documentation other than permanent documentation to be retained for seven years after payment for the last reimbursement claim has been received for the school year.

To demonstrate compliance with record keeping requirements

·       Retain program records for seven years after the last payment from the last reimbursement claim has been received from the school year.

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

Resource Management: During this review DA was unable to locate financial records for the Nonprofit School Food Services Account (NSFSA) for school year 2024 – 2025.  The State of Oklahoma requires financial documentation for USDA Child Nutrition Programs (in DA’s case the National School Lunch Program and the School Breakfast Program) to be retained for seven years after payment from the last reimbursement claim has been received from the school year (July 1 – June 30).

As part of the records DA was unable to locate were records demonstrating the end of school year revenue and expense report having been conducted for the NSFSA for school year 2024 – 2025. The report is conducted to verify the nonprofit status of the school food services account [as required by federal regulations 7 CFR Part 210.14 (a), 7 CFR Part 210.14 (b), and 7 CFR Part 210.19 (a) (1)].

To demonstrate compliance with resource management requirements:

·       Retain financial records for seven years after payment has been received for the last reimbursement claim the school year.

·       Make plans to conduct the revenue and expense report for school year 2025 – 2026 (07/01/25 – 06/30/26), all revenue and expenses have been received for the school year.

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

Procurement Review Summary Report

Date: 03-06-26

Name of Agency: Drexel Academy                                             Date of AR off-site review: 10-07-25

Reviewer: Matthew Smith                                                           Date of AR on-site review: 11-13-25                                           12/09/25, and 02-10-26

Persons interviewed: Dr. Reubin McIntosh and                           Date of exit conference: 03-02-26

                                    Eboni Knauls

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)

Code of Conduct: The code of conduct in place at the time the PR was opened had an individual designated with a responsibility for interpreting the code who is no longer with Drexel Academy (DA).  Federal regulations [2 CFR Part 200.318 (c) and 2 CFR Part 400.2 (b) (1)] requires School Food Authorities (SFA) to “…maintain written standards of conduct covering conflicts of interest and governing its employees engaged in the selection, award, and administration of contracts.”

To demonstrate compliance wit code of conduct requirements:

·       Revise the code of conduct to remove the individual no longer employed by DA and replace the name with the position title.

·       Provide the revised code of conduct along with DA’s plan for corrective action to demonstrate understanding and compliance.

Failure to Provide Records: During this PR, DA failed to provide requested records as required by federal regulation [7 CFR Part 210.9 (b) (17)] and DA’s agreement with Oklahoma Human Services (OKDHS).  The following requested record was not provided during the PR:

·       The detailed vendor list for school year 2024 – 2025 listing each purchase made with each vendor used.  DA stated they could not locate procurement records for school year 2024 – 2025.

During the on-site portion of the Administrative Review (AR), DA informed the reviewer they could not locate procurement records for school year 2024 – 2025.

To demonstrate compliance with requirements to provide records:

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

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.  The procurement plan also had staff members designated with responsibilities who were no longer employed by DA.  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.
• Update the procurement plan to designate the responsibilities for staff members no longer employed by DA to position titles.
• Provide the updated procurement plan, along with DA’s plan for corrective action to demonstrate understanding and compliance.

Record keeping: During this review DA was unable to locate procurement records. Federal regulation [2 CFR Part 200.318 (i)] requires SFAs to retain records sufficient to detail the history of each procurement transaction.  The State of Oklahoma requires these procurement records to be retained for seven years after payment is received for the last reimbursement claim for the school year.

To demonstrate compliance with record keeping requirements:

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

[1] “Laws may include but are not limited to: Title VI of the Civil rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, American with Disabilities Act of 2008, Age Discrimination Act of 1975, Civil Rights Restoration Act of 1987 (per USDA Memo CRD 01-2026).”

[2] “Regulations may include but are not limited to: 7 CFR 15, 7 CFR 16, 28 CFR 35, 28 CFR 36, 28 CFR 42, USDA Departmental Regulations, FNS Program Regulations (per USDA Memo CRD 01-2026).”

[3] “Laws may include but are not limited to: Title VI of the Civil rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, American with Disabilities Act of 2008, Age Discrimination Act of 1975, Civil Rights Restoration Act of 1987 (per USDA Memo CRD 01-2026).”

[4] “Regulations may include but are not limited to: 7 CFR 15, 7 CFR 16, 28 CFR 35, 28 CFR 36, 28 CFR 42, USDA Departmental Regulations, FNS Program Regulations (per USDA Memo CRD 01-2026).”