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Administrative Review Summary Report

Date:  09-19-18

Name of Agency:  Crossroads Youth and Family Services

            Date of off-site review: 07-17-18

Reviewer:  Matthew Smith                                                    Date of on-site review: 08-21-18

Persons interviewed:  Terran Manning                                   Date of exit conference: 08-21-18

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 local wellness policy for the SFA did not contain goals for other school based activities as required by 7 CFR Part 210.31 (c) (1).  The SFA took corrective action adding goals for other school based activities.
  • Meal Patterns: During the menu week assessment conducted as part of this AR for the week of 06/17/18—06/23/18, some non-systemic insufficient serving sizes were discovered for lunch meals on 06/22/18 and 06/23/18 [7 CFR Part 210.10 (c)].  The SFA corrected both of these insufficient serving sizes.  The breakfast meals served during the week the assessment the SFA met 85.71% of the weekly fruit component servings using 100% fruit juice [7 CFR Part 220.8 (c)] .  The SFA took corrective action by adding fresh fruit to the menu for the week bringing the weekly percentage of the fruit component met by using 100% fruit juice below 50%.
  • The SFA served non-creditable items as part of the meal components:  During the menu week assessment for the week of 06/17/18—06/23/18, the SFA served the following non-creditable items as part of the meal components of lunch meals (7 CFR Part 210 Appendix C):
    • The turkey franks served with the meal on 06/20/18.
    • The meatballs served with the meal on 06/22/18.

           The SFA took corrective action by replacing both items with items that could be credited.

  • Record Keeping Finding: During the menu week assessment it was discovered the production records completed for the breakfast and lunch meals did not reflect what was actually served as required by 7 CFR Part 210.10 (a) (3).  Through the cycle menu and other documentation the records were completed to reflect the meals served.  Prior to the On-Site portion of this review, the SFA provided production records demonstrating corrective action was taken, the production records completely documented the meals served.

Corrective action for the above was made prior to the conclusion 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 July 17, 2018:

Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of June 17 through 23, 2018; your agency did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at lunch, the School Breakfast Program, and the Afterschool Snack Program, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv).  For the breakfast meals during the menu week, the percentage for meeting whole grain rich was 90%.  For the lunch meals during the menu week, the percentage for meeting the whole grain rich requirement was at 79.1%.

The following items during the menu week assessed (June 17 through 23, 2018) were not WGR:

  • The muffins served with the breakfast meal on 06/21/18
  • The hoagie rolls served with the lunch meals on 06/22/18

The SFA took corrective action replacing the non-WGR items above prior to the On-Site Portion of this AR.  No further action is required for the above non-WGR items.

During the On-Site visit on 08/21/18, the SA reviewer discovered the rolls being served with lunch were not WGR.  The reviewer gave the SFA technical assistance and requested corrective action.  Also during the On-Site portion of the review the SA reviewer discovered the graham crackers served with snack on 08/20/18 were not WGR.  The reviewer gave technical assistance through email on 08/31/18, and requested corrective action.

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.

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

Counting and Claiming: A review of the counting system demonstrates non-systemic counting errors for the review period (June 2018), which results in a Performance Standard Violation I (PSI), 7 CFR Part 210.18 (g) (1) (ii).  These errors were non-systemic in nature and appeared to be human errors for two days during the review period (June 2018). 

The first of the human errors that occurred for the meal counts for breakfast and lunch meals appears to have happened during the transfer from the meal rosters to the edit check spreadsheets.  This error caused both the breakfast and lunch meal count for 06/13/18, to be over claimed by one meal for both the breakfast and lunch meal services.

The second of the human errors found were from the meal roster having a total of zero meals for both the breakfast and lunch meal rosters on 06/14/18.  The rosters had meals marked in the boxes next to the names, which appears to have caused the person who completes the edit check to claim six meals for breakfast and six meals for lunch.  This caused an addition over claim of six meals for both breakfast.

The following is the outcome for the SFA's School Breakfast Program (SBP) claim for June 2018:

  SFA OKDHS Diff.
Free 214 207 +7

The following is the outcome for the SFA's National School Lunch Program (NSLP) for June 2018:

  SFA OKDHS Diff.
Free 214 207 +7

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).  No other counting and claiming errors were found during the review period.  The errors above were determined to be non-systemic in nature by the SA reviewer.

These are serious, non-systemic errors in the counting and claiming system.They result in Performance Standard 1 Violations and require fiscal action [7 CFR Part 210.18 (g) (1) (ii) and 7 CFR Part 210.18 (I) (1)].

To demonstrate compliance with counting and claiming:

  • Review the counting and claiming system and create a plan to insure accurate consolidation of daily meal counts.
  • Provide copies of August 2018's completed meal rosters, a copy of August 2018's claim, and copies of August 2018's edit check forms, along with your corrective action plan to demonstrate understanding and compliance.   

Failure to provide requested records:  The SA reviewer requested the following documents and information on 08/31/18:

  • The After School Snack meal roster for August 2018
  • The After School Snack Program edit check for August 2018
  • The snack meal count for 08/21/18. 

2 CFR Part 210.9 (b) (17) requires all SFAs to provide upon request all "…accounts and records pertaining to its school food service to the state agency."  The SA reviewer
again requested the documents on 09/14/18.  At the time of this report your agency failed to provide the requested records.

To demonstrate compliance with providing requested records:

  • Provide the requested documents and snack meal count
  • Provide the above along with your corrective action plan to demonstrate understanding and compliance.

Reviewer's Comments:  I want to commend the agency for making corrective action for many of the findings for this review prior to the conclusion of the On-Site portion of this AR.   

Procurement Review Summary Report

Date:  09-19-18

Name of Agency:  Crossroads Youth and Family Services

                                                                                                       Date of AR off-site review: 07-17-18

Reviewer:  Matthew Smith                                                       Date of AR on-site review: 08-21-18

Persons interviewed:  Terran Manning                                   Date of exit conference: 08-21-18

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

There were no findings for the procurement review.

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

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