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Administrative Review Summary Report

Date:  09-20-17

Name of Agency:  Youth Services for Oklahoma County               Date of off-site review: 07-13-17

Reviewer:  Matthew Smith                                                                  Date of on-site review: 08-24-17, 08-26-17, and 09/19/17

Persons interviewed:  Christina Craft                                                Date of exit conference: 09-19-17

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

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted July 13, 2017:

Meal Patterns:A review of 06/18/17 through 06/24/17 indicated some insufficient portion sizes at breakfast and lunch.

The breakfast meal pattern 7 CFR Part 220.8 (c) requires the following minimum serving sizes; 1oz. by weight bread/grain daily and 12.5-14 oz. per week, 1 cup Fruit, and 1 cup fluid milk, offered as a choice between 1% and fat free.   No more than 50% of the fruit components for a menu week can be met with 100% fruit juice.

Insufficient quantities

  • The weekly 100% fruit juice serving limit was exceeded the maximum 50% of the fruit components served during the week.  The percentage of 100% fruit juice served to meet the fruit component during the week assessed was 68.83%.  

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 06/24/17 the daily serving size for the meat/meat alternative component was insufficient.  This meal only credited 1.50 oz. toward the meat/meat alternative component daily serving size.  This insufficient serving size was due to the sliced cheese only crediting at 0.5 oz. per slice.  

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 the insufficient serving size into compliance with the meal patterns for grades 9-12.
  • Bring the menu week percentage of the fruit component being met by use of 100% fruit juice under the maximum level of 50%.
  • Submit your plan for corrective action to demonstrate understanding and compliance.    

Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of June 18 through 24, 2017; your agency did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at breakfast and lunch, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv).   For breakfast the percentage for meeting the whole grain rich requirement was 75%.  For the lunch the percentage for meeting the whole grain rich requirement was at 100%.

  • 06/20/17 the pancake batter used to make pancakes was not WGR.
  • 06/21/17 the pancake batter used to make waffles was 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.

The SFA served non-creditable food item as part of the meal component.  During the menu assessment it was determined your school is serving a non-creditable item. In order for the items to be creditable they must contain a CN label or an acceptable production formulation statement, 7 CFR 210 Appendix C.  Crediting information for USDA commodities can be found on the commodity fact sheets available on the USDA website. The following item was identified as non-credible:

  • The turkey sausage served with the breakfast meal on 06/20/17.

Finding CN labeled products can be challenging. Remember; items similar to CN labeled products, but not the same, are not acceptable. Your ability to purchase food from suppliers with experience serving schools should allow your staff to obtain acceptable products. If all attempts fail and you are unable to obtain CN labels for the items you serve, your only choices are; discontinue serving the item or cook the item from scratch. When scratch cooking; we recommend using the USDA recipes because they will eliminate the panning needed when scratch cooking.

If a food is non-creditable and no other creditable foods are offered, the serving is considered insufficient.  The USDA now considers insufficient serving sizes to be "missing components". Finding of missing components on subsequent reviews will be considered reoccurring and our office may have to access fiscal action.

To demonstrate compliance with the CN label/product specification requirement:

  • Obtain and provide a copy of the needed product formulation statements. Work with venders and sales representatives to obtain this documentation. 
  • If product formulation statement(s) or CN labeling is not available, provide a copy of the replacement creditable item's labels.
  • Provide a copy of your corrective action plan along with the documentation list to demonstrate understanding and compliance.  

Reviewer's Comments:I would like to commend Youth Services for Oklahoma County (YSOC) for doing an excellent job in running the National School Lunch Program, the School Breakfast Program, and the After School Snack Program.  In particular I would like to commend Christina Craft for doing an excellent work in administering these programs for YSOC.  The areas covered in the above sections are areas that some work is needed. It is normal for the Administrative Review (AR) process to find areas that some tinkering is needed in order to bring programs into compliance with federal regulation.  Again I want to communicate this AR went really well.

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