Administrative Review Summary Report

Date: 10-19-20

Name of Agency: Oklahoma Juvenile Justice Services, Inc. Date of off-site review: 07-13-20

Reviewer: Matthew Smith Date of on-site review: 09-10-20

Persons interviewed: Angela Herring and Date of exit conference: 10-07-20

Thursa Roye

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):

Afterschool Snack Program Monitoring Checklist: During school year 2019-2020 Oklahoma Juvenile Justice Services, Inc. (OJJS) failed to complete the self-monitoring reviews [7 CFR Part 210.9 (c) (7)]. During the off-site portion of this AR, OJJS completed the self-monitoring reviews for school year 2019-2020.
System for Award Management (SAM) Registration: OJJS failed to register with SAM as required by OKDHS School Nutrition Program. Prior to the On-Site portion of this AR the SFA took corrective action by completing the registration process for SAM.

Corrective action for the above was made prior to 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 13, 2020:

Buy American Provision: During the Off-Site portion of the AR, a food product was found that were not domestically produced. 7 CFR Part 210.21 (d) requires SFAs when possible to buy domestically produced food products. Limited exceptions to the requirements to procure domestically produced food products are permitted. USDA memo SP-24-2016 documents the following exceptions to this requirement:

The food product is not produced or manufactured within the United States
The food product is not produced or manufactured domestically in sufficient quantities.
The food product is not produced or manufactured domestically in satisfactory quality.
The costs of domestically produced or manufactured food products are significantly higher in cost than non-domestic products.

If a SFA is going to use one of the above exceptions they must keep documentation justifying the exception.

The following food products were found during the Off-Site portion of this AR that were not domestically produced or manufactured:

The canned pineapple product served with the lunch served on 06/22/20, was a product of the Philippines.
The caned mandarin oranges product served with the lunch served on 06/26/20, was a product of China.

OJJS did not have documentation justifying the use of these products under one of the permitted exceptions. Work with your vendors to ensure the products used in your program are compliant with the buy American provision. When you determine it is necessary to use one of the permitted exceptions, make sure you keep documentation to justify its use.

To demonstrate compliance with the buy American provision:

Review the products that are used in OJJS' school nutrition program for compliance with the buy American provision.
Provide OJJS' corrective action plan to demonstrate understanding and compliance.

Milk Variety: OJJS served only one variety of milk (1% unflavored milk) with breakfast meals during the week of 06/22/20 through 06/28/20. 7 CFR Part 220.8 (d) requires at least two types of fluid milk be offered with each breakfast meal from a choice of at least two varieties (one of the choices must be unflavored fat free milk or 1% unflavored milk):

Fat free unflavored milk
Fat free flavored milk
1% unflavored milk

Only the above varieties can be offered as part of the School Breakfast Program (SBP).

7 CFR Part 210.18 (I) (2) (ii) (A) requires all meals served where no milk variety is offered [as required by 7 CFR Part 210.10 (d) and 7 CFR Part 220.8 (d)] to be disallowed through fiscal action. Therefore, all the breakfast meals served during the week of 06/22/20 through 06/28/20 will be disallowed.

To demonstrate compliance with milk variety requirements:

Begin offering at least two varieties of milk from the list above (one of the varieties must be unflavored).
Provide OJJS' corrective action plan to demonstrate understanding and compliance.

Professional Standards: Records and documentation of training completed during school year 2019-2020 were not kept for employees with duties within OJJS school food services program. Federal regulations [7 CFR Part 210.30 (g)] requires School Food Authorities (SFA) to document compliance with the annual training requirements. This required documentation will demonstrate compliance with the training requirements documented in 7 CFR Part 210.30 (b) (3), 7 CFR Part 210.30 (c), 7 CFR Part 210.30 (d), and 7 CFR Part 210.30 (e). The following are the training requirements documented in the preceding regulations:

Job Category*	Annual Requirements
Directors	12 hours
Managers	10 hours
Staff (full time)	6 hours
Part-Time Staff (working less than 20 hours per week in the SFA's school nutrition program)	4 hours
Mid-year hires in all categories (January 1^st or later)	One-half of training requirement for each job category.

*Your SFA may not have all the job categories listed above. All SFA's have a director.

The above training requirements are required to be completed every school year (July 1^st to June 30). USDA Memo SP 39-2015 requires SFAs to use an approved training tracking tool. During the AR the State Agency (SA) Reviewer emailed the SA approved training tracking tool provided by email on August 10, 2020. 7 CFR Part 210.30 (g) requires the SFA each year to document the compliance with training requirements. Training should be documented on the training tracking tool throughout the school year, best practice is to add the training as it is completed. This will ensure all the training gets entered into the tool.

Begin keeping records on a training tracking tool of trainings completed by staff members with duties within OJJS' school food services program.

Trainings that can be credited toward the professional standards annual training requirements include [7 CFR Part 210.30 (b) (3), 7 CFR Part 210.30 (c), and 7 CFR Part 210.30 (d)]:

Meal counting and the reimbursement claim procedures
Identification of reimbursable meals at the point of service
Annual civil rights training
Nutrition
Health and safety standards

To demonstrate compliance with professional standard requirements:

Begin keeping documentation on trainings completed by staff members with duties within OJJS school food services programs.
Begin tracking training on the SA approved tracking tool provided by email on 08/20/20.
Provide OJJS' plan for corrective action to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted September 10, 2020:

Meal Patterns:On the day of review, 09/10/20, an insufficient serving size was discovered for the lunch meals.

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

Insufficient daily serving size for the bread/grain component for the lunch meals served on 09/10/20. Crackers were served that only credited 0.5 oz. toward the daily bread/grain component. No other items that could be credited toward this component were served. The minimum daily serving size for the bread/grain component for grades 9-12 is 2 oz. [7 CFR Part 210.10 (c)].

The above insufficient serving size was determined to be non-systemic in nature. The State Agency (SA) is exercising its discretion to not apply fiscal action for the above insufficient quantity 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 OJJS' 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 OJJS' plan for corrective action to demonstrate understanding and compliance.

Reviewer's Comments: I want to commend Angela Herring and Thursa Roye for their work on OJJS' school food services program.

Procurement Review Summary Report

Date: 10-19-20

Name of Agency: Oklahoma Juvenile Justice Services, Inc. Date of AR off-site review: 07-13-20

Reviewer: Matthew Smith Date of AR on-site review: 09-10-20

Persons interviewed: Angela Herring Date of exit conference: 10-07-20

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):

Buy American Provision: During the Off-Site portion of the AR, a food product was found that were not domestically produced. 7 CFR Part 210.21 (d) requires SFAs when possible to buy domestically produced food products. Limited exceptions to the requirements to procure domestically produced food products are permitted. USDA memo SP-24-2016 documents the following exceptions to this requirement:

The food product is not produced or manufactured within the United States
The food product is not produced or manufactured domestically in sufficient quantities.
The food product is not produced or manufactured domestically in satisfactory quality.
The costs of domestically produced or manufactured food products are significantly higher in cost than non-domestic products.

If a SFA is going to use one of the above exceptions they must keep documentation justifying the exception.

The following food products were found during the Off-Site portion of this AR that were not domestically produced or manufactured:

The canned pineapple product served with the lunch served on 06/22/20, was a product of the Philippines.
The caned mandarin oranges product served with the lunch served on 06/26/20, was a product of China.

The SFA did not have documentation justifying the use of these products under one of the

permitted exceptions. Work with your vendors to ensure the products used in your program are compliant with the buy American provision. When you determine it is necessary to use one of the permitted exceptions, make sure you keep documentation to justify its use.

To demonstrate compliance with the buy American provision:

Review the products that are used in your school nutrition program for compliance with the buy American provision.
Provide OJJS' corrective action plan to demonstrate understanding and compliance.