Administrative Review Summary Report

Date: 05-07-24

Name of Agency: Oklahoma Juvenile Justice Services, Inc. Date of off-site review: 03-07-24

Reviewer: Matthew Smith Date of on-site review: 04-09-24

Fiscal Action: Oklahoma Human Services (OKHS) is exercising its discretion to not assess fiscal action for the performance standard two violation as permitted by federal regulation [7 CFR Part 210.18 (g) (2)].

Persons interviewed: Thursa Roye and Date of exit conference: 05-03-24 Miceala Stevenson

Programs Operated by the School Food Authority (SFA): This 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):

Failure to Provide Records: Oklahoma Juvenile Justice Services, Inc. (OJJS) failed to provide records during the off-site portion of this AR necessary to complete the menu week assessment for this AR. Prior to the completion of the on-site portion, OJJS provided the requested records.
Professional Standards – Eight Hour Food Safety Training: OJJS’ new school food services director failed to complete eight hours of food safety training within the time periods required by federal regulation [7 CFR Part 210.30 (b) (1) (iv)]. Prior to the beginning of this AR, the director completed an eight-hour food safety training.
Professional Standards – Training Tracking: At the beginning of this AR, OJJS was not tracking employees (with duties in their school food services program) progress toward compliance with annual training requirements as required by federal regulation [7 CFR Part 210.30 (g)]. Prior to the completion of the off-site portion of this AR, OJJS began tracking training on a Oklahoma Human Services (OKHS) approved training tracking tool.

No further action is required for the above.

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted March 7, 2024:

Afterschool Snack Program – First Self-Monitoring Inspection: OJJS failed to conduct the first self-monitoring inspection of their Afterschool Snack Program within the first four weeks of school [as required by federal regulation 7 CFR Part 210.9 (c) (7)]. Federal regulation [7 CFR Part 210.69 (c) (7)] requires a second self-monitoring inspection be conducted before school ends for the school year.

To demonstrate compliance with Self-Monitoring Inspection requirements:

Provide OJJS’ plan for corrective action to demonstrate understanding and compliance.

Civil Rights – Written Procedure for Handling Civil Rights Complaints: OJJS’ written procedure for handling civil rights complaints did not contain all the current protected classes [as required by USD FNS Instruction 113 and USDA Memo CRD 01-2022].

To demonstrate compliance with requirements for written procedures for handling civil rights complaints:

Update OJJS’ written procedures for handling civil rights complaints to contain all the current protected classes.
Provide a copy of the updated written procedures for handling civil rights complaints, along with OJJS plan for corrective action demonstrating understanding and compliance.

Professional Standards – Training Records: At the time of the AR Off-Site, OJJS could not locate the training records for last school year (2022 – 2023). Federal regulation [7 CFR Part 210.15 (b) (8)] requires records demonstrating compliance with the annual training requirements be retained for at least three years after the last reimbursement claim for the school year has been received.

To demonstrate compliance with training record retention requirements:

Begin retaining training records for at least three school years after the last reimbursement claim for the school year has been received.
Provide OJJS’ plan for corrective action demonstrating understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted April 9, 2024:

Edit Checks: During the review of the counting and claiming system for the review period (February 2024) it was discovered the edit check process was not being conducted properly. OJJS was checking the meal counts totaled up by staff members taking the point of service count rather than checking the daily meal count against the residents present at the time of the meal service [as required by federal regulations 7 CFR Part 210.8 (a) (3) (i) and 7 CFR Part 220.11 (d)].

To demonstrate compliance with edit check requirements:

Begin conducting the daily edit checks as required by federal regulations [7 CFR Part 210.8 (a) (3) (i) and 7 CFR Part 220.11 (b)].
Provide a copy of the edit checks for April for breakfast, lunch, and snack.
Provide the above documentation along with OJJS’ plan for corrective action demonstrating understanding and compliance.

Meal Patterns: During the menu week assessed 02/18/24 – 02/24/24 there were some insufficient serving sizes for the lunch menus served.

The lunch meal pattern: Federal regulation [7 CFR 210.10 (c)] requires the following minimum serving sizes for the grades 9-12 meal pattern:

Meal Component	Required Serving
Bread/Grain	2 oz. by weight daily and 14 – 17 oz. per week

*All items used to meet the daily and weekly bread/grain servings must be Whole Grain-Rich.

Fruit

1 cup daily and 7 cups per week

*Up to half of the weekly serving can be met with the use of 100% fruit juice.

Meat/Meat Alternative	2 oz. by weight daily and 14 – 17 oz. per week
Milk	1 cup daily and 7 cups per week

*Students must be given a choice of milk from fat free unflavored, fat free flavored, and 1% unflavored.

**One of the choices must be unflavored.

Vegetable

1 cup daily and 7 cups per week

Vegetable Subgroups to be offered throughout the week

-Dark Green ½ cup -Red/Orange 1 ¼ cup -Legume ½ cup per week

-Starchy ½ cup -Other ¾ cup

Insufficient Quantities

The menu served on 02/24/24 had an insufficient daily serving for the meat/meat alternative component. The fish sticks served with this day’s menu only credited 1.5 oz. toward the daily serving for the meat/meat alternative component.
The required weekly serving for the dark green vegetable subgroup was not met. No vegetables could be credited toward this subgroup.

These 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).

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 OJJS for corrective action to demonstrate understanding and compliance.

OJJS served non-creditable food items as part of the meal component. During the menu assessment, for the week of 02/18/24 through 02/24/24 it was determined your agency is serving a non-creditable item. This was due to the product not having a Child Nutrition (CN) label issued by the USDA, or a product formulation statement issued by the manufacturer [as required by Appendix C to 7 CFR Part 210 and Appendix C to Part 220].

The chicken fajita meat served with the lunch menu served on 02/20/24.

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

Provide a CN label or product formulation statement for the product.
If product formulation statement(s) or CN labeling is not available, the product will have to be replaced. If this is the case, please provide a copy of the replacement creditable item’s labels. If the replacement is produced from a recipe, please provide the recipe.
Provide a copy of the above documentation, along with OJJS’ plan for corrective action to demonstrate compliance and understanding.

Production Records: OJJS was not completely filling out the production records. Federal regulations [7 CFR Part 210.10 (a) (3) and 7 CFR Part 220.8 (a) (3)] require SFAs to keep production records documenting how the meals produced are compliant with the meal patterns, as well as to be filled out in a manner providing data for proper providing data for meal planning.

To demonstrate compliance with production record requirements:

Begin completely filling out production records as required by federal regulations [7 CFR Part 210.10 (a) (3) and 7 CFR Part 220.8 (a) (3)].
Provide one breakfast production record and one lunch production record.
Provide the above documentation along with OJJS’ plan for corrective action demonstrating understanding and compliance.

Whole Grain Rich – Percentage of Weekly Serving Under 80%: During the assessment of breakfast and lunch menus for the week of 02/18/24 through 02/24/24 it was discovered the percentage of the bread/grain component weekly serving for the breakfast menus was under 80%. The percentage of the weekly serving of the bread/grain component serving for the breakfast menus was 50%. Federal regulations [7 CFR Part 210.10 (c) (2) (iv) (B) and 7 CFR Part 220.8 (c) (2) (iv) (B)] require the percentage of the weekly serving for the bread/grain component (for breakfast and lunch) to be at least 80% WGR.

To demonstrate compliance with WGR requirements:

Review the breakfast menus for the menu week assessed. Determine where changes can be made to bring the percentage of the weekly serving into compliance with the meal pattern.
Provide OJJS’ plan for corrective action to demonstrate compliance and understanding.

Procurement Review Summary Report

Date: 05-07-24

Name of Agency: Oklahoma Juvenile Justice Services, Inc. Date of AR off-site review: 03-07-24

Reviewer: Matthew Smith Date of AR on-site review: 04-09-24

Persons interviewed: Thursa Roye and Date of exit conference: 05-03-24

Miceala Stevenson

Programs Operated by the School Food Authority (SFA): This 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 for Oklahoma Juvenile Justice Services, Inc.