Date: 02-13-25

Name of Agency: Saint Catherine School                                    Date of off-site review: 11-07-24

Reviewer: Matthew Smith                                                               Date of on-site review: 12-12-24

Fiscal Action: None assessed                                                                 

Persons interviewed: Micelle Anthamatten and                          Date of exit conference: 02-03-25

                                    Suzanne Hayes

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):

·       Meal Patterns:  During the menu week assessment of breakfast and lunch menus for the week of 10/21/24 – 10/25/24, insufficient serving sizes were discovered for one breakfast menu.  Prior to the completion of on-site portion of this AR, Saint Catherine School (SCS) took corrective action brining the menu into compliance with the minimum daily serving sizes

No further action is required for the above. 

 

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

Production Records:  During the menu week assessed the production records were not filled out as required to “…show how the meal offered contribute d to the required meal components and food quantities for each age/grade group every day [as required by federal regulations 7 CFR Part 210.10 (a) (3) and 7 CFR Part 220.8 (a) (3)].”

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 documents along with Saint Catherine School’s (SCS) plan for corrective action to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted December 12, 2024:

There were no findings for the on-site portion of this AR.

Reviewer’s Comments: I would like to commend St. Catherine School for all the hard work being done by dedicated employees in the school food services program. Your team is fantastic, keep up the good work!

Procurement Review Summary Report

Date: 02-13-25

Name of Agency: Saint Catherine School                                    Date of AR off-site review: 11-07-24

Reviewer: Matthew Smith                                                               Date of AR on-site review: 12-12-24

Persons interviewed: Michelle Anthamatten and                        Date of exit conference: 02-03-25

                                    Suzanne Hayes

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 during the Procurement Review (PR):

·       Procurement: At the time of the PR was commenced, Saint Catherine School (SCS) provided a procurement plan that was incomplete which caused it to not fully document procurement practices as required by federal regulations [2 CFR Part 200.318 (a), 7 CFR Part 210.21 (c), and 7 CFR Part 220.16 (c)].  During the PR SCS provided a procurement plan compliant with federal regulations.

No further action is required for the above.

Findings for the Procurement Review (PR)

Solicitation Document:  The solicitation document used in the use of the small purchase method to procure a vendor for school year 2023 – 2024, did not contain required language, or all the products purchased during the school year. 

The solicitation document also did not contain this language “…requiring the purchase of foods that meet the Buy American Provision in all procurement procedures, solicitations, and contracts [as required by federal regulation 7 CFR Part 210.21 (d) (3) and 7 CFR Part 220.16 (d) (3)].”

During a review of selected vendor invoices, products were discovered that were not listed in SCS’ solicitation document.  Federal regulation [2 CFR Part 200.319 (a)] requires “all procurement transactions to be completed in a manner that provides full and open competition.”  Had all the products been listed in the solicitation document, it could have caused the selected vendor and other potential vendors to respond differently.  Including all the products to be purchased during the school year, also could have caused the potential vendor not providing a response to respond to the solicitation document.

To demonstrate compliance with solicitation document requirements:

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

Technical Assistance (not a finding)

Small Purchase Method:  During the procurement process for the vendor used for school year 2023 – 2024, SCS only received one response to their solicitation prior to selecting the only responding vendor.  Federal regulations [2 CFR Part 200.319 (c) (1) and 2 CFR Part 200.320 (a) (2) (i)] require School Food Authorities (SFA) to receive responses be received from an adequate number of qualified sources prior to a determination being made on a vendor.  The USDA has determined a non-response as not being an appropriate bidder response.

OKDHS School Nutrition Programs (SNP) recommends contacting at least three or more vendors to ensure at least two responses are received to a solicitation.  The Tulsa metropolitan area has additional vendors that service schools other than the two SCS contacted during school year 2023 – 2024.

SFA are required to retain “…records sufficient to detail the history of each procurement transaction [as required by federal regulation 2 CFR Part 200.318 (i)].  These records to be retained for at least three school years plus the current school year.

Training must be completed by June 30th of each school year (the school year begins on July 1st)

 

Trainings that can be credited toward annual training requirements include (but are not limited to):

• Eligibility determination
• Verification process
• Annual civil rights training
• Meal counting and the reimbursement claim procedures
• Nutrition health and safety standards
• HACCP food safety topics
• Procurement in school nutrition programs

To demonstrate compliance with professional standard requirements:

• Provide SCS’ corrective action plan to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted March 11, 2021:

Record Keeping: A review of the production record for the lunch menu served for the day of review (03/11/21) conducted during this AR indicated an issue with documentation on the lunch production record for the day of review (03/11/21). The following issue was noted:

• The production record for the day of review (03/11/21) had a serving size for the broccoli served as ½ cup. Pictures of the serving spoon documented a ¾ cup serving size for the broccoli.

To insure proper integrity, documentation of food production should accurately note the amount of servings planned (including adults and second servings), the actual serving sizes for each item and the total amount of food product used to prepare the meal. 

For serving sizes, document the serving sizes planned and served. For meats and meat entrees list the number of pieces, one slice, one burger, one sandwich, or serving in ounces 

(ex. 5 nuggets or 2 ounces slice). Ounces should reflect only the actual serving size and will be rarely used. Unless fresh fruit is being served, fruits and vegetable are primarily list by cup size (ex. 1 whole banana, ½ Cup diced pears or ¾ Cup green beans). Using standardized recipes will help the agency in planning for the correct serving size. 

For the total amount prepared, use actual weights. For meats or fresh vegetables, list the weight (ex. 10 lbs., 5 ounces) or total number of pieces prepared. For canned vegetables and fruits, document the weight of the can or specify the can size (ex. 2, 108 oz. cans or 1, # 10 can). For breads, pastas and grains, document the total weight or number of slices. For milk, document the number of gallons or pints used. 

For the planned number of servings, documentation of food production should accurately note the amount of servings planned (including adults and second servings). 

SFAs are required to keep production records for all the meals that are produced and claimed for reimbursement [7 CFR Part 210.10 (a) (3)]. Federal regulation 7 CFR Part 210.10 (a) (3) requires the production record show:

"…how the meal offered contributes to the required food components and food quantities for each grade served every day." The production records are a part of the documents supporting a SFA's reimbursement claim and are required to be kept for at least three school years [7 CFR Part 210.20 (b) (14)]. 

To demonstrate compliance with Production Documentation:

• Staff should begin immediately completing the daily production records by; listing all items served, listing components in the proper categories and documenting actual serving sizes.
• Ensure production records are complete.
• Provide a copy of one lunch production record
• Provide the above along with SCS’ corrective action plan to demonstrate understanding and compliance.

Reviewer’s Comments: I want to commend the staff members who work with the SFA’s school nutrition programs on a job well done during this review. All the agency staff members that I interacted with were professional and provided everything I requested in a timely fashion.

Date: 04-16-21

Name of Agency: Saint Catherine School

                                                                    Date of AR off-site review: 02-02-21

Reviewer: Matthew Smith                        Date of AR on-site review: 03-11-21

Persons interviewed: Suzanne Hayes     Date of exit conference: 03-30-21

This School Food Authority (SFA) operates the National School Lunch Program.

Buy American Provision: During the menu week assessment, a food product was discovered that was no domestically produced. Federal regulation [7 CFR Part 210.21 (d)] requires School Food Authorities (SFA) 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.

The following food product was discovered during the menu week assessment conducted as part of this AR that were not produced or manufactured domestically:

• Mandarin oranges that were produced in China that were served with the lunch meals served on 01/12/21.

Saint Catherine School (SCS) did not have documentation justifying the use of this nondomestic product under one of the permitted exceptions. SFAs should work with their vendors to ensure the food products used in your school food services program are compliant with the Buy American Provision. When a SFA determines it is necessary to use one of the permitted exceptions, the SFA must ensure documentation is kept to justify its use.

To demonstrate compliance with the Buy American Provision:

• Review the food products used in your school food services program for compliance with the Buy American Provision.
• Provide SCS’ corrective action plan to demonstrate understanding and compliance.

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