Date: 04-16-21

Name of Agency: Saint Catherine School   Date of off-site review: 02-02-21

Reviewer: Matthew Smith                            Date of 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.

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted February 2, 2021:

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.

Local Wellness Policy: The SFA’s local wellness policy needs to have the following added:

• Guidelines and standards for the marketing of food and beverages on campus during the school day [as required by 7 CFR Part 210.31 (c) (3) (iii)].
• A plan for measuring the implementation of the policy [as required by 7 CFR Part 210.31 (c) (6)].
• Designation of personnel responsible for ensuring the policy is implemented [as required by 7 CFR Part 210.31 (e) (1)]. It is recommended no more than two people be designated with this responsibility.
• Designation of personnel responsible for assessing the policy [7 CFR Part 210.31 (e)]. It is recommended no more than two people be designated with this responsibility.

When changes to the local wellness policy occur review them with the committee and post the policy changes where you publicly post the policy. Once you review and update your policy, consider the policy updated for this program year. An evaluation of program requirements must occur once during a 3-year cycle and any other time the agency or committee identifies the need for updating. All policy updates need to be documented in a wellness assessment report, USDA Memo SP24-2017. The wellness report needs to be posted publicly as required by 7 CFR Part 210.30 (E) (2). To demonstrate compliance with the local wellness policy:

• ·Add the following to the local wellness policy
  •  Guidelines and standards for the marketing of food and beverages.
  •  A plan for measuring the implantation of the policy.
  • Designation of personnel with the responsibility for ensuring the implementation of the policy.
  • Designation of personnel with the responsibility for assessing the policy.
• Provide a copy of the updated local wellness policy with the required changes listed above.
• Provide the above requested documentation along Saint Catherine School’s (SCS) plan for corrective action to demonstrate compliance and understanding.

Professional Standards: SCS’ school food services director (Jerry Gardner) failed to complete 12 hours of training that could be credited toward the annual training requirements during school year 2019-2020. During school year 2019-2020, the director completed 10.5 hours that could be credited toward the annual training requirements. Federal regulations [7 CFR Part 210.30 (b) (3), 7 CFR Part 210.31 (c), 7 CFR Part 210.30 (d), and 7 CFR Part 210.30 (e)]:

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.