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Administrative Review Summary Report

Date:  12-10-19

Name of Agency:  Peace Academy

                                                                                                   Date of off-site review: 10-14-19

Reviewer:  Matthew Smith                                                    Date of on-site review: 11-21-19

Persons interviewed:  Shazia Malik                                      Date of exit conference: 11-21-19

This School Food Authority (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):

  • Civil Rights:  The SFA's website did not have the non-discrimination statement on the Al Café web page [FNS Instruction 113-1]. Prior to the completion of the On-Site portion of the AR the non-discrimination statement was added to the website.



    The documentation that the SFA provided for the last annual civil rights training did not contain all the required topics contained in FNS Instruction 113-1.  Prior to the On-Site visit the SFA conducted a civil rights training that contained all of the required topics. 
  • Local Wellness Policy: The most recent documentation of the most recent update to the policy and the updated local wellness policy were not posted publicly at the time of the Off-Site visit [7 CFR Part 210.31 (d) (2) and 7 CFR Part 210.31 (d) (3)].  Prior to the completion of the On-Site portion of this AR both documents were posted to the SFA's website.
  • Record Keeping:  A review of the production records conducted during the assessment of breakfast and lunch menus for the week of 09/16/19 through 09/20/2019 indicated some issues with documentation on the production records [7 CFR Part 210 (a) (3)].  At the time of the On-Site visit the SFA provided production records for one breakfast meal and one lunch meal that demonstrate compliance with 7 CFR Part 210.10 (a) (3) accurately documenting reimbursable meals were being served.

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 October 14, 2019:

Direct Certification:  Peace Academy failed to submit the school's direct certification list by the August 1, 2019 deadline.  7 CFR Part 245.6 (b) (3) (ii) requires SFAs to submit their direct certification list to the State Agency (OKDHS School Nutrition Programs), by the following deadlines during each school year:

  • August 1st
  • August 20th
  • October 20th
  • February 1st

OKDHS School Nutrition Programs provides by email SFAs with the spreadsheet for direct certification and instructions on how to fill out and submit the spreadsheet prior to each direct certification deadline listed above.

To demonstrate compliance with direct certification requirements:

  • Submit Peace Academy's corrective action plan to demonstrate understanding and compliance direct certification deadlines.

Local Wellness Policy:  Peace Academy has the following areas need to be added to the SFA's local wellness policy:

  • The policy does not designate personnel designated with the responsibility for assessing the policy as required by 7 CFR Part 210.31 (c) (4) and 7 CFR Part 210.31 (e) (1).   No more than two people should be designated with this responsibility.
  • The policy also does not designate personnel with the responsibility for implementing the policy [7 CFR Part 210.31 (c) (4) and 7 CFR Part 210.31 (e) (1)].  No more than two people should 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 and the policy need to be posted publicly as required by 7 CFR Part 210.31 (d) (2) and 7 CFR Part 210.31 (d) (3).   

To demonstrate compliance with local wellness policy requirements:

  • Designate personnel in the local wellness policy with the responsibility for assessing the local wellness policy.
  • Designate personnel in the local wellness policy with the responsibility for ensuring the implementation of the policy.
  • Post updated local wellness policy publicly on the Al Café web page or on a public bulletin board at Peace Academy.
  • Provide a copy of the policy to include the personnel designations along with Peace Academy's corrective action plan to demonstrate compliance and understanding.

Meal Patterns:A review of 09/16/19 through 09/20/19 indicated some insufficient portion sizes at lunch.

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes;

For grades K-8: 1 oz. by weight meat/meat alternate daily and 9-10 oz. per week, 1 oz. by weight bread/grain daily and 8-9 oz. per week, ½ cup fruit daily and 2 ½ cups per week, ¾ cup vegetables daily (dark green subgroup ½ cup/week, red/orange subgroup ¾ cup/week, legumes subgroup ½ cup/per week, starchy subgroup ½ cup/week, and other subgroup ½ cup/week) 3 ¾ cups/week, and 1 cup fluid milk daily, 5 cups weekly, offered as a choice between 1% and fat free.

For grades 9-12: 2 oz. by weight meat/meat alternate daily and 10-12 oz. per week, 2oz. by weight bread/grain daily and 10-12 oz. per week, 1 cup fruit daily and 5 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) 5 cups/week, and 1 cup fluid milk daily, 5 cups weekly, offered as a choice between 1% and fat free.

Insufficient quantities

  • On 09/18/19, for grades 9-12, the bread used for the sandwich served with the meal credited at 1.75 oz. for two slices.  

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 all insufficient serving sizes and missing components in compliance with the meal patterns for grades 9-12.
  • Submit your plan for corrective action to demonstrate understanding and compliance.

Resource Management:  The balance of the Nonprofit School Food Services Account (NSFSA) exceeded three months average operating expenses at the time the end of the year revenue and expense report was conducted.  7 CFR Part 210.14 (b) requires the NSFSA to have a balance at or below three months average operating expenses.  Peace Academy's three months average operating expenses was $19,857.31, the end of year balance for the NSFSA was $26, 939.18.  The balance was $7,081.87 over the allowed three months average operating expenses. 

When revenue exceeds three months' average operating cost, the SFA must find ways to use the money for food service.  The excess money ($7,081.87) must be spent on expenses that are allowable and should be used only for the operation and improvement of school food service (the Administrative Review cannot be closed until the excess has been spent).  Improving food quality or environment should always be an option. 

To demonstrate compliance with resource management requirements:

  • Provide a written plan on how the excess balance in the NSFSA will be spent.
  • Submit the above along with Peace Academy's corrective action plan to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted November 21, 2019:

Eligibility Certification:  During the review it was determined that two applications were certified in error. The first application with a certification error resulted in one student receiving reduced price meals when the student should have been receiving free meals.  The second application with a certification error resulted in one student receiving free meals when the student should have been receiving reduced priced meals.  Both errors appear to have been made by the determining official looking at the wrong part of the eligibility table when determining these two applications. These errors resulted in a Performance Standard I (PSI) Violations, 7 CFR Part 210.18 (g) (1). 

During the On-Site portion of the AR the SFA the applications with the errors were brought to the SFA's attention.   7CFR Part 245.6 (c) (3) (iii) requires the SFA to send notification to the households in writing, and allow 10 calendar days for a possible hearing request for the household when benefits are reduced. 

The school-reviewing official must review each incoming application to ensure that the household submitted a complete application. If the application is complete, the official must then determine whether the household is categorically eligible or income eligible for benefits. It is recommended that someone come behind the determining official and double check the math and benefit category.  A space is provided on the application for a second person to sign off on the determination.

This is a Performance Standard 1 (PS 1) violation which requires fiscal action, 7 CFR Part 210.18 (g) (1).

To demonstrate compliance with eligibility certification requirements:

  • Inform the households in writing of their change in benefits status, allow 10 days for a possible hearing request
  • Once the 10 calendar day timeframe has past, change the benefits status from free to reduced meal eligibility.
  • Provide copies of the letters sent, date changes were made and your written corrective action plan to demonstrate understanding and compliance.  

Reviewer's Comments:  I want to commend the staff members and volunteers who work with the SFA's school nutrition programs on a job well done during this review.   Keep up the good work.  

Procurement Review Summary Report


 

Date:  12-10-19

Name of Agency:  Peace Academy
                                                                                         Date of AR off-site review: 10-14-19

Reviewer:  Matthew Smith                                          Date of AR on-site review: 11-21-19

Persons interviewed:  Shazia Malik                            Date of exit conference: 11-21-19

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

The following areas were corrected during the Procurement Review (PR):

 

  • Procurement Plan: At the time of the PR was commenced, the procurement plan  provided did not document the steps taken to assure that minority and women's small business enterprises and labor surplus firms are used when possible [2 CFR Part 200.321].  During the PR Peace Academy provided a plan that documented the above.

Corrective action for the above was made during the PR.  No further action is required for the above

There were no additional findings regarding procurement.

Reviewer's Comments:  Peace Academy's personnel is doing a good job complying with the federal regulations regarding procurement.

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