Skip to main content

Administrative Review Summary Report

Date:  02-23-21

Name of Agency:  Saints Peter and Paul Catholic School                  Date of off-site review: 10-01-20

Reviewer:  Matthew Smith                                                                      Date of on-site review: 11-12-20

Persons interviewed:  Joanne Brown and                                               Date of exit conference: 02-19-21
                                     Jennifer Mullins

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):

  • Resource Management – Indirect Costs:  During school year 2019-2020 Saints Peter and Paul Catholic school (SPPCS) was charging indirect costs to their Nonprofit School Food Services Account (NSFSA) [7 CFR Part 200.57] without an indirect cost rate agreement.  Prior to the completion of the on-site portion of this AR SPPCS took corrective action by directing their financial personnel to no longer charge indirect costs to their NSFSA.

  • Verification:  During school year, 2019-2020 SPPCS verified eight household applications. This exceeded the requirement of only verifying three percent of the approved household applications on file on October 1, 2019 [7 CFR Part 245.6a].  The SFA should have only verified four approved household applications (103 on file on 10/1/19).  The SFA took corrective action by verifying only three percent of the household applications on file on October 1, 2020 for the verification process for school year 2020-2021.
 

Corrective action for the above were made prior to the On-Site portion of this AR.  No further action is required

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted October 1, 2020:

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 during the school day [as required by federal regulation, 7 CFR Part 210.31 (c) (3) (iii)].  These guidelines and standards should have their own section of the policy, and must cover Saints Peter and Paul Catholic School’s (SPPCS) existing guidelines and standards for the marketing of food on campus during the school day, or the guidelines and standards adopted for the marketing of food and beverages on campus during the school day.  Federal regulation [7 CFR Part 210.11 (a) (5)] defines the school day as “…the period from midnight before, to 30 minutes after the end of the official school day.”
  • The local wellness committee membership [as required by federal regulations, 7 CFR Part 210.31 (c) (5) and 7 CFR Part 210.31 (d) (1)].   Each member of the committee should be listed along with their relationship to SPPCS.

To demonstrate compliance with the local wellness policy:

  • Add guidelines and standards for the marketing of food and beverages on campus during the school day to the local wellness policy.
  • Add the local wellness committee membership to the local wellness policy
  • Provide a copy of the updated local wellness policy with the required changes listed above.
  • Provide the above requested documentation along with SPPCS’ plan for corrective action to demonstrate compliance and understanding.   

Professional Standards:  During school year 2019-2020, two of the full time staff members failed to meet the annual six hour  training requirement [as required by 7 CFR Part 210.30 (d)].  Only five of the training hours completed by the full time employee in question could be credited toward the annual training requirements.  Federal regulations [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)] have the following annual training requirements:

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 1st 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.

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

For school year 2020-2021, the school food services director has completed seven hours of training. The school food services director will need to complete an additional five hours of creditable training to meet the 12 hours required prior to June 30, 2021.

Your food services full time employees all have seven hours of training that could be credited toward the annual training requirements, thus completing the required training hours for school year 2020-2021. 

To demonstrate compliance with professional standard requirements:

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

Resource Management – Unpaid Meal Charge Policy:  The unpaid meal charge policy does not address the steps leading up to the households unpaid meal charges being charged as bad debt and being paid for by funds not from the nonprofit school food services account.  USDA Memos SP46-2016 and USDA Memo SP23-2017 requires SFAs to have an unpaid meal charge policy that communicates how the funds will be collected to pay the unpaid meal charges.

To demonstrate compliance with unpaid meal charge policy requirements:

  • Develop an unpaid meal charge policy that addresses the steps leading up to the endowment paying households unpaid meal charges.
  • Provide a copy of the update meal charge policy along with SPPCS’ corrective action plan to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted November 12, 2020:

Benefit Issuance Document:  Errors were discovered on the Benefit Issuance Document (BID) during the review of household applications and direct certification documentation.

Three students were listed on the SPPCS’ BID as being approved for reducedo8 priced meals (as of 01/22/21), when all three students were listed on direct certification documentation received by SPPCS. 

Federal regulation [7 CFR Part 245.6 (b)] requires SFAs to make adjustments in eligibility determinations when direct certification lists are received throughout the school year.  When receiving each direct certification list SFAs should compare the list to their BID and make updates and changes as needed.

SPPCS made the changes in their point of service system and on their BID on 01/22/21, changing all the affected students from reduced priced meals to free meals, as well as to send letters to the affected households on 01/25/21.

To demonstrate compliance with Benefit Issuance Document (BID) requirements:

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

Reviewer’s Comments:  I want to commend all the staff members who work with the SPPCS’ school food services program on the good work they are doing with their programs.  Keep up the good work

Procurement Review Summary Report

Date:  02-23-21

Name of Agency:  Saints Peter and Paul Catholic School                  Date of AR off-site review: 10-01-20

Reviewer:  Matthew Smith                                                                       Date of AR on-site review: 11-12-20

Persons interviewed:  Joanne Brown and                                               Date of exit conference: 02-19-21
                                      Jennifer Mullins

This School Food Authority (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.

Reviewer’s Comments:  I want to commend Jennifer Mullins on a job well done on Saints Peter and Paul Catholic School’s compliance with federal procurement regulations.

Back to Top