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Administrative Review Summary Report

Administrative Review Summary Report

Date:  12-19-19

Name of Agency:  St. Anthony Behavioral Medicine Center

                                                                                                         Date of off-site review: 11-07-19

Reviewer:  Matthew Smith                                                         Date of on-site review: 12-12-19

Persons interviewed:  Rebecca Laprarie and                           Date of exit conference: 12-12-19

                                        Angela Harrison

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):

  • Buy American Provision:The breakfast served on 10/09/19 was served with canned Mandarin oranges that were imported from China [7 CFR Part 210.21 (d)].Prior to the On-Site visit the SFA provided documentation that a limited exemption for the Buy American Provision was used by the SFA.
  • Civil Rights:The written procedure for handling civil rights complaints provided at the time of the Off-Site visit has an incomplete non-discrimination statement on it, as well as to have the wrong office contact information at the USDA.Procedures for civil rights are required to have the current non-discrimination statement, as well as having the current location to send the civil rights complaints (FNS Instruction 113-1).At the time of the On-Site visit the SFA provided an updated procedure for handling civil rights complaints containing the current non-discrimination statement with the current correct contact information.
  • Meal Pattern:Insufficient serving size for the meat/meat alternative for the beef and pasta meal option for lunch served on 10/13/19 [7 CFR Part 210.10 (c)].Prior to the On-Site visit the SFA took corrective action bringing this menu item's meat/meat alternative to this menu option into compliance with the meal pattern requirements.
  • Local Wellness Policy: The SFA's local wellness policy needs to have the following added:  a description for the measuring of the implementation of the policy [7 CFR Part 210.31 (c) (6)], guidelines and standards added for the marketing of food and beverages sold on campus during the school day [7 CFR Part 210.31 (c) (3) (iii)], and to have the names and titles of the wellness committee added to it [7 CFR Part 210.31 (c) (5) and 7 CFR Part 210.31 (d) (1)].  At the time of the On-Site visit the SFA provided a local wellness policy that contained all of the required areas.
  • Professional Standards: The SFA's food services director did not complete eight hours of food safety within 30 days of being hired or within five years of the date of hire [7 CFR Part 210.30 (b) (v) and 7 CFR Part 210.30 )b) (v)].Prior to the On-Site visit the director completed eight hours of food safety.

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

Resource Management:  The SFA did not have adequate internal controls to ensure only allowable cost were charged to the Nonprofit School Food Services Account (NSFSA).  2 CFR Part 200.303 requires SFAs to establish and maintain effective internal controls over the funds from the reimbursement claims and any funds that are co-mingled with those reimbursement funds.  A few examples of appropriate internal controls are having written procedures and having financial management standard operating procedures.

Resource management findings and issues are closely related to the broader procurement issues and will be addressed in the Procurement Review at a later date.

Reviewer's Comments:  St. Anthony Behavioral Medicine Center staff members involved with the operation of the facility's school nutrition programs are doing a good job.  During reviews it is normal to have findings.  The staff members that I worked with during this review were quick to take corrective action and to provide the documentation and information necessary to conduct this review.

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