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Administrative Review Summary Report

Date:  10-28-19

Name of Agency:  Youth and Family Services, Inc.

                                                                                              Date of off-site review: 09-10-19

Reviewer:  Matthew Smith                                               Date of on-site review: 10-17-19

Persons interviewed:  Latisha Davis and                         Date of exit conference: 10-17-19

                                        Jo Moore

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):

  • Local Wellness Policy:The policy provided at the time of the off-site needed to have the following added: description of how and when the policy will be assessed [7 CFR Part 210.31 (c) (4) and 7 CFR Part 210.31 (e) (1)], designation of personnel responsible for ensuring the implementation of the policy, and for assessing the policy [7 CFR Part 210.31 (c) (4) and 7 CFR Part 210.31 (e) (1)], a description for the measuring the implementation of the policy [7 CFR Part 210.31 (c) (6)], and the policy did not contain guidelines and standards for food and beverages sold on campus during the school day [7 CFR Part 210.31 (3) (iii)].

    The documentation of the most recent assessment and update was not documented on a triennial wellness assessment report [USDA Memo SP24-2017].  At the time of the Off-Site portion of this review the documentation of the most recent assessment and update (the triennial wellness assessment report) was not posted publicly [7 CFR Part 210.31 (e) (2)].

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 September 10, 2019:

Meal Patterns:A review of 08/12/19 through 08/18/19 indicated some insufficient portion sizes at lunch. 

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes; 2 oz. by weight meat/meat alternate daily and 14-17 oz. per week, 2oz. by weight bread/grain daily and 14-17 oz. per week, 1 cup fruit daily and 7 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) 7 cups/week, and 1 cup fluid milk daily, 7 cups weekly, offered as a choice between 1% and fat free. 

Insufficient quantities

  • On 08/14/19, the meal only credited 1.5 oz. toward the meat/meat alternative.  The bread served only credited 1.75 oz. (for two slices) toward the bread/grain component.
  • On 08/16/19 the bun served with this meal only credited 1.25 oz. toward the bread/grain component of this meal.
  • On 08/18/19, the bread served only credited 1.75 oz. (for two slices) toward the bread/grain component.
  • The required weekly serving for the meat/meat alternative component was not met.  The menus served during this week credited 13.50 oz. toward the meat/meat alternative.

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. 

The SFA served non-creditable food item as part of the meal component.  During the menu assessment it was determined your school is serving a non-creditable item. In order for the items to be creditable they must contain a CN label or an acceptable production formulation statement, 7 CFR 210 Appendix C.  Crediting information for USDA commodities can be found on the commodity fact sheets available on the USDA website. The following item was identified as non-credible:

  • The chicken product served with the lunch meal on 08/16/19.

Finding CN labeled products can be challenging. Remember; items similar to CN labeled products, but not the same, are not acceptable. If you are unable to obtain CN labels for the items you serve, your only choices are; discontinue serving the item or cook the item from scratch. When scratch cooking; we recommend using the USDA recipes because they will eliminate the planning needed when scratch cooking.

If a food is non-creditable and no other creditable foods are offered, the serving is considered insufficient.  The USDA now considers insufficient serving sizes to be "missing components". Finding of missing components on subsequent reviews will be considered reoccurring and our office may have to access fiscal action.

To demonstrate compliance with the CN label/product specification requirement:

  • Obtain and provide a copy of the needed product formulation statements. Work with venders and sales representatives to obtain this documentation. 
  • If product formulation statement(s) or CN labeling is not available, provide a copy of the replacement creditable item's labels.
  • Provide a copy of your corrective action plan along with the documentation list to demonstrate understanding and compliance.  

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted October 17, 2019:

Counting and Claiming: A review of the counting system demonstrates a non-systemic counting error for the review period (August 2019).  The error resulted in an over claim for the after school snack program for the month of August 2019, which caused a Performance Standard Violation I (PSI), 7 CFR Part 210.18 (g) (1) (ii).  

The error appeared to have occurred when the claim was entered into the online claiming system.  The SFA's online claim had 54 snacks being claimed, when the edit check and the snack meal roster for August of 2019 had 52 snacks counted as being served during the month of August. 

Below are the differences, our reviewer identified, in your February snack count, when comparing the electronically generated edit check to the snacks listed on your agency's claim:

  SFA OKDHS Diff.
Free 54 52 -2

Free snacks were over claimed by 2 snacks.

7 CFR Part 201.8 (a) (2) requires each SFA to review their claims for accuracy prior to submitting them to the State Agency (SA).

The error results in Performance Standard 1 Violations and require fiscal action [7 CFR Part 210.18 (g) (1) (ii) and 7 CFR Part 210.18 (I) (1)].

To demonstrate compliance with counting and claiming:

  • Review the counting and claiming system and create a plan to insure accurate daily meal counts are taken and recorded.
  • Provide copies of the following: edit checks and the meal rosters for the meals and snacks claimed for November 2019 and the claim for November 2019.

Reviewer's Comments:  I want to commend the staff members at Youth and Family Services, Inc. who work with school nutrition programs on a job well done during this review.   Keep up the good work. 

Procurement Review Summary Report

Date:  10-28-19

Name of Agency:  Youth and Family Services, Inc.

                                                                                                    Date of AR off-site review: 09-10-19

Reviewer:  Matthew Smith                                                    Date of AR on-site review: 10-17-19

Persons interviewed:  Latisha Davis and                              Date of exit conference: 10-17-19

                                        Jo Moore

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 during the Procurement Review (PR):

  • Procurement: At the time of the PR was commenced, your agency did not provide a procurement plan that met federal requirements [7 CFR Part 210.21(c) and 7 CFR Part 220.16 (c)].  During the PR a copy of a procurement plan that was in compliance was provided to the State Agency (SA) Reviewer.

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

There were no additional findings for the procurement review.

 

Reviewer's Comments:  I want to commend the personnel who have duties related to Youth and Family Services' procurement for their school nutrition programs with their compliance with federal procurement regulations.

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