Administrative Review Summary Report

Date:  01-05-22

Name of Agency:  Crossroads Youth and Family Services             Date of off-site review: 09-09-21

Reviewer:  Matthew Smith                                                             Date of on-site review: 10-18-21

Persons interviewed:  Tydree Lewis                                          Date of exit conference: 12-16-21                                   

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

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted September 9, 2021:

The School Food Authority (SFA) met the weekly fruit serving requirement with the use of fruit juice over the allowable amount: The breakfast menu week assessed (08/09/21 —08/18/21) the SFA met the weekly fruit serving requirement by using fruit juice.  Federal regulations [7 CFR Part 210.10 (c) (2) (ii) and 7 CFR Part 220.8 (c) (2) (ii)] require no more than half of the weekly serving of the fruit component may be met using 100% fruit juice.  The juice percentage for the breakfast week of 08/09/21 - 08/18/21 was 72.73%.  Fruit juice may be used to meet the daily serving requirements for the fruit component of a meal, but only half of the daily serving can be met using 100% fruit juice (half cup), and the other half cup be met using canned, fresh, or frozen fruit.

To demonstrate compliance with fruit juice weekly serving requirements:

• Review menus for compliance with weekly fruit juice serving requirements
• Submit Crossroads Youth and Family Services’ (CYFS) plan for corrective action to demonstrate understanding and compliance.

Local Wellness Policy: CYFS’ local wellness policy needs to have the following added:

• The goals for other school based activities that promote student wellness.  Federal regulation [7 CFR Part 210.31 (c) (1)] requires local wellness policies to have the following goal areas: goals for nutrition, goals for nutrition promotion, goals for physical activity, and goals for other school based activities that promote student wellness
• Guidelines and standards for the marketing of food and beverages on campus during the school day as required by federal regulation [7 CFR Part 210.31 (c) (4) (iii)].
• The local wellness committee membership.  Federal regulations [7 CFR Part 210.31 (c) (5) and 7 CFR Part 210.31 (d) (1)] require local wellness policies to have the local wellness committee membership listed.  This list must include the relationship of the committee member to CYFS.

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 reviewed and updated, 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 a need.  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 for CYFS
  • Goals for other school based activities.
  • Guidelines and standards for the marketing of food and beverages on campus during the school day.
  • CYFS’ local wellness committee membership
• Provide a copy of the updated local wellness policy with the required changes listed above.
• Provide the above requested documentation along CYFS’ plan for corrective action to demonstrate compliance and understanding.   

Meal Patterns:  A review of the week of 08/09/21 through 08/18/21 indicates some insufficient portion sizes at lunch during this week

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes for the grades 9-12 meal pattern:

• 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, 7 cups per week
  • Vegetable Subgroup Services:
    • Dark green subgroup ½ cup/week
    • Red/orange subgroup 1 ¼ cup/week
    • Legumes subgroup ½ cup/per week
    • Starchy subgroup ½ cup/week
    • Other subgroup ¾ cup/week) 7 cups/week.
•  1 cup fluid milk daily, 7 cups weekly, offered as a choice between 1% (unflavored) and fat free (flavored or unflavored).  You must offer two varieties daily.

Insufficient Quantities

• The lunch menu served on 08/09/21, only 5/8 cup of vegetables credited toward the daily serving for the vegetable component.
• The lunch menu served on 08/10/21, the taco shells only credited 0.75 oz. toward the daily serving for the bread/grain component.
• The lunch menu served on 08/11/21, only 7/8 cup of vegetables credited toward the daily serving for the vegetable component.
• The lunch menu served on 08/14/21, the salad served had a serving size of 1 cup crediting ½ cup toward the daily serving for the vegetable component.

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 your staff 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 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 CYFS’ plan for corrective action to demonstrate understanding and compliance.    

Professional Standards – Eight Hour Food Safety Training:  CYFS’ school food services director (Tydree Lewis) failed to complete eight hours of food safety training within 30 days of starting in the position, or within five years of starting in the position as required by federal regulation [7 CFR Part 210.30 (b) (1) (v)].  CYFS was provided information by email (10/14/21) on a free online eight-hour food safety training through the Institute of Child Nutrition’s (ICN) iLearn app.

To demonstrate compliance with professional standards – Eight-hour food safety training requirements:

• Have the school food services director complete eight hours of food safety training.
• Provide documentation of the director’s completion of eight hours of food safety training.
• Provide the above along with CYFS’ plan for corrective action to demonstrate understanding and compliance.

Professional Standards – Annual Training Requirements:  During school year 2020 – 2021 CYFS’ school food services director failed to complete 12 hours of training that could be credited toward annual training requirements [as required by 7 CFR Part 210.30 (b) (3)]. 

Also, during school year 2020 – 2021, all but one of the employees with part time duties in CYFS’ school food services program (average of 19 hours a week or less) failed to complete four hours of training that could be credited toward the annual training requirements [as required by 7 CFR Part 210.30 (d)].

Job Category*	Annual Training Requirement
School Food Services Director	12 hours
School Food Services Manager	10 hours
Full-Time Staff (averaging 20 hours  a week or more in the school food services program)	6 hours
Part-Time Staff (averaging 19 hours a week or less in the school food services program)	4 hours
Mid-year hires in all categories (January 1st or later)	One-half of the training requirements for each job category.

*School Food Authorities (SFA) may not have all the job categories listed above.  All SFAs 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 reimbursement claim procedures
• Identification of reimbursable meals at the point of service
• Annual civil rights training
• Nutrition
• HACCP food safety topics

To demonstrate compliance with professional standards – annual training requirements:

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

Whole Grain-Rich (WGR) Bread/Grain: For the reviewed menu week of 08/09/21 – 08/18/21 and the day of review (10/18/21); CYFS did not meet the 100% Whole Grain-Rich (WGR) requirement for bread/grain products served at breakfast and lunch, 7 CFR Part 220.8 (c) (2) (iv) and 7 CFR Part 210.10 (c) (2) (iv).  The percentage for meeting the WGR requirement for breakfast was 46%.  The percentage for meeting the WGR requirement for lunch was 82.6%. 

The following items were determined not to be WGR:

• For Breakfast Menus:
  • The cereals (choice of Berry Colossal Crunch or Tootie Fruities) served with the breakfast menus for 08/09/21, 08/11/21, and 08/13/21.
  • The blueberry muffins served with the breakfast menu for 08/10/21.
  • The cereals (choice of Oat Blenders or Tootie Fruities) served with the breakfast menu for 10/21/21.
• For the lunch Menus:
  • The taco shells served with the lunch menu for 08/10/21.
  • The tortillas used for the rollups served with the menu for 08/13/21.
  • The rolls served with the lunch menu for 10/21/21.

The percentage of the weekly servings met with WGR items must be brought up to 100% for both breakfast and lunch in order to be in compliance with federal regulations [7 CFR Part 210.10 (c) (2) (iv) and 7 CFR Part 220.8 (c) (2) (iv)].

To demonstrate compliance with Whole Grain-Rich Grain (QGR) requirements:

• Evaluate the products used by CYFS to determine if they meet the WGR requirement.  Replace any products determined not to meet the WGR requirement.
• Provide a copy of CYFS’ corrective action plan to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted October 18, 2021:

Afterschool Snack Program – Meal Pattern:  During the review of five consecutive days’ worth of production records for the Afterschool Snack Program, insufficient serving was discovered.  Federal regulation [7 CFR Part 210.10 (o) (2)] has the following meal pattern for the Afterschool Snack Program for children ages 6 – 18:

•  Serve two of the following (must be from two different components):
  • Milk – Low-fat (1% or less, unflavored only) or fat free (flavored or unflavored) – 1 cup
  • Vegetables and Fruits – ¾ cup
  • Grains and Breads – 1 oz.
  • Meat/Meat Alternative – 1 oz.

The review discovered the following snack insufficient serving:

• 08/10/21, you only served ½ cup of orange wedges.

To demonstrate compliance with Afterschool Snack – Meal Pattern requirements:

• Review your snack menus for compliance with the Afterschool Snack Program meal pattern for ages 6 – 18 years old.
• Bring all insufficient serving sizes into compliance with the Afterschool Snack Program for ages 6 -18 years old.
• Provide CYFS’ plan for corrective action to demonstrate understanding and compliance.

HACCP Food Safety Inspections:  During school year 2020 – 2021, CYFS failed to request a second inspection for their single site.  Federal regulation [7 CFR Part 210.13 (b)] requires SFAs to receive at least two food safety inspections during the school year.  If two are not received, the SFA must call their local health department and request a second inspection.  The SFA must document their local health department’s response if they decline to conduct the second inspection.

To demonstrate compliance with HACCP Food Safety Inspections:

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

Procurement Review Summary Report

Date:  01-5-22

Name of Agency:  Crossroads Youth and Family Services             Date of AR off-site review: 09-09-21

Reviewer:  Matthew Smith                                                               Date of AR on-site review: 10-21-21

Persons interviewed:  Tydree Lewis                                           Date of exit conference: 12-16-21                      

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.