Date:  04-19-22

Name of Agency:  Drexel Academy                                             Date of off-site review: 02-07-22

Reviewer:  Matthew Smith                                                        Date of on-site review: 03-24-22 and 03-29-22

Persons interviewed:  Kami Swartwood                          Date of exit conference: 04-14-22                       

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):

• Local Wellness Policy:  The local wellness policy did not contain the following required are: 
  • The policy did not designate personnel with the responsibility for assessing the policy [7 CFR Part 210.31 (e)]
  • The policy did not contain a description for how the public is provided with the opportunity for participating the local wellness policy process [7 CFR Part 210.31 (c) (5)]

Prior to the completion of the on-site portion of this AR, Drexel Academy updated their policy to contain the above required areas.

• Professional Standards – Eight Hour Food Safety Training:  The school food services director did not complete eight hours of food safety training within 30 days of starting in the position, or within five years of starting in the position [7 CFR Part 210.30 (b) (1) (v)[.  Prior to the on-site portion of this AR, the director completed eight hours of food safety training.

Corrective actions for the above findings were made prior to the completion 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 February 7, 2022

Buy American Provision:  During the menu week assessment of breakfast and lunch menus (for the week of 01/24/22 – 01/28/22), a food product was discovered that was not domestically produced.  Federal regulations [7 CFR Part 210.21 (d) and 7 CFR Part 220.16 (d)] requires School Food Authorities to buy domestically produced food products.

The following food product was discovered during the menu week assessment conducted that were not domestically produced:

• The peaches served with the breakfast menu on 01/25/22 and with the lunch menu on 01/26/22 were a product of Greece.

To demonstrate compliance with the Buy American Provision:

• Review the food products used in Drexel Academy’s school food services program for compliance with the Buy American Provision.
• Provide Drexel Academy’s plan for corrective action to demonstrate understanding and compliance.

Meal Patterns:  During the menu week assessment of the breakfast and lunch menus for 01/24/22 – 01/28/22 some insufficient serving sizes for the lunch menus were discovered.

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes for the grades K – 5 meal pattern:

Meal Component	Required Serving
Bread/Grain	1 oz. by weight daily and 8 – 9 oz. per week

*All items used to meet the daily and weekly bread/grain servings must be Whole Grain-Rich.

Fruit

½ cup daily and 2 ½ cups per week

*Up to half of the weekly serving can be met with the use of 100% fruit juice.

Meat/Meat Alternative	1 oz. by weight daily and 8 – 10 oz. per week
Milk	1 cup daily and 5 cups per week

*Students must be given a choice of milk from fat free unflavored, fat free flavored, and 1% unflavored. **One of the choices must be unflavored.

Vegetable	¾ cup daily and 3 ¾ cups per week
Vegetable Subgroups to be offered throughout the week
-Dark Green ½ cup     -Red/Orange ¾ cup     -Legume ½ cup per week -Starchy ½ cup           -Other ½ cup

Insufficient Quantities

§  The required minimum serving for the bread/grain component was not met.  The menus served during the weekly only credited 5.75 oz.

The above insufficient serving sizes were determined to be non-systemic in nature.

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).

To demonstrate compliance with Meal Patterns:

• Review your menus for compliance with the meal patterns for grades K – 5.
• Bring all insufficient serving sizes and missing components in compliance with the meal patterns for grades K – 5.
• Submit Drexel Academy’s plan for corrective action to demonstrate understanding and compliance.

The school served non-creditable food items as part of the meal component.  During the menu week assessment, conducted for the week of 01/24/22 through 01/28/22 it was determined your school is serving a non-creditable item.  This was due to the product not having a Child Nutrition (CN) label issued by the USDA, or a product formulation statement issued by the manufacturer [as required by Appendix C to 7 CFR Part 210 and Appendix C to 7 CFR Part 220].

• The taquito product served with the lunch menu served on 01/25/22.

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

• Provide a CN label or product formulation statement for the product. 
• If product formulation statement(s) or CN labeling is not available, the product will have to be replaced.  If this is the case, please provide a copy of the replacement creditable item’s labels. If the replacement is produced from a recipe, please provide the recipe.
• Provide a copy of the above documentation, along with Drexel Academy’s plan for corrective action to demonstrate compliance and understanding.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted March 24, 2022 and March 29, 2022:

Counting and Claiming: A review of the counting system demonstrates systemic counting and claiming error for the review period, January 2022, which results in a Performance Standard

Violation I (PSI), 7 CFR Part 210.18 (g) (1) (ii).  The error was systemic in nature and was found for breakfast and lunch monthly counts. 

Below are the differences, our reviewer identified, in Drexel Academy’s November Lunch counts, when comparing the meal roster to the meals listed on Drexel Academy’s claim:

	Drexel Academy Roster Counts	Drexel Academy November Claim	OKDHS School Nutrition Programs Count	Difference
Free	644	561	644	-83

Free lunch meals were under claimed by 83 meals.

The error in the number of lunch meals claim appears to have occurred when the monthly meal count was entered into OKDHS School Nutrition Programs online claiming system.  Instead of entering 644 free lunch meals, 561 free lunch meals were entered.

7 CFR Part 210.8 (a) (2) requires each SFA to review their claims for accuracy prior to submitting them to the State Agency (SA).

To demonstrate compliance with counting and claiming requirements:

• 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: meal rosters for March 2022, edit check forms for March 2022.

• Provide the above copies, along with Drexel Academy’s plan for corrective action to demonstrate understanding and compliance.   

Reviewer’s Comments:  I want to commend Kami Swartwood on a job well done with the AR!  Keep up the good work!

Procurement Review Summary Report

Date:  04-19-22

Name of Agency:  Drexel Academy                                             Date of AR off-site review: 02-07-22

Reviewer:  Matthew Smith                                                        Date of AR on-site review: 03-24-22

 and 03-29-22

Persons interviewed:  Kami Swartwood                                      Date of exit conference: 04-1-22   

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

 

There were no findings for the procurement review.