Administrative Review Summary Report

Date: 01-12-23

Name of Agency: Saint Mary’s Catholic School Date of off-site review: 09-20-22

Reviewer: Matthew Smith Date of on-site review: 10-25-22

and 11-04-22

Persons interviewed: Elizabeth Martin-Burkett Date of exit conference: 01-09-23

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

Findings and Recommendations Identified During the Off-Site Portion of the Review Conducted September 20, 2022:

Civil Rights – Tool for Gathering Data on Ethnicity and Race: The student information form, used to gather data on the student ethnicity and race, is not using the required two-question format. The form only has a question to gather data for each program participant’s ethnicity. The USDA requires a two-question format to gather data on program participants’ ethnicity and race [as required by FNS Instruction 113-1]. The first question is to gather data on each program participant’s ethnicity and the second question is to gather data on each program participant’s race.

To demonstrate compliance with civil rights requirements:

The student information form must have a question added to gather data on each program participant’s race.
Please provide a copy of the updated student information form, as well as Saint Mary’s Catholic School’s (SMCS) plan for corrective action to demonstrate understanding and compliance.

Local Wellness Policy: The local wellness policy provided by SMCS during the off-site portion of this AR had not been assessed since the beginning of last school year (2021 – 2022). The local wellness policy directs the policy be assessed and updated each “new” school year. Federal regulation [7 CFR Part 210.31 (e) (2)] requires the policy to be assessed at least once every three years. Due to SMCS’ local wellness policy requiring the assessment to be completed each “new” school year, this is the standard that Oklahoma Human Services School Nutrition Programs (OHS SNP) will hold SMCS to.

During the off-site portion of the AR, SMCS did not provide documentation of the most recent assessment and update to the local wellness policy. Federal regulation [7 CFR Part 210.31 (e)] requires a triennial wellness assessment report be completed to document the assessment of the local wellness policy. OHS SNP requires the triennial wellness assessment report form (provided by OHS SNP) be used to for compliance with this requirement.

At the time of the off-site visit, SMCS did not have their most recent triennial wellness assessment report form posted publicly. Federal regulation [7 CFR Part 210.31 (d)] requires documentation of the most recent assessment to be posted publicly.

To demonstrate compliance with local wellness policy requirements:

Assess and update SMCS’ local wellness policy.
Document the assessment of SMCS’ local wellness policy on OHS SNP’s triennial wellness assessment report form.
Publicly post the policy and the triennial wellness assessment report form either on SMCS’ website, or on a public bulletin board at SMCS.
Provide copies of the updated local wellness policy, the triennial wellness assessment report form, and documentation of the public posting of both these documents.
Provide the above along with SMCS plan for corrective action demonstrating understanding and compliance.

Meal Patterns: During the menu week of lunch menus (08/22/22 – 08/26/22) assessed a non-systemic insufficient serving was discovered.

The lunch meal pattern 7 CFR 210.10 (c) requires the following minimum serving sizes for the grades K-8 meal pattern:

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

*80% of the weekly bread/grain serving 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 9 – 10 oz. per week
Milk	1 cup daily and 7 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 weekly serving for the bread/grain component was not met. The menus served during the week credited a minimum weekly bread/grain component serving of 6 oz.

This insufficient serving size was 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-8.
Bring all insufficient serving sizes and missing components in compliance with the meal patterns for grades K-8.
Submit CROCHS for corrective action to demonstrate understanding and compliance.

The school served non-creditable food items as part of the meal component. During the menu assessment, for the week of 08/22/22 through 08/26/22 it was determined your school served a non-creditable item.

The corndog product served as part of the lunch menu on 08/23/22. This product did not have a Child Nutrition (CN) issued by the USDA or a product formulation statement as required by federal regulation [7 CFR Part 210 Appendix C].

Replace this product with one that can be credited toward the NSLP meal patterns.

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

Obtain a new product formulation statement containing the required missing information Work with venders and sales representatives to obtain this documentation.
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 SMCS’ plan for corrective action to demonstrate understanding and compliance.

Findings and Recommendations Identified During the On-Site Portion of the Review Conducted October 25, 2022 and November 4, 2022:

Certification and Benefit Access – Incomplete Household Applications: During the review of all household applications it was determined that six household applications were incomplete. The household applications did not have the last four digits of the primary wage earner or other adult in the household listed or the box was not checked on the application documenting no social security number. Federal regulation [7 CFR Part 245.6 (a) (6)] requires the household application to have the last four digits of the adult household member signing the application listed, or if the adult does not have a social security number the application must indicate this.

To demonstrate compliance with certification and benefit access requirements:

Contact the households in question to request the applications be completed.
Provide OHS SNP with the dates each of the household applications in question were completed.
Provided the above along with SMCS’ plan for corrective action to demonstrate understanding and compliance.

Reviewer’s Comments: The findings contained in this report in no way reflect on the job being done by the people working with SMCS’ school food services program. For it being, Ms. Martin-Burkett first year in the program, she is doing a good job learning the requirements of the National School Lunch Program

Procurement Review Summary Report

Date: 01-12-23

Name of Agency: Saint Mary’s Catholic School Date of AR off-site review: 09-20-22

Reviewer: Matthew Smith Date of AR on-site review: 10-25-22

and 11-04-22

Persons interviewed: Elizabeth Martin-Burkett Date of exit conference: 01-09-23

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

The following areas were corrected during the Procurement Review (PR):

Procurement Plan: The procurement plan provided during the off-site portion of the Administrative Review (AR) did not address the use of the micro-purchase method of procurement. Federal regulation [2 CFR Part 200.318 (a)] requires each SFA to have a procurement plan that addresses the procurement methods being used by the SFA.

To demonstrate compliance with procurement plan requirements:

Update or amend SMCS’ procurement plan to address the use of the micro-purchase method of procurement.
Proved a copy of the updated procurement plan along with SMCS’ plan for corrective action to demonstrate understanding and compliance.