Report 2016-139 Recommendation 2 Responses
Report 2016-139: California Department of Education: It Has Not Ensured That School Food Authorities Comply With the Federal Buy American Requirement (Release Date: July 2017)
Recommendation #2 To: Education, Department of
To strengthen its administrative reviews and help ensure that school food authorities comply with the Buy American requirement, Education should update its written procedures to include guidance for how its reviewers should interpret common food labels with regard to compliance with the Buy American requirement. It should develop this guidance in consultation with the USDA and should begin working with the USDA by no later than October 1, 2017.
6-Month Agency Response
In September 2017, Child Nutrition Consultants, Child Nutrition Assistants, and program staff received mandatory training on the Buy American Provision (BAP). Additional mandatory training on the BAP will be offered in February 2018, to reinforce the procedures entitled, "During the On-site SNP AR with the SFA: Reading Food Labels," (Attachments 1-5).
- Estimated Completion Date: February 2018
- Response Date: January 2018
California State Auditor's Assessment of 6-Month Status: Fully Implemented
Education provided evidence demonstrating that it updated its written procedures to include guidance for how its reviewers should interpret common food labels with regard to compliance with the Buy American requirement. Accordingly, we assess this recommendation as fully implemented.
60-Day Agency Response
On September 11, 2017, Education provided additional training and guidance to staff regarding the review of food labels for compliance with the Buy American requirements. Further, Education obtained additional guidance on the evaluation of product labels during a USDA management evaluation technical assistance visit on July 31, 2017. Education continues to work with the USDA as they update the Administrative Manual and the Buy American requirements.
- Completion Date: September 2017
- Response Date: October 2017
California State Auditor's Assessment of 60-Day Status: Partially Implemented
Education provided training to its staff related to the interpretation of common food labels and what those labels should lead a reviewer to determine about compliance with the Buy American requirement. Education has not yet provided to us updated procedures for its reviewers that incorporate this guidance. Accordingly, we assess this recommendation as partially implemented.
- Auditee did not address all aspects of the recommendation
Agency responses received are posted verbatim.