Federal child nutrition programs

1. February 2014 Federal child nutrition programs SCHOOL PROGRAMS BRANCH U.S. Department of Agriculture Food and Nutrition Service Child Nutrition Division

2. Objectives • Provide an overview of the Federal Child Nutrition Programs, their administration and structure • Clarify what is expected of those operating the Child Nutrition Programs • Introduce you to new policies currently being implemented under the Child Nutrition Programs • Answer questions about the operation of the Child Nutrition Programs • Provide a tutorial on how to access online information resources

3. Structure and Administration of Child Nutrition Programs

4. www.fns.usda.gov/cnd

5. Organizational Structure

6. FNS Regional Offices NortheastRegion Mountain Plains Region MidwestRegion WesternRegion Mid AtlanticRegion SoutheastRegion SouthwestRegion

7. Administrative Flow FNS Headquarters Alexandria, VA FNS Regions - 7 State Agencies - 56 School Food Authorities – nearly 21,000 Schools – more than 100,000

8. Respective Duties Headquarters Regional Offices • Legislation • Write regulations • Develop national policy • Implement regulations • Technical assistance • Program oversight • Management evaluations

9. Child Nutrition Programs • National School Lunch Program (NSLP) • Afterschool Snack Service • Seamless Summer Option • School Breakfast Program (SBP) • Special Milk Program for Children (SMP) • Child and Adult Care Food Program (CACFP) • At-Risk Afterschool Meals • Summer Food Service Program (SFSP) • Fresh Fruit and Vegetable Program (FFVP)

10. Legislative Authority The National School Lunch Act • National School Lunch Program • Fresh Fruit and Vegetable Program • Child and Adult Care Food Program • Summer Food Service Program The Child Nutrition Act of 1966 • School Breakfast Program • Special Milk Program

11. The Regulatory Process

12. Regulatory Process • Proposed Rule • published for comments, not to be implemented • Evaluate comments • read/consider comments • Final or Interim Regulation • implemented; comments taken on Interim Regulation • Notices • announce routine updates

13. Your Role in the Regulatory Process • In order for the regulatory process to work, we need your help! • Your comments help FNS write rules • www.regulations.gov

14. 7 CFR Part 210 • National School Lunch Program regulations • Title 7 of the Code of Federal Regulations, Part 210

16. National School Lunch Program Operations

17. SFA vs. LEA School Food Authority Local Educational Agency • SFA – School Food Authority • Governing body responsible for the administration of one or more schools • Has legal authority to operate a Program • LEA – Local Educational Agency • Governing body responsible for certifying and verifying F/RP school meal eligibility

18. Non-Profit Food Service • Observe limitations on: • food service revenues 210.14(a) • Competitive foods 210.11(b) • Maintain financial management system and account for all revenue and expenditures 210.14 • Money must be used for the meal program • Profits from competitive food must go to food service account

19. Meals Priced as a Unit • A single reimbursable meal is priced as a unit • charges for reimbursable meals cannot be assessed based on individual components • Different prices may be charged depending on the total cost of producing each meal • Some entrées are more expensive to purchase and/or prepare

20. Point of Service Meal Counts • Count the number of reimbursable meals served by type at the point of service or through another system approved by the State • Count meals where you can accurately determine: • if the meal meets component requirements • the eligibility status of the child

21. Meal Service • The lunch period: 10:00 a.m. - 2:00 p.m. • Meals must meet nutrition requirements • Schools must display signage telling students what constitutes a reimbursable meal

22. Overt Identification • Make no discrimination against any child because of his or her eligibility for F/RP meals in accordance with the approved policy statement • SFA will not overtly identify students based upon their eligibility status • SP-45-2012 clarified the prohibition on overt identification

23. Sanitation and Health • Obtain two food safety inspections per year • Report number of inspections to State Agency • Develop food safety program/HACCP • http://www.fns.usda.gov/food-safety/food-safety-resources#Nutrition

24. Recordkeeping Requirements • Upon request, make all accounts and records pertaining to school food service available to the State and FNS • Keep records for 3 (+) years • Records must be available for audit or review at a reasonable time and place

25. Claims for Reimbursement • Monthly unless combined with short months • By benefit category--free, reduced-price, paid • File claims within 60 calendar days or by State’s due date • Report number of children approved for free or reduced price meals and the total enrollment on last operating day of October – This data is used to complete the FNS-742 report

26. Equity in School Lunch Pricing/Nonprogram Foods Revenue • Seeks to ensure that sufficient funds are provided to the food service account for paid lunches • Must be calculated annually • Paid Lunch Equity Tool updated annually • Non-program Revenue Tool • FNS Policy Memo SP 15-2014 provides guidance, calculations and flexibilities for SY 2014-15

27. National Average Payment Factors • The average per lunch rates for reimbursement of free, reduced price and paid meals • Adjusted annually – the rates of reimbursement change every year • New rates become effective every July 1

28. 6-Cents Performance Based Reimbursement • The HHFKA provides performance-based reimbursement for SFAs that demonstrate compliance with the meal patterns for both lunch and breakfast • Additional 6 cents paid only for lunches claimed • 86% of SFAs in the country are certified

29. The 6-Cents Certification Process Moving Forward • Certification during Administrative Review: SP 51-2013 • If SFA has not submitted certification materials, State agency will assess certification during an admin review • SFAs may still submit certification documentation to State agency • Ongoing compliance with the meal pattern requirements is monitored during administrative reviews • FNS continues to work with State agencies to ensure that all SFAs meet certification requirement

30. 6-Cents Cont’d • Some aspects of the meal pattern are phased in over several years • SFAs must demonstrate compliance with those requirements in effect at time of certification • SFAs must demonstrate compliance with both breakfast and lunch if SFA offers breakfast

31. Coordinated Review Effort (CRE) • Now defunct---new Administrative Review process recently developed • New Administrative Review designed to be streamlined and more comprehensive • State agency conducts reviews with occasional help from FNS staff • 3-year review cycle began SY2013-14

32. New Administrative Review Process • Extensive guidance and resources available on FNS website: http://www.fns.usda.gov/cnd/guidance/adminreview.htm • Also refer to FNS policy memo SP 12-2013 • adminreview@fns.usda.gov

33. NSLP Meal Pattern Requirements

34. Updated Meal Requirements • The Healthy, Hunger-Free Kids Act of 2010 (HHFKA) directed USDA to implement the most significant update of nutrition standards for the school meal programs in over three decades • Changes were effective: • July 1, 2012 (SY 2012/13) for lunches • July 1, 2013 (SY 2013/14) for breakfasts

35. Phased-in Targets • To ease the transition to the new meal patterns for State agencies and SFAs, many of the HHFKA’s requirements are phased in over time • For SY 2013-14: • Implementation of new breakfast meal pattern • Upcoming targets for SY 2014-15: • 100% of grains components to be “whole-grain rich” (majority WGR) • First sodium reduction target • Breakfast fruit serving increases to 1 cup per day • Future Targets: • Second sodium target: SY 2017-18 • Final sodium target: SY 2022-23

36. Free and Reduced Price Meals

37. Eligibility • Two processes for determining: • Household Application • Income eligibility • Categorical eligibility • Direct certification

38. Categorical Eligibility • Receipt of SNAP, TANF or FDPIR benefits • Eligibility extended to all children in household • “Other Source” status such as foster child or enrolled in Head Start • Individual eligibility • May be determined by application or direct certification

39. A Comparison of Application Types Income Application Categorical Application • Last four digits of the SSN of signing adult • Current income • Frequency of income • Source of the income • Household members, including child • Signature of adult household member • Child’s name • Case number or indication of status • Signature of adult household member

40. Income Eligibility Guidelines (IEGs) • Used to determine eligibility for free or reduced price meals based on the family’s income • FNS makes these calculations based upon the Federal poverty guidelines • Issued in the Spring each year

41. Income for Eligibility • Children from families whose income equals 130 percent of poverty or less are eligible for free meals • Children from families whose income is more than 130 but less than 185 percent of poverty are eligible for reduced price meals • Children from families whose household income is above 185 percent of poverty pay full price for their meals

42. IEGs SY 2014-2015

43. Income and Households • Income • before any deductions (such as taxes, Social Security taxes, insurance premiums, charitable contributions and bonds) • Household • a group of related or non-related people living under one roof as one economic unit

44. Migrant, Runaway, or Homeless Children • Migrant children in the Migrant Education Program • Runaways in the programs under Runaway and Homeless Youth Act • Homeless children under the McKinney-Vento Act

45. Foster Children & Head Start • Foster Children • Any child whose care and placement is the responsibility of the State • Any child who is formally placed by a court with a caretaker household • Head Start • All children enrolled in Head Start are categorically eligible

46. Mandatory Direct Certification • Requires the LEA to conduct direct certification with SNAP at least three times per year (more times highly encouraged) • All children in the household certified for free meals if any child or adult in the household receives SNAP • State agency enters into an agreement with their SNAP agency establishing direct certification procedures • These households are not subject to verification

47. Discretionary Direct Certification • An LEA may certify a child for free meals without further application by directly communicating with officials to determine if the child is: • a TANF family member • FDPIR • homeless • served by certain runaway or homeless youth programs • a migrant • a Head Start enrollee • In foster care

48. Confidentiality • Individual children’s eligibility status and information protected by NSLA • Law allows limited disclosures • Any direct certification system or data exchange must ensure limited disclosure within statutory requirements

49. Eligibility Manual • Available on our website • Incorporates all memos and changes regarding F/RP policies • Updated annually