FEDERAL CHILD NUTRITION PROGRAMS

Rosemary O’Connell Kevin Maskornick

USDA Food and Nutrition Service Child Nutrition Division October 22, 2012

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   Answer questions about the operation of the Child Nutrition Programs Provide a tutorial on how to access online information resources

www.fns.usda.gov/cnd

Organizational Chart

Secretary of Agriculture Under Secretary for Food, Nutrition and Consumer Services

Food and Nutrition Service

Center for Nutrition Policy and Promotion

Regional Offices

OPS CGA ROS SNAP

Special Nutrition (CND, FDD, WIC)

MTF

Western Region

FNS Regional Offices

Mountain Plains Region Midwest Region Northeast Region Mid Atlantic Region Southeast Region Southwest Region

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Administrative Flow

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

Respective Duties

Headquarters

   Legislation Write regulations Develop national policy

Regional offices

    Implement regulations Technical assistance Program oversight Management evaluations

Flow of Reimbursement

Congress appropriates funds FNS prepares budget for programs FNS Regions estimate State $ needs States receive SFA claims and draw down on the LOC Regions give states Letter of Credit 3 month supply to draw down States receive Grant Award Document Estimate of Annual $

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)

Child Nutrition Programs FY11

ADP NSLP

31.8 million

SBP

12.1 million

SFSP

2.3 million

CACFP

3.4 million About 100,000 schools in NSLP About 89,000 schools in SBP Federal Appropriations for NSLP/SBP in FY 2012 are over $13.4 billion

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

REGULATORY PROCESS

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

Regulatory Process

   In order for the regulatory process to work, we need your help!

Your comments help us write our rules www.regulations.gov

7 CFR 210 THE NATIONAL SCHOOL LUNCH PROGRAM REGULATIONS

SFA vs. LEA

School Food Authority

   SFA – School Food Authority Governing body responsible for the administration of one or more schools; Has legal authority to operate a Program

Local Educational agency

  LEA – Local Educational Agency Governing body responsible for certifying and verifying F/RP school meal eligibility

Non-profit Food Service

 Observe limitations on:  food service revenues sec. 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  Competitive food money must go to food service or school approved group

Procurement

   Free and open competition in procurement required and follow Federal, State and local bidding and contracting requirements Geographic preference allowed 210.21

 Encourages purchases from local farmers Buy American requirement  Domestic commodity or  Produced in the US  51 % of the final processed product must consist of agricultural commodities that were grown domestically.

Price Lunch as a Unit

 A single reimbursable meal is priced as a unit  charges for reimbursable meals cannot be assessed based on individual components

Point of Service 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

Meal Service

   The lunch period is between 10:00 a.m. 2:00 p.m.

Some exceptions apply Schools must display signage explaining the components that constitute a reimbursable meal

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 FNS recently circulated memo SP-45-2012 clarifying the prohibition on overt identification

Sanitation and Health

 Obtain two food safety inspections per year  Develop food safety program/HACCP  Inspections satisfy the requirements for all child nutrition programs operating in the same service area

Retain Your Records

 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

How You Get Your $$$

 Claim reimbursement at assigned rates. The SFA official signing the claim is responsible for review and analysis for accuracy. Failure may result in withholding, suspension or termination   SFA official takes responsibility for accurate claims Edit checks verify accuracy of claims

How You Get Your $$$ Cot’d

    File claims within 60 days  SA can shorten this period Consolidated claims are OK  each school’s data is retained Claim is for 1 month  combine months with 10 or less operating days (but do not cross fiscal years) Report number of F/RP children and total enrollment on last operating day of Oct

Equity in School Lunch Pricing

 Seeks to ensure that sufficient funds are provided to the food service account for paid lunches  Must be calculated annually  Information and PLE Tool updated in Spring for the upcoming School Year ool  Non-program Revenue Tool

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  Additional 6 cents reimbursement available this SY

Coordinated Review Effort - CRE  Now defunct---new administrative review process under development  State agency conducts reviews with occasional help from FNS staff  Also covers general areas:  civil rights  reporting/recordkeeping  food safety...

 3-year review cycle begins SY2013-14

NSLP MEAL REQUIREMENTS

Updated Meal Requirements

  The Healthy, Hunger-Free Kids Act of 2010 mandated USDA to update school meals Changes are effective:  July 1, 2012 (SY 2012/13) for lunches  July 1, 2013 (SY 2013/14) for breakfasts

New Dietary Specifications

     Calorie minimums and maximums More fruits and vegetables Limit on sodium (gradual reduction over time) Limit on trans fat (zero grams per serving)   Limit on saturated fat (less than 10% of calories) Weekly averages Nutrient analysis of meals conducted by State agency during administrative review

    

New Meal Pattern

Food-based meal pattern Fruits and vegetables are separate components Vegetable subgroups must be offered over the week  Dark Green  Red/Orange  Beans/Peas (legumes)  Starchy  “Other” Fruits must be offered at breakfast and lunch Skim milk (unflavored/flavored) and low fat milk (unflavored)

New Meal Pattern

 Whole grain-rich requirement  In SY 12/13, at least ½ of grains offered during the week must be whole grain-rich  For breakfasts: SY 13/14  In SY 14-15, all grains offered must be whole grain-rich  Lunches and breakfasts  “Whole grain-rich” = at least 50% whole grains and the remaining grains in the product must be enriched

Competitive Foods

 Foods sold in competition with lunches during lunch periods (e.g., a la carte)   State agencies and SFAs must have rules to control the sale of competitive foods  Income from the sale of such foods must benefit nonprofit school food service Foods of Minimal Nutritional Value are prohibited in food service area during lunch  See list in Appendix B of 7 CFR 210 (soda, gum, certain candies, candy coated popcorn...)

A School Store

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Local Wellness Policy

 Policy developed at the local level to enhance the school nutrition environment  Nutrition education and physical activity  Nutrition guidelines for foods available on campus during school day  Reimbursable school meal guidelines  A plan for measuring implementation  Community involvement

Children with Disabilities

  SFAs must accommodate a child whose disability prevents him/her from consuming the school meal as prepared Request a statement from a licensed physician’s that identifies:  Child’s disability  Why disability restricts diet  Major life activity affected  Foods to be omitted & offered

Children with Special Dietary Needs

  Food intolerances or allergies are not considered, by law, a disability SFA has discretion to make meal accommodations on a case-by-case basis   A medical statement from a recognized medical authority (as identified by the State) is required For milk substitution only, a parent statement is allowed

Offer versus Serve

    Intended to reduce food waste Mandatory for senior high schools in NSLP Optional for SBP and for NSLP at lower grades Students may decline 2 food components at lunch, but must select a fruit or a vegetable

A Brief Overview

FREE AND REDUCED PRICE MEALS

Eligibility

 Household Application  Income eligibility  Categorical eligibility  Direct certification

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

A Comparison of Applications

Income 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

Categorical application

   Child’s name Case number or indication of status Signature of adult household member

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 as determined by the Department of Health and Human Services

IEGs Calculations

  Children from families whose income equals 130 percent of poverty or less are eligible for free meals Children from families whose income equals between 131 and 185 percent of poverty are eligible for reduced price meals

Household Size

SY 2012-2013

Reduced Price Meals (185 Percent) Free Meals (130 Percent)

3 4 1 2 5 6 7 8 For Each Additional Person, Add

Annual

20,665 27,991 35,317 42,643 49,969 57,295 64,621 71,947 +7,326

Month

1,723 2,333 2,944 3,554 4,165 4,775 5,386 5,996 +5611

Week

398 539 680 821 961 1,102 1,243 1,384 +141

Annual

14,521 19,669 24,817 29,965 35,113 40,261 45,409 50,557 +5,148

Month

1,211 1,640 2,069 2,498 2,927 3,356 3,785 4,214 +429

Week

280 379 478 577 676 775 874 973 +99

Income and Household

  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

Migrant, Runaway or Homeless Children

   Migrant children in the Migrant Education Program Runaways in the programs under RHYA Homeless children under the McKinney-Vento Act

Foster Children/Head Start

  Foster Children  Any foster child whose care and placement is the responsibility of the State  Any foster child who is placed by a court with a caretaker household Head Start  All children enrolled in Head Start are categorically eligible

Mandatory Direct Certification for SNAP Households

 Requires the LEA to directly certify as eligible for free meals any child who is a member of a household receiving SNAP benefits  State agency must enter into an agreement with their SNAP agency establishing direct certification procedures

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  homeless  served by certain runaway or homeless youth programs  a migrant  a Head Start enrollee

Documentation for Direct Certification

  SNAP or TANF officials relay documentation to schools that a child is part of a household certified to get those benefits Documentation may include:  Name of child  A certifying statement  Identifiers (e.g., SSN and DOB)  Signature of SNAP/TANF official  Date

Direct Certification Improvement Plans

  SY 2012-2013 – 90%; SY 2013-14 – 95% CIPs should include: • The specific measures the State will use to identify more children who are eligible for direct certification based on SNAP data • A multiyear timeline for the State to implement these measures • Goals for the State to improve direct certification results.

Should also address progress in complying with requirements to phase out

SNAP “letter method”

and conduct multiple direct certification matches

with SNAP

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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

Recipient of Information

Programs under the National School Lunch Act or Child Nutrition Act Federal/State or local means tested nutrition programs with eligibility standards comparable to the NSLP Federal education programs

What May be Disclosed

All eligibility information Eligibility status only Eligibility status only State education programs administered by a State agency or local education agency Local education programs Eligibility status only NO eligibility information, unless parental consent is obtained Medicaid or the State Children’s Health Insurance Programs (SCHIP), administered by a State or local agency authorized under titles XIX or XXI of the Social Security Act to identify and enroll eligible children All eligibility information unless parents elect not to have information disclosed

Requirements

Prior notice and consent not required Prior notice and consent not required Prior notice and consent not required Prior notice and consent not required Parental consent Must give prior notice to parents and opportunity for parents to decline to have their information disclosed State health programs other than Medicaid/SCHIP, administered by a State agency or local education agency Federal health programs other than Medicaid/SCHIP Local health program Eligibility status only NO eligibility information, unless parental consent is obtained NO eligibility information, unless parental consent is obtained Comptroller General of the United States for purposes of audit and examination All eligibility information Federal, State, or local law enforcement officials investigating alleged violations of any of the programs under All eligibility information the NSLA and CNA or investigating violations of any of the programs that are authorized to have access to names and eligibility status Prior consent not required Parental consent Parental consent Prior notice and consent not required Prior notice and consent not required

Eligibility Manual

  Available on our website Incorporates all memos and changes regarding F/RP policies  Updated annually

THE VERIFICATION PROCESS

Verification

  Local responsibility, though the State may conduct the process Use number of applications approved as of October 1 as pool  LEAs must verify a minimum number of applications by November 15 every year

Standard Sample Size

 3% or 3000, whichever is less, of “error prone” applications  Error prone is income within $100 per month ($1200 per year) of the threshold established through the IEG.

Verification Process

   Confirmation Review  Made by someone other than person who made initial determination to check for errors if no electronic data system used in initial determination Replacing Applications  Up to 5% on case-by-case basis Notifying Household  Request documentation  Provide contact information

Completing Verification

  With non-respondents, one follow-up attempt is required  LEA should document the follow-up attempt, perhaps on the application If benefits reduced or terminated, inform household in writing and provide appeal rights  Unless appealed, change the child’s eligibility status within 10 days

Verification Summary Report

  FNS-742, Verification Summary Report  LEA submits annually to SA, by March 1 SA consolidates reports and submits to FNS by April 15  Electronic submission available

SPECIAL PROVISIONS 1, 2 & 3 AND THE COMMUNITY ELIGIBILITY OPTION

Provision 2

Simplified Counting & Claiming  Schools make eligibility determinations and count meals by type (F/RP/P) in the first year (Base Year)   Use claiming percentages from base year in non-base years, take total meal counts only.

Schools certify children for F/RP meals for up to 4 school years  All students receive meals at no charge

Base Year Example

September 2011: 80 free meals 15 reduced price meals + 5 paid meals = 100 total meals per day

80/100 = 80% Free 15/100 = 15% Reduced 5/100 = 5% Paid

Non-Base Year Example

September 2012 Total meal count for the month: 150 Reimbursement claim: .80 x 150 = 120 free rate .15 x 150 = 23 reduced price rate .05 x 150 = 7 paid rate

Provision 3 Simplified Counting & Claiming   Schools follow procedures similar to those under Provision 2 Schools receive the same level of federal cash and commodity assistance each year, with some adjustments, for a 4-year period

Provision 3 Simplified Counting & Claiming  Base Year  Outside of the 4-year cycle  Offer meals either at no charge, or charge students eligible for RP/P meals  Make eligibility determinations andcount daily meals by type  Establish base year socioeconomic data  Claim reimbursement from these counts

Provision 3 Simplified Counting & Claiming  Non-Base Years  Offer all meals at no charge  Count total meals    Claim reimbursement according to Base Year numbers adjusted for: Inflation Change in enrollment  Change in number of operating days

Extensions

 Provisions 2 and 3 can be extended for 4-years if the income level of the school’s population:  Remained stable  Declined  Had negligible improvement (5% or less)

Community Eligibility Option

    LEA or schools electing Community Eligibility option serve all students free lunches and breakfasts for 4 successive school years.

Must have a percentage of Identified Students greater than or equal to 40% to qualify.

Reimbursement claims are based on the percentage of Identified Students multiplied by a factor of 1.6.

The remainder of meals not covered under the Identified Student percentage multiplied by the factor will be reimbursed at the paid rate.

SCHOOL BREAKFAST PROGRAM

Severe Need Schools

 Schools receive higher reimbursement in SBP if at least 40% of lunches served in the 2nd preceding year were free or reduced price  Schools without 2nd preceding year history may be eligible

FRESH FRUIT AND VEGETABLE PROGRAM

School Selection Criteria

    Must be elementary school Must operate NSLP Must submit an application Must have at least 50% F/RP  Priority given to schools with highest % of low income students   Total enrollment of all schools must result in a per-student allocation of $50-$75 Provided apart from lunch or breakfast

SNACKS UNDER THE NSLP

AFTERSCHOOL SNACK SERVICE

      Sponsored or operated by school district Located in district where at least one school participates in NSLP All snacks served free at area eligible schools Free, reduced price, and paid snacks at all other schools Children age 18, or under, at start of school year On regular school days

USDA Reimbursement

  One afterschool snack per child per day Meal pattern (2 of 4 items):  fluid milk  Vegetable or fruit  Grains/bread  meat/ meat alternate  School must keep records

CHILD AND ADULT CARE FOOD PROGRAM AND SUMMER FOOD SERVICE PROGRAM

What does CACFP do?

  Provides reimbursements for:  Nutritious meals to eligible children 12 years and under* in non-residential child care  Afterschool meals and snacks to children 18 and under in low-income areas  Meals in emergency shelters to residents 18 and under  Nutritious meals to eligible adults in non-residential day care centers Operates year-round

At-risk afterschool meals

     Reimbursable supper, or another meal, and snack Located in low-income areas All suppers and snacks served free Children age 18, or under, at start of school year After school, week-ends, and holidays

What does SFSP do?

  Provides reimbursement for nutritious meals and snacks during the summer months and other extended school breaks in areas of economic need Draws children to supervised activities that are safe, fun, healthy and educational   Fills the nutritional gap for children who rely on free and reduced price school meals Schools can be sponsor sites when not in session

SFSP advantages

  Receive maximum rates of reimbursement Pay for any allowable cost, whether operating or administrative   Plan and budget more reliably Waive review of experienced school sponsors’ budgets  SFSP vs. Seamless Summer Option (SSO)

How can schools participate in SFSP?

   Become a and camps SPONSOR : organize meal services for children at local schools, as well as recreation centers, playgrounds, parks, Host a SITE : supervise children’s meals at the local school Be a VENDOR : prepare and sell meals to another sponsor

Seamless Summer Option

 Combines NSLP, SFSP, SBP  Available to SFAs in any State  Operates much like the NSLP  Serves meals at summer site  Goal is to encourage schools to provide summer meals

Seamless Summer Option

  Serve all meals free to children May be used over long breaks in year around schools   Same recordkeeping/claim/documentation as NSLP/SBP Receive NSLP/SBP rates

TEAM NUTRITION OVERVIEW AND ONLINE RESOURCES

Team Nutrition

Goal

To improve children’s lifelong eating and physical activity habits by using the principles of the

Dietary Guidelines for Americans

Objectives

Provide Foodservice Training and Technical Assistance Provide Nutrition Education and Promotion Materials Involve School and Community Partners in Promoting Healthy Eating and Physical Activity

Be a Team Nutrition (TN) School

Why Enroll?

     Encourages partnerships between teachers, school foodservice staff, principals and parents Receive notification FIRST of new materials Receive materials given ONLY to TN Schools It’s EASY! It’s FREE!!

Team Nutrition Resources

   Resources for schools 

MyPlate

Resources  Eat Smart. Play Hard.

TM Resources  Power of Choice Empowering Youth Nutrition Essentials

HealthierUS School Challenge

     Voluntary initiative Schools must meet specified criteria Certified for 4 years Local and National recognition To date, 3098 elementary and secondary schools in 46 States are currently certified as Bronze, Silver, Gold, or Gold of Distinction awardees

HealthierUS School Challenge Resources       Visit http://www.teamnutrition.usda.gov/ Online Interactive Applications Online Competitive Foods Calculator Online Technical Assistance Tools Application Kit Submit applications electronically Simplified district application process

What is the web address for the FNS Child Nutrition Programs?

www.fns.usda.gov/cnd

Web Resources Tutorial

 During this tutorial, we will:  Acquaint you with the layout of the FNS website  Direct you to valuable online information resources  Show you how to enroll your school as a Team Nutrition school and join the HealthierUS School Challenge SLI DE 95

Thank You!