Clarifications Issued on Child Nutrition Programs

By Maureen Acquino | Posted on April 16, 2020

Updated Child Nutrition blog 410

As the COVID-19 pandemic continues, park and recreation professionals are continuing to support their communities by providing meals through the federal child nutrition programs. This is an ever-evolving situation, and we admire your flexibility and compassion while navigating the complex regulations of meal service.

The U.S. Department of Agriculture Food and Nutrition Service (USDA-FNS) has recently released clarifications to previously stated rules. This new guidance is designed to answer outstanding questions regarding pandemic meal service and ensure that all kids in your community have access to healthy, nutritious daily meals.

USDA-FNS has also issued a proposed rule that would simplify and clarify the Summer Food Service Program (SFSP) requirements, including streamlining monitoring and application requirements for experienced sponsors and codifying many existing program flexibilities that had been available through nationwide waivers. Please support this rule by submitting comments by April 22, to share the impact the proposed rule would have on the ability of sponsors to operate strong, financially viable programs.

While the statements below do clarify meal-program questions specific to this pandemic time, please first check with your meal sponsor or state agency before making any changes to your meal service program.

Can meals be served on weekends and during previously scheduled school closure (like spring break)?

Yes. As schools are closed due to COVID-19, daily meals, including weekends and during anticipated school breaks, may be served through the Summer Food Service Program (SFSP) and the Seamless Summer Option (SSO). More information can be found in question 22.

Under the Non-Congregate waiver, can CACFP and SFSP operators deliver meals directly to program participants’ homes?

Yes. As long as the operator has state agency approval and follows federal confidentiality requirements, meals may be delivered ONLY to children and adults enrolled in a CACFP and SFSP program. These meals do not need to be shelf-stable.

To support SFSP meal delivery, schools must first obtain written consent from households of eligible children (this could include email or other electronic means) that the household wants to receive delivered meals. Delivery may be completed by mail or delivery service, or hand-delivered by staff, volunteers, or community organizations. Schools must notify eligible households that their information will be shared with external organizations to execute meal delivery.

There is no additional reimbursement for home delivery or mobile meal delivery, but related expenses, such as postage or delivery service fees, would be considered an allowable cost under the CACFP.

More information on CACFP delivery can be found in questions 9-13, and more information on SFSP delivery can be found on the USDA-FNS website.

Can multiple meals be provided at one time, or do meals need to be provided on a daily basis?

Multiple meals may be provided at one time, as long as the number of meals does not exceed the allowed amount. For example, under SFSP and SSO, up to two meals or one meal and one snack, per child, per day, in any combination except lunch and supper, are allowed. Under CACFP At-Risk, up to one snack and one meal per child per day are allowed. More information can be found in question 15.

Can meals still be reimbursed if we’re not able to serve milk?

Yes, but your state agency needs to approve this exception. If emergency conditions temporarily prevent programs from obtaining milk, the state agency may allow programs to serve meals without milk and still be reimbursed. More information can be found in questions 1 and 2.

More information on questions regarding closed/open meal sites, activity waivers, meal sponsors, and civil rights can be found within the document as well. Guidance on meal program waivers, as well as additional supports for your program, can be found in this previous blog post.

For more information about NRPA’s response to COVID-19, as well as available resources for park and recreation professionals, please see our Coronavirus Disease 2019 (COVID-19) webpage.

Maureen Acquino is a Program Manager at NRPA.