Demonstration Project for Non-Congregate Feeding for Outdoor Summer Meal Sites Experiencing Excessive Heat with Q&As

Through this memorandum, pursuant to the authority of section 749(g) of the Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Act, 2010 (PL 111-80), the Food and Nutrition Service (FNS) is continuing the 2017 demonstration project allowing non-congregate feeding at certain outdoor summer meal sites experiencing excessive heat for summer 2018, to develop and test alternative methods of providing access to summer meals for low income children. Please review this guidance carefully, as some elements of the demonstration project, particularly data submission requirements, are different than in prior years. This memorandum also includes “frequently asked questions” regarding the administration of the demonstration project [Attachment A].

In 2017, 48 sponsors participated in the demonstration project. Collectively, 43,821 meals were claimed under the demonstration authority, supporting the basis for the continuation of the demonstration project. Continuation of the demonstration project into summer 2018 will enable FNS to collect data on the effectiveness of allowing for non-congregate feeding in certain situations and analyze more fully the need for future program adjustments. Data collected from this demonstration will be used to evaluate the effect on summer meal participation when sponsors are permitted to maintain service to children who would otherwise lose access to meals when excessive heat makes impractical the operation of a congregate meal site lacking a temperature-controlled alternative site. It is crucial that state agencies and sponsors participating in the demonstration ensure they are able to submit the required data elements prior to implementing non-congregate feeding under this demonstration. Demonstration projects exist for the purpose of obtaining information for future policy decisions, and for this reason, USDA is strengthening the data collection aspect of this demonstration.

Under the demonstration project, Summer Food Service Program (SFSP) and National School Lunch Program Seamless Summer Option (SSO) sponsors operating approved outdoor meal sites without temperature-controlled alternative sites may operate as non-congregate sites on days when the area is experiencing excessive heat. Non-congregate meal service shall be permitted only on days when the National Weather Service (NWS) has issued a Heat Advisory, an Excessive Heat Warning, or an Excessive Heat Watch for the area in which an approved outdoor meal site is located.

Applying for Participation in the Demonstration Project

State Agency Responsibilities

State agencies who would like to offer the Demonstration Project for Non-Congregate Feeding for Outdoor Summer Meal Sites Experiencing Excessive Heat to their sponsors must notify their FNS regional office (RO) in writing by June 15, 2018. Participation in the demonstration project is contingent on the commitment of both the sponsor and the state agency to submit timely data as specified below. Only those demonstration projects which submit required data will be eligible for reimbursement for non-congregate meals under demonstration parameters.

Sponsor Responsibilities

For summer 2018, sponsors located in states that are participating in the demonstration project must notify their state agency, in writing, of their interest in participating in the demonstration project. In their request, the sponsors must identify outdoor congregate meal sites lacking temperature-controlled alternative sites that would be included in the demonstration project prior to initiating their summer program. Sponsors who have already applied or been approved to participate this summer may submit an addendum to the state agency. Sponsors must select sites that are viable options for successful SFSP/SSO participation under the congregate meal requirement on days when the area is not experiencing excessive heat. The demonstration project will simply allow maintenance of the meal service at those sites on days when excessive heat makes service of congregate meals impractical or dangerous. Outdoor sites with available temperature-controlled alternative sites will not be included in the demonstration project, and should serve meals at the temperature-controlled alternative site if the area is experiencing excessive heat.

Exceptional Circumstances

In prior years of this demonstration project, FNS has reviewed requests based on exceptional circumstances other than excessive heat on a case-by-case basis. For summer 2018, FNS will continue to consider requests based on exceptional circumstances related to extreme weather events, such as wildfires, flooding, etc. State agencies and sponsoring organizations must send requests through the RO for advance approval by the FNS national office (an advanced notice of intent to participate is not required). State agencies should work closely with the requesting sponsor to develop a complete and comprehensive request that describes the exceptional circumstances imposing a barrier to congregate feeding, justifies the need for the exception, and describes how the sponsor’s operations will change and how eliminating the congregate feeding requirement will address the problem. The request also should identify the state agency’s support for the request and plan for oversight of the demonstration and must describe the recordkeeping and documentation that will be used to demonstrate compliance with program requirements.

Participation Requirements

Approved outdoor sites must comply with the congregate meal requirements on all other days of operation. Requirements pertaining to the number and type of meals that may be served each day continue to apply and sponsors must continue to provide all required components of a reimbursable meal. Because meals served will be consumed offsite, sponsors should carefully consider all food safety issues and risks. Only one meal may be provided to each child present at the meal site for each meal service. Meals may not be provided to adults or given to children to bring to other children not present at the site. All meal counting, claiming, and state and sponsor monitoring and oversight requirements continue to apply.

Sponsors electing to participate in the demonstration project must submit with their claims for reimbursement the following information to the state agency:

• The specific dates on which participants were permitted to take meals offsite; and
• The number of meals claimed that were taken offsite by participants.

As in prior years, states are required to submit certain data elements under Part 34 of the FNS-418, Report of the Summer Food Service Program for Children, and Part 18 of the FNS-10, Report of School Program Operations. For summer 2018, FNS has updated the data elements that states must provide, under the title “Non-Congregate Feeding Demonstration:”

• The name and number of sponsors approved by the state agency to participate in the demonstration project;
• The name and number of sponsors who participated in demonstration project;
• The number of sites which used the demonstration project and the number of meals taken offsite, per site;
• The total number of meal service sessions that utilized this heat demonstration project, by meal type;
• The number of calendar days on which at least one sponsor participating in the demonstration project permitted participants to take meals offsite;
• The total number of meals claimed that sponsors permitted participants to take offsite.

State agencies are reminded to distribute this memorandum to program operators. Program operators should direct any questions concerning this guidance to their state agency. State agencies with questions should contact the appropriate FNS regional office.

Angela Kline
Director
Policy and Program Development Division
Child Nutrition