Cherokee Nation
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DATE: | November 18, 2014 | |
POLICY MEMO: | SP07 -2015 | |
SUBJECT: | Assessing Proposed Nutrition Education Costs in the National School Lunch Program and School Breakfast Program | |
TO: | Regional Directors Special Nutrition Programs Financial Management All Regions |
State Directors Child Nutrition Programs All States |
This memorandum provides guidance on the process state agencies and school food authorities (SFAs) should use when assessing requests to fund nutrition education related expenses from the nonprofit school food service account. Nutrition education is an integral part of the mission of the National School Lunch Program (NSLP) and School Breakfast Program (SBP) when the nutrition education and related activities directly support the operation and/or improvement of the school food service 7 CFR Part 210.12(a).
State agencies and SFAs have the discretion to determine the allowability of SFAs to use nonprofit school food service account funds to pay for costs. In determining what proposed nutrition education costs and related activity may be supported with funds from the nonprofit school food service account, an SFA and state agency should assess the allowability of costs by considering the activity’s impact in directly supporting the operation and/or improvement of the school food service. In doing so, an SFA and the state agency must consider whether the proposed cost:
The cost principles serve an extremely important function in considering proposed costs and assisting program operators in better understanding how school food service account funds are being used. The OMB cost principles are a tool to be used by SFAs and state agencies for the purpose of cost determination and are not intended to dictate the extent of financial assistance for a particular cost objective.
When considering proposed uses of nonprofit school food service account funds for nutrition education costs, we have provided the following assessment questions to assist you in determining if costs are allowable under the federal cost principles; i.e., necessary, reasonable and allocable.
To complete an assessment of a proposed cost, both the SFA and state agency should summarize the assessment of the cost, including why the cost is allowable (i.e., necessary, reasonable, and allocable) in light of the responses to the questions above. This summary would assist the SFA in communicating a request and the state agency in communicating a decision for each proposed cost to the nonprofit school food service account and provide supporting documentation upon request by Food and Nutrition Service (FNS) and/or a federal/state auditor. State agencies should direct questions to the appropriate FNS regional office.
Sarah E. Smith-Holmes
Director
Program Monitoring and Operational Support Division
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.