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Child Nutrition Emergency Operational Costs Reimbursement Programs: State Agency Implementation Plan Template and Q&A Guidance

EO Guidance Document #
FNS Document #
SP09 CACFP07-2021
Resource type
Policy Memos
Guidance Documents
DATE: March 15, 2021
SUBJECT: Child Nutrition Emergency Operational Costs Reimbursement Programs: State Agency Implementation Plan Template and Q&A Guidance
Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States
State Directors
Food Distribution Programs
All States

This memorandum announces the release of the state agency supplemental Implementation Plan Templates for use in the Child Nutrition Emergency Operational Costs Reimbursement Programs. These documents will be used by state agencies to guide the development and structuring of the implementation plan(s), as provided for in the state applications and must be submitted to the Food and Nutrition Service (FNS) as a condition of receiving funding under these reimbursement programs. The due date for the implementation plans is May 10, 2021.

Separate implementation plan templates are provided for the School Programs Emergency Operational Costs Reimbursement Program and the Child and Adult Care Food Program Emergency Operational Costs Reimbursement Program (Attachments B and C). An implementation plan must be completed for each reimbursement program in which the state agency has elected to participate.

As a reminder state implementation plans should be submitted directly to with a CC to the appropriate FNS regional office and include the following elements:

  1. An estimate of the number of program operators eligible for payments, organized by recipient type (i.e., SFAs, CACFP institutions, day care homes;
  2. An estimate of total funding amount needed by the state agency in order to effect such payments organized by reimbursement month;
  3. Any substantive updates to the process by which payments are calculated and disbursed to program operators, if applicable;
  4. A projected timeline for disbursement of payments to program operators;
  5. A narrative description of how the state agency will accomplish the following:
    • Ensure the accuracy of payment calculations;
    • Notify program operators of payments and complete related solicitations and outreach; and
    • Collect and document summary infom1ation on the use of these funds by the state and each program operator.

In addition, the implementation plan templates include an assurance statement covering the applicability of standard child nutrition monitoring and recordkeeping requirements as they relate to the issuance usage of funds made available under these reimbursement programs.

State agencies may commence work on their supplemental implementation plan(s) if they have already submitted their application for the Child Nutrition Emergency Operational Costs Reimbursement Programs to FNS. However, they are advised not to submit their supplemental implementation plan prior to receiving a formal application acceptance letter from FNS, which will be provided in PDF format via email attachment. FNS is currently working expeditiously to process application materials submitted by state agencies to date.

Lastly a new set of Q&As is included with this guidance release (Attachment A), addressing questions regarding the implementation plan template the payment calculation formula, and other topics. Further Q&A guidance addressing additional topics should be expected in the future.

The table on the following page highlights some key dates and deadlines as they relate to implementation of and participation in the reimbursement programs:

Key Dates and Deadlines
Feb. 25, 2021 Application due to FNS including participation status and narrative disbursement plan
May 10, 2021 Supplemental implementation plan due to FNS
June 30, 2021 States should begin disbursing funds to program operators
July 31 2021* States should request additional funds from FNS, as appropriate
Sept. 30, 2021 Funds availability (obligation) deadline
Jan. 31 2022 Funds distributed to program operators (liquidation) deadline; recovery process begins
March 31, 2022 All unliquidated funds returned to FNS; implementation report due

* This date has been changed from Aug. 3 l , 2021, as referenced in previous FNS guidance published on Jan. 26, 2021 to better ensure that state agencies have sufficient time to obligate funds following award.

State agencies with questions should contact the appropriate FNS regional office.

Jessica Saracino
Acting Director
Program Monitoring and Operational Support Division
Child Nutrition Programs


  1. Emergency Operating Costs Q&A #2
  2. Emergency Operating Costs Q&A #3
  3. School Meals State Implementation Plan Template
  4. CACFP State Implementation Plan Template
Page updated: March 21, 2023

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.