Flexibility for the Administrative Review Cycle Requirement
In School Year 2013-2014, the U.S. Department of Agriculture’s Food and Nutrition Service (FNS) introduced the unified Administrative Review and a 3-year review cycle (7 CFR 210.18). Since then, FNS has received feedback about the difficulties of the shorter review cycle, both for the state agencies conducting the reviews, and for School Food Authorities (SFAs) preparing for and responding to reviews. FNS has made improvements to the process to minimize unnecessary burden and inefficiencies, and many states and SFAs have successfully implemented the 3-year review cycle. However, we recognize that many state agencies and SFAs face significant resource and time constraints, and we are committed to supporting program operators as they strive to run exceptional school meals programs.
The purpose of this memorandum is to provide guidance to state agencies who have determined that the 3-year review cycle hinders effective allocation of the state agency’s resources, and effective and efficient program management. To improve customer service, FNS is allowing state agencies to request waivers of the 3-year review requirement and extend the review cycle.
When submitting an Administrative Review cycle waiver request, state agencies must use the process described in SP15 CACFP12 SFSP05-2018: Child Nutrition Program Waiver Request Guidance and Protocol- Revised May 24, 2018, and are strongly encouraged to use the template provided with that guidance. State agencies must ensure that their waiver request clearly identifies:
- How the waiver will improve services under the program;
- Expected outcomes of the waiver; and
- How the waiver would allow the state to maximize resources available to support school meals programs.
FNS will continue to accept Administrative Review cycle waiver requests until further notice. State agencies must submit their waiver requests through their Regional Office. Requests for Administrative Review cycle waivers may include up to two additional years for a total of a 5-year review cycle. Waivers may be submitted for the current cycle or the upcoming cycle.
In addition, FNS recognizes that streamlining program requirements across programs may significantly reduce administrative burden and increase consistency across programs. We strongly encourage states to coordinate internally when they administer multiple programs and encourage state agencies to identify opportunities to streamline the review and participation requirements in all child nutrition programs. For example, we encourage states to consider flexibilities available for SFAs to align child nutrition programs administrative activities such as those detailed in SP09 CACFP04-2013: Streamlining At-risk Meal Participation for School Food Authorities, November 28, 2012. In addition, state agencies can use available flexibilities to perform different monitoring activities concurrently. For example, SP39-2017: Local Agency Procurement Reviews for School Food Authorities, June 30, 2017, provides state agencies with the discretion to continue completing procurement reviews on the same 3-year cycle as the Administrative review.
FNS will continue to communicate closely with states and provide oversight, technical assistance, and training resources to help state agencies conduct Administrative Reviews with integrity.
State agencies are reminded to distribute this memorandum to program operators. Program operators should direct any questions concerning this guidance to their state agencies. State agencies should direct any questions concerning this guidance to the appropriate FNS regional office.