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Oversight and Monitoring of the School Meals Programs- Information Regarding Onsite and Offsite Strategies and Options

FNS Document #
SP 12-2023
Resource type
Policy Memos
Resource Materials
PDF Icon SP 12-2023 Memo (135.70 KB)
PDF Icon SP 12-2023 Attachment (213.65 KB)
DATE: April 6, 2023
SUBJECT: Oversight and Monitoring of the School Meal Programs - Information Regarding Onsite and Offsite Strategies and Options
TO: Regional Directors
Special Nutrition Programs
All Regions
State Directors
Child Nutrition Programs
All States

The purpose of this memorandum is to provide guidance regarding onsite and offsite strategies and options for oversight and monitoring of the school meal programs.

One of the primary responsibilities of the Food and Nutrition Services (FNS) is the oversight and management of the 16 federal nutrition assistance programs. Program monitoring is essential for ensuring that the federally funded child nutrition programs meet the requirements set forth in regulations, are operated with integrity, and provide nutritious meals and snacks to those who participate in the programs.

With the announcement of the start of the COVID-19 Public Health Emergency (PHE) on March 13, 2020, onsite monitoring of the Child Nutrition Programs became challenging and difficult to conduct as the number of COVID-19 cases increased and social distancing measures were enacted. FNS issued nationwide waivers for onsite monitoring requirements, allowing state agencies to monitor program operations offsite. Offsite monitoring helped ensure program integrity while protecting the health and safety of staff and participants.

As outlined in SP 03-2023, Offsite Monitoring of the Child and Adult Care Food Program and School Meal Program After the Public Health Emergency Ends, The Department of Health and Human Services recently announced that May 11, 20223 is the planned end date for the PHE. Given this expiration date, the FNS-issued nationwide onsite monitoring waivers are set to expire on June 10, 2023, 30 days after the end of the PHE. In addition to these nationwide waivers, FNS issued individual offsite monitoring waivers for states that requested them. While not impacted by the end of the PHE, these waivers are scheduled to expire on June 30, 2023.

FNS understands that state agencies quickly adapted review and monitoring procedures to include offsite strategies in response to the COVID-19 PHE and are interested in continuing to adapt some review procedures. The intent of this memorandum is to provide guidance to state agencies regarding onsite monitoring when it is required by regulations and what monitoring procedures are recommended when states have discretion to conduct monitoring on or offsite. FNS recognizes that there is not a universal approach to monitoring. Although this memorandum outlines areas of discretion in general, state agencies also have some discretion when considering the oversight needs of individual program operators when determining what could be reviewed onsite versus offsite. Some operators may benefit from most review activities conducted onsite, and for others, onsite time may be better utilized on technical assistance. Please note that these on-site and off-site strategies apply to both congregate and non-congregate meal service options.

Accompanying this memorandum is an appendix that outlines the various review provisions and the onsite and offsite strategies and options applicable to the school meal programs.

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

Jessica Saracino
Program Monitoring and Operational Support Division
Child Nutrition Programs


Page updated: April 10, 2023