|DATE:||May 31, 2013|
|POLICY MEMO:||CACFP12, SFSP14-2013|
|SUBJECT:||Transitioning from the Summer Food Service Program to Child and Adult Care Food Program At-risk Afterschool Meals|
Special Nutrition Programs
Child Nutrition Programs
This memorandum highlights flexibilities available to Summer Food Service Program (SFSP) sponsors transitioning into the At-risk Afterschool Meals component of the Child and Adult Care Food Program (CACFP) during the school year. Many existing SFSP sites are well-positioned to offer afterschool meals during the school year through CACFP. Both organizations and communities benefit when meals are offered to children in low income communities year-round. Organizations benefit from having the ability to hire year-round staff, a continuous flow of reimbursements providing additional financial stability, and recognition in the community as a stable source of services. Communities benefit by having a partner that provides year-round nutrition services for children and brings increased federal funds into the local economy.
In an effort to streamline participation in CACFP, the Food and Nutrition Service (FNS) is waiving some application requirements for SFSP sponsors in good standing that wish to apply to participate in CACFP for the first time. Sponsors considered in good standing are those that are not currently seriously deficient in their operation of the SFSP. Additionally, FNS is eliminating duplicative application requirements.
Each new CACFP institution is required to meet the performance standards outlined in 7 CFR §226.6(b)(1). Because SFSP sponsors are already familiar with operating a child nutrition program, they are not required to provide documentation that they have practices in place to ensure that the meal service, recordkeeping, and other program requirements are performed properly. Successful operation of SFSP provides evidence of this performance standard.
Management plans are not required as part of the CACFP application unless the institution intends to sponsor more than one facility. In addition, at-risk centers should be afforded latitude with regard to budgets. FNS has previously noted that, although a budget is a necessary element of determining the viability of a program applicant, the level of budgetary detail requested should be commensurate with the size and scope of the applicant. In the case of at-risk centers, states are encouraged to obtain only the information necessary to enable them to assess the viability of the applicant (see CACFP 11-2007, Accommodations for Non-Traditional Program Operators, July 3, 2007). CACFP sponsoring organizations are required to provide documentation indicating that they meet their state’s criteria for ensuring delivery of benefits to otherwise unserved facilities or participants. Because states already have a priority system in place for selecting SFSP sponsors to eliminate an overlap in service, states generally need not require existing SFSP sponsors applying to participate in CACFP to provide any further documentation of providing benefits to unserved facilities or participants.
The following are required for participation in SFSP and therefore are not required to be produced as part of the CACFP application process:
- Confirmation of Area Eligibility of Centers: SFSP sites that establish area eligibility through the use of school data may use their area eligibility determination for SFSP and CACFP afterschool meals for a period of five years. There is no need to re-establish area eligibility for CACFP. However, because area eligibility for CACFP At-risk Afterschool Meals must be based on school data, SFSP sites that established eligibility using Census data or based on income eligibility forms must provide additional documentation indicating that they are area eligible based on school data.
- Non-discrimination Statement: SFSP sponsors are not required to resubmit a nondiscrimination policy statement to participate in the CACFP. Additionally, if the media release submitted for SFSP indicated that the sponsor offers year-round meal services, an additional media release is not required.
- Health and Safety Inspections: Where the state or local health and safety inspection standards for at-risk afterschool centers and SFSP feeding sites are the same, CACFP state agencies may accept documentation of a current inspection obtained by a sponsor for SFSP.
- Documentation of Tax-exempt Status: Private nonprofit organizations are not required to resubmit documentation of tax exempt status for CACFP when such documentation was submitted for purposes of participation in SFSP.
As a reminder, institutions are no longer required to apply to CACFP annually. Once the initial application has been approved, limited annual information is required (see CACFP 19-2011, Child Nutrition Reauthorization 2010: Child and Adult Care Food Program Applications).
State agencies that administer more than one USDA child nutrition program are required to enter into a single agreement with school food authorities (SFAs) with respect to the operation of any combination of the child nutrition programs [7 CFR §225.6(e)]. State agencies are also strongly encouraged to enter into a single agreement with other sponsors operating more than one child nutrition program. Therefore, if the same state agency administers both CACFP and SFSP, SFSP sponsors interested in offering afterschool meals through CACFP during the school year are required only to sign an addendum to the existing SFSP agreement. In states where CACFP and SFSP are administered by different state agencies, the sponsors must submit applications to, and enter into an agreement with both state agencies. However, the state agencies are encouraged to work together to share information and streamline the application and agreement process.
Sponsors that participate in SFSP are familiar with operating a USDA child nutrition program and should not be required to attend training prior to submitting a CACFP application. Similarly, members of the food service staff who receive meal service training under the SFSP are not required to attend separate CACFP training on meal services.
However, sponsor administrative staff must be informed about program requirements and attend the necessary training. CACFP state agencies may offer targeted training on the at-risk component of CACFP during SFSP trainings to eliminate the need for the sponsor’s administrative staff to attend a separate CACFP training.
CACFP sponsors must conduct pre-approval visits to each center to discuss program benefits and requirements and ensure that the facility is capable of providing the proposed meal service. State agencies may waive the requirement for pre-approval visits for centers that operated as SFSP sites.
Sponsors that operate SFSP and CACFP at-risk meals are not required to monitor their sites following the SFSP requirements and then monitor those same sites again following the CACFP requirements during the school year. Instead, such sponsors may follow the CACFP monitoring schedule year-round. If sponsors choose to follow the CACFP monitoring schedule year-round, one of the three annual reviews must occur during the summer, review for SFSP requirements, include the review of a meal service, and be unannounced; two reviews must occur during the school year, review for CACFP requirements, at least one must include the review of a meal service, and at least one must be unannounced.
A sponsor’s excess funds from either CACFP or SFSP may be used in its operation of other child nutrition programs. Therefore, if at the end of the summer a sponsor has excess reimbursement from its operation of SFSP, those funds may be used for allowable costs in its operation of CACFP.
We recognize that these simplifications are easiest to implement when the same state agency administers both the CACFP and SFSP. However, in states where the CACFP and SFSP are administered by separate agencies, we encourage the CACFP and SFSP state agencies to collaborate and share information where applicable to continue to streamline participation. The FNS regional office also may offer assistance in these situations.
State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions regarding this memorandum to the appropriate state agency. State agency contact information is available at http://www.fns.usda.gov/cnd/Contacts/StateDirectory.htm. State agencies should direct questions to the appropriate FNS regional office.
Child Nutrition 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.