| DATE: | February 10, 1998 |
| MEMO CODE: | SFSP Policy Memorandum #1-98 |
| SUBJECT: | Sponsor and Site Application Requirements |
| TO: | Regional Directors Child Nutrition Programs All Regions |
Section 19(a) of the National School Lunch Act addresses the need to reduce paperwork to the maximum extent possible for state and local education agencies, other entities participating in nutrition programs, and families of children participating in these programs. The extensive Summer Food Service Program (SFSP) sponsor and site application procedures have repeatedly been targeted by program administrators, including those in attendance at the recent National SFSP meeting, as potential areas where paperwork could be reduced and state and sponsor administrative efforts better targeted.
In response to these concerns, this memorandum provides states with a waiver procedure for those sponsor and site application requirements which they believe are no longer essential in some situations. Therefore, any state agency that wishes to adopt the revised application requirements set forth in this memorandum may obtain a waiver by notifying the regional office, in writing, of its intent to implement all or only selected provisions of this memorandum. This will greatly simplify the waiver process for State agencies wishing to implement some or all of these changes to the current application procedures. Please note that the state agency reporting requirements normally associated with waivers do not apply to waivers granted under this memorandum. However, regional offices should provide us with a list of states that receive these waivers by June 1, 1998.
It is evident that many state agencies believe that some current application procedures are no longer necessary for sponsors and sites that have successfully participated in the SFSP. Therefore, this memorandum establishes revised application procedures for “experienced” sponsors and sites which state agencies may take advantage of for the 1998 SFSP. For the purposes of this memorandum, “experienced” sponsors are those sponsors which, in the determination of the state agency, operated the same sites in the SFSP in the prior year with no significant deficiencies or operational problems. Experienced sponsors which add new sites must follow the current site application requirements for their new sites, but may follow the revised requirements for all other sites, and for sponsor information.
The following chart outlines current sponsor and site application requirements, and revised requirements for “experienced” sponsors. References to “N/A” on the chart are intended to convey that a sponsor need not report the required information unless a change has taken place since the information was most recently provided. Of course, this memorandum does not relieve sponsors of their responsibility to inform the state agency of changes that take place after the application has been completed.
Sponsor and Site Application Requirements
General Requirements for Site Information Sheets
| Current Requirements, with Regulatory Citations | Requirements for “Experienced” Sponsors/Sites |
| Description of organized and supervised system for serving meals to attending children. [§225.6(cX2)(i)(A)] | N/A |
| Estimated number and types of meals to be served and time of meal service for each site. [§225.6(c)(2)(i)(B)] | Estimated number and types of meals to be served and time of meal service for each site. |
| Arrangements for delivery and holding of meals until they are served, and for storing and refrigerating leftovers. [§225.6(c)(2)(i)(C)] | N/A |
| Arrangements for food service during periods of inclement weather. [§225.6(c)(2)(i)(D)] | N/A [Note: If the site's location will change in the event of inclement weather, sponsors must always provide notice of the alternate location to the state agency.] |
| Access to a means of communication for making adjustments to the number of meals delivered in accordance with the site's average daily attendance. [§225.6(c)(2)(i)(E)] | N/A |
| Whether each site is rural or non-rural, and whether the site's food service will be self-prepared or vended. [§225.6(c)(2)(i)(H)] | N/A [Note: If this provision is waived, state agencies should remind sponsors that a failure to report a change could result in over- or under-payments.] |
Additional Requirements for Area-Eligible Sites: Open and Enrolled
| For “open” and “open-enrolled” sites, documentation of area eligibility based on elementary school free and reduced price enrollment data or census data, as appropriate based on guidance issued 2/25/94. Such documentation is required to be obtained every other year. [§§225.6(c)(2)(i)(F) and (G); §225.6(c)(2)(ii)(B)] [Note: Per guidance issued on 4/23/92, “open-enrolled” sites exist where enrolled sites are initially open to broader community participation, but the sponsor limits attendance for reasons of security, safety, or control.] | For “open” and “open-enrolled” sites, new documentation of area eligibility every 3 years when based on elementary school free and reduced price enrollment data. When census data are used, new documentation of eligibility is required only when new census data are made available, or earlier if the state agency has reason to believe that an area's socioeconomic status has changed significantly since the last census. [Note: This requirement is not intended to establish 1999 as the “base year” for site eligibility determinations. For example, a site which last established its eligibility in 19976is not required to re-establish eligibility until 1999.] |
| For “closed enrolled” sites, the projected number of children enrolled and the projected number of children eligible for free and reduced price meals based on individual free and reduced price applications. [§225.6(c)(2)(i)(G)] | For “closed enrolled” sites, the projected number of children enrolled and the projected number of children eligible for free and reduced price meals based on individual free and reduced price applications. |
Additional Requirements for Camps
| Documentation showing the number of children enrolled in each session who are eligible for free or reduced price meals. [§225.6(c)(2)(iii)] | Documentation showing the number of children enrolled in each session who are eligible for free or reduced price meals. |
Additional Requirements for Migrant Sites
| Certification from a migrant organization which attests that the site serves children of migrant worker families. If the site also serves non-migrant children, the sponsor must also certify that the site predominantly serves migrant children. [§225.6(c)(2)(ii)(A)] | N/A |
Additional Requirements for Homeless Feeding Sites
| Submission of information sufficient to document that the site is not a residential child care institution, and that the site's primary purpose is to provide shelter and one or more meal services per day to homeless families. [§225.6(c)(2)(iv)] | N/A |
| Description of the method used to ensure that cash payments, food stamps, and in-kind services are not received for any SFSP meal served to children at the site. [§225.6(c)(2)(iv)] | N/A |
Additional Requirements for National Youth Sports Program (NYSP) Sites
| Certification that all children who will receive meals are enrolled participants in the NYSP. [§225.6(c)(2)(v)] | N/A |
Other Requirements for Sponsor Applications
| Information in sufficient detail to enable the state agency to determine whether the applicant meets the criteria for participation as set forth in §225.14. [§225.6(c)(2)(vi)] [Note: Sponsors must meet all of the requirements of current §225.14, except for those provisions modified by this memorandum (§§225.14(d)(1), (d)(4), (d)(5), and (d)(6)).] | N/A |
| The extent of program payments needed, including a request for advance payments and start-up payments, if applicable. [§225.6(c)(2)(vi)] | The extent of program payments needed, including a request for advance payments and start-up payments, if applicable. |
| A staffing and monitoring plan. [§225.6(c)(2)(vi)] | A staffing and monitoring plan. |
| A complete administrative and operating budget. [§225.6(c)(2)(vii)] | A complete administrative and operating budget. |
| If an invitation for bid (IFB) is required under section 225.15(g), a plan for and synopsis of the IFB. [§225.6(c)(2)(viii)] | N/A |
| For sponsors that seek to operate the program as units of local, municipal, county or state government, or as private nonprofit organizations, certification that they will have direct operational control over the program, as defined in §225.14(d)(4). [§225.6(c)(2)(x)] | N/A |
Instead of having two applications—one for new sponsors and one for experienced sponsors - states may wish to distribute “pre-printed” applications to their experienced sponsors. These preprinted applications would contain information from the sponsor's previous year's application for those items listed above for which annual submission of information is not required, and blanks for sponsors to fill in with the remaining annual information. Sponsors would review the pre-printed information, and make changes as necessary. States may also wish to have a signature page on which the sponsor certifies that it has updated the pre-printed information as necessary.
Please forward this memorandum to your state agencies immediately so that interested states may receive waivers in time for implementation this summer. Please convey to your states, however, that requesting a waiver under this memorandum is strictly voluntary.
STANLEY C. GARNETT
Director
Child Nutrition Division