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SY 2022-23 Unanticipated School Closure Comparison Table

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Technical Assistance
Resource Materials

The USDA Food and Nutrition Service (FNS) is offering this comparison table to assist state agencies and program operators as they transition from operations under COVID-19 nationwide waivers to operations designed around their own unique circumstances. For Summer Food Service Program (SFSP) and Seamless Summer Option (SSO) operations during unanticipated school closures (USC) in school year (SY) 2022-2023, state agencies have the choice to return to normal, pre-COVID operations or to seek flexibilities through submission of individual state waivers authorized by Section 12(l) of the Richard B. Russell National School Lunch Act. Please note that FNS expects that program operators will only use these waivers when congregate meal service is limited by the COVID-19 pandemic. Specific information for each waiver is provided in the table.

Topic
What You Could Do Using COVID-19 Nationwide Waivers (including waiver #)
Options Available for SY 2022-23 Operations
Certification
Site EligibilityNationwide Waiver of Area Eligibility Requirements for Service Institutions Operating the Summer Food Service Program during Unanticipated School Closures in School Year 2021-22 (waiver #104) allowed all states to approve sponsors to operate SFSP open sites during USC in areas not located in “Areas in which poor economic conditions exist.”Sites may qualify to operate as opens site during USC when the site has participated in the program at any time during the current year or in either of the prior two calendar years or when a site is area eligible using methods for establishing site eligibility for summer 2022 and school year 2022-23 described in SP 10-2022, CACFP 08-2022, SFSP 04-2022, Area Eligibility for Summer 2022 and School Year 2022-23, May 13, 2022 or methods for establishing site eligibility outside of novel COVID-19 related options as described in SP 08-2017, CACFP 04-2017, SFSP 03-2017, Area Eligibility in Child Nutrition Programs, Dec. 1, 2016.
Area Eligibility for Closed Enrolled SitesNationwide Waiver to Allow Area Eligibility for Closed Enrolled Sites in the Summer Food Service Program and the National School Lunch Program Seamless Summer Option – Extension 2 (waiver #64) allowed all states to approve sponsors to qualify to operate SFSP closed enrolled sites that are area eligible, including during USC for SY 2020-21, without the collection of income applications.

Closed enrolled sites must establish site eligibility through individual income eligibility of children attending the site.

States with individual waivers of area eligibility for closed enrolled sites for summer 2022 may use them during USCi.

Meal Service
Non-congregateNationwide Waiver to Allow Non-Congregate Meal Service for Service Institutions Operating the Summer Food Service Program during Unanticipated School Closures in School Year 2021-22 (waiver #101) allowed meals to be served in a non-group setting to children and adult participants during USC.

Congregate meal service is required during USC (children must be served and eat each meal on site in a supervised setting).

States may request an individual waiver of congregate meal service for USC operations occurring under COVID-19 conditions in SY 2022-23ii.

Meal Times

Nationwide Waiver of Meal Times Requirements for Service Institutions Operating the Summer Food Service Program during Unanticipated School Closures in School Year 2021-2022 (waiver #102) suspended federal mealtime restrictions during USC, allowing states to approve more than one meal to be served at a time.

  • Sites could distribute meals for multiple days at one time, generally up to one week.
  • Meal distribution or delivery times still had to be established.

Service times must be established for each meal, and only one meal may be served during each service time.

  • SFSP: three hours must elapse between the beginning of one meal service, including snacks, and the beginning of another meal service, except that four hours must elapse between lunch and supper if no snack is served.
  • SSO: breakfast must be served in the morning; lunch must be served 10 a.m.-2 p.m.; supper service must begin before 7 p.m. and end by 8 p.m.; snacks must be adequately spaced between meals.

States with an individual waiver of meal time requirements for summer 2022 may use them during USC. States also may request an individual waiver of meal time requirements specifically for USC operations occurring under COVID-19 conditions in SY 2022-23iii.

Parent/Guardian Pick UpNationwide Waiver to Allow Parents and Guardians to Pick Up Meals Served by Service Institutions through the Summer Food Service Program during Unanticipated School Closures in School Year 2021-22 (waiver #103) allowed parents or guardians to pick-up meals during USC on an eligible child’s behalf.

Meals must be served directly only to eligible children.

States may request an individual waiver to allow parents/guardians to pick up meals on a child’s behalf for USC operations occurring under COVID-19 conditions in SY 2022-23iv.

Meals at School SitesNationwide Waiver to Allow Service of Meals at School Sites during Unanticipated School Closures in School Year 2021-22 (waiver #105) allowed state agencies to approve meal service operations at school sites during USC.

Meals must be served at non-school sites during USC.

States may request an individual waiver to allow meal service operations at school sites for USC operations occurring under COVID-19 conditions in SY 2022-23v.

Claiming & Reimbursements
Meal Reimbursement - Seamless Summer OptionNationwide Waiver to Allow Summer Food Service Program Reimbursement Rates in SY 2021-22 (waiver #86) allowed school food authorities to claim National School Lunch Program Seamless Summer Option meals and snacks at the Summer Food Service Program reimbursement rates.Meals must be claimed at the current National School Lunch and School Breakfast Program reimbursement rates for the Seamless Summer Optionvi.
Meal RequirementsNationwide Waiver to Allow Offer Versus Serve Flexibilities in the Summer Food Service Program – Extension 2 (waiver #67) allowed all state agencies to approve the use of Offer Versus Serve (OVS) meal parameters by both school food authority and non-school food authority sponsors using the Summer Food Service Program meal pattern.

Operators must follow the meal patterns for each program.

  • Summer Food Service Program: Must follow the Summer Food Service Program meal pattern.
  • Seamless Summer Option: Must follow the National School Lunch Program meal pattern.
  • Offer Versus Serve is permitted only for school food authority sponsors for both SFSP and SSO.

States with individual waivers to allow OVS by non-SFAs for summer 2022 may use them during USCvii.

Monitoring & Reporting
Daily Records - Does not include financial, training, monitoring, and other sponsor level record

Same as normal operations

  • Meal counts, separated by meal type and by:
    • First meals served to eligible children
    • Second meals served to eligible children
    • Meals served to adults performing food service labor (allowable cost but not reimbursed)
    • Meals served to non-program adults, if any (neither allowable cost nor reimbursable)
    • Excess or leftover meals
    • Non-reimbursable meals
  • Count of meals prepared or delivered, by type
  • Menus

Same as normal operations

  • Meal counts, separated by meal type and by:
    • First meals served to eligible children
    • Second meals served to eligible children
    • Meals served to adults performing food service labor (allowable cost but not reimbursed)
    • Meals served to non-program adults, if any (neither allowable cost nor reimbursable)
    • Excess or leftover meals
    • Non-reimbursable meals
  • Count of meals prepared or delivered, by type
  • Menus
First Week Site VisitsNationwide Waiver to Waive First Week Site Visits in the Summer Food Service Program - Extension 2 (waiver #65) allowed sponsors to not visit each of their sites at least once during the first week of operation under the program, for sites that operated successfully in the previous year and sponsors that successfully participated in the Child and Adult Care Food Program or the National School Lunch Program.

States must return to conducting first week site visits.

States with individual waivers of the first week site visit requirement for summer 2022 may use them for USC operations occurring under COVID-19 conditions in SY 2022-23viii.


i Individual waivers of eligibility requirements for closed enrolled sites for summer 2022 have an effective period of May 1, 2022 to April 30, 2023 and may be used for USC operations occurring during the school year through April 30, 2023.

ii Individual waivers of the congregate meal service requirement during USC have an effective period of Oct. 1, 2022 to April 30, 2023. FNS expects that flexibilities provided under the congregate meal service Section 12(l) waiver will only be implemented by program operators when congregate meal service is limited by the COVID-19 pandemic. Local program operators, in collaboration with the state agency, are best positioned to determine to what extent these waivers are needed.

iii Individual waivers of the meal times requirements for summer 2022 have an effective period of May 1, 2022 through April 30, 2023 and may be used for USC operations occurring during the school year through April 30, 2023. Individual waivers of the meal times requirement during USC during SY22-23 have an effective period of Oct. 1, 2022 to April 30, 2023. FNS expects that flexibilities provided under the meal times Section 12(l) waiver for USC during SY 2022-23 will only be implemented by program operators when congregate meal service is limited by the COVID-19 pandemic. Local program operators, in collaboration with the state agency, are best positioned to determine to what extent these waivers are needed.

iv Individual waivers to allow parent pick up of meals during USC have an effective period Oct. 1, 2022 to April 30, 2023. FNS expects that flexibilities provided under the parent pick up Section 12(l) waiver will only be implemented by program operators when congregate meal service is limited by the COVID-19 pandemic. Local program operators, in collaboration with the state agency, are best positioned to determine to what extent these waivers are needed.

v Individual waivers to allow meal service at school sites during USC have an effective period of Oct. 1, 2022 to April 30, 2023. FNS expects that flexibilities provided under the school sites Section 12(l) waiver will only be implemented by program operators when congregate meal service is limited by the COVID-19 pandemic. Local program operators, in collaboration with the state agency, are best positioned to determine to what extent these waivers are needed.

vi The annual adjustments to the reimbursement rates for the National School Lunch and School Breakfast Programs are effective from July 1, 2022 through June 30, 2023. These rates include a temporary increase authorized under Section 2 of the Keep Kids Fed Act of 2022. The rates notice can be found here.

vii Individual waivers to allow OVS for summer 2022 have an effective period of May 1, 2022 through April 30, 2023 and may be for USC operations occurring during the school year through April 30, 2023.

viii Individual waivers of the first week site visit requirement for summer 2022 have an effective period of May 1, 2022 through April 30, 2023 and may be used for USC operations occurring during the school year through April 30, 2023.

Page updated: December 20, 2023