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A School Food Authority’s Guide to School Meals: Summary of Flexibilities

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While many schools will return to their regular cafeteria meal service this year, some may continue with socially distant meal service models, such as grab-and-go meals or meals in the classroom. Some schools will provide a virtual learning option for students who are not ready to return to in-person learning this fall, for example, due to an increased risk of severe illness and/or special healthcare needs.

When to use meal service flexibilities

For school year (SY) 2021-2022, the following meal service flexibilities are available to schools:

These flexibilities should only be used when needed due to the public health emergency. For example, a school that has returned to in-person learning for all children would no longer need to provide parent/guardian pick-up of meals. However, if the same school unexpectedly needs to transition to virtual or hybrid learning for a period of time, the school could allow parents/guardians to pick up meals for their children during that time. (See Question 4 of SP 15-2021.) Schools are also reminded of flexibilities available during unanticipated school closures under regular program policy.

When to use meal pattern flexibilities

USDA understands the importance of healthy school meals, and encourages schools to meet the nutrition standards to the greatest extent possible. We also understand that some schools may need targeted flexibility to maintain a safe meal service in SY 2021-2022. USDA issued a nationwide waiver to allow schools to request flexibility for select meal pattern requirements that are more difficult to meet when serving pre-packaged, grab-and-go meals, which some schools may continue with for safety reasons.

To participate under the meal pattern flexibilities, schools must contact the state agency for approval. We expect this waiver to help during this transition year, as schools work towards more nutritious meals. For information on using meal pattern flexibilities due to supply chain or product availability disruptions, click here. Additionally, USDA encourages schools to visit the Team Nutrition webpage to find resources to support healthier school meals.

When to use meal claiming flexibilities

Under standard meal counting and claiming, schools must establish individual children’s eligibility for free or reduced price meals, and collect payment from children who are not eligible for free school meals. In SY 2021-2022, schools may participate under the Seamless Summer Option (SSO) of the National School Lunch Program (NSLP), which allows schools to serve free meals to all students. SSO speeds up service of meals and facilitates implementation of Centers for Disease Control and Prevention (CDC) recommendations for safe school meal service, which include serving meals outdoors or in classrooms.

Schools participating under SSO in SY 2021-2022 will also receive the Summer Food Service Program reimbursement rates—which generally are 11 percent higher for breakfast and 15 percent higher for lunch. This additional funding will help to offset the costs associated with providing a safe meal service, such as personal protective equipment and packaging costs for individually wrapped, grab-and-go meals.

Both of these meal care claiming flexibilities are available to schools for all of SY 2021-2022.

When to use afterschool care program flexibility

Normally, to participate in the afterschool meals component of the Child and Adult Care Food Program (CACFP), sites must be located in an eligible area. To participate in the NSLP Afterschool Snack service, sites must be located in an eligible area or count and claim snacks based on each child’s eligibility status. For SY 2021-2022, USDA issued a waiver allowing schools and afterschool care centers to participate in the afterschool meal/snack service, and serve and claim all meals and snacks at the free rate, regardless of their location. Schools offering afterschool care programs can use this waiver to increase access to nutritious meals and snacks in the new school year. The afterschool care program flexibilities may be used during the regular school year throughout SY 2021-2022.

Pandemic Electronic Benefit Transfer (P-EBT)

While schools are understandably focused on children’s return to the classroom, we know that both school and state administrators have contingency plans in place that include the possible resumption of virtual or hybrid schedules. As part of that planning, USDA will encourage states to develop and submit P-EBT plans to USDA as early in the school year as possible. With an approved P-EBT plan on the shelf, states and schools will be in a position to deliver benefits to children when they’re needed most.

It is essential that schools work with closely with their states to collect and submit the data necessary to support their states’ P-EBT plans. The active involvement of school administrators is essential to the efficient delivery of P-EBT benefits that are targeted to the children whose access to school meals is compromised by a temporary return to virtual instruction.

It is equally important that schools and school districts provide an opportunity for households to establish their eligibility for P-EBT benefits throughout the school year. That means accepting and processing free and reduced-price meal applications from households with children who are new to the school system, and to households who have become newly income-eligible for benefits.

Guidance for SY 2021-2022 is available on USDA's P-EBT website. USDA looks forward to working with schools and school districts, through their states, to ensure the success of their P-EBT programs.

Supply chain or product availability disruptions

Schools have options for addressing unexpected distribution or product availability disruptions. Using authority under 2 CFR 200, School Food Authorities (SFAs) may conduct emergency “non-competitive” procurements to replace unexpected contract gaps with alternative sources or products. SFAs may be challenged in finding adequate replacements, and may need to consider multiple products or multiple vendors to address disruptions. SFAs might consider purchasing smaller quantities through multiple local producers or small businesses as alternatives for products they generally purchase in a single, large transaction through a broadline distributor.

When a school is unable to safely provide a meal component at meals due to supply chain issues related to COVID-19 or is unable to meet dietary specifications with available products, requesting meal pattern flexibilities is an option. For SY 2021-2022, USDA issued a targeted nationwide meal pattern waiver that provides flexibilities for select school meal pattern requirements. To participate under the meal pattern flexibilities, schools must contact the state agency for approval. In addition, USDA provided a waiver to state agencies that allows them to not take fiscal action when a school is unable to serve all required meal components.

Some SFAs have reported challenges with procuring the appropriate type and variety of fluid milk to meet meal pattern requirements. In addition to meal pattern flexibilities, there are existing milk-specific flexibilities (7 CFR 210.10(d)(2)) that may be used to address supply chain issues in a disaster, such as supply chain disruptions caused by COVID-19. If emergency conditions temporarily prevent a school that normally has a supply of fluid milk from obtaining delivery of that milk, a state agency may allow the school to serve meals during the emergency period with an alternate form of fluid milk or without fluid milk.

SFAs could experience increased costs as they adapt to unexpected disruptions. The increased reimbursement rates that FNS is providing for SFAs participating in the SSO waiver for SY 2021-22 may be helpful in defraying these additional costs.