Attachment H - Administration Guide for the Summer Food Service Program

OMB Control# 0584-0280
Expiration Date 12/31/2022

Attachment H. Administration Guide for the Summer Food Service Program

This information is being collected from sponsoring organizations. Section 13 of the Richard B.
Russell National School Lunch Act (NSLA) 42 U.S.C. § 1758, as amended, authorizes the Summer
Food Service Program for Children (SFSP). This information is required to administer and operate
this program in accordance with the NSLA. Under the Privacy Act of 1974, any personally
identifying information obtained will be kept private to the extent required by law. According to the
Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a valid OMB control number.
The valid OMB control number for this information collection is 0584-0280. The time required to
complete this information collection is estimated to average 2 hours and 30 minutes per response,
including the time for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the collection of information. Send
comments regarding this burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, to: U.S. Department of Agriculture, Food and
Nutrition Services, Office of Policy Support, 1320 Braddock Place, Fifth Floor, Alexandria, VA
22314,ATTN: PRA (0584-0280*). Do not return the completed form to this address.

ADMINistration
guide
Summer FOOD

SERVICE PROGRAM

1

2016

The 2016 edition of this guidance has been revised and extensively reformatted for ease of use. The
revisions to content from the 2015 version, in the pre-designed format, can be found on the USDA
FNS Summer Food Service Program web page at: http://www.fns.usda.gov/sfsp/handbooks.
In addition, throughout the text, references have been made to memoranda issued by the Food and
Nutrition Service. The numbering system may differ from your State agency.

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations
and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering
USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or
reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g.
Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where
they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact
USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made
available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form,
(AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or
write a letter addressed to USDA and provide in the letter all of the information requested in the form. To
request a copy of the complaint form, call (866) 632-9992.
Submit your completed form or letter to USDA by:
MAIL:
U.S. Department of Agriculture
Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410
FAX:
(202) 690-7442
EMAIL:
program.intake@usda.gov
This institution is an equal opportunity provider.

REVISED MARCH 2016

CONTENTS

−INTRODUCTION

1
2
3

Introduction
Additional Resources
Summer 2016

−CHAPTER 1: PROGRAM ELIGIBILITY

7
8
9

12
15
18
23
27

Sponsor Eligibility
Specific Eligibility Requirements for Sponsors
Additional Eligibility Requirements and
Flexibilities by Sponsor Type
Sponsor Participation in Other Child
Nutrition Programs
Site Eligibility
Special Types of Sites
Documenting Site Eligibility
Documenting Participant Eligibility
Questions and Answers

−CHAPTER 2: SPONSOR AND SITE IDENTIFICATION

33
34
36
37
40
43

State Agency Selection Priorities for Sponsors
Sponsor Priorities for Selecting Sites
Selecting Food Service Staff
Ensuring Site Access through Promotion
Pre-Operational Requirements
Questions and Answers

−CHAPTER 3: SPONSOR APPLICATION

47
48
50
51
53
54

Sponsor Training
Application Requirements
Review of Applications
State-Sponsor Agreement
Appeal Rights
Questions and Answers

−CHAPTER 4: MEAL REQUIREMENTS

57
58
60
61
64
65
66
66
67
69
70

Number and Type of Meals
Meal Pattern Requirements
Meal Service Requirements
Meal Service Options
Serving Local Foods
Meal Time Requirements
Meal Count Forms
Site Caps
Leftover Meals or Components
Meals Served to Adults
Questions and Answers

10

CONTENTS

−CHAPTER 5: VENDING OPTIONS

75
75
77
79
79
80

Sponsor Meal Preparation
Purchasing Meals from Schools
Purchasing Meals from a FSMC
USDA Foods
Additional Foods
Questions and Answers

−CHAPTER 6: PROCUREMENT AND BID PROCEDURES

83
83
85
96
97
99

Procurement
Procurement Methods
Food Service Management Company Contracts
Procurement Tips and Strategies
Local Procurement Strategies
Questions and Answers

CHAPTER 7: STAFF DUTIES AND TRAINING

105
107
112
114

Staff Duties
Training
Volunteer Opportunities
Questions and Answers

−CHAPTER 8: PROGRAM INTEGRITY

117
120
121
124

Monitoring Sites
Administrative Reviews of Sponsors
Civil Rights Requirements
Questions and Answers

CHAPTER 9: PROGRAM COSTS AND REIMBURSEMENTS

127
129
131
132
133
134
135

Advance Payments
Program Reimbursements
Other Sources of Program Income
Unallowable Costs
Non Reimbursable Meals
Non-Contractible Management Responsibilities
Questions and Answers

−CHAPTER 10: RECORDKEEPING

139
141
143
144

Administrative Records
Operating Cost Records
Maintaining Records of Costs and Tracking Funds
Questions and Answers

4

REference Materials

(Attachments Listed By Program Function)

PROGRAM BASICS

147
153
154
155
159

Definitions of Program Terms
Glossary of Acronyms
SFSP Meal Pattern Requirements
SFSP Federal Guidance
SFSP Site Definition & Eligibility Documentation

APPLICATION AND PLANNING
161 Proactive Planning for Sponsors

163 Agreement to Furnish Food Service for the SFSP
164 Application Requirements for New and Experienced
Sponsors/Sites
166 Food Service Equipment Needs
167 Sample Position Description (Cook)
168 Prototype Household Application for the SFSP
170 Planning Checklist: SFSP
172 Sample News Release: Open Sites
173 Sample News Release: Enrolled Sites and Camps
174 Sponsor/Site Agreement for the SFSP
175 Training Checklist for Administrative Staff
176 Training Checklist for Monitors
177 Training Checklist for Site Staff

MANAGING THE MEAL SERVICE
179 Meal Count Worksheet for Camps
180
181
182
184
185
186
187

Inventory Control Sheet
Inventory Control Sheet Instructions
Daily Meal Count Form
Instructions for Meal Count Form – Daily
Meal Count (Weekly Consolidated)
Instructions for Meal Count Form (Weekly Consolidated)
Meal Count – Consolidation Form of First (1st) and Second
(2nd) Meals Served
188 Racial and Ethnic Data Form
189 Racial and Ethnic Data Form Instructions

RECORDKEEPING AND COST ACCOUNTING 190 Checklist of Records
192
193
194
195
196
197
198

Mileage Record – Administrative Staff
Mileage Record – Site and Food Service Staff
Time Report – Administrative Staff
Time Report – Site and Food Service Staff
Summary of Administrative Expenses
Summary of Administrative Expenses Instructions
Worksheet for Cost of Food Used

PROCUREMENT 199 Federal Contract Provisions
PROGRAM INFORMATION 202 Comparison of Programs SFSP/NSLP/SSO
206 Income Eligibility Guidelines

5

Introduction

The U.S. Department of Agriculture’s (USDA) Summer Food Service Program (SFSP) relies on innovative and collaborative
efforts to reach children in need. USDA encourages collaborations with valued partners at the National, State, and local
levels to raise awareness about the nutrition gap low-income children face when schools close for the summer and the
availability of summer meals to close this gap.
The SFSP was established to ensure that low-income children continue to receive nutritious meals when school is not in
session. Free meals that meet Federal nutrition guidelines are provided to all children at approved SFSP sites in areas
with significant concentrations of low-income children.
The SFSP operates during school vacations, primarily in the summer months – from May through September. It may also
provide meals during vacation breaks in schools that are operated on a year-round basis or a continuous school calendar,
or during emergency school closures from October through April.
USDA’s Food and Nutrition Service (FNS) administers the SFSP at the national and regional levels. Within each state, the
Program is administered by the State department of education or an alternate state-designated agency.
Locally, public or private non-profit organizations that want to “sponsor” the Program apply and are approved by the
State agency to operate the Program. These sponsoring organizations sign Program agreements with their respective
State agencies and are responsible for overseeing Program operations. Sponsors receive Federal reimbursement from
the State agency to cover the administrative and operating costs of preparing and serving meals to eligible children at
one or more meal sites.

1

Additional

Resources

FNS has several resources available to aid individuals and organizations interested
in working with the SFSP:
•

The main SFSP website is a great starting point to find all web-based Program resources:
http://www.fns.usda.gov/sfsp/summer-food-service-program-sfsp

•

The SFSP Handbooks webpage includes links for Program guidance for sponsors, monitors, and site supervisors:
http://www.fns.usda.gov/sfsp/handbooks
•

2016 Nutrition Guidance for Sponsors: information on Federal nutrition and food service requirements.

•

2016 Monitor’s Guide: information on sponsors’ monitoring role for the SFSP.

•

2016 Site Supervisor’s Guide (Spanish and English versions): information on the site supervisor’s role in the SFSP.

•

2016 State Monitor Guidance: information on State agencies’ monitoring role for the SFSP *New Guidance, Coming
Spring 2016*

•

The FNS Policy Memos webpage includes up-to-date information about important Program changes:
http://www.fns.usda.gov/sfsp/policy

•

The Legislation webpage provides an overview of government legislation impacting the Program:
http://www.fns.usda.gov/sfsp/legislation

•

The Summer Toolkit includes tips and resources to help sponsors prepare for and improve the Program:
http://www.fns.usda.gov/cnd/summer/library/toolkit.pdf

•

The Mapping Tools page can be used to find underserved areas and potential partners:
http://www.fns.usda.gov/sfsp/mapping-tools-summer-meal-programs

•

The Summer Meals Best Practices webpage is full of inspiring SFSP success stories from across the country:
http://www.fns.usda.gov/sfsp/best-practices

•

The Farm to Summer webpage includes tips on how to improve Summer Meal Programs through the integration of
local foods and related enrichment activities: http://www.fns.usda.gov/farmtoschool/farm-summer

•

The FNS monthly Summer Meals Newsletters offer timely tips sponsors can use to improve Program outreach and
expansion: http://www.fns.usda.gov/sfsp/summer-meal-newsletters

2

Summer 2016
Learning does not end when school lets out. Neither does the need for good nutrition. USDA Summer
Meal Programs offer nutritious meals and snacks to low-income children during the summer months
and long vacations. Often, these children receive meals through the School Breakfast Program (SBP)
or the National School Lunch Program (NSLP) during the school year, and may be at risk of hunger or
poor nutrition during the summer months. The SFSP brings Federal dollars into communities in the
form of combined reimbursements for meals and operations/administrative costs. Local government
and community leaders can help by making SFSP a priority.

Check out the Summer Meals Toolkit page!
http://www.fns.usda.gov/sfsp/summer-meals-toolkit

3

Increasing access and participation in
the SFSP is an important FNS priority.
Historically, summer meals served through
the SFSP and the NSLP reach only about

17% OF 21M
children receiving free or reduced-price
lunches during the school year.

FNS has developed new resources for use by State agencies and
other organizations participating in these programs. The SFSP
relies on innovative and collaborative efforts to reach children in
need. The “Summer Meals Toolkit” is designed for individuals and
organizations interested in serving as summer meal champions
in their communities at any level of program administration. It is
a valuable resource for partner organizations on how they can
best support and participate in the SFSP. The toolkit includes
information on meal service at open sites, partner collaboration,
vendor relations, and other best practices.
As an organization/sponsor interested in administering the
SFSP, you are the link that translates this Federal benefit into
nutritious meals and snacks for children. If you are new to the
Program, please consider participating as a site or a sponsor
in this important mission. If you are a returning sponsor, please
consider adding sites and activities that will help draw children
to your existing program.

LOOKING AHEAD:
Through the State Targeted Assistance Team (STAT)
Project, USDA-FNS has identified key best practices for
increasing and sustaining participation in the SFSP, and
has shared these strategies with Regional offices, State
agencies, and other partners across the nation. Through
the continuation of the STAT Project, and the establishment of long-term sustainability goals, USDA-FNS hopes
to maintain its historic Program growth and to continue expanding access and participation in underserved
areas while maintaining integrity.

4

5

CHAPTER 1

PROGRAM
ELIGIBILITY
• SPONSOR ELIGIBILITY
• SPECIFIC ELIGIBILITY REQUIREMENTS
FOR SPONSORS
• ADDITIONAL ELIGIBILITY REQUIREMENTS AND
FLEXIBILITIES BY SPONSOR TYPE
• SPONSOR PARTICIPATION IN OTHER CHILD
NUTRITION PROGRAMS
• SITE ELIGIBILITY
• SPECIFIC TYPES OF SITES
• DOCUMENTING SITE ELIGIBILITY
• DOCUMENTING PARTICIPANT ELIGIBILITY

sPONsOR
ELIGIBILITY
(7 CFR 225.14(b), (c), and (d))

Who may be a sponsor?
A sponsoring organization must be a public or private non-profit school food authority (SFA);
a public or private non-profit college or university; a public or private non-profit residential
summer camp; a unit of local, county, municipal, State, or Federal Government; or any other type of
private non-profit organization. All sponsors must also be tax exempt and must demonstrate the
administrative and financial ability to manage a food service effectively. Most sponsors must provide
a year-round public service to the area in which they intend to provide the SFSP.

Sponsor Responsibilities
SFSP sponsors must be able to assume responsibility for the entire administration of the
Program. As a sponsor, an organization at a minimum will:
•
•
•
•

Attend the State agency’s training
Locate and recruit eligible sites
Hire, train, and supervise staff and volunteers
Competitively procure food to be prepared or a
vendor for meals to be delivered

•
•
•
•

Monitor all sites
Prepare claims for reimbursement
Ensure that the sites are sustainable
Maintain all program documents for 3 years, plus
the current year

For organizations not yet ready to take on the responsibilities required of a sponsor, participation as a site under
an existing sponsor is the best option. This is the most effective way to prepare an organization to become a
sponsor in future years.

7

SPEcific ELIGIBILITY
Requirements
FOR SPONSORS
(7 CFR 225.14)

TO BE DEEMED ELIGIBLE, SPONSORS MUST:

Demonstrate Financial
and Administrative Capability

requirement for sponsors of residential camps, migrant
sites and in certain other limited circumstances.

Potential and returning sponsors are required to
demonstrate that they have the necessary financial
and administrative capability to comply with Program
requirements. They must accept final financial and
administrative responsibility for all of their sites.

Exercise Management Control Over Sites
New applicants and returning sponsors (not exempted by
the State agency) must demonstrate in their applications
that they will exercise management control over the
meal service at all of their sites. Management control of
the meal service means that the sponsor is responsible
for maintaining contact with meal service staff, ensuring
that there is adequately trained meal service staff on site,
and monitoring site operations throughout the period of
program participation. This management responsibility
cannot be delegated below the sponsor level. The quality
of the meal service, the conduct of site personnel, and
the adequacy of recordkeeping reflect directly upon the
sponsor’s performance. This performance is subject
to audit by the State agency, by the USDA Office of the
Inspector General, and by the Government Accountability
Office (GAO).

Not Be Seriously Deficient
To be approved, applicants must not have been declared
seriously deficient or terminated from the SFSP or any
other Federal Child Nutrition Program in previous years.
However, such an applicant may be approved if the State
agency determines that it has taken appropriate corrective
actions to prevent recurrence of the deficiencies and has
repaid any outstanding debts.

Serve Low-Income Children
Sponsors must agree to provide regularly scheduled meal
service for children in designated low-income areas (called
“areas in which poor economic conditions exist”) or they
must agree to serve low-income children. Camps do not
need to meet this criterion.

Conduct Pre-Operational Visits
Prior to approval, sponsors must visit new sites and any
sites that had operational problems in the previous year.
When a sponsor applies for the SFSP, they must certify that
the required pre-operational site visits have been conducted
and that sites are capable of providing meal service for the
number of children as planned.

Conduct a Non-profit Food Service
Sponsors must conduct food services through SFSP that
are not for profit. A sponsor is operating a non-profit food
service if the food service operations are principally for
the benefit of participating children and all of the Program
reimbursement funds are used solely for the operation or
improvement of such food service. This does not mean the
Program must break even or operate at a loss, but that all
income must be used for the sole purpose of operating a
non-profit food service.

Sign Written Agreements
Approved sponsors must sign a written permanent
agreement with the State agency. See State-Sponsor
Agreement in “Chapter 3: Sponsor Applications.”

Check out the Tips
for Successful Sponsors Toolkit page!

Provide Year-Round Service
Sponsors must provide a year-round public service to
the area in which they intend to provide the SFSP. State
agencies may grant exceptions to this year-round service

http://www.fns.usda.gov/sfsp/summer-meals-toolkit

8

Additional
Eligibility
Requirements
AND FLEXIBILITIES BY SPONSOR TYPE
SFAs and CACFP Sponsors
SFAs and other organizations currently in good standing in the NSLP, SBP or Child and Adult Care Food Program (CACFP)
are not required to submit further evidence of financial and administrative capability when applying for SFSP participation.
Typically, SFA and CACFP institutions participating in other Child Nutrition Programs have already demonstrated that
they have the financial and administrative capability necessary to operate the NSLP, SBP, or CACFP. A CACFP institution is
considered to be in good standing if it has no serious deficiencies declared in its most recent review cycle. However, the
State agency has the discretion, and is encouraged, to deny the applications or, at a minimum, require additional evidence
of financial and administrative capability from SFAs and CACFP sponsors that have had significant problems operating the
NSLP, SBP, or CACFP (SFSP Memorandum 5-2012: Simplifying Application Procedures in the Summer Food Service Program,
October 31, 2011,SFSP Memorandum 4-2013: Summer Feeding Options for School Food Authorities, November 23, 2012 and
SFSP Memorandum 6-2014: Available Flexibilities for CACFP At-Risk Afterschool Sponsors and Centers, November 12, 2013).

Private Non-Profit Sponsors
Special rules apply to private non-profit organizations. Private non-profit sponsors must be tax exempt under section
501(c) of the Internal Revenue Code of 1986. Although churches must be tax-exempt, there is no Federal requirement that
they provide documentation of their tax-exempt status. Therefore, churches are the only private non-profit organizations
not required to obtain documentation of Federal tax exempt status; all other private non-profit organizations must provide
documentation from the IRS of their tax-exempt status. For purposes of Program participation, a church could be its
integrated auxiliaries, or a convention or association of churches, synagogue, religious order, or religious organization that is
an integral part of a church, and that it is engaged in carrying out the functions of a church (IRS Publication 557, Tax-Exempt
Status for Your Organization). The State agency can provide more specific details about the participation of all private non­
profit organizations (SFSP Memorandum 09-2013, Tax Exempt Status for Private Non-profit Organizations and Churches in the
Child and Adult Care Food Program and the Summer Food Service Program, January 24, 2013).

Experienced Sponsors
Sponsors and sites that have successfully participated in SFSP in the previous year (meaning those that have not been
found to be seriously deficient in Program operation) may submit condensed information for succeeding years. Experienced
sponsors and sites in good standing, meaning those which successfully participated in the previous year, only need to
submit information that is likely to change from year to year and are not required to submit the same detail of organizational
and operational information required of new sponsors. The condensed information required of experienced sponsors and
sites is described in 7 CFR 225.6(c)(3) (SFSP Memorandum 5-2012: Simplifying Application Procedures in the Summer Food
Service Program, October 31, 2011).

9

SPONSOR
PARTICIPATION
IN OTHER CHILD NUTRITION PROGRAMS

Sponsors participating in additional Federal Child Nutrition Programs must meet requirements
for dual participation in these programs. As detailed below, some of these requirements may be
different from what is required of sponsors not participating in other Child Nutrition Programs.
The NSLP

Seamless Summer Option (SSO)

(7 CFR 225.2, 225.14(d)(2))

The SSO offers SFAs an alternative option to SFSP, with
streamlined administrative requirements. Guidance and
clarification on all summer meal options available to
schools is provided through SP 07-2013, SFSP 04-2013,
Summer Feeding Options for School Food Authorities Revised,
November 23, 2012, available at http://www.fns.usda.gov/
sites/default/files/SP07_SFSP04-2013.pdf

Schools offering accredited summer school programs may
be reimbursed for serving meals during the summer in one of
three ways: through the SFSP, the NSLP and SBP, or the NSLP
Seamless Summer Option (SSO). Schools wishing to serve
meals only to children enrolled in academic summer school
programs may receive reimbursement only through the NSLP
and SBP (SFSP Memorandum 04-2013: Summer Feeding
Options for School Food Authorities, November 23, 2012).

The SSO allows SFAs to provide free summer meals in
low income areas during the traditional summer vacation
periods and, for year-round schools, school vacation
periods longer than 15 school days. The SSO is designed to
encourage more SFAs to provide meals during summer
and other school vacation periods. This option combines
features of the NSLP, SBP, and SFSP. See SP 37-2015, 2015
Edition of Questions and Answers for the National School
Lunch Program’s Seamless Summer Option, May 22, 2015
for more information. Refer to the chart in Attachment 30
for a comparison of programs.

If, in addition to serving children enrolled in accredited
summer school, the school plans to serve children in the
community at large, it may operate an open site through
the SFSP or the SSO as described below. However, the SFA
must ensure that these sites are open not only to children
enrolled in summer school, but to any children in the area
served by the site.
Schools that operate accredited summer school programs
may not enroll in the SFSP as a restricted open site instead
of an open site, so that meals may be served only to
summer school participants. This is not the intent of the
restricted open site option and is an unauthorized use of
this site designation. The purpose of the restricted open
site designation in SFSP is to allow sponsors that want to
operate an open site to restrict or limit site participation
due to reasons of space, security, safety, or control.

The Special Milk Program (SMP)
Sponsors may elect to operate the SFSP at some of their
sites while operating the SMP at other sites. However, a
single site cannot simultaneously participate in the SFSP
and the SMP.
Sponsors electing to administer the SMP must enter into
a separate agreement with the State agency to operate
the SMP at those sites or at those times when it is not
participating in the SFSP. The State agency can provide
information on operating the SMP.

More information can be found in the

Working with Schools Toolkit page!

http://www.fns.usda.gov/sites/default/files/sfsp/SMTSchools.pdf

10

The CACFP

This provision will be most applicable to At-Risk Afterschool
Care Programs. Because most At-Risk Programs may not
receive reimbursement during the summer months, we
encourage these programs to convert to the SFSP for the
summer. In that case, they can serve the same children that
they serve during the school year.

CACFP institutions that develop a separate food service
program for children who are not enrolled in the CACFP, and
meet SFSP eligibility criteria, may be approved to participate
in the SFSP. Institutions that are approved for both the CACFP
and the SFSP must ensure that the same children are not
served meals in both programs. Separate records must be
kept for each program. Institutions may not switch back and
forth between participation in CACFP and participation in SFSP
to serve the same children.

For more information about the At-Risk Programs, please see
the “At-Risk Afterschool Meals Program Handbook”: http://
www.fns.usda.gov/sites/default/files/atriskhandbook.pdf
In other cases, however, if CACFP institutions wish to
participate in the SFSP, they must serve children that would
otherwise not be served under the CACFP. Institutions may not
switch programs simply to receive a higher reimbursement
in the summer months (SFSP Memorandum, 05-2012:
Simplifying Application Procedures in the Summer Food
Service Program, October 31, 2011 and SP 06-2014, CACFP
03-2014, SFSP 06-2014: Available Flexibilities for CACFP
At-Risk Sponsors and Centers Transitioning to Summer Food
Service Program (SFSP), November 12, 2013).

Institutions may not establish separate entities using separate
tax identification numbers to serve the same children
under different child nutrition programs in order to avoid
the Program restrictions or to earn higher reimbursement.
However, if there is a legitimate need for a separate
organization and it meets the requirements in the preceding
paragraph, then it may be approved to participate in SFSP if it
meets SFSP eligibility criteria.
In an effort to improve participation in SFSP by eligible
institutions, some application requirements for CACFP
institutions in good standing that wish to apply to participate
in SFSP for the first time have been waived. “Good standing”
means the institution must have no serious deficiencies
declared in its most recent review cycle. CACFP institutions
that want to operate the SFSP at the same sites where they
provide meal service through the CACFP may follow the
application requirements for experienced SFSP sponsors and
sites instead of the application requirements for new sponsors
and sites (SP 06-2014, CACFP 03-2014, SFSP 06-2014:
Available Flexibilities for CACFP At-Risk Sponsors and Centers
Transitioning to Summer Food Service Program (SFSP),
November 12, 2013).

For more information about Child Nutrition

Programs, visit the FNS Web site at:

http://www.fns.usda.gov/child-nutrition-programs

11

Site
Eligibility
(7 CFR 225.6(c)(2) and (3))

Sponsors may operate the SFSP at one or more sites, which are the actual locations where meals
are served and children eat in a supervised setting. Eligible sites are those that serve children
in low-income areas or those that serve specific groups of low-income children. Sponsors must
provide documentation that proposed sites meet the income eligibility criteria required by law.
There are three common types of sites: open sites, camps (residential and nonresidential), and
closed enrolled sites.
There are also sites that serve special populations of children or have unique characteristics. These include, but may not be
limited to: restricted open sites, migrant sites, and National Youth Sports Program (NYSP) sites. In the following section, we
describe these types of sites and discuss how sponsors can document their eligibility. See Attachment 5 for a summary of site
descriptions and ways to document site eligibility.

Open Sites

Restricted Open Sites

(7 CFR 225.2 definitions, Attachment 1)

(7 CFR 225.2 definitions, Attachment 1)

Most sponsors establish site eligibility on “need and
openness.” If a site is located in a needy area where 50 percent
or more of the children residing in the area are eligible for
free or reduced-price school meals (see “Documenting Site
Eligibility,” below) and meals are made available to all children
in the area on a first-come, first-serve basis, these sites
are considered open. Sponsors of open sites must take the
necessary steps to allow meal service access to all children
requesting a meal at the site. Information regarding the meal
service at open sites must be publicized in the community
served. See below for information on how to document that a
site is eligible to be open.

On occasion, a sponsor that would normally operate an
open site – meaning initially open to broad community
participation – must restrict or limit the meal site’s
attendance for reasons of space, security, safety, or control.
In recognition of these circumstances, these types of sites
operate as restricted open sites. The sponsors must make
known publicly that the site is open on a first-come, firstserve basis to all children of the community at large, but that
the meal service will be limited as stated above.
Both open and restricted open sites must be located in a
school attendance area where 50 percent or more of the
children residing in the area are eligible for free or reducedprice school meals. This percentage must be documented
by data provided by public and non-profit private school
officials, census data, welfare or education agencies, zoning
commissions, or other appropriate sources.

NOTE:
To qualify as a restricted open site, the site initially must be open to broad community participation from the
eligible area in which it is located.
The only limits that may be imposed on participation are daily limits for reasons of security, safety, space or control.

12

Closed Enrolled Sites
household applications, the sponsor must carefully monitor
actual participation during its early program visits to
ensure that the 50 percent level is actually reached. (Refer
to the Income Eligibility Guidelines, Attachment 31).

(7 CFR 225.2 definitions, Attachment 1)

Closed enrolled sites are usually established where:
• An identified group of needy children live in a
“pocket of poverty”
•

Identified low-income children are transported to a
congregate meal site located in an area with less than
50 percent eligible children

•

A program provides recreational, cultural, religious, or
other types of organized activities for a specific group
of children.

Accredited summer schools do not qualify as closed enrolled
sites and should obtain reimbursement for meals under the
NSLP, unless they are also open to the community for the
meal service and are in an area where at least 50% or more
of the children qualify for free or reduced-price meals. In
addition, residential and non-residential camps may not use
area eligibility to establish site eligibility.

These types of sites are open only to enrolled children or to
an identified group of children, as opposed to the community
at large. Closed enrolled sites must also establish the
eligibility either through the individual income eligibility of
the children attending the site or through area eligibility. To
establish eligibility based on the income of the individual
children; sites must collect household applications. At least
50 percent of the enrolled children at the site must be eligible
for free or reduced-price school meals.

For-Profit Sites
State agencies may approve meal service sites that are not
identified as non-profit locations if the sites:
• Are operated under the sponsorship of an eligible
public or private non-profit service institution

Instead of determining the individual income eligibility of
each enrolled child, a site may document its status as a
closed enrolled site by using area eligibility information, as
described in the next section. This may only be used if the
site is serving children that live in the area in which the site
is located (SFSP Memorandum: Waiver for Closed Enrolled
Sites, November 17, 2002).

•

Operate as open sites or restricted open sites

•

Are located in an area in which at least 50 percent of
the children are from households that are eligible for
free or reduced-priced school meals

•

Make meals available to all children in the area and serve
meals to children on a first come, first served basis

•

Serve all meals at no charge.

Enrolled for-profit sites and for-profit camps are not eligible
to participate.

The site information sheet that sponsors submit to the
State with an application to participate in the SFSP must
include the projected number of children eligible for free
or reduced-price school meals and the projected total
enrollment for each site. If site eligibility is based on

If approved to operate the meal service at a for-profit site,
a sponsor must maintain operational control over the meal
service at the site and must ensure that no SFSP funds are
provided to the site. The site operators may not prepare the
meals, and funds may not be provided, given or otherwise
paid to the site to employ site staff. Only the sponsor’s
trained staff and volunteers and sponsor-trained site staff
serving as volunteers are permitted to distribute the meals
(SFSP Memorandum 13-2011: For Profit Locations as Meal
Sites, April 8, 2011).

Gardening is a great way to keep kids active and engaged
in your program. For more tips on offering local foods and
agriculture-based activities, visit:
http://www.fns.usda.gov/farmtoschool/farm-summer

13

NSLP Operated Sites

camps, participants spend the duration of the organized
program in a 24-hour supervised care setting and
receive a regularly scheduled food service. Sponsors of
nonresidential camp sites must offer a continuous schedule
of organized cultural or recreational programs for enrolled
children between meal services. Unlike open, restricted
open and closed enrolled sites, sponsors of both residential
and nonresidential camps do not have to establish area
eligibility. However, they must collect and maintain individual
household applications. Camps are reimbursed only for
those enrolled children who meet the free or reduced-price
eligibility standards.

SFAs applying to operate the SFSP at the same sites
where they provide meal services through the NSLP may
follow the application requirements for experienced SFSP
sponsors and sites instead of the application requirements
for new sponsors and sites (SFSP Memorandum 4-2013:
Summer Feeding Options for School Food Authorities,
November 23, 2012).
SFAs applying to operate the SFSP must provide the
following information:
• Whether the site is rural or non-rural
•

Whether the site’s food service will be self-prepared
or vended

•

If a migrant site, certification from a migrant
organization that the site serves children of migrant
worker families and that it primarily serves migrant
children if it also serves non-migrant children (see
Migrant Sites chapter)

•

If a homeless site, information demonstrating the
site is not a residential child care institution (RCCI),
description of the method used to ensure that no
cash payments or other in-kind services are used
for meal service, and certification that the site only
claims meals served to children.

Tribal Governments
A Tribal government is recognized as a “public entity” or
“local government,” when consistent with state law. Thus,
a Tribal government may sponsor SFSP sites as long as
other eligibility requirements are met. A Tribal government
granted non-profit status would be considered a private
non-profit entity for purposes of SFSP and, therefore, could
act as a sponsor of SFSP sites as long as other eligibility
requirements are met (SFSP Memorandum 14-2012: Tribal
Participation in the Child and Adult Care Food Program and
Summer Food Service Program, July 24, 2012).

Check out the FNS Sample Letter
to Tribal Leaders!

Camps
(7 CFR 225.2 definitions, Attachment 1)

Camps can be residential or nonresidential day camps
which offer regularly scheduled food service as part of
an organized program for enrolled children. In residential

http://www.fns.usda.gov/sites/default/files/cnd/SMT­
LettertoTribalLeaders.pdf

14

SPECIAL TYPEs
OF SITES
(7 CFR 225.2 definitions, 225.6(c)(2)(i)(J), and 225.6(c)(3)(i)(D))

Rural Sites

The State agency will be able to provide information on
whether sites are considered rural for program purposes.

The SFSP has two different levels of administrative
reimbursement rates. The higher reimbursement rates are
for sponsors of sites that prepare or assemble their own
meals and for sponsors of sites located in rural areas. The
lower rate is for all other sponsors.

Migrant Sites
(7 CFR 225.6(c)(2)(i)(K))

Migrant site eligibility is based upon a determination that
the site predominantly serves children of migrant workers.
The sites operate like area-eligible open or restricted open
sites and are reimbursed for meals served to all attending
children. The determination of site eligibility based upon
migrant status must be updated annually.

A rural area is any area that is not part of a Metropolitan
Statistical Area as defined by the Office of Management and
Budget (OMB).
With the approval of the State agency, an area may be
defined as rural if it is a part of a Metropolitan Statistical
Area (MSA), but is isolated from the urban center. An MSA is:
• A locale where there is at least one urbanized area of
50,000 or more in population, plus adjacent territory that
has a high degree of social and economic integration
with the core as measured by commuting ties; or
•

To confirm migrant status, sponsors must submit
information obtained from a migrant organization that
certifies that the site serves a majority of children of
migrant workers. If the site also serves non-migrant
children, the sponsor must also certify that the site
predominantly serves migrant children. This status
information must be updated annually. Contact your State
agency to be put in contact with your local migrant center
(SFSP Memorandum 04-2007: Migrant Site Eligibility
Determinations, February 23, 2007).

An area where there is at least one urban cluster with
a population of at least 10,000 but less than 50,000,
plus adjacent territory that has a high degree of social
and economic integration with the core as measured by
commuting ties.

Continuous School Calendar/Year-Round Sites

For more information on Metropolitan Statistical Areas,
see OMB Bulletin No. 13-01, Revised Delineations of
Metropolitan Statistical Areas, Micropolitan Statistical
Areas, and Combined Statistical Areas, and Guidance on
Uses of the Delineations of These Areas, February 28, 2013,
at http://www.whitehouse.gov/sites/default/files/omb/
bulletins/2013/b13-01.pdf

(7 CFR 225.2 Definitions)

A “continuous school calendar” is defined in the SFSP
regulations as a situation in which all or part of the student
body of a school is (a) on a vacation for periods of 15
continuous school days or more during October through
April and (b) in attendance at regularly scheduled classes
during most of May through September.

Sponsors may use the FNS Rural Designation Tool to
determine whether a site is rural: http://www.fns.usda.gov/
rural-designation

Some school districts use a calendar that provides less than 15
days for off-track periods. In these situations, State agencies
may waive the 15-continuous-school-day requirement provided
that the school system is operating regular class sessions (i.e.,
not summer school or remedial classes for a portion of the
student body) on a year-round basis.

Sponsors should consider only those locales not
designated as Metropolitan to be rural (SFSP
Memorandum 04-2015; Rural Designations in the Summer
Food Service Program, April 21, 2015). Please consult your
State agency for further clarification on these concepts or
reference OMB Bulletin No. 10-02.

Check with your State agency for additional guidance.

15

If the income eligibility standards for participation in NYSP
are stricter than those used to determine eligibility for free
or reduced-price meals then it will qualify for participation
in the SFSP as well. In addition to written certification
that the site meets SFSP income eligibility guidelines,
sponsors must review the site’s records to verify that the
information is correct.

When schools operate on a year-round or continuous school
calendar, the SFSP may offer meals throughout the year to
preschool children and off-track students (i.e., year-round
students on vacation at times other than the summer).
These sites may be open or closed enrolled sites, located in
the school or at other locations.
If operated as an open site at a location other than the
school, the meal service must be open to the entire
community and must be eligible based on school or census
data. While the meal service is intended to serve off-track
students, it is possible that an on-track student may show
up at the site. In these situations, sponsors are not expected
to identify or exclude on-track students. Sponsors should
plan for or prepare for additional meals and consider
adding more site staff to supervise the meal service.

Upward Bound
Closed enrolled sites that are not area eligible and
that serve both Upward Bound and non-Upward Bound
participants must maintain applications on file to
document that enough children meet the individual income
eligibility requirements to satisfy the 50 percent threshold
required for closed enrolled sites. However, because
Upward Bound requires that two-thirds of the participants
in a program must be both low-income and potential
first-generation college students, closed enrolled sites
that serve only Upward Bound participants automatically
qualify for SFSP participation (SFSP Memorandum 06­
2015: Categorical Eligibility in the Summer Food Service
Program, December 8, 2014).

If the site is operating as closed enrolled, meals may be
served only to enrolled preschool children and off-track
students (at least 50 percent of enrolled participants must
be eligible for free or reduced-price school meals).
If a year-round site is located in the school, sponsors must
be careful not to “double claim” meals or claim SFSP rates
for meals served to on-track students participating in the
NSLP. Schools that operate both year-round SFSP and NSLP
or SBP should establish different meal services for the yearround and on-track populations, keep separate meal counts,
and develop cost allocation plans for proper proration of
overhead and administrative costs between the programs.

Mobile Sites
Traditionally, SFSP sites are located in schools,
playgrounds, parks, wfaith-based organizations,
community buildings, or similar places. Mobile meals may
provide the flexibility sponsors need to reach children
who do not have access to such traditional sites. In rural
areas, where children may live in isolated locations,
access to meal service sites operated by schools, parks
and recreation departments, and private non-profit
organizations is often limited. In urban areas, violence and
traffic safety concerns are examples of issues that may
limit viable options for site locations.

The National Youth Sports Program (NYSP) Sites
(7 CFR 225.2 definitions and 225.6(c)(2)(i)(I))

A NYSP site may qualify for the Program by:
• Determining that 50 percent of the children enrolled
reside in geographical areas where poor economic
conditions exist;
•

Determining that 50 percent of the children enrolled
meet the income eligibility guidelines for free or
reduced-price school meals; or

•

Certifying in writing that it meets the income eligibility
guidelines of the Department of Health and Human
Services (DHHS), which is the primary grantor for NYSP
(SFSP Memorandum 06-2015: Categorical Eligibility in
the Summer Food Service Program, December 8, 2014).

In mobile meals, the sponsor delivers meals to an area
using a route with a series of stops at approved sites in the
community. The meal service must take place on approved
days and the sponsor must serve reimbursable meals
during approved service times.

Check out the Mobile Meal toolkit
page for more tips!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT­
Mobile_Feeding.pdf

16

Sponsors operating mobile meals are subject to the
following requirements:
•
Each location where a bus or other vehicle stops to
serve meals must meet the site eligibility criteria and
other requirements set forth in Program regulations.
For example, the site must be area eligible, the meal
service must be supervised, meals must be consumed
on the bus or near the drop-off location, times of meal
service must be established, and the sponsor must
have the ability to adjust meal deliveries based on
fluctuations in attendance.
•

reimbursement for a third meal on days that it claims a
snack for reimbursement.
Camp reimbursements are based on the number of children
served who are eligible for free or reduced-priced meals.
Sponsors of camps must maintain the documentation that
demonstrates the free or reduced-price eligibility of the
children they claim reimbursement for and must make it
available for review by the State agency. Camps may also
charge non-eligible children a separate fee for meals.

Farmers Market Sites

Sponsors of mobile sites must take extra precautions
to ensure that food is safe for children to eat. State
and local health and safety standards must be met at
all times. At a minimum, food must be maintained at
proper temperatures along the entire delivery route,
and temperatures must be monitored with a food
thermometer. Program staff serving meals must follow
appropriate hand washing procedures, as required by
local health and safety regulations.

•

A site supervisor must be present at each meal service.
Mobile sites may operate as a full service route, where
the site supervisor travels with the vehicle along the
route and supervises the site at each stop or where
meals are delivered to each stop with an on-site
supervisor waiting to receive the meals. Site supervisors
must remain on site during the entire approved meal
service time, regardless of site attendance.

•

State and sponsor monitoring visits and reviews at
mobile sites must adhere to the same requirements as
traditional SFSP sites.

Across the country, sponsors are opening sites at farmers
markets as a way to increase access to healthy foods.
Concentrated foot traffic around fresh, nutritious foods,
along with existing events and activities, make farmers
markets ideal partners in helping kids and teens stay
active and nourished while school is out. Farmers markets
can provide a safe place for children to congregate, and
may offer the additional benefits of providing access to
the freshest ingredients, connecting children with the
sources of their food, increasing foot traffic to the market,
and raising community awareness about the Summer
Food Service Program. Setting up a meal site at a farmers
market also allows sponsors to leverage existing activities
that are associated with the market, giving kids an
enjoyable experience in addition to a healthy meal, and
removing the burden of coordinating activities from scratch.
State agencies and sponsors can use USDA’s Farmers
Market Directory to locate markets in their area at http://
www.ams.usda.gov/local-food-directories/farmersmarkets.

For more information on the mobile meal model, and
funding opportunities, consult SFSP Memorandum 2-2014:
Mobile Feeding Options, November 12, 2013.

Camp and Migrant Sites
(7 CFR 225.9(d)(10) and 225.16(b)(1))
By law, camp sponsors can only be reimbursed for meals
served to children who are eligible for free or reducedprice meals according to the income guidelines for the
NSLP and SBP. With State agency approval, camps and
migrant sites may claim reimbursement for serving up
to three meals or two meals and one snack to eligible
children each day. Therefore, a camp or migrant site
may not claim reimbursement for snacks on days that it
claims reimbursement for breakfast, lunch, and supper.
Alternately, a camp or migrant site may not claim

17

Documenting
Site Eligibility
Sponsors must be able to document that their sites are eligible to participate in the Program.
The documentation requirements vary by the type of site, as detailed below.
Documenting Area Eligibility for Open or
Restricted Open Site

Generally, sponsors will find it most helpful to directly
contact their State agency in order to obtain the current
year’s free and reduced-price data to document the need
of the area they wish to serve. The local public school
district and non-profit private schools serving the area
in which a sponsor intends to offer the SFSP may also
provide sponsors with the number of children who are
eligible for free or reduced-price school meals and the total
enrollment(s) of the school(s).

(42 U.S.C. §1761(a)(1)(A); (7 CFR 225.6(c))

The two primary sources of data that may be used to
determine whether the area that will be served is eligible
are school data or census data.
School data may be used to establish area eligibility,
excluding camps. In order for a site to be determined area
eligible, school data must indicate that the proposed meal
site is located in a school attendance area where at least 50
percent of the children are eligible for free or reduced-price
school meals.

In school districts where busing or school choice policies
are in place, if the site is located in the school from which free
and reduced-price meal eligibility data is obtained, sponsors
may always rely on the NSLP data for that individual school.
Additionally, where busing or school choice policies are in
place, but school attendance areas are still defined, school
and non-school site eligibility may be determined based on
the enrollment or attendance data obtained for:
• The school the children attend

School Data
To qualify sites, sponsors may use data from elementary,
middle, or high schools as long as the site is located in the
attendance area of the school. This data should be based on
the percentage of children in the school attendance area in
which the site is located that are certified eligible for free
or reduced-price school meals, not the actual school meal
participation rates. In most cases, current-year school data
provides the most accurate representation of an area’s
current economic circumstances. State agencies, at their
discretion, are permitted to use data from any month in the
school year to establish area eligibility. Once area eligibility is
established, the duration of determination for site eligibility
is five years. (SFSP Memorandum 03-2015: Area Eligibility
in Child Nutrition Programs, November 21, 2014 and SFSP
Memorandum 11-2014: Effective Date of Free or ReducedPrice Meal Eligibility Determinations, December 3, 2013).

•

The school the children would have attended (i.e., the
neighborhood school where the children live) were it not
for the school’s busing or school choice policy.

Program sponsors may determine a site to be area eligible
under the second option described above only if the SFA
is able to document the percentage of children eligible for
free or reduced-price school meals at each school before
and after students are reassigned. The same method
of determining site eligibility must be used for all sites
participating under a particular Program sponsor to avoid
duplicate counting.

Check out the Program Simplifications Toolkit for more on site eligibility!
http://www.fns.usda.gov/sites/default/files/cnd/SMT-ProgramSimplifications.pdf

18

If the school district does not have defined school
attendance areas, the use of school data is not permitted
for non-school sites. In this case, census data must be
used to determine area eligibility for NSLP and SFSP.
Please note that census data may be used as a first
choice for determining area eligibility for NSLP and SFSP,
rather than using the options described above, even if
school attendance areas are defined (SFSP Memorandum
3-2013: Determining Area Eligibility Based on School Data,
November 23, 2012).

using census data are required to use the most recent
data available. Once area eligibility is established, the
duration of determination for site eligibility is five years.
Therefore, eligibility must be reassessed every five
years for SFSP sites relying on census data to establish
eligibility (SFSP Memorandum 03-2015: Area Eligibility in
Child Nutrition Programs, November 21, 2014).
SFSP site eligibility can be determined using either Census
Block Groups (CBGs) or Census Tracts. Sites located in a
CBG or Census Tract in which 50 percent or more of the
children are eligible for free or reduced-price school meals
are considered area eligible. Additionally, a potential SFSP
site that is determined not to be area eligible, but is located
immediately adjacent to an eligible area, may request
State agency and Regional office approval to determine
site eligibility based on a weighted average of up to three
adjacent CBGs. In this case, an SFSP site will be considered
area eligible if the percentage of children eligible for free
or reduced-price meals in up to three adjacent CBGs when
averaged is 50 percent or more, provided that at least
40 percent of children in each of the individual CBGs are
eligible for free or reduced-price meals. Census Tracts may
not be combined.

Community Eligibility Provision (CEP)
As an alternative to collecting individual applications for
free or reduced-price meals, CEP allows schools and
local education agencies (LEAs) with a high percentage of
low-income children to offer free meals to all students.
Qualifying schools serve free lunch and breakfast through
the NSLP and SBP.
Individual school data must be used to determine area
eligibility for SFSP, even if schools are participating in
CEP as part of a group of schools or a school district and
claiming meals with a shared identified student percentage
(ISP). These individual school data are obtained by
contacting the State agency. In order to determine eligibility
using CEP data, multiply the most current school level ISP
by the 1.6 factor. This means if a school has an individual
ISP of at least 31.25, then the result will be at least 50
percent (31.25 x 1.6 = 50) and meal sites located in the
attendance area of the school are area eligible for 5 years.
Household income information collected via alternate
income forms (e.g., forms collected to allocate education
funding) may not be used to determine area eligibility (SFSP
Memorandum 3-2015: Area Eligibility in Child Nutrition
Programs, November 21, 2014).

Census Tract and CBG data are available through the
FNS Area Eligibility Mapper, which is located at: http://
www.fns.usda.gov/areaeligibility. The map also can be
used to conduct weighted averaging as discussed above.
Instructions for determining eligibility using these data
are available at: http://www.fns.usda.gov/sites/default/
files/Census%20Instructions%202014_0.pdf (SFSP
Memorandum 3-2015: Area Eligibility in Child Nutrition
Programs, November 21, 2014).
The Census Bureau estimates household income annually
using the American Community Survey (ACS). USDA
releases new census data every fiscal year (October
1). State agencies consider the information submitted
regarding area eligibility in its review of each applicable
SFSP Site Application.

For more information on CEP, see
http://www.fns.usda.gov/school-meals/community­
eligibility-provision

Area eligibility established using CEP data is effective for
a period of five years.

Because area eligibility for CACFP at-risk afterschool
meals must be based on school data, SFSP sites that
established eligibility using census data must provide
additional documentation indicating that they are area
eligible based on school data to participate in CACFP atrisk afterschool meals.

Census Data
Sponsors also may document the area eligibility of their
proposed open or restricted open sites on the basis of
census data. SFSP sites that choose to establish eligibility

19

HOW TO DETERMINE CENSUS AREA ELIGIBILITY

METHOD 1:

METHOD 2:

DETERMINING ELIGIBILITY USING THE FNS
AREA ELIGIBILITY MAPPER

DETERMINING ELIGIBILITY USING THE

FRAC FOOD MAPPER

1

1

Go to:

Go to either FRAC map:
CACFP

http://www.fns.usda.gov/areaeligibility

To find by address, enter the address in the
“Find address or place” box in the top right.

2
3

•

asp?command=scope&map=0

SFSP and SSO

Zoom in and out of the map using
the (+) and (-) signs, respectively.

•

http://216.55.168.186/FairData/SummerFood/
map.asp?command=scope&map=0

2
3

In the resulting map, the red
highlighted color indicates
eligibility as noted in the
map legend. Additional information,
including details for each CBG, can
be obtained by clicking on the map at
the address location. These additional
data include the CBG numerators and
denominators that may be used in the
weighted averages mentioned above.

4

http://216.55.168.186/FairData/CACFP/map.

To find by address, click on “Find”
and enter the address.

In the resulting map, the highlighted
color indicates eligibility as
indicated in the map layer key.

4

If an address falls on a border
between an eligible and ineligible
CBG, click on the blue star and then
INFO and scroll in the “2010 Block Group
Information” window to “Eligible? (Yes or No).

A larger map is available by
clicking “View Larger Map” at the
bottom of the screen.

For a more in-depth explanation of how to use the mappers, including how to
calculate weighted averages, please see :
http://www.fns.usda.gov/sites/default/files/Census%20Instructions%202014_0.pdf

20

Other Site Eligibility Data
If sponsors are unable to document the need of their area
or site(s) by using sources such as current-year school
data, recent census tract or CBG data, enrollment data,
or migrant children status, they should consult with their
State agency about the possibility of using other types of
data to determine area eligibility for a period of five years
(e.g., local zoning data, housing authority information,
economic surveys, etc.) to document site eligibility (SFSP
Memorandum 3-2015: Area Eligibility in Child Nutrition
Programs, November 21, 2014).

Using “area” eligibility data for the location of the
site, rather than using the household application to
document that at least half of the enrolled children at
each site are eligible for free or reduced-price school
meals. (This option is not available for camps.); (SFSP
Memorandum: Waiver Closed Enrolled Sites, November
17, 2002); or

•

Using census data when the site is located outside of
an eligible area

As part of the application process, sponsors of closed
enrolled sites must provide the State agency with:
• A statement of how they intend to document SFSP
eligibility, using one of the methods listed above

For example, if the proposed site is at a public housing
development, and school and census data cannot qualify
the site as area eligible, the State agency could assess
the income eligibility requirements of the public housing
development. If the income eligibility requirements are
less than or equal to SFSP income guidelines, then the
proposed site could be determined area eligible.
In addition, sponsors may document area eligibility by
submitting documentation from a Tribal authority which
certifies that the proposed site is located on a Tribal
reservation, on trust land, or in an Alaska Native village
where 50 percent or more of the children in the defined
area are eligible for free or reduced-price school meals.

•

An estimate of the total number of children enrolled at
the site; and

•

An estimate of the number of children enrolled at
the sites that are documented as eligible for free
or reduced-price school meals, unless using area
eligible data

Sponsors of closed enrolled sites that are not “area
eligible” must have the following information on file for
each site:
• Records of the total number of children enrolled
at the site; and

Documenting Closed Enrolled Site Eligibility
To qualify as a closed enrolled site, at least 50 percent of
the enrolled children must be from households that meet
the income eligibility guidelines. Sponsors can document
an enrolled site’s eligibility by:
• Obtaining lists by name and eligibility status of
enrolled children for free or reduced-price meals
from schools operating the NSLP or SBP. Parental
consent forms are not required in order for the local
SFA to provide this information to SFSP sponsors
•

•

•

List(s) of income eligible children provided by the
school system; or

•

The actual eligibility forms for income eligible children

Sponsors of closed enrolled sites that are “area eligible”
should follow the guidance for documenting area eligibility
for open or restricted open sites.

Documenting Camp Site Eligibility
Sponsors that operate residential summer camps
and nonresidential day camps offering both organized

Asking the parent or guardian of each enrolled child to
complete a household application (See Attachment 11)
21

programming and a regularly scheduled food service
may participate in the SFSP. Nonresidential day camps
may participate only as sites under eligible sponsoring
organizations. Enrolled for-profit sites or for-profit
camps are not eligible for participation in SFSP (SFSP
Memorandum 03-2011: For Profit Locations as Meal Sites,
April 8, 2011).

Duration of Income Eligibility Determinations: Guidance and
Q&As, October 31, 2014).
Sponsors of camps are not required to submit the approved
household applications or school lists of eligible children to
the State agency. However, they must maintain the lists or
original approved forms for all eligible children in separate
files for each camp session, and the documents must be
available for review by the State agency.

Unlike other types of sites, camps do not have to establish
income eligibility at the 50 percent level. Instead, camps
are reimbursed only for meals served to children who
meet the income eligibility criteria for free or reducedprice school meals. In order to determine eligibility
for children, camp sponsors may use the household
application (Attachment 11) or rely on list(s) of income
eligible children provided by the school system. However,
State agencies may require camp sponsors to use the
household application (Attachment 11) or a State agency
equivalent form.

Other Income Eligible Programs
Sponsors may utilize household applications from other
programs that base their eligibility on the same criteria
as the SFSP, but should contact the State agency to verify
that the same thresholds and definitions are used for both
programs. For example, sponsors can use documentation
of income-eligible Upward Bound participants, provided
and certified by an Upward Bound grantee, to document
the eligibility of closed enrolled sites, or residential
or non-residential camps. Upward Bound income
applications may be used in lieu of the SFSP application
to determine income eligibility for all SFSP participants
since both programs have an income eligibility threshold
of 185 percent of the national poverty guidelines (SFSP
Memorandum 06-2015: Categorical Eligibility in the
Summer Food Service Program, December 8, 2014).

SFSP sponsors of closed enrolled and camp sites must
collect and report to State agencies income eligibility
information in order to determine the eligibility of
individual participants for free meals under the SFSP
[Eligibility Duration for Closed Enrolled and Camp Sites
(7 CFR 225.15(f))]. Such information must be updated
annually and may not be more than 12 months old.
Household applications should be considered current and
valid until the last day of the month in which the form
was dated one year earlier. The date to be used to make
this determination is the date on which either the parent
or guardian signs the form, or the sponsor official signs
the application to certify eligibility of the participant. For
example, a form signed and dated by a sponsor on June 1,
2014, is considered valid until June 30, 2015. If the date of
parent signature is not within the month of certification or
the immediately preceding month, the effective date must
be the date of certification (SFSP Memorandum 01-2015:

Frequency of Site Eligibility Determinations
(7 CFR 225.6(c)(3)(i)(B))

In an effort to provide consistent administration across
Program lines to State agencies and SFSP sponsoring
organizations, sponsors of sites determined to be area
eligible based upon school and census data are only
required to submit documentation every five years (SFSP
Memorandum 03-2015: Area Eligibility in Child Nutrition
Programs, November 21, 2014). Sponsors using other data
sources, including household applications, must document
site eligibility every five years.

22

Documenting
PARTICIPANT
ELIGIBILITY
(7 CFR 225.2 Definitions, Attachment 1)

Children age 18 and under may receive meals through SFSP. A person 19 years of age and over who
has a mental or physical disability (as determined by a State or local educational agency) and who
participates during the school year in a public or private non-profit school program (established for
the mentally or physically disabled) is also eligible to receive meals.

SPONSORS MAY DETERMINE AND DOCUMENT PARTICIPANT ELIGIBILITY IN THE FOLLOWING WAYS:
Household applications

The English version of the USDA prototype application
can be found in this handbook as Attachment 11. Additional
information on household applications can be found in the
Eligibility Manual for School Meals available online: http://www.
fns.usda.gov/2015-edition-eligibility-manual-school-meals.

The household application prototype was designed by
USDA/FNS to determine the income eligibility of enrolled
children for all camps (residential and non-residential)
and closed enrolled sites. The information collected on
the household application includes household size and
income or the case number for benefits received under
the Supplemental Nutrition Assistance Program (SNAP,
formerly the Food Stamp Program), Temporary Assistance
to Needy Families (TANF), or the Food Distribution Program
on Indian Reservations (FDPIR). Sponsors may also use
alternate forms developed either by themselves or the State
agency, as long as the forms request the same information
as is found on the USDA prototype household application.
Forms developed by sponsors must be approved by the
State agency before use. Eligibility based on household
applications is valid for 12 months. Families must re-apply
and sponsors must re-determine income eligibility annually.

Head Start and Early Head Start Eligibility Forms
Children enrolled in Federal Head Start or Early Head
Start Programs are categorically eligible for free meals
in SFSP without further application. Sponsors may
establish eligibility of all Head Start enrollees through
documentation provided by the Head Start program.
Forms of acceptable documentation include: an approved
Head Start application, a statement of Head Start
enrollment, or a list of participants from a Head Start
official. Eligibility based on such documentation is valid for
12 months. Participation in a State-funded or Indian Tribal
Organization-funded pre-kindergarten program may be
a basis for extending automatic eligibility for free meals.
For additional information, please see SP 40-2013, CACFP
11-2013, SFSP 13-2013, Questions and Answers Regarding
the Participation of Head Start Programs in Child Nutrition
Programs, May 17, 2013, http://www.fns.usda.gov/sites/
default/files/SP40-2013os_0.pdf.

If a sponsor requires a form in a foreign language, the
translated NSLP Household Application may be used
to determine individual income eligibility in the SFSP.
Translated forms for NSLP are available online at http://
www.fns.usda.gov/cnd/Application/familyfriendlyapps.html.

23

outlines various types of requestors and any restrictions
on receipt of information.

In addition, infants and toddlers, and, in some instances,
pregnant women, who receive Early Head Start services
are categorically eligible. Applicant families also may
indicate a child’s participation in Head Start on the
household application (SP 38-2009, CACFP 08-2009, SFSP
07-2009, Extending Categorical Eligibility to Additional
Children in a Household, August 27, 2009).

If a request for information is not authorized under the
statute or when authorized release is limited to name
and eligibility status, the release can always be made
with informed consent by the parent or guardian (SFSP
Memorandum 15-2010: Disclosure Requirements for the
Child Nutrition Programs, August 23, 2010).

Disclosure Requirements for Eligibility Information
When SFSP sponsors have to obtain individual eligibility
information, they can obtain a child’s eligibility status from
another Child Nutrition Program operator to expedite the
certification process [7 CFR 245.6(f)].

Other Data
(7 CFR 225.2)

Area eligibility also may be established by using
documentation from other approved sources to
demonstrate that 50 percent or more of the children
in a defined area are eligible for free or reduced-price
school meals. Eligibility determinations using approved
alternative data also remain in effect for five years.
Approved alternative data sources may include:
• Departments of Welfare
• Zoning Commissions
• USDA’s Rural Development (RD) Housing Authorities
• Housing and Urban Development (HUD) Housing
Authorities
• Local Housing Authorities.

Schools and other Child Nutrition Program operators
may disclose aggregate information to the public
without parental notification. This is allowed so long as
an individual or group of children’s eligibility cannot be
identified through release of the aggregate data or by
means of deduction. This can be helpful to State advocacy
organizations and others considering the characteristics
of the Program (SFSP Memorandum 17-2014: Sharing
Aggregate Data to Expand Program Access and Services in
Child Nutrition Programs, April 24, 2014).
There are, however, restrictions on the disclosure and
use of information obtained from a household application,
as well as criminal penalties for improper release of
information. FNS recommends that SFSP sponsors cite
the regulation (7 CFR 225.15(f)-(l)) when responding to
requests for release of information. Part 5 of the Eligibility
Manual for School Meals, July 2015 edition, provides
specific guidance on applying the statutory and regulatory
requirements. The manual may be found at http://www.
fns.usda.gov/2015-edition-eligibility-manual-school­
meals. A convenient source of information is the manual’s
“Disclosure Chart,” found on page 82, which briefly

For example, if an SFSP site is located in a HUD housing
authority development and it does not qualify based
on school or census data, the site may be considered
area eligible using HUD data if residents of the housing
development meet income eligibility requirements that
are equivalent to or more restrictive than the SFSP
requirements. Sponsors should work with the State
agency to locate and with the agency that maintains the
data to confirm this information (SFSP Memorandum
3-2015: Area Eligibility in Child Nutrition Programs,
November 21, 2014).

24

Automatic Eligibility

National Youth Sport Program (NYSP)

Certain categories of children are automatically eligible
for free meals and no income information is required.
This is referred to as categorical eligibility. Children may
be classified as categorically eligible for a period of 12
months through:
• Participation in another comparable Federal
assistance program, including SNAP, FDPIR, or TANF
•

Documentation that the child is homeless, runaway, or
migrant, a foster child; or

•

Enrollment in a Federally-funded Head Start Program
or a comparable State-funded Head Start Program or
pre-kindergarten programs (SFSP Memorandum 06­
2015: Categorical Eligibility in the Summer Food Service
Program, December 8, 2014).

The NYSP is a national program intended to provide
economically disadvantaged youth, ages 9 to 16, the
opportunity to receive daily sports instruction and
educational programs. Although the NYSP is not currently
funded by Congress, children participating in NYSPs
operated by higher education institutions are eligible
to participate in SFSP upon showing residence in a
low-income area or on the basis of income eligibility
information provided for enrollment in the NYSP.
Therefore, colleges and universities that offer NYSP and
adhere to participant eligibility requirements that are the
same as or stricter than the SFSP income requirements
may consider participants categorically eligible for free
SFSP meals (SFSP Memorandum 06-2015: Categorical
Eligibility in the Summer Food Service Program, December
8, 2014).

NOTE:
•

Upward Bound

If one child in a household is receiving SNAP,
FDPIR, or TANF benefits, all other children
in the household are categorically eligible to
participate in SFSP.

Upward Bound is a program funded by the U.S.
Department of Education (DOE) to provide academic
support to teens from low-income families preparing
for college. While participants in Upward Bound are not
categorically eligible for free or reduced-price meals
under SFSP, sponsors of household programs may use
an Upward Bound application in lieu of a household
application to determine individual eligibility. Those
children who are determined eligible for Upward Bound
based on income may be considered eligible for SFSP
meals without further application. However, participants
who are determined eligible for Upward Bound based on
criteria other than income, such as being a potential first
generation college student, must complete an household
application in order to determine individual eligibility for
SFSP (SFSP Memorandum 06-2015: Categorical Eligibility
in the Summer Food Service Program, December 8, 2014).

(SFSP Memorandum 10-2010: Questions and Answers
on Extending Categorical Eligibility to Additional Children
in a Household, May 3, 2010).

Foster children can be certified eligible without an
application if the sponsor obtains documentation from
an appropriate State or local agency indicating the status
of the child as a child in foster care. In instances where
a child or family may temporarily reside with another
household, that child is still considered homeless. The
SFSP sponsor can determine eligibility for homeless
children through documentation provided by the homeless
liaison or another source (SFSP 05-2011-Revised, Child
Nutrition Reauthorization 2010: Categorical Eligibility of
Children in Foster Care, April 16, 2013).

Workforce Investment Act Participation
Applicants that participate in the Workforce Investment
Act (WIA) program are considered categorically income

25

eligible for the SFSP (SFSP Memorandum 06-2015:
Categorical Eligibility in the Summer Food Service Program,
December 8, 2014). The WIA is designed to link local
labor market needs and community youth programs and
service. For purposes of establishing SFSP eligibility,
sponsors must obtain either:
• A signed household application with a notation that
the applicant is a WIA participant; or
•

A list containing the names and ages of individual
WIA participants enrolled at that site and signed by
a WIA official

•

Received in addition to the service member’s basic pay

•

Received as a result of the service member’s
deployment to or service in an area that has been
designated as a combat zone; and

•

Not received by the service member prior to his/her
deployment to or service in the designated combat
zone. A combat zone is any area that the President of
the United States designates by Executive Order as an
area in which the U.S. Armed Forces are engaging or
have engaged in combat.

The exclusion of combat pay, as described above, is
extended to Deployment Extension Incentive Pay (DEIP).
DEIP is given to active-duty service members who agree
to extend their military service by completing deployment
with their units without re-enlisting.
This exemption applies only until the service members
return to their home station. Any additional DEIP payments
provided to service members serving at their home station
is considered income as they are no longer considered
deployed (SFSP Memorandum 4-2010 Revised: Exclusion of
Military Combat Pay, September 15, 2010).

Military Privatized Housing
The housing allowance for military personnel living in
privatized housing has been permanently excluded from
consideration as income when determining household
eligibility for free or reduced-price meals.
“Privatized housing” refers to the Military Housing
Privatization Initiative, a program operating at a number
of military installations. It is important to note that this
income exclusion is only for service members living
in housing covered under the Initiative. It is not an
allowable exclusion for households living off-base in the
general commercial/private real estate market (SFSP
Memorandum: Exclusion of the Housing Allowance for
Military Households in Privatized Housing - Reauthorization
2004: Implementation CN 1, July 1, 2004).

Armed Forces FSSA
The Department of Defense (DOD) provides certain
members of the Armed Forces and their families a Family
Subsistence Supplemental Allowance (FSSA) designed to
bring a household’s income up to the Federal poverty line
and decrease the reliance on SNAP for affected members
and their families. The amount of the FSSA, based on
household size and income may not exceed $500 per
month. Previously, the Child Nutrition Programs’ eligibility
determinations counted the FSSA payment as earned
income for households. In 2004, Congress established that
any FSSA that a household receives must not be treated as
income in determining eligibility for free and reduced-price
meals under any of the Child Nutrition Programs (SFSP
Memorandum 07-2006 Revised: U.S. Armed Forces Family
Supplemental Subsistence Allowance – Excluded from
Income Consideration; August 25, 2006).

Military Combat Pay
Military combat pay has been excluded from consideration
as income when determining household eligibility for
free or reduced-price meals. Combat pay is defined as
an additional payment made under Chapter 5 of Title 37
of the United States Code, or as otherwise designated
by the Secretary to be excluded, that is received by the
household member who is deployed to a designated
combat zone. Combat pay is excluded if it is:

26

26

CHAPTER 1

Questions
and answers
1

3

IF THE PROGRAM IS ADMINISTERED
BY A NON-PROFIT INSTITUTION,
DOES IT AUTOMATICALLY MEET THE
REQUIREMENT TO CONDUCT A NON-PROFIT
FOOD SERVICE UNDER SFSP?

MAY A PRIVATE, NON-PROFIT
SPONSOR CONTINUE TO PARTICIPATE
IN SFSP IF ITS TAX EXEMPT STATUS
HAS BEEN REVOKED BY THE IRS?
SFSP regulations at 7 CFR 225.2 and 225.14(a)(5) require
private, non-profit organizations to be tax-exempt in
order to be eligible to sponsor the SFSP. As a result,
SFSP sponsors that have had their tax-exempt status
automatically revoked by the IRS are not eligible for
participation in SFSP.

No. The institution’s status as a public or private nonprofit cannot be used as evidence that the institution
is operating a non-profit food service. Non-profit food
service status is determined by the scope of the food
service activities conducted by the institution and the
use of the food service revenues. All income to the
Program must be retained and used for the sole purpose
of operating a non-profit food service. The institution is
limited to allocating costs to the Program for allowable
expenses of serving meals to eligible participants.

2

If an approved SFSP sponsor has had its tax-exempt
status automatically revoked, the State agency will
inform the sponsor that it is seriously deficient and its
SFSP participation will be terminated in accordance with
7 CFR 225.11(c). However, as required by SFSP statutory
and regulatory authorities, the State agency must provide
the sponsor a reasonable opportunity to correct the
serious deficiency. The only appropriate corrective action
would be a sponsor’s submission of documentation from
the IRS indicating that:
• The sponsor or the part of the organization under
which the sponsor is operating continues to be taxexempt under Section 501(a) of the Internal Revenue
Code of 1986; or

WHAT DOES IT MEAN TO BE IN “GOOD
STANDING” WITH THE SFSP?

A sponsor in “good standing’ has successfully participated
in the previous year with no serious deficiencies.

•

27

The organization has submitted an application to
the IRS for reinstatement of tax-exempt status
(SFSP Memorandum 17-2011: Automatic Revocation
of Tax Exempt Status, June 30, 2011).

4

FOR CACFP SPONSORS OPERATING
AT-RISK AFTERSCHOOL MEALS,
WHAT ARE THE ADVANTAGES OF
OPERATING THE SFSP?

Organizations also may plan ahead by including in their
application plans for operating emergency sites during
the school year. Sponsors are encouraged to consider
this when applying to the Program. This enables State
agencies to pre-approve sponsors to operate emergency
meal sites during unanticipated school closures during
their initial application process, ensuring a rapid
response when an emergency situation arises.

There are many benefits for sponsors operating a yearround meal model, including:
• Having the ability to hire year-round staff
•

Receiving a continuous flow of reimbursements that
increase financial stability

•

Bringing increased Federal funds to the
local economy; and

•

Earning recognition in the community as a stable
source of services.

States also may exempt sponsors proposing to operate
a site during an unanticipated school closure during the
regular school year from submitting a new application if
they have participated in the Program during the current
year or previous two calendar years (7 CFR 225.14(a);
SFSP Memorandum 14-2011, Existing Flexibilities in the
Summer Food Service Program, May 9, 2011).

If the new SFSP sites are the same sites where CACFP
meal services are provided, CACFP sponsors may
follow the streamlined application requirements that
experienced SFSP sponsors and sites use, rather than
having to apply as a new SFSP sponsor or site. Sponsors
currently in good standing are also not required to
provide additional proof of financial and administrative
capability when applying for the SFSP.

6

WHAT IS “CATEGORICAL
ELIGIBILITY”?

Categorical eligibility eliminates the need for children
who already meet income eligibility requirements in a
specified Federal program to submit additional income
information for the SFSP. There are two ways children
can be classified as categorically eligible:

More information may be found in SFSP Memorandum
06-2014: Available Flexibilities for CACFP At-Risk
Sponsors Transitioning to the Summer Food Service
Program, November 12, 2013 (http://www.fns.usda.gov/
available-flexibilities-cacfp-risk-sponsors-and-centerstransitioning-summer-food-service-program).

•

Through participation in another comparable
Federal assistance program, such as SNAP, FDPIR,
or TANF; or

•

5

SFSP CAN BE OPERATED DURING
THE SCHOOL YEAR WHEN THERE ARE
EMERGENCY SCHOOL CLOSURES.
HOW CAN A SPONSOR PARTICIPATE IN THIS
COMPONENT OF THE PROGRAM?

Through documentation that the child is homeless,
runaway, or migrant; a foster child; or enrolled in a
Federally-funded Head Start or similar, State-funded
pre-kindergarten program.

For more information about establishing categorical
eligibility, please see SFSP Memorandum 06-2015:
Categorical Eligibility in the Summer Food Service
Program, December 8, 2014 at http://www.fns.usda.gov/
sites/default/files/SFSP06-2015os.

The SFSP regulations allow expedited approval of meal
sites during an emergency. Organizations with current
agreements to operate the SFSP may be approved
to open emergency meal sites (SFSP Memorandum
18-2014: Disaster Response, May 19, 2014) during the
school year if schools are closed (7 CFR 225.6(e)(1)(iii)).

28

7

WHAT SOURCES OF INCOME ARE
EXCLUDED WHEN DETERMINING
INCOME ELIGIBILITY FOR THE SFSP?

in previously issued guidance for NSLP [CACFP 062014, Effective Date of Free or Reduced Price Meal
Eligibility Determinations, December 3, 2013 available
at http://www.fns.usda.gov/sites/default/files/SP11_
CACFP06_SFSP11-2014os.pdf. Schools may not use
date of parent or guardian signature.

The following sources of income should be excluded
when determining a child’s income eligibility for the
Program:
• Military benefits, including privatized housing
allowance, military combat pay, and the Armed
Forces FSSA
•

Value of in-kind compensation

•

Payments directly received by a residential child care
institution or an institution on the child’s behalf

•

Any cash income or value of benefits excluded by
statute, such as the value of benefits under SNAP or
FDPIR and some Federal educational benefits

•

Payments received from a foster care agency or
court for the care of foster children

•

Student financial assistance provided for the
costs of attendance at an educational institution,
such as grants and scholarships awarded to meet
educational expenses and not available to pay
for meals

•

Loans, such as bank loans, since these funds are
only temporarily available and must be repaid

•

Infrequent earnings received on an irregular basis,
such as payment for occasional baby-sitting or
mowing lawns

9

WHAT METHODS MAY SFSP
SPONSORS USE TO ESTABLISH THE
EFFECTIVE DATE OF ELIGIBILITY?

SFSP sponsors may use either the date of parent
signature or the date of certification to establish the
effective date of eligibility.

10

FOR HOW LONG IS ELIGIBILITY
OF CHILDREN VALID WHEN AN
APPLICATION IS SUBMITTED?

Eligibility for children is generally effective for 12 months.
If a household application form is signed and dated by the
parent on January 12, 2016, then it is valid from January
1, 2016 through January 31, 2017.

11

HOW IS AREA ELIGIBILITY
DETERMINED FOR SFSP FOR
SUMMER 2016 FOR A SCHOOL
THAT BEGAN CEP IN 2014 AND HAS HAD NO
CHANGE TO THEIR ISP?

A detailed list of income exclusions may be found in the
School Meals Eligibility Manual, available online: http://
www.fns.usda.gov/2015-edition-eligibility-manualschool-meals.

To determine area eligibility, an individual school’s ISP
multiplied by 1.6 is used as a proxy for the free and
reduced-price percentage: an individual CEP school site
that has an individual ISP of at least 31.25 is area eligible
(31.25 x 1.6 = 50). A redetermination of area eligibility is
required every 5 years, unless the State agency is aware
of significant economic changes in the area.

8

WHAT METHODS MAY SCHOOLS
PARTICIPATING IN CACFP AND SFSP
USE TO ESTABLISH THE EFFECTIVE
DATE OF ELIGIBILITY?
Schools participating in the SFSP may use either
the date of submission or the date of certification to
establish the effective date of eligibility as described

29

12

HOW IS AREA ELIGIBILITY
DETERMINED FOR SFSP FOR
SUMMER 2017 FOR A SCHOOL
THAT BEGAN CEP IN 2014 AND HAD A
CHANGE TO THEIR ISP IN 2015?

in the area. The school does not remain SFSP area
eligible for five years from the initial determination as
the determination that established area eligibility was
not correct. The State agency may use school or census
data to attempt to make the SFSP site area eligible.

14

Provided the CEP school remains SFSP area eligible
(ISP multiplied by 1.6 remains equal or greater than 50
percent), there is no change to the SFSP site approval
process. The State agency may opt to change the date
of SFSP area eligibility determination to 2015 based
on the more recent CEP calculation, which in turns
shifts the required 5-year redetermination by one year.
Alternatively, the State agency may make no change
from the initial determination and must re-determine
SFSP area eligibility in five years.

IS THE FOLLOWING SCENARIO
CORRECT?

2013 - CEP ESTABLISHED FOR A SCHOOL
DISTRICT AND ALL SCHOOLS HAVE ISP X
1.6 EQUAL OR GREATER THAN 50 PERCENT.
• THIS SCHOOL DISTRICT’S YEAR CEP
CYCLE IS 2013 – 2016.
• SCHOOLS APPLY FOR SFSP IN 2016.
• STATE AGENCY DETERMINES/CONFIRMS
EACH SCHOOL IS SFSP AREA ELIGIBLE
BASED ON THE 2013 CEP DATA THAT
WAS USED TO CALCULATE THE ISP.
• SFSP AREA ELIGIBILITY FOR THE
SCHOOL DISTRICT IS GOOD FOR 5
YEARS, OR THROUGH 2020, BASED ON
THE 2013 CEP DETERMINATION.

13

HOW IS AREA ELIGIBILITY
DETERMINED FOR SFSP FOR
SUMMER 2017 FOR A SCHOOL
THAT BEGAN CEP IN 2014 AND HAD AN
ADMINISTRATIVE REVIEW IN 2016 THAT
FOUND THE SCHOOL’S ISP WAS NOT
CORRECT? THE REDETERMINATION RESULTS
IN AN ISP MULTIPLIED BY 1.6 THAT IS
LESS THAN 50 PERCENT. THE SCHOOL IS
NOT SFSP AREA ELIGIBLE BASED ON THE
CORRECTED CALCULATION.

Yes, the SFSP sites are certified for 5 years, based
on the 2013 data that was used to calculate the ISP.
A redetermination will be due 5 years from 2016 for
SFSP, even though a CEP ISP is due sooner. The 5 year
eligibility is locked in for SFSP.

While FNS guidance indicates SFSP area eligibility
determinations made using either school or census
data must be re-determined every five years, there is an
assumption that the initial area eligibility determination
was correct. If an State agency identifies the CEP
determination was erroneous and the corrected
determination results in the (CEP) school not being SFSP
area eligible based on the CEP calculation, an SFSP area
eligibility redetermination must occur for the upcoming
summer. Identifying the CEP error is similar to the State
agency becoming aware of significant economic changes

The exception is if an error in the 2013 data is discovered.

30

31

CHAPTER 2

Sponsor
and Site
Identification
•

STATE AGENCY SELECTION PRIORITIES

•

SPONSOR PRIORITIES FOR SELECTING SITES

•

SELECTING FOOD SERVICE STAFF

•

ENSURING SITE ACCESS THROUGH PROMOTION

•

PRE-OPERATIONAL REQUIREMENTS

State Agency
Selection
Priorities
FOR SPONSORS
(7 CFR 225.6(b)(5))

Confusion and waste result when two or more sponsors compete for the same sites or target
children in the same geographical area. Since such an overlap in service conflicts with Program
objectives, the State agency usually approves only one sponsor to serve an area.
When determining which of the competing sponsors will
serve an area, the National School Lunch Act requires the
•State agency to give priority to:
• Local SFA sponsors
•

Government and private non-profit organization
sponsors that have successfully operated the SFSP in a
prior year

•

New government sponsoring organizations; and then

•

New private non-profit organization sponsors.

To support the greatest Program participation and access,
it may be appropriate for States to allow sites in relatively
close physical proximity to operate in the community, each
serving its own participants. Sponsors should be able to
explain why differences in the population of children they
intend to serve require multiple sites in close proximity
to each other. Sites may also be close in proximity but
separated by a physical barrier that limits access, such as a
busy highway.

NOTE:
If Program operators feel they have a unique situation where competition is posing a significant
problem, they may contact the State agency for assistance.

Operating Limitations
(7 CFR 225.6(b)(6))

All sponsors may be approved for a maximum of 200 sites and a maximum total average daily
attendance at all sites of 50,000 children. The State agency may approve exceptions if the sponsor
can demonstrate that it has the capabilities of managing a Program larger than these limits.

33

Sponsor
Priorities for
Selecting Sites
Finding Eligible Sites

It is important that a sponsor adequately evaluate the needs and resources of the area they hope to
serve before making final plans for site operations. Mapping and other data tools can be used to locate
high-need, eligible areas and potential sites, such as libraries, schools, museums, and low-income
housing units. FNS and its partner organizations have resources available to facilitate this process.

Capacity Builder
The Capacity Builder is a tool that allows users to see where SFSP sites are or have been in their communities,
and add “layers” of information, such as poverty data, in absolute numbers and relative percentages. Potential
site locations and partners can be added to the map, and previous site locations can also be highlighted, helping
to prevent site overlap. http://www.fns.usda.gov/capacitybuilder
For a map that shows the locations of areas served by schools where at least 50 percent of enrolled children
are eligible for free or reduced-price meals go to: http://www.fns.usda.gov/areaeligibility.

Once sponsors have evaluated the needs of the area, they will have an easier time evaluating potential sites and determining
the size of their operations. Because sponsors must assume administrative and financial responsibility for total SFSP
operations at all sites under their supervision, they must be certain that a site can offer a quality meal service. For returning
sites, where site supervisors have had a poor performance record in past summers or where supervisors were unable
to institute timely corrective action, sponsors should carefully consider taking them on. Depending on the nature of these
problems, the State agency may also choose not to approve such sites for the Program.
The following list outlines several major considerations for sponsors evaluating potential sites. In addition, a Site Selection
Worksheet is included in the SFSP Sponsor Monitor's Guide, available at http://www.fns.usda.gov/cnd/summer/library/
handbooks.html and may be useful to sponsors in determining a site’s suitability.

Check out the Using Data and Targeted Expansion toolkit pages for more!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Data.pdf
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Expansion.pdf

34

Administrative Capability

Meal-Friendliness

In addition to selecting the sites at which meals will be
served, sponsors must decide how many sites to administer
and how many children they will serve at each site. This
decision will depend greatly on the need for a site in the area,
the administrative capabilities of the sponsor, and the size of
the site Programs. Sponsors must plan to operate Programs
that are consistent with the size of their administrative staff
and the extent of their expertise. A small sponsor with limited
administrative experience should carefully place limits on the
number of sites where it will offer meals.

Ideal sites will have tables and chairs readily available,
kitchens in which to prepare and clean up meals, large
refrigerators to store leftovers, and restrooms for kids and
staff to use. Special consideration will be needed for sites
located outdoors.

Site Activities
Children are drawn to locations that offer educational,
enrichment, and recreational activities. Selecting sites that
can provide an activity along with the meal, such as an art
project, game, school or community garden, or nutrition
lesson, is a strategy sponsors can use to boost participation
and overall enjoyment at their sites.

Accessibility
Sites should be easy to reach by foot, car and public transit.
Some children will be walking to their neighborhood site
alone, so sponsors should ensure that sites are located in
safe areas. Sponsors should try to avoid placing sites in areas
with physical barriers to access, such as near busy streets
without crosswalks. Sponsors should also make sure their
sites are accessible to children with and without disabilities.

Volunteer Base
Hosting a site at a venue that already has a strong volunteer
base, such as a soup kitchen or local faith-based organization,
is a good way to ensure a site will be fully staffed and wellpromoted in the community. More information about building
partnerships with well-established community organizations
is included in the Community Partnerships section below.
For more ideas about staffing your site, see “Chapter 7: Staff
Duties and Training.”

The Addressing Transportation Challenges

Toolkit page has more great tips!

http://www.fns.usda.gov/sites/default/files/sfsp/SMT­
Transportation.pdf

Community Partnerships

Sponsors may consider selecting site locations based on
the potential for community partnerships. Partnering with
community-based organizations can be helpful in building
awareness of the Program, finding additional financial
support, coordinating site activities, and recruiting volunteers
to serve meals to children. Sponsors may reach out to the
following organizations when looking for community partners:
• Parks and recreation centers
•

Youth organizations, such as YMCAs, Boys and Girls
Clubs, 4-H programs, and Scout troops

•

Social service organizations, such as food pantries,
WIC clinics, and donation centers

•

Minority referral services

•

Food hubs, farmers markets, and local food and
gardening organizations

•

Cooperative Extension and SNAP-Ed

•

Local parents groups

•

Faith-based organizations, such as churches,
synagogues, or mosques

•

National anti-hunger organizations, such as Share Our
Strength and the Food Research and Action Center
(FRAC) operating at the local level

In addition to offering support to existing sites, these and
other partner organizations may have space available to
host a site. Sponsors may consider reaching out to wellestablished community-based partners early on, as utilizing
these partnership may help to create a stronger, more
impactful Program.

35

SELECTING

food service staff
Sponsors who prepare meals on site or in a central kitchen are responsible for choosing staff, including a food service
manager, food production staff, and general kitchen help. The number of food service employees will depend on
the number and type of meals prepared. The following daily staffing schedule is provided as a guide for a Program
serving lunches and snacks.

DAILY STAFFING SCHEDULE
NUMBER
OF MEALS

HOURS
OF LABOR

STAFF NEEDS

1 to 50

6 to 8

1 full-time employee

51 to 100

8 to 10

1 full-time employee*
1 full-time employee**

101 to 200

12 to 20

2 full-time employees*
1 part-time employee**

201 to 300

20 to 24

3 full-time employees*
1 part-time employee**

1
2

**These part-time employees may be optional or as
needed, based on menu requirements.
The range of hours for labor varies based on the skills of
the food service employees and the convenience foods
used in the menus. If the sites serve breakfast, add 1
hour of labor for every 50 breakfasts prepared. Sites require less time for labor when serving snacks than when
serving breakfast or lunch.

TIPS FOR SELECTING STAFF

Determine the number of staff you will
need. The type of employee and the
amount of experience needed will vary
with the duties each will perform.

Use qualified volunteers, such as parents
or supervisory adults, to help you operate
the program. These individuals may offer
help during food service and in supervising the
children while they eat. Parental involvement
should be encouraged. Parents often see their
involvement as a benefit too!

3

*These full-time employees can be scheduled for only
the hours they are needed and may not be required to
work an 8 hour day.

All food service employees must meet the
health standards set by local and State
health authorities.

4

Develop a job description for each food
service position that describes duties and
responsibilities for the position.

For example:
Food production employees will have food preparation
duties and must be shown how to fill out the necessary
records. They must know how to use recipes and meet
the necessary meal pattern requirements. It is also
important that staff be able to recognize complete meals
and food safety guidelines.
Other personnel will have food service or cleanup duties
and responsibilities. Write down the requirements of the
job and go over the schedule of activities. A sample position
description for a cook is provided in the Reference Section.
For the position of food service managers, consider
someone with a food production or nutrition background
with food service experience.

36

Ensuring Site
Access through
Promotion
Once sites are identified, it is important that families are made aware of open site locations
and the availability of meals. Sponsors are encouraged to make use of FNS communication
resources, which are available online. The following resources can be used to promote summer
meals in any community:
•

The Summer Meals Toolkit includes helpful strategies sponsors can use to build awareness of their Programs:
http://www.fns.usda.gov/sites/default/files/SFSP_toolkit.pdf

•

The monthly Summer Meals Newsletters offer timely tips sponsors can use to improve Program outreach and
expansion: http://www.fns.usda.gov/sfsp/summer-meal-newsletters

•

The Summer Meals Best Practices Page shares proven success stories from Programs across the country:
http://www.fns.usda.gov/sfsp/best-practices

•

Additional FNS resources, including fliers, door hangers, public service radio announcements (PSAs), and training
videos are available on the FNS website: http://www.fns.usda.gov/sfsp/raise-awareness

The following sections outline outreach ideas sponsors can incorporate into their promotional strategy to ensure children in
their community have access to meals.

Mandatory School Outreach
The SFSP State agency must ensure that SFAs cooperate
with sponsors to inform eligible families of the availability
and location of free meals for students when the regular
school year ends. The State agency will facilitate a working
relationship between SFAs and sponsors to ensure that
schools help promote the availability of meals for children
during the summer months. For more information on the
school outreach requirements, see SFSP Memorandum
7-2014: Expanding Awareness and Access to the Summer
Food Service Program, November 12, 2013.

State superintendents of education to encourage further
involvement with the Program. Education leaders can issue
PSAs and press releases in support of the Program, or
host a site at their school. Sponsors can encourage friendly
competition among local schools, issuing a “Summer Meal
Challenge” to host a site or to serve more meals.
Along with schools, other community-based organizations
frequented by children and families can assist with outreach
and promotion. Sponsors may consider reaching out to
local health agencies, grocery stores, and social service
organizations, encouraging the posting or distribution of
fliers to patients, customers, and clients.

In addition to this mandatory school outreach, the Summer
Meal Toolkit includes sample letters sponsors may send
to school principals, school food service directors, and

37

Media Promotion

Traditional and social media outlets can be extremely helpful to sponsors working to communicate with
families. Sponsors may consider using the following forms of media to spread the word about your Program:
Local Newspapers

Twitter

Sponsors can write a Letter to the Editor or submit an
Op-Ed promoting the Program. The piece should conclude
with a “call to action,” encouraging site attendance or
asking community members to support the Program.
Sponsors can also pitch a story, inviting a reporter to visit
a site and write about the Program.

Twitter is a great platform to get information out quickly
and to discover outreach tips from new and experienced
sponsors in other communities. Sponsors can use
#SummerMeals and #SummerFoodRocks to share
outreach tips, and can follow @USDANutrition to stay
updated on what’s happening at the National level.

Check out the News Releases and Story

Pitching Toolkit page for more!

Interested in hosting a Twitter Town Hall?

Check out our Toolkit page!

http://www.fns.usda.gov/sites/default/files/cnd/
SMT-News%20ReleasesandStoryPitching.pdf

http://www.fns.usda.gov/sites/default/files
/cnd/SMT-TwitterTownhalls.pdf

Local TV Stations

Facebook

Local TV news reporters love a feel-good story in the
summertime – what could be better than a story about kids
enjoying a nutritious meal in the sunshine? Sponsors can
invite a TV reporter to cover a “special event,” such as a
local Kick-Off event. News reporters may also be interested
in interviewing a site supervisor or the parent of a child
who benefits from the Program.

Facebook has become an increasingly popular information
source for families, and should not be overlooked in your
outreach strategy. Sponsors may consider creating their
own Facebook page, which they can encourage community
members to “Like” and “Share”. Facebook allows sponsors
to provide real-time updates about their Program and
have greater control over their messaging.

Local Radio Stations

Instagram

Sponsors can request an interview at the station office, or
invite a local radio personality to broadcast from a popular
site. Radio stations are often interested in participating
in community events, and may even be willing to provide
“swag” to share with the kids. Sponsors can also prepare
a PSA for radio stations to air during commercial breaks.

Instagram is a great way to show children and families
all the fun that is happening at summer sites! Sponsors
can use #SummerMeals and #SummerFoodRocks when
sharing photos, and check in on these same hashtags to
see what is happening at other sites around the country.
In addition to encouraging site volunteers and participants
to “Like” their posts, sponsors can encourage volunteers
and participants to “Share” their own site experience
on social media! Older children and teens can spread
information to their friends and family members, helping to
boost outreach efforts and participation.

NOTE:

Always have children’s parents sign a Media
Release Form (Attachment 13) before using their
photo or recorded image to promote your Program.

38

Summer Meal Champions

Finding local summer meal champions is an important part of building community trust and running
a successful Program. Champions can come in all shapes and sizes, and can show support in many
different ways. Here are a few common examples:
Elected Officials

Teen Ambassadors

Local elected officials can issue press releases in support
of the Program, and those with webpages and newsletters
can use these platforms to encourage their constituents
to participate or volunteer at sites. Elected officials can
also participate in site visits and attend summer KickOff events. If you need assistance reaching out to them,
contact your State agency.

Reaching teens is an important aspect of any outreach
strategy, and has been a challenge for sponsors across
the country. Asking teens to design and implement
their own summer meals outreach strategy, or at
minimum, seeking their input, can be helpful to increase
participation among older children.

Tribal Leaders
Outreach to tribal communities is a priority for FNS,
and leaders can be helpful in ensuring children on
reservations have access to summer meals. If you have
a tribal community in your area, your local tribal leaders
can provide information about site locations, and can
encourage community members to become involved as
site managers and Program volunteers.

Faith-Based Leaders
Faith-based leaders can host sites at their synagogues,
churches, mosques, and other places of worship, and can
further support the Program by providing site location
information to the families they serve.

Local Athletes
Many children look up to professional and collegiate
athletes, making them invaluable spokespeople. Before
the Program begins, athletes can issue a robo-call or
radio announcement to build community awareness of
the Program. Athletes can also participate in your KickOff and “Spike” events throughout the summer, helping
to boost turnout among children.

Radio Personalities
Radio personalities, including those reaching diverse
ethnic markets, can engage in promotion of the Program,
both on-air and online. Radio hosts often have many
Twitter and Facebook followers, including children and
teens who may benefit from meals.

39

Pre-Operational
Requirements
Sponsor/Site Agreement
If a sponsor plans to administer a Program at sites not
legally affiliated with their organization (for example, at
recreation programs or vacation Bible schools), the sponsor
should enter into an agreement with the site supervisor
or responsible site official. The agreement should list, in
specific terms, the responsibilities of the site supervisor,
which will make it easier for the site personnel to
understand their duties.

operating the SFSP at the site, including its responsibility to
maintain contact with meal service staff, ensure that there
is adequately trained meal service staff on site, and monitor
site operations. A sample Sponsor/Site Agreement form is
included in the Reference Section as Attachment 14.

See the Sponsor Relations Toolkit
page to learn more!

However, the agreement does not relieve the sponsor
of final administrative and financial responsibility for

http://www.fns.usda.gov/sfsp/summer-meals-toolkit

Health and Sanitation

in conformance with all applicable State and local laws
and regulations [7 CFR 225.6(e)(9)]. Some SFSP facilities
may not be required to meet all State and local health
and safety requirements; for example, those that do not
prepare food on site. However, a SFSP sponsor may not be
declared by the State agency exempt from State and local
health and safety requirements. Only the State agency
that enforces these requirements may exempt sponsors
from documenting adherence to the full requirements.
This exemption should be documented in writing by that
appropriate State agency. Regardless of an exemption, there
must be some level of health and safety standards in place
to ensure that adequate facilities are available to prepare
and store meals (SFSP Memorandum 7-2015, Health and
Safety Inspection Requirements, December 10, 2014).

When sponsors have chosen their prospective sites,
they must notify the health department in writing of all
prospective site locations and arrange for prompt and
regular trash removal.
Before Program operations begin, sponsors must submit
to the State agency a copy of the letter notifying the
local health department of their intention to provide a
food service at specific times at planned sites (SFSP
Memorandum 07-2015: Health and Safety Inspection
Requirements, December 10, 2014).
Additionally, SFSP sponsors are required to enter into
an agreement with the State agency that their sites
will maintain proper sanitation and health standards

Check out the Health Inspection Tips for more information!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Health_Inspections.pdf

40

Planning for Extreme Weather Conditions

Concerns for the physical health and safety of children and consideration of extreme weather
conditions must be addressed by the State agency when a site is being approved.
Additionally, State agencies may waive the requirement
that, during an unanticipated school closure, SFSP sites
may not be located at school sites. Although schools may
be closed, some school buildings may be unaffected by the
disaster and may be approved as a location for emergency
meals. FNS may also approve flexibility to accommodate
the needs of severely impacted areas as a result of other
exceptional emergency situations or man-made disasters,
such as a human pandemic or chemical plant explosion,
which may impact the ability of schools, institutions, and
sponsors to continue normal Program operations.

State agencies must ensure that sponsors have made
appropriate arrangements for food service during periods of
inclement weather. Although all outdoor SFSP sites are not
required to have an alternate temperature-controlled site,
sponsors should have a contingency plan for dealing with
extreme weather conditions, such as thunderstorms and
excessive heat. Options include:
• Discontinuing the meal service, if safety is a concern
•

Using a tent to provide extra shade on extremely hot days

•

Partnering with a housing community to use an air
conditioned lobby or community room on extremely hot days

FNS extended the 2014 demonstration project allowing
non-congregate meals at certain outdoor sites
experiencing excessive heat through summer 2016. Under
the demonstration project, SFSP sponsors operating
approved outdoor meal sites without temperature
controlled alternative sites may operate as non-congregate
sites on days when the area is experiencing excessive heat.
For more information, see SFSP Memorandum 8-2015:
Demonstration Project for Non-Congregate Feeding for Outdoor
Summer Meal Sites Experiencing Excessive Heat with Q & As,
December 11, 2014, available at http://www.fns.usda.gov/
sites/default/files/SP14_SFSP08-2015os.pdf.
Sponsors are also encouraged to plan for emergency
situations in advance to ensure a rapid disaster
response. Sponsors can work with State agencies to
become pre-approved to operate emergency meal sites
during unanticipated school closures during their initial
application process, as SFSP regulations allow expedited
approval of meal sites during an emergency. Organizations
with current agreements to operate the SFSP may
be approved to open emergency meal sites (SFSP
Memorandum 18-2014: Disaster Response, May 19, 2014).
Based on the significant needs of each community, FNS
Regional offices may waive the Program requirements for
sponsors to document that each site is serving an area in
which poor economic conditions exist. These requirements
may be waived for existing eligible sites located in areas
damaged by a natural disaster that must relocate to areas
that are not eligible based on school or census data.

41

Pre-Operational Site Visits
Prior to approval, sponsors must visit new sites and any sites
that had operational problems in the previous year. However,
State agencies have the option to waive the pre-operational
site visit requirement for experienced SFSP sponsors, CACFP
sponsors and SFAs participating in the NSLP or SBP and who
are in good standing in these programs.
These visits are to determine that the sites have the
facilities to provide meal service for the anticipated
number of children in attendance and the capability to
conduct the proposed meal service. Sponsors should
record the date of the pre-operational visit to each site and
the name of the person who visited each site.
See the 2016 SFSP Sponsor Monitor's Guide, available at
http://www.fns.usda.gov/sfsp/handbooks for a sample form

that can be used to record pre-operational visit information
(SFSP Memorandum 12-2011: Waiver of Site Monitoring
Requirements in the Summer Food Service Program, April 5,
2011; SFSP Memorandum 5-2012: Simplifying Application
Procedures in the Summer Food Service Program, October 31,
2011; SFSP Memorandum 4-2013: Summer Feeding Options
for School Food Authorities, November 23, 2012; and SFSP
Memorandum 6-2014: Available Flexibilities for CACFP At-Risk
Afterschool Sponsors and Centers, November 12, 2013).
When a sponsor applies for the SFSP, the sponsor must
certify that all required pre-operational site visits have been
conducted. These pre-operational visits must not be confused
with required site visits during the first week of Program
operations (see “Chapter 8: Program Integrity” for a further
discussion of these site visits).

Check with your State agency for additional guidance.

42

CHAPTER 2

Questions
and answers
1

3

WHEN SHOULD SPONSORS BEGIN
PLANNING SITE OUTREACH IF THEY
WANT TO EXPAND?

Yes. Once prospective sites have been chosen, the
health department must be notified in writing of all
prospective site locations and arrangements for prompt
and regular trash removal must be made. Additionally,
sponsors must conduct pre-operational site visits to
determine that they have the facilities to provide meals
for the anticipated number of children in attendance and
the capability to serve meals.

Sponsors should begin setting participation goals
in the fall if they hope to expand in the summer.
Winter is a good time for sponsors to begin meeting
with community partners and exploring new site
options. Sponsors looking to expand may refer to the
Site Recruitment Strategies Toolkit page for more
tips on conducting successful site outreach: http://
www.fns.usda.gov/sites/default/files/sfsp/SMT-Site_
Recruitment.pdf. Sponsors should check with their
State agency for more specific information.

2

4

WHAT ARE SOME ADVANTAGES TO
OPERATING SCHOOL-BASED SITES?

ARE THERE ANY PRE-OPERATIONAL
REQUIREMENTS SPONSORS
MUST FULFILL ONCE THEY HAVE
CHOSEN THEIR PROSPECTIVE SITES?

HOW OFTEN CAN SPONSORS
ADD SITES?

Generally, sponsors may add sites to their Program
at any time during the approved operational period.
However, the sponsor must provide the State agency
with all the necessary information on each additional
site and receive approval before serving and claiming
meals at the new site(s). Sponsors should check with
their State agency for more specific information.

As trusted, familiar, community-based organizations,
schools are well-positioned to serve summer meals.
Local education agencies operating NSLP and SBP
are already familiar with the USDA meal pattern
standards, have trained staff and proper kitchen
equipment, and will have an easier time adjusting
to the Program than many other organizations.
Schools can operate either the SFSP or the SSO, the
latter of which allows schools to continue to provide
NSLP meals during the summer and requires less
administrative paperwork.

43

6

4 CONtINUED

In order to ensure strong participation all summer long,
sponsors should continue to conduct outreach for the
entire duration of the Program. Sponsors can promote
use of the Summer Food Rocks Site Finder and the
National Hunger Hotline, which families can use to find
sites in their neighborhood. Sponsors may also continue
to share FNS promotional materials, such as postcards,
bookmarks, and flyers with children.

In addition, schools may have an easier time
conducting participant outreach. Schools are already
required to conduct SFSP outreach in the spring, and
have a direct connection to children and families living
in the neighborhood. Schools also often have learning
and recreation opportunities available for children
in the summer, which can help boost attendance.
Because of the benefits of hosting sites at schools,
the State agency must give priority to SFAs when
approving sponsors.

5

ARE THERE OUTREACH EFFORTS
TO DO IN MID-SUMMER?

Sponsors often face a “mid-summer lull” – or
participation drop – in late July. In order to keep the
momentum going strong, sponsors may consider hosting
a “Spike” event. Spike events take place typically in the
middle of the summer, and can include a parade, health
fair, music concert, or other family-friendly event. For
more ideas, please see the Hosting Events Toolkit page:
http://www.fns.usda.gov/sites/default/files/sfsp/SMTEvents.pdf.

WHAT ARE FREE WAYS TO
CONDUCT OUTREACH?

Schools are required to inform families of the
availability and location of free meals when school
is not in session [7 CFR 210.12(d)]. Sponsors can
encourage schools to go above and beyond this
requirement by issuing a PSA to all families, and
by sharing FNS outreach materials, such as flyers,
postcards, and bookmarks, with students. Promotional
materials may be found on the SFSP “Raise Awareness”
webpage: https://origin.drupaluat.fns.usda.gov/sfsp/
raise-awareness.
Sponsors can also work with statewide advocacy
groups, local organizations, and public and private
agencies to amplify their outreach message. Many of
these organizations have experience with, and systems
for, communicating with the public. Sponsors can also
share the “Raise Awareness” outreach materials with
staff members at these organizations.
Sponsors can also work with traditional and social
media outlets to spread the word about the Program.
Attachment 13 provides sample news releases for open
and closed enrolled sites that sponsors can use as
templates to craft their outreach message.

44

45

CHAPTER 3

Sponsor
Application
•

SPONSOR TRAINING

•

APPLICATION REQUIREMENTS

•

REVIEW OF APPLICATIONS BY THE STATE AGENCY

•

STATE-SPONSOR AGREEMENT

•

APPEAL RIGHTS

Check out the Program Simplifications Toolkit
page to learn more!
http://www.fns.usda.gov/sites/default/files/cnd/SMT-ProgramSimplifications.pdf

Sponsor
Training
Each year, State agencies are required to offer training for their sponsors before the application
process begins.
At this training, sponsors receive guidance on Program
and regulatory aspects of SFSP administration, including,
at minimum:
•
An overview of the Program’s purpose
•
A review of the sponsor’s responsibilities
•
An overview of Civil Rights requirements
•
A review of the site supervisor’s responsibilities

•
•

Tips on how to identify a reimbursable meal
An overview of the site/sponsor agreement

A Program administrator and key staff member(s) from each
new sponsoring organization are required to attend State
agency training in order for the organization to be eligible to
participate in the Program.

NOTE:
The deadline for submitting a written application to operate the SFSP in the summer months is June 15.
However, State agencies may establish earlier deadlines. Sponsors that apply to operate the program during
emergencies are exempt from application deadlines.
[(7 CFR 225.6(b)(1))]
See: http://www.fns.usda.gov/sites/default/files/deadlines.pdf

47

Application
Requirements
New potential sponsors must submit an application to the State agency before the agency’s deadline
date. Applicants should be certain that they have filled out the application completely and that they
have forwarded all of the necessary supporting documentation to the State agency. Incomplete
applications will cause a delay in the approval of the sponsor.
• For each enrolled site, provide a written policy

All sponsors are required to submit an initial Program
application, paper or electronic. A list of application
requirements cannot be all-inclusive, since variations occur
with each State agency and with the nature of different food
services. However, the following list indicates the basic
application requirements that sponsors must satisfy:

statement on the availability of free meals. This policy
statement, which must be approved by the State agency,
explains that the same meal is served to all enrolled
children regardless of reimbursement status and
without discrimination against any child because of race,
color, national origin, sex, age or disability.

• Submit documentation of tax-exempt status under
the Federal Internal Revenue Code of 1986 if they are
private non-profit entities. SFSP regulations do not
require church sponsors to obtain Federal tax-exempt
documentation; however, please check with the State
agency for documentation requirements.

Camps that charge separately for meals also must
explain that the camp uses USDA’s eligibility standards
for family size and income levels at the level of reducedprice school meals, as follows:
• Describe how the camp accepts household
applications from campers and assures that children
who receive SNAP, FDPIR, or TANF benefits are
automatically eligible for free meals.

• Demonstrate adequate administrative and financial
responsibility to manage an effective food service.

• Describe how the camp will collect payments from
children who must pay the full price for their meals
and how the camp ensures that children receiving
free meals are not overtly identified.

• Provide a site information sheet for each proposed site.
The site information sheet includes documentation that
the site is capable of managing an effective meal service;
meal service times; documentation of eligibility; and, if the
sponsor qualifies as a camp, documentation of the number
of children enrolled in the Program that are eligible for
free or reduced-price school meals. Attachment 8 displays
information that new vs. experienced sponsors are
required to include on site information sheets. (See also
“Chapter 1: Documenting Site Eligibility” for documenting
open, restricted open, and closed enrolled site eligibility.)

• Assure that the camp has a hearing procedure for
families who want to appeal a denial of eligibility for
free meals.
• Assure that if a family requests a hearing, the child
will continue to receive free meals until a decision
is made by the hearing official.

• Provide a copy of a proposed media release with the

NOTE:

application.The application may not be approved without
it. Once the media release statement is approved by the
State agency, it must be provided to media outlets (e.g.,
newspapers, television and radio stations, city government
web sites) serving the area where the sites are located.

Sponsors of mobile sites must complete a site

information sheet for each proposed stop, as each

stop is considered a site.

48

• The purpose of the media release is to announce the

• Apply for advance payments, if needed. These are

availability of free meals, the nondiscrimination policy,
and complaint procedures if an individual wishes to file
a complaint for violation of non-discrimination policy.
Enrolled sites and camps must include the reduced-price
income eligibility guidelines in the media release. The
media release also must state that children who are part of
households that receive SNAP, FDPIR, or TANF benefits are
automatically eligible for free meals.

payments that may be received before the Program
begins to pay for administrative and operating costs
that are incurred before the Program starts. (Advance
payments are explained in detail in “Chapter 9: Program
Costs and Reimbursements.”)

• Certify that a training will be conducted for monitors
and site personnel. Include information explaining
when the training will be held and the topics that will
be discussed. (“Chapter 7: Staff Duties and Training”
contains an in-depth explanation of this training
requirement.)

Attachment 13 provides sample news releases for open and
closed enrolled sites. In addition to the information that is
required to be included in the media release, we encourage
sponsors to include other relevant information, such as
activities that will be provided for children at the SFSP sites.

• For sponsors that plan to use a food service
management company (FSMC) to provide meals, provide
a copy of the invitation for bid; for sponsors that plan
to use an SFA to provide meals, provide the proposed
agreement. Sponsors should also submit plans for
advertisement for bids if they intend to contract with a
FSMC. (For more information about this agreement, see
“Chapter 6: Procurement and Bid Procedures.”)

• Submit a complete management plan that includes
staffing needs and an administrative budget. Sponsors
will need to indicate the number of people who will be
working in each position, the number of hours per day
each will work, and the total estimate for employee
salaries, including hourly wages and fringe benefits.

• Submit documentation of tax-exempt status under

• Apply for start-up payments if available, and if the

the Federal Internal Revenue Code of 1986 if they are
private non-profit entities. SFSP regulations do not
require church sponsors to obtain Federal tax-exempt
documentation; however, please check with the State
agency for documentation requirements.

sponsor wants to receive them. Start-up payments
are described in “Chapter 9: Program Costs and
Reimbursements.”

• If the sponsor is a governmental entity or a private non­
profit organization, certify that the sponsor will have
direct operational control at each site.

49

Review of
Applications
(7 CFR 225.6(b)(3) and 225.11(c))

Within 30 days of receiving a completed application, the State agency will notify the applicant of its
approval or disapproval. If the application is incomplete, the State agency will notify the applicant
within 15 days and provide technical assistance to help the applicant complete the application process.
Approval to participate must be denied to any applicant found
to be seriously deficient in the operation of any Federal Child
Nutrition Program, including those disqualified from the CACFP
(SFSP Memorandum 1-2008: Nationwide Expansion of Summer
Food Service Program Simplified Cost Accounting Procedures,
January 2, 2008).

in place, only annual updates to the application, including a
budget, are required.

After the initial application is approved by the State
agency, the sponsor will be required to sign a permanent
agreement with the State agency. Once this agreement is

Sponsors will receive reimbursement only for meals that
are served after they have been approved for Program
operations. Sponsors must be certain that they have been
approved before they begin meal services.

Once sponsors are approved, they must operate the SFSP
according to: Federal regulations; SFSP instructions and
guidance materials; and applicable State and local laws.

Annual Application Updates

have had operational problems, a State agency will require
more detailed information on the site information sheets.
Less information may be required for a sponsor experienced
in operating the Program. Since this regulatory provision
is optional, not all State agencies adopt this variation in
application processing. For more information on your
State’s application requirements, contact your State agency.
(See Attachment 8, which shows how the regulatory
requirements for site information sheets differ between new
and experienced sponsors and sites.)

Once an initial application has been approved by the State
agency, limited annual updates to the application will be
required. Information required in the annual update to the
application will vary from State to State. However, Federal
law requires that sponsors submit an annual budget for
approval by the State agency (SFSP Memorandum 03-2011,
Child Nutrition Reauthorization 2010: Permanent Agreements,
January 14, 2011). Attachment 8 displays information that
new and experienced sponsors are required to provide.
Note: State agencies may exempt standard application
procedures for those sponsors that want to provide Program
benefits in times of emergencies (i.e., unanticipated school
closures from October through April or at any time during
the year for an area with a continuous school calendar). A
sponsor may be exempted from filing an application if they
have participated in the SFSP in the current year or in either
of the two previous calendar years.

SFAs participating in the NSLP or SBP and CACFP institutions in
good standing that want to operate the SFSP at the same sites
where they provide meal service through the NSLP or CACFP
may follow the application requirements for experienced SFSP
sponsors and sites instead of the application requirements
for new sponsors and sites (SFSP Memo 5-2012: Simplifying
Application Procedures in the Summer Food Service Program,
October 31, 2011 and SFSP Memorandum 4-2013: Summer
Feeding Options for School Food Authorities, November 23,
2012). Contact your State agency if you are interested in a
streamlined application process.

State agencies also may vary application requirements
based on their assessment of sponsors’ experience or
expertise in operating the Program. As a sponsor, if you
50

State-Sponsor
Agreement
(7 CFR 225.6(e))

In order to participate in the SFSP, sponsors must enter into a permanent Program agreement with the
State agency. The agreement is a legally binding document that specifies the rights and responsibilities
of both the sponsor and State agency, and should be read carefully before being signed.

Required Elements of an Agreement
Under the agreement, the sponsor must agree to:
• Operate a non-profit food service during the agreed
upon period (usually from May through September for
children on school vacation)
•

•

Serve meals that meet Program requirements (see
“Chapter 4: Meal Requirements”) at the approved sites
during times designated as meal service periods by the
sponsor and serve the same meal to all children
Serve meals without cost to all children (except that
camps may charge for meals served to children not
served meals under the Program)

•

Issue a free meal policy statement

•

Train administrative and site personnel as required

•

Claim reimbursement only for types of meals specified
in the agreement and served without charge to eligible
children at approved sites during the approved meal
service period

•

•

Maintain proper sanitation and health standards as
required by State and local law

•

Use in the Program food donated by USDA and
accepted by the sponsor

•

Have access to facilities necessary for storing,
preparing, and serving food

•

Maintain a financial management system as prescribed
by the State agency

•

Maintain on file documentation of required site visits and
reviews and make all accounts and records relating to the
Program available to authorized officials on request

•

Retain financial and administrative responsibility
for the Program

•

Operate the Program or facility in compliance
with Civil Rights laws and implementing
nondiscrimination regulations

Submit claims for reimbursement as required by the
State agency

See Attachment 4 for a list of current SFSP Federal Policies.
Check with your State agency about any changes.

51

Permanent Agreements
The Healthy, Hunger-Free Kids Act of 2010 requires that
the agreement between the State agency and sponsor be
permanent. This means that once the State agency and
sponsor enters into an agreement, it does not need to be
renewed. However, sponsors operating under a permanent
agreement must submit an annual budget for administrative
costs that must be approved by the State agency.
It is important to understand that describing the agreement
as “permanent” means only that the agreement has no
predetermined expiration date. However, the sponsor is
required to submit an application annually. Under certain
circumstances, these agreements may be amended or
cancelled, and this feature of the agreement does not create
contractual obligations beyond those described in the SFSP
regulations. This requirement reduces paperwork for sponsors

and State agencies and simplifies Program management (SFSP
Memorandum 03-2011: Child Nutrition Reauthorization 2010:
Permanent Agreements, January 14, 2011).
A State agency must enter into a single permanent
agreement with a SFA that operates more than one Child
Nutrition Program administered by the State agency.
Additionally, an addendum to the existing permanent
agreement may be made for institutions participating in
CACFP and SFSP when the same State agency operates
both Programs (SFSP Memorandum 5-2012: Simplifying
Application Procedures in the Summer Food Service Program,
October 31, 2011).

52

Sponsors Operating in Multiple States

Organizations may be approved to sponsor sites located in
any State, regardless of whether the sponsor is physically
located within the boundaries of the State where the
proposed site is located.

State agencies may approve only sites that are located
within their State. Sponsors must enter into an agreement
with the State agency for each State where its sites are
located, regardless of where the sponsor itself is actually
based (FNS Instruction 794-5, Agreements with Entities
Which Operate Interstate Schools and Facilities).

Sponsors not located within the State where a proposed
site is located must take additional measures to ensure
that the State agency is able to complete its monitoring
duties. To better facilitate State agency monitoring
of multi-State sponsors, these sponsors must make
requested materials available in the State where the sites
are located, such materials can be sent in accordance with
the form requested by the State agency, e.g., postal service,
fax, email, etc.

Therefore, when a sponsor is located in one State and
operates sites in other States, an agreement must be
entered into with the administering agency in all States
where the sponsor has a site (SFSP Memorandum 1-2014:
Sponsors Operating in Multiple States: REISSUED, November
12, 2013).

Appeal Rights

(7 CFR 225.6(b)(3) and 225.13)

Any sponsor denied participation in the Program or denied Program payment may obtain a hearing
by an official other than the one directly responsible for the original determination. At the time of the
denial, the State agency must tell the sponsor whom to contact for an appeal.
The following State agency actions may be appealed:

•

Denial of a sponsor’s site application

•

Denial of sponsor’s request for an advance payment

•

•

Denial of a sponsor’s claim for reimbursement (except
on decisions made by FNS with respect to late claims or
upward adjustments)

If applicable, denial of a FSMC’s application for
registration or the revocation of a FSMC’s registration

•

Claim against a sponsor for remittance of a payment

•

Refusal by the State agency to forward to FNS an
exception request by the sponsor for payment of a late
claim or a request for an upward adjustment to a claim

•

Termination of a sponsor’s (or a site’s) participation
in the Program

NOTE:
A checklist summarizing the planning activities described throughout Part I of this guide is included as Attachment 6.

53

CHAPTER 3

Questions
and answers
1

WHEN SHOULD A SPONSOR BEGIN
PLANNING FOR THE SUMMER?

2

WHAT DO SPONSORS NEED TO DO TO
APPLY TO PARTICIPATE IN THE SFSP?

Providing summer meals is a year-round effort, and
there are activities sponsors can do at any point during
the year to proactively plan for the summer. Sponsors
should refer to their State and Region-specific deadlines
when organizing their plans, but can use the Proactive
Planning for Sponsors Toolkit page as a general guide:
http://www.fns.usda.gov/sfsp/summer-meals-toolkit.

3

WHAT HAPPENS AFTER A SPONSOR IS
APPROVED TO PARTICIPATE IN THE SFSP?

When a sponsor is approved to participate in the SFSP,
the State agency will complete and sign a permanent
Program agreement with each sponsor. The agreement
is a legal binding document that specifies the rights and
responsibilities of both the sponsor and State agency and
should be read carefully before being signed.

4

DOES FNS PROVIDE ANY PLANNING
TOOLS FOR SPONSORS?

Sponsors can refer to the following FNS resources for
additional tips:
• Proactive Planning for Sponsors Toolkit page:
http://www.fns.usda.gov/sites/default/files/sfsp/
SMT-Proactive_Sponsors.pdf

Sponsors should contact their State agency and obtain
a sponsor application, and make sure to submit the
application to the State agency before the agency’s
deadline. Applicants should be certain that they have
filled out the application completely and that they have
forwarded all the necessary supporting documentation.
Incomplete applications will cause a delay in approval of
the sponsor.

54

•

Summer Meal Policy Resources: http://www.
fns.usda.gov/sites/default/files/cnd/SMTPolicyResources.pdf

•

State Application Deadlines for Sponsors: http://
www.fns.usda.gov/sites/default/files/deadlines.pdf

55

CHAPTER 4

Meal
Requirements
•

NUMBER AND TYPE OF MEALS

•

MEAL PATTERN REQUIREMENTS

•

MEAL SERVICE REQUIREMENTS

•

MEAL SERVICE OPTIONS

•

SERVING LOCAL FOODS

•

MEAL TIME REQUIREMENTS

•

MEAL COUNT FORMS

•

SITE CAPS

•

LEFTOVER MEALS OR COMPONENTS

•

MEALS SERVED TO ADULTS

Number
and Type
of Meals
(7 CFR 225.16(b))

Sponsors may serve one or two meals a day at open,
restricted open, and enrolled sites. With State agency
approval, sponsors may serve two meals (including snacks)
each day. Sponsors may choose which combination of meals
they would like to serve; however, serving lunch and supper
on the same day is not allowed.

With State agency approval, camp or migrant site sponsors
may serve up to three meals (including snacks) each day.
Allowable meal combinations include:
• Breakfast, Lunch, and Supper
• Breakfast, Lunch, and Snack
• Lunch, Supper, and Snack
• Any combination of meals or snacks that is less than the
maximum number allowed

ALLOWABLE MEAL COMBINATIONS
Breakfast only

Snack only

Lunch only

Supper only

Lunch and snack

Breakfast and snack

Breakfast and lunch

Supper and snack

Breakfast and supper

Two snacks

Meal services can be operated by different sponsors at the
same site; however, the maximum number of meals allowed
at a site under the regulations [7 CFR 225.16(b)] must not be
exceeded (two meals for open, restricted open, and enrolled
sites; 3 meals for camp or migrant sites). For example, if a
sponsor is approved to serve only lunch at a site, a different
sponsor may be approved to serve breakfast or a snack at
the same site, because the maximum (two meals) is met but
not exceeded (SFSP Memorandum 08-2016: Summer Food
Service Program Questions and Answers, November 12, 2015).

Check out the Planning Your Menu Toolkit page to learn more about vending options!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-PlanningYourMenu.pdf

Before the State agency approves the Program application, a sponsor will have to indicate the method it will use to provide
meals to children. Several factors such as the cost of food, the number of meals required, the type of meal service, the number
and type of sites, community dietary preferences, and the facilities available at each site will influence the sponsor's choice.

57

Meal
Pattern
Requirements
(7 CFR 225.16(d))

It is important for the success of the SFSP to serve nutritious meals that meet meal pattern
requirements and that are appetizing to children. Careful menu planning is necessary to meet this goal.
The meal pattern requirements assure well-balanced meals
that supply the kinds and amounts of foods that children
require to help meet their nutrient and energy needs. The
meal patterns establish the minimum portions of the various
food components that must be served to each child in order
for the participating sponsor to receive reimbursement for
each meal.

Snack

Breakfast

Juice may not be served when milk is served as the only
other component of a snack.

For a snack to be a reimbursable meal, it must contain two
of the four components listed below.
• One serving of milk (whole, low-fat, or fat-free)
• One serving of vegetables, fruits, or 100% juice
• One serving of a grain
• One serving of meat or meat alternate

For a breakfast to be a reimbursable meal, it must contain:
• One serving of milk (whole, low-fat, or fat-free)
• One serving of a vegetable, fruit, or full-strength juice; and
• One serving of a grain
• An OPTIONAL serving of a meat or meat alternate may
also be served

Please refer to the SFSP Meal Pattern Requirements and
information on creditable meal components, in the SFSP
Nutrition Guidance for Sponsors: http://www.fns.usda.gov/
sfsp/handbooks.

Lunch
For a lunch or supper to be a reimbursable meal, it must
contain:
• One serving of milk (whole, low-fat, or fat-free)
• Two or more servings of vegetables, fruits, or fullstrength juice
• One serving of a grain; and
• One serving of meat or meat alternate

58

Meal Pattern Adjustments

SFSP sponsors may be approved, in certain cases, to serve meals that meet the meal pattern requirements
of other Child Nutrition Programs. The following section lists a few common meal pattern exceptions.
Infant Meals

meal pattern requirements for children ages 1 through 5
years old in Section 226.20(c) of CACFP regulations.

(7 CFR 225.16(f)(2))

Because an infant’s (0 through 11 months) dietary needs
are based on individual development and may be more
complicated than those for toddlers and older children,
sponsors must receive prior approval from the State agency
to serve meals to infants. All meals served to infants must
comply with infant meal pattern requirements in Section
226.20(b) of the CACFP regulations. The State agency can
assist sponsors in making sure that their meals comply with
these requirements if they serve infants.

Meals for Children Aged 12 to 18
(7 CFR 225.16(d))

Meals for Children Aged 1 to 6
(7 CFR 225.16(f)(2))

SFSP regulations allow adjusted portion sizes for younger
children. The sponsor must demonstrate to the State agency
that it can control portion sizes and follow the age-appropriate

The meal patterns specify the minimum portions of each
food component for each meal or snack. Because teenagers
have greater food needs, sponsors may serve adult-size
portions to older children. Adult-size portions may be
found in Section 226.20(c) of CACFP regulations. Also, as
a reminder, extra food may always be served to improve
the nutrition of participating children – that is, food served
in addition to the food necessary to meet the meal pattern
requirements. (SFSP Memorandum 5-2016: Meal Service
Requirements in the Summer Food Service Program, with
Questions and Answers, November 12, 2015: http://www.fns.
usda.gov/sites/default/files/SP05_SFSP05-2016os.pdf).

Other Dietary Substitutions and Exceptions

(7 CFR 225.16(f)(4))

Disabilities

Medical or Special Dietary Needs

Sponsors are required to provide reasonable meal and snack
accommodations for children whose disability restricts their
diet. The accommodation must be supported by a medical
statement, signed by a licensed physician or a licensed
health care professional who is authorized to write medical
prescriptions under State law (health care professional). The
medical statement must identify the disability, the foods to be
omitted, and the foods that can be substituted (FNS Instruction
783-2, Rev.2, 10-14-94; and SFSP Memorandum 15-2015:
Statements Supporting Accommodations for Children with
Disabilities in the Child Nutrition Programs, March 30, 2015). A
statement from the child’s physician or health care professional
is required because it ensures that the requested substitutions
are medically appropriate and meet the nutritional needs of
that child, and to justify that the modified meal is reimbursable.

Meal or food substitutions may be made at a sponsor’s
discretion for a child with a non-disability medical or other
special dietary need. Such determinations must be made on
a case-by-case basis and must be supported by a medical
statement that identifies the medical or special dietary need
and which foods should be omitted and foods that should
be substituted. This medical statement must be signed
by a recognized medical authority or other health care
professional specified by the State agency. Sponsors should
be aware that meal or food substitutions for non-disability
medical or special dietary needs that are outside the meal
pattern requirements are not reimbursable.

Sponsors are required to make reasonable accommodations
for children with disabilities; however, they are not expected
to make accommodations that are so expensive or difficult
that it would cause the sponsor undue hardship. In most
cases, children with disabilities can be accommodated with
little expense or difficulty.
59

While sponsors are not required to accommodate dietary
preferences, such as vegetarian diets, they are highly
encouraged to do so within the existing meal patterns. The
SFSP meal patterns allow for a variety of foods items within
the required meal components and are flexible and adaptable
enough to accommodate dietary preferences.

Non-Dairy Milk Substitutes
210.10(m)(2)). In addition, in order for the meal to be
reimbursable, non-diary beverages served in lieu of fluid milk
must be nutritionally equivalent to milk and provide specific
levels of calcium, protein, vitamins A and D, magnesium,
phosphorus, potassium, riboflavin, and vitamin B-12 (7
CFR 210.10(d)(3)). Schools that decide not to offer milk
substitutions for children with medical or special dietary
needs must communicate this decision to all households.

Schools participating in SSO or in SFSP and following the
National School Lunch Program meal patterns may offer
non-dairy milk substitutes to children who cannot consume
fluid milk due to a medical or special dietary need that does
not rise to the level of a disability. Schools must receive
a written request from a recognized medical authority or
a parent or guardian that identifies the child’s medical or
dietary reason for needing a milk substitute (7 CFR

Meal Service

Requirements

(7 CFR 225.6(e), 225.15(b), and 225.16)

In addition to serving meals that meet meal pattern requirements, sponsors must comply with the
following rules when serving meals at each of their sites:
Serve the same meal to all children

children in situations where not enough food is available for
the duration of the entire designated meal service times.

This means all children receive a meal meeting the meal
pattern requirements, not that all meals must be identical
in every component. Children with disabilities must be
accommodated and therefore may not receive the same
meal. See the Dietary Substitutions/Modifications above for
additional information.

Sponsors should plan ahead and do their best to ensure every
eligible child receives a meal. Sites should communicate with
their sponsoring organization on a regular basis to discuss
anticipated attendance and to make adjustments in meal
orders. Sponsoring organizations should train site supervisors
on procedures regarding how and when to adjust meal orders
for the next day.

Ensure that children eat all meals on site
(7 CFR 225.6(e)(15))

Meals must be consumed on site in order to be eligible for
reimbursement, unless the State agency has been notified
prior to meal service for a field trip or FNS has approved other
off-site meal consumption. Failure to meet this “congregate
feeding” requirement results in the disallowance of meals
and may lead to a determination of serious deficiency of
the sponsor’s operation of the Program. In extenuating
circumstances, sponsors may allow meals to be consumed
off-site as long as the meals consumed off-site are not
claimed for reimbursement.

Ensure all children receive a meal
Make sure that all children in attendance at the site receive
one meal before any child is served a complete second meal,
or before any adult meals are served. Sponsors of open sites
should be aware of other open site locations for referring

Adhere to local health and sanitation regulations
Information may be found in SFSP Memorandum 07-2014:
Health and Safety Inspection Requirements, December 10, 2014.
Check with the State agency for more details.

Make arrangements for inclement weather
If meals are served outdoors, make adequate arrangements
for food service during inclement weather, such as rain or
extreme heat. This could include an alternate indoor site, a
shady spot for hot days, or, if necessary, discontinuation of
meal service.

Serve meals on-time
Serve meals during the meal service times submitted on the
Site Information Sheet and approved by the State agency.The
State agency must approve any changes in meal service times.
60

Meal
Service
Options
Taking Food Components Offsite
Sponsors should notify the State agency of any changes
(additions and/or cancellations) to scheduled field trips. If the
State agency is not notified prior to the field trip, meals served
may be considered “consumed off-site” and may not be
reimbursed. Sponsors serving meals off-site must carefully
ensure the safety and quality of the meals by using adequate
storage equipment to transport them.

Sponsors may allow a child to take one fruit, vegetable, or
grain item offsite to eat later without prior State agency
approval. The fruit, vegetable, or grain item taken offsite
must be from the child’s own meal or from a “share table”
(learn more about share tables on page 67 Sponsors should
only allow this at sites where there are enough staff to
monitor this practice. This helps ensure no issues, such as
food safety or Program integrity, arise. Site personnel must
supervise all children on the site while they are eating meals
(SFSP Memorandum 5-2016: Meal Service Requirements
in the Summer Food Service Program, with Questions and
Answers, November 12, 2015: http://www.fns.usda.gov/
meal-service-requirements-summer-meal-programs­
questions-and-answers.

Non-Congregate Meals Demonstration Project
Through summer 2016, sponsors have the opportunity to
participate in a demonstration project allowing service of
non-congregate meals at certain outdoor summer meal
sites experiencing excessive heat. Under the demonstration
project, SFSP and SSO sponsors operating approved
outdoor meal sites without temperature-controlled
alternative sites may operate as non-congregate sites
on days when the area is experiencing excessive heat.
FNS may extend this demonstration project to other
situations where exceptional circumstances make service
of congregate meals at approved meal sites impractical.
For more information, see http://www.fns.usda.gov/sites/
default/files/SP14_SFSP08-2015os.pdf (SFSP Memorandum
8-2015: Demonstration Project for Non-Congregate Feeding for
Outdoor Summer Meal Sites Experiencing Excessive Heat with
Q & As, December 11, 2014).

Field Trips during Meal Service Times
Sponsors should notify the State agency of all field trips
that affect the time or location of meal service, although
formal approval of the alternative meal service is not a
Federal requirement. Sponsors also are advised to notify the
food service vendor in advance of any field trips affecting
meal service, if applicable. It may be useful for sponsors
to provide a calendar of scheduled trips with the Program
application. (Refer to SFSP Memorandum: Field Trips in SFSP,
February 3, 2003).

61

Offer Versus Serve

(7 CFR 225.16(f)(1)(ii))

Offer versus serve (OVS) is a concept that applies to menu planning and meal service which allows
children to decline some of the food offered in a reimbursable breakfast, lunch, or supper.
OVS is not allowed at snack (see SFSP Memorandum 5-2016:
Meal Service Requirements in the Summer Food Service
Program, with Questions and Answers, November 12, 2015).
The goals of OVS are to simplify Program administration and
reduce food waste and costs while maintaining the nutritional
integrity of the SFSP meal that is served. All SFSP sites,
regardless of location or type of sponsorship, may use OVS.
Although SFSP regulations indicate that OVS is available only
to school sponsors, FNS extended this option to non-school
sponsors in October 2011. Utilizing OVS does not preclude the
sponsor from maintaining a non-profit operation.

Breakfast:

Please remember that OVS is not required. It is a meal
planning and service option the sponsor may choose to
implement.

Lunch or Supper:

The following four food items must be offered:
• One serving of fruit/vegetable
• One serving of grains
• One serving of fluid milk
• One additional serving of fruit/vegetable, grains, or a
serving of a meat/meat alternate
• All the food items offered must be different from
each other
• A child must take at least three of any of the four food
items offered

The following four food components must be offered through
at least five different food items:
• One serving of meat/meat alternate,
• Two servings of fruit and/or vegetables (two different
food items),
• One serving of grains, and
• One serving of fluid milk.
• Lunch or supper requirements differ from breakfast in that
a child must take at least three of the food components,
rather than items, listed above from the five food items
offered. Three food components are required for an adequate,
nutritious meal for children.

For a meal to be eligible for reimbursement, all food
components in the required minimum serving sizes must
be offered. A food component is one of the food groups that
comprise a reimbursable meal. Sites must always offer all
the food components that comprise a reimbursable meal
in at least the minimum required amounts. A food item is a
specific food offered within the components comprising the
reimbursable meal. For example, separate ½ cup servings
of peaches and pears are two food items that comprise one
component, the fruit and vegetable component.

Offering two servings of the same food item is not permissible
under OVS in SFSP. All food items offered must be different
from each other. For example, a breakfast menu that includes
a serving of milk, a serving of fruit, and two servings of toast
is not a reimbursable meal under OVS in SFSP because the
toast is two of the same food item. Additionally, a larger food
item that is worth two servings in weight, such as a two ounce
muffin, counts as only one food item under OVS in SFSP, not
two. Offering different food items supports and encourages
the practice of offering a variety of food choices for children,
which increases the likelihood that children will select foods
they prefer and reduces waste.

Check out the How to Do Offer Versus

Serve Toolkit page for tips!

http://www.fns.usda.gov/sites/default/files/sfsp/SMT­
OfferVersusServe.pdf

It is important to note that the OVS requirements in SFSP are
different from the OVS requirements in NSLP. All non-school
sponsors electing to use OVS and schools participating in
SFSP and electing to follow the SFSP meal patterns are
required to follow the SFSP OVS requirements. In order to
ensure that children are receiving enough food to meet their
nutritional needs, OVS requirements in SFSP are as follows:

62

If a sponsor chooses to use OVS, they must indicate this
intention on the sponsor or site application. State agencies
may not institute a statewide ban on OVS. However, specific
sponsors or sites may be restricted from utilizing the option
on a case-by-case basis. If a State agency denies a sponsor's
request to use OVS in SFSP, the sponsor may not appeal the
decision. The sponsor may submit another request the next
operating year. (SFSP Memorandum 5-2016: Meal Service
Requirements in the Summer Food Service Program, with
Questions and Answers, November 12, 2015).

School sponsors that elect to use the NSLP or SBP meal
pattern and SFAs operating SSO are required to follow the OVS
requirements of NSLP and SBP. For more information, see 7
CFR 210.10(e), 7 CFR 220.8(e), and SP 57-2014, Updated Offer
versus Serve Guidance for the National School Lunch Program
and School Breakfast Program in School Year 2014-2015 at
http://www.fns.usda.gov/meal-service-requirements-summer­
meal-programs-questions-and-answers.

Serving Meals Family Style

Serving meals family style can help children develop good eating habits through the personal example
provided by supervising adults.
Camp and closed enrolled sites offer the best setting for
implementing family style meals, provided that adults are
available to assist children during the meal and staff and
children are together for an extended period of time to provide
a relaxed, stable environment conducive for teaching good
eating habits. Family style meal service should not be used at
other types of sites.

not take the full required portion of a meal component,
the supervising adult should offer the food component to
the child again.
These practices are in line with family style meal service
guidance in CACFP.
Family style meal service allows children to identify and
be introduced to new foods, new tastes, and new menus,
while developing a positive attitude toward nutritious foods,
sharing in group eating situations, and developing good
eating habits. Even when a complete family style meal
service is not possible or practical, it may be useful to
offer a component or components in a family style manner,
particularly when smaller children are being served or when
a new food item is being introduced.

If meals at camps or closed enrolled sites are served family
style, sponsors must ensure that:
• A sufficient amount of food must be placed on each
table to provide the required portions of each of the
food components, as outlined in 7 CFR 225.16, for all
children at the table and to accommodate Program
adults supervising the meal service, if they eat with the
children.
•
•

Children should initially be offered the full required
portion of each food component.

For more information on family style service, consult FNS
Instruction 783-3, Rev. 1, Family Style Meal Service in the
Summer Food Service Program and SFSP Memorandum
5-2016: Meal Service Requirements in the Summer Food
Service Program, with Questions and Answers, November 12,
2015: http://www.fns.usda.gov/meal-service-requirements­
summer-meal-programs-questions-and-answers.

When a child does not initially accept the full required
portion of a meal component, it is the responsibility of
the supervising adults to actively encourage each child
to accept the service of the full required portion for each
food component of the meal pattern. For example, if a
child initially refuses a food component, or initially does

NOTE:

Another great resource for promoting nutritious meals when school is not in session is the newly revised
memorandum SFSP 6-2016, Promoting Nutrition in Summer Meal Programs, with Best Practices, November 12, 2015
http://www.fns.usda.gov/promoting-nutrition-summer-meal-programs-best-practices

63

Serving
Local Foods
Serving local foods can improve meal quality and appeal, encourage kids and teens to develop
healthy eating habits, and educate them about where their food comes from.
Summer is often a time of agricultural abundance which can
reduce food costs, and purchasing local foods can support
regional economic development, while also providing
wholesome products to kids. Sponsors can purchase local
foods directly from farmers, through distributors or Food
Service Management Companies, from food hubs, farmers

markets, Community Supported Agriculture (CSA)’s, and
school or community gardens. For more information on
finding, buying, and serving local foods, please see the
Local Procurement section of this guide and visit USDA’s
Farm to Summer website: http://www.fns.usda.gov/
farmtoschool/farm-summer.

Check out the new Local Foods and Related Activities in Summer Meal Programs Memo:
http://www.fns.usda.gov/sites/default/files/SP07_SFSP07-2016os.pdf

64

Meal Time
Requirements
(7 CFR 225.16(c))

Additionally, certain time restrictions apply to sites
participating in the Program that do not prepare meals
on site and require meal delivery. Sites that arrange
meal delivery must be prepared to store the meals until
mealtime, according to standards prescribed by local health
authorities. State agencies will approve meal service at
these sites only if:
• Food is not held in temp danger zones for longer than
allowed by State agency or local health safety codes.

Sponsors must establish meal times for each site and
provide this information to the State agency. Therefore,
when applying to participate in the Program or providing
annual updates on Program information, sponsors must
provide the State agency with the meal service times for
each site. Sponsors are not required, though, to ensure that
specific amounts of time pass between the meal services
(e.g., 3 hours in between breakfast and lunch being served).
Additionally, there are no Federal restrictions on serving
meals on weekends. Sponsors that wish to serve meals on
the weekend must first receive State approval.

•

Proper facilities exist on site for storing the meals.

Sponsors are encouraged to establish meal service times that
best accommodate the needs of participating children and the
site’s operational requirements. Sponsors should work closely
with their State agency to establish meal times which provide
flexibility to accommodate unanticipated circumstances, such
as late meal deliveries, while fulfilling Program requirements.

States may establish meal time restrictions; however,
any State restrictions are considered additional State
requirements and must be approved by the Regional office
(SFSP Memorandum 5-2016: Meal Service Requirements
in the Summer Food Service Program, with Questions and
Answers, November 12, 2015; http://www.fns.usda.gov/
meal-service-requirements-summer-meal-programs­
questions-and-answers.

Check out the How to Establish Meal Service Times Toolkit page!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-MealServiceTimes.pdf

Supper Meal Service Exceptions
State agencies are allowed to approve SFSP sponsors to
serve suppers in place of lunches in certain circumstances,
including where:
• An area is eligible for the Program but sites, meal
preparation facilities, or staff are not available for a
lunch meal service; or
•

Therefore, State agencies may approve a sponsor to serve a
supper in place of a lunch when it is feasible and appropriate.
Except for camps and migrant sites, sponsors are not
allowed to serve a supper and a lunch at the same site (SFSP
Memorandum 5-2016: Meal Service Requirements in the
Summer Food Service Program, with Questions and Answers,
November 12, 2015: http://www.fns.usda.gov/meal-service­
requirements-summer-meal-programs-questions-and­
answers.)

An organization has developed late-afternoon or evening
programs for children in low-income areas to keep
them occupied in the summer months, but do not have
sufficient resources to provide children with meals.

65

Meal
Count Forms
(7 CFR 225.6(e), 225.15(b), and 225.16)

In addition to serving meals that meet meal pattern requirements, sponsors must comply with the
following rules when serving meals at each of their sites:
Attachments 18, 19, and 20 are sample meal count forms.
Attachment 18 is a daily meal count form. Attachment 19 is
a weekly, consolidated meal count form. Attachment 20 is a
consolidated form for 20 days that also provides guidance on
calculating reimbursable second meals.

A training session attendance sign-in sheet for site personnel
can be used by sponsors to assemble a list of the signatures
of the site supervisors and assistants who are responsible
for signing daily records. Sponsors can use these lists when
reviewing the records returned by the sites to ensure that
the proper person is signing the daily records. Daily meal
count sheets are required; however, the weekly consolidated
meal count form is not.

Site Caps
(7 CFR 225.6(d)(2), CFR 225.6(d)(1)(iii), 7 CFR 225.6(d)(2))

All SFSP sites are required to have an approved site cap. The
purpose of a site cap is to ensure that a site does not purchase
and/or produce meals outside the capability of the site and the
need of the community, thereby reducing waste and protecting
the integrity of the Program. Sponsors, through the required
training provided to site supervisors under 7 CFR 225.6(e)(1)
(6) and 225.15(d)(1), must ensure site supervisors are trained
and fully understand site caps requirements. This would
include clarifying that special events, such as summer kick-off
and late-summer back-to-school events, which may result in
larger than average participation, would require approval of a
temporary site cap increase.

66

For sponsors of self-prep sites, Program regulations require
site caps to be based on the capacity of the site to prepare
and/or distribute meals and on the number of children for
which their facilities are adequate [7 CFR 225.6(d)(1)(iii)]. For
sponsors of vended sites, Program regulations require site
caps to be based on either historical records of attendance
at the site or, if a record from prior years is not available,
the State agency should have an established procedure to
determine an appropriate cap [7 CFR 225.6(d)(2)]. For more
information, refer to SFSP Memorandum 16-2015: Site Caps in
the Summer Food Service Program: Revised, April 21, 2015.

Leftover Meals
or Components
(7 CFR 225.15(b))

All sponsors must plan, prepare, or order meals with the goal of serving one meal per
child at each meal service, and must ensure that entire meals and food components are not
frequently left over and unusable.

PLAN AHEAD

OFFER SECOND HELPINGS

The form of the food should be appropriate for
the age of the children so that it can be easily
consumed within the meal service period. For
example, if fruit is cut into smaller pieces, it is
easier for young children to eat. Site staff should
be aware of foods that may be difficult to eat,
such as unpeeled oranges, and should provide
assistance when necessary. Additionally, it is
important to set meal service times that give
children plenty of time to eat their entire meal.

A limited number of second meals served as a unit
can be claimed for reimbursement, as long as the
total number of second meals does not exceed two
percent of first meals served by the sponsor, for
all sites, during the claiming period. If the State
agency determines that the sponsor has failed to
plan ahead and incorrectly prepare or order meals,
second meals may be disallowed.

DESIGNATE A “SHARE TABLE”
Sponsors may create a “sharing table” or stations
where children may return whole items that they
choose not to eat. Sponsor must check that “share
tables” are in compliance with State and local
health and safety codes first. Unopened, unused,
whole food items left on the share table are then
available to other children who may want additional
helpings. This practice may be facilitated by serving
meal components that can be easily “recycled.” For
example, if an apple is served as part of a meal, a child
can return the apple to the share table.

When equipment is available, complete meals and
nonperishable components that remain on a share
table may be appropriately stored for later service. All
recycled food items must be stored in accordance with
State and local health and safety codes and must be
documented. Please check with your State and local
health department or food service codes regarding
sharing tables. (SFSP Memorandum 5-2016: Meal Service
Requirements in the Summer Food Service Program, with
Questions and Answers, November 12, 2015: http://www.
fns.usda.gov/meal-service-requirements-summermeal-programs-questions-and-answers).

67

TRANSFER MEALS TO BUSIER SITES
If allowed by State and local health and safety codes, extra meals can be transferred from a site with too many
meals to a site with a shortage. It is important to note, though, that meals above the receiving site’s approved
site cap are not reimbursable.
The safety of the leftover meals must be maintained. Meals or components that are transported or “shared” must be
kept in compliance with all State and local health and safety standards (SFSP Memorandum 5-2016: Meal Service
Requirements in the Summer Food Service Program, with Questions and Answers, November 12, 2015: http://www.
fns.usda.gov/meal-service-requirements-summer-meal-programs-questions-and-answers).

DONATE MEALS TO CHARITY
When it is not possible to reuse or store leftover food, FNS encourages sponsors to consider donating it to
non-profit organizations working to address hunger in the community. Sponsors may also choose to send
leftover meals or food home with children. Although donated meals, including non-reimbursable meals or meal
components sent home with children, may not be claimed for reimbursement, food donation avoids unnecessary
waste and can save expensive disposal and storage costs. Sponsor policies relating to food donations must
comply with State and local health and sanitation codes.
If health and food safety codes allow for donations, such options could include donating to eligible local food
banks or charitable organizations, meaning any food bank or charitable organization which is exempt from
tax under section 501(c)(3) of the Internal Revenue Code of 1986 (26 U.S.C. 501(c)(3). These include homeless
shelters, food pantries, or other types of facilities that serve meals or distribute food to needy persons. Donated
meals may not be claimed for reimbursement (SFSP Memorandum
07-2012: Guidance on the Food Donation Program in Child Nutrition Programs, February 3, 2012 and SFSP
Memorandum 5-2016: Meal Service Requirements in the Summer Food Service Program, with Questions and
Answers, November 12, 2015: http://www.fns.usda.gov/meal-service-requirements-summer-meal-programsquestions-and-answers.
As a result of USDA’s Food Recovery and Gleaning Initiative of 1997, a “Best Practice” manual was created which
highlighted measures to provide unused food to needy organizations. In addition, the “Let’s Glean!” Toolkit was
developed as a resource guide on food recovery programs for businesses, community-based organizations,
private citizens, and public officials and describes some of the food recovery activities taking place at that time and
suggestions for new efforts which can be accessed at http://www.usda.gov/documents/usda_gleaning_toolkit.pdf.

68

Meals Served
to Adults
(7 CFR 225.15(b))

non-Program funds to cover the cost of these meals.
The sponsor may include those funds as Program
income and pay for these meal costs from its nonprofit
food service account. [7 CFR 225.2 Definition of Income
accruing to the Program].

Sponsors have the option to serve meals to anyone.
However, only meals served to children may be claimed
as reimbursable meals. Along with children ages 18 years
and younger, SFSP regulations at 7 CFR 225.2 also defines
children as persons over 18 years of age who are determined
by the State or local educational agency or a local public
education agency as having a mental or physical disability
and who participate during the school year in a public
or private non-profit school program established for the
mentally or physically disabled. Therefore, meals served to
any person who meets the above definition may be claimed
as reimbursable meals (SFSP Memorandum 5-2016: Meal
Service Requirements in the Summer Food Service Program,
with Questions and Answers, November 12, 2015 http://www.
fns.usda.gov/meal-service-requirements-summer-meal­
programs-questions-and-answers.)

When a sponsor chooses to serve meals to adults, the rules
below must be followed:
• All children (including any person who meets the
definition of 7 CFR 225.2) must be fed first

Meals served to adults (other than those provided for in 7
CFR 225.2) must be reported differently than those served to
children, depending on the classification of the adult served,
as either a Program or a non-Program adult.
•

Program Adults work directly with the meal service at
the site as either volunteers or paid employees. Meals
may be served free to adults who meet this definition.
These meals may not be claimed for reimbursement, but
may be counted as operating costs [7 CFR 225.9(d)(5)].

•

Non-Program Adults do not work in any direct way
with the meal service at the site, such as a parent or
guardian. If a sponsor chooses to serve meals to nonProgram adults, the sponsor may charge a fee for the
meal. The cost of meals served to non-Program adults
may be counted as part of the sponsor’s operating costs
only if the adult pays at least the full cost of the meal
(including food and non-food supplies, labor, and the
value of commodities), or non-Program funds cover the
full cost of the meal and the money received is reported
as income to the Program. If the sponsor chooses to
serve the meal at no charge, then the sponsor must use
69

•

Income from the sale of adult meals and non-Program
funds used to pay for adult meals must be documented
as income to the Program to offset documented costs

•

Meals served to children (including second meals),
Program adults, and non-Program adults must be counted
and recorded separately on the daily meal count form

The calculation of meal costs should be based on the full cost
of producing the meal (i.e., food, supplies, labor, and other
costs incurred by the sponsor). Sponsors should also include
the value of the USDA Foods used to prepare the meal or this
value may be based on the current year annual entitlement
per meal value of USDA Foods.

CHAPTER 4

Questions
and answers
1
HOW MANY AND WHAT TYPE OF MEALS
CAN A SPONSOR SERVE EACH DAY?

The meal pattern chart on page X of this handbook lists
the required food components for each meal type and the
minimum required serving sizes for each of those food
components. Sponsors should also review the USDA’s
Food Buying Guide for Child Nutrition Programs (http://
www.fns.usda.gov/tn/food-buying-guide-for-childnutrition-programs) for assistance with determining
portion sizes and what quantities to purchase. See
chapter on “Vending Options” for more information.

Open, restricted open, or closed enrolled sites may
be approved to serve up to two meals each day. For
example, a site might serve breakfast and lunch or lunch
and a snack. However, an open, restricted open, or closed
enrolled site may not serve lunch and supper on the
same day.
Camps and sites serving primarily children of migrant
families may serve up to three meals or two meals and
one snack with State agency approval.

2

3

WHAT ARE THE MEAL PATTERN
REQUIREMENTS?

Besides serving meals that meet meal pattern
requirements, sponsors must be certain that:

It is important that sponsors serve nutritious meals that
meet meal pattern requirements and that are appealing
to children. The meal pattern establishes the minimum
portions of each component that must be served to each
child for the meal to be reimbursable.
•

Breakfast must contain one serving of milk, one
serving of a vegetable or fruit or full-strength
juice and one serving of a grain. A meat or meat
alternate is optional.

•

A lunch or a supper must contain one serving of
milk, two or more servings of vegetables and/or
fruits, one serving of a grain and one serving of
meat or meat alternate.

•

A snack must contain two of the following food
components: milk, fruit or vegetable, grains, and
meat or meat alternate. However, juice may not be
served when milk is served as the other component.

WHAT ARE THE OTHER
REQUIREMENTS FOR THE MEALS?

70

1.

All children eat all meals on site (unless the sponsor
determines the site has enough staff to monitor
to allow children to take one fruit, vegetable, or
grain item off-site; see Attachment 17 for more
information).

2.

All children receive one meal before any child is
served a complete second meal. Sponsors must also
comply with State and local health and sanitation
regulations, make adequate arrangement for food
service during inclement weather, serve meals
during the approved times of meal service, and notify
the State agency if the site is planning a field trip
affecting the meal service time and location.

4

ARE THERE TIME RESTRICTIONS FOR
ANY OF THE MEAL SERVICE?

In most cases, meal accommodations for disability
and non-disability reasons can be met by selecting a
food substitution from the list provided in the medical
statement. The USDA recommended course of action
in situations involving substitutions for disability and
non-disability medical or special dietary needs is to
encourage Program operators to work closely with the
child’s parents or guardians and the child’s physician or
health care professional (as described below) to protect
the health and wellbeing of the child.

No, there are no Federal time restrictions. Sponsors
must continue to establish meal times for each site
and provide this information to the State agency, but
sponsors are not required to ensure that specific
amounts of time pass between meal services.
However, State agencies may establish meal time
restrictions. Such restrictions would be considered
additional State requirements and subject to FNS
Regional office review and approval.

7

5

WHEN MAKING A MEAL
ACCOMMODATION, WHO IS
CONSIDERED AN “ACCEPTABLE
MEDICAL PROFESSIONAL?”

Program regulations require all meals prepared by a
FSMC to be unitized, with or without milk, unless the
State agency has approved a request for exceptions to
the unitizing requirement for certain components of the
meal. This request for an exemption could be granted
when a sponsor requests to utilize the OVS option.
State agencies are encouraged to provide for sponsors
a prototype contract that does not include the unitized
meal requirement.

Along with a physician and at the State agency’s
discretion, “a State licensed health care professional
who is authorized to write medical prescriptions
under State law” is considered an acceptable medical
professional. See SFSP Memorandum 15-2015,
Statements Supporting Accommodations for Children
with Disabilities in the Child Nutrition Programs, March
30, 2015: http://www.fns.usda.gov/sites/default/files/
cn/SP32_CACFP13_SFSP15-2015os.pdf.

6

8

MAY NON-SCHOOL SPONSORS
PURCHASE NON-UNITIZED
MEALS FROM AN FSMC WHEN
UTILIZING THE OVS OPTION?

WHAT IS A “REASONABLE
ACCOMMODATION,” ACCORDING TO
DISABILITY REQUIREMENTS?

The general guideline in making accommodations
for children with disabilities is to ensure children
with disabilities are able to participate in and receive
benefits from programs that are available to children
without disabilities. Sponsors are required to make
reasonable accommodations for children whose
disability restricts their diet. Section 15.b3 of USDA’s
Nondiscrimination on the Basis of Handicap in
Programs or Activities Receiving Federal Financial
Assistance defines reasonable accommodations.

DO MEAL ACCOMMODATIONS
NEED TO MEET THE MEAL
PATTERN REQUIREMENTS?

Meal accommodations for children with non-disability
medical or special dietary needs must meet the meal
pattern requirements in order to be reimbursable.
Meal accommodations for children with disabilities
that restrict their diet do not need to meet the meal
pattern requirements in order to be reimbursed but
should be nutritionally sound and meet the nutritional
needs of the child. For more information on this,
contact your State agency.

71

9

10

WHAT CAN SPONSORS
DO TO IMPROVE THE
NUTRITIONAL QUALITY OF
THE MEALS THEY SERVE?

ARE THERE RESOURCES
AVAILABLE TO HELP SPONSORS
PLAN THEIR MENUS?

FNS has many resources sponsors can use to plan
their menus, including the following:
• Meal Service Options:
http://www.fns.usda.gov/sfsp/summer-mealstoolkit

Sponsors interested in serving healthier meals can refer
to the following FNS resources:
• Team Nutrition Resource Library:
http://www.fns.usda.gov/tn/resource-library

•

Planning Healthy Summer Meals:
http://www.fns.usda.gov/sfsp/summer-mealstoolkit

•

Team Nutrition Healthy Meals Resource System:
http://healthymeals.nal.usda.gov/

•

Team Nutrition Healthy Meals Resource System:
http://healthymeals.nal.usda.gov/

•

Summer Nutrition Guidance for Sponsors Handbook:
http://www.fns.usda.gov/sfsp/handbooks

•

USDA Recipes for Child Care:
http://www.nfsmi.org/Templates/TemplateDefault.
aspx?qs=cElEPTYzJmlzTWdyPXRydWU=

•

USDA “What’s Cooking” Cookbooks:
http://www.whatscooking.fns.usda.gov/

•

Summer Meals Toolkit Page:
http://www.fns.usda.gov/sfsp/summer-meals-toolkit

•

USDA’s What’s Shaking: Creative Ways to Boost
Flavor with Less Sodium:
http://healthymeals.nal.usda.gov/whatsshaking

•

USDA’s Farm to Summer page:
http://www.fns.usda.gov/farmtoschool/farm-summer

•

USDA Recipes for Schools:
http://www.nfsmi.org/Templates/TemplateDefault.
aspx?qs=cElEPTEwMiZpc01ncj10cnVl

72

73

CHAPTER 5

VENDING

OPTIONS

•

SPONSOR MEAL PREPARATION

•

PURCHASING MEALS FROM SCHOOLS

•

PURCHASING MEALS FROM A FSMC

•

USDA FOODS

•

ADDITIONAL FOODS

•

Sponsor Meal

Preparation

(7 CFR 225.2 definitions)

Many sponsors choose to prepare their own meals, which provide them with maximum control over
the quality of preparation. Depending on the facilities available at its sites, a sponsor may prepare
meals at each site location or at a central kitchen.
Preparing meals at the site requires that each site have
adequate kitchen and storage facilities. Sponsors preparing
meals at a central kitchen must decide how to distribute
the meals from the central kitchen to the sites, and safely
deliver and store them until meal service. Sponsors
preparing meals on site or in a central kitchen should
refer to the 2015 SFSP Nutrition Guidance for Sponsors,

available at http://www.fns.usda.gov/sfsp/handbooks, for
more information on planning, distributing, storing and
serving meals. Sponsors preparing or assembling meals
either at each site or at a central kitchen receive higher
administrative reimbursement rates. (See “Chapter 9 –
Program Costs and Reimbursements” for more information
about special reimbursement rates.)

PURCHASING MEALS
FROM SCHOOLS
(7 CFR 225.15(b), 16(f))

Purchasing products and services for use in meals must achieve full and open competition in
compliance with Program regulations.
If sponsors choose not to prepare meals for sites, they may
enter into a noncompetitive agreement to purchase meals
from a school food service facility. Most schools have meal
preparation and service facilities since they serve meals to
children during the school year. Also, experienced school
food service personnel are often available for summer jobs.
Sponsors that wish to obtain SFSP meals from a school
should contact the local superintendent of schools, or the
principals of local non-profit private schools. SFA sponsors
who participate in the NSLP or SBP at any time during
the year may substitute the meal pattern requirements of

the NSLP and SBP respectively for the SFSP meal pattern
requirements for meals served at school sites. State agency
approval of this substitution is not required. However, meals
served at non-school sites using the NSLP or SBP meal
pattern requirements by a SFA sponsor requires State
agency approval.
If a non-SFA sponsor purchasing meals from an SFA wishes
to substitute the meal pattern requirements of the NSLP and
SBP respectively for the SFSP meal pattern requirements,
a formal request for permission must be submitted to the

75

Such an arrangement will require either a written
agreement or a contract between the sponsor and the SFA.
(Attachment 7 in the Reference Section includes a sample
agreement between the school and sponsor to furnish
prepared meals.)

with prior State agency approval, use the meal requirements
of those programs instead of the SFSP meal patterns. SFA
sponsors may use the meal requirements of the NSLP or
SBP instead of the SFSP meal patterns without obtaining
State agency approval. Sections 210.10 and 210.10(a) of
NSLP regulations and Sections 220.8 and 220.8(a) of SBP
regulations describe requirements for school meals. [(7 CFR
225.16(f)(1)(i))]

Schools participating in NSLP or SBP are accustomed to
preparing meals that meet Federal nutritional requirements.
Sponsors serving meals that are prepared in schools may,

Soliciting Local Schools

(7 CFR 225.15(b)(1))

Federal regulations strongly encourage sponsors to first
consider their local SFA as a source for obtaining meal
service. Using the facilities of local public or private schools
to prepare or obtain meals offers the sponsor several
advantages. These schools often prepare large numbers of
meals during the school year and already have the facilities
and the staff to prepare meals for the SFSP. In addition,
many schools are accustomed to preparing meals that
meet USDA requirements if they participate in other Child
Nutrition Programs. Also, the agreement needed to obtain
the service of an SFA is simpler to execute than the formal
competitive procurement process that is required to use a
commercial company.

When assessing a school’s ability to provide meal service,
sponsors must consider whether or not an adequate
delivery service to sites can be established and whether the
meals prepared by the school are comparable in price and
quality to those available from commercial vendors.
Sponsors that use local SFA facilities must enter into a
written agreement with the school, but are not required to
utilize the competitive bid procedures described below if
the school itself does not obtain its meals from an FSMC.
Attachment 7 in the Reference Section includes a sample
agreement between the school and sponsor to furnish
prepared meals.

Year-Round Contracts with SFAs

Generally, if the school itself obtains its meals from an FSMC, the sponsor may not enter into an
agreement for meal service, but must use the competitive bid procedures described below.
However, if a sponsor is considering using an SFA that
has executed a year-round contract with an FSMC it may
be permitted to enter into an agreement with the SFA.
The sponsor should check with the State agency before
implementing a contract to determine whether SFSP
meals may be included in a contract that was competitively
procured on a cost-plus-fixed fee basis (SFSP Memorandum
1-2004: Contract Requirements for School Sponsors, March
2, 2004).

Sponsors that are SFAs participating in the NSLP have the
option to comply with the NSLP procurement standards
found in 7 CFR 210.21 in lieu of SFSP procurement
standards in 7 CFR 225.17. State agency approval is not
required to utilize this option. NSLP has comprehensive
requirements in these areas and compliance with the NSLP
requirements satisfies the intent of the corresponding SFSP
requirements and will simplify participation for SFAs (SFSP
Memorandum 4-2013: Summer Feeding Options for School
Food Authorities, November 23, 2012).

76

PURCHASING MEALS
FROM A FSMC
(7 CFR 225.15(m))

In the SFSP, the term “food service management company” is defined slightly differently than in the
other Child Nutrition Programs.
In SFSP, this means any commercial enterprise or non­
profit organization with which a sponsor may contract for
preparing unitized meals, with or without milk, for use in the
Program, or for managing a sponsor’s food service operations
in accordance with the limitations set forth in the Program
regulations on management responsibilities of sponsors.
FSMCs may be (a) public agencies or entities; (b) private non­
profit organizations; or (c) private, for-profit companies.

or the contract with the FSMC included the provision of
SFSP meals. Please contact the State agency with questions.
Consult “Chapter 6: Procurement and Bid Procedures” of
this guide, for additional information about the various
requirements and procedures that such sponsors must
follow when they are contracting with a FSMC.
FSMCs and SFAs contracting to prepare SFSP meals must
provide unitized meals to the sponsors’ site(s) unless the
State agency has approved a waiver of the unitized meal
requirement. The unitized meal requirement specifies
that the meal components (except milk or juice) must be
packaged, delivered, and served as a unit. Milk or juice,
which may be packaged and provided separately, must be
served with the meal and only such complete meals are
reimbursable. (7 CFR 25.6(h)(3))

All SFSP sponsors may competitively solicit and award
a contract with a FSMC or with a school to obtain their
meals. SFSP sponsors are encouraged to enter into State
and local intergovernmental agreements with schools or
inter-entities, where appropriate, for procurement or use of
common or shared goods and services. Generally, sponsors
may not contract with a school using a FSMC unless the
school’s Request for Proposal, Invitation for Bid (IFB), and/

Check out the Vended Meals Toolkit page for a guide to choosing the right vendor!
http://www.fns.usda.gov/sites/default/files/cnd/SMT-Vended%20Meals.pdf

Soliciting a FSMC
If a written agreement with a local school is not possible
or is not beneficial, sponsors may competitively solicit and
contract with an FSMC to prepare and deliver meals. There
are specific management responsibilities that sponsors may
not contract out, such as monitoring, staff training, enforcing
corrective action, or preparing program applications
and claims for reimbursement. Sponsors remain legally

responsible for ensuring that the food service operation
meets all requirements specified in the agreement they
sign with the State agency. It is also important to note that
the contract is between the sponsoring organization and
the FSMC only, and neither USDA nor the State agency have
jurisdiction to enforce it with either party, or to resolve any
disputes that may arise.

77

Factors Involved with
Contracting with a FSMC

(7 CFR 225.2 definitions, 225.6(g) and (h), and 225.15(m))

There are several factors that can influence a sponsor’s decision to contract for meals with an FSMC.
These factors may include the sponsor’s lack of food preparation facilities or personnel, a site that
is unsuited for meal preparation, or a large number of sites spread over a wide geographical area.
Sponsors that decide to contract with an FSMC to obtain
meals are called “vended sponsors” and must meet various
program requirements and follow certain procedures.
FSMCs that enter into a contract with a sponsor to prepare
and deliver meals must provide meals that comply with
Program regulations and their contract with the sponsor.
The duration of an agreement with an FSMC generally is
limited to a single year, due to the nature and design of the
SFSP. However, to be consistent in the administration of all
child nutrition programs, SFSP sponsors, with State agency
approval, may execute agreements with FSMCs that include
an option for renewal that does not exceed four additional
years from the original agreement. This optional extended
agreement streamlines the procurement process with FSMC
contracts but does not compromise the integrity of SFSP.
Every precaution must be taken to ensure procurements
are conducted in accordance with Federal procurement
standards. And, all contracts shall include a termination
clause whereby either party may cancel for cause with a 60­
day notification. Sponsors should contact the State agency

for more details (SFSP 09-2007, July 27, 2007, Food Service
Management Company Contracts).
It is important that both sponsors and FSMCs (including
commercial meal vendors) are familiar with the
information in this section. A successful vended operation
depends on both parties fully understanding their mutual
responsibilities in the Program.
FSMCs are required to have State or local health certification
for the facilities in which they propose to prepare meals for
use in the SFSP and must ensure that State and local health
and sanitation requirements are met at all times. FSMCs
also must ensure that meals are inspected periodically as
required under Program regulations (SFSP Memorandum
7-2015: Health and Safety Inspection Requirements,
December 11, 2014).
Additionally, as with all purchases for Program use, FSMC
contracts must be competitively procured in compliance
with 7 CFR Parts 225.15 and 225.17 as well as 2 CFR Part
200.317-.326.

FSMC Limitations
(7 CFR 225.15(a) (3))

There are some specific Program management
responsibilities that sponsors may NOT contract out to an
FSMC, including, but not limited to:
• Assuming official recordkeeping responsibilities,
including meal count information to substantiate claims
•

Submitting claims

•

Training and monitoring administrative and site staff

•

Announcing availability of meals to the news media

•

Determining income eligibility and maintaining
individual income eligibility statements

Sponsors should check with the State agency before
allowing an FSMC to undertake any other tasks that may
have been identified as management functions that may
not be delegated. SFAs that contract with FSMCs for some
or all aspects of the management of the food service
program may allow the FSMC to conduct the same activities
for SFSP that are performed for NSLP. SFAs should be
reminded, however, that the SFA maintains responsibility
for submitting claims and remains accountable for
ensuring that all SFSP requirements are met (SFSP 04­
2013 – REVISED: Summer Feeding Options for School Food
Authorities, November 23,2012).

78

USDA FOODS

(7 CFR 225.9(b))

Sponsors eligible to receive USDA Foods (donated
commodities) under the SFSP include:
• Sponsors preparing meals on site or at a central kitchen

•

•

Contact your State agency regarding the current available
list and how to receive USDA Foods for all eligible sponsors.

Sponsors purchasing meals from a SFA that
participates in the NSLP

SFA sponsors that procure their SFSP meals from the
same FSMC that competitively provided their most
recent NSLP and/or SBP meals

Additional
Foods
If a site chooses to purchase additional food with SFSP funds, the food must be a creditable food
under the meal pattern requirements.
Expenditures for foods that may not be served as part of the
reimbursable meal based on the SFSP meal patterns are
not allowable costs. Condiments served with a creditable
food are exempt from this restriction. Sites wishing to
serve additional foods that do not meet SFSP meal pattern
standards must use non-Program funds.
Sites with additional funds available are encouraged to use
the funds to improve the reimbursable meals served by
using fresher, healthier, more nutritious products, such as
fresh fruits and vegetables, lean meats, and unprocessed
cheeses. Foods such as turkey wraps, fresh watermelon,
grapes, and carrots with hummus are nutritious options
that children enjoy. (SFSP Memorandum 6-2012: Serving
Additional Foods in SFSP, November 23, 2011.)

must meet the conditions of the permit which has given
them authority to operate as a food service establishment.
Please refer to SFSP Memorandum 1-2016, Procuring Local
Meat, Poultry, Game, and Eggs for Child Nutrition Programs,
October 22, 2015 for specific questions and answers
related to these products available at http://www.fns.usda.
gov/procuring-local-meat-poultry-game-and-eggs-child­
nutrition-programs.

For more tips on adding fresh, healthy items to your menu,
refer to the 2015 Nutrition Guidance for Sponsors available
at http://www.fns.usda.gov/sfsp/handbooks.
Recently, FNS has received a number of questions related to
buying local meat, poultry, game, and eggs. SFSP operators

79

CHAPTER 5

Questions
and answers
1
WHAT ARE THE SPONSOR’S
CHOICES OF MEAL PREPARATION
METHODS TO USE WHEN
PROVIDING MEALS TO CHILDREN?

the facilities of local public or private schools to
prepare or obtain meals offers sponsors several
advantages. These schools often prepare large
numbers of meals during the school year and
already have the facilities and staff for such a
service. Many schools are also accustomed to
preparing meals that meet USDA requirements if
they participate in other Child Nutrition Programs.

Sponsors may choose from several methods of meal
preparation when providing meals. They may either
prepare and assemble their own meals, or obtain
meals from a SFA, a FSMC, a commercial for-profit
company or a private non-profit organization. Sponsors
should check with their State agency for a list of
establishments that they may contract with to prepare
their meals.

2

5

WHAT OPTIONS ARE AVAILABLE
FOR SPONSORS WHO CANNOT
CONTRACT WITH A FSMC?

Yes. FSMCs must have State or local health certificates
for the facilities they use to prepare meals for the
SFSP and they must ask local health authorities or
independent agencies to periodically inspect the
meals they serve to determine bacteria levels. Further,
companies must maintain records supported by
invoices, receipts, or other evidence that demonstrates
Program responsibilities are met. These records must
be kept by the companies for at least three years
from the date of receipt of final payment under the
contract. In addition, these types of companies may not
subcontract with another company for the total meal
or for assembling the meal because this will inflate
costs and lessen control of the quality and supply of
the meals.

MAY A SITE SELL À LA CARTE ITEMS
DURING AN SFSP MEALSERVICE?

Yes. The sale of à la carte items by SFSP sponsors
or sites during a meal service is permitted. However,
the non-Program and Program components of the
food service operation must be tracked separately,
accounting for the receipt, obligation, and expenditure
of all SFSP funds. The sponsor must maintain
accounting records documenting proper cost allocation
between the Program and non-Program components
of its food service operation and the State agency
must ensure through the review process that all SFSP
reimbursements are used solely for conducting nonprofit food service operations.

3

4

ARE THERE CERTAIN REQUIREMENTS
FSMCS NEED TO FULFILL?

ARE THERE ANY ADVANTAGES TO
OBTAINING MEALS FROM AN SFA?

Sponsors should work with their State agencies to find
viable options for procuring meals. Sponsors can also
contact their State Department of Agriculture, the USDA
Rural Development office in their State, and other public
agencies to identify potential FSMCs.

Sponsors are encouraged to contact the local
SFA about the possibility of obtaining meals
under a written agreement with a school. Using

80

81

CHAPTER 6

Procurement
and Bid
Procedures
•

PROCUREMENT

•

PROCUREMENT METHODS

•

FOOD SERVICE MANAGEMENT COMPANY CONTRACTS

•

PROCUREMENT TIPS AND STRATEGIES

•

LOCAL PROCUREMENT STRATEGIES

Procurement

All procurement of food, supplies, goods, and other services with Program funds by sponsors must
comply with procurement standards prescribed in Uniform Administrative Requirements for Grants
and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
located at 2 CFR Part 200 as well as 7 CFR Part 225. Procurement standards are specifically located
in 7 CFR Part 225.17 and 2 CFR Part 200.317-326. (Note: Parts 3016 and Part 3019 have been
superseded by 2 CFR Part 200 as adopted and supplemented by USDA in 2 CFR Part 400 for the SFSP
and other Child Nutrition Programs.)
The State agency can provide more detailed information since, in addition to complying with the minimum Federal standards,
sponsor purchases may have to meet more restrictive State and local standards, as well as special procurement requirements
that may be established by the State agency, with approval of FNS, to prevent fraud, waste, and Program abuse.

Procurement
Methods
(2 CFR Part 200.320)

Micro-Purchase

Small Purchase

(Purchases between $3,500-$150,000, or most
restrictive threshold)
(2 CFR Part 200.320(b))
The Federal Small Purchase Threshold as it relates to all FNS
program procurements under Federal grants is currently set
at $150,000 (SFSP Memorandum 01-2013: Federal Small
Purchase Threshold Adjustment, October 2, 2012).

(Purchases between $0- $3,500)
(2 CFR Part 200.320(a) and 200.67)
2 CFR Part 200 implemented a new micro-purchase
threshold for the purchase of supplies or services, the
aggregate amount of which does not exceed $3,500. Micropurchases may be awarded without soliciting competitive
quotations if the price is considered to be reasonable and
must be equitably distributed among qualified suppliers.
For example, a sponsor must not make all purchases from
one source rather; the sponsor must make purchases from
all qualified sources equally.

This threshold allows for more small purchase procurements
to be conducted using simple and informal methods, such
as price or rate quotations, for securing products and
services, provided that each procurement is conducted in
a manner that ensures free and open competition. Price or
rate quotations must be obtained from an adequate number
of qualified sources prior to purchasing from one of them.
The institution must document the date, vendors consulted,
and quotes received (including for verbal quotes). Store
advertisements may be considered as documentation. State
and local agencies may set a lower small purchase threshold

Check out Procurement

By Micro-Purchases Webinar!

https://www.youtube.com/watch?v=C-saG-g6fG4

83

and thereby impose more restrictive procurement procedures as authorized by 2 CFR Part 200.318(a).Therefore, all State and
local procurement requirements still apply.
Contracts using the small purchase threshold may be subject to required Federal contract provisions found at 2 CFR Part 200,
Appendix II (Attachment 29).

When purchases are estimated to exceed the most restrictive small purchase threshold (Federal is
$150,000), sponsors must conduct a cost or price analysis (2 CFR Part 200.323). The following two
formal procurement options are used for procuring a contract over $150,000 (such as with a FSMC):
Competitive Sealed Bids

The Public Solicitation is a Request for
Proposal (RFP)

(formal advertising) (Purchases over $150,000 or most
restrictive threshold)
(2 CFR Part 200.320(c))
Bids are publicly solicited from two or more responsible
bidders and a firm fixed-price contract (lump) sum or
unit price is awarded to the lowest price responsive and
responsible bidder whose bid conforms with all contract
specifications, terms, conditions, and required provisions.
Fixed priced contract is (with or without adjustment factors)
based on a specified price index such as the Consumer Price
Index (CPI). The public solicitation is an Invitation for Bid (IFB).
•

A RFP is used to solicit responses in a competitive negotiation
procurement method. A RFP is more qualitative in nature,
and the vendor solicitation responses are scored based on
evaluation criteria specified in the solicitation. For example,
a portion of the score could be based on a taste test, or
performance history with delivery times. Price must be the
primary consideration when awarding a contract under this
competitive procurement method.

Bids must be solicited from an adequate number of
known suppliers, providing them sufficient response
time prior to the date set for opening the bids and the
IFB must be publically advertised.

•

The IFB, which will include any specifications and
pertinent attachments, must define the items or services
to be procured in order for the bidder to properly respond.

•

All bids will be publicly opened at the time and place
prescribed in the IFB.

•

A firm fixed price contract award will be made in
writing to the responsible bidder with the lowest
responsive bid. Where specified in bidding documents,
factors such as discounts, transportation cost, and life
cycle costs must be considered in determining which
bid is lowest. Payment discounts will only be used to
determine the low bid when prior experience indicates
that such discounts are usually taken advantage of.

•

Any or all bids may be rejected if there is a sound
documented reason.

Competitive Proposals
(2 CFR Part 200.320(d))
Competitive proposals are publicly solicited from an
adequate number of qualified sources with more than one
source submitting an offer with either a fixed-price or costreimbursable type contract awarded. It is used when conditions
are not appropriate for the use of sealed bids.
84

•

The RFP must be publicized and identify all evaluation
factors and their relative importance and any response
must be considered.

•

The RFP must be solicited from an adequate number of
qualified sources.

•

The institution must have a written method for
conducting the technical evaluations of the proposals
received and for selecting recipients.

•

Contracts must be awarded to the proposal that is
most advantageous to the program, with price and
other factors considered.

Food Service
Management
Company
Contracts
It is important that FSMCs respond to the IFB or RFP accurately and completely. FSMCs that
attempt to modify any provision of the IFB or RFP, or otherwise fail to comply with all IFB or RFP
requirements, will be considered “non-responsive” and ineligible for contract award.
A State agency may require each food service management company, operating within the State, to register based on State
procedures. A State agency may further require the food service management company to certify that the information
submitted on its application for registration is true and correct and that the food service management company is aware
that misrepresentation may result in prosecution under applicable State and Federal statutes. [7 CFR Part 225.6(g)]
The solicitation needs to outline the need and scope of the required products and services and, if this includes purchasing,
menu planning services, etc., the solicitation needs to include having the FSMC provide menus. The FSMC needs to respond
with a full understanding of the meal requirements, sanitation, meals to be served and meal patterns, sites, and 7 CFR Part
225.17 procurement standards related to geographic preference. Including all contract provisions and regulations as well as
meals to be served by the sponsor, pattern requirements, cycle menus, and meal quality standards help sponsors evaluate
FSMC proposals to determine the most responsive and responsible offer or with price as the primary consideration.

85

Standard Contracts for FSMCs

State agencies may require sponsors to use a standard contract developed by the State agency for
meals provided by an FSMC. These standard contracts may vary according to different State and local
requirements. This document can serve a dual purpose. It may contain the specific information a
bidder needs to submit (IFB) and, upon acceptance of the bid and execution, it becomes the contract.
The standard contract threshold sets a contract award amount that triggers additional procurement requirements. If a FSMC
contract exceeds the $150,000 threshold, the sponsor must use the State agency-developed standard contract. Sponsors must
apply this threshold to the aggregate value of FSMC contracts which include projected costs from multiple Child Nutrition
Programs (SFSP Memorandum 07-2013: Summer Food Service Program Standard Contract Threshold, January 24, 2014).
For example, a sponsor that receives funds from the SFSP and the CACFP and contracts with a FSMC to procure meals for both
programs must apply the standard contract threshold to the projected value of the contract. Public entities and organizations
with exclusive year-round contracts are exempt from the standard contract requirement.
Sponsors with individual contracts that do not exceed the standard contract threshold may use their existing or usual form
of contract provided it has been submitted to and approved by the State agency. Individual contracts that exceed $150,000
in aggregate value require use of the State agency’s standard contract and must adhere to the stricter bid opening and
acceptance procedures as required by the SFSP regulations.
SFAs in exclusive year-round contracts with FSMCs are not required to use the standard contract developed by the State
agency for SFSP (7 CFR 225.6(h)(2)). These SFAs also are not required to use separate competitive bidding procedures in
procuring SFSP meals, provided all SFSP-related requirements are included in the solicitation and resulting contract [7 CFR
§225.15(h)(4)]. If the SFSP is added to an existing contract, it should be noted that this may represent a material change
to the contract (SFSP Memorandum 4-2013: Summer Feeding Options for School Food Authorities, November 23, 2012).
Additionally, SFAs may comply with the NSLP requirements for contracting with FSMCs outlined in 7 CFR §210.16 in lieu of
the SFSP requirements at 7 CFR §225.15(h)(4)(i)-(xii).

Formal Competitive Bid Waivers
(7 CFR 225.15(m)(4))

Sponsors that choose to purchase meals from SFAs are not required to conduct competitive procurements to obtain
those meals but must still enter into agreements which include the terms and conditions of the purchasing arrangements
with the SFAs. Sponsors that are schools or SFAs and have an exclusive contract with an FSMC for year-round service;
sponsors whose total contracts with FSMCs will not exceed $150,000, or any applicable State or local thresholds, are not
required to comply with the competitive sealed bid procedures provided below. In addition to any applicable State or local
laws governing bid procedures, all other sponsors that contract with an FSMC shall comply with the competitive sealed
bid procedures below. The State agency is responsible for ensuring that contracting and bidding procedures meet USDA
requirements and will provide technical assistance to sponsors to help them meet these requirements (SFSP Memorandum
13-2014: Procurement Thresholds in the Summer Food Service Program, January 10, 2014).

86

Competitive Sealed Bid Procedures for
FSMC Contracts exceeding $150,000

(7 CFR 225.15(m)(4)(i)-(xii) and SFSP Memorandum 13-2014: Procurement Thresholds in the Summer Food Service Program, January 10, 2014)

Formal competitive sealed bid procedures include t
he following steps:
•

Preparing the IFB.

•

Publicly announcing not less than 14 days before bids
are opened. Announcements must include the time and
place of the bid opening.

•

Notifying the State agency of the time and place at
least 14 days before the bid opening.

•

Publicly opening all bids.

•

Submitting bid to State agency prior to accepting.

•

Submitting to the State agency copies of all contracts,
a certificate of independent price determination, and
copies of all bids received, as well as the sponsor’s
reason for selecting the chosen FSMC. (In some cases,
these documents must be submitted to the State
agency before issuing a contract award.)

The IFB must include:
•

A cycle menu approved by the State agency.

•

Food specifications and meal quality standards.

•

A statement requiring compliance with SFSP
regulations.

•

Nonfood items essential for conducting the food service.

•

Special meal requirements to meet ethnic or religious
needs or dietary modifications for children with special
physical or medical needs, only if these are necessary
to meet the needs of the children to be served.

•

The location of the sponsor’s sites and the estimated
range of meals required.

The IFB must NOT:

Careful preparation is the most important step in the
competitive bid process. Sponsors must supply the IFB to all
companies responding to the public announcement.

•

Specify a minimum price.

•

Provide for loans or any other monetary benefit, term,
or condition to be made to sponsors by FSMCs.

•

Include nonfood items that are not essential to the
conduct of food service.

FSMC Bid Bond/Bonding Requirements

If FSMCs submit a bid over $150,000, they must submit a
bid bond/guarantee in an amount not less than 5 percent
and no more than 10 percent of the value of the contract for
which the bid is made, as determined by the sponsor and
specified in the IFB. FSMCs are prohibited from posing any
alternative forms of bid bonds (SFSP Memorandum 13­
2014: Procurement Thresholds in the Summer Food Service
Program, January 10, 2014).

Cash, certified checks, letters of credit, and escrow
accounts, are not acceptable substitutes for bid bonds.
The bond must be from one of the surety companies listed
in the most recent issue of the United States Department
of Treasury (TRE) Circular 570, which is available from
the Government Printing Office (GPO) for a small fee.
Sponsors may obtain a copy by calling (202) 512-1800, or by
downloading at: http://www.fms.treas.gov/c570/index.html.

87

FSMC BID SPECIFICATIONS
It is important that the FSMC respond to the IFB accurately and completely. FSMCs
that attempt to modify any provision of the IFB, or otherwise fail to comply with all IFB
requirements, will be considered “non-responsive” and ineligible for contract award.
FSMC regulations on cycle menus and meal quality standards in 225.7(c) and (d)(6), and 225.15(m).
The sponsor must include the following information in the IFB so that bidders will know the exact terms of the bid:

Site Information
(7 CFR 225.6(h)(2)(iii))

The sponsor must include a list of proposed site
names, addresses, delivery locations, times of meal
service, and days of operation. With this information,
a bidder can estimate the cost of delivery and the
feasibility of meeting the sponsor’s requirements. The
sponsor should specify in the IFB that single deliveries
for multiple meals (e.g., breakfast and lunch) are
allowed only at those sites that are equipped with
adequate storage and refrigeration facilities.

Cycle Menu
(225.15 (m)(4)(v) and (vii) and 7 CFR 225.6(h)(2)(vi))

The sponsor also must attach a cycle menu that
lists the types and amounts of food in each meal.
Program regulations specify minimum meal
pattern requirements, but sponsors may improve
upon these minimums to increase the variety and
appeal of menus. Sponsors may request approval
from the State agency for variations from the meal
requirements only when necessary to meet ethnic,
religious, economic, or nutritional needs.

Meal Requirements
(7 CFR 225.15(m)(4)(vi) and 225.7(c))

As part of the IFB, the sponsor must provide the
FSMC with a copy of the meal requirements outlined
in Section 225.16 of the SFSP regulations. The
sponsor also must provide a copy of the minimum
food specifications and model meal quality standards

required by Section 225.7(c) of the SFSP regulations.
The FSMC must deliver meals that meet these meal
requirements and minimum food specifications and
model meal quality standards.

Reimbursable Meals
(7 CFR 225.6(h)(2)(ix) and 225.15(m)(4)(ix))

Under the provisions of the contract between the
sponsor and the FSMC, the sponsor is required to
pay only for the delivered meals that meet these
requirements and should not pay for ineligible
meals. Similarly, the sponsor will receive payments
from the State agency only for meals that meet
these requirements.

Quality Control
(7 CFR 225.7(c) and (d)(6))

An effective quality control system is essential for
verifying that meal components meet the minimum
quantity requirements. During food preparation,
the FSMC should regularly inspect and measure
items to ensure correct sizes and weights. Setting
production equipment for the desired specifications
is no substitute for a quality control system,
because equipment settings may become distorted
during operation. State agencies and sponsors are
responsible for sampling meals and disallowing
payment for meals that fail to meet minimum
standards. The entire meal must be disallowed for
reimbursement if any component does not meet
minimum standards.

88

Delivery of Meals
(7 CFR 225.16(c)(5))

Sites without adequate facilities for holding meals
within the temperature ranges established by State
or local health ordinances must receive all meals
not more than one hour before the beginning of
the meal service. The FSMC should carefully plan
delivery routes and schedules and review them
with the sponsor. Delivery personnel for FSMCs
should become familiar with their routes before the
SFSP begins to help avoid confusion. The FSMC or
sponsor should evaluate and restructure the routes
if deliveries for some sites are consistently late.
The FSMC is responsible for ensuring that sufficient
equipment is available to handle such changes
(for example, additional trucks, refrigeration, etc.).
Sponsors must plan a system for serving meals when
the weather is bad or for canceling meal deliveries
and service at sites lacking sheltered facilities. The
FSMC should be notified of these contingency plans.

the IFB. The FSMC bases a bid on the specifications
and expects to be serving close to the number of
meals listed in the estimate. A sizeable discrepancy
between estimated and actual participation can
increase or decrease the FSMC’s unit production
cost. Therefore, the sponsor must carefully estimate
the number of meals it will need each day. Sponsors
also should consider including a provision that
will decrease the per-meal price if the number of
meals served exceeds expectations. Sponsors may
increase or decrease the number of meals specified
in the IFB only after notifying the FSMC. Sponsors
should consider specifying in the IFB a time period
during which changes in a site’s meal orders may
be made to the vendor. A reasonable time frame for
notifying the vendor may be within 24 to 36 hours
of the change. Increases in maximum meal service
levels at sites receiving vended meals must be
approved by the State agency.

Special Accounts
Unitized Meals

(7 CFR 225.6(f))

(7 CFR 225.6(h)(3))

The State agency may require sponsors to set up
special accounts at financial institutions. If such
accounts are established, the sponsor must deposit
any payments received from the State agency in
the special account. Both the FSMC and the sponsor
must authorize any checks drawn on this account.
This is to help ensure that the company receives
payment for the eligible meals it provides to the
sponsor’s Program.

Sponsors must ensure that FSMCs provide
“unitized” meals with or without milk or juice. This
means that meals must be individually portioned,
packaged, delivered, and served as a unit. The milk
or juice may be packaged and provided separately,
but must be served with the meal unit. Other
variations of unitized meals can be approved by the
State agency.

USDA Foods
(7 CFR 225.9(b))

Sponsors of vended programs can only receive
USDA Foods if the vendor is a school or school
district, or if the sponsor is an SFA that competitively
procures its SFSP meals from the same FSMC that
competitively provided its most recent NSLP meals.

Meal Range Adjustments
(7 CFR 225.6(h)(2)(xi))

Actual participation under a given sponsorship
frequently varies from the estimate specified in

89

Additional FSMC Requirements

There are several specific requirements FSMCs should be aware of before submitting a bid. These
requirements are:
Health Certification and Inspection

sponsor at the end of each month, at a minimum. The
FSMC must keep the books and records concerning the
sponsor’s food service operations for three years, or longer
if required by the State agency, from the date of receipt
of final payment under the contract. Representatives of
the State agency, USDA, and the United States GAO may
examine or audit these records at any reasonable time
and place. Records must be retained longer if there is an
unresolved audit or investigation.

(7 CFR 225.6(h)(2)(v))

A FSMC must have State or local health certification for
each facility preparing or serving meals for the SFSP.
The company must ensure that health and sanitation
requirements are met at all times. In addition, the company
must ask local health authorities or independent agencies
to periodically inspect the meals they serve to determine
bacteria levels. These levels must conform to the standards
set by local health authorities. The company must submit
the results of the inspections promptly to the sponsor
and the State agency. Your State agency will provide more
information on these inspections during your training.

Subcontracts
(7 CFR 225.6(h)(2)(ii))

FSMCs may not subcontract with another company for the
total meal (with or without milk) or for assembling of the
meal. Subcontracting is prohibited because it inflates costs
and lessens the sponsor’s control over the quality and
supply of the meals.

State Agency Inspections/Administrative
Reviews
(7 CFR 225.7(d)(6) and (e))

The State agency will conduct administrative reviews of the
sponsor’s Program operations. The reviews are designed
to ensure that the sponsor’s overall Program is operating
according to requirements. The results of these reviews
may affect the amount of reimbursement a sponsor
will receive and the payment to the FSMC. The FSMC
should designate an official to be familiar with the total
Program, particularly with the sponsor’s responsibilities.
For example, in addition to reading the SFSP regulations,
this guide, and other aids for the sponsor, the FSMCs
representatives may attend training sessions arranged by
sponsor for food service personnel.

Contract Responsibility and Payment
(7 CFR 225.6(h)(2)(ix)

It is important for the prospective FSMC to realize that
the contract is a private contract between the FSMC and
the sponsor. Neither USDA nor the State agency has any
jurisdiction in the payments made to the FSMC. Before
contracting to provide meals for the Program, the FSMC
needs to assess the sponsor’s capability to meet the terms
of the contract and the sponsor’s capability to pay them
for all meals that are properly delivered. If applicable, the
company should become familiar with the sponsor’s past
performance in this or other federally funded programs.

FSMCs also should be aware that the State agency must
inspect the FSMC’s facilities as part of the sponsor review. In
addition, the State agency may conduct inspections of food
preparation facilities and food service sites and perform
meal quality tests. This inspection is independent of the one
the FSMC provides.

The FSMC must understand that the sponsor must pay
for meals delivered by the FSMC in accordance with the
contract. State agencies and USDA are not parties to such
contracts. Federal reimbursement to sponsors is based
solely upon the number of complete meals that are properly
served to eligible children. Therefore, if sponsors do not
meet their responsibilities (such as ensuring that meals
are served as a unit), meals must be disallowed. Although
the sponsor remains contractually liable for the number
of meals delivered in accordance with the contract, the
FSMC should make sure that it is informed of any sponsor
disallowances made by the State agency.

Records
(7 CFR 225.6(h)(2)(vii))

FSMCs must maintain records (supported by invoices,
receipts, or other evidence) that the sponsor needs to meet
Program responsibilities. Companies must report to the

90

State Agency Approval of FSMC Bids

(7 CFR 225.6(h)(6))

All FSMC bids totaling $150,000 or more must be submitted to the State agency for approval before the sponsor can accept
a bid. In addition, any bids (regardless of dollar amount) that exceed the lowest bid must be submitted to the State agency
for approval before acceptance, with an explanation of why that particular bid was chosen. The IFB that the sponsor accepts
will become the contract for Program operations between the sponsor and the FSMC. The State agency will keep copies
of all contracts between sponsors and FSMCs (SFSP Memorandum 13-2014: Procurement Thresholds in the Summer Food
Service Program, January 10, 2014).

Awarding the FSMC Contract
Sponsors must award the contract to the responsive and responsible bidder whose per-meal bid was lowest in price.
“Responsive” bidders are those whose bids conform to all of the terms, conditions, and requirements of the IFB. The sponsor
should award the contract at least two weeks before Program operations will begin to allow time for both the FSMC and the
sponsor to prepare. The sponsor must give to the State agency copies of all bids the sponsor received and the reason it chose
that particular FSMC.
Sponsors are encouraged to use the services of small and minority businesses, and women’s business enterprises, and
should consult local and State authorities regarding the applicability of preference and set-aside provisions. Only statutory
or court decreed preferences and set-asides that are not excessive may be used.

Award Conference
Contracts using federal funds must contain the Federal
contract provisions identified in 2 CFR Part 200, Appendix
II Contract Provisions for Non-Federal Entity Contracts
Under Federal Awards (Attachment 29) as required by 2
CFR 200.326.

After awarding but before executing the contract, all
sponsor and FSMC representatives should meet to discuss
their mutual and individual responsibilities in the SFSP.
In this meeting, which is called the award conference,
the representatives should review the IFB’s required
procedures for adjusting meal deliveries, cycle menus,
food quality specifications, and meal packaging, as well as
sanitation requirements.
The FSMC also must be familiar with all State and local
health requirements, particularly those concerning food
preparation and meal delivery. Most vended meals are
packaged to prevent contamination. Thus, the greatest
danger usually results when meals are held too long
or are stored under improper temperature controls.
Sponsors should also inform the FSMC of the function of
monitors, reviews, and statistical monitoring, if applicable
as directed by your State agency, in the operation of SFSP.

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FSMC Performance Bond

(7 CFR 225.15(m)(6)) and 2 CFR Part 200.325(b))

When an FSMC and a sponsor enter into one or more
contracts totaling over $150,000, the company must obtain
a performance bond from a surety company listed in the
current United States TRE Circular 570. The Circular is
available from the GPO for a small fee. Sponsors may
obtain a copy by calling (202) 512-1800 or downloading
the file from: https://www.fiscal.treasury.gov/fsreports/
ref/suretyBnd/supplements.htm (SFSP Memorandum 13­
2014: Procurement Thresholds in the Summer Food Service
Program, January 10, 2014).

The amount of the bond must be no less than 10 percent
or no more than 25 percent of the value of the contract, as
determined by the State agency and specified in the IFB.
FSMCs are prohibited from posing any alternative forms of
performance bonds. Cash, certified checks, letters of credit,
and escrow accounts are not acceptable substitutes for
performance bonds. The FSMC must furnish a copy of the
bond to the sponsor within 10 days of the contract’s award.

Use of Small, Minority, and Women’s

Businesses
(2 CFR Part 200.321 and 7 CFR 225.17(d))

All sponsors are encouraged to take affirmative steps to
ensure that small, minority firms and women’s business
enterprises and labor surplus area firms are used
when possible. Affirmative steps may include placing
such businesses on solicitation lists and ensuring such
businesses are solicited whenever they are deemed
potential sources. When economically feasible, sponsors
may wish to divide their total requirements into smaller
tasks or quantities to permit maximum participation

by small and minority business and women’s business
enterprises. They may also want to establish delivery
schedules that will help these business enterprises meet
deadlines. Sponsors can use the services and assistance
of the Small Business Administration and the Minority
Business Development Agency of the Department of
Commerce, and require the prime contractor, if subcontracts
are let, to take the affirmative steps listed above.

92

Assistance Provided By the Small
Business Administration (SBA)
(7 CFR 225.17(d)(5))

The SBA is an independent Federal agency established to provide assistance to all small businesses.
The SBA provides prospective, new, and established members of the small business community
with financial assistance, management training, and counseling. SBA’s policy is to extend the fullest
opportunity for minorities and disadvantaged people to participate in the small business sector. For
more information about the SBA and its services, visit the web site at http://www.sbaonline.sba.gov.
The SBA may be able to help minority-owned and disadvantaged FSMCs/commercial meal vendor improve or develop their
businesses in the following areas.

Financial Assistance

the bonding process accessible to small and emerging
contractors that find bonding unavailable to them. The
SBA is authorized to guarantee a qualified surety up to
90 percent of losses incurred under bid payment bonds.
The SBA can also guarantee performance bonds that are
issued to contractors on contracts up to $1 million. FSMCs
that anticipate problems in obtaining bid and performance
bonds for the SFSP may contact the SBA for assistance
(SFSP Memorandum 13-2014: Procurement Thresholds in the
Summer Food Service Program, January 10, 2014).

FSMCs that need money and cannot borrow it on reasonable
terms from conventional lenders may be able to get
assistance from the SBA’s loan programs. However, by law,
the SBA may not make a loan if a business is able to obtain
funds from a bank or other private source. The SBA may
either participate with a bank or other lender in a loan, or it
may guarantee up to 90 percent of a loan against loss. If the
bank or other lender cannot provide funds using either of
these methods, the law provides that the SBA can consider
lending the entire amount as a direct government loan, if
the funds are available. The SBA loans may be used to help
FSMCs purchase equipment, facilities, and supplies.

Management and Counseling Assistance
The SBA places special emphasis on improving the
management ability of small business owners and
managers. Accordingly, small business specialists may
be able to assist minority-owned FSMCs with their
management problems. They also may provide counseling
on the problems or concerns FSMCs may have in meeting
requirements for the SFSP.

Surety Bonds
Under the SFSP, FSMCs that submit bids over $150,000 and
that enter into a food service contract for over $150,000
must obtain bid and performance bonds. The SBA makes

Minority-owned FSMCs should contact SBA's nearest field office for prompt assistance.

93

Default and Disallowances

Sponsor Disallowances

•

Delivering meals that are missing components; and

(7 CFR 225.11(d) and (e))

•

Changing menus or substituting components without
the sponsor’s prior approval.

If the State agency disallows meals for any of the following
reasons, the sponsor is still responsible for paying the FSMC:
•

Excess meals, which are a result of failure to plan and
prepare, or order and adjust, meal orders with the
objective of providing only one meal per child at each
meal service;

•

Allowing meals to be eaten off-site;

•

Failure to serve meals as a unit;

•

Claiming meals served to adults;

•

Serving meals outside the approved timeframes; and

•

Serving meals in excess of approved levels.

FSMC Disallowances
(7 CFR 225.6(h)(2) and (3))

Violations that would cause disallowances in the FSMCs
payment from the sponsor’s reimbursement are:

Default of FSMC Contract
A sponsor should ensure that the FSMC contract contains
a default or termination clause that allows the sponsor
to terminate the contract if the FSMC does not comply
with the contract terms. The sponsor will notify the FSMC
(and Surety Company, if a performance bond is in effect)
of specific instances of unsatisfactory performance. If the
FSMC does not immediately take corrective action, the
sponsor may request the surety company to provide another
FSMC, or the sponsor may negotiate another contract. The
sponsor can negotiate this other contract on a competitive
or non-competitive basis. The clause should state that the
defaulting FSMC (or Surety Company if applicable) is liable
for any difference in price between the original price and the
new contract price.

•

Delivering meals that are not unitized;

•

Delivering meals that are wholly or partially spoiled;

Other procurement regulations related to
FSMCs include:

•

Delivering meals outside the designated delivery times;

•

•

Delivering meals with components that are less than
the required size or weight;

Debarment, Suspension, (2 CFR Part 180) and Lobbying
(2 CFR Part 418 and 200.450);

•

Civil Rights Statement (FNS Instruction 113 Appendix B).

Best Practices for FSMC Contracts

Food Service Sites

Approved Meal Levels

Sponsors should provide the FSMC with a list of approved
food service sites, along with the limit on the number of
meals that may be claimed for reimbursement for each
site. It is likely that some approved sites, for one reason
or another, may have been canceled or dropped from
participation before food service operations begin. A new
list should be provided to the FSMC well before it is to start
food service operations and at any other time during the
Program when sites are added or deleted. The sponsor
should notify the company within the time limits mutually
agreed upon in the contract if any site on its delivery
schedule is going to be dropped or canceled.

During the application approval process, the State agency
will approve sponsors that purchase meals from a FSMC to
serve a maximum number of meals at each meal service
for each site. The approved level represents the maximum
number of meals sponsors can serve and claim for
reimbursement at each meal service at their vended sites.
The State agency may reduce the approved level at any time
if it determines that a site’s attendance is below its approved
level. If a sponsor finds that the approved level is too low,
the sponsor may seek an adjustment by requesting the
State agency to conduct a site review; or the sponsor may
document in writing (to the State agency) that attendance at
a site exceeds the approved level.

94

Sponsors must plan for and adjust meal orders with the
objective of serving only one meal to each child at each
meal service. A vended sponsor must inform its FSMC of:
•

The approved level for each meal service at each site
where the FSMC will deliver meals

•

Any adjustments in the approved level for its sites

independently request more or fewer meals. These
requests must be channeled through the sponsor. Meal
deliveries may be adjusted only by the sponsor. If the
sponsor wants to order in excess of the approved meal
level, State agency approval is required.
The attendance at sites will probably fluctuate during
the duration of the Program, especially if there is no
organized activity at a site other than the food service.
Sponsors should try to anticipate certain fluctuations in
attendance (such as local events that may interfere with
site participation) and make arrangements in advance with
the FSMC to adjust orders. For example, a consistent drop
in attendance each Friday should be handled by reducing
the number of meals delivered on Fridays.

Such sponsors must advise the FSMC that the approved
level for each site is the maximum number of meals that
can be served at that site. This does not mean that these
sites will serve that specific number of meals each day. The
sponsor must clearly inform its FSMC that it will only be
ordering the number of meals actually needed, based on
participation trends and with the intent of serving only one
meal to each child at each meal service. During reviews,
State agencies will disallow all served meals that exceed
the approved level for each site.

Whenever possible, meals should be transferred from a
site with too many meals to a site with a shortage, provided
that the site’s approved meal level is not exceeded.
Monitors should be aware of the procedures for handling
extra meals so they can assist the site supervisors in
making transfers or other arrangements.

Adjusting Meal Deliveries
One of the most important topics for discussion in the
award conference is the adjustment of meal deliveries.
As a sponsor, you should establish a system for collecting
information on attendance changes from its sites,
translating these changes into adjustments in the meal
order, and communicating these adjustments to the FSMC.
In turn, the FSMC should have an organized system for:
•

Receiving orders for delivery adjustments

•

Documenting orders for delivery adjustments

•

Adjusting production levels, if necessary

•

Ensuring that delivery receipts are changed to reflect
adjusted meal orders

•

During the course of the Program, sites may cease food
service operations on either a temporary or permanent
basis. Also, new sites may be authorized to participate in the
SFSP. Site deletions and additions may necessitate changes
in delivery routes and production levels, and will require the
FSMCs cooperation. Sponsors are responsible for making
sure the FSMC is informed of such changes.

Communication
Good communication is essential for smooth Program
operations. Even with good management and good
intentions, complaints about the food service can arise.
FSMCs and sponsors should establish a system for
communicating and resolving complaints. Experience
indicates that problems can be most efficiently resolved
when both the sponsor and the FSMC designate officials to
receive and respond to suggestions and complaints.

Ensuring that adjusted meal orders for each site are
correctly packaged and loaded for delivery

The FSMC’s key personnel must be aware of these
responsibilities. For example, the FSMC’s delivery
personnel must understand that site supervisors cannot

Procurement Ethics

(2 CFR Part 200.318(c)

connection. The code of conduct must also provide for
disciplinary action to be applied in the event the standards
are violated.

State agencies and Child Nutrition Program operators
are required to write a code of conduct to govern the
performance of employees (and sponsors) engaged in
procurement. These written standards must prohibit
employees from soliciting gifts and other incentives from
prospective contractors, and also prohibit employees from
participating in the selection, award, or administration of
any contract to which they have a personal or financial

(SFSP Memorandum 09-2015: Written Codes of Conduct
and Performance of Employees Engaged in Award and
Administration of Contracts, November 21, 2015)

95

Procurement
Tips and
Strategies

Improving Product Selection and
Specifications
Sponsors may want to consider any number of the
following when developing bid specifications:

Careful selection of products and meals in the procurement
process can be critical to the success of a site. Sourcing items
that both meet meal pattern requirements and are palatable
and appealing to children yields numerous benefits:
•

Children are more likely to finish snacks and meals,
thereby receiving optimal nutrition;

•

Food waste is reduced;

•

Sites are more likely to maintain or increase
participation; and

•

Program goals of teaching children to enjoy healthy
foods and develop lifelong healthy eating habits
are facilitated.

TASTE, GRADE,

APPEARANCE,

BRAND PREFERENCE,

ETHNIC OR CULTURAL

ACCEPTABILITY,

SEASONALITY, AND

GEOGRAPHIC ORIGIN

For more information on developing food specifications, refer to the Food Purchasing and Receiving section in the 2014
Nutrition Guidance for Sponsors handbook or download Choice Plus: A Reference Guide for Foods and Ingredients from
the Institute of Child Nutrition (formerly known as the National Food Service Management Institute) at: http://nfsmi.org/
documentLibraryFiles/PDF/20080201030612.pdf.

96

Local
Procurement
Strategies
In many regions across the country, summer brings new opportunities to source local foods. Sponsors
may decide to target local products for inclusion in their Program in order to increase the quality and
appeal of meals, provide enhanced opportunity for nutrition education to Program participants, and
contribute to the local economy.
Local foods can span the entire plate, and can be
included within all components of a meal. While fruits
and vegetables are a logical starting point for summer
meal providers, grains, beans, fish, poultry, and meat can
also be sourced locally during the summer months. For

specific guidance on purchasing local meat see SFSP
Memorandum 01-2016, Procuring Local Meat, Poultry,
Game, and Eggs for the Child Nutrition Programs: http://
www.fns.usda.gov/procuring-local-meat-poultry-game-and­
eggs-child-nutrition-programs.

97

BELOW ARE SOME FACTORS TO CONSIDER WHEN ADDING LOCAL FOODS:
Defining Local

must be communicated as a preference to ensure that other
producers, vendors, and distributors have the chance to
bid. There are many ways to communicate a preference for
food from local sources whether sponsors are following the
informal or formal bidding process.

There are many options for defining “local,” and definitions
vary widely depending on the unique geography and climate
where a sponsor and its meal sites are located. Sponsors
can define local as within a certain number of miles, within
the county, State, or region.

If a sponsor is making a purchase under the new micropurchase threshold (below $3,500), the sponsor may do
so without obtaining price quotes provided the price is
reasonable and purchases are distributed equitably among
qualified suppliers. For purchases below the most restrictive
applicable small purchase threshold, as discussed earlier
in this chapter, a sponsor can simply gather three quotes
from producers that meet their definition of local, and
guarantee that the food comes from a local source. If making
a purchase that is over the small purchase threshold,
the sponsor may include language in the solicitation that
will target foods from local sources. For instance, the bid
request can state that a responsive vendor will provide
product within 24 or 48 hours of harvest, or that they will
offer farm field trips. A product specification may include
a variety of produce that is native to the sponsor’s region.
As with any procurement, sponsors must ensure that these
requirements are not restricting competition.

A sponsor’s definition of local may change with seasonality;
for instance during the school year, a district may decide
that their definition of local is within the State, but during
the summer months, the district selects a more narrow
definition due to a greater abundance of local products
available during that season. There is no Federal definition
of local.

Sourcing Local Products
Sponsors can find local foods through a variety of sources.
Sponsors may start by asking their mainline distributor or
meals vendor to label the source of origin for their products,
and in doing so may find that the vendor is already providing
local products. If a vendor is not already sourcing locally,
the sponsor may ask them to do so in the future and include
language in product specifications or solicitations that
communicate a preference for products from local sources.
Sponsors may survey their area to see if there is a food hub
that is buying and aggregating food from local producers. If
buying directly from a farm is a viable option, sponsors may
wish to start by surveying producers in their area through
phone calls, farm visits, or a stop by the local farmer’s
market to see what’s available during summer months.
Sponsors that have access to a garden may consider
planting specifically for the Program.

Geographic Preference
A sponsor may decide to use Geographic Preference
to target products from local sources through a formal
solicitation. In 2011, the Food and Nutrition Service
published the Final Rule titled, “Geographic Preference
Option for the Procurement of Unprocessed Agricultural
Products in the Child Nutrition Programs” (76 Federal
Register 78” 22 April 2011, 22603-22608). This allows
sponsors to give a point or price preference to bidders that
meet their definition of local for unprocessed products.
Using this option enables a sponsor to award its contract to
a bidder that did not necessarily provide the lowest bid, but
the original bid price must still be paid.

Methods of Procurement
Due to the requirement to maintain fair and open competition
at all times, a sponsor may not require that product come from
a local source. The purchase of products from local sources

For more information on the variety of ways to source products locally for Child Nutrition
Programs, please visit the procurement section of USDA’s Farm to School website
http://www.fns.usda.gov/farmtoschool/procuring-local-foods

Consult the Guide to Procuring Local Foods for Child Nutrition Programs
http://www.fns.usda.gov/sites/default/files/f2s/F2S_Procuring_Local_Foods_Child_Nutrition_Prog_Guide.pdf

98

CHAPTER 6

Questions
and answers
3

1

WHAT TYPE OF INFORMATION DOES
THE SPONSOR NEED TO PROVIDE TO
FSMCS WHEN THEY ARE INVITING TO
BID ON THE CONTRACT?

Sponsors should award the contract to the responsive
and responsible bidder whose per meal bid was lowest
in price. Responsive bidders would be considered
those whose bids conform to all of the terms,
conditions, and requirements of the IFB. Sponsors are
encouraged to use the services of small and minority
businesses and women’s business enterprises and
should consult local and State authorities regarding
the applicability of preference and set-aside
provisions. For bids totaling $150,000 or more, or to
select a bid that is not the lowest bid, sponsors must
first receive State agency approval before acceptance.

Sponsors will need to include a list of proposed site
names, addresses, delivery locations, times of meal
service, and days of operation. They should also include
a cycle menu that lists the types and amount of food
in each meal, a copy of the meal pattern requirements
and minimum food specifications, and model meal
quality standards. Sponsors will need to ensure that the
companies they plan to contract with provide “unitized”
meals. Additionally, sponsors must carefully estimate
the number of meals needed each day because a sizable
difference between estimated and actual participation
can increase or decrease the FSMCs unit production cost.
Sponsors must clarify that commodities will be received
only if the vendor is a school or school district, or if the
sponsor is a SFA that procures its meals from the same
FSMC that currently provides NSLP meals.

2

TO WHOM SHOULD A SPONSOR
AWARD THE CONTRACT?

DO COMMERCIAL FSMCS NEED TO BE
REGISTERED WITH THE STATE AGENCY?

It depends. Commercial FSMCs are no longer required
by Federal law to register with the State agency.
However, States may continue to require their own
registration procedures. This policy gives State
agencies flexibility in managing the SFSP. Some State
agencies have found the registration process to be
beneficial and continue to require it.

99

This requirement should not be interpreted to allow
sponsors the ability to arbitrarily award the contract
other than to the lower price responsible bidder whose
bid conforms to all the material terms and conditions
of the solicitation. Additionally, in situations where a
sponsor wishes to disallow the bid of a previous FSMC
due to poor performance, the sponsor should bring forth
documentation of specific incidents and deficiencies,
correspondences regarding these matters, and any
requests for corrective actions or resolution. This
documentation should clearly demonstrate why the
award to this specific contractor would not be in the best
interest of the sponsor, or the SFSP.

4

IS IT POSSIBLE FOR AN
ORGANIZATION SUCH AS A COLLEGE
OR UNIVERSITY TO HAVE YEAR­
ROUND CONTRACTS THAT PROVIDE MEAL
SERVICE FOR THE SFSP IN CONJUNCTION
WITH OTHER ON CAMPUS MEAL SERVICES?

8

MUST SPONSORS ALWAYS ACCEPT
THE LOWEST BID?

Contracting with small, minority, and women’s
business enterprises and labor surplus firms is a
government-wide requirement at 2 CFR Part 200.321
as well as in procurement standards in Program
regulations. [7 CFR Part 225.17(d) and 7 CFR Part
226.22(f)]. Contracting with these entities may be a
way of attracting local businesses and potentially
achieving lower prices as these entities often do not
have the overhead expenses of larger companies.

Yes. This arrangement can work provided the scope
of the SFSP meal service is included in the original
solicitation (i.e., RFP/IFB) and the resulting contract.

5

7

WHAT ARE THE ADVANTAGES OF
CONTRACTING WITH A MINORITY
BUSINESS?

MUST SFA SPONSORS USE SFSP
PROCUREMENT STANDARDS?

No. SFAs participating in the NSLP may choose to
comply with the NSLP procurement standards found in
7 CFR 210.21 in lieu of SFSP procurement standards
at 7 CFR 225.17 (SFSP Memorandum 4-2013: Summer
Feeding Options for School Food Authorities, November
23, 2012).

Procurement regulations at 2 CFR Part 200.320(c)(2)
(iv) for sealed bids requires that a fixed price contract
be awarded to the lowest responsive and responsible
bidder; 200.320(d) for competitive proposals requires
that a fixed price or cost-reimbursable type contract
be awarded to the responsible firm whose proposal
is most advantageous to the Program with price
and other factors considered. Policy guidance,
Procurement Questions dated July 14, 2005, primarily
addressed to school food authorities operating NSLP
and SBP, requires price to be the primary factor.
However, SP 12, CACFP 05, SFSP 09-2016: Guidance
on Competitive Procurement Standards for Program
Operators, dated November 13, 2015, clarified this
guidance in that price must be the primary factor for
contract awards in all Programs. Awarding a bid to the
lowest bidder may not be required as long as there is
sound documented reason the bid may be rejected.
This is one reason that it is important that sponsors
document issues with vendors. For example, make
sure to document if meals are incomplete, delivered
outside of required temperature, etc. Sponsor should
not have to accept lowest bidder if there have been
ongoing compliance issues with that bidder. Consult
with your State agency as needed.

6

WHAT IS THE STANDARD CONTRACT
THRESHOLD AND IN WHAT
SITUATIONS MUST A SPONSOR USE
A STANDARD CONTRACT?
The standard contract threshold is set at $150,000.
Non-profit sponsors conducting procurement with
an anticipated value greater than $150,000 must
use the State agency supplied standard contract.
This requirement only applies to non-profit sponsors
operating exclusively in the summer, and does not
apply to public institutions and organizations with
year-round contracts.

100

management-and-budget-super-circular-2cfr-part-200
and also SFSP 02-2016, Questions and Answers on the
Transition to and Implementation of 2 CFR Part 200,
October 30, 2015, at http://www.fns.usda.gov/questionsand-answers-transition-and-implementation-2-cfrpart-200.

For an IFB, the terms and conditions must be written
in such a way that they require bidders to demonstrate
their ability to be a responsible bidder without
restricting competition. These include clear and
accurate written specifications, terms, and conditions
that bidders must meet to ensure that the contract
award is based on price alone. Such provisions
may include evidence of liability insurance, proof
of financial viability, or other conditions as clearly
identified in the IFB.

9

10

WHAT IS CONSIDERED A
“TRANSACTION” WHEN
USING AGGREGATE COST
AND MICRO-PURCHASE METHODS?

WHAT IS THE SUPER-CIRCULAR AND
WHO DOES IT APPLY TO?

A transaction is an occurrence in which two or more
entities exchange goods, services, or money between
or among them under an agreement formed for their
mutual benefit. The following examples illustrate
transactions in the context of micro-purchasing:

The Office of Management and Budget (OMB) published
regulations commonly referred to as the SuperCircular on December 19, 2014. These regulations
are located at 2 CFR Part 200 and replace 7 CFR Parts
3015, 3016, 3017, 3018, 3019 and 3052, as well as a
number of other OMB circulars such as A–122 (Cost
Principles for Non-Profit Organizations), A-110 (Uniform
Administrative requirements for Grants and Agreements
with Institutions of Higher Education, Hospitals, and
Other Non-Profit Organizations), A-21 (Cost Principles
for Educational Institutions), A-87 (Cost Principles for
State, Local and Indian Tribal Governments), A-102
(Grants and Cooperative Agreements with State and
Local Governments), and A-133 (Audits of States,
Local Governments, and Non-Profit Organizations).
The regulations apply to awards of Federal financial
assistance to all “non-Federal entities” that carry out
Federal awards including States, local governments,
Indian tribes, institutions of higher education, or nonprofit
organizations such as SFSP local Program operators.
2 CFR Part 200 regulations apply to all grant funds
received after December 26, 2014. For more information
related to the Super-Circular, see SFSP 18-2015, Office
of Management and Budget Super-Circular 2 CFR Part
200, March 18, 2015, at http://www.fns.usda.gov/office-

A Program operator purchases computer paper, ink
cartridges, paper towels, and cleaning fluids from the
same supplier at the same time. That would be a single
transaction. If the aggregate cost of these items (that
is, the total bill) does not exceed the micro-purchase
threshold, the transaction is a micro-purchase under 2
CFR Part 200.320(a).
A Program operator makes the following purchases
on the same day at two separate locations: computer
paper and ink cartridges at a retail office supply store,
and paper towels and cleaning fluids at a different retail
store. The dollar amount spent at each supplier is less
than the micro-purchase threshold. Each purchase is
a separate transaction made from different suppliers.
Neither supplier is involved in the transaction with the
other. Therefore, these transactions are micro-purchases
and the Program operator has distributed purchases
among qualified suppliers.

101

12

11

HOW DO THE NEW
PROCUREMENT STANDARDS
AFFECT PROGRAM OPERATORS
PURCHASING COOPERATIVELY?

WHAT IS MEANT BY DISTRIBUTING
MICRO-PURCHASES EQUITABLY
AMONG QUALIFIED SUPPLIERS
AND “SPREADING THE WEALTH”?

Program operators purchasing cooperatively for
common or shared goods and services through
State and local intergovernmental agreements
or inter-entity agreements are encouraged (see
2 CFR Part 200.318(e)). When entering into these
agreements, Program operators are reminded that all
procurement standards in Program and governmentwide regulations apply to the cooperative in the
same way as to the Program operator. The Program
operator is responsible for ensuring all contracted
vendors have been properly procured and contract
monitoring is performed. Often in such cooperative
arrangements, Program operators fail to take into
account that “piggybacking” onto an awarded contract
without a provision for “piggybacking” in the original
solicitation may create a material change, thereby
requiring a new solicitation. Likewise, paying a fee
and becoming a member of a third-party vendor
that manages or buys products on behalf of the
cooperative, or Program operator, is not allowed
unless the services of a third-party vendor has been
competitively procured.

Program operators using the micro-purchase method
may not always purchase from only one source; rather,
purchases must regularly be made using available
qualified sources. This provides qualified sources the
opportunity for business or “spreading the wealth”.
For example, a purchase of computer paper valued
$1,000 qualifies as a micro-purchase. No competitive
price quotation is necessary for the purchase and no
cost or price analysis applies. However, the Program
operator’s written procurement procedures, as
required in 2 CFR Part 200.318(a), must include a
procedure that such purchases must be rotated among
qualified suppliers.

102

103

CHAPTER 7

Staff duties

and training

•

STAFF DUTIES

•

TRAINING

•

VOLUNTEER OPPORTUNITIES

•

Staff Duties

The size and type of a sponsor’s SFSP will dictate many of the sponsor’s staffing needs. Depending on a sponsor’s program,
many positions will require only part-time employment, particularly in the planning and close-out phases. Also, varied
opening and closing dates of individual site operations affect staffing needs. In every case, however, the sponsor must
provide adequate personnel for overall Program management and monitoring.
The following are examples of duties and responsibilities by position. Small programs may not need a different person
for the staff positions described. Sponsors needing more specific staffing guidance should consult with the State agency.

Director Responsibilities
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

•
•

Assistant Director Responsibilities

Annually attend State agency training
Provide overall management and supervise the SFSP
Select sites
Submit applications/agreements to State agency
Correspond with State agency
Coordinate with other agencies and conduct
outreach efforts
Hire, train, and supervise staff
Arrange for food preparation or delivery
Ensure that all monitoring requirements are met
Adjust meal orders
Submit reimbursement vouchers
Ensure civil rights compliance
Handle all negotiations with vendors for purchased meals
Coordinate and delegate outreach responsibilities
Ensure all program documents are maintained for
3 years plus the current year
Ensure site information with the State agency is current
and reflects the operation of each site including change in
meal service types, meal service times, and the average
number of children served (for meal cap)
Ensure site supervisors know how meals will be provided
(vended or self-prep delivered) and the menu
Ensure office and sites have "Justice For All" poster

•
•
•
•
•
•

Provide initial and ongoing training for sponsor
and site personnel
Design forms for recordkeeping purposes
Maintain liaison with vendor to adjust meal delivery
Check reimbursement vouchers
Maintain time and attendance records of staff
Maintain records on number of meals served

Assistant Director Responsibilities
•
•
•
•
•
•
•
•

•
•

Ensure area schools have access to outreach materials
Schedule monitors’ visits
Check monitors’ reports
Prepare weekly summaries of monitoring efforts
Provide ongoing training for monitors
Visit sites with monitors
Determine need for and following through on corrective action
Review the meal counts submitted by sites for unusual
meal count patterns, (e.g., first meals always or usually
equals meals delivered)
Oversee several monitors
Report site problems to the Director or Assistant Director

Bookkeeper Responsibilities
The bookkeeper should maintain records on the following:
•
•
•
•
•
•
•
•
•

105

Daily site reports, invoices, and bills
Food costs
Labor costs
Administrative costs
Other costs
Program income
Prepare reimbursement vouchers
Prepare payroll
Purchase office supplies

Monitor Responsibilities
Monitors are critical to the successful operation of SFSP
sites. They are the “eyes and ears,” providing valuable
feedback about how the sites are operating by visiting sites
on a regular basis and observing meal services.
To meet Program monitoring requirements, USDA
recommends no less than one monitor for every 15 to 20
sites in urban areas. The number of monitors necessary for
rural sites may increase depending upon the geographic
area to be covered. Monitors should:
•
•
•
•
•
•
•
•
•
•

Check on site operations to ensure that site personnel
maintain records
Ensure the Program operates in accordance with the
requirements
Visit all sites within the first week of food service operations
Review food service operations of all sites within the
first four weeks of operation
Prepare reports of visits and reviews
Report unresolved or critical issues to the Director
Revisit sites as necessary
Suggest corrective actions for problems encountered
Ensure that sites take corrective actions
Conduct on-site training as necessary

Site Supervisor Responsibilities
•
•
•
•
•
•
•
•
•
•
•
•
•

The monitor visits sites on a regular basis
and observes meal service operations.

•

See “Chapter 8: Program Integrity,”
for more information.

106

Attend sponsor training
Ensure civil rights is properly implemented
Stay at the site for the entire meal service
Inform Director or Assistant Director of field trips
Have communication with Director or Assistant Director
for changes in meal service
Serve meals
Clean up after meals
Ensure safe and sanitary conditions at the site
Ensure the safety of food, and comply with local health
and safety standards
Receive and account for delivered meals
Ensure that children eat all meals on site
Plan and organize daily site activities, including
nutrition education
Implement alternate food service arrangements during
inclement weather
Take accurate meal counts at point of service (unless an
alternate system that provides an accurate count has
been approved by the State agency)

Training

Training is one of the major administrative responsibilities of a sponsor. A smoothly operated
Program demands that sponsors provide training throughout the duration of the Program.
After a comprehensive training effort on Program requirements is complete, a weekly or bi-weekly meeting will help ensure
that monitoring, site, and administrative personnel are performing according to program regulations, that all meals will be
eligible for reimbursement, and that accurate and adequate records are available to document the costs and meals claimed.
Comprehensive training and coordination of efforts can also improve site quality and maximize the benefit received by
participating children.
To enhance this training effort, good communications (both internal and external) should be established with the State
agency, the school vendor or FSMC, the in-office staff members, the monitors, the site staff and the health officials/
inspectors. For example, meetings and telephone contacts with site and monitoring staff will provide opportunities to
ask questions, discuss site operations, and provide specific training on any problem area. In addition, discussions of
job descriptions and explanations about the organizational structure enable staff members to understand their own
responsibilities as well as those of their coworkers.

Sponsor Training Duties
(7 CFR 225.7(a) and 225.15(d)(1))

Sponsors are required to annually attend State agency training and must train all administrative staff
and site staff before they undertake their responsibilities.
Because these staffing groups have different program responsibilities, most sponsors will want to offer two different training
sessions to focus on each group’s specific functions. All staff should receive a letter or flyer announcing the date, time, location,
and importance of attending the training session that has been planned for their particular function. Sponsors should also
remind staff shortly before the date of the session. The date, names of attendees, and documentation of the topics covered
must be recorded for each training session offered. (See Attachment 15 for training checklists for administrative, monitor, and
site staff training sessions.) Sponsors that provide SFSP meals during emergency school closure situations (from October
through April or anytime of the year in an area with a continuous school calendar) may be exempted from attending the State
agency annual training prior to beginning operations.

Sponsor Training of Administrative Staff
(7 CFR 225.15(d)(1))

The training session offered for administrative staff will explain the responsibilities and duties of all sponsor personnel
helping to administer the SFSP at the sponsor level. These personnel include the office staff (assistants, clerks,
bookkeepers, and secretaries), area supervisors, and most importantly, monitors.
The specific training needs of sponsor administrative staff will vary. Specific areas of the training may require greater depth
with different employees. However, all training for administrative staff should cover the following topics and use the training
materials listed in the sample outline. This outline also is provided in the Reference Section as Attachment 15.
107

1

2

3

a general explanation of
the Program, emphasizing
the following topics:

how the Program will
operate within the
framework outlined in
this guide.

the specific duties of monitors.

PROVIDE

DESCRIBE

•

Purpose of the Program

•

Site eligibility

•

Recordkeeping
requirements

Use the menu schedule,
sample delivery receipts, and
sample daily reporting forms
for sites, including:

•

Organized site activity

•

How meals will be provided

•

Meal requirements

•

•

Nondiscrimination
compliance

The delivery schedule (if
applicable)

•

•

Outreach

What records are kept and
what forms are used

108

OUTLINE
Use monitor review form and
visit report and the mileage log,
including:
•

Conducting site visits/reviews

•

Sites for which they are
responsible

•

Monitoring schedule

•

Reporting procedure

•

Follow-up procedure

•

Office procedures

Sponsor Training of Monitor Personnel

Monitors should be present at both the site and administrative training to ensure a comprehensive
understanding of program operations at both levels.
The sponsor must provide monitors with thorough training because only those monitors knowledgeable in program
requirements and duties will be able to provide meaningful feedback to the sponsor. Since the monitoring function is so
important to proper program operations and full reimbursement, sponsors should conduct separate training sessions for
monitors that highlight their specific functions. This training should outline the specific duties of monitors including:
•

Sites for which they will be responsible

•

Conducting site visits/reviews

•

Monitoring schedules

•

Reporting/recordkeeping procedures

•

Follow-up procedures

•

Office procedures

•

Local sanitation and health laws

•

Civil rights

•

Reporting of racial/ethnic data

•

Considerations for personal safety, if necessary

This training outline may be found in Attachment 15. Materials to use include the site visit and review forms, monitor
mileage log, Monitor’s Guide, and ethnic/racial data form.

Sponsor Training of Site Staff
(7 CFR 225.15(d)(1))

SFSP regulations require that no food service site may operate until personnel at the site have
attended at least one of the sponsor’s training sessions. This is an annual requirement.
Sponsors must document the attendance at site training
sessions and schedule additional sessions for those staff
that are absent. Regulations also require that at least one
person who has been trained by the sponsor be present
at each of the sponsor’s sites during the time of the meal
service. This means that if a site supervisor who has
attended the sponsor’s training session resigns during the
summer, the sponsor is responsible for ensuring that the
new site supervisor receives all necessary training before
taking charge of the site.

A notice of the site training session should be sent to local
health inspectors so that they have the opportunity to attend
the training and become more familiar with the food service
operations. If any site receives meals through a FSMC or SFA
the company or school representatives should be invited
to attend the training and participate in the discussion of
menus and delivery schedules.

NOTE:
State agencies may waive this requirement for sponsors that provide program benefits during emergency
situations from October through April or at any time in an area with a continuous school calendar. Check with
your State Agency for additional guidance.

109

TRAINING TOPICS

At a minimum, sponsors should be certain that they cover the following topics in the training session for site personnel.
(See Attachment 15 for this training outline.)

1

PROVIDE

a general explanation of
the Program:
•

Purpose of the Program

•

Site eligibility

•

Necessity for accurate
records

•

Importance of organized
activities at sites

4

OUTLINE

the Monitor’s
responsibilities:
•

•
•

Use the Sponsor Monitoring
Handbook: http://www.fns.
usda.gov/sites/default/
files/MonitorsGuide.pdf
Duties and authority
Areas of assignment
and introduction to site
supervisors

2

DESCRIBE

how the site will operate:
For sites obtaining meals from
FSMCs/commercial meal vendors/
commercial meal vendors, SFAs, or
sponsor’s central kitchen:
•

Meal pattern requirements and
the meal service offered (use
planned menus)

3

EXPLAIN

recordkeeping
requirements:
•

Daily recordkeeping
requirements

•

Delivery receipts (sample
forms)

•

Seconds, leftovers, and
spoiled meals

•

Daily labor: actual time spent
on food service and time and
attendance records

•

Delivery schedules (exact times)

•

Adjustments in the delivery
amount

•

Facilities available for storing
meals

•

Collection of daily record
forms

•

Who to contact about problems
(provide sponsor’s name/
phone number)

•

Maintain copies of meal
service forms

•

Approved level of meal service
or “site cap.”

For sites where meals are prepared
on site

6

EXPLAIN

•

Meal pattern requirements

•

Inventory (use inventory forms)

•

Meal adjustments (use production
records)

Explain other miscellaneous
policy (use sponsor's
policy), such as:

•

Meal preparation adjustments

•

Problems of inclement
weather and alternate
service areas

•

Problems with unauthorized
adults eating Program meals

•

Problems with discipline

•

Review of equipment,
facilities, and materials
available for organized
recreational activities

•

Review of trash removal
system

•

Corrective action

•

Nutrition education

5

EXPLAIN

Civil Rights requirements:
Use the Site Supervisor’s Guide:
•

•

English: http://www.fns.
usda.gov/sites/default/files/
SiteSupervsGuide.pdf
Spanish: http://www.fns.usda.
gov/sites/default/files/spSiteSupervsGuide.pdf

110

Sponsor Training of Food Service Staff

All food service staff must be trained on Program operations and must understand:
•

The goals of SFSP

•

The meal pattern requirements

•

The importance of preparing nutritious meals
that meet the Dietary Guidelines for Americans

•

The food safety rules and sanitation guidelines

•

Operation of food service equipment

•

Development of and following standardized recipes

It is important for sponsors to have regular meetings with
food service staff to get input from them on an on-going
basis. During these meetings, encourage new ideas on how to
improve the current menu, food production, and food service
areas. Make sure to ask employees what they would like to
see to make their jobs better.

NOTE:

No site may operate until staff has attended a

SFSP operations training session.

Sponsors should contact the State SFSP administering agency
for training materials promoting nutrition education, food safety
information, recipes, and more. Video packages are available
for group training or self-study. You can also visit the Institute
of Child Nutrition’s website (http://www.theicn.org/) for many
more resources.

111

Volunteer
Opportunities
Volunteers provide a great support system for the Program. There are a number of services
volunteers can assist with, including:
Outreach

Meal Preparation

Volunteers can help with promotion by posting fliers in
their neighborhood, writing letters to their local newspaper
in support of the Program, and serving as “Summer Meal
Spokespeople” throughout their community. Sponsors
may direct outreach volunteers to the “Raise Awareness”
webpage on the FNS website: http://www.fns.usda.gov/sfsp/
raise-awareness.

Sponsors preparing their own meals can utilize volunteers
for meal preparation activities. Volunteer groups can also
provide free meals to the parents and guardians, who under
Program regulations are not eligible to receive meals. (See
“Chapter 5: Vending Options” for more information about
self-prep.)

Site Supervision
Trained volunteers can serve as site supervisors. See “Site
Supervisor Responsibilities” (above) for more information
about this role. The Site Supervisor Guide, available online,
provides a more detailed overview of this position: http://
www.fns.usda.gov/sites/default/files/SiteSupervsGuide.pdf
(English) and http://www.fns.usda.gov/sites/default/files/
SiteSupervsGuide.pdf (Spanish).

Site Activities
Volunteers can bring their unique expertise and interests
to the Program by providing site activities. Volunteers can
coordinate an art project, give a musical performance,
provide a nutrition lesson, read a story, or host an athletic
competition for the children. Site activities can be regular
(for example, every Friday could be “Music Day”) or a one­
time affair, depending on the volunteer’s preference.

ACCURATE POINT-OF-SERVICE COUNTS ARE CRITICAL!
It is critical that site personnel and monitors understand the importance of accurate point-of service meal
counts. Only complete meals served to eligible children can be claimed for reimbursement. Therefore, meals
must be counted at the actual point of service, i.e., meals are counted as they are served, to ensure that an
accurate count of meals served is obtained and reported. Counting meals at the point of service also allows
site personnel to ensure that only complete meals are served.

112

There are a number of places sponsors can look when searching for volunteers:
Local Employers

Senior Citizen Programs

Local businesses are always looking for ways to “give
back” to the community, and may be interested in sending
employees to a site to serve meals over the lunch hour.
Employers can “claim” one day each week as their own – for
example, the local bank can send staff members to their
neighborhood site every Tuesday.

Local senior organizations represent an excellent source
of committed volunteers. A number of senior volunteer
organizations exist across the country, including AARP’s

Internship Programs
Sponsors can create a “Summer Meals Internship”
opportunity to encourage high school or college students to
become involved. Internship opportunities, paid or unpaid,
can be a resume builder for students. Giving a young
volunteer an “official” title may also boost their commitment
level, providing children a reliable mentor they can count on
all summer long.

“Create the Good” (http://www.createthegood.org/) and Senior
Corps (http://www.nationalservice.gov/programs/senior­
corps). Sponsors interested in working with senior groups
may consider hosting an “Intergenerational Meals” site by
coordinating their Program with a senior meals program.

Volunteer Directories
Sponsors can post volunteer opportunities in local volunteer
directories, often available in print and online. Sponsors can
also share opportunities on national volunteer websites,
such as Volunteer.gov (https://www.volunteer.gov/), Idealist
(http://www.idealist.org/), or VolunteerMatch (http://www.
volunteermatch.org/).

Check out the Intergenerational Meals Model Toolkit page for more!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Intergenerational_Model.pdf

113

CHAPTER 7

Questions
and answers
1
WHAT SHOULD A SPONSOR CONSIDER
WHEN DECIDING THEIR STAFFING NEEDS?

It is very important for the sponsor to provide adequate
personnel for overall Program management and
monitoring in order to fully comply with Program
requirements. Depending on a sponsor’s Program,
many positions will require only part-time employment,
particularly in the planning and closeout phases. The
need for recordkeeping personnel varies according
to the size of the Program. To meet monitoring
requirements, USDA recommends one monitor for
every 15 to 20 sites in urban areas. The number of
monitors necessary for rural sites may increase
depending upon the geographic area to be covered.
Also, varied opening and closing dates of individual
sites may affect staffing needs. In every case the
sponsor must provide adequate personnel for overall
Program management and monitoring.

2

I HAVE TO HIRE STAFF TO OPERATE
THE KITCHEN. WHAT ARE SOME OF
THE THINGS I HAVE TO TAKE INTO
CONSIDERATION?
Before you hire your meal service staff, you will have
to first determine the number and the type of meals
you will be serving and consider the budget amount
you will have at your disposal. From there, you can
determine how many staff you need to hire. Take into
consideration their experience, and don’t be afraid
to utilize qualified volunteers in your operations.
Also make sure they meet health standards outlined
by your local and State authorities. Once you have
selected your food service employees, ensure they

understand, at a minimum, the goals of the SFSP, the
meal pattern requirements, the importance of serving
meals that meet the Dietary Guidelines, and food
safety and sanitation rules. You can contact your State
administering agency for training resources.

3

ONCE A SPONSOR IS APPROVED TO
OPERATE THE PROGRAM, WHAT ARE
THEIR TRAINING RESPONSIBILITIES?

4

ARE UNPAID STAFF OR VOLUNTEERS
ALSO REQUIRED TO BE TRAINED?

Training is one of the sponsor’s major administrative
responsibilities. A smoothly operating Program
will require that training be provided by sponsors
throughout the duration of the summer. A
comprehensive training effort, including weekly
or biweekly meetings on Program requirements,
will help to make certain that the monitor, site, and
administrative personnel are performing according
to USDA regulations. Sponsors should attend
State agency training and then train both their
administrative and site personnel before these staff
members undertake their responsibilities. SFSP
regulations require that no food service site may
operate until personnel at the site have attended at
least one of the sponsor’s training sessions. This is an
annual requirement.

Yes; training should be commensurate with the type
of activities the volunteers will be participating in.

114

115

CHAPTER 8

Program

Integrity

•

MONITORING SITES

•

ADMINISTRATIVE REVIEWS OF SPONSORS

•

CIVIL RIGHTS REQUIREMENTS

•

Monitoring
Sites
Monitoring is essential to making a Program successful. Having knowledgeable trained monitors will
enable Program operations to comply with Program requirements and run more smoothly.
Having an efficient and capable monitoring staff is one of
the first steps towards successful operations. A monitor
serves as a direct link between the sponsor’s administrative
office and the actual food service sites. Establishing a
proper monitoring system will help prevent problems from
occurring and will make it easier to correct any problems
that arise during the summer. The size of the monitoring
staff will, of course, depend on the size of the sponsor’s
Program. This is discussed in greater detail in "Chapter 7 –
Staff Training and Duties."

Visits and Reviews
Monitors are required to perform site visits and site
reviews at various times throughout program operations.
These are further discussed in the Sponsor Monitor’s
Guide, which provides more detailed information on
sponsor monitoring requirements and sample forms.
These reviews are an important part of the State agency’s
responsibility to ensure the integrity of the Program. Site
visits and reviews are defined as:
•

Site Visit:
Requires monitor to ensure that the food service is
operating smoothly and that any apparent problems are
immediately resolved.

•

Site Reviews:
Requires monitor to determine if the site is meeting
all the various Program requirements. Monitor must
observe a complete meal service from beginning to end,
including delivery or preparation of meals, the meal
service, and clean up after meals.

The sponsor must ensure that the monitor’s responsibilities
and authority are clear to the monitoring staff, site
supervisors, and office personnel. Monitors must:
•

Participate in annual training, understand Program
requirements, including civil rights requirements

•

Ensure that sites operate according to Program
guidelines

•

Carry a supply of all necessary forms during site visits
and reviews

•

Provide training for site personnel when needed

•

Spend enough time at each site to ensure proper
Program operations

Refer to the Sponsor Monitor’s Guide for detailed information on sponsor monitoring requirements and sample forms.

117

Sponsor Monitoring Requirements
(7 CFR 225.14(c)(6) and 225.15(d)(2) and (3))

Sponsors must ensure that the following minimum monitoring requirements are met:
Pre-operational Visits

Check with your state agency for additional guidance.

7 CFR 225.15(d)

Prior to submitting a request for approval to the State
agency, sponsors must certify that all required sites (such
as new sites and sites with previous serious deficiencies)
have been visited and have the capability and the facilities to
provide the meal service planned for the number of children
anticipated to be served.

Site Visits
7 CFR 225.15(d) (2) and (3)

Sponsors must visit each site at least once during the
first week of operation. However, the first week site visit
requirement is waived for returning sites that operated
successfully during the previous summer (or other most
recent period of operation) and had no serious deficiency
findings. Sponsors of these sites are still required to
review the site within the first four weeks of operation
(SFSP Memorandum 12-2011: Waiver of Site Monitoring
Requirements in the Summer Food Service Program, April
5, 2011) http://www.fns.usda.gov/waiver-site-monitoring­
requirements-summer-food-service-program.

State Agencies have the authority to waive the requirement
that sponsors visit each site at least once during the first
week of Program operations [7 CFR 225.15(d)(2)] for
sponsors in good standing with the CACFP and NSLP (SFSP
Memorandum 06-2014: Available Flexibilities for CACFP
At-Risk Sponsors and Centers Transitioning to Summer Food
Service Program (SFSP), November 12, 2013) http://www.
fns.usda.gov/available-flexibilities-cacfp-risk-sponsors-and­
centers-transitioning-summer-food-service-program.

Site Reviews
7 CFR 225.15(d)(3)

Sponsors must conduct a review of the food service at least
once in the first four weeks of Program operations. If a site
operates less than four weeks, the sponsor must still conduct
a review. After this initial period, sponsors must conduct a
“reasonable” level of monitoring.

118

Monitoring Reports

All visits and reviews must be documented. Records of
visits and reviews will help sponsors assess the operation
of sites. Records are only useful, however, when they are
carefully reviewed by sponsor personnel and when follow-up
monitoring is scheduled to ensure that any corrective actions
have been taken to improve site operations.
Each sponsor must, therefore, design a tracking system for
handling monitor reports. Sponsors should have a system
that will ensure that monitors return reports frequently –
if possible every day. The reports should be immediately

reviewed by a specific member of the sponsor’s staff who
is responsible for following up on any problems. The staff
member should:
•

Review any problems found by the monitor

•

Call the site supervisor, if necessary

•

Document corrective action taken at the site

•

Schedule a follow-up review, if necessary

•

Sign and date the report

The sponsor review official should base the timing of a
follow-up review on the severity of the problem.

NOTE:
Sponsors must maintain all records for three years after the end of the fiscal year of operation, or longer if
required by the State agency. These records must be accessible to Federal and State agency personnel for audit
and review purposes. For more information, see "Chapter 10: Recordkeeping."
(7 CFR 225.8(a))

Reviewing Monitor Reports
When sponsors or their staff review monitor reports, they
also should pay attention to the quality of the reports. There
are several indicators that may be apparent in the monitors’
reports that may suggest the monitor’s lack of program
knowledge or the monitor’s misunderstanding of his or her
responsibilities. Additional training would be appropriate if
the monitor:

•

Recommends a corrective action and fails to note
the action taken or fails to initiate correction of the
problem(s)

•

Fails to recommend adjustments in orders when the
number of meals exceeds attendance

•

Arrives at sites late and/or does not stay for the entire
meal service

•

Did not answer all questions on the report, or if the
responses are incomplete

•

Rarely notes problems and does not include comments
in the remarks section of the report

•

Observes that the number of meals delivered and/
or served and the number of children who are in
attendance are always the same and yet does not
follow-up on this suspicious pattern to see if meal
counts are being taken appropriately

Sponsors must be sure that monitors schedule visits and
reviews so that they can meet the Program requirements.
A good monitoring schedule and an efficient system for the
review and follow-up on the monitor’s reports are necessary
for effective Program operations.

119

Administrative
Reviews of
Sponsors
BY THE STATE AGENCY
(7 CFR 225.7(d)(2))

During the summer, State agencies will complete an
administrative review of most sponsors’ Program
operations. This administrative review will involve visits
by State agency personnel to the sponsor’s site(s) and
office. The reviews are designed to ensure that a sponsor’s
overall program is operating according to requirements
and to provide technical assistance to a sponsor if there are
questions about Program operations.

Violations

A State agency review of site operations should
involve observing the meal service operations and the
recordkeeping at the site. A review at the sponsor level
should involve a review of the records maintained by the
sponsor. All sponsors must make their records available
for the State agency’s review and must implement all
corrective actions recommended by the State agency. The
results of a State agency review may affect the amount of
reimbursement a sponsor receives.

When the State agency finds violations during a site review,
it will require the sponsor to correct the problems found. If
the State agency finds a high level of meal service violations
at a site, it will immediately require the sponsor to follow a
specific corrective action plan. The State agency will initiate
a follow-up system to ensure that sponsors take the specific
action (as outlined in the plan) for correcting site violations.

(7 CFR 225.11(c)(1-4))

Violations of Program requirements may result in withholding
or recovery of reimbursements, corrective action, or
termination and exclusion from future Program participation.

Corrective Action Plan
(7 CFR 225.11(f))

120

PROGRAM VIOLATIONS

INCLUDE BUT ARE NOT LIMITED TO:

•

Failure to maintain adequate site or sponsor records.

•

Failure to report sites to health department.

•

Failure to adjust meal orders to conform to changes in
site attendance.

•

Continued use of FSMCs/commercial meal vendor that

violate health codes.

•

Failure to have a trained site supervisor at each site
during the meal service.

•

Submission of false information to the State agency.

•

Use of Program funds for unallowable costs.

•

Serving more than one meal to a child at one time.

•

•

Children eating complete meals off-site (Note: This does
not refer to the permissible practice of allowing children
to take a fruit, vegetable, or grain component off-site.)

Failure to return excess start-up or advance payments to

the State agency.

•

Not adhering to competitive bid procedures.

•

Noncompliance with civil rights laws and regulations.

•

Failure to count meals at point of service.

•

Meal count consolidation errors.

•

Failure to meet training on monitoring requirements.

•

Claiming meals that were not served to eligible children.

•

Serving meals (or in the case of OVS sites, offering meals)
that do not include all required meal components and/or
correct quantities.

Civil Rights
Requirements
(7 CFR 225.7(g) and FNS Instruction 113-1)

All participating sponsors must inform potential participants
of the availability of the SFSP. In addition, all sponsors and
their sites are required to:
• Display in a prominent place at the site and in the
sponsor’s office, the “And Justice for All” poster
developed by USDA or approved by FNS
•

Make Program information available to the public
upon request

•

Take reasonable steps to ensure meaningful access
to services for limited English proficient persons by
providing information in the frequently encountered, nonEnglish languages of individuals eligible to be served or
likely to be affected by the program

•

•

Make reasonable modifications in policies and
procedures to ensure individuals with disabilities
have equal access and effective communication when
accessing the Program

•

Include the nondiscrimination statement, and instructions
for filing a complaint, in their public release and in any
Program information directed to parents of participants
and potential participants

•

Ensure that meals are served to all attending children,
regardless of their race, color, national origin, sex, age,
or disability

•

Ensure that all children have equal access to services
and facilities at the site regardless of race, color, national
origin, sex, age or disability

Ensure that translations are accurate concerning the
availability and nutritional benefits of the Program

121

Race and Ethnic Data
Each year, every sponsor must determine the number of potentially eligible participants by racial/
ethnic category for the area served. This information may be obtained from census data or public
school enrollment data.
b. Asian
A person having origins in any of the original peoples of
the Far East, Southeast Asia, or the Indian subcontinent,
including, for example, Cambodia, China, India, Japan,
Korea, Malaysia, Pakistan, the Philippine Islands,
Thailand, and Vietnam.

The sponsor also must collect ethnic/racial category data
each year by ethnic/racial category for each site under the
sponsor’s jurisdiction. Sponsors of residential camps must
collect and maintain this information separately for each
session of the camp. For all other sites, the sponsor must
count the participating children at least once during the
site’s operation. The sponsor may use visual identification
to determine a participant’s racial/ethnic category. For
collection purposes, a participant may be included in the
group to which he or she appears to belong, identifies with,
or is regarded as a member of by the community.

c. Black or African American
A person having origins in any of the black racial groups
of Africa.
d. Native Hawaiian or Other Pacific Islander
A person having origins in any of the original peoples of
Hawaii, Guam, Samoa, or other Pacific Islands.

To provide flexibility and ensure data accuracy, separate
categories must be used when collecting and reporting
race and ethnicity. Ethnicity must be collected first.
Respondents must be offered the option of selecting one or
more racial designations.

e. White
A person having origins in any of the original peoples of
Europe, the Middle East, or North Africa.

The minimum designations for collection are:

Ethnicity:
a.

Hispanic or Latino
A person of Cuban, Mexican, Puerto Rican, South or
Central American, or other Spanish culture or origin,
regardless of race. The term “Spanish origin” can be
used in addition to “Hispanic or Latino.”

b.

Not Hispanic or Latino

The sponsor must retain data, as well as documentation
for the data, for the required three years. The sponsor must
use safeguards to prevent the data from being used for
discriminatory purposes. Such safeguards include allowing
access to program records containing this data only by
authorized personnel. A sample Race and Ethnic Category Data
Form is shown as Attachment 21 in the Reference Section.

Race:
a.

American Indian or Alaska Native
A person having origins in any of the original peoples of
North and South America (including Central America), and
who maintains tribal affiliation or community attachment.

122

Disability Accommodations

The general guideline in making accommodations for children with disabilities is to ensure children
with disabilities are able to participate in and receive benefits from programs that are available to
children without disabilities.
Under Federal statute and Program regulations sponsors
are required to provide reasonable accommodations for
children whose disability restricts their diet when supported
by a medical statement that includes recommended
alternate foods and is signed by a licensed physician
or a health care professional who is authorized to write
medical prescriptions under State law (FNS Instruction
783-2, Rev. 2, Meal Substitutions for Medical or Other Special
Dietary Reasons; SFSP 15-2015: Statements Supporting
Accommodations for Children with Disabilities in the Child
Nutrition Programs, March 30, 2015). http://www.fns.usda.
gov/available-flexibilities-cacfp-risk-sponsors-and-centers­
transitioning-summer-food-service-program. The definition
of a “reasonable accommodation” is found in section 15b.13
of USDA’s Nondiscrimination in Programs or Activities
Receiving Federal Financial Assistance.

Food Allergies In Schools and Early Care and Education
Programs,” a joint report from the Department of Health &
Human Services and the Centers for Disease Control and
Prevention: http://www.cdc.gov/healthyyouth/foodallergies/
pdf/13_243135_A_Food_Allergy_Web_508.pdf.
Sponsors must take appropriate steps to ensure that
communication with people with disabilities is as equally
effective as communication with people without disabilities.
Sponsors must also provide auxiliary aids and services
when needed to communicate effectively with people who
have communication disabilities. http://www.ada.gov/
effective-comm.htm

Additionally, sponsors may make substitutions in the meal
patterns due to a non-disability medical or special dietary
need. Such substitutions may only be made when supported
by a medical statement signed by a recognized medical
authority that includes recommended alternate foods.
Meal accommodations for non-disability medical or special
dietary needs must be within the meal pattern requirements
in order to be reimbursable.
In most cases, meal accommodations for children with
a disability or non-disability medical or special dietary
needs can be met by following the recommended alternate
food substitutions included on the medical statement. For
additional information on accommodating food allergies,
sponsors may refer to “Voluntary Guidelines for Managing

123

CHAPTER 8

Questions
and answers
1

WHAT ARE THE SPONSOR’S MONITORING
REQUIREMENTS FOR THE SFSP?

be served or likely to be affected by the program.
Ensure translations are accurate, and include the
nondiscrimination statement and instructions
for filing a complaint on all materials directed to
participants and their families. Sponsors also must
take appropriate steps to ensure that communication
with people with these disabilities is as equally
effective as communication with people without
disabilities. In addition, sponsors must ensure meals
are served to all attending children regardless of
race, color, national origin, sex, age or disability, and
make sure all children have equal access to services
and facilities. All sponsors must collect beneficiary
data each year by racial/ethnic category for each site
under the sponsor’s jurisdiction. The sponsor must
count the participating children at least once during
the site’s operation.

An efficient and capable monitoring staff is essential to
the success of any sponsor’s program. Monitors must
ensure that the site operates the Program according
to Program guidelines. This requires a pre-operational
visit, which is conducted before a site operates the
SFSP. These visits are required for all sites to determine
that the sites have the facilities to provide meal service
for the anticipated number of children in attendance.
Also, a sponsor must visit all new sites and sites that
experienced operational problems the previous year at
least once during the first week of operation to make
sure the food service operation is running smoothly
and to verify information such as the site address,
storage, holding and preparation facilities, and serving
capabilities. Further, sponsors must conduct site reviews
of all sites at least once during the first four weeks of
program operations to observe delivery or preparation of
meals, service of meals, children eating the meals, and
clean up after meals.

2

3

WILL THE SPONSOR’S PROGRAM BE
REVIEWED BY THE STATE AGENCY?

Sponsors will receive a periodic administrative review
by the State agency or FNS Regional office staff during
the course of operations, which will include a review of
the office and at least one site. Sponsors must make
records available for the State agency reviewer and
must take any corrective actions required by the State
agency. Results of an administrative review may affect
the amount of reimbursement a Program will receive.
The review may involve assessing how the claim for
reimbursement is prepared and looking at the records
maintained by the organization. It will also include a look
at site operations to observe the meal service operation
and recordkeeping.

WHAT ARE THE SPONSOR’S CIVIL
RIGHTS REQUIREMENTS?

All participating sponsors must inform potential
beneficiaries, particularly minorities, of the
availability of the SFSP. Sponsors are required
to display the “And Justice for All” poster in a
prominent place at the site and the sponsor’s office.
Also sponsors need to make Program information
available to the public, take reasonable steps to
provide information in appropriate languages other
than English based on the frequently encountered,
non-English languages of individuals eligible to

124

125

CHAPTER 9

Program
Costs and
Reimbursements
•

ADVANCE PAYMENTS

•

PROGRAM REIMBURSEMENTS

•

OTHER SOURCES OF PROGRAM INCOME

•

UNALLOWABLE COSTS

•

NON-REIMBURSEABLE MEALS

•

NON-CONTRACTIBLE MANAGEMENT RESPONSIBILITIES

Advance
Payments
(7 CFR 225.9(c))

When sponsors apply for the Program, they may request advance payments for their total Program
costs, for their operating costs, or for their administrative costs.
Although sponsors are no longer required to categorize
costs as operational or administrative when submitting
claims for reimbursement, advance payments are still
categorized as such. Therefore, sponsors may not request
an advance for operating and administrative costs
combined, but must make these requests separately.
When determining the amount of the advance payment, the
State agency will make the best possible estimate based
on the sponsor’s request and any other available data.
These payments are advances on the reimbursement that
sponsors will receive for a month of operations and will
be deducted from future reimbursement payments. The
advances should help sponsors maintain a positive cash
flow because they will have funds available to meet program
costs as they arise throughout the month.
Sponsors can refer to SFSP Memorandum 11-2015:
Assessing Costs in the Summer Food Service Program,
February 25, 2015 for more information. The memo also
includes a tip sheet sponsors may use when budgeting for
their Program: http://www.fns.usda.gov/assessing-costs­
summer-food-service-program.

Also refer to SFSP memorandum 08-2016: Summer Food
Service Program Question and Answers November 12, 2015
for more information. http://www.fns.usda.gov/summer­
food-service-program-questions-and-answers.

Advances for Operating Costs
(7 CFR 225.9(c)(1))

Sponsors must request each advance payment for operating
costs from the State agency at least 30 days before the
payment dates of June 1, July 15, and August 15. If sponsors
participated in the previous year’s Program, the advance
payments for operating costs usually will be based on
the reimbursement they earned during the same month
of the previous year. The State agency also may estimate
advance payments as a percentage of anticipated costs.
The State agency must receive certification that a sponsor
(except for school sponsors) has held training sessions
on program requirements for site and sponsor personnel
before it will release the second month’s operating advance
to the sponsor. A sponsor may not receive an advance for
operating costs in any month when it will not be operating
for at least 10 days.

127

Advances for Administrative Costs

Start-up Payments

(7 CFR 225.9(c)(2))

(7 CFR 225.2 definitions and 225.9(a))

Sponsors must request each advance payment for
administrative costs from the State agency at least 30 days
before the payment dates of June 1 and July 15. If sponsors
operate the Program less than 10 days in June but at least
10 days in August, they will be issued the second month’s
payment for advance administrative costs on August 15.
Sponsors planning to operate the Program for less than 10
days cannot receive advance payments for administrative
costs. State agencies may adjust the amount of advances
based on monitoring or audits. Finally, per 225.9(c), State
agencies are required to offer advances to all SFSP
sponsors requesting advances. If the State agency has
reason to deny the request, they must offer the institution
appeal rights (225.13(a)).

The State agency may, at its discretion, provide the sponsor
with a limited amount of start-up payments (up to a maximum
of 20 percent of the sponsor’s approved administrative
budget). These start-up payments, which are deducted from
later administrative reimbursements, are for administrative
costs incurred in planning a food service and in establishing
effective management procedures for that service. Sponsors
may request the start-up payments if they are available, when
they apply for the Program. If approved, the start-up payments
may not be provided any earlier than two months before food
operations begin (SFSP Memorandum 7-2014: Expanding
Awareness and Access to Summer Meals, November 12, 2013).
http://www.fns.usda.gov/expanding-awareness-and-access­
summer-meals.

Check out 'The No Kid Hungry Summer Meals Calculator'.
This tool, developed and made available to sponsors at no cost by Share Our Strength,

a national anti-hunger organization, walks through the entire budget planning process to develop a proposed

budget. This includes considering resources and costs associated with the Program, and looks at scenarios for

different levels of service. The tool accounts for elements of a Summer Meal Program broadly, including those

necessary for a successful mobile meals model.

To download the tool, visit:
https://bestpractices.nokidhungry.org/sites/default/files/resources/nkh_summer_meals_calculator_for_2016.xlsx

128

Program
Reimbursements
(7 CFR 225.9(d))

Reimbursements are based on the number of reimbursable meals served multiplied by the sum of
administrative and operational rates. Sponsors must maintain complete records to document all
costs and meals they claim for reimbursement. Sponsors are not eligible for reimbursement unless
they have signed an agreement with the State agency. (The necessary records are discussed in
“Chapter 10: Recordkeeping” of this guide.)
Allowable Operating Costs

Allowable Administrative Costs

(7 CFR 225.2 definitions and FNS Instruction 796-4, Rev. 4)

(7 CFR 225.2 definitions and FNS Instruction 796-4, Rev. 4)

Reimbursements may be used to cover allowable operating
costs that include, but are not limited to, the cost of food
used, nonfood supplies, and space for the food service.
Cost incurred by the sponsor for rental of food service
preparation faclilites are allowable.

Reimbursements may be used to cover allowable
administrative costs incurred by your organization for
activities related to planning, organizing, and administering
the Program.

Check out the Cost Assessments Toolkit page to learn more!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Assessing_Costs.pdf

Claim for Reimbursement
Sponsors receive their Program payments based on the number of meals served multiplied by the
appropriate combined administrative and operating rates for reimbursement.
Sponsors assume complete responsibility for all of
the information they submit on their claims. Claims for
reimbursement must reflect only meals that meet SFSP
requirements and are actually served to eligible children
during the claiming period (SFSP Memorandum, January 2,
2008; Nationwide Expansion of Summer Food Service Program
Simplified Cost Accounting Procedures). http://www.fns.usda.
gov/nationwide-expansion-summer-food-service-program­
simplified-cost-accounting-procedures.

Based on records that are regularly submitted by the sites,
sponsors must report the number and type of first and
second meals served to all children; sponsors of camps need
to report the meals served to eligible children only. The total
number of second meals claimed cannot exceed two percent
of the number of first meals, for each type of meal served
during the claiming period. State agencies can provide further
guidance on serving second meals and on those situations
where second meals will not be reimbursed. A sample
Consolidation Form for 1st and 2nd Meals is included as
Attachment 20.

129

regulatory requirements (SFSP Memorandum 07-2007:
Electronic Record and Reporting Systems, June 15, 2007).
(http://www.fns.usda.gov/electronic-record-and-reporting­
systems-1)

Sponsors must maintain records of all operating and
administrative costs, as well as any Program income
received. These records must be available for review by
the State agency.
After the reimbursement claim form is completed, a sponsor
must sign the form and send it to the State agency as soon
as possible within the month following the month covered
by the claim. Claims will not be paid if they are submitted
more than 60 days after the last day of the month covered
by the claim unless an exception is granted by FNS. The
State agency may impose a shorter deadline for submission
of the claim within the 60-day requirement. Revised claims
that reflect a change in reimbursement amount must be
submitted within 60 days, unless the revision is a downward
adjustment. All claims submitted by sponsor after 60 days
that would generate a payment for reimbursement (an
upward adjustment) must follow the late claim policy in
which the State agency may grant an exception once every
36 months.
State agencies may establish additional Program
requirements, which are reviewed and approved by the
appropriate FNS Regional office (SFSP Memorandum 06­
2013: Additional State Requirements in the SFSP REVISED,
January 24, 2013). (http://www.fns.usda.gov/additional­
state-agency-requirements-summer-food-service-program.)
Sponsors can check with their State agency to see if there are
additional, State-level requirements.

State agencies may allow sponsors to consolidate
claims as follows:
(7 CFR 225.9(d)(3)):

•

10 days or less in their initial month of operation
combined with the claim for the subsequent month; or

•

Up to three consecutive months may be combined, as
long as the combined claim only includes 10 days or less
from the first and last month of Program operations (i.e.,
a total of 20 extra days).

If a sponsor operates for less than 10 days in the final month,
it may combine the claim from the last operating days with
the claim for the previous month. This combined claim must
be submitted to the State agency within 60 days of the last
day of operation (SFSP Memorandum; Authority for Sponsors
to Combine Claims for Reimbursement, May 15, 2000). (http://
www.fns.usda.gov/sfsp-051500.)

Sponsors are encouraged to streamline recordkeeping and
reporting systems by establishing an Internet or electronicbased system, including but not limited to application
submissions and claims processing. However, any electronic
system must include a means to fully access Program
benefits without Internet or computer access and must not
create a barrier to participation. Otherwise, an individual
might be denied access to Program benefits.
In cases where participating institutions are unable or
unwilling to implement electronic based systems, it may not
be reasonable to expect that a State agency will be able to
provide the same level of service that users of electronic
systems receive. Regardless, States must still meet all

130

$

Other Sources of

Program Income

Funds accruing to the food service include all funds received from Federal, State, local, and other sources,
except program advances, start-up funds, or reimbursement payments received from the State agency.
Sources of funds that are considered program income include:

•

Cash donations specifically identified for use
in the Program

•

Any Federal, State or local funds specifically provided
to the Program

These funds must be designated specifically for the SFSP. Records
reflecting income may include:

•

Deposit records

•

Voucher stubs

•

Receipts

Any reimbursements or funds that exceed a sponsor’s
expenditures must be used in a way that benefits SFSP
services to children or other Child Nutrition Programs operated
by the sponsor. Sponsors with funds remaining at the end of
the Program year should use them as start-up funds or for
improving SFSP services in the following year. Sponsors may
not transfer excess funds to operations that are not related to
the Child Nutrition Programs or to increase salary or fringe
benefit costs when the sole purpose of the increase is to reduce
the food service program balance. If the sponsor will not be
participating in SFSP the next year, funds may be used towards
the sponsor’s provision of other Child Nutrition Programs. If the
sponsor does not operate any other Child Nutrition Programs,
the State will collect the excess funds.

Check out the Sources of Additional Funding to learn more!
http://www.fns.usda.gov/sites/default/files/cnd/SMT-SourcesofAdditionalFunding.pdf

131

Unallowable
Costs
(FNS Instruction 796-4, Rev. 4)

Unallowable costs are costs for which Program funds may not be used. They include, but are
not limited to:
•

Costs for excess meals ordered or prepared but not served to eligible children, i.e., meals in excess of
legitimate Program adult meals and reimbursable meals, unless specifically approved by the State agency

•

Meals served in violation of Program requirements; e.g. additional foods served that are not compliant with the
meal patterns, meals or ineligible components consumed off-site or second meals served in excess of the 2
percent tolerance

•

Rental costs for periods beyond the close-out date for Program operation

•

Any other costs incurred that Program officials determine to be in violation of applicable laws or regulations;

•

The cost to purchase food (including coffee, etc.) for use outside of the SFSP

•

The cost of meals served to administrative adult personnel, or any other adults that are not in the operation of
the food service

•

Cost of spoiled or damaged meals

•

For vended sponsors, the cost of meals delivered by a FSMC to a non-approved site, or for meals not delivered
within the agreed upon delivery time, meals served in excess of the approved cap (SFSP Memorandum 162015: Site Caps in the Summer Food Service Program: Revised, April 21, 2015, http://www.fns.usda.gov/sitecaps-summer-food-service-program-revised) spoiled or unwholesome meals, or meals that do not meet meal
requirements or quality standards

•

Bad debts, which are any losses arising from non-collectible accounts and other claims and related costs

•

Repayment of over-claims and other Federal debts

•

Contributions and donations including contingency reserves, USDA-donated commodities and other donated
food, labor, and supplies

•

Fines or penalties resulting from violations of, or failure to comply with Federal, State, or local laws and regulations

•

Entertainment and fundraising costs

•

Interest on loans, bond discounts, costs of financing and refinancing operations, and legal and professional
fees paid in connection therewith

•

Costs resulting from an under-recovery of costs under other grant agreements

•

Direct capital expenditures or option to purchase rental costs for: acquisition of land or any interest in land;
acquisition or construction of buildings or facilities, or the alteration of existing buildings or facilities; nonexpendable equipment of any kind; repairs that materially increase the value or useful life of buildings,
facilities, or non-expendable equipment; and other capital assets, including vehicles

Check out the Budgeting for Success Toolkit page for tips on controlling your expenses!
http://www.fns.usda.gov/sites/default/files/sfsp/SMT-Budgets.pdf

132

NonReimbursable
Meals
Sponsors may claim reimbursement only for those meals that meet SFSP requirements.
Reimbursement may not be claimed for:
•

Meals not served as a complete unit (except in “OVS” sites where complete meals must be offered to
participants)

•

Meal patterns or types not approved by State agencies

•

Meals served at sites not approved by State agencies

•

Meals consumed off-site , except for field trips for which the State agency was notified in advance
(this does not include a fruit, vegetable, or grain component that the State agency and sponsor may
allow to be taken off-site)

•

More than one meal served to a child at a time

•

Second meals in excess of 2 percent of the number of first meals served by type during the
claiming period

•

Meals served outside of approved timeframes or approved dates of operation

•

Meals served to ineligible children in camps (those not meeting the income eligibility guidelines
for free or reduced-price school meals)

•

Meals that are spoiled or damaged

•

Meals in excess of the site’s approved level of meal service (cap for vended sponsors) (SFSP
Memorandum 16-2015: Site Caps in the Summer Food Service Program: Revised, April 21, 2015,
http://www.fns.usda.gov/site-caps-summer-food-service-program-revised)

•

Meals missing/inadequate component

•

Meals over the cap

•

Meals served to adults but included in count of reimbursable meals

•

Meals that were not served

•

Meals served to anyone other than eligible children

133

NonContractible
Management
Responsibilities
(7 CFR 225.15 (a)(3))

Sponsors may NOT contract out management
responsibilities of the Program, including but not limited to
the following tasks:
• Meal ordering
•

Assuming official recordkeeping responsibilities,
including meal count information to substantiate claims

•

Submitting claims

•

Training and monitoring administrative and site staff

•

Announcing availability of meals to the news media

•

Determining income eligibility and maintaining
individual income eligibility statements

Sponsors should check with the State agency before
allowing a FSMC to undertake any other tasks that may be
considered management functions or any tasks that are
related to the bulleted items listed above.

NOTE:
FNS Instruction 796-4, Rev. 4, Financial Management
http://www.fns.usda.gov/sites/default/files/796-4.pdf

Summer Food Service Program for Children, provides information on establishing standards,
principles and guidelines in the development and maintenance of financial management systems.
The State agency can provide this information.

134

CHAPTER 9

Questions
and answers
1
CAN A SPONSOR REQUEST AN ADVANCE
PAYMENT FROM THE STATE AGENCY?

Yes. When sponsors apply for the Program they
may request advance payments to assist in meeting
operation and administrative expenses. These
payments will be advances on the reimbursement
received for a month of operation and will be deducted
from future reimbursement payments. The advances
help maintain a positive cash flow by making funds
available to meet program costs as they arise
throughout the month

2

IS THE SPONSOR REQUIRED TO
INFORM THE STATE AGENCY HOW
MUCH OF AN ADVANCEMENT
THEY WANT AND THE PURPOSE? OR CAN
A SPONSOR SIMPLY CHECK A BOX THAT
INDICATES YES, THEY WANT A JUNE
ADVANCE OR A JULY ADVANCE, AND THE
STATE AGENCY CALCULATES THE AMOUNT?

4

HOW DOES A SPONSOR RECEIVE
THEIR REIMBURSEMENT?

Reimbursement is based on the claims for
reimbursement that a sponsor submits to their State
agency. Claims for reimbursement reflect meals that
meet SFSP requirements and are served to eligible
children during the claiming period. Claims must be
submitted to the State agency within 60 days after the
last day of the operating month, unless the State has
established an earlier deadline.

Yes, the sponsor must specify the amount. The State
agency will determine if and how much of the amount
requested will or will not be granted.

3

The reimbursement is intended to help cover the
administrative and operating costs of running the
SFSP. However, the reimbursements may not be
enough to cover all Program costs. The sponsor
is responsible for all costs incurred above the
amount reimbursed. More information about how
reimbursements are calculated may be found
at http://content.govdelivery.com/attachments/
USFNS/2016/01/13/file_attachments/473979/.

5

WILL A SPONSOR BE REIMBURSED
FOR ALL COSTS ASSOCIATED WITH
RUNNING THE SFSP?

DO SPONSORS HAVE TO SUBMIT
DOCUMENTATION OF THEIR COSTS
WHEN CLAIMING REIMBURSEMENT?

The SFSP simplified cost accounting procedures base
reimbursements on the number of meals served times
the reimbursement rate, without requiring a comparison
to actual or budgeted costs. Under this simplified
structure, sponsors are no longer required to submit
documentation of their costs to the State agency for
reimbursement. However, sponsors still must maintain
documentation indicating that their reimbursements were

The amount of reimbursement a sponsor receives
is an amount equal to the number of eligible meals
served to children, multiplied by the current combined
administrative and operating reimbursement rates.

135

5 CONtINUED
spent on allowable Child Nutrition Program costs. This
documentation must be available for State agency review
(SFSP Memorandum 03-2008: Simplified Procedures in
Summer Food Service Program, February 14, 2008, http://
www.fns.usda.gov/simplified-procedures-summer-foodservice-program).

activities for SFSP that are performed for NSLP.
The SFA, however, must maintain responsibility
for submitting claims and remains accountable
for ensuring all SFSP requirements are met (SFSP
Memorandum 4-2013: Summer Feeding Options for
School Food Authorities, November 23, 2012, http://
www.fns.usda.gov/summer-feeding-options-schoolfood-authorities).

6

8

HOW CAN SPONSORS WITHOUT
ACCESS TO AN ELECTRONIC
DOCUMENTATION SYSTEM SUBMIT
CLAIMS FOR REIMBURSEMENT?

IF SPONSORS DO NOT HAVE TO SUBMIT
DOCUMENTATION OF THEIR COSTS
WHEN CLAIMING REIMBURSEMENT,
WHY DO THEY STILL HAVE TO DOCUMENT MY
EXPENSES?
SFSP regulations require State agencies to disallow
any portion of a claim for reimbursement and recover
payments to a sponsor if the sponsor is unable to
document that the reimbursement was used for allowable
Child Nutrition Program costs. Therefore, if a sponsor
lacks required documentation (identified as a result of
an administrative review), the State agency must declare
the sponsor seriously deficient, require corrective action,
and recover the reimbursement (FNS Instruction 796-4,
Revision 4; 7 CFR 225.12(a)).

7

CAN SPONSORS CONTRACT OUT
ANY OF THEIR MANAGEMENT
RESPONSIBILITIES?

While electronic recordkeeping systems have been
helpful in streamlining Program administration,
FNS recognizes that it is important to ensure that
implementing an electronic system does not create a
barrier to participation. State agencies are encouraged
to establish electronic systems, but must also include a
means to fully access Program benefits without internet
or computer access. State agencies are required to
provide the same level of service to users of nonelectronic systems as those with electronic systems,
and must still meet all regulatory requirements (SFSP
Memorandum 07-2007: Electronic Record and Reporting
Systems, June 15, 2007, http://www.fns.usda.gov/
electronic-record-and-reporting-systems-1).

9

Sponsors may not contract out certain management
responsibilities of the SFSP such as monitoring,
staff training, enforcing corrective action, or
preparing Program applications and claims for
reimbursement. Sponsors remain legally responsible
for ensuring that the food service operation meets all
requirements specified in the agreement they sign
with the State agency.

DOES FNS HAVE OTHER RESOURCES
AVAILABLE TO HELP A SPONSOR
WITH COST ASSESSMENT?

Sponsors looking for additional cost assessment
resources should refer to SFSP Memorandum 112015: Assessing Costs in the Summer Food Service
Program, February 25, 2015, in addition to the FNS
Instruction 796-4, Rev. 4, Financial Management –
Summer Food Service Program for Children, http://
www.fns.usda.gov/assessing-costs-summer-foodservice-program. The memo includes a tip sheet that
sponsors can use when considering proposed uses of
the non-profit food service account funds for SFSPrelated costs. The memo and tip sheet can be found at
http://www.fns.usda.gov/assessing-costs-summerfood-service-program.

SFAs, however, may comply with the NSLP
requirements for contracting with FSMCs outlined in 7
CFR 210.16 in lieu of the SFSP requirements at 7 CFR
225.15(h)(4)(i)-(xii). SFAs that choose to contract with
FSMCs for some or all aspects of the management of
the NSLP may allow the FSMC to conduct the same

136

137

CHAPTER 10

Recordkeeping

•

ADMINISTRATIVE RECORDS

•

OPERATING COST RECORDS

•

MAINTAINING RECORDS OF COSTS AND TRACKING FUNDS

This chapter provides information on what records must be kept to justify claims for
reimbursements. There are a number of additional records sponsors must maintain in their files.
These records and the records discussed in this chapter are summarized in Attachment 22,
Checklist of Records.

Administrative
Records
Sponsors must keep full and accurate records so they can substantiate the number of Program
meals that they have submitted on each claim for reimbursement and that SFSP funds are used only
for allowable SFSP costs. Records must also be kept to confirm the sponsor is in good standing with
all Program requirements.
Meal Count Records

•

Complete second meals served to children, by type

(7 CFR 225.15(c))

•

Excess meals or meals leftover

All sponsors must use daily site records in order to
document the number of Program meals they have served
to children. The sponsor must provide all necessary record
sheets to the sites. Site supervisors are then responsible
for keeping the records each day. The site personnel must
complete the records based on actual counts taken at each
site for each meal service on each day of operation. Site
personnel must be sure that they record all required counts.
These counts should include the number of:

•

Non-reimbursable meals

•

Meals served to Program adults, if any

•

Meals served to non-Program adults, if any

•

•

Meals delivered or prepared, by type (breakfast,
snack, lunch, supper). A designated member of the
site staff must verify the adequacy and number of
meals delivered by checking the meals when they are
delivered to the site
•

Vended programs must support this information
with a signed delivery receipt

•

Programs with a central kitchen should also
support this information with a signed delivery
receipt for good Program management

Complete first meals served to children, by type

Sponsors should collect these site records at least every
week. They may have their monitors pick up site reports
on designated days, or the site supervisors may be asked
to mail the records to the sponsor’s office. When they
collect the site records, sponsors should check for the site
supervisor’s signature. Any sponsor serving vended meals
must be sure that the figure entered as the number of meals
delivered on the site record is the same as that entered on
the vendor’s report. If there is any discrepancy between
the numbers, the sponsor should immediately contact the
vendor and site supervisor and resolve the problem. The
sponsor should make a permanent note of the discrepancy
as well as the action that was taken to resolve it.
A sample Daily Meal Count Form is included in the Reference
Section as Attachment 18. A consolidated (weekly) meal
count form is included as Attachment 19.

139

Training Records

•

Site visits during the first week of Program operations

(7 CFR 225.9(c)(1))

•

Site visits throughout the summer

Sponsors must keep records that document:
•

Date(s) of training for site and administrative personnel

•

Attendance at each training session by having attendees
sign an attendance form

•

Topics covered at each training session

Site Review Records

Sponsors that have requested advance payments for
operating costs must send certification that they have
completed training for site and administrative personnel to
the State agency. Without this certification, the State agency
will not release the second advance payment for operating
costs to the sponsor. This requirement, however, does not
apply to school sponsors.

(7 CFR 225.15(d) (3))

Site Visit Records
(7 CFR 225.14 (c)(6) and 225.15 (d)(2) and (3))

Sponsors must be able to document that they have met their
monitoring requirements. Monitors must submit a report for:
•

A sample First Week Site Visit Form can be found in the
SFSP Sponsors Monitors Guide, available at http://www.fns.
usda.gov/sfsp/handbooks.

Monitors must submit a review report form for each
site review during the first four weeks of Program
operations, and for site reviews throughout the duration
of the Program. This form will contain much of the same
information as the Site Visit Form plus information
concerning meal preparation and delivery schedules, the
quality and accuracy of site records and recordkeeping, the
regular adjustment of meal orders, and whether changes
are made in menus. A Site Review Form can be found in the
SFSP Sponsors Monitors Guide, available at http://www.fns.
usda.gov/sfsp/handbooks.

Pre-operational site visits

140

Operating
Cost Records
(7 CFR 225.2 definitions and FNS Instruction 796-4, Rev. 4)

Operating costs are allowable costs incurred by the sponsor for preparing and serving meals to
eligible children and Program adults. These costs include, but are not limited to, cost of food used,
labor, nonfood supplies, and space for the food service. Rural sites may include costs that are
directly incurred in transporting children from rural homes to rural food service sites. All costs must
be fully documented and they must represent actual Program costs.

Food Costs for On Site Preparation
(FNS Instruction 796-4, Rev. 4)

The data that is necessary for computing the cost of food
used is more extensive when sponsors prepare their own
meals on site or at a central kitchen. Records to support the
cost of food used should include, at a minimum:
•

Receiving reports that record the amount of food
received from the supplier

•

Purchasing invoices

•

Records of any returns, discounts, or other credits not
reflected on purchase invoices

•

Inventory records that show the kinds of food items on
hand at the beginning and end of the inventory period,
the quantity of each item, documented major inventory
adjustments, and the total value of the beginning and
ending inventory

•

Cancelled checks or other forms of receipt for payment

Food costs cover the cost of purchases and the cost of
processing, transporting, storing, and handling food that
is donated (including USDA Foods) or purchased by the
sponsor. Sponsors cannot charge the Program for major
reductions of food in stock that are the result of fire, theft,
spoilage, contamination, or any event other than normal
usage. Attachment 17 in the Reference Section provides a
sample inventory form and instructions for sponsors that
prepare meals on site or at a central kitchen. Attachment 28
provides a worksheet to compute the cost of food used.

Food Costs for Vended Programs

(FNS Instruction 796-4, Rev. 4)

The cost of food used means the cost of the preparation or the cost of preparation and delivery of
meals charged to the sponsor by the FSMC or the school facility.
This cannot include charges for meals delivered to nonapproved sites, meals not delivered within the established
delivery time, meals that are spoiled or do not meet meal
pattern requirements, or meals that do not meet the
requirements or terms of the contract. The sponsor should
not pay the FSMC or school facility for these meals. The

sponsor must maintain records that include the signed
delivery slips to support the claim for reimbursement.
The delivery slip must provide sufficient detail to document
compliance with SFSP requirements. The delivery slip is the
sponsor’s only identifier that the meal served matched the

141

menu for that day, unless a substitution has been indicated.
Although the Federal regulations do not specifically define
what should be addressed on the delivery slips, the site
supervisor or designated site personnel should:
•

Determine what meals they are signing for on the
delivery slip

•

Check the quantity

•

Ensure that meals meet the meal pattern requirements

•

Note any errors/differences on the delivery slip

•

Maintain the signed detailed delivery slip to support the
sponsors claim for reimbursement

It is strongly encouraged that, at a minimum, the delivery
slip includes:
•

What meal is being delivered

•

The number of meals delivered

•

The delivery date and time

Administrative Costs

(7 CFR 225.2 definitions, FNS Instruction 796-4, Rev 4)

Administrative costs are costs incurred by the sponsor for activities related to planning, organizing,
and administering the Program. Generally, these activities include:
•

•

Preparing and submitting an application for
participation, including a management plan containing
budgets of operating and administrative costs, and
staffing and monitoring plans

•

Preparing and submitting claims for reimbursement

•

Performing other activities that are necessary for
planning, organizing, and managing the Program

Establishing the eligibility of open or restricted open
sites by collecting school or census tract data or family
household applications for closed enrolled sites to
determine if 50 percent or more of the children are eligible

Generally, costs incurred for these activities are:
•

Labor costs for administrative activities

•

Rental costs for offices, office equipment, and vehicles;

For camps, determining the number of children eligible
based on a review of family size and income forms

•

Vehicle allowance and parking expenses

•

Office supplies

•

Attending training provided by the State agency

•

Communications

•

Hiring and training site and administrative personnel

•

Insurance and indemnification

•

Visiting sites, reviewing and monitoring operations at
sites, and documenting these visits and reviews

•

Audits

•

Travel

•

•

Preparing and submitting a plan for and summary of the
invitation to bid when the sponsor wants to contract
with a FSMC

Labor Costs
(FNS Instruction 796-4, Rev. 4)

Labor costs include compensation by sponsors for labor that is required to prepare and serve meals,
to supervise children during the meal service, and to clean up after the meal service.
These costs may include wages, salaries, employee benefits, and the share of taxes paid by the sponsor. Sponsors must
keep accurate time and attendance records for all labor costs that are attributed to the SFSP. A sample Staff Time Report for
food service and site staff is included in the Reference Section as Attachment 26.

142

Other Operating Costs

(FNS Instruction 796-4, Rev. 4)

Other operating costs may include, but are not limited to:
•

Costs of nonfood supplies

•

Rental costs for buildings, food service equipment, and
vehicles

•

Utility costs

•

Mileage allowances

A sample mileage form for food service and site staff is included
in the Reference Section as Attachment 24. If sponsors feel that
they may have “other” costs that are not listed, they may contact
the State agency for a determination as to whether or not they
may use reimbursement to cover those costs. Sponsors must
keep all records and documentation to support any costs that
they claim for reimbursement.

Maintaining
Records
OF COSTS AND TRACKING FUNDS
(7 CFR 225.15(c))

Records must be maintained that document the amount
and purpose of all administrative costs attributed to
SFSP. For example, time and attendance records must
be kept to document labor costs. Attachment 27 in the
Reference Section includes a worksheet and instructions for
documenting administrative costs.
Sponsors must be able to account for the receipt, obligation,
and expenditure of all SFSP funds. However, this does not
mean that sponsors are necessarily required to maintain
SFSP funds in a separate bank account from other
institution expenditures. Sponsors must ensure that all
SFSP reimbursements are being used solely for conducting
non-profit food service operations.
When a sponsor’s total food service is not conducted
principally for the benefit of its own SFSP participants,
the non-Program and Program components of the food
service operation must be tracked separately. Through this
separation, the institution must ensure that the SFSP non­

profit food service Program component does not support
any non-Program food service activities such as vending or
catering operations or adult meal services.
Attachments 23, 25, and 27 are sample forms for tracking
administrative costs. Attachment 23 is a sample form for
administrative staff (including monitors) to use in keeping
track of mileage, Attachment 25 tracks administrative staff
hours worked, and Attachment 27 is a sample form for
summarizing all administrative costs.

Retention of Records
(7 CFR 225.8(a))

Sponsors must maintain all records for three years after
the end of the fiscal year of operation, or longer if required
by the State agency. These records must be accessible to
Federal and State agency personnel for audit and review
purposes. Further, these records can only be disposed of
after three years if there are no unresolved audit findings or
the Program is not under investigation.

143

CHAPTER 10

Questions
and answers
1

WHAT TYPE OF RECORDS DO
SPONSORS NEED TO KEEP
FOR THE PROGRAM?

To substantiate your claim for reimbursement,
sponsors must keep all records of meal counts
taken daily at each site, operating costs including
food and other costs, administrative costs including
labor and supplies, and funds accruing to the
Program. In addition, records need to be maintained
that document the training sponsors have provided
for their site(s) and administrative personnel and
document they have met monitoring requirements.
Additionally, records that document the sponsor’s
eligibility for the SFSP, such as the application to
participate in the SFSP and the signed agreement
with the State agency, must be maintained.

2

HOW LONG ARE SPONSORS
REQUIRED TO MAINTAIN
THESE RECORDS?

Sponsors must maintain all records for three years
following the submission date of the final claim for
reimbursement, or longer if required by the State
agency. For audit and review purposes these records
will need to be made available upon request to Federal
and State agency personnel. Further, records can only
be disposed of if there are no unresolved audit findings
or the Program is not under investigation.

144

Reference

Materials

PROGRAM
PROGRAM
BASICS
BASICS

Definitions of Program Terms
from the SFSP Federal Regulations (7 CFR 225.2 Definitions)
Act means the National School Lunch Act, as amended.
Administrative costs means costs incurred by a sponsor related to planning, organizing, and managing a food
service under the Program, and excluding interest costs and operating costs.
Adult means, for the purposes of the collection of social security numbers as a condition of eligibility for
Program meals, any individual 21 years of age or older.
Advance payments means financial assistance made available to a sponsor for its operating costs and/or
administrative costs prior to the end of the month in which such costs will be incurred.
Areas in which poor economic conditions exist means:
• The attendance area of a school in which at least 50 percent of the enrolled children have been
determined eligible for free or reduced-price school meals under the National School Lunch Program and
the School Breakfast Program;
• A geographic area where, based on the most recent census data available or information provided from a
department of welfare or zoning commission, at least 50 percent of the children residing in that area are
eligible for free or reduced-price school meals under the National School Lunch Program and the School
Breakfast Program;
• A geographic area where a site demonstrates, based on other approved sources, that at least 50 percent
of the children enrolled at the site are eligible for free or reduced-price meals under the National School
Lunch Program and the School Breakfast Program;
• A closed enrolled site.
Camps means residential summer camps and nonresidential day camps which offer a regularly scheduled food
service as part of an organized program for enrolled children. Nonresidential camp sites shall offer a continuous
schedule of organized cultural or recreational programs for enrolled children between meal services.
Children means (a) persons 18 years of age and under, and (b) persons over 18 years of age who are determined
by a State educational agency or a local public educational agency of a State to be mentally or physically
handicapped and who participate in a public or non-profit private school program established for the mentally or
physically handicapped.
Closed enrolled site means a site which is open only to enrolled children, as opposed to the community at large,
and in which at least 50 percent of the enrolled children at the site are eligible for free or reduced-price school
meals under the National School Lunch Program and the School Breakfast Program, as determined by approval
of applications in accordance with 225.15(f).
Continuous school calendar means a situation in which all or part of the student body of a school is (a) on a
vacation for periods of 15 continuous school days or more during the period October through April and (b) in
attendance at regularly scheduled classes during most of the period May through September.
Costs of obtaining food means costs related to obtaining food for consumption by children. Such costs may
include, in addition to the purchase price of agricultural commodities and other food, the cost of processing,
distributing, transporting, storing, or handling any food purchased for, or donated to, the Program.

147

ATTACHMENT 1

PROGRAM
PROGRAM
BASICS
BASICS

Definitions of Program Terms, Continued

Current income means income, as defined in 225.15 (f)(4)(vi), received during the month prior to application for

free meals. If such income does not accurately reflect the household’s annual income, income must be based

on the projected annual household income. If the prior year’s income provides an accurate reflection of the

household’s current annual income, the prior year may be used as a base for the projected annual income.

Department means the U.S. Department of Agriculture.

Disclosure means individual children’s program eligibility information obtained through the free and reduced-

price meal eligibility process that is revealed or used for a purpose other than for the purpose for which the

information was obtained. The term refers to access, release, or transfer of personal data about children by

means of print, tape, microfilm, microfiche, electronic communication or any other means.

Documentation means:

The completion of the following information on a free meal application:

• Names of all household members:
• Income received by each household member, identified by source of income (such as earnings, wages,
welfare, pensions, support payments, unemployment compensation, social security and other cash
income);
• The signature of an adult household member; and
• The last four digits of the social security number of the adult household member who signs the

application, or an indication that he/she does not possess a social security number; or

For a child who is a member of a household receiving SNAP, FDPIR, or TANF benefits, “documentation” means
completion only the following information on a free meal application:
• The name(s) and appropriate SNAP, FDPIR, or TANF case number(s) for the child(ren); and
• The signature of an adult member of the household.
Experienced site means a site which, as determined by the State agency, has successfully participated in the
Program in the prior year.
Experienced sponsor means a sponsor which, as determined by the State agency, has successfully participated
in the Program in the prior year.
Family means a group of related or nonrelated individuals who are not residents of an institution or boarding
house but who are living as one economic unit.
FDPIR household means any individual or group of individuals which is currently certified to receive assistance
as a household under the Food Distribution Program on Indian Reservations.
Fiscal Year means the period beginning October 1 of any calendar year and ending September 30 of the
following calendar year.
FNS means the Food and Nutrition Service of the Department.
FNSRO means the appropriate FNS Regional office.

148

ATTACHMENT 1, CONTINUED

PROGRAM BASICS

Definitions of Program Terms, Continued
Food Service Management Company (FSMC) means any commercial enterprise or non-profit organization with
which a sponsor may contract for preparing unitized meals, with or without milk, for the use in the Program, or
for managing a sponsor’s food service operations in accordance with the limitations set forth in 225.15. Food
service management companies/commercial meal vendor may be:
• Public agencies or entities;
• Private, non-profit organizations; or
• Private, for-profit companies.
Homeless children or youth means individuals who lack a fixed, regular, and adequate nighttime residence and
includes: (i) children and youths who are sharing the housing of other persons due to loss of housing, economic
hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping grounds due to the lack of
alternative adequate accommodations; are living in emergency or transitional shelters; are abandoned in hospitals;
or are awaiting foster care placement; (ii) children and youths who have a primary nighttime residence that is a
public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings
(within the meaning of section 103(a)(2)(C)); (iii) children and youths who are living in cars, parks, public spaces,
abandoned buildings, substandard housing, bus or train stations, or similar settings; and (iv) migratory children
(as such term is defined in section 1309 of the Elementary and Secondary Education Act of 1965) who qualify as
homeless for the purposes of this subtitle because the children are living in circumstances described in clauses (i)
through (iii). Subtitle B of title VII of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11431 et seq.)
Household means “family,” as defined in this section.
Income accruing to the program means all funds used by a sponsor in its food service program, including but
not limited to all monies, other than program payments, received from Federal, State and local governments,
from food sales to adults, and from any other source including cash donations or grants. Income accruing to the
Program will be deducted from combined operating and administrative costs.
Income standards means the family-size and income standards prescribed annually by the Secretary for
determining eligibility for reduced -price meals under the National School Lunch Program and the School
Breakfast Program.
Meals means food which is served to children at a food service site and which meets the nutritional
requirements set out in this part.
Medicaid means the State medical assistance program under title XIX of the Social Security Act (42 U.S.C. 1396
et seq.).
Milk means whole milk, low fat milk, skim milk, and buttermilk. All milk must be fluid and pasteurized and must
meet State and local standards for the appropriate type of milk. Milk served may be flavored or unflavored. In
Alaska, Hawaii, American Samoa, Guam, Puerto Rico, the Trust Territory of the Pacific Islands, the Northern
Mariana Islands, and the Virgin Islands of the United States, if a sufficient supply of such types of fluid milk
cannot be obtained, reconstituted or recombined milk may be used. All milk should contain Vitamins A and D at
the levels specified by the Food and Drug Administration and at levels consistent with State and local standards
for such milk.
Needy children means children from families whose incomes are equal to or below the Secretary’s Guidelines
for Determining Eligibility for Reduced-Price School Meals.

149

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PROGRAM BASICS

Definitions of Program Terms, Continued
New site means a site that did not participate in the Program in the prior year, or, as determined by the State
agency, a site that has experienced significant staff turnover from the prior year.
New sponsor means a sponsor that did not participate in the Program in the prior year or, as determined by the
State agency, a sponsor that has experienced significant staff turnover from the prior year.
NYSP means the National Youth Sports Program administered by the National Collegiate Athletic Association.
NYSP feeding site means a site at which all of the children receiving Program meals are enrolled in the NYSP
and which qualifies for Program participation on the basis of documentation that the site meets the definition of
“areas in which poor economic conditions exist” as provided in this section.
OIG means the Office of the Inspector General of the Department.
Open site means a site at which meals are made available to all children in the area and which is located in an
area in which at least 50 percent of the children are from households that would be eligible for free or reducedprice school meals under the National School Lunch Program and the School Breakfast Program, as determined
in accordance with paragraph (a) of the definition of Areas in which poor economic conditions exist.
Operating costs means the cost of operating a food service under the Program,
Including:
• Cost of obtaining food;
• Labor directly involved in the preparation and service of food;
• Cost of nonfood supplies;
• Rental and use allowances for equipment and space, and
• Cost of transporting children in rural areas to meal sites in rural areas.
Excluding:
• The cost of the purchase of land, acquisition or construction of buildings;
• Alteration of existing buildings;
• Interest costs;
• The value of in-kind donations, and
• Administrative costs.
Private non-profit means tax exempt under section 501(c) of the Internal Revenue Code of 1986, as amended.
Private non-profit organization means an organization (other than private non-profit residential camps, school
food authorities, or colleges or universities participating in the NYSP) that meets the definition of “private non­
profit” in this section and which:
• Administers the Program;
• Operates in areas where a school food authority has not indicated that it will operate the Program in the
current year;
• Exercises full control and authority over the operation of the Program at all sites under its sponsorship;
• Provides ongoing year-round activities for children or families;
• Demonstrates that it possesses adequate management and the fiscal capacity to operate the Program; and
• Meets applicable State and local health, safety, and sanitation standards.
Program means the Summer Food Service Program for Children authorized by Section 13 of the Act.

150

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PROGRAM
PROGRAM
BASICS
BASICS

Definitions of Program Terms, Continued

Program funds means Federal financial assistance made available to State agencies for the purpose of making
Program payments.
Program payments means financial assistance in the form of start-up payments, advance payments, or
reimbursement paid to sponsors for operating and administrative costs.
Restricted open site means a site which is initially open to broad community participation, but at which the
sponsor restricts or limits attendance for reasons of security, safety or control. Site eligibility for a restricted
open site shall be documented in accordance with paragraph (a) of the definition of Areas in which poor economic
conditions exist.
Rural means (a) any area in a county which is not a part of a Metropolitan Statistical Area or (b) any “pocket”
within a Metropolitan Statistical Area which, at the option of the State agency and with FNSRO concurrence, is
determined to be geographically isolated from urban areas.
School food authority (SFA) means the governing body which is responsible for the administration of one or
more schools and which has the legal authority to operate a lunch program in those schools. In addition, for the
purpose of determining the applicability of food service management company registration and bid procedure
requirements, “school food authority” also means any college or university which participates in the Program.
Secretary means the Secretary of Agriculture.
Self-preparation sponsor means a sponsor which prepares the meals that will be served at its site(s) and
does not contract with a food service management company for unitized meals, with or without milk, or for
management services.
Session means a specified period of time during which an enrolled group of children attend camp.
Site means a physical location at which a sponsor provides a food service for children and at which children
consume meals in a supervised setting.
SNAP household means any individual or group of individuals which is currently certified to receive assistance
as a household under the SNAP Program
Special account means an account that a State agency may require a vended sponsor to establish with the
State agency or with a Federally insured bank. Operating costs payable to the sponsor by the State agency are
deposited in the account and disbursement of monies from the account must be authorized by both the sponsor
and the food service management company.
Sponsor means a public or private non-profit school food authority, a public or private non-profit residential
summer camp, a unit of local, municipal, county or State government, a public or private non-profit college or
university currently participating in the NYSP, or a private non-profit organization which develops a special
summer or other school vacation program providing food service similar to that made available to children
during the school year under the National School Lunch and School Breakfast Programs and which is approved
to participate in the Program. Sponsors are referred to in the Act as “service institutions.”

151

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PROGRAM
PROGRAM
BASICS
BASICS

Definitions of Program Terms, Continued

Start-up payments means financial assistance made available to a sponsor for administrative costs to enable it

to effectively plan a summer food service, and to establish effective management procedures for such a service.

These payments shall be deducted from subsequent administrative cost payments.

State means any of the 50 States, the District of Columbia, the Commonwealth of Puerto Rico, the Virgin Islands

of the United States, Guam, American Samoa, the Trust Territory of the Pacific Islands, and the Northern Mariana

Islands.

State agency means the State educational agency or an alternate agency that has been designated by the Governor

or other appropriate executive or legislative authority of the State and which has been approved by the Department

to administer the Program within the State, or, in States where FNS administers the Program, FNSRO.

State Children’s Health Insurance Program (SCHIP) means the State medical assistance program under title XXI

of the Social Security Act (42 U.S.C. 1397aa et seq.).

TANF means the State funded program under part A of title IV of the Social Security Act that the Secretary

determines complies with standards established by the Secretary that ensure that the standards under the

State program are comparable to or more restrictive than those in effect on June 1, 1995. The program is commonly

referred to as Temporary Assistance for Needy Families, although States may refer to the program by another name.

Unit of local, municipal, county or State government means an entity which is so recognized by the State

constitution or State laws, such as the State administrative procedures act, tax laws, or other applicable State

laws which delineate authority for government responsibility in the State.

Vended sponsor means a sponsor which purchases from a food service management company the unitized

meals, with or without milk, which it will serve at its site(s), or a sponsor which purchases management services,

subject to the limitations set forth in Sec. 225.15, from a food service management company.

Yogurt means commercially prepared coagulated milk products obtained by the fermentation of specific

bacteria, that meet milk fat or milk solid requirements and to which flavoring foods or ingredients may be added.

These products are covered by the Food and Drug Administration’s Standard of Identity for yogurt, low-fat yogurt,

and nonfat yogurt, (21 CFR 131.200), (21 CFR 131.203), (21 CFR 131.206), respectively.

[54 FR 18208, Apr. 27, 1989, as amended at 54 FR 27153, June 28, 1989; 55 FR 13466, Apr. 10, 1990; 61 FR

25553, May 22, 1996; 64 FR 72483, Dec. 28, 1999; 64 FR 72895, Dec. 29, 1999]

152

ATTACHMENT 1, CONTINUED

PROGRAM BASICS

Glossary of Acronyms
ABBR

Full Name

ABBR

Full Name

CACFP

Child and Adult Care Food Program

RCCI

Residential Child Care Institution

CBG

Census Block Group

RD

USDA’s Rural Development

CEP

Community Eligibility Provision

SBA

Small Business Administration

CFR

Code of Federal Regulations

SFA

School Food Authority

DEIP

Deployment Extension Incentive Pay

SFSP

Summer Food Service Program

DHHS

United States Department of Health and
Human Services

SMP

Special Milk Program

DOC

Department of Commerce

SNAP

Supplemental Nutrition Assistance
Program

DOD

Department of Defense

SSO

Seamless Summer Option

DOE

Department of Education

STAT

State Technical Assistance Team

FDPIR

Food Distribution Program on Indian
Reservations

TANF

Temporary Assistance to Needy Families

FNS

Food and Nutrition Service

TRE

Department of Treasury

FSMC

Food Service Management Company

USC

United States Code

Family Subsistence Supplemental
Allowance

USDA

United States Department of Agriculture

FSSA

WIA

Workforce Investment Act

GAO

Government Accountability Office

GPO

Government Printing Office

HUD

Department of Housing and Urban
Development

IFB

Invitation for Bid

IRS

United States Internal Revenue Service

ISP

Identified Student Percentage

JTPA

Job Training Partnership Act

NSLP

National School Lunch Program

NYSP

National Youth Sports Program

OVS

Offer Versus Serve

PSA

Public Service Announcement

153

ATTACHMENT 2

PROGRAM BASICS

Meal Pattern For Children
Select the appropriate components for a reimbursable meal

Breakfast

Lunch/Supper

Milk

Required

Required

Fluid milk (whole, low-fat, or fat-free)

1 cup (½ pint,
8 fluid ounces)2

1 cup (½ pint,
8 fluid ounces)3

Vegetables and Fruits
Equivalent quantity of any combination of:

Required

Required

Vegetable or fruit or

½ cup

¾ cup total4

¾ cup

Full-strength vegetable or fruit juice

½ cup (4 fluid ounces)

¾ cup

¾ cup (6 fluid ounces)5

Grains/Breads6
Equivalent quantity of any combination of:

Required

Required

Bread or

1 slice

1 slice

1 slice W

Cornbread, biscuits, rolls, muffins, etc. or

1 serving

1 serving

1 serving

Cold dry cereal or

¾ cup or 1 ounce7

Cooked cereal or cereal grains or

½ cup

½ cup

½ cup

Cooked pasta or noodle products

½ cup

½ cup

½ cup

Meat and Meat Alternates
Equivalent quantity of any combination of:

Optional

Required

Lean meat or poultry or fish or

1 ounce

2 ounces

1 ounce

Alternate protein products or

1 ounce

2 ounces

1 ounce

Cheese or

1 ounce

2 ounces

1 ounce

Egg (large) or

½

1

½

Cooked dry beans or peas or

¼ cup

½ cup

¼ cup

Peanut or other nut or seed butters or

2 tablespoons

4 tablespoons

2 tablespoons

1 ounce=50%10

1 ounce

8 ounces or 1 cup

4 ounce or ½ cup

Food Components and Food Items

8

Serve all three

Nuts or seeds9 or
Yogurt

11

4 ounces or ½ cup

Serve all four

4

Snack

Serve two of the four

1 cup (½ pint,
8 fluid ounces)2

¾ cup or 1 ounce7

1

For the purposes of the requirement outlined in this table, a cup means a standard mea­
suring cup.

2

Served as a beverage or on cereal or used in part for each purpose.

7 Either volume (cup) or weight (ounces), whichever is less.

3

Served as a beverage.

8 Must meet the requirements of 7 CFR 225 Appendix A.

4

Serve two or more kinds of vegetable or fruits or a combination of both. Full-strength vegeta­
ble or fruit juice may be counted to meet not more than one-half of this requirement

9 Tree nuts and seeds that may be used as meat alternate are listed in Program guidance.

5

Juice may not be served when milk is served as the only other component.

6

Bread, pasta or noodle products, and cereal grains (such as rice, bulgur, or corn grits) shall
be whole-grain or enriched. Cornbread, biscuits, rolls, muffins, etc., shall be made with
whole-grain or enriched meal or flour. Cereal shall be whole-grain, enriched or fortified.

Serving sizes and equivalents will be in guidance materials to be distributed by FNS to State
agencies.

10 No more than 50 percent of the requirement shall be met with nuts or seeds. Nuts or seeds
shall be combined with another meat/meat alternate to fulfill the requirement. For purposes
of determining combinations, one ounce of nuts or seeds is equal to one ounce of cooked lean
meat, poultry or fish.
11

Plain or flavored, unsweetened or sweetened.

154

ATTACHMENT 3

PROGRAM BASICS

Federal Guidance

Sponsors must understand and follow Federal requirements to successfully run the Summer Food Service
Program (SFSP). Consult the applicable State agency for copies of, or questions about, any of the Federal
regulations, Office of Management and Budget Circulars, and FNS Instructions. Below is a list describing both
numbered and unnumbered Child Nutrition Program policies that impact the SFSP.
Available at http://www.fns.usda.gov/sfsp/policy

CHILD NUTRITION NUMBERED AND UN-NUMBERED POLICIES
November 13,
2015

SFSP Memorandum # 9-2016: Guidance on Competitive Procurement Standards for Program Operators

November 12, 2015

SFSP Memorandum # 8-2016: Summer Food Service Program Questions and Answers

November 12, 2015

SFSP Memorandum # 7-2016: Local Foods and Related Activities in Summer Meal Programs, with Questions
and Answers

November 12, 2015

SFSP Memorandum # 6-2016: Promoting Nutrition in Summer Meal Programs, with Best Practices

November 12, 2015

SFSP Memorandum # 5-2016: Meal Service Requirements in the Summer Meal Programs, with Questions and
Answers

October 22, 2015

SFSP Memorandum # 1-2016: Procuring Local Meat, Poultry, Game, and Eggs for the Child Nutrition Programs

June 31, 2015

SFSP Memorandum # 21-2015: Service of Traditional Foods in Public Facilities

June 22, 2015

SFSP Memorandum # 10-2014 (v3): Smoothies Offered in the Child Nutrition Programs

June 16, 2015

TA 01-2015: Child Nutrition Programs and Traditional Foods

June 10, 2015

SFSP Memorandum # 20-2015: 2015 Edition of Eligibility Manual for School Meals

May 19, 2015

SFSP Memorandum # 19-2015: Voluntary Menu Labeling in the NSLP and SBP

April 21, 2015

SFSP Memorandum # 04-2015 (v.3): Rural Designations in the Summer Food Service Program – Revised

April 21, 2015

SFSP Memorandum # 16-2015: Site Caps in the Summer Food Service Program Revised

March 30, 2015

SFSP Memorandum # 15-2015: Statements Supporting Accommodations for Children with Disabilities in the
Child Nutrition Programs

March 20, 2015

SFSP Memorandum # 14-2015: Guidance on Prohibition of Separation by Gender during CNP Meal Service

March 18, 2015

SFSP Memorandum # 18-2015: Office of Management and Budget Super-Circular 2 CFR 200

March 11, 2015

SFSP Memorandum # 13-2015: CN Labels Copied with a Watermark Acceptable Documentation,

March 11, 2015

SFSP Memorandum # 12-2015: Administrative Review Process Regarding the Child Nutrition (CN) Label,
Watermarked CN Label and Manufacturer’s Product Formulation Statement

February 25, 2015

SFSP Memorandum # 11-2015: Assessing Costs in the Summer Food Service Program

December 12, 2014

SFSP Memorandum # 09-2015: Summer Food Service Program Waiver Request Guidance and Protocol

December 11, 2014

SFSP Memorandum # 08-2015: Demonstration Project for Non-Congregate Feeding for Outdoor Summer Meal
Sites Experiencing Excessive Heat with Q&As

December 10, 2014

SFSP Memorandum # 07-2015: Health and Safety Inspection Requirements

December 9, 2014

SFSP Memorandum # 06-2015: Categorical Eligibility in the Summer Food Service Program

November 21, 2014

SFSP Memorandum # 03-2015: Area Eligibility in Child Nutrition Programs

155

ATTACHMENT 4

PROGRAM BASICS

Federal Guidance, Continued

CHILD NUTRITION NUMBERED AND UN-NUMBERED POLICIES
November 21, 2014

SFSP Memorandum # 02-2015: Written Codes of Conduct and Performance of Employees Engages in Award
and Administration of Contracts

October 31, 2014

SFSP Memorandum # 01-2015: Duration of Income Eligibility Determinations: Guidance and Questions and
Answers

May 19, 2014

SFSP Memorandum # 18-2014: Disaster Response

April 24, 2014

SFSP Memorandum # 17-2014: Sharing Aggregate Data to Expand Program Access and Services in Child
Nutrition Programs

April 24, 2014

SFSP Memorandum # 16-2014: Streamlined and Simplified Summer Food Service Program Requirements:
Frequently Asked Questions

January 10, 2014

SFSP Memorandum #14-2014: Demonstration Project for Non-Congregate Feeding for Outdoor Summer
Feeding Q&As

January 10, 2014

SFSP Memorandum #13-2014: Procurement Thresholds in the Summer Food Service Program

January 10, 2014

SFSP Memorandum #12-2014: Guidance on Income Eligibility Determinations and Duration REISSUED

December 3, 2013

SFSP Memorandum #11-2014: Effective Date of Free or Reduced-Priced Meal Eligibility Determinations

November 12, 2013

SFSP Memorandum #9-2014: Summer Food Service Program Question and Answers 2014

November 12, 2013

SFSP Memorandum #7-2014: Expanding Awareness and Access to the Summer Food Service Program

November 12, 2013

SFSP Memorandum #6-2014: Available Flexibilities for CACFP At-Risk Afterschool Sponsors and Centers

November 12, 2013

SFSP Memorandum #5-2014: Use of School and Census Data

November 12, 2013

SFSP Memorandum #3-2014: Census Data Release: Fiscal Year 2014

November 12, 2013

SFSP Memorandum #2-2014: Mobile Feeding Options

November 12, 2013

SFSP Memorandum #1-2014: Sponsors Operating in Multiple States: REISSUED

January 24, 2013

SFSP Memorandum #9-2013: Tax Exempt Status for Private Non-profits and Churches in the Child and Adult
Care Food Program and Summer Food Service Program

January 24, 2013

SFSP Memorandum #7-2013: Summer Food Service Program Standard Contract Threshold

January 24, 2013

SFSP Memorandum #6-2013: Additional State Requirements in SFSP REVISED

November 23, 2012

SFSP Memorandum #4-2013: Summer Feeding Options for School Food Authorities

November 23, 2012

SFSP Memorandum #3-2013: Determination Area Eligibility Based on School Data

October 9, 2012

SFSP Memorandum #2-2013: Procurement Geographic
Preference Q&As – Part II

October 02, 2012

SFSP Memorandum #1-2013: Federal Small Purchase Threshold Adjustment

July 24, 2012

SFSP Memorandum #14-2012: Tribal Participation in the CACFP and SFSP

April 26, 2012

SFSP Memorandum #11-2012: Eligibility Based on Census Data: 2012 Data Release REVISED

April 10, 2012

SFSP Memorandum #10-2012: Disaster Response

February 13, 2012

SFSP Memorandum #9-2012: Eligibility Based on Census Data: 2012 Data Release

February 03, 2012

SFSP Memorandum #7-2012: Guidance on the Food Donation Program in Child Nutrition Programs

November 23, 2011

SFSP Memorandum #6-2012: Additional Foods in the Summer Food Service Program

October 31, 2011

SFSP Memorandum #5-2012: Simplifying Application Procedures in the Summer Food Service Program

October 06, 2011

SFSP Memorandum #1-2012: Rural Development’s Community Facilities Program

156

ATTACHMENT 4, CONTINUED

PROGRAM BASICS

Federal Guidance, Continued
CHILD NUTRITION NUMBERED AND UN-NUMBERED POLICIES
August 03, 2011

SFSP Memorandum #18-2011: Translations for the Free and Reduced-Price School Meals Application and
CACFP Meal Benefit Income Eligibility Form

June 30, 2011

SFSP Memorandum #17-2011: Automatic Revocation of Tax Exempt Status

May 18, 2011

SFSP Memorandum #16-2011: Restricted Open Sites and Summer Schools

May 13, 2011

SFSP Memorandum #15-2011: Child Nutrition and WIC Reauthorization 2010: Implementation of Section 361,
Full Use of Federal Funds, FAQ 2

May 9, 2011

SFSP Memorandum #14-2011: Existing Flexibilities in SFSP

April 8, 2011

SFSP Memorandum #13-2011: For-Profit Locations as Meal Sites

April 5, 2011

SFSP Memorandum #12-2011: Waiver of Site Monitoring Requirements

April 1, 2011

SFSP Memorandum #10-2011: Eligibility of Children Evacuated from Japan and Bahrain

March 29, 2011

SFSP Memorandum #09-2011: Child Nutrition and WIC Reauthorization 2010: Implementation of Section 361,
Full Use of Federal Funds

March 8, 2011

SFSP Memorandum #08-2011: Child Reauthorization 2010: Cooperation with Program Research and Evaluation

February 18, 2011

SFSP Memorandum #07-2011: Child Reauthorization 2010: Section 361, Full Use of Federal Funds

February 15, 2011

SFSP Memorandum #06-2011: Child Reauthorization 2010: Privacy Protection and the Use of Social Security
Numbers

January 31, 2011

SFSP Memorandum #05-2011: Child Reauthorization 2010: Categorical Eligibility of Foster Children

January 14, 2011

SFSP Memorandum #03-2011: Child Reauthorization 2010: Permanent Agreements

January 14, 2011

SFSP Memorandum #02-2011: Child Reauthorization 2010: Eligibility Requirements and Site Limits for Private
Non-profit Organizations

August 23, 2010

SFSP Memorandum #15-2010: Disclosure Requirements for the Child Nutrition Programs

August 2, 2010

SFSP Memorandum #14-2010: Update on the Publication of Updated Poverty Guidelines

June 11, 2010

SFSP Memorandum #13-2010: Update on the Continuing Delay of Publication of Updated Poverty Guidelines

May 24, 2010

SFSP Memorandum #12-2010: Prototype Application Materials for School Year 2010-2011

May 5, 2010

SFSP Memorandum #11-2010: Waiver on Providing Income Limits on Applications

May 3, 2010

SFSP Memorandum #10-2010: Q&As: Extending Categorical Eligibility to Addition Children in a Household

May 3, 2010

SFSP Memorandum #09-2010: Extension of 2010 Sponsor Application Deadline

April 19, 2010

SFSP Memorandum #08-2010; Categorical Eligibility – Temporary Assistance to Needy Families

January 29, 2010

SFSP Memorandum #07-2010; Eligibility of Haitian Refugees for Child Nutrition Programs

November 13, 2009

SFSP Memorandum #06-2010; Geographic Preference for the Procurement of Unprocessed Agricultural
Products in the Child Nutrition Programs

November 12, 2009

SFSP Memorandum #05-2010; Q&As: Milk Substitution for Children with Medical or Special Dietary Needs
(Non-Disability)

September 15, 2009

SFSP Memorandum #04-2010; Exclusion of Military Combat Pay

October 9, 2009

SFSP Memorandum #02-2010; Procurement Questions

October 9, 2009

SFSP Memorandum #01-2010; Applying Geographic Preferences in Procurements for the Child Nutrition
Programs - Update

August 27, 2009

SFSP Memorandum #07-2009; Extending Categorical Eligibility to Additional Children in a Household

157

ATTACHMENT 4, CONTINUED

PROGRAM BASICS

Federal Guidance, Continued
CHILD NUTRITION NUMBERED AND UN-NUMBERED POLICIES
August 5, 2008

SFSP Memorandum # 09-2008; Automatic Eligibility for Early Head Start Participants

May 16, 2008

SFSP Memorandum # 06-2008; Automatic Eligibility for Free Meal Benefits Extended to All Children Enrolled
in Head Start

February 15, 2008

SFSP Memorandum 04-2008; Sharing Income Eligibility Information Between Child Nutrition Programs

February 14, 2008

SFSP Memorandum 03-2008; Simplified Procedures in the Summer Food Service Program

January 2, 2008

SFSP Memorandum # 01-2008; Nationwide Expansion of Summer Food Service Program Simplified Cost
Accounting Procedures

July 27, 2007

SFSP Memorandum #9-2007; Food Service Management Company Contracts

June 11, 2007

SFSP Memorandum #08-2007; Operation of Child Nutrition Programs during a Pandemic

June 15, 2007

SFSP Memorandum # 07-2007; Electronic Record and Reporting Systems

February 23, 2007

SFSP Memorandum #04-2007; Migrant Site Eligibility Determinations

January 19, 2007

SFSP Memorandum #01-2007; SFSP—Exceptions to Approving Sponsors Prior to Program Operations

August 25, 2006

SFSP Memorandum #07-2006; U.S. Armed Forces Family Supplemental Subsistence Allowance – Permanently
Excluded from Income Consideration for the Child Nutrition Programs

August 30, 2005

U.S. Armed Forces Family Supplemental Subsistence Allowance – Excluded from Income Consideration

June 29, 2005

SFSP Memorandum #01-05: Simplified Summer Food Program: December 2, 2004; Transmittal of Guidance on
Simplified Q & A’s

July 1, 2004

Exclusion of the Housing Allowance for Military Households in Privatized Housing - Reauthorization 2004:
Implementation Memo CN 1

May 26, 2004

Eligibility of Upward Bound Sites

March 2, 2004

SFSP #1-04; Contract Requirements for School Sponsors

February 3, 2003

Field Trips in the SFSP

May 15, 2000

Authority for Sponsors to Combine Claims for Reimbursement

158

ATTACHMENT 4, CONTINUED

PROGRAM BASICS

Site Definitions & Eligibility
Documentation
SFSP Site
A site is the physical location where program meals are served to
children and where children consume meals in a supervised setting.

Open Site

Camps

Closed Enrolled Site

• Is located in an area where at

•

Serves only an identified group of
children in a specific program or activity

least 50% of the children are
eligible for free or reduced-price
school meals.

• Reimbursed for all attending
children

Restricted Open Site

•

Residential sites must offer
regular schedule of food
service as part of the program;
non residential day camp
sites must offer continuous
scheduled cultural or
recreational program between
meal services
Reimbursed only for children
meeting free or reduced-price
school meals

for reasons of security, safety or
control due to staff (and other)
limitations

at large

• Reimbursed for all children in

attendance when at least half
are eligible for free or reducedprice meals

Eligibility Documentation

Community on a first-come, firstserved basis

• Sponsor may limit attendance

• Site is not open to the community

Eligibility Documentation

One of the following

Income eligibility applications

• Reimbursed for all attending
children

Sponsor may obtain lists of names
and eligibility of enrolled children
for free or reduced-price meals
from schools where children receive
school lunch or breakfast

Eligibility Documentation
One of the following

School
Data

Income eligibility applications
accurately completed – and at least
50%of enrollees are eligible for free
or reduced-price school meals

Census Block
Group Data

Use “area” eligibility data or
census data for the location of the
site to show at least 50% of the
area households meet the income
eligibility guidelines

159

ATTACHMENT 5

PROGRAM BASICS

Site Definitions & Eligibility

Documentation, Continued

Residential Summer Camp and Non-Residential Day Camp
Reimbursed only for meals served to campers who have been individually
determined to be eligible for free or reduced-price meals

Migrant Site

National Youth Sports Program (NYSP)

• May be located in needy or non-needy areas
• Must serve primarily children of migrant families, may

Eligibility Documentation

serve to other children as well

• Reimbursed for all children served

One of the following

Eligibility Documentation
One of the following

Migrant organization
certifies that the site
serves migrant children

If other children are
served, the migrant
organization certifies
that the site primarily
serves migrant children

160

50% of enrolled children
meet the income eligibility
guidelines for free or
reduced-price meals

Sponsor provides
written certification that
it meets DHHS income
guidelines

50% of enrolled
children reside in
geographical area
where poor economic
conditions exist.

Sponsors may obtain
lists of names and
eligibility of enrolled
children for free or
reduced-price meals
from school lunch or
breakfast

ATTACHMENT 5, CONTINUED

APPLICATION AND PLANNING

Proactive Planning
for Sponsors
Providing summer meals is a year-round effort. At any point throughout the year, there are things you can do to
proactively approach SFSP expansion.
Go to USDA and Partner Resources.

SPONSOR PLANNING
Given that States have their own deadlines, this list provides general information that sponsors can use to plan
their Summer Meal Programs.

FALL
F Ensure all claims for reimbursement have been filed.
F Consolidate daily meal counts and submit reimbursement claims.
F Take time to reflect on the summer with site administrators and what could be improved or what worked.
F Reflect on the service provided by your vendor. Ensure the food was well-received by the children. Revise

menus as needed.
F Review unserved and underserved areas near current sites. Recruit sites to these areas of need.
F Compare participation from this year to that of prior years, as well as current participation for free and reduced-

price meals in local schools.
F Reach out to sites that were underutilized and offer support to increase participation for the coming year.
F Consider providing nonmonetary awards to recognize sites that excelled during the summer.
F Set participation goals for the next summer and plan how you will accomplish them.
F Look out for dates on mandatory sponsor training from your State agency.

WINTER
F Sign up for and attend mandatory sponsor training classes.
F Determine which sites are returning, explore new site options, and meet with community partners.
F Plan site staff training, meal production and delivery, and programs and activities.

MARCH/APRIL
F Review sites and ensure you are aware of their locations, operational hours, staff, and dates for monitoring.
F Think about how meals will be delivered to the sites and how many will be served.
F Complete pre-operational site visits.
F Ensure administrative staff are trained.
F Finish application and renewal forms.
F Contract with a food service management company, if necessary.
F Check with the State agency to determine if there are any potential sites lacking sponsors or areas lacking

sites and sponsors and consider extending service to those areas.

161

ATTACHMENT 6

APPLICATION AND PLANNING

Proactive Planning for Sponsors, Continued

PRIOR TO OPENING
F Ensure your sites are still available and ready to serve meals.
F Conduct outreach to families and children near your sites.
F Finish health inspection letter.
F Ensure site staff and volunteers have been trained.
F Prepare to promote SFSP kick-off events in conjunction with your other State and organizational partners.
F June 15: All sponsor applications must be submitted to the State agency. Note that States may have earlier

deadlines.

WHILE OPEN
F Engage with partners to see what else they need to support the Program.
F Conduct monitoring visits to sites and ethnic/racial participation evaluation.
F Ensure all monitoring and financial management documentation is complete and accurate.

162

ATTACHMENT 6, CONTINUED

APPLICATION AND PLANNING

Agreement to Furnish Food Service for
the Summer Food Service Program
This is a template. Non-SFA sponsors purchasing meals from an SFA must have documentation or a contract/written agreement for the provision of meals.

THIS AGREEMENT is made and entered into between (school)
and (sponsor)

WHEREAS the (school)

agrees to supply unitized meals (inclusive/

exclusive) of milk and juice to (sponsor)

with and for the rates herein listed:

Breakfast ....... $

each

Lunch .......... $

each

Snacks .......... $

each

Supper .....…. $

each

It is further agreed that (school)
, pursuant to the provisions of the
Summer Food Service Program regulations, attached copy of which is part of this agreement, will assure that
said meals meet the minimum meal pattern requirements as to components and portion sizes, and will maintain
full and accurate records that the (sponsor)
will need to meet
its responsibility including menu records containing the amount of food prepared and daily number of meals
delivered by type.
These records must be reported to the (sponsor)
promptly at the end of
the month. (School)
agrees also to retain records
required under the preceding clause for a period of 3 years from the date of receipt of final payment under this
agreement (or longer, if an audit is in progress); and upon request, to make all accounts and records pertaining to
the Program available to representatives of the U.S. Department of Agriculture and the General Accounting Office
for audit or administrative review at a reasonable time and place.
This agreement shall be effective as of (date)
. It may be terminated by notice in writing given
by either party hereto to the other, at least 30 days prior to the date of termination.
IN WITNESS WHEREOF, the parties hereto have executed this agreement as of the dates indicated below:

School Official

Title

Sponsor

Date

Title

Date

Location of food preparation center(s):

163

ATTACHMENT 7

APPLICATION AND PLANNING

Application Requirements for New and
Experienced Sponsors/Sites
Once a sponsor’s initial program application has been approved by the State agency, the sponsor enters into a permanent agreement with the
State agency and is required to submit more limited annual updates to the application. This chart indicates the elements of the application
that are not required beyond the initial application. However, State agencies may require more information annually from sponsors that
have demonstrated past operational problems.

New Sponsors/Sites
and Sponsors/Sites
with Past Operational
Problems

Experienced
Sponsors/Sites

Organized and supervised system for serving meals to children

Required

Not Required

Estimated number and types of meals to be served and times
of service

Required

Required

Arrangements for delivery and holding of meals and storing
leftovers for next day meal service

Required

Not Required

Arrangements for food service during periods of inclement
weather

Required

Not Required

Access to means of communication for making necessary
adjustments for number of meals to be served at each site

Required

Not Required

Whether the site is rural or non-rural and whether the site’s
food service will be self-prepared or vended

Required

Not Required

Requirement

Site Information Sheet: 7 CFR 225.6(c)(2)(i) and (3)(i)

Required
Open sites and restricted open sites: documentation
supporting area eligibility determination

Required

Documentation must
be submitted every five
years when school or
census data is used, or
earlier if requested by the
State agency.

Closed enrolled sites: the projected number of children
enrolled and projected number of children eligible for f/rp

Required

Required

Required

Not Required

Required

Required

meals for each site
NYSP sites: certification from sponsor that all children who
will receive SFSP meals are enrolled participants in NYSP
Camps: number of children enrolled in each session who
meet Program income standards

164

ATTACHMENT 8

APPLICATION AND PLANNING

Application Requirements for New and
Experienced Sponsors/Sites, Continued
New Sponsors/Sites
and Sponsors/Sites
with Past Operational
Problems

Experienced
Sponsors/Sites

Migrant sites: certification from migrant organization that
site serves children of migrant worker families. If site also
serves non-migrant children, sponsor must certify that the site
primarily serves migrant children.

Required

Not Required

Homeless meal sites: information that demonstrates that
site is not a residential child care institution; description of
method used to ensure that no cash payments or other inkind services are used for meal service; certification that site
only claims meals served to children

Required

Not Required

Information that demonstrates that applicant meets
requirements in §225.14; extent of Program payments needed
including advance and start-up payments (if applicable);
staffing and monitoring plan

Required

Not Required

Complete administrative and operating budget which
includes projected administrative expenses and information
of how sponsor will operate the Program within estimated
reimbursement

Required

Not Required

Requirement

Other Application Requirements: 7 CFR 225.6(c)(2)(ii) and (3)(ii)

Required

Summary of how meals will be obtained; if invitation for bid is
required, sponsors must submit a schedule for bid dates and
a copy of their IFB

Required

For sponsors seeking approval as unit of local, municipal,
county or State government, certification that it will directly
operate the Program in accordance with §225.14(d)(3).

Required

165

If IFB is required, sponsors
must submit schedule for
bid dates and copy of IFB if
a change has occurred from
previous year. If method
for procuring meals has
changed from previous year,
sponsors must submit a
summary of how meals will
be obtained.

Not Required

ATTACHMENT 8, CONTINUED

APPLICATION AND PLANNING

Food Service Equipment Needs
Number of Children

Equipment
1 - 50

51 - 100

101 - 200

201 - 300

Range with
ventilating hood

1 range with oven; 30"
domestic or 30" - 36"
commercial
(2 burners)

1 range with oven 30"
- 36" commercial
(4 burners)

1 range with oven 30"
- 36" commercial (2 if
over 150 children)
(6 burners)

2 ranges with ovens
30" - 36" commercial
or 1 range w/oven 60"
or larger commercial
(8 burners)

Refrigerator with
shelves

single section
domestic 18 cu. ft. or
commercial
reach-in 20-25 cu. ft.

double section
commercial
reach-in 40-50 cu. ft.

double section
triple section
commercial
commercial
reach-in 50-60 cu. ft.
reach-in 60-75 cu. ft.
or 64 sq. ft. (8 ft. x 8 ft.) or 64 sq. ft. (8 ft. x 8 ft.)
walk-in
walk-in

Freezer

same as refrigerator

same as refrigerator

same as refrigerator

same as refrigerator

Work Tables
(Allow 4 linear ft.
per worker). Use
countertops as
tables

1 table

2 table

3 table

4 tables

Sink with separate
hand sink

1 sink - 3
compartments

1 sink - 3
compartments

1 sink - 3
compartments

1 sink - 3
compartments

If the site will serve over 100 children, the following equipment is recommended to supplement the minimum
items listed above:
•

Steam equipment (kettle, steamer)

•

Hot food holding cabinet

•

Convection oven

•

Electric food slicer

•

Mixer with attachments (vegetable slicer/shredder, meat and food chopper)

166

ATTACHMENT 9

APPLICATION AND PLANNING

Sample Position
Description (Cook)
Job Title: Cook

Effective Date:

Prepares, seasons, and cooks soups, meats, vegetables, desserts, and other foods for consumption by children and some adults.
Responsibilities:

% Time

Reads from menu and recipes to estimate food requirements and orders food from supplier or
procures it from storage.

%

Prepares food according to food safety requirements, and records temperatures of equipment
and food at time of service. Reinforces the practice of frequent hand-washing and takes steps to
prevent cross-contamination.

%

Adjusts thermostat controls to regulate temperature of ovens, broilers, grills, roasters, and/or
steam kettles.

%

Measures and mixes ingredients according to recipe, using variety of kitchen utensils and
equipment, such as blenders, mixers, grinders, slicers, and tenderizers, to prepare soups,
salads, gravies, desserts, sauces, and casseroles.

%

Bakes, roasts, broils, or steams meats, fish, vegetables, and other foods.

%

Adds seasoning to food during mixing or cooking, according to standardized recipes.

%

Observes and tests food being cooked by tasting, smelling, and taking the internal temperature
of food to determine that it is cooked.

%

Carves meat, portions food on serving plates, and adds gravies, sauces, and garnishes to food
orders.

%

May supervise other cooks and kitchen employees.

%

May wash, peel, cut, and shred vegetables and fruits to prepare them for use.

%

May bake bread, rolls, cakes, and pastry.

%

Keeps accurate records of amounts used.

%

Clean up as necessary.

%

167

ATTACHMENT 10

168

MI
Child’s Last Name

If NO 

> Go to STEP 3.

Grade

Total Household Members
(Children and Adults)

Name of Adult Household Members (First and Last)

2x Month

How often?
Bi-Weekly

Homeless, 
Migrant,
Runaway

Monthly

How often?

$
$

$
$

Last Four Digits of Social Security Number (SSN) of 
Primary Wage Earner or Other Adult Household Member

$

$

$

Bi-Weekly 2x Month Monthly

$

Weekly

$

$

Earnings from Work

X

X

X

Public Assistance/ Child
Support/Alimony

X

X

Weekly

2x Month

How often?
Bi-Weekly

Monthly

Check if no SSN

$

$

$

$

$

Pensions/Retirement/
All Other Income

Weekly

2x Month

How often?
Bi-Weekly

Monthly

Printed name of adult completing the form

Street Address (if available)

Apt #

Signature of adult completing the form

City

 State

 Zip 

Today’s date

Daytime Phone and Email (optional)

“I certify (promise) that all information on this application is true and that all income is reported.  I understand that this information is given in connection with the receipt of Federal funds, and that school officials may verify (check) the information. I am aware that if I purposely give false 
information, my children may lose meal benefits, and I may be prosecuted under applicable State and Federal laws.”

Contact information and adult signature

The “Sources of Income for 
Adults” chart will help you 
with the All Adult 
Household Members 
section..

The “Sources of Income for 
Children” chart will help 
you with the Child Income 
section. 

$

Weekly

Foster
Child

Write only one case number in this space.

Student?
Yes
No

List all Household Members not listed in STEP 1 (including yourself) even if they do not receive income. For each Household Member listed, if they do receive income, report total gross income (before taxes) for each 
source in whole dollars (no cents) only. If they do not receive income from any source, write ‘0’. If you enter ‘0’ or leave any fields blank, you are certifying (promising) that there is no income to report.

B. All Adult Household Members (including yourself)    

Sometimes children in the household earn income. Please include the TOTAL income earned by all Household Members listed in 
STEP 1 here.

A. Child Income

Case Number:

Child income

If  YES >   Write a case number here then go to STEP 4 (Do not complete STEP 3)

Report Income for ALL Household Members  (Skip this step if you answered ‘Yes’ to STEP 2)

Flip the page and carefully 
review the charts titled 
“Sources of Income” for 
more information. 

STEP 4

Child’s First Name

Do any Household Members (including you) currently participate in one or more of the following assistance programs: SNAP, TANF, or FDPIR?   

Not sure what income to 
include here?

STEP 3

STEP 2

Children in Foster care
and 
Children in Foster care and 
children who meet the 
definition of Homeless, 
Migrant or Runaway are 
eligible for free meals. Read 
How to Apply for Free and 
Reduced Price School Meals 
for more information.

Definition of Household
Definition of Household 
Member: “Anyone who is 
living with you and shares 
income and expenses, even if 
not related.”

List ALL Household Members who are infants, children, and students up to and including grade 12 (if more spaces are required for additional names, attach another sheet of paper)

Check all that apply

STEP 1

Complete one application per household. Please use a pen (not a pencil).

Apply online at www.abcdefgh.edu
Apply online at www.abcdefgh.edu

Prototype Household Application for Free and Reduced Price Summer Meals

2016­2017 Prototype Household Application for Free and Reduced Price Summer Meals
(For Use by Camps and Closed Enrolled Sites)

APPLICATION AND PLANNING

­ A child receives income from a private
pension fund, annuity, or trust

­Income from any other source

­ Basic pay and cash bonuses
(do NOT include combat pay, 
FSSA or privatized housing
allowances)
­ Allowances for off­base
housing, food and clothing

If you are in the U.S. Military:

­ Worker’s compensation
­ Supplemental Security
Income (SSI)
­ Cash assistance from State
or local goverment
­ Alimony payments
­ Child support payments
­ Veteran’s benefits

­ Unemployment benefits

Public Assistance / Alimony /
Child Support

Source of Income for Adults
­ Salary, wages, cash bonuses
­ Net income from self­
employment (farm or
business)
­ Strike benefits

Earnings from Work

railroad retirement and
black lung benefits)
­ Private Pensions or
disability
­ Income from trusts aor
estates
­ Annuities
­ Investment income
­ Earned interest
­ Rental income
­ Regular cash payments
from outside household

­ Social Securtity (including

Pensions / Retirement /
All Other Income

Apply online at www.abcdefgh.edu

169

For School Use Only

Determining Official’s Signature

Total Income
Weekly

Date

Bi-Weekly

2x Month

How often?
Monthly

        White

1400 Independence Avenue, SW
Washington, D.C. 20250­9410
(202) 690­7442; or
program.intake@usda.gov.         

fax: 
email: 

Date

Reduced

Eligibility:

Verifying Official’s Signature

Free

Denied

Office of the Assistant Secretary for Civil Rights

This institution is an equal opportunity provider.

U.S. Department of Agriculture

mail: 

Date

To  file  a  program  complaint  of  discrimination,  complete  the  USDA  Program  Discrimination  Complaint  Form, 
(AD­3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write 
a letter addressed to USDA and provide in the letter all of the information requested in the form.  To request a 
copy of the complaint form, call (866) 632­9992.  Submit your completed form or letter to USDA by: 

Categorical Eligibility
Confirming Official’s Signature

Household size

Annual Income Conversion: Weekly x 52, Every 2 Weeks x 26, Twice a Month x 24 Monthly x 12

Do not fill out

   Native Hawaiian or Other Pacific Islander 

Persons with disabilities who require alternative means of communication for program information (e.g. Braille, 
large  print,  audiotape,  American  Sign  Language,  etc.),  should  contact  the  Agency  (State  or  local)  where  they 
applied for benefits.   Individuals who are deaf,  hard of hearing or have speech disabilities may contact USDA 
through the Federal Relay Service at (800) 877­8339.  Additionally, program information may be made available 
in languages other than English.

          Black or African American 

The Richard B. Russell National School Lunch Act requires the information on this application. You do not have 
to  give  the  information,  but  if  you  do  not,  we  cannot  approve  your  child  for  free  or  reduced  price  meals.  You 
must include the last four digits of the social security number of the adult household member who signs the 
application.  The  last  four  digits  of  the  social  security  number  is  not  required  when  you  apply  on  behalf  of  a 
foster child or you list a Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy 
Families (TANF) Program or Food Distribution Program on Indian Reservations (FDPIR) case number or other 
FDPIR identifier for your child or when you indicate that the adult household member signing the application 
does not have a social security number. We  will  use your information to determine if your child is eligible for 
free or reduced price meals, and for administration and enforcement of the lunch and breakfast programs. We 
MAY  share  your  eligibility  information  with  education,  health,  and  nutrition  programs  to  help  them  evaluate, 
fund, or determine benefits for their programs, auditors for program reviews, and law enforcement officials to 
help them look into violations of program rules.
In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and 
policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA 
programs are prohibited from discriminating based on race, color, national origin, sex, religious creed, disability, 
age, political beliefs, or reprisal or retaliation for prior civil rights activity in any program or activity conducted 
or funded by USDA.

Ethnicity (check one):            Hispanic or Latino 
Not Hispanic or Latino
Race (check one or more):       American Indian or Alaskan Native
Asian 

We are required to ask for information about your children’s race and ethnicity. This information is important and helps to make sure we are fully serving our community. Responding 
to this section is optional and does not affect your children’s eligibility for free or reduced price meals.

Children's Racial and Ethnic Identities

­ A friend or extended family member
regularly gives a child spending money

­Income from person outside the household

OPTIONAL

­ A child is blind or disabled and receives
Social Secrity benefits
­A Parent is disabled, retired, or deceased, and
their child receives social security benifits

­ A child has a job where they earn a salary or
wages

­ Social Security
­ Disability Payments

­ Survivor’s Benefits

­ Earning from work

Example(s)

Source of Income for Childen

Sources of Income

Sources of Child Income

INSTRUCTIONS

(For Use by Camps and Closed Enrolled Sites)

Prototype Household Application for Free and Reduced Price Summer Meals
APPLICATION AND PLANNING

APPLICATION AND PLANNING

Planning Checklist: Summer Food
Service Program
Date completed

Action

1.

/

/

Meet with community leaders, if possible, or survey community for assistance in determining suitable site
locations.

2.

/

/

Choose possible sites and compile written documentation supporting the eligibility of each site. This involves
determining the method to be used to show need (such as area eligibility based on census tract or school district
data, or the enrollment of each participating child).

3

/

/

Choose method of meal preparation (self-preparation of meals or purchase of meals from a school food authority
or a public or private food service management company).

4.

/

/

If meals will not be prepared by the sponsor, contact local schools and other possible vendors concerning vending
meals for the Program.

5.

/

/

Contact recreation departments, schools, and local service organizations to coordinate recreation activities with
planned food service at sites.

6.

/

/

Contact reliable site supervisors from previous year(s) to determine if they have an interest in continuing in the
Program.

7.

/

/

Attend training workshops offered by State agency personnel.

8.

/

/

Hire secretarial staff to assist the program director.

9.

/

/

Develop specifications for the invitation to bid (if applicable).

10.

/

/

Publicly advertise the bid, at least 14 days before bid openings (if applicable).

11.

/

/

Estimate potential Program reimbursement and develop budget and staffing plans for the Program.

12.

/

/

Solicit volunteer help at sites whenever possible.

13.

/

/

Hire an assistant program director, if necessary.

14.

/

/

Design forms, use the State agency's sample forms, or the sample forms in the Reference Section of this
handbook for all aspects of Program operations.

15.

/

/

Set up a filing system for those documents that must be maintained for at least 3 years.

16.

/

/

For camps, obtain data for each child to document eligibility for free or reduced-price school meals. This also
applies to sites where eligibility is based on the enrollment group served.

17.

/

/

Notify the health department of your intention to operate a food service program, giving a list of sites you plan
to serve.

18.

/

/

Submit to the State agency a copy of the notification letter to the health department as part of the application for
participation.

19.

/

/

Conduct a pre-operational visit to all new or problem sites.

20.

/

/

Submit a complete application with accompanying documents to the State agency. Include all attachments as
requested by the State agency.

21.

/

/

Use proper procedures to select a vendor (if applicable).

22.

/

/

Meet the vendor and develop delivery schedules (if applicable).

170

ATTACHMENT 12

APPLICATION AND PLANNING

Planning Checklist: Summer Food Service
Program, Continued

Date completed

Action

23.

/

/

Arrange for facilities, equipment, and food purchases at self-preparation sites (if applicable).

24.

/

/

Hire monitors and site supervisors.

25.

/

/

Hold training workshops for monitors and site supervisors.

26.

/

/

Announce the availability of the Program and the nondiscrimination policy through the local media.

27.

/

/

Finalize monitoring schedules and any emergency procedures.

28.

/

/

Arrange to have a nondiscrimination poster, either developed by USDA or approved by the State agency, for each
site.

171

ATTACHMENT 12, CONTINUED

APPLICATION AND PLANNING

Sample News Release:
Open Sites

[Name of sponsor]
is participating in the Summer Food Service Program. Meals will be provided
to all children without charge and are the same for all children regardless of race, color, national origin, sex, age
or disability, and there will be no discrimination in the course of the meal service. Meals will be provided, at a first
come, first serve basis, at the sites and times as follows:
[list all sites along with the starting and ending times of meal service for each site]

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies,
the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are
prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior
civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print,
audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits.
Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service
at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form,
(AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter
addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint
form, call (866) 632-9992.
Submit your completed form or letter to USDA by:

(1) Mail: U.S. Department of Agriculture

Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410

(2) Fax: (202) 690-7442; or
(3) Email: program.intake@usda.gov
This institution is an equal opportunity provider.
172

ATTACHMENT 13

APPLICATION AND PLANNING

Sample News Release:
Enrolled Sites and Camps

[Name of sponsor]
is participating in the Summer Food Service Program. Meals will be provided
to all eligible children free of charge. (To be eligible to receive free meals at a residential or non-residential camp,
children must meet the income guidelines for reduced-price meals in the National School Lunch Program. The
income guidelines for reduced-price meals by family size are listed on the next page.) Children who are part of
households that receive Supplemental Nutrition Assistance Program (SNAP, formerly foods stamps) benefits or
benefits under the Food Distribution Program on Indian Reservations (FDPIR), or Temporary Assistance to Needy
Families (TANF) are automatically eligible to receive free meals.
Acceptance and participation requirements for the Program and all activities are the same for all regardless of
race, color, national origin, sex, age or disability, and there will be no discrimination in the course of the meal
service. Meals will be provided at the sites and times as follows:
[list all sites and the starting and ending times of meal service for each site]

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies,
the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are
prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior
civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print,
audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits.
Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service
at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form,
(AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter
addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint
form, call (866) 632-9992.
Submit your completed form or letter to USDA by:

(1) Mail: U.S. Department of Agriculture

Office of the Assistant Secretary for Civil Rights
1400 Independence Avenue, SW
Washington, D.C. 20250-9410

(2) Fax: (202) 690-7442; or
(3) Email: program.intake@usda.gov

This institution is an equal opportunity provider

173

ATTACHMENT 13, CONTINUED

APPLICATION AND PLANNING

Sponsor/Site Agreement
for the Summer Food Service Program
Name of site:
Address of site:
Site supervisor:

Telephone:

The person named above agrees to:
1. Serve meals to all needy children 18 years of age and under (or persons 19 and over who are mentally or
physically disabled and participating in a public or private non-profit school program for the mentally or
physically disabled).
2. Serve meals that meet the minimum meal pattern requirements.
3. Provide adequate supervision during the meal service.
4. Maintain and submit promptly such reports and records that the sponsor requires.
5. Report to the sponsor any changes in the number of meals required as attendance fluctuates.
6. Report any other problems regarding the meal services.
7. Comply with civil rights laws and regulations.
8. Attend sponsor training sessions.

Site Supervisor

Date

Sponsor

Date

174

ATTACHMENT 14

APPLICATION AND PLANNING

Training Checklist
for Administrative Staff
Use this checklist for training sponsor administrative staff, including office assistants, clerks, bookkeepers,
secretaries, area supervisors, and monitors.

1. General explanation of the Program:
____ Purpose of the Program

____ Site eligibility

____ Recordkeeping requirements

____ Organized site activity

____ Meal requirements

____ Nondiscrimination compliance

2. How the Program operates:
____ How meals will be provided

____ The delivery schedule, if applicable

____ What records are kept and what forms are used

3. Special duties of Monitors (include if separate training is not held for monitors):
____ How to conduct site visits and reviews

____ Sites for which each monitor is responsible

____ Monitoring schedule

____ Reporting procedures

____ Office procedures

175

ATTACHMENT 15

APPLICATION AND PLANNING

Training Checklist
for Monitors
____ Sites for which they will be responsible
____ Conducting site visits and reviews
____ Monitoring schedules
____ Reporting and recordkeeping procedures
____ Follow-up procedures
____ Office procedures
____ Local sanitation and health laws
____ Civil Rights requirements
____ Reporting racial/ethnic data
____ Personal safety precautions, if necessary

176

ATTACHMENT 15, CONTINUED

APPLICATION AND PLANNING

Training Checklist
for Site Staff
1. General explanation of the Program
____ Purpose of the Program
____ Site eligibility
____ Importance of accurate records especially meal counts
____ Importance of organized activities at sites

2. How sites operate
A. For vended sites:
____ Types of meals to be served and the meal pattern requirements (provide planned menus)
____ Delivery schedules (give exact times)
____ Adjustments in the number of meals delivered
____ Facilities for storing meals
____ Who to contact about problems (name and phone number)
____ Approved level of meal service

B. For self-preparation sites:
____ Meal pattern requirements
____ Inventory (use inventory forms)
____ Meal adjustments (use production records)
____ Meal preparation adjustments

3. Recordkeeping requirements
____ Daily recordkeeping requirements
____ Delivery receipts (provide sample forms)
____ Seconds, leftovers and spoiled meals
____ Daily labor – actual time spent on food service and time and attendance records
____ Collection of daily record forms
____ Maintain copies of meal service forms

4. Monitors’ responsibilities (use site visit and review forms)
____ Duties and authority
____ Introduce monitors and discuss areas of assignment

177

ATTACHMENT 15, CONTINUED

APPLICATION AND PLANNING

Training Checklist
for Site Staff, Continued
5. Civil Rights requirements (use Site Supervisor’s Guide)
6. Other policies/issues
____ What to do in inclement weather and alternate service areas
____ How to handle unauthorized adults trying to eat meals
____ How to handle discipline
____ Review equipment, facilities, and materials available for recreational activities
____ Review trash removal requirements
____ Discuss corrective action
____ Nutrition education

178

ATTACHMENT 15, CONTINUED

MANAGING THE MEAL SERVICE

Meal Count Worksheet for Camps

Meal Count
Worksheet for
Camps

Date

Camper’s Name

Meals Code

B

L

S

B

L

S

B

L

S

B

L

S

B

L

S

B

L

S

B

L

S

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.

Total Eligible Meals:

Total Ineligible Meals:

Total Program Adult Meals:

Total Non-Program Adult Meals:

Site Supervisor/Designee Signature

Date

179

ATTACHMENT 16

MANAGING THE MEAL SERVICE

Sample Inventory Control Sheet
Name of site/sponsor:

On site:

Central kitchen:
Inventory period:

/

/

to

1. Food item

2. Purchase unit-­
size & description
(case, bag, can, lb.)

/

/

Beginning inventory: $

3. # of units on hand

4. Unit cost

Ending inventory

180

5. Total cost

$

ATTACHMENT 17

MANAGING THE MEAL SERVICE

Inventory Control Sheet Instructions

The value of the beginning inventory is determined by taking a physical count before the food service operation begins. The
value of the beginning inventory thereafter is the same as the ending inventory for the previous month.
A complete physical inventory of all purchased foods, commodities, and supplies on hand must be taken at the end of the
reporting period.
For ease in taking a physical count of foods in storage, arrange the items according to food groups in the storage area and
arrange each group in alphabetical order, for example, canned fruits and fruit juices - apples, apricots, etc. Store food in
cases, boxes, or other containers marked with the date received and cost per unit to facilitate the taking of inventories.
Column 1. Enter the name of the food item, such as corn, green beans, or mayonnaise.
Column 2. Enter the size pack, such as, 6/#10 case, #50 bag, or #10 can. If different size containers of the same food item are
on hand, use a separate line for each size and a separate line for each different unit cost of the same size pack.
Column 3. Enter the number of units (of the size shown in column 2) found on hand from actual count.
Column 4. Enter the unit cost for the size unit shown in column 2 (use the unit cost written on package or unit). Use

invoices to determine the unit cost per item and total food purchases for the reporting period.

Column 5. Obtain the total cost by multiplying the number of units (column 3) by the unit cost (column 4) and enter in

column 5. Add column 5 (total cost) on all pages for the inventory at the end of the month. This total is the

value of the ending inventory.

This is a permanent source document and must be retained for a period of three years following the date of submission
of the final claim for reimbursement for the fiscal year.

181

ATTACHMENT 17, CONTINUED

MANAGING THE MEAL SERVICE

Sample Daily Meal Count Form

Site Name:

Meal Type (circle) : B

Address:

L

SN

SU

Telephone:

Supervisor’s Name:

Delivery Time:

Date:

/

/

Meals received/prepared ______ + Meals available from previous day ______ = _______ (Total meals available)

[1]

First Meals Served to Children (cross off number as each child receives a meal):
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

42

43

44

45

46

47

48

49

50

51

52

53

54

55

56

57

58

59

60

61

62

63

64

65

66

67

68

69

70

71

72

73

74

75

76

77

78

79

80

83

84

85

86

87

88

89

90

91

92

93

94

95

96

97

98

99

100

101 102 103

104

105

106

107

108

109

110

111

112

113

114

115

116

117

118

119 120

121 122

123

124

125

126

127

128 129

130

131

132

133

134

135

136

137

138

139 140

141 142 143

144

145

146

147

148

150

81

82

149

18

19

20

[2]

Total First Meals +
Second meals served to children:
1 2

3

4

5

Total Second Meals +

[3]

Total Program Adult Meals +

[4]

6 7 8 9 10

Meals served to Program adults:
1 2

3

4

5

6 7 8 9 10

Meals served to non-Program adults:
1 2

3

4

5

Total non-Program Adult Meals +

6 7 8 9 10

[5]

TOTAL MEALS SERVED =

[6]

Total damaged/incomplete/other non-reimbursable meals +

[7]

Total leftover meals +

[8]

Total of items:

[6]

+ [7] + [8] =
[9]
(Item [9] should be equal to item [1])

Number of additional children requesting a meal after all available meals were served:
1 2

3

4

5

6

7

8

9 10

11

12

13

14

15

By signing below, I certify that the above information is true and accurate:

Signature

Date

182

ATTACHMENT 18

MANAGING THE MEAL SERVICE

Sample Daily Meal Count Form, Continued

Site Name:

Date:

/

/

First Meals Served to Children (cross off number as each child receives a meal):
151 152 153

154

155

156

157

158

159

160

161

162

163

164

165

166

167

168

169 170

171 172 173

174

175

176

177

178

179

180

181

182

183

184

185

186

187

188

189 190

191 192 193

194

195

196

197

198

199

200

201

202

203

204

205

206

207

208

209 210

211 212 213

214

215

216

217

218

219

220

221

222

223

224

225

226

227

228

229 230

231 232 233

234

235

236

237

238

239

240

241

242

243

244

245

246

247

248

249 250

Total First Meals +

[2]

Second meals served to children:
1 2

3

4

5

Total Second Meals +

[3]

Total Program Adult Meals +

[4]

Total non-Program Adult Meals +

[5]

6 7 8 9 10

Meals served to Program adults:
1 2

3

4

5

6 7 8 9 10

Meals served to non-Program adults:
1 2

3

4

5

6 7 8 9 10

TOTAL MEALS SERVED =

[6]

Total damaged/incomplete/other non-reimbursable meals +

[7]

Total leftover meals +

[8]

Total of items:

[6]

+ [7] + [8] =
[9]
(Item [9] should be equal to item [1])

Number of additional children requesting a meal after all available meals were served:
16 17 18 19 20 21 22 23 24 25 26 27 28 29 30

183

ATTACHMENT 18, CONTINUED

MANAGING THE MEAL SERVICE

Instructions for Meal Count Form - Daily
Each site must take a point-of-service meal count every day. This form may be used for the daily meal count.
1.

Line 1 equals the total meals available. That number equals the number of meals received or prepared plus the
number of meals available from the previous day.

2.

Line 2 equals the total number of first meals served to children. Cross out each number as a child receives a meal.
Include any teenagers, 18 and under, paid or unpaid, who are helping out at the site. (If more than 150 children are
served at the site, use the optional second page. For sites needing the second page, we suggest printing this form
front to back.)

3.

Line 3 equals the total number of second meals served to children. (Remember, reimbursable meals are limited to no
more than two percent of the total number of first meals served.)

4.

Line 4 equals the total number of meals served to Program adults. “Program adults” are adults who work directly
as part of the operation of the food service. This includes all adults who prepare meals, serve meals, clean up, or
supervise the children. This does not include teenagers, 18 and under, who may perform these tasks at the site.
Meals for children 18 and under are fully reimbursable, and you would count these meals on Line 2.

5.

Line 5 equals the total number of meals served to non-Program adults. “Non-Program adults” are adults who are not
directly involved in the operation of the food service. Non-Program adults include any sponsor administrative staff,
such as monitors or sponsor directors, or State or Federal reviewers.

6.

Line 6 equals the total number of meals served, which is the sum of Lines 2 – 5.

7.

Line 7 equals the total number of meals that are unusable because they are damaged, incomplete, or otherwise nonreimbursable.

8.

Line 8 equals the total number of leftover meals, which is calculated by subtracting Line 6 from Line 1.

9.

Line 9 equals the sum of Lines 6, 7, and 8. It accounts for all meals and should equal Line 1.

10. Use the line at the bottom of the form to record the number of children requesting a (first) meal after all available
meals were served. This information is helpful in adjusting meal orders upward.
11. The site supervisor must sign and date the meal count form.

184

ATTACHMENT 18, CONTINUED

MANAGING THE MEAL SERVICE

Sample Meal Count
(Weekly Consolidated)
Site Name:
Address And Phone Number:
Site Supervisor:

Meal Type:
(Circle) B L Sn Su

Week of:

Monday

Tuesday

Wednesday

Thursday

Friday

Saturday

/

Sunday

/

Total For
Week

1. Number of meals

received/prepared

2. Number of meals

available from previous
day

3. Number of first meals
served to children

4. Number of second
meals served to
children

5. Number of meals served
to Program adults

6. Number of meals served
to non-Program adults

7. Number of incomplete/
damaged meals

8. Number of leftover
meals

9. Number of additional

children requesting a
meal after all available
meals were served

10. Money collected/to

be collected for adult
meals

Remarks:

Signature of Site Supervisor:

185

ATTACHMENT 19

MANAGING THE MEAL SERVICE

Instructions for Meal Count Form (Weekly Consolidated)

1. Use this form to consolidate daily meal count information (see Attachment 20).
2. Use a separate consolidated meal count form for each meal type.
3. Information for Items 1 – 9 should be transferred directly from the Daily Meal Count Form for the week.
4. Information for Item 10, Money Collected/To Be Collected For Adult Meals, is not collected on the
Daily Meal Count Form.

5. When completed, this form must be signed and dated by the Site Supervisor.

186

ATTACHMENT 19, CONTINUED

MANAGING THE MEAL SERVICE

Sample Meal Count - Consolidation Form of
First (1st) and Second (2nd) Meals Served
Claim Period:

/

/

Site

to

/

Breakfast
1st Meal

2nd Meal

/
Lunch
1st Meal

2nd Meal

Snack
1st Snack

2nd Snack

Supper
1st Meal

2nd Meal

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
Total
Meal Type

(A)
Total 1st Meals/Snacks
Served

(B)
Total 2nd Meals/Snacks
Served

(C)
2nd Meal/Snack
Limitation
(.02 x A)

(D)
Allowable 2nd Meals/
Snacks – Lesser of (B)
or (C)

(E)
Allowable Total Meals/
Snacks
(A) + (D)

Breakfast
Lunch
Snack
Supper

187

ATTACHMENT 20

MANAGING THE MEAL SERVICE

Racial and Ethnic Data Form**
Sponsor:

Site:

Site Contact Name:

Title:

Site Address:

Date of visit:

Site Supervisor:

Ethnic Categories

Number or Participating Children

Hispanic or Latino
Not-Hispanic or Latino
Hispanic or Latino: A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin,
regardless of race. The term “Spanish origin” can be used in addition to “Hispanic or Latino.”

Racial Categories

Number or Participating Children*

American Indian or Alaska Native
Asian
Black or African American
Native Hawaiian or Other Pacific Islander
White
•

American Indian or Alaska Native: A person having origins in any of the original peoples of North and South America,
(including Central America), and who maintains tribal affiliation or community recognition.

•

Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent,
including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and
Vietnam.

•

Black or African American: A person having origins in any of the black racial groups of Africa. Terms such as “Haitian”
can be used in addition to “Black or African American.”

•

Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples of Hawaii, Guam,
Samoa, or other Pacific Islands.

•

White: A person having origins in any of the original peoples of Europe, the Middle East or North Africa.

Monitor’s Signature

Date

** Note: Based on OMB Notice, Revisions to the Standards for the Classification of Federal Data on Race and Ethnicity, published 10/30/97 and in FNS
Instruction 113-1, Civil Rights Compliance and Enforcement Nutrition Programs and Activities, published November 8, 2005. See Back for Instructions.

188

ATTACHMENT 21

MANAGING THE MEAL SERVICE

Racial and Ethnic Data Form Instructions
Instructions for Completing the Racial and Ethnic Data Form
• The sponsor should complete this form for each site under its jurisdiction each year. Sponsors of residential
camps must collect this information for each camp session. For all other sites, the sponsor must count the
participating children at least once during the site’s operation.
• The sponsor may use visual identification to determine a participant’s racial and ethnic category or the
parents of a participant may be asked to identify the racial and ethnic group of their child(ren). A participant
may be included in the group that he/she appears to belong, identifies with, or is regarded as a member by
the community.
• To provide flexibility and ensure data quality, separate categories shall be used when collecting and reporting
race and ethnicity. Ethnicity shall be collected first. Respondents shall be offered the option of selecting one
or more racial designations.
• The sponsor must retain racial and ethnic data, as well as documentation for the data for 3 years and must
safeguard this information to prevent its use for discriminatory purposes. Access to Program records
containing racial and ethnic data should be limited to authorized personnel.

189

ATTACHMENT 21, CONTINUED

RECORDKEEPING AND COST ACCOUNTING

Checklist of Records

Note: This is intended as a template and is not an all-inclusive list. Please check with your State agency to see if your State has other
record requirements.

1. Records that document eligibility for the Summer Food Service Program:

____ Approved agreement

____ Application

____ Site Information Sheet for each site

____ Evidence to show eligibility for each site based on serving needy children (or in the case of camps and

enrolled sites, evidence to show that children are individually documented as being eligible for free or
reduced-price school meals)
____ Public release
____ Letter from IRS showing tax-exempt status (for private non-profit sponsors)
____ Pre-operational site visit forms
____ Sponsor/site agreements
____ Documentation of training
____ Letter of engagement of CPA firm or independent accountant, or State or local government accountant and
management letter (if applicable)

____ Letter to health department

2. Records that support the number of meals served to children:

____ Daily count of milks delivered

____ Daily count of milks leftover

____ Daily count of meals prepared or received at sites

____ Daily count of complete first meals served to children

____ Daily count of complete second meals served to children

____ Daily count of meals served to Program and non-Program adults

____ Daily count of disallowed meals

____ Daily count of excess meals

3. Records that support food service costs:

____ Food inventories

____ Delivery receipts for vended meals

____ Payroll and time-and-attendance records for site personnel

____ Purchase invoices

4. Records that support administrative costs:

____ Payroll and daily time-and-attendance records for administrative personnel

____ Rental agreements for office equipment or space

____ Mileage records

190

ATTACHMENT 22

RECORDKEEPING AND COST ACCOUNTING

Checklist of Records, Continued

5. Records to support funds accruing to the Program:
____ Site records of cash collected
____ Copies of receipts given for cash donations
____ Records of any other funds received for the Summer Food Service Program

6. Other records:
____ Agreement with schools to furnish meals
____ Contract with a food service management company
____ Bid procedures used
____ Records and inventories of USDA-donated foods
____ Monitor’s reports of site visits and reviews
____ Records of training conducted
____ Menu records
____ Receipts, invoices, and bills for all rented or purchased items and services
____ Bank statements and deposit slips
____ Accounting ledgers
____ Sanitation and health reports
____ Certification of Independent Price Determination (FSMC contracts)
____ Beneficiary Data Form
____ Food Donations
____ Procurement Procedures
____ Written Standards of Conduct
____ All sponsor procedures which reflect the SFSP operations

191

ATTACHMENT 22, CONTINUED

RECORDKEEPING AND COST ACCOUNTING

Mileage Record –
Administrative Staff*
Name of Employee:
Date

Odometer
Reading: Start

Odometer
Reading: Stop

Number of
Miles

Signature of Employee

Itinerary

Date

* Use this form for any staff performing an administrative task (e.g. monitors, sponsor administrative staff visiting/reviewing sites).
Note: Mileage costs must be in the administrative budget approved by the State Agency.

192

ATTACHMENT 23

RECORDKEEPING AND COST ACCOUNTING

Mileage Record –
Site and Food Service Staff*
Name of Employee:
Date

Odometer
Reading: Start

Odometer
Reading: Stop

Number of
Miles

Signature of Employee

Itinerary

Date

* Use this form for any staff performing an operating task, specifically related to the food service (e.g. site staff, cooks, etc. transporting meals).
Note: Mileage costs must be in the administrative budget approved by the State Agency.

193

ATTACHMENT 24

RECORDKEEPING AND COST ACCOUNTING

Time Report –
Administrative Staff*
Sponsor name:

Sponsor Number:

Sponsor address:

Week of:

Hours Worked in SFSP Administration
Name

Hours
Per Day
S

M

Total
Hours
Weekly
T

W

T

F

Hourly
Wage

Total
Claimable

S

I understand that this information is being given in connection with the receipt of Federal funds and that deliberate
misrepresentation may subject me to prosecution under applicable State and Federal criminal statutes.

Supervisor’s signature

Date

*Use this form for administrative staff performing administrative cost tasks, that is, tasks related to the administration of the Program (e.g. monitors, book
keepers, office staff, directors).
Note: Administrative labor costs must be in the administrative budget approved by the State Agency

194

ATTACHMENT 25

RECORDKEEPING AND COST ACCOUNTING

Time Report –
Site and Food Service Staff*
Site/Sponsor name:

Site/Sponsor Number:

Site/Sponsor address:

Week of:

Date:

/

/

Hours Worked in Food Service
Name

Hours
Per Day
S

M

Total
Hours
Weekly
T

W

T

F

Hourly
Wage

Total
Claimable

S

I understand that this information is being given in connection with the receipt of federal funds and that deliberate
misrepresentation may subject me to prosecution under applicable state and federal criminal statutes.

Site supervisor’s signature

Date

* Use this form for all site-level and food service staff performing operating costs tasks, that is, tasks directly related to the food service (e.g. meal servers,
cooks, supervising children at the site).

195

ATTACHMENT 26

RECORDKEEPING AND COST ACCOUNTING

Summary of Administrative
Expenses
1. Name of sponsor :
2. Month and year:
3. Position (a)

# of People in
that position

Salary per
hour

(b)

(c)

# of hours
spent on SFSP
administration
(d)

Total

(e)

X

$

X

=

$

X

$

X

=

$

X

$

X

=

$

X

$

X

=

$

X

$

X

=

$

(f) Total salaries paid

$

4. Salaries (line 3f)

$______________

5. Transportation

$______________

6. Communication

$______________

7. Rental of office space

$______________

8. Office supplies

$______________

9. Utilities

$______________

10. Use allowance of furniture and fixtures

$______________

11. Audit fees

$______________

12. Legal fees

$______________

13. Office building maintenance

$______________

14. Other (specify)

$______________
$______________
$______________

15. TOTAL

$_____________

196

ATTACHMENT 27

RECORDKEEPING AND COST ACCOUNTING

Summary of Administrative Expenses, Continued

Item number:
1. Enter the name of the sponsor.
2. Enter the time period (month and year) covered by the form.
3. Enter:
A. the position,
B. the number of people working in that position,
C. the hourly salary rate they receive,
D. the number of hours they spend working with SFSP administration,
E. the total dollar amount spent on salaries for that position (b x c x d), and
F. add the total dollar amount spent on salaries for all positions.
4. Enter the total dollar amount spent on salaries during the month (line 3f).
5. Enter the total dollar amount spent on transportation during the month.
6. Enter the total dollar amount spent on communication during the month.
7. Enter the total dollar amount spent on the rental of office space during the month.
8. Enter the total dollar amount spent on office supplies during the month.
9. Enter the total dollar amount spent on utilities during the month.
10. Enter the total dollar amount spent on use allowance of furniture and fixtures.
11. Enter total dollar amount spent on audit fees.
12. Enter total dollar amount spent on legal fees.
13. Enter total dollar amount spent on office building maintenance.
14. Enter the total dollar amount spent on miscellaneous administrative supplies or services during the
month that do not fall under any of the categories mentioned above.
15. Add items 4 through 14 and enter the total administrative expenses for the month.
Be sure you collect and keep the receipts for all of the administrative expenses (i.e., canceled checks, gasoline
receipts, receipts for printing).

197

ATTACHMENT 27, CONTINUED

RECORDKEEPING AND COST ACCOUNTING

Worksheet for Cost of Food Used
1. Site
2. Month/year
3. Cost of food used:
A. Beginning inventory

$__________________________

B. Inventory adjustment (+ or -)

$__________________________

C. Purchases (including milk)

$__________________________

D. Total food available

$__________________________

E. Less ending inventory

$__________________________

F. Total cost of food used

$__________________________

Instructions
4. Enter name of site.
5. Enter month and year.
6. A. Enter dollar value of beginning inventory.
B. Enter amount of adjustment (plus or minus) for any transfer, spoilage, pilferage, etc. (explain any
adjustment on the back of this form).
C. Enter the dollar value of all food purchases made during the month. This should equal food
expenditures.
D. Enter the total of A + C (+ or -) B.
E. Enter dollar value of ending inventory.
F. Enter the total of D - E (total cost of food used).

198

ATTACHMENT 28

PROCUREMENT

Federal Contract Provisions
APPENDIX II TO PART 200—CONTRACT PROVISIONS FOR NON-FEDERAL ENTITY CONTRACTS UNDER
FEDERAL AWARDS
In addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the
non-Federal entity under the Federal award must contain provisions covering the following, as applicable.
(A) Contracts for more than the simplified acquisition threshold currently set at $150,000, which is the inflation
adjusted amount determined by the Civilian Agency Acquisition Council and the Defense Acquisition
Regulations Council (Councils) as authorized by 41 U.S.C. 1908, must address administrative, contractual,
or legal remedies in instances where contractors violate or breach contract terms, and provide for such
sanctions and penalties as appropriate.
(B) All contracts in excess of $10,000 must address termination for cause and for convenience by the nonFederal entity including the manner by which it will be effected and the basis for settlement.
(C) Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that
meet the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the
equal opportunity clause provided under 41 CFR 60-1.4(b), in accordance with Executive Order 11246,
“Equal Employment Opportunity” (30 FR 12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended
by Executive Order 11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,”
and implementing regulations at 41 CFR part 60, “Office of Federal Contract Compliance Programs, Equal
Employment Opportunity, Department of Labor.”
(D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all
prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision
for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146-3148) as supplemented by
Department of Labor regulations (29 CFR Part 5, “Labor Standards Provisions Applicable to Contracts
Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must
be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified
in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay
wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage
determination issued by the Department of Labor in each solicitation. The decision to award a contract or
subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity
must report all suspected or reported violations to the Federal awarding agency. The contracts must also
include a provision for compliance with the Copeland “Anti-Kickback” Act (40 U.S.C. 3145), as supplemented
by Department of Labor regulations (29 CFR Part 3, “Contractors and Subcontractors on Public Building or
Public Work Financed in Whole or in Part by Loans or Grants from the United States”). The Act provides that
each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the
construction, completion, or repair of public work, to give up any part of the compensation to which he or she
is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal
awarding agency.

199

ATTACHMENT 29

PROCUREMENT

Federal Contract Provisions, Continued

(E) Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts
awarded by the non-Federal entity in excess of $100,000 that involve the employment of mechanics or
laborers must include a provision for compliance with 40 U.S.C. 3702 and 3704, as supplemented by
Department of Labor regulations (29 CFR Part 5). Under 40 U.S.C. 3702 of the Act, each contractor must be
required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40
hours. Work in excess of the standard work week is permissible provided that the worker is compensated
at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40
hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide
that no laborer or mechanic must be required to work in surroundings or under working conditions which
are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or
materials or articles ordinarily available on the open market, or contracts for transportation or transmission
of intelligence.
(F) Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of
“funding agreement” under 37 CFR §401.2 (a) and the recipient or subrecipient wishes to enter into a contract
with a small business firm or nonprofit organization regarding the substitution of parties, assignment
or performance of experimental, developmental, or research work under that “funding agreement,” the
recipient or subrecipient must comply with the requirements of 37 CFR Part 401, “Rights to Inventions Made
by Nonprofit Organizations and Small Business Firms Under Government Grants, Contracts and Cooperative
Agreements,” and any implementing regulations issued by the awarding agency.
(G) Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387), as
amended—Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires
the non-Federal award to agree to comply with all applicable standards, orders or regulations issued
pursuant to the Clean Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended
(33 U.S.C. 1251-1387). Violations must be reported to the Federal awarding agency and the Regional office of
the Environmental Protection Agency (EPA).
(H) Debarment and Suspension (Executive Orders 12549 and 12689)—A contract award (see 2 CFR 180.220)
must not be made to parties listed on the government wide exclusions in the System for Award Management
(SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 (3 CFR
part 1986 Comp., p. 189) and 12689 (3 CFR part 1989 Comp., p. 235), “Debarment and Suspension.” SAM
Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well
as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549.
(I) Byrd Anti-Lobbying Amendment (31 U.S.C. 1352)—Contractors that apply or bid for an award exceeding
$100,000 must file the required certification. Each tier certifies to the tier above that it will not and has
not used Federal appropriated funds to pay any person or organization for influencing or attempting to
influence an officer or employee of any agency, a member of Congress, officer or employee of Congress, or
an employee of a member of Congress in connection with obtaining any Federal contract, grant or any other
award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with non-Federal funds that takes
place in connection with obtaining any Federal award. Such disclosures are forwarded from tier to tier up to
the non-Federal award.

200

ATTACHMENT 29, CONTINUED

PROCUREMENT

Federal Contract Provisions, Continued

(J) See §200.322 Procurement of recovered materials. A non-Federal entity that is a state agency or agency of a
political subdivision of a state and its contractors must comply with section 6002 of the Solid Waste Disposal
Act, as amended by the Resource Conservation and Recovery Act.
The requirements of Section 6002 include procuring only items designated in guidelines of the
Environmental Protection Agency (EPA) at 40 CFR part 247 that contain the highest percentage of recovered
materials practicable, consistent with maintaining a satisfactory level of competition, where the purchase
price of the item exceeds $10,000 or the value of the quantity acquired during the preceding fiscal year
exceeded $10,000; procuring solid waste management services in a manner that maximizes energy and
resource recovery; and establishing an affirmative procurement program for procurement of recovered
materials identified in the EPA guidelines.

201

ATTACHMENT 29, CONTINUED

PROGRAM INFORMATION

Comparison of Programs
SFSP/NSLP/SSO
This is a comparison between the various Child Nutrition Summer Meal Programs. The purpose of this comparison chart is to
inform and encourage more School Food Authorities (SFAs) to provide meals in the summer and other times when school is
not in session. Both the Summer Food Service Program (SFSP) and Seamless Summer Option (SSO) reduce paperwork and
administrative burden, making it easier for SFAs to feed children in low-income areas during the summer months or during
the extended breaks of a year-round school schedule.
Areas where the provisions in the SSO are same as SFSP, rather than NSLP, are highlighted as Same as SFSP.

Topic

SFSP

NSLP/SBP

SSOv

Eligible
Sponsors

SFAs, Local government
agencies, Private non-profit
organizations, Universities or
Colleges, Community & faith-based
organizations.
SFAs are waived of the requirement
to demonstrate financial and
administrative capability for
program operations.

SFAs

SFAs currently administering
the NSLP and/or SBP.

Times of
Operation

• May – September for traditional
school calendar areas
• October-April during
unanticipated school closures (i.e.
emergencies)
• During student vacations of 15
days or more for schools on a
continuous year calendar.

When school is in session as
established by the school district,
including summer school

• May – September for
traditional school calendar
areas.
• October-April during
unanticipated school closures
(i.e. emergencies).
• During student vacations of 10
days or more for schools on a
continuous year calendar.

Meal Service
Locations

Schools, Camps, Churches,
Community Centers, Housing
Projects, Libraries, Migrant Centers,
Parks, Playgrounds, Pools, and
Other public sites where children
gather.

Schools, Residential Child Care
Institutions (RCCIs).

Same as SFSP

Meal Cost for
Children

All meals are free. (Although camps
are only reimbursed for children
who qualify for free or reducedprice meals, camp sponsors may,
and usually do, provide meals free
of charge to all children).

Meal cost (free/reduced-price/
paid) for children is based on their
income eligibility.

Same as SFSP

202

ATTACHMENT 30

PROGRAM INFORMATION

Comparison of Programs SFSP/NSLP/SSO, Continued
Topic
Establishing
Site Eligibility

SFSP

NSLP/SBP

Open sites: In the attendance area
of a school or in a geographic area
defined by census data where 50
percent or more of the children
qualify for free or reducedprice school meals, and open to
community.

Schools: Public and private nonprofit schools of high school grade
and under that are part of State’s
education system.

Enrolled sites: 50 percent or
more of enrolled children are
eligible for free or reduced-price
meals, determined by approved
application, or operate in an eligible
area.

SSOv
Same as SFSP

RCCIs:
Public and licensed, non-profit,
private.

Migrant sites: Certification by a
migrant organization that the sites
serve children of migrant farm
workers.
Camps: Offer a regularly scheduled
food service as part of an organized
program for enrolled children.
*As applicable, alternative
forms of data may be used to
establish site eligibility, including
Special provision data (including
Community Eligibility) under NSLP/
SBP, and Census data.
Type of Meals

• Breakfast
• Lunch
• Snack (AM or PM)
• Supper

• Breakfast
• Lunch
• Afterschool Snacks

Same as SFSP

Breakfast
Lunch
Afterschool Snack

Same as SFSP

Breakfast must be served in the
morning hours; lunch must be offered
between 10:00 am and 2:00 pm.

Breakfast must be served in
the morning hours; lunch must
be offered between 10:00 am
and 2:00 pm; snacks must be
evenly and adequately spaced
between other meal service
times; supper meal times must
be established for each site.

Lunch & supper cannot be
reimbursed for the same day by
the same site, except for camp and
migrant sites.
Maximum
Number of
Meals

2 meals for most sites.

Meal Service
Time
Requirements

No time limits on duration of meal
service or amount of time that must
elapse between the beginning of
one meal and the beginning of the
next.

3 meals for migrant sites and
camps.

203

ATTACHMENT 30, CONTINUED

PROGRAM INFORMATION

Comparison of Programs SFSP/NSLP/SSO, Continued
Topic

SFSP

NSLP/SBP

SSOv

Claiming of
Second Meal

Up to 2% of the entire claim in any
given month.

N/A

May claim second breakfast
but cannot claim lunches and
snacks.

Commodities

1.5 cents per meal for sponsors
and self-prep sites
May also receive bonus
commodities, as available, in
accordance w/ statute.

24.75 cents per meal (2014-15
school year)
May also receive bonus
commodities, as available, in
accordance w/ statute.

Same as NSLP

Reimbursement
Rates

Calendar Year 2016

School Year 2015-16***

All eligible meals provided
under SSO reimbursed at
NSLP/SBP applicable free rates
for the school year beginning
July 1 of the prior calendar
year.
(SY 15-16). When the new rates
for the upcoming SY (SY 16-17)
become effective on July 1,
the new rates apply for meals
served in SSO from July 1 to the
end of the summer program.
Since the NSLP rates change on
July 1, the June and July claims
cannot be combined.

Type of
meal

Self-prep
or rural

All Other
Types of
Sites

Breakfast

2.0925

2.0375

Lunch or
Supper

3.6850

3.5875

Snack

0.8650

0.8450

*For the contiguous States only; rates
for Alaska & Hawaii are higher.

Type of
meal

Breakfast*

Lunch
**

Snack

Paid

.29

.43

.07

R/P

1.69

2.90

.42

Free

1.99

3.30

.84

*Includes severe need payment.
**Includes additional 6 cents
performance- based reimbursement.
***For the contiguous States only; rates
for Alaska & Hawaii are higher.

Reimbursement
Method

SFSP sponsors receive the
maximum reimbursement (meals
times rates) without regard to their
actual or budgeted costs.
Sponsors may use reimbursements
to pay for any allowable program
cost.
Camps are reimbursed only for
meals served to eligible children.

Total meals by type times the free,
reduced, or paid rate for each type
of meal.
Extra $.02 per lunch if 60 percent
or more of lunches in second
preceding year were free or
reduced-price.
Additional payments for free or
reduced-price breakfasts in severe
need schools.

If area eligible, all meals
reimbursed at NSLP/SBP free
rate.
Extra reimbursements available
under NSLP/SBP provided
under SSO, as applicable.
If applications required (camps
or closed enrolled in noneligible area), free and reducedprice meals reimbursed
at free NSLP/SBP rate; no
reimbursement for paid meals
at these sites.

Required
Monitoring by
SFA/Sponsors

Pre-operational visits before a
new or problem site operates the
summer program.
Site visits the first week of
operation (waived for sites that
operated successfully the previous
summer).
Site review during first 4 weeks of
operation, followed by additional
monitoring as needed.

On site review of lunch counting
and claiming system for each
school by Feb. 1st each year.

Review of meal counting,
claiming and meal pattern
and food safety compliance at
least once during each site’s
operation.

204

ATTACHMENT 30, CONTINUED

PROGRAM INFORMATION

Comparison of Programs SFSP/NSLP/SSO, Continued
Topic

SFSP

NSLP/SBP

SSOv

Required
Monitoring by
State agency

Review every 3 years; more
frequently based on program size
and prior problems identified by
the State agency.

Review every 3 years or more if
there is an ongoing audit.

SA must review at least one
SSO site in operation at all SFAs
scheduled for an administrative
review. The review may be
conducted in the summer prior
to or following the scheduled
administrative review.

Meal Pattern

Meal pattern must meet 7 CFR
225.16(d) standards, though School
Food Authorities may substitute
NSLP/SBP meal patterns.

Must meet requirement for NSLP
in 7 CFR 210.10; or SBP in 7 CFR
220.8.

Same as NSLP/SBP*
*Additional flexibilities granted
in specific circumstances:
Refer to policy memo SP-39­
2014, “Questions and Answers
for the National School Lunch
Program’s Seamless Summer
Option.”

Offer vs.
Serve Option

Optional for all SFSP sites.

Optional for at all grade levels for
breakfast and required at high
school level only for lunch.

Optional but if elect to use, must
follow OVS requirements of
NSLP and SBP.

Eligible
Participants

Persons 18 years or younger and
persons 19 or older with a physical
or mental disability, as defined by
the State.

Students enrolled in a school
of high school grade and under
determined by the SA; including
persons enrolled in a school
program for the mentally or
physically disabled; and persons
under 21 enrolled in a RCCI.

Same as NSLP/SBP

Public
Notification

Sponsor must send public media
notice regarding program and
eligibility.

SFA must send public media
notice regarding program and
letter or notice with an application
to parents for all children in
attendance at the school at the
beginning of each school year.

Public media notice may be
done but is not required
SFA must state in application
how each site (excluding closed
enrolled sites) will promote the
availability of meals to children
in the community.

205

ATTACHMENT 30, CONTINUED

PROGRAM INFORMATION

Income Eligibility Guidelines
[Effective from July 1, 2015 to June 30, 2016]
Federal
poverty
guidelines

Household size

Reduced price meals—185%
Annual

Monthly

Annual

Twice
per
month

Every
two
weeks

Free meals—130%
Weekly

Annual

Monthly

Twice
per
month

Every
two
weeks

Weekly

48 Contiguous States, District of Columbia, Guam and Territories
1 ..............................................................

11,770

21,775

1,815

908

838

419

15,301

1,276

638

589

295

2 ..............................................................

15,930

29,471

2,456

1,228

1,134

567

20,709

1,726

863

797

399

3 ..............................................................

20,090

37,167

3,098

1,549

1,430

715

26,117

2,177

1,089

1,005

503

4 ..............................................................

24,250

44,863

3,739

1,870

1,726

863

31,525

2,628

1,314

1,213

607

5 ..............................................................

28,410

52,559

4,380

2,190

2,022

1,011

36,933

3,078

1,539

1,421

711

6 ..............................................................

32,570

60,255

5,022

2,511

2,318

1,159

42,341

3,529

1,765

1,629

815

7 ..............................................................

36,730

67,951

5,663

2,832

2,614

1,307

47,749

3,980

1,990

1,837

919

8 ..............................................................

40,890

75,647

6,304

3,152

2,910

1,455

53,157

4,430

2,215

2,045

1,023

For each additional family member add

4,160

7,696

642

321

296

148

5,408

451

226

208

104

Alaska
1 ..............................................................

14,720

27,232

2,270

1,135

1,048

524

19,136

1,595

798

736

368

2 ..............................................................

19,920

36,852

3,071

1,536

1,418

709

25,896

2,158

1,079

996

498

3 ..............................................................

25,120

46,472

3,873

1,937

1,788

894

32,656

2,722

1,361

1,256

628

4 ..............................................................

30,320

56,092

4,675

2,338

2,158

1,079

39,416

3,285

1,643

1,516

758

5 ..............................................................

35,520

65,712

5,476

2,738

2,528

1,264

46,176

3,848

1,924

1,776

888

6 ..............................................................

40,720

75,332

6,278

3,139

2,898

1,449

52,936

4,412

2,206

2,036

1,018

7 ..............................................................

45,920

84,952

7,080

3,540

3,268

1,634

59,696

4,975

2,488

2,296

1,148

8 ..............................................................

51,120

94,572

7,881

3,941

3,638

1,819

66,456

5,538

2,769

2,556

1,278

For each additional family member add

5,200

9,620

802

401

370

185

6,760

564

282

260

130

Hawaii
1 ..............................................................

13,550

25,068

2,089

1,045

965

483

17,615

1,468

734

678

339

2 ..............................................................

18,330

33,911

2,826

1,413

1,305

653

23,829

1,986

993

917

459

3 ..............................................................

23,110

42,754

3,563

1,782

1,645

823

30,043

2,504

1,252

1,156

578

4 ..............................................................

27,890

51,597

4,300

2,150

1,985

993

36,257

3,022

1,511

1,395

698

5 ..............................................................

32,670

60,440

5,037

2,519

2,325

1,163

42,471

3,540

1,770

1,634

817

6 ..............................................................

37,450

69,283

5,774

2,887

2,665

1,333

48,685

4,058

2,029

1,873

937

7 ..............................................................

42,230

78,126

6,511

3,256

3,005

1,503

54,899

4,575

2,288

2,112

1,056

8 ..............................................................

47,010

86,969

7,248

3,624

3,345

1,673

61,113

5,093

2,547

2,351

1,176

For each additional family member add

4,780

8,843

737

369

341

171

6,214

518

259

239

120

206

ATTACHMENT 31

State Contact Information

Alabama Department of Education
http://www.alsde.edu/
Phone: 334-242-1988
Fax: 334-353-5388

Georgia Department of Early Care
and Learning
http://decal.ga.gov/
Phone: 404-656-5957
Fax: 404-651-7184

Maryland Department of Education
http://marylandpublicschools.org/MSDE/
programs/schoolnutrition/index.html
Phone: 410-767-0199
Fax: 410-333-2635

Alaska Department of Education & Early
Development
http://www.eed.state.ak.us/tls/cnp/
Phone: 907-465-8710
Fax: 907-465-8910

Hawaii Department of Education
http://ohcnp.k12.hi.us/programs/index.htm
Phone: 808-587-3600
Fax: 808-587-3606

Arizona Department of Education

Idaho Department of Education

http://www.azed.gov/health-nutrition/
Phone: 602-542-8700
Fax: 602-542-3818

http://www.sde.idaho.gov/site/cnp/
Phone: 800-432-4601
Fax: 208-334-2228

Arkansas Department of Human Services

Illinois State Board of Education

https://dhs.arkansas.gov/dccece/snp/
WelcomeSNPM.aspx
Phone: 800-482-5850 ext 28869
Fax: 501-682-2334

http://www.isbe.state.il.us/nutrition/default.htm
Phone: 800-545-7892
Fax: 217-524-6124

Indiana Department of Education
California Department of Education

Massachusetts Department of Elementary
& Secondary Education
http://www.doe.mass.edu/cnp/nprograms/sfsp/
Phone: 781-338-6480
Fax: 781-338-3399

Michigan Department of Education
http://www.michigan.gov/mde/0,4615,7-14066254---,00.html
Phone: 517-373-4013
Fax: 517-373-4022

Minnesota Department of Education
http://education.state.mn.us/MDE/JustParent/
SchSummerMeal/
Phone: 651-582-8543
Fax: 651-582-8501

Fax: 916-445-4842

http://www.doe.in.gov/student-services/
nutrition
Phone: 317-232-0850
Fax: 317-232-0855

Colorado Department of Education

Iowa Department of Education

http://www.mde.k12.ms.us/OCN/SFSP
Phone: 601-576-5005
Fax: 601-576-1417

http://www.cde.state.co.us/index_nutrition.htm
Phone: 303-866-6934
Fax: 303-866-6663

http://educateiowa.gov/
Phone: 515-281-4757
Fax: 515-281-6548

Missouri Department of Health &
Senior Services

Connecticut Department of Education

Kansas Department of Education

http://www.sde.ct.gov/sde/site/default.asp
Phone: 860-807-2050
Fax: 860-807-2127

http://www.kn-eat.org/CNW/CNW_Menus/
index.htm
Phone: 785-296-2276
Fax: 785-296-0232

http://www.cde.ca.gov/fg/aa/nt/
Phone: 800-952-5609

DC Office of the State Superintendent
of Education
http://www.osse.dc.gov
Phone: 202-741-5252
Fax: 202-724-7656

Kentucky Department of Education
http://education.ky.gov/federal/SCN/Pages/
Summer-Food-Service-Program-(SFSP).aspx
Phone: 502-564-5625
Fax: 502-564-5519

Delaware Department of Education
http://www.doe.k12.de.us
Phone: 302-735-4060
Fax: 302-739-4654

Louisiana Department of Education
http://www.louisianabelieves.com/
Phone: 225-342-3720
Fax: 225-342-3305

Florida Department of Agriculture &
Consumer Services

Maine Department of Education

http://www.freshforfloridakids.com/
Phone: 800-504-6609
Fax: 850-617-7402

http://www.maine.gov/doe/
Phone: 207-624-7909
Fax: 207-624-6841

207

Mississippi Department of Education

http://www.dhss.mo.gov
Phone: 573-751-6269
Fax: 573-526-3679

Montana Division of Health
Enhancement and Safety
http://opi.mt.gov/Programs/SchoolPrograms/
School_Nutrition/Summer.html
Phone: 406-444-2501
Fax: 406-444-2955

Nebraska Department of Education
http://www.education.ne.gov/NS/index.html
Phone: 402-471-3566
Fax: 402-471-4407

Nevada, Department of Agriculture
http://nutrition.nv.gov/Programs/Summer_
Food_Program_(SFSP)/
Phone: 775-353-3600
Fax: 775-353-3661

New Hampshire Department of Education

Oregon Department of Education

Vermont Department of Education

http://education.nh.gov/program/nutrition/
food_svc.htm
Phone: 603-271-3494
Fax: 603-271-1953

http://www.ode.state.or.us/search/
results/?id=208
Phone: 503-947-5600
Fax: 503-378-5156

http://education.vermont.gov/nutrition/
summer-food-programs
Phone: 802-479-1207
Fax: 804-479-1822

New Jersey Department of Agriculture

Pennsylvania Department of Education

Virgin Islands Department of Education

http://www.state.nj.us/agriculture/divisions/fn/
Phone: 609-984-0692
Fax: 609-984-0878

http://www.education.pa.gov/Teachers%20
-%20Administrators/Food-Nutrition/Pages/
Summer-Food-Service-Program.aspx#.
VtmbRFVOmpo
Phone: 800-331-0129
Fax: 717-787-7698

http://www.vide.vi/
Phone: 340-774-0100, ext 2811
Fax: 340-774-9705

New Mexico Children Youth &
Families Department
https://cyfd.org/family-nutrition
Phone: 505-827-9961
Fax: 505-827-9957

New York Department of Education
http://portal.nysed.gov/portal/page/portal/CNKC
Phone: 518-473-8781
Fax: 518-473-0018

North Carolina Department of
Public Instruction
http://childnutrition.ncpublicschools.gov/
programs/summer-nutrition-opportunities
919-807-3507
Fax: 919-807-3516

North Dakota Department of
Public Instruction

Puerto Rico Child Nutrition Program
150 Federico Costa St.
Phone: 787-773-6273
Fax: 787-753-8155

Rhode Island Department of Education
http://www.ride.ri.gov/cnp/NutritionPrograms/
SummerFoodServiceProgram.aspx
Phone: 401-222-4253
Fax: 401-222-6163

South Carolina Department of Education
http://ed.sc.gov/districts-schools/nutrition/
summer-food-program/
Phone: 803-734-8194
Fax: 803-737-4148

http://www.dpi.state.nd.us/child/programs.
shtm
Phone: 701-328-4565
Fax: 701-328-2461

South Dakota Department of Education

Ohio Department of Education

Tennessee Department of
Human Services

http://education.ohio.gov/Topics/OtherResources/Food-and-Nutrition/Summer-FoodService-Program/2015-Summer-Food-ServiceProgram
Phone: 877-644-6338
Fax: 614-752-7613

http://doe.sd.gov/cans/sfsp.aspx
Phone: 605-773-4746
Fax: 605-773-6846

http://www.tn.gov/humanservices/article/csssummer-food-service-program
Phone: 615-313-4749
Fax: 615-741-4165

Texas Department of Agriculture
Oklahoma Department of Education
http://sde.ok.gov/sde/summer-foodservice-program
Phone: 405-521-3327
Fax: 405-521-2239

http://www.squaremeals.org
Phone: 877-839-6325
Fax: 888-203-6593

Utah State Office of Education
http://www.schools.utah.gov/cnp/
Phone: 801-538-7513
Fax: 801-538-7883

208

Virginia Department of Health
http://www.vdh.virginia.gov/livewell/
programs/sfsp/
Phone: 804-864-7800
Fax: 804-864-7853

Washington Office of Superintendent of
Public Instruction
http://www.k12.wa.us/childnutrition/
Phone: 360-725-6200
Fax: 360-664-9397

West Virginia Department of Education
http://wvde.state.wv.us/child-nutrition/
Phone: 304-558-2708
Fax: 304-558-1149

Wisconsin Department of
Public Instruction
http://dpi.wi.gov/community-nutrition/sfsp
Phone: 608-266-7124
Phone: 608-267-9123

Wyoming Department of Education
https://edu.wyoming.gov/beyond-theclassroom/nutrition/summer-food/
Phone: 307-777-7168
Fax: 307-777-8924

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