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School Nutrition Bulletin 1819 Special Edition #3

Monday, April 22, 2019

From the WI DPI School Nutrition Team (SNT)

 

Paid Lunch Equity: Guidance for School Year 2019-20

Action required by all School Food Authorities (SFAs): SFAs are required to complete this Paid Lunch Equity Survey before June 7, 2019. This survey will take less than 5 minutes to complete and will serve as documentation on how pricing SFAs intend to comply with the guidance described below.

Note: Residential Child Care Institutions (RCCIs), SFAs participating in Provision 2, participating in Community Eligibility Provision (CEP) SFA-wide, or are non-pricing (do not charge for meals) should complete the Paid Lunch Equity Survey, but do not complete the Paid Lunch Equity Tool.

USDA Policy Memorandum SP 27-2019 Paid Lunch Equity: Guidance for School Year 2019-20
Section 760 of the Consolidated Appropriations Act, 2019 (Public Law 116-6) (the Appropriations Act), Congress provides that only SFAs that had a negative balance in the nonprofit school food service account as of December 31, 2018, shall be required to establish prices for paid lunches according to the Paid Lunch Equity (PLE) provisions in Section 12(p) of the Richard B. Russell National School Lunch Act, 42 U.S.C. 1760(p) and implemented in National School Lunch Program regulations at 7 CFR 210.14(e).

Consistent with the terms of the Appropriations Act, USDA Policy Memorandum SP 27-2019 provides notice that any SFA with a positive or zero balance in its nonprofit school food service account as of December 31, 2019, is exempt from PLE requirements found at 7 CFR 210.14(e) for school year (SY) 2019-20.

SFAs that had a negative balance in the nonprofit school food service account as of December 31, 2018, must follow PLE requirements when establishing their prices for paid lunches in SY 2019-20.

IMPORTANT: We would like to emphasize that SFAs still maintain the option to complete the steps necessary to determine their target SY 2019-20 paid lunch price, consistent with program regulations at 7 CFR 210.14, and adjust their paid meal prices accordingly.

Paid Lunch Equity Tool
Pricing SFAs with a negative balance in the nonprofit school food service account as of December 31, 2018, must complete the SY 2019-20 PLE Tool to establish prices for paid lunches for SY 2019-20.

Pricing SFAs with zero or positive balances may want to consider completing, at a minimum, the “Unrounded Requirement Finder” tab of the SY 2019-20 PLE Tool, located on the School Nutrition Team Financial Management webpage. The completion of this tab on the PLE Tool ensures that SFAs have the minimal amount of paid lunch price data needed to inform the calculation moving forward should they ever need to complete the PLE Tool in the future.

The Paid Lunch Equity Exemption Form
State agencies are required to demonstrate oversight of the PLE provision and maintain documentation that includes a record showing each SFA implementing the exemption had a positive or zero balance in the nonprofit school food service account as of December 31, 2018.

All SFAs are required to complete the online Paid Lunch Equity Survey, and we have structured the PLE Survey to also act as your SFA's PLE Exemption Form, depending on your response. If you know your nonprofit school food service account balance as of December 31, 2018, you should be able to complete and submit the online form in less than 5 minutes.

Once you submit the PLE Survey/Exemption Form, you will be sent a copy of your responses via email for your records.

Paid Lunch Equity Q&A
Q1. What if my pricing SFA does not complete the PLE Exemption Form?
A1. The PLE Survey (which also acts as your SFA’s PLE Exemption Form) is a requirement for all pricing SFAs. Failure to complete this form will delay approval of your online contract and possibly result in a claims withholding.

Q2. My SFA has completed the PLE Survey. Is there a separate exemption form?
A2. No, the results of the PLE Survey will also serve as the PLE Exemption Form record, based on your response.

Q3. When should the online PLE Exemption Form be submitted by?
A3. The PLE Survey (which is also the PLE Exemption Form) should be completed by June 7, 2019.

Q4. My SFA is a CEP mixed district. Do I need to complete the PLE Survey/Exemption Form?
A4. Yes. SFAs that are CEP mixed districts will need to complete the PLE Survey.

Q5. If we plan to use the PLE Tool and will not apply for a PLE exemption, does my SFA still complete the PLE Survey?
A5. Yes, all SFAs need to complete the PLE Survey/Exemption Form.

Q6. Do I need to keep the email that provides a copy of my responses to the PLE Survey/Exemption Form?
A6. Yes. This is considered a record which documents compliance and is subject to record keeping requirements (3 years plus the current year).

Q7: Our SFA will update our Online Contract for SY 2019-20 in May. If the PLE Survey/Exemption Form supports and documents that our agency qualifies for the PLE exemption, what should be uploaded into the Online Contract where a copy of the PLE Tool is requested?
A7: When your SFA qualifies for the PLE exemption (because your SFA had a zero or positive balance), and you’ve indicated that your SFA is not completing the PLE Tool, do not upload anything where the PLE Tool is requested. If your SFA did not qualify for an exemption, or if your SFA elected to still complete the PLE Tool and increase prices accordingly, the PLE Tool must be uploaded into the SY 2019-20 Online Contract.

Q8. My SFA is non-pricing (district-wide CEP, Provision 2, or do not charge for any meals). Do I need to complete the PLE Survey/Exemption Form?
A8. Yes, all SFAs need to complete the PLE Survey/Exemption Form.

Q9. My SFA will be completing the PLE Tool. Is the PLE Tool posted online?
A9. Yes. We’ve also attached the PLE Tool to this email, or you can access it online. When you click on the PLE Tool SY 19-20, an excel icon will pop up in the lower left of your screen. Be sure to click on the “Enable Editing” button for the Excel sheet to appear.
 

Questions? Please email the School Nutrition Team at dpifns@dpi.wi.gov.

School Nutrition Bulletin 1819 Special Edition #3, 4/22/19
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This is a communication from the WI Department of Public Instruction, School Nutrition Team.
You can contact the School Nutrition Team at dpifns@dpi.wi.gov. To subscribe to schoolmealsnews, please send an email to dpifns@dpi.wi.gov.
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WI DPI School Nutrition Team · PO Box 7841 · WI Department of Public Instruction · Madison, WI 53707-7841 · USA