Wednesday, September 2, 2020
Announcements from the WI DPI School Nutrition Team (SNT)
- Important Updates
PLEASE NOTE: All waivers below were extended through December 31, 2020. However, USDA Food and Nutrition Service (FNS) reserves the right to withdraw any or all of these waivers subject to availability of funding.
School meals may be served under the National School Lunch and School Breakfast Programs to students based on eligibility or through the National School Lunch Program Seamless Summer Option (SSO) or Summer Food Service Program (SFSP).
The waivers below apply to those School Food Authorities (SFAs) and sponsoring agencies that choose to utilize the SSO or SFSP through December 31, 2020. For information regarding the operation of the National School Lunch Program (NSLP) and School Breakfast Program (SBP) for school year 2020-21, check out the Serving School Meals Under the NSLP During COVID-19 in SY 2020-21 Q&A located on our School Meals Program COVID-19 Information webpage.
IMPORTANT: To participate in the NSLP’s SSO, you must complete an SSO application, which will provide automatic approval. To participate in the SFSP, you must update your SFSP contract ASAP following the instructions provided in the SFSP Requirements and Deadlines guidance.
What do the USDA Nationwide Waivers Mean?
This waiver removes the requirement to collect income eligibility applications to determine that 50 percent of the children are eligible for free and reduced price meals in SFSP and SSO closed enrolled sites.
What does this mean? A closed enrolled site is a site that serves only an identified group of children age 18 and under, who are participating in a specific program or activity. This is not an option for a school site providing an academic program (virtual or in person). Only non-school sites can be closed enrolled sites under SSO or SFSP. Non-school closed enrolled SFSP or SSO sites do not have to determine eligibility by collecting and determining income applications. All student meals can be claimed at the free rate.
Determine how your SFA will operate the SSO or SFSP. There are three types of sites:
- Open - all children, 18 and under in the community, eat free. Schools and non-school sites can elect this option. Meals must be made available to the community for children 18 and under.
- Restricted Open - sites that meet the open site criteria, explained above, but are later restricted for safety, control, or security reasons. Serves children age 18 and under. Schools and non-school sites can elect this option.
NOTE: Schools need to follow some sort of “open” concept. An example might be making meals available to other household members (age 18 and under) of enrolled students. Schools could choose to serve meals just one day a week at a school or community site and provide a week's worth of meals at once for community participants. This may help schools to meet the open requirement but who don’t have the ability to do this daily, particularly when students are back in buildings.
- Closed Enrolled - A site that serves only an identified group of children age 18 and under, who are participating in a specific program or activity. Only non-school sites can participate as a closed enrolled site this fall. School sites providing instruction must participate as an open or restricted open site.
This waiver removes the requirement for SFSP sponsors to visit each of their sites at least once during the first week of operation under the program, for sites that have operated successfully in the previous year and sponsors that successfully participate in the Child and Adult Care Food Program (CACFP) or the National School Lunch Program (NSLP).
What does this mean? Only the full monitoring review to be completed prior to the end of the fourth week of operation is required for SFSP sites that have operated successfully in the SFSP during the prior year or have successfully participated in the CACFP or NSLP. The site review only needs to be completed once per calendar year unless problems are identified during the site review and follow-up is warranted. For new sites that do not fall into the described situation, all site monitoring is required — pre-operational visit, first week visit, and full review prior to the end of the 4th week of operation.
This waiver removes the 1) required minimum elapsed time between meal services and maximum durations of individual meals services in the SFSP and 2) parameters on the timing of lunches and breakfasts under the National School Lunch and School Breakfast Programs for the SSO.
What does this mean? SFAs and sponsoring agencies can serve meals when it is most convenient for households. Multiple days’ worth of meals may be served all together, lunch served with breakfast for the next day or any other combination.
This waiver allows all SFSP sites to use Offer versus Serve (OVS). OVS is designed for congregate feeding and, if used in a non-congregate setting, must be done so with thoughtful planning and consideration. The conditions under which sponsors are operating and their ability to follow appropriate safety measures in providing meals are factors to consider. OVS is not intended to be a way to circumvent meal pattern requirements, or eliminate specific components.
What does this mean? OVS is now allowed in SFSP as well as in SSO, NSLP and the SBP.
This waiver allows SSO and SFSP sites to operate as open sites (i.e. providing free meals to all children 18 and under in the community) in areas that are not located in “areas in which poor economic conditions exist”.
What does this mean? SFAs and sponsoring agencies may operate open meal sites without having to meet the requirement of at least 50 percent of the children receiving meals being eligible for free or reduced-price meals. For example, if a school or sponsoring agency typically serves a population that is 22 percent free and reduced-price, this site can operate as an open site, providing free meals to all children in the community even if they do not meet the 50 percent eligibility requirement. If implementing SSO or SFSP this school year, schools and sponsoring agencies must continue their plan for ensuring that meal sites are targeting benefits to children in need.
This waiver allows SFAs and sponsoring agencies the ability to ask for flexibility to serve meals that do not meet the meal pattern requirements. This includes the requirement that SFAs must offer students a variety of at least two different options of fluid milk at breakfast and lunch.
What does this mean? SFAs and sponsoring agencies can continue to request flexibilities for meal pattern requirements. Flexibilities must be approved by a member of the School or Community Nutrition Team.
Meal pattern waiver requests are approved on a case-by-case basis. Justifications that may be approved include: procurement/availability issues, unresolvable food safety concerns, sodium, milk, whole grain requirements for SY 2020-21, and minimizing potential exposure to COVID-19 while supporting nutritious meals. Requests will not be approved due to preference, student acceptance, and waste.
In the Question and Answers for the Child Nutrition Programs during SY 2020-21 #5, USDA announced that the 2018 Final Rule, Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements (83 FR 63775, December 12, 2018) has been vacated due to a court ruling on the matter. School meal patterns must return to the 2012 standards, defined in 7 CFR 210.10(c) and 220.8(c), as follows:
- Flavored milk may be only non-fat in the NSLP, SBP, and CACFP;
- All grains served in the NSLP and SBP must be whole-grain rich; and,
- School meals offered through the NSLP and SBP must meet Target 2 weekly sodium levels.
FNS understands that procurement for SY 2020-2021 was underway when this court decision was made. Therefore, SFAs may submit a Meal Pattern Flexibility Waiver for SY 2020-21 if the 2012 requirements cannot be met. All SFAs, including those who apply for the Meal Pattern Flexibility Waiver for SY 2020-21, must return to the 2012 requirements, listed above, for the 2021-22 school year.
This waiver removes the requirement that SSO and SFSP meals must be served in a congregate setting and consumed by participants on site.
What does this mean? If your SFA is utilizing the SSO for school meals, all students receiving virtual instruction must be offered meals, including those in district virtual academies who typically do not have access to the NSLP or SBP. Whereas, in contrast, if your SFA is utilizing the National School Lunch and School Breakfast Programs, serving students receiving virtual instruction is optional. Make sure to fill out the Non-Congregate Feeding Waiver for SY 2020-21 to let us know your plans.
Meals served in the cafeteria or classroom are considered congregate meals. In non-congregate settings, such as a pick-up site, SFAs and sponsoring agencies may provide meals to students to take home for consumption. Meals may be picked up or delivered.
This waiver removes the requirement that meals must be served to eligible children. It allows Program operators the ability to distribute meals to a parent or guardian to take home to their children. There must be a plan in place for ensuring that Program operators are able to maintain accountability and program integrity. Meals should only be distributed to parents or guardians of eligible children, and duplicate SSO and SFSP meals are not distributed.
What does this mean? Parents and guardians of eligible children may pick up meals on their students’ behalf for consumption in the home. SFAs and sponsoring agencies cannot provide duplicate meals to students.
This waiver allows SFAs and sponsoring agencies the ability to operate the SSO and SFSP through December 31, 2020. This facilitates the safe provision of meals by eliminating the need to collect meal payments, including cash payments, at meal sites. Operating SSO or SFSP speeds up service of meals, reducing contact and potential exposure to COVID-19. This eliminates the need for a point-of-service during curbside pick-up to track and claim meals. Program staff may simply keep a count of all meals served.
NOTE: The SSO and SFSP may be implemented with any method of educational instruction; whether in-person, virtual, or any variation of instruction. Under the SSO and SFSP, meals must be offered to all students, including virtual learners.
For more information on the SSO or SFSP, visit the Emergency Summer Meals COVID-19 Information webpage. We are working on putting together Serving School Meals under SSO or SFSP During COVID-19 in SY 2020-21 Q&A, which will include common questions and answers related to the SSO and SFSP. Make sure to check this document frequently as things have been changing quickly.
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This institution is an equal opportunity provider.
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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