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School Nutrition Bulletin 2122-44

Thursday, May 19, 2022

Announcements from the WI DPI School Nutrition Team (SNT)

May 19th was WI School Garden Day! Check out this Video from our AmeriCorps Farm to School Staff!
 

Updates from the U.S. Department of Agriculture (USDA)
 

Two Additional Waiver Opportunities

USDA announced late last week two additional waiver opportunities. These waivers provide needed flexibility and allow State and local Program operators to overcome challenges resulting from COVID-19. USDA Food and Nutrition Service (FNS) expects Program operators will only use these flexibilities for the duration and extent that they are needed.

  • Waiver 25: Paid Lunch Equity [42 U.S.C. 1760(p)(2) and 7 CFR 210.14(e)] (July 1, 2022-June 30, 2023)
  • Waiver 26: Use of Prior Year Eligibility Determinations for School Year 2022-2023 Carryover [42 U.S.C. 1758(b)(C) and 7 CFR 245.6(c)(2)] (July 1, 2022-June 30, 2023)

More information about and how to apply for these waivers is forthcoming.

USDA Policy Memorandum SP 10-2022: Area Eligibility for Summer 2022 and School Year 2022-23

School Food Authorities (SFAs) that operated the National School Lunch Program (NSLP) in school year (SY) 2021-22 collected students’ individual free and reduced price eligibility information that is required to make area eligibility determinations for summer 2022 and SY 2022-23. However, SFAs that used the nationwide waiver COVID-19: Child Nutrition Response #85, Nationwide Waiver to Allow the Seamless Summer Option through School Year 2021-22 to operate the NSLP Seamless Summer Option (SSO) during SY 2021-22 do not have complete free and reduced price eligibility information to make area eligibility determinations for summer 2022 and SY 2022-23, FNS explored potential resources and flexibilities within the Agency’s existing authority to support continuity of operations as State agencies and Program operators transition from the nationwide waivers.

This memo goes through the two additional options available for summer 2022 and SY 2022-23. These options are not available for sites located in the attendance area of schools that operated NSLP in SY 2021-22.

Option 1 - Use of School Year 2019-20 Free and Reduced Price Application Data: Program operators may use school data from a designated month of SY 2019-20 to qualify as area eligible in summer 2022 and SY 2022-23. For NSLP afterschool snacks and SSO, data used to determine area eligibility must be the most recent data available. Most commonly, the designated month will be October (true for Wisconsin). Area eligibility determinations made using school data must be re-determined every five years, therefore, area eligibility determinations made for summer 2022 using SY 2019-20 data are effective through summer 2024, and determinations made for SY 2022-23 may be effective through SY 2024-25.

Option 2 - Allow All Schools to Use Community Eligibility Provision Data: Schools that operated SSO during SY 2021-22 do not have complete free and reduced price data necessary to establish area eligibility. However, schools were required to conduct Direct Certification and may have continued to collect data on other “identified students,” including those directly certified with other programs or who would have been categorically eligible for free school meals without an application. For Community Eligibility Provision (CEP) schools, the 1.6 multiplier provides an estimate of the total number of students eligible for free and reduced price meals in CEP schools. The product of the identified student percentage (ISP) multiplied by 1.6 is used as a proxy for the percentage of free and reduced price students for area eligibility purposes. If the result is equal to or greater than 50 percent, meal sites located at the school (or in the attendance area of the school) are area eligible. USDA FNS is extending the policy allowed for CEP schools to all schools that operated SSO during SY 2021-22 to use school-level ISP multiplied by the factor of 1.6 to determine area eligibility. Only schools that operated SSO during SY 2021-22 may determine area eligibility using this option. Once area eligibility is established, all NSLP afterschool snack programs, SSO, etc. may establish sites based on the determination.

Existing CEP Schools: A school that is already operating CEP must continue to determine area eligibility for its attendance area using its approved school-level ISP.

Non-CEP Schools: Schools that operated SSO during SY 2021-22 and are not participating in CEP may use the same guidance as CEP schools to determine area eligibility for a school’s attendance area. The individual school’s ISP is multiplied by a factor of 1.6. If the resulting percentage is at least 50, meal sites within the school’s attendance area are area eligible.

IMPORTANT: Using CEP ISP data to establish area eligibility does not mean an SFA is electing CEP for SY 2022-23. This option is only available to non-CEP schools, on this limited basis, to determine area eligibility in the absence of other school data. Additionally, determinations based on this option for non-CEP schools will only be valid for summer 2022 and SY 2022-23.
 

Updates from the DPI School Nutrition Team (SNT)
 

USDA Statewide Waiver Approval and Application Process

WI DPI's Statewide Waiver Request been approved by USDA. In order for USDA to grant statewide waivers, the National School Lunch Act requires that:

  • The waiver must facilitate the purpose of the program;
  • The public must receive notice and information regarding the proposed waiver; and
  • The waiver will not increase the overall cost of the Program to the Federal Government.

WI is Currently Approved for the Following Waivers:

Summer Operations (Seamless Summer Option-SSO) 2022

  • Non-Congregate Meal Service During Summer 2022
  • Parent/Guardian Pickup during Summer 2022

National School Lunch Program (NSLP) and School Breakfast Program (SBP) (July 1, 2022-June 30, 2023)

  • Non-Congregate Meal Service
  • Parent/Guardian Meal Pickup
  • Meal Service Times
  • Offer Versus Serve

School Year Administration (NSLP/SBP/SFSP) (July 1, 2022-June 30, 2023)

  • Administrative Review Onsite Requirements

Special Milk Program (SMP) (July 1, 2022-June 30, 2023)

  • Non-Congregate Milk Service
  • Parent/Guardian Milk Pickup

Fresh Fruit and Vegetable Program (FFVP) (July 1, 2022-June 30, 2023)

  • Parent/Guardian FFVP Pickup
  • Alternate Site

Unanticipated School Closures (July 1, 2022-June 30, 2023)

  • Non-Congregate Meal Service during Unanticipated School Closures in SY 2022-23
  • Parent/Guardian Meal Pickup during Unanticipated School Closures (SSO/SFSP)
  • Meal Service Times for Unanticipated School Closures in SY 2022-23
  • Meals at School Sites for Unanticipated School Closures in SY 2022-23

USDA has stressed the fact that the waivers Wisconsin is currently approved for should only be utilized for COVID-related reasons. Program operators are expected to only use these flexibilities for the duration and extent that they are needed.

Q: What qualifies as a COVID-related reason?
A: A school would need to be closed due to COVID incidence, resulting in limited congregate meal service within the community. In most situations, the school would need to be located within a county with a high rate of COVID-related illness as determined by the Department of Health Services Webpage. If a school closes but is not located in a county with a high rate of COVID incidence, the SNT would need to collect additional information by contacting the local health department to find out what is going on in the community.

Q: What does not qualify as a COVID-related reason?
A: A school is closed but not due to COVID incidence. Special circumstances may be reviewed by the SNT. Additionally, the following reasons are not considered COVID-related:

  • Individual cases of COVID
  • Staff shortages
  • Supply chain disruptions
  • Convenience
  • Parent requests
  • Students who choose to learn virtually

Q: How do we apply?
A: If your SFA needs to apply for a waiver, contact us at SSO@dpi.wi.gov. We will talk through each situation and provide a link to a waiver request form as appropriate.

Q: How long is an approved waiver good for?
A: The SNT will be approving waivers for a two week period. In some cases, that could be extended depending on the situation.

Q: What if I am operating the Seamless Summer Option (SSO) through June 30? What waivers does my SFA qualify for?
A: If you are operating SSO through June 30, you may continue to use Federal waivers (non-congregate and parent/guardian pick up) without a COVID-related reason. After July 1, the new COVID-related reasons will apply.

The DPI SNT is required to report on the items listed below to USDA by October 30, 2023. Therefore, SFAs may be asked to report local level information regarding these items.

  • A description of how the waivers impacted meal service operations at participating sites;
  • A description of whether the waivers resulted in improved services to children;
  • A description of how the waivers reduced the quantity of paperwork necessary to administer the Program; and
  • The number of program operators that used the waivers.

Community Eligibility Provision (CEP) Updates

The Community Eligibility Provision (CEP) is a non-pricing meal service option for schools and school districts in low-income areas. CEP allows high-poverty schools and districts to serve breakfast and lunch at no cost to all enrolled students without collecting household applications. Local Education Agencies (LEAs) interested in CEP should review the information on the CEP Webpage to assess if it may be a good fit. LEAs with sites that are Eligible or Near-eligible for CEP will receive a separate communication regarding the application process soon.

The updated CEP Application Materials include the CEP Agreement Form and Eligibility Worksheet. The annual CEP Intent Form has also been updated. The CEP Application is for new participants in CEP and LEAs required to reapply for CEP following the end of their prior 4 year CEP cycle. A complete application must include a signed CEP Agreement Form and a completed Eligibility Worksheet. The Student Roster tab in the Eligibility Worksheet is only required if specifically requested by DPI during application approval. If additional information is needed for CEP approval, a DPI School Nutrition Team staff member will reach out.

The Intent Form is for LEAs that currently participate in CEP. The Intent Form may be used to indicate that the LEA will continue CEP participation without any changes, to indicate significant changes to CEP participation, or to request an increase to the Identified Student Percentage (ISP).

The deadline for submitting CEP Applications and Intent Forms is August 31, 2022. Typically, the deadline is June 30, however, due to the COVID-19 pandemic, the USDA Food and Nutrition Service allowed states to apply for a waiver affecting deadlines for CEP. The WI DPI applied for and was Approved for this Waiver. Under this waiver, DPI will accept CEP forms until August 31, 2022. LEAs are encouraged to submit their completed forms as soon as possible, and well in advance of the August 31 deadline. The online school nutrition contract cannot be approved until applicable CEP forms are received and approved. For this reason, delay in CEP form submission may delay contract approval and/or claim reimbursement.

LEAs should continue conducting Full Enrollment Direct Certification runs up to June 30 to try to increase the ISP as much as possible.

The CEP-Related Waivers for the 2022-23 school year also expand the time frame from which ISP data may be pulled from. Typically, DC data from on or prior to April 1 is used. The waiver allows DC data and additional documentation up to June 30, 2022 to be used to establish the ISP for the 2022-23 school year. If your LEA is applying for CEP, reapplying for CEP, or wants to apply for an increase to the ISP, be sure to run the LEA’s full enrollment through Direct Certification towards the end of June. DC runs should be completed before any end-of-school year rollover occurs so that the data is reflective of the student body at the end of the 2021-22 school year (including graduating students).

Please note that an ISP of 62.50% equates to a 100% free claiming percentage. Therefore, if an LEA can attain data to support an ISP of 62.50% prior to June 30, there is no need to continue to run DC up to June 30 for CEP purposes. For example, an LEA with a single site that has an ISP of 64.00% as of April 1, 2022 could submit a CEP application in May using the April 1 data to be approved for a 100% free claiming percentage. For this school, additional DC runs in June would not affect the free claiming percentage since the April 1 data already supports the highest possible free claiming percentage.

Please submit questions and completed CEP forms to CEP@dpi.wi.gov.

 

Other Updates and Information
 

Institute of Child Nutrition S.T.A.R. Webinar: Strategies for Managing Food Allergies in Schools
Date: Thursday, May 26, 2022*
Time: 2-3:00 pm CST

Webinar Registration Link

Now more than ever, school nutrition operators and school communities need ongoing support and a well-formed plan on how to manage food allergies in schools. The May STAR Webinar will feature USDA, FNS Office of Food Safety, and Food Allergy Research and Education.

The webinar will highlight current food allergy resources available for operators, as well as provide an overview of food allergies, the top food allergies, how to manage food allergies, and considerations and circumstances for special diets. By applying the information provided, operators can be well equipped to ensure safety procedures are in place to manage food allergy issues that may arise in schools.

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Wisconsin Department of Public Instruction
Jill K. Underly, PhD, State Superintendent
125 S Webster Street
Madison, WI 53703
(608) 266-3390 • (800) 441-4563