Initial Site Visits in the Summer Food Service Program

On Sept. 19, 2022, the Food and Nutrition Service (FNS) published the Final Rule: Streamlining Program Requirements and Improving Integrity in the SFSP. The rule amended Summer Food Service Program (SFSP) regulations to strengthen program integrity by clarifying, simplifying, and streamlining program administration to facilitate compliance with program requirements. Through the rule, USDA codified changes to the regulations that will simplify the application process, enhance monitoring requirements, clarify existing requirements, and provide more discretion at the state agency level to manage program operations. Compliance with the provisions of this rule must begin by May 1, 2023 (except for those state agencies that have an approved waiver for implementation by Jan.1, 2024).

These regulatory changes provide sponsors with the opportunity to manage their resources in ways that best suit their program operations while conducting initial site visits and food service reviews. As part of their monitoring responsibilities, SFSP regulations at 7 CFR 225.15(d)(2) require sponsors to visit certain sites at least once during the first two weeks of program operations. For sites that operate for seven calendar days or fewer, the initial site visits must be completed during the sites’ period of operation. The purpose of the initial site visits is to allow sponsors the opportunity to provide technical assistance, if needed, to improve service delivery and to correct any deficiencies observed in program operations at the site level. Sponsors must take immediate action to correct deficiencies found during the initial site visits. Examples of deficiencies include whether meal pattern requirements are met, meals are stored properly to ensure food safety, meals are served during the approved meal service times, and whether meals are counted and checked before signing delivery receipts.

Sponsors are required to conduct initial site visits during the first two weeks of operations for:

• All new sites (as a reminder, for summer 2023, all non-congregate sites are considered new sites).
• All sites that have been determined by the sponsor to need a visit based on criteria established by the state agency pertaining to operational problems noted in the prior year.
• Any other sites that the state agency has determined need a visit.

Per 7 CFR 225.15(d)(3), sponsors are also required to conduct a full review of food service operations at each site at least once during the first four weeks of program operations using the monitoring form developed by their respective state agency. The purpose of the food service review is to determine if the site meets all program requirements. After this initial food service review, the sponsor must maintain a reasonable level of site monitoring to ensure continued program compliance. During the food service review, sponsors observe the entire meal service including food delivery or meal preparation, meal counts and review daily records maintained by the site supervisor.

To allow sponsors to use their time and resources more efficiently, a full review of food service operations may be conducted during the initial site visit. For example, if a sponsor’s site that requires an initial site visit operates from June 1 to July 31, the initial visit must occur no later than June 14 and the required food service review must occur no later than June 28. At the sponsor’s discretion, it may conduct both the initial site visit and the food service review at the same time. The sponsor does not have to wait until the initial site visit is completed to conduct the food service review.

Sponsors should prioritize non-congregate rural visits and take into consideration scheduling and actual meal distribution times. Conducting the full review of food service operations at the time of the initial site visit may be particularly helpful due to the proximity and distance of these sites. For monitoring guidance of non-congregate rural sites, please refer to Questions and Answers #2: Summer 2023 Non-congregate Meal Service in Rural Areas, published on April 20, 2023.

State agencies are reminded to distribute this memorandum to program operators. Program operators should direct any questions concerning this guidance to their respective state agency. State agencies with questions should contact the appropriate FNS regional office.

Jessica Saracino
Director
Program Monitoring and Operational Support Division
Child Nutrition Programs