Available Flexibilities for CACFP At-risk Sponsors and Centers Transitioning to Summer Food Service Program

Organizations currently participating in the at-risk afterschool meals component of the Child and Adult Care Food Program (CACFP) are well-positioned to offer summer meals. Although CACFP at-risk afterschool meals may not be served during the summer months, these organizations may be eligible to serve summer meals through the Summer Food Service Program (SFSP) or the Seamless Summer Option (SSO) under the National School Lunch Program. The Food and Nutrition Service (FNS) encourages participation in both programs so as to establish a year-round presence in the communities in which they serve. Previous guidance highlighted provisions to simplify SFSP application procedures [CACFP 03-2012: Simplifying Application Procedures in the Summer Food Service Program, Oct. 31, 2011]. This memorandum highlights existing flexibilities available to CACFP institutions to simplify their participation in SFSP.

Sponsor Application Requirements

CACFP institutions currently in good standing are not required to submit further evidence of financial and administrative capability when applying for SFSP participation [CACFP 03-2012: Simplifying Application Procedures in the Summer Food Service Program, Oct. 31, 2011]. To be considered in good standing, the institution must have no serious deficiencies declared in its most recent review cycle.

CACFP institutions participating in the at-risk afterschool meals component that want to operate the SFSP at the same sites where they provide CACFP meal services may follow the application requirements outlined in 7 CFR 225.6(c)(3) for experienced SFSP sponsors and sites, instead of the requirements under 7 CFR 225.6(c) 2) for new sponsors and sites [CACFP 03-2012: Simplifying Application Procedures in the Summer Food Service Program, Oct. 31, 2011].

Agreements

State agencies that administer more than one child nutrition program are required to enter into a single agreement with a Program operator with respect to the administration of any combination of child nutrition programs [7 CFR 225.6(e)]. Therefore, if the same state agency administers both CACFP and SFSP, institutions interested in offering summer meals through SFSP are required only to sign an addendum to the existing CACFP agreement.

Applicants in states where CACFP and SFSP are administered by different state agencies must enter into agreements with both state agencies. State agencies are encouraged to work together to share information and streamline the application and agreement process as much as possible.

Site Eligibility

CACFP at-risk afterschool centers must establish area eligibility through the use of school data [7 CFR 226.17a(i)]. Once area eligibility has been established it is valid for a period of five years and may be used to demonstrate eligibility for other child nutrition programs. A CACFP afterschool meals center applying to participate in SFSP or SSO is not required to re-establish area eligibility [SFSP 03-2014, Census Data Release: fiscal year 2014, Nov. 8, 2013].

Health and Safety Inspections

SFSP regulations do not establish federal health and safety standards. Instead, sites must meet state and local health and safety standards. In cases where health and safety standards for at-risk afterschool centers and SFSP sites are the same, SFSP state agencies must accept documentation of a valid current inspection from the CACFP institution.

Training

At-risk afterschool meal sites in good standing are not required to attend training prior to submitting an SFSP application [CACFP 03-2012, Simplifying Application Procedures in the Summer Food Service Program Oct. 31, 2011]. However, administrative staff must be informed of SFSP requirements and required to attend sponsor training, prior to beginning Program operations. State agencies that administer both CACFP and SFSP are encouraged to offer targeted supplemental training on SFSP requirements during CACFP trainings, to eliminate the need for afterschool center staff to attend a separate SFSP training.

Monitoring Requirements

SFSP and SSO sponsors are required to visit each site they oversee at least once during the first week of program operation [7 CFR 225.15(d)(2)]. State agencies may waive this requirement for SFSP and SSO sponsors in good standing in the CACFP and NSLP respectively. However, sponsors must ensure that each of their sites are monitored as otherwise required by program regulations during the period of operation [CACFP 03-2012, Simplifying Application Procedures in the Summer Food Service Program, Oct. 31, 2011].

Financial Management

SFSP funds may be used to support any federal child nutrition program. A sponsor’s excess funds from either CACFP or SFSP may be used in its operation of either program, or any other child nutrition programs. For example, if, at the end of the school year, excess reimbursement from CACFP at-risk afterschool operations exists, those funds may be allocated towards allowable costs in SFSP [FNS Instruction 796-2, Financial Management – Child and Adult Care Food Program]. However, FNS strongly encourages sponsors to first exhaust their SFSP funds on their summer meal operations to ensure a robust summer program before allocating excess SFSP funds to another child nutrition program.

State agencies are reminded to distribute this information to program operators immediately. Program operators should direct any questions regarding this memorandum to the appropriate state agency. State agency contact information is available at http://www.fns.usda.gov/cacfp/program-contacts. State agencies should direct questions to the appropriate FNS regional office.

Cynthia Long
Director
Child Nutrition Division