Exceptions to Approving Sponsors Prior to Program Operations

This memorandum provides regional offices with the authority, under certain circumstances, to approve state agency requests to reimburse SFSP sponsors whose applications are not approved prior to the beginning of their meal service operations. We are issuing this memorandum in response to requests from several regional offices.

With regional office approval, state agencies may reimburse sponsors for meals served prior to the date of approval when extenuating circumstances have delayed approval of the sponsor’s application. For example, approval could be delayed beyond a sponsor’s start date because the state agency experiences a backlog of applications in the week prior to June 15 (or the state-agency established application deadline). Approval could also be delayed due to the time needed for a state to review additional information it requests from a sponsor (e.g., a description of the sponsor’s proposed service area).

In making a request, state agencies should provide regional offices with the following information for each situation:

• the date an application was submitted by the sponsor;
• the state’s deadline for applications;
• the date of state agency approval;
• the period for which retroactive reimbursement is being requested (not to exceed 30 calendar days prior to approval);
• the number of sites and estimated number of meals affected;
• the reason that state agency approval was delayed; and
• an assurance that all Program requirements including training, monitoring, record keeping, and meal pattern requirements, have been met for the period of reimbursement being requested.

This memorandum is intended to address unusual cases in which a sponsor submitted a timely application but approval was unavoidably delayed by the state agency. It is not intended to address situations in which applications were submitted after the beginning meal service operations. Finally, any sponsor that provides meal service prior to having an approved agreement with the state does so at its own risk.

There is no guarantee that reimbursement will be provided.

STANLEY C. GARNETT
Director
Child Nutrition Division