Introduction. Who Administers The Program?

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1 Introduction The Summer Food Service Program (SFSP) was established to ensure that lowincome children continue to receive nutritious meals when school is not in session. Free meals, that meet federal nutrition guidelines, are provided to all children at approved SFSP sites in areas with significant concentrations of lowincome children. The SFSP operates during school vacations, primarily in the summer months. It may also provide meals during vacation breaks where schools are operated on a year-round basis or a continuous school calendar, or during emergency school closures from October through April. Who Administers The Program? The U.S. Department of Agriculture s Food and Nutrition Service (FNS) administers the SFSP at the national level. Within each State, the State Department of Education, an alternate State-designated agency, or the appropriate FNS Regional Office administers the program. Locally, public or private non-profit organizations that want to sponsor the Program apply and are approved by the New York State Education Department (SED) to operate the Program. These sponsoring organizations sign annual Program agreements with SED and are responsible for overseeing Program operations. Sponsors receive federal and State reimbursement through SED to cover their costs of preparing and serving meals to eligible children at one or more feeding sites. Simplified Summer Program (formerly the 14-State Lugar Pilot Project) The Fiscal Year 2008 Omnibus Appropriations Act extended the Simplified Summer Food Service Program (formerly referred to as the Lugar pilot), to New York State in the summer of The Simplified program ensures the maximum level of per meal reimbursement, allows greater flexibility in the use of program funds, and reduces some of the reporting requirements. The focus of this initiative is to serve more eligible children by encouraging new organizations to participate and by expanding existing programs to maximize capacity in providing adequate access to all eligible children in their communities. The following is information regarding the implementation of simplified procedures in the Summer Food Service Program: 1

2 The Importance of Sound Program Management The purpose of the simplified procedures is to facilitate and encourage participation by eligible sponsors in order to reach more hungry children in the summer months and other times during the year when they do not have access to school meals. Elimination of the cost comparison reduces administrative tasks and ensures a stable per meal reimbursement rate, thus making it easier for sponsors to participate. With the implementation of these reduced program requirements, it is critical that states and sponsors practice sound program management to ensure that the integrity of the SFSP is preserved. SED will ensure this through careful selection of applicants, thorough training efforts especially directed to new sponsors, diligent monitoring, and prompt follow up where problems are found. Sponsors can help ensure this through maintaining high quality administrative oversight and meal service. Other SFSP Requirements Except for the elimination of cost comparisons to determine reimbursements, sponsors must continue to meet all other Program requirements that are contained in the regulations at 7 CFR 225 and all applicable instructions, circulars, or other guidance, unless otherwise exempted by FNS. Attachment 6 provides a comprehensive list of the regulations, circulars, instructions and guidance. The following is a discussion of some of these requirements: Applications Sponsors must continue to meet all application requirements contained in 225.6(c) and , except as noted below for budget submissions by experienced SFSP school sponsors. Once their applications are approved, all sponsors will participate under the simplified procedures, including private nonprofit organizations. To safeguard the Program s integrity, especially since the cost comparisons are no longer required for sponsors, SED will carefully review all applications to ensure that only qualified organizations are approved to participate. A critical aspect of this review, as described in 225.6(b)(9) and (c), is to ensure that approval to participate is denied to any applicant that is found to be seriously deficient in the operation of any of the child nutrition programs (CN Programs). SED will check the national disqualified list to ensure that applicants have not been disqualified from the Child and Adult Care Food Program. Refer to (c) for a more detailed explanation of serious deficiency as the term applies to the SFSP and denial and termination procedures for SFSP applicants or participants determined to be seriously deficient. 2

3 Budget Submissions Except as noted below, all sponsors must continue to submit budgets with their applications for participation as specified in 225.6(c)(2)(ii)(b) and 225.6(c)(3)(ii)(b) and to receive advance payments as specified in 225.9(c)(1)(i) and 225.9(c)(2)(i) of the SFSP regulations. SED will continue to carefully review sponsors budgets to ensure adequate resources will be applied to management, oversight, and meal service. Any updates to the budget without supported costs will be denied. Sponsors must provide complete financial disclosure and maintain accurate non profit food service accounts. FNS Instruction (REV. 4) requires sponsors to demonstrate the comparison of actual outlays against budgeted amounts. SED retains the authority to deny any expenses added to the sponsor s approved budget. Sponsors are required to submit any changes to its approved budget to SED prior to filing a final claim for reimbursement. In addition, sponsors requesting a second advance payment will be required to certify that its projected administrative costs do not differ significantly from the approved budget. Exception: SED is waiving these requirements for experienced public schools or private nonprofit schools that are in good standing. SED encourages schools to exercise caution regarding costs allocated to the Program. Unallowable costs previously identified during the budget/budget amendment process, will go undetected by SED until a review and/or audit is conducted. Schools should be aware of the increased liability they may incur as a result of eliminating the budget review process. Cost Records Although sponsors do not have to report their costs under the simplified procedures, they must continue to maintain records which show the source and application of funds and contain information pertaining to reimbursement funds (e.g., authorization, obligations, unobligated balances, assets, liabilities and outlays), and income. Sponsors are also required to maintain accurate, current, and complete disclosure of the financial transactions of the program. Nonprofit Food Service Sponsors must operate a nonprofit food service for eligible children, as required in 225.6(e)(1) of the SFSP regulations. Benefits to children and the quality of program administration must not be diminished as a result of these simplified program requirements. Sponsors must be able to document that they have maintained a nonprofit food service by retaining copies of all revenues received and expenses paid from its nonprofit food service. Sponsors must be informed that expenses paid from the nonprofit food service must be allowable costs that are necessary, reasonable, and properly documented. 3

4 Sponsors that operate other CN Programs do not need to maintain a separate nonprofit food service for the SFSP; SFSP funds may be included in the sponsor s nonprofit food service account that supports the other programs. However, records and supporting documentation must be maintained and properly identified to permit the sponsor, reviewers, and auditors to evaluate and verify all SFSP fiscal activities. Excess Program Funds Under the simplified procedures, the only limitation on the use of reimbursement that exceeds costs while the program is in operation, is that the funds are spent on allowable SFSP costs, as described in FNS Instruction 796-4, Rev. 4. Although sponsors are not obligated to do so, SED recommends that they use any excess Program funds to improve the meal service or other aspects of the food program. Sponsors use of excess program funds that remain at the end of the year may vary depending on whether they operate other CN Programs: Sponsors that operate other CN Programs throughout the year must keep the excess program funds in its joint, nonprofit food service account and may use these funds to pay for allowable costs for the other programs or for the next year s SFSP costs. Sponsors that do not operate other CN Programs during the year are not obligated to return unused funds at the end of SFSP operations. However, organizations that expect to continue to sponsor the program in the next year must keep any excess funds for that year s operations. If the sponsor does not provide any other programs, the State may collect the excess funds. Quality Meal Service and Administration SED will work with sponsors at each phase of the Program as noted in the following points to ensure that sponsors do not reduce the meal service quality through poor management of program resources. Review Sponsors Budgets Prior to the start of program operations, SED will review the budget submitted with the sponsor s application to determine whether the sponsor has planned to provide effective administration, oversight, and a quality meal service for the children. If the sponsor is new to the program, SED could compare its proposed budget to those of experienced sponsors, similar in size, location, and type of organizations. Training Efforts During annual sponsor training described in 225.7(a), SED will discuss the importance of careful planning and management of resources in order to provide quality meal service. 4

5 Monitoring Operations SED will monitor the quality of service, using comparisons to the sponsor s efforts in previous years or comparisons to other sponsors operating in a similar environment. If the quality appears to have diminished from previous years efforts, the State may require sponsors to amend their budgets to ensure that adequate resources are dedicated to providing a quality meal service. Seamless Summer Option The purpose of Seamless Summer Option is to reach more hungry children in low-income areas in the summer and to help schools provide more efficient meal services to those children. For school districts that have operated the National School Lunch Program and the SFSP, the Seamless Summer Option offers a reduction in paperwork and administrative burdens. 5

6 ABOUT THIS GUIDANCE: This publication provides information for staff of all local organizations that participate or plan to participate as sponsors in the Summer Food Service Program for Children (SFSP). It consists of the following parts: PAGES 1 7 PAGES 9-80 PAGES PAGES INTRODUCTION PLANNING THE PROGRAM provides information to help guide potential sponsors through the early stages of program planning. This part includes information on eligibility requirements for sponsors, sites, and participants; evaluating and selecting feeding sites; determining the type of meal service to offer; staffing needs; and applying to operate the SFSP. ADMINISTERING THE PROGRAM outlines the administrative responsibilities of a sponsor in the areas of training, monitoring, civil rights, program payments, record keeping, reviews, and evaluations. FOOD SERVICE MANAGEMENT COMPANIES discusses how a sponsor can contract with a food service management company, a school, or a private non-profit organization to obtain meals. This part includes information on the sponsor's and food service management company's responsibilities in relation to the food service operations at feeding sites. 6

7 Summer 2012 FNS and State agencies are engaged in a continued effort to increase participation in the SFSP. Did you know that the SFSP is one of the most needed but underutilized Federal nutrition assistance programs? Although 20.6 million eligible children received free or reduced-priced school meals during fiscal year 2010, only 2.3 million participated in the SFSP, and an additional 1 million participated in the National School Lunch Program (NSLP) during the summer months. That s only 3.3 million eligible children receiving meals during the summer months. There are many hungry children that we need to reach with this program! To aid in this effort, the Healthy, Hunger-Free Kids Act of 2010, Public Law , made some modifications to the SFSP requirements that have been incorporated into this guidance. These changes will simplify Program administration and better ensure that families of eligible children are made aware of the availability of SFSP meals. As an eligible organization interested in administering the SFSP, you are the link that translates this Federal benefit into meals for children. If you are new to the program, please consider participating as a site or a sponsor in this important mission. If you are a returning sponsor, please consider adding sites and activities that will help draw children to your existing program. FNS has created a SFSP Outreach Toolkit that can help you prepare to operate a summer program. The toolkit is available at: 7

8 8

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