The TDA outlined current rules and regulations related to meal service during school closures, gave updates on waivers, answered questions, and outlined resources available to offer clarification and assistance.
This report is intended to give you an overview and highlight of the discussions on the various topics the committee took up. This report is not a verbatim transcript of the hearing; it is based upon what was audible or understandable to the observer and the desire to get details out as quickly as possible with few errors or omissions.
Angela Olige, Assistant Commissioner for Food and Nutrition, TDA
- 895 school districts/open enrollment charters closed as of 12 PM today
- 932 with private schools included
- HB 6201- passed by House and in Senate
- President will sign, then USDA will provide implementation guidance to TDA and all state agencies
- TDA is working on 15 waivers, submitted 10, 4 are being worked on, and 1 is no longer needed (USDA has provided guidance)
- Meals given out of compliance will not be eligible for reimbursement
- Sites with 50% or less who qualify for free/reduced meals, may serve meals at those sites to children. May serve using Seamless Summer Option (SSO) or Summer Food Service Program (SFSP)
- A Closed Enrolled Summer Site is a site that is under 50% free/reduced
- Will need complete application before you submit first claim (not before you serve)
- March 13th was date of approval from USDA for congregate waiver and schools being able to serve
- Service starting March 13th and after is eligible for reimbursement if they meet federal regulations
- Multiple Meal Service- You may serve multiple meals at one time in SSO and SSP, meals delivered to homes, and grab and go. Each child is only allowed to receive 2 meals or 1 meal and a snack. You can send that combo of whatever you are doing for 5 days at a time in the period of one day
- You are not allowed to do lunch and supper in SSO and SSP
- Schools operating under CACFP can still provide supper
- Documentation is crucial
- Some private and charters use grocery stores and USDA is working on meal flexibility- that should come through when the bill is passed
- Document your attempt to meet meal patterns, even if you are unable to meet regulation, just document
- Emergency Procurement Regulations in place- CFR 200-320 Methods of Procurement to be Followed in Emergency Situations
- Challenge: Parents picking up meals and children not being present
- Summer food service, you are allowed to serve any child that comes to your site, without checking if they attend that school
- USDA is grappling with this problem. One possible solution may be to use a closed enrollment process. If that happens, a parent may come to the school where their child is enrolled and the parent has to provide ID of who they are. School has to verify that parent has children at their school- then school can provide meals for number of children in their household. We are hoping that will protect program integrity
- School districts can work with other orgs to limit amt of time household will have to go to different sites for services
- Texas Emergency Food Assistance Program- all food banks have contracts with TDA to operate that. It’s a different source of funding. School district can serve as a site for this, but doesn’t replace other programs. Every state is affected, so when food runs out, we can’t rely on other states
- USDA issues revised Q&A document- on their website
- Question in regards to spring break
- USDA provided guidance saying meals could be provided if a spring break was postponed under SFSP and SS
- Some schools served meals during their normal spring break as early response and we are working to get those meals reimbursed
- We are suspending all administrative reviews at this point in time- that is one of the waivers we have applied to with USDA
- Documentation is so critical
- what/why/attempts you made to meet federal regulations even if you weren’t able to
- www.squaremeals.org/coronavirus
- Answers are evolving, questions can be submitted on www.squaremeals.org
- You can also work with ESC’s to submit questions
- We are trying to work out process of how we can quickly respond to questions. Refer to FAQ’s on website for latest information. Listen to audio calls, we will be having them more frequently
- TDA is going to telework with skeleton crew at the office
- We are trying to minimize duplicate coverage and we need school districts to work together collaboratively. Work together to maximize how you can get service to discrete individuals so we can reach who needs to be reached and not compromise integrity of the program
Q&A
- Discuss how many meals per day and per week:
- Reiterated earlier advice concerning 2 meals or 1 meal and a snack per child. If you are doing 5 meals in one day, you would deliver 2X5 of whatever combo. Could be done in grab and go setting or delivering to a home. You have to know if you are area eligible or not
- One pending waiver is regarding districts that are only open for a few hours a day, we are asking about how national school breakfast and school lunch works in this case
- If a school is open, you would follow NSB and SSP
- If you are operating open enrolled site, student has to be in the vehicle. Closed enrolled, parent would have to give identification and follow rules I already gave. Yes, you may serve on Saturday and Sunday
- If under SSO, in an area that is eligible, that is 50% or over, any child that comes to your site may eat free
- Schools can do seamless summer options?
- We need you to say “COVID-19” in documentation. SSO guidance will be put on website. If you were already doing SSO for 2018-2019 and sites haven’t changes, you will be able to just let us know which sites are operating
- We are in an automated payment system and we have to make sure claim checks against application
- We don’t qualify for SFP, but we are feeding all children that need food right now. Do we keep doing this?
- If you are operating a closed site under 50%, then you are eligible to operate SFP. Reach out to ESC for help with that
- Can we use bus drivers to do home delivered meals?
- Yes. You may use your federal funds for expenses attributable to delivering meals to a home
- Clarify eligibility.
- In a school that is in an area that is under 50% free/reduced eligible, you can operate closed enrolled site. Procedures and policies are on squaremeals.org
- Will they relax the eligible meals qualifications?
- Not currently on the table. We will push that up to USDA
- Non- Congregate waiver has been issued for SFSP and SSO, does not yet exist for CACSP, but will if new U.S. house bill is passed
- Do they need to follow subgroup requirements for National School Lunch/Breakfast Program?
- Do everything you can to follow federal regs, but if its not available, document
- How do you process a claim?
- Same way as always, intake on squaremeals.org/coronavirus, then application will be done, and the claim can then be paid. We will put app guidelines on website
- Can siblings pick up for children if the parent is unavailable?
- If sibling is 18 or under, it would fall under guidelines of closed enrollment site. Area eligible is the check for program eligibility. When a sibling comes, there is no check to ensure it goes to the right place. We would need another check in place to ensure we meet the need under the intent of these programs
- Can we serve CACSP and a summer meal so kids can receive 3 meals?
- CACSP has not qualified for waiver yet, so undetermined as of now
- Will staff still get paid if they are not working?
- It is a district decision but funding for staff is an allowable expense with the child nutrition funds. Districts just have to decide what they want to do
- Home delivery?
- Yes. But you can’t do home delivery and to-go in the same area
- Do we need to track numbers?
- Yes, under SSP and SSO, it is just a meal count. In a closed enroll site, you have to deal with meal rosters. 50% and above, it is just a matter of tallying how many you gave out
- Rural area?
- District decision on how you want to do it. Sec. Purdue announced program working with the Baylor Institute. Working with THI and USDA to provide guidelines
- Any federal regulations we don’t have a waiver for, you have to comply with. Document what is not possible and how you have attempted
- Can a CE do an amendment to a permanent agreement if they are not eligible for summer feeding?
- Yes, at this time since it’s an emergency. Work with FSFP to make this happen
- No Kid Hungry just announced $1 million in emergency grants- go to that website
- Yes, you may serve 7 days a week if you have the means to do so
- Thank you to all the food service people, staff, administrators, who are working tirelessly to meet needs of students during this time
- Please be mindful of food safety before delivering, make sure you notify household of perishable goods
- Helpful letter from Angela Olige: http://www.squaremeals.org/Portals/8/files/H1N1/AO%20Supt%20Letter%20Letterhead.pdf