Effective Date of Free or Reduced Price Meal Eligibility Determinations

1. Effective Date of Free or Reduced Price Meal Eligibility Determinations SP 11 2014

2. Background • “The specific point in time for the effective date of eligibility is not addressed in Program regulations.” • The Eligibility Manual for School Meals provides that the determination, notification, and implementation of free or reduced meal status be made within ten operating days from the date the application is received by the LEA. • “Therefore, if the LEA chooses, it could establish the date of submission of an application as the effective date of eligibility, rather than the date the official approves it.” • Flexibility is for available for NSLP, SBP, SMP, SFSP, and CACFP

3. Key Points • Optional, not required. • LEA must inform State Agency of intention to exercise this option • Applications must be complete, containing all required information at the time of submission • LEA’s can use this flexibility when waiting for documentation of other source categorical eligibility (homeless, migrant, etc.) as indicated on a HH application • Must be done for all schools/programs and all students within an LEA • Must document the date that the application was submitted • Must refund money paid prior to the time of eligibility documentation or forgive accrued debt • The LEA can only claim those meals at the higher reimbursement rate if the child is given a refund or their debt is discharged.

4. How to Start? • LEA must notify State Agency of participation in this option. • Contact Tonya Smither at SCN by email. • Effective date for participation is the date the notification is submitted the State Agency.

5. Benefits of Flexibility • Among others: • Assist low income children by allowing them to receive free or reduced price school meals during the eligibility determination period-either refunding money paid or forgiving accrued debt • Assist LEAs that are experiencing challenges with unpaid debt.

6. Suggestions Draft an internal policy on how this will proceed. Key points to consider include: • how to ensure that applications are marked correctly for date received • how refunding or debt discharge will be carried out • What documents will be kept as records and where? LEA’s need to document date of eligibility, date that the student was repaid/debt forgiven, amount (and how).

7. Suggestions School managers at the least need to make certain applications are dated for the submission date. Date stamps would be one easy way to have managers mark applications for submission date. How will this best work for your district?

8. Remember! • If utilizing this flexibility requires adjustment of your claim, make the needed changes before the end of the month! You have until the end of the month to make changes.

9. Questions? A Q & A will be released as a follow-up to this overview.

10. SP 13 - 2014 School Food Service Account Revenue from the Sale of Non-Program Foods

11. Background Now Regulations allowed the sale of non-program foods, purchased by non-profit SFS account-if the revenue of these sales benefited SFS or a school/student organization/program The SFS recovers all costs incurred when it is the source of foods or goods for other entities officially sanctioned by the school Previously

12. In Other Words… • If food or goods are purchased through existing contracts for a school approved group, you are required to recover all food and time costs.

13. Requirements • Food or goods purchased through non-profit school food service for other entities must be bid items through existing contracts • Purchase cost must be paid in full by the entity or group • Any labor cost (time) associated with purchasing these goods must be paid to school food service • These school programs or student organizations must be officially sanctioned by the school School food service must be cautious that food service funds, whether food or labor, are not lost in these arrangements.

14. Labor Costs • Those costs associated with purchasing and receiving goods • Food preparation

15. Charging for labor • Best to have a contract regarding costs and all other terms and conditions. This contract is essential if catering. • Determine a factor for the average labor cost; one suggestion is 20% of the food costs, minimum, added to cover the various forms of labor associated with these purchases • The key is to capture this revenue to cover all food service expenses.

16. Suggested Guidelines • Draft an internal policy to establish standard procedures for receiving and processing orders for other entities: -Is there a minimum order? -What is the amount of notice that you need to place an order? How many days and when is your delivery day? - Establish consistent labor pricing practices • Place these orders on a separate invoice, keeping these transactions documented and separate from orders for school meals programs. • Code as catering in accounting records, not as a la carte or adult food sales. • Maintain good records!

17. Questions? We will develop a Q & A to follow-up to this overview.