Reauthorization Provisions for School Nutrition Programs (SNP) - 9/21/2004
DATE: September 21, 2004
TO: Sponsors of School Nutrition Programs
FROM: Linda Rosenbaum-Grubbs, Supervisor
Food and Nutrition Service
SUBJECT: Summary of Reauthorization Provisions for School Nutrition Programs
This is a summary of the provisions of the Child Nutrition and WIC Reauthorization Act of 2004 that affect sponsors of School Nutrition Programs at the local level. Reauthorization provisions that primarily affect the federal and state levels are not included here.
This list is intended only as a “heads-up” for provisions to be implemented. FNS has already issued policies on several of these provisions and will continue to issue detailed guidance on each provision as more information is received from USDA. If you have any questions about a provision after receiving detailed guidance about implementation, please contact MDE Food and Nutrition Service at 651-582-8526, 800-366-8922, or e-mail to fns@state.mn.us <mailto:fns@state.mn.us>.
1. Provisions Effective Immediately (as of enactment of Reauthorization)
The following provisions are effective immediately, beginning school year 2004-05. FNS will continue to issue guidance on these topics as more information is received from USDA. USDA will issue federal regulations for most of these provisions, but not until 2005 or in some cases 2006.
Access & Streamlining
• Eligibility determinations for free/reduced price meal benefits are valid for the entire school year (households are not requested or required to update the school on household size, income, or assistance).
• Accounting for breakfast costs is removed as a requirement for Severe Need breakfast reimbursement.
• The waiver of weighted averages for nutrient analysis is extended to 2009.
• The exclusion of privatized military housing allowances from income eligibility determinations is made permanent.
• Categorical eligibility for runaway, homeless, and migrant youth is expanded.
• Local direct certification efforts are allowed.
• Provision 2 sponsors may have district-wide claiming percentages.
• Provision 3 sponsors may use a district-wide enrollment factor.
Integrity
• Clarifies that the certification process for school meals is a responsibility of the “local education agency.”
• Schools that demonstrate a high level of or high risk for administrative error in approval of school meal benefits will receive additional reviews from the state agency.
Healthy School Nutrition Environment
• Schools are required to make efforts to increase student consumption of those foods that are specifically recommended in the most recent Dietary Guidelines for Americans.
• The provision relating to purchases of locally produced foods and school gardens is extended (expires in 2009 instead of 2007).
2. Provisions Effective School Year 2005-06
These provisions will go into effect for school year 2005-06. Some provisions may be implemented earlier through issuance of USDA memorandums.
Access & Streamlining
• WIC will be added to MFIP, Food Stamps, and FDPIR as a basis for categorical eligibility for free school meals.
• The “seamless summer” option, for claiming summer meals through NSLP, will be made permanent.
• Discretionary direct certification for homeless, runaway and homeless grant program, migrant children is allowed.
• School meal applications may be signed electronically.
Integrity
• For school year 2005-06, the verification deadline will be moved up to November 15; verification sample size will be 3% of error prone applications, with alternate systems allowed for school districts with improved response rates or improved application approval procedures; schools required to have a toll free number for verification contacts; schools required to follow up with households that don’t respond.
• Schools will be authorized to obtain “direct verification” data directly from agencies that certify households for food stamps or similar benefits.
• Schools will be allowed to provide private free/reduced-price information to third-party contractors for the purpose of verification.
Healthy School Nutrition Environment
• The number of required food safety inspections will be increased from one to two per school year.
• Schools will be required to implement a HACCP system for food safety.
• Milk will be required to be offered in a variety of fat contents (drops requirement that a type of milk has to be offered if 1% of students chose it during the previous year).
• At the request of a medical authority or parent for medical or other special dietary needs, schools may substitute non-dairy beverages determined by USDA to be nutritionally equivalent to fluid milk for the fluid milk component.
• Schools may not prohibit the sale of milk on school premises.
• Schools must establish local wellness policies by June 30, 2006.
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