School Nutrition Program Update

10/8/2020

Meal Program Selection

  • On August 31, 2020, USDA issued a nationwide waiver allowing Summer Food Service Program and Seamless Summer Operations to continue to operate through December 31, 2020, providing the choice for Texas contracting entities to operate the National School Lunch Program or one of the summer feeding programs through the end of 2020.

    School Food Authorities must notify TDA by September 30, 2020 of which program(s) they plan to operate through December 31, 2020.

    Based on current USDA guidance, which is subject to change, TDA has developed guidelines for each option available to school districts and community organizations. Please refer to the information below and continue to check the COVID-19 FAQ for School Year 2020-2021 frequently, as updates are ongoing.
    Note that USDA reserves the right to withdraw this approval subject to the availability of funding.
  • CEs may not combine NSLP and the Summer Program between sites. The choice of programs are as follows:
  1. Summer Feeding with the option of CACFP At-Risk snack/supper
  2. NSLP with the option of the After School Care Program (ASCP)
  • Upon the Current Program selection as of September 30, 2020
    • Only 1 change of program(s) can be made this day forward for the remainder of the school year.
NOTE: As of 10/7/2020, summer feeding will end on December 31, 2020.
  • CEs receive a confirmation email from TDA when submitting intake forms. Make sure your computer does not block TDA emails. Check the SPAM folder if you have not received TDA emails.

Waivers for Flexibilities

It is important to understand that all guidance still applies with the exception of the current flexibilities available. CEs must notify TDA for approval when implementing waivers.

Current Waivers for Flexibility are as Follows:

  1. Non-Congregate Feeding - Grab n Go (GG) and/or Home Delivery (HD)
  2. Parent PickUp w/o child present
  3. Meal Times - Multiple Meals Served
  4. Bulk Items - Serving a food item in bulk. i.e. gallon of milk for multiple meals
  5. Area Eligibility - To approve a non-area eligible site.
  6. Offer Versus Serve - USDA issued a nationwide waiver of the requirement that senior high schools must participate in OVS service. More guidance in FAQs, Q11.
  7. Monitoring - USDA issued a nationwide waiver of onsite monitoring requirements for meals served under NSLP/SBP, SSO, and SFSP.
To ensure program integrity during this time, all CEs must, to the maximum extent practicable, continue monitoring activities of operations offsite (e.g., through a desk audit). All CEs must assess the activities they normally do while onsite and determine which of those activities are not possible as a desk audit. To the extent possible, CEs should incorporate technology as part of the desk audit, including video, photographs, and teleconferencing. Many of these technologies are widely available and free.
CEs must thoroughly document the desk audit, including, but not limited to:
• When it was conducted.
• Who the CE interacted with at the site.

• What technical assistance was provided.

• Those areas of the review that could not be completed as part of the desk audit.

Note that SFSP operators in good standing may be approved to waive the required first-week site visit altogether.
More guidance in FAQs, Q14.

See the FAQs for further guidance on these waivers.

Summer Feeding Program Implementation

To be eligible for the Summer Feeding Program you must have an eligible area with a need to feed all 18 & under children in the community "due to COVID-19". If the site is in a non-eligible area, you MUST have an approved area eligible waiver intake form in order to provide meals under the summer feeding program.

  • CEs with multiple sites combining eligible and non-eligible areas will submit an area eligibility intake form for all non-eligible area sites.
  • Promote and advertise the summer feeding (GG) sites. The purpose of feeding under a summer feeding program is to meet the need of an eligible area (>50% F/R) due to the impact of COVID-19. If you are not serving meals to children of the eligible area you may be asked to return to NSLP.
  • Home Delivery (HD) - Must have prior consent from the household to deliver meals to the house. Documentation must be kept on file.
  • Documentation - Review the outline of documentation for the program you are participating in. TDA may request to review your documentation at any time. See the direct links for the following programs.
  1. Seamless Summer Option (SSO)
  2. Summer Food Service Program (SFSP)

Site Documentation

  • Closed Enrolled Sites - Must have a roster for meals served. Cannot use only a tally sheet to count meals.

  • Open Sites (GG) - May use a tally sheet to count meals.

  • Virtual Learners - Must receive meals from an Open Site.

Food Service Management Company (FSMC):
  • FSMC does not make a decision on program selection. The CE is responsible for the program implemented. However, a FSMC can provide operational guidance.
  • A CE with an FSMC who is making a program change such as summer feeding through December 31, 2020, must provide a Legal Opinion to TDA. An attorney must review the FSMC contract and verify if there is a material change or not. If there is not a material change then an emergency procurement will not be approved. Please see FAQs, Q77 & Q78.
77.How do I address impacts on my Food Service Management Company (FSMC) contract if my district decides to switch from NSLP/SBP to one of the summer nutrition programs? FSMC contracts are based on estimated meal counts by program. SFAs utilizing a FSMC must obtain a legal opinion that assesses whether changing the program operation during the waiver period will result in a material change that requires additional action.

Refer to TDA webinar on 10/7/2020. TDA Webinar Recordings

Common Summer Feeding Site Application Errors

For Summer Feeding site applications:
  • September is in SY 19-20 application
  • October is in SY 20-21 application
  • CV GG/CV HD - Be sure all named sites reflect the service provided.
  1. Grab n Go (CVGG)
  2. Home Delivery (CVHD)
  3. Original School Name site (Elementary School) - When feeding congregate students at a site, a regular named site application must be approved.
  • Free/Reduced % - Make sure the % of F/R for the site is correct.
  • Summer Feeding: ALL sites being Closed Enrolled will not be approved. The CE should participate in NSLP if all sites are Closed Enrolled.

NSLP Monthly Submission Form

Only NSLP sites who are implementing a non-congregate meal service will submit the monthly submission form.

  1. The first page of this form is to notify TDA if the CE will implement the flexibilities in the following month.
  2. The second page is asking for the number of non-congregate meals in the past month's meal service.
  • CEs who submitted the Intake form to notify TDA of flexibility implementation should have received a confirmation email with the link to the form. The form is located on squaremeals.org.

Administrative Reviews

The Texas Department of Agriculture (TDA) appreciates your commitment to your students and their nutritional needs. TDA does realize this has been a challenging time.

In September 2020, TDA sent a notification temporarily suspending Administrative Reviews (ARs), Financial Reviews (FRs), and Procurement Reviews (PRs) until after September 30, 2020.


  • Reviews will resume on October 1st, 2020.
  • For PRs, Contracting Entities will have until October 21, 2020, to upload initial documents and complete the procurement table.
  • TDA will continue with 2020-2021 SY reviews based on the programs selected by the CE. The Resource Management Summary and Procurement Review will continue to be a part of the AR regardless of the program currently participating in


  • CEs who do not have an AR scheduled may have a "spot check" review for the paperwork of Intake forms and supporting documentation. Be sure to have the contracting entity application updated, Attachment B.


At-Risk Program Documentation

It is important to understand the documentation requirements per program.

See the following links for documentation requirements per program.


Verification Process

  • October 1 Verification Begins - ALL CEs submit the verification report. ALL CEs who have F/R applications as of Oct. 1 will conduct the verification process.
  • See Verification Process information here.

Region 6 Child Nutrition Specialists

Julie Dorman

Child Nutrition Program Specialist, SNP/SSO

936-435-8238

jdorman@esc6.net


Cindy Scott

Child Nutrition Program Specialist, SNP/SSO

936-435-8234

cscott@esc6.net


Dina Herrick

Child Nutrition Program Specialist, CACFP/SFSP

936-435-8244

dherrick@esc6.net

This guidance is not considered all-inclusive.

Please see squaremeals.org for further guidance.

Note: If TDA makes changes to the website direct links in this announcement may become void.

This institution is an equal opportunity provider. This program is funded by the USDA.