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Sites Approved to Operate in Close Proximity

Nutrition Services Division Management Bulletin

To: Summer Food Service Program Sponsors

Number: 04-704

Attention: Food Program Director

Date: August 2004

Subject: Open Summer Meal Sites Approved to Operate in Close Proximity

Reference: United States Department of Agriculture Summer Food Service Program (SFSP) Policy Memo 04-06; SP Policy Memo 04-06

This Management Bulletin provides the attached guidance from the United States Department of Agriculture (USDA) regarding "open" sites operating in close proximity. Please share this information with appropriate staff.

This memo is to inform sponsors and State agencies how multiple open sites may operate a summer program in close proximity to one another following the current program regulations. 

In many neighborhoods, State agencies have allowed only one site to operate, and State agencies have always given schools priority over the area.  This situation does not support current USDA priorities to expand access and participation in summer meals. The goal is best accomplished by bringing meals to where the children are through utilizing faith and community based organizations to serve additional summer meal sites.  This policy memo offers several situations where State agencies can approve more than one open site, if given some assurance the same children will not be served at multiple sites. 

Even in a small geographic area of a quarter mile square, we have seen a park program, a school, and a Boys and Girls Club and found the children at each location feel more comfortable going to that particular site and are not interested in traveling to another site for a second meal. 

We found schools have had only limited success drawing children from the surrounding community.  Schools are primarily serving their enrolled summer-school children and have only a small number of children from the community come for a meal.  Children are by and large not interested in returning to school during the summer to receive a meal.  Feedback has shown that instead of having to walk to another site children prefer to receive a meal at a community based site where they are already participating in activities. 

We have noted situations in several surveys and field reviews where it would be practicable to have two or more open sites in close proximity in an area, each serving its own distinct group of children.  (For example, an elementary school serves lunch in the cafeteria to summer school and some community children, and a public park activity two blocks away also serves lunch but to a different age-group of children.)  Historically, schools would have priority over the whole area, and the nearby park sites could not participate in the Summer Food Service Program (SFSP). The children would have to leave the park site and go to the school for the meal, something many children do not want to do.  We believe the goal should be to take the summer meals program to where the children are.

To support the greatest summer meal participation and access it may be appropriate to allow multiple open sites to operate in the community, each serving its own audience, under these conditions: the sites need to serve at the same/similar time and for a similar length of time to prevent children from going to more than one site for the same meal.

State agencies need to require sponsors wanting to operate sites in close proximity to each other to document in their program applications how they plan to deal with sites in close proximity to ensure children do not travel from site to site for meals.  Where relevant you may request the sponsor to explain how differences in the population of children they intend to serve require multiple sites in close proximity to each other.  It is also reasonable to request sites shorten the meal service time to prevent children from eating at more than one site.   

If your reviewers see a situation where this rule is abused, they should then address this with the sponsor.  Reviewers should inquire how the sponsor(s) plan to correct the problem.  We recommend the State agency allow the sponsor to test their corrective action plan to see if it eliminates the problem, before the State agency takes action to mandate a change or close the site.  The reviewer should follow up with the sponsor by phone or a site visit if possible to ensure the problem has been corrected.

USDA Policy Memo 04-06 (attachment is no longer available)

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Wednesday, April 15, 2015

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