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Providing Meals During an H1N1 School Closure

Sponsors approved for meal programs may continue to provide reimbursable meals to low-income children during school closures and/or student dismissals caused by the H1N1 influenza virus.

Schools participating in the National School Lunch Program (NSLP) or School Breakfast Program (SBP) that are closed following declaration of a public health emergency may provide reimbursable meals using a modified Summer Food Service Program (SFSP) or Seamless Summer Feeding Option (SSFO). This modified option allows specific portions of the SFSP or SSFO to be waived. Providing meals during school closures and/or student dismissals is optional.

The United States Department of Agriculture (USDA) and Nutrition Services Division (NSD) encourage School Food Authorities (SFAs) and Community Organizations (COs) to consider this option. SFAs and COs should target and feed low income families while maintaining social distancing measures by keeping people from gathering in groups. With these goals in mind, meal delivery approaches may include, but are not limited to:

  • Delivering meals to bus stops
  • Delivering sack breakfasts or lunches to neighborhood community centers
  • Providing meal pick-up stations at local churches or parks
  • Delivering meals to low income housing projects

How to Obtain Approval to Serve Meals During an H1N1 Closure

Meal reimbursements must be claimed through the SFSP or the SSFO in the Child Nutrition and Information Payment System (CNIPS). SFAs and COs must have the following items approved by the NSD prior to commencing H1N1 Waiver operations:

  • SFSP or SSFO Agreement (available in CNIPS Download Forms)
  • H1N1 Waiver Request Form (available in CNIPS Download Forms)
  • CNIPS SFSP or SSFO site application(s)

SFAs and COs already approved to operate either the SFSP or SSFO are not required to submit a new Agreement. SFAs and COs not currently approved for the SFSP or SSFO should submit an Agreement immediately. Site applications must be completed in CNIPS only for sites that are closed by the State or local health department due to an H1N1 outbreak.

In addition to the H1N1 Waiver, flexibilities already exist in some USDA nutrition assistance programs that could support social distancing measures during a human pandemic, such as alternatives to schools meals and mailing or electronic transmission of benefits. To find out more about specific program options, please visit the USDA Disaster Assistance Web Page External link opens in new window or tab. .

Questions and Answers

Please note, for purposes of this Q&A, a school closure occurs when all students and staff are sent home. In a school dismissal, the school may remain open for staff while the children are sent home. The H1N1 Waiver may be used for school closures and dismissals. This Q&A uses the term closure for both circumstances.

  1. Which SFSP and SSFO requirements are waived for H1N1-related school closures?
    To support social distancing measures necessary during these outbreaks, the requirement that meals be served and consumed in a congregate setting is waived. Pre-operational training and monitoring requirements are also waived. The requirement that SFSP and SSFO operations occur only at non-school sites during an unexpected school closure that takes place during the school year is also waived. Requests to waive other operational requirements applicable to the need to provide meals during an H1N1-related closure will be considered on a case-by-case basis.
  2. What entities are eligible to operate the SFSP or SSFO during H1N1-related school closures?
    Any SFA or CO otherwise eligible to operate the SFSP or SSFO and which also enters into an agreement with the NSD to operate such programs when schools are closed due to an H1N1 outbreak may participate. SFAs and COs must have the following items approved by the NSD prior to commencing H1N1 Waiver operations: SFSP or SSFO Agreement, H1N1 Waiver Request Form, and CNIPS SFSP or SSFO site application(s).
  3. How does an SFA or CO initiate participation in H1N1 Waiver activities?
    The SFA or CO must submit an H1N1 Waiver Request Form (available in CNIPS Download Forms) to the NSD. An SFA or CO not already approved for the SFSP or SSFO must also submit an SFSP or SSFO Agreement. While multiple organizations in a community may work to respond to H1N1-related school closures, the NSD will not approve H1N1 Waiver requests that would duplicate coverage. Therefore, it is critical that communities identify the institution most able to respond to a closure at a particular school.
  4. Is it mandatory that meals be provided during a school closure?
    No. However, SFAs and COs are encouraged to ensure that the needs of low income students are met during extended school closures.
  5. May an SFA or CO operate the SFSP or SSFO only during an H1N1 outbreak and not during the summer?
    Yes, although we strongly encourage SFAs and COs to serve low income children during the summer as well.
  6. Are Child and Adult Care Food Program (CACFP) participants eligible for the H1N1 Waiver?
    The H1N1 Waiver is targeted to children who attend schools that have been closed due to H1N1. However, meals may be served to all children age 18 and under in the household if at least one child attends the closed school. If a child care center that participates in the CACFP is located in a closed school, students enrolled in that center are eligible for meals provided to children attending the closed school.
  7. May SFAs and COs serve parents and other adults in the community if they pay for the meal? What should we do about providing meals to nurses and other health care providers who may be providing vaccines to the public?
    If the SFA or CO has the capacity to provide meals to adults, they may do so but will not be reimbursed for those meals. Meals delivered to the home may be provided only for children in the family who are age 18 and under. Additionally, SFAs and COs should identify resources to address the needs of low income parents, as well as individuals who are preparing meals, giving vaccinations, or otherwise supporting efforts to combat the H1N1 virus.
  8. May an SFA operate the SSFO during an H1N1 outbreak and the SFSP during the summer?
    Yes, if the SFA has agreements with the NSD to operate both programs.
  9. If schools are not closed but a number of children are absent due to the H1N1 virus, may SFAs or COs provide reimbursable meals to these children?
    No. The H1N1 Waiver may be implemented only if the entire school is closed, i.e., all students are out of school.
Waiver Implementation
  1. From what level does the public health emergency declaration need to come in order to implement the H1N1 Waiver? For example, does the State or local health department have to declare an H1N1 public health emergency or is the declaration made at the Federal level?
    United States Department of Health and Human Services Secretary Kathleen Sebelius has already declared that a nationwide public health emergency exists involving H1N1 under the authority of Section 319 of the Public Health Service Act. Therefore, the H1N1 Waiver may now be implemented if a school is closed by State or local authorities.
  2. Who confirms that a school closure is for H1N1 instead of seasonal flu?
    Decisions regarding school closures are made at the State or local level. Therefore, the State or local public health department or other designated officials would be responsible for determining whether the closure is related to H1N1 or seasonal flu.
  3. Is the start date of the H1N1 Waiver determined by the SFA or CO?
    In consultation with the NSD, school district, and State and local public health officials, the SFA or CO determines when to begin serving meals under the H1N1 Waiver once a school is closed. SFAs and COs may decide whether to provide meal service immediately when schools are closed or delay implementation. The USDA and NSD encourage meal service to begin as soon after the closure as possible.
  4. Are H1N1 Waiver requests made after schools have been closed or may schools submit a request in advance?
    SFAs and COs are encouraged to develop and submit an H1N1 Waiver Request Form before the need for a school closure arises.
  5. The following requirements apply to the SFSP: media release, notification to the health department, pre-award compliance, health inspection certification, and budget. May these be waived under the H1N1 Waiver?
    The only SFSP requirements waived under the H1N1 Waiver are those relating to serving meals in a congregate setting and pre-operational training and monitoring. Otherwise, the SFSP and SSFO will generally operate as they do during the summer months. Requests to waive these and other operational requirements will be considered on a case-by-case basis.
  6. The SFSP establishes time frames for serving breakfast, lunch, and supper. May this requirement be waived and could this be a “standard” waiver, like waiving congregate feeding?
    This requirement may be waived in order to accommodate meal distribution systems that would provide children with more than one meal. For example, an SFA could have a daily distribution at which both breakfast and lunch are provided. The distribution method should be included on the H1N1 Waiver Request Form, and approval will be considered on a case-by-case basis.
  7. May meals be served on weekends and holidays (e.g., Thanksgiving)?
    SFAs and COs may be approved by the NSD to provide meals on weekends and holidays, if appropriate for the local circumstances.
  8. How would the H1N1 Waiver operate in year-round schools when the closure period includes a period when the SFSP or SSFO is normally scheduled to operate?
    If a school has a scheduled operation of the SFSP or SSFO during a planned break, it would need to operate under the H1N1 Waiver because of the need for social distancing.
Meal Distribution and Eligibility
  1. Who is eligible to receive meals?
    All children age 18 and under who reside in a household where at least one child is enrolled in the closed school are eligible to receive meals.
  2. How do SFSP and SSFO site eligibility requirements apply to H1N1 Waivers? Must all schools served be in low income areas?
    The primary goal of meal service offered during an H1N1-related school closure is to address the loss of school meals for the low income children enrolled in the closed school. Modifications to the SFSP and SSFO site eligibility requirements are provided in order to address the unique circumstances of these school closures. For purposes of the H1N1 Waiver, the determination of site eligibility is based not on the location of the site, but rather on the closed school’s population. For closed schools with 50 percent or more of the enrolled students eligible for free or reduced-price meals, SFAs and COs may develop meal distribution methods in which meals are available to all families with children enrolled in that school, with a focus on serving low income children. For closed schools with less than 50 percent free or reduced-price enrollment, meal distribution methods must more directly target the households of enrolled children who are eligible for free or reduced-price meals. Schools should use current free and reduced-price certification information or, if necessary depending on the timing of the school closures, immediate prior year eligibility certifications.
  3. May schools with less than 50 percent of children eligible for free or reduced-price meals serve paid children as long as they target children eligible for free and reduced-price meals? If so, would their meals be claimed at the free rate?
    Yes. Although the purpose of this effort is to ensure that low income children who would normally receive free or reduced-price school meals have access to nutritious meals during school closures, children that normally pay full price for their school meals may be served as long as the plan developed by the SFA or CO targets low income children. Children enrolled at the closed schools who come forward to receive meals should not be turned away. Children who are not eligible for free or reduced- price meals may be in need during a pandemic if parents are unable to work due to business closures or because of the need to provide child care. The H1N1 Waiver could provide a timely resource that would not necessarily be needed during normal school operation. Meals provided to children who are classified as paid under the NSLP or SBP will be reimbursed at the free rate under SSFO or at the applicable SFSP rate (see Q&A #42).
  4. Do private schools that normally participate in the NSLP or SBP qualify for the H1N1 Waiver?
    Yes. Private schools that participate in the NSLP or SBP are eligible to enter into an agreement for meal service during H1N1-related closures. Because they are SFAs, they may operate the SFSP or SSFO.
  5. May meals be provided to siblings who are not in school or who do not attend the closed school?
    Yes. If a household has a child enrolled in the closed school, reimbursable meals may be served to all children age 18 and under in that household.
  6. How many meals per child may be offered each day? May supper be provided? May meals be distributed for more than one day?
    The maximum number of meals that may be offered remains the same as under SFSP or SSFO: up to two meals, or one meal and one snack per child, each day. Meals may be served in any combination except lunch and supper. As discussed in Q&A #15, the NSD may approve a distribution approach that includes meals for multiple days if food safety and other requirements are met.
  7. What distribution methods and logistical issues need to be considered?
    In order to meet the need for social distancing during an H1N1 outbreak, the meal distribution methods should be either pick-up or delivery models. All methods should focus on targeting a closed school’s low income children using the free and reduced-price certification information available in each SFA. The logistical issues could be numerous and further support the need for SFAs and COs to begin planning immediately.
  8. Is there a plan for alternate meal delivery to children whose parents do not have transportation?
    As noted above, the SFA or CO determines the meal distribution method or methods. If the SFA or CO determines there is a need and it is logistically feasible to deliver meals directly to homes, it may do so with NSD approval.
  9. May a parent/caregiver of a child enrolled in a closed school pick up meals for all of the children in the household?
    Yes. As long as the meal distribution site can verify that the adult picking up meals has an enrolled child in the closed school, this would be permissible. This arrangement should be described on the H1N1 Waiver Request Form.
  1. Will NSLP edit checks be waived for meals provided under the H1N1 Waiver?
    The USDA has not provided a blanket waiver for edit checks. The NSD will work with the affected SFAs and COs to ensure that meal counts submitted are valid given local circumstances.
  2. How should SFAs and COs count the additional children in the household that are not enrolled in the closed schools but are provided with meals?
    At a minimum, the number of meals distributed must be recorded.
  3. Will separate reporting be required for meals served to children under the H1N1 Waiver or will the standard meal count reporting procedures apply?
    Separate meal counts and records must be maintained for meals served under the H1N1 Waiver. All of the meals for H1N1 closures must be claimed in SFSP or SSFO claims section in CNIPS.
  4. An SFA plans to check students’ names from a roster when meals are picked up. If an individual picking up meals requests meals for other children in the household, is the SFA required to record the names of the other children receiving meals or simply record that additional meals were provided to the household in which the enrolled child resides?
    The NSD encourages SFAs and COs to retain some type of meal count by student. If additional meals are requested for other children in the household, the SFA or CO may provide those meals and claim them at the free rate. The SFA or CO should have some method to avoid duplication so that meals for a given family are not provided twice. Whatever method is used, it is important that a record of the meals provided be maintained.
  5. How can a school with less than 50 percent free and reduced-price eligibility target low income children without overtly identifying that those children are eligible for free or reduced-price meals?
    This will mostly depend on how the SFA or CO provides meals. The SFA or CO should describe their meal distribution method on the H1N1 Waiver Request Form. Meal service must be targeted to children eligible for free or reduced-price meals, but that does not preclude the service of some meals to paid children. Meal distribution sites could be located in areas that are easily accessible to low income children, such as low income apartment complexes or housing projects.
Counting and Claiming Meals
  1. How will Provision 2 and Provision 3 schools be handled?
    Because all Provision 2 and 3 schools have a very high percentage of children eligible for free and reduced-price meals, SFAs and COs may develop H1N1 Waiver requests that make meals available to all enrolled students when the school is closed.
  2. Are second meals allowed under the H1N1 Waiver?
    No. Second meals may not be served under the H1N1 Waiver.
  3. May an SFA or CO collect a co-pay for reduced-price meals at closed schools where less than 50 percent of the children are eligible for free and reduced-price meals?
    No. Meals must be provided at no charge and no payment may be collected from students.
  4. Will there be a maximum number of meals that may be claimed by an affected area?
    No, there is no maximum total number of meals that may be claimed in an area. However, to ensure the integrity of the H1N1 Waiver, the NSD may establish a daily limit on meals served. SFAs and COs will be notified by the NSD in the event that a limit is established.
  5. Since all children in every household are eligible for free meals (including children not enrolled in school) and children do not have to come to pick up their meals, explain how the NSD will determine that a meal count is "reasonable?"
    The NSD will use factors such as the total enrollment of the closed school(s) and the extent and severity of the H1N1 outbreak in the community to determine if the meal counts are reasonable.
Meal Contents
  1. What are the meal requirements?
    The meals must meet the regular menu planning requirements of the SFSP or SSFO. The SFA and CO may find it easier to use food based menu planning and provide the maximum portion size, rather than providing meals based on the various ages of the children served. Offer versus serve (OVS) will not apply and all meals must be unitized, meaning a complete reimbursable meal that meets the requirements of the menu planning method used, including milk, must be distributed. Shelf-stable milk and USDA commodity foods may be used.
  2. Will a variety of fat contents in milk still be required?
  3. Will the milk requirement be waived if there is a shortage of shelf-stable milk?
    SFAs and COs should make plans to have shelf-stable milk on hand. If milk availability becomes an issue, the USDA will work with the NSD to provide the needed flexibility.
  4. Are SFAs and COs required to accommodate documented special needs?
    Yes. Any special needs issues should be addressed on the H1N1 Waiver Request Form.
Allowable Costs/Available Funds
  1. At what rates will the meals be reimbursed?
    SFAs and COs operating the H1N1 Waiver under the SFSP will be reimbursed at the appropriate rural/self-prep or urban/vended rates. SFAs and COs operating the H1N1 Waiver under the SSFO will be reimbursed at the applicable free meal rate for school meal programs. The reimbursements are provided on a per meal basis and no additional Federal funds, i.e., start-up or administrative, will be provided.
  2. What types of expenses may be paid from the nonprofit school food service account under the H1N1 Waiver?
    Schools may pay allowable costs from the nonprofit school food service account. Allowable costs may include equipment or supplies needed to hold and distribute meals, costs related to meal distribution, and staff wages for meal preparation and distribution. Public or private nonprofit organizations operating under the SFSP are not required to have a separate nonprofit food service account, but all regular SFSP requirements related to allowable costs and recordkeeping will apply.
  3. Will security at food delivery sites be reimbursed?
    Security is an allowable cost that may be paid from the reimbursement provided or from other funds in the nonprofit school food service account.
  4. Will there be an increased reimbursement to offset the cost of shelf stable products?
    No. Reimbursements are provided on a per meal basis.
  5. Will there be any additional administrative funds allocated to SFAs or COs operating under an H1N1 Waiver?
    No. Reimbursements are provided on a per meal basis and are expected to cover both administrative and operating expenses.
Questions:   SFSP: Melissa Garza | | 916-322-5885
SFSO: Donna Reedy | | 916-327-5866
Last Reviewed: Friday, July 29, 2016
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