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Questions and Answers on Head Start Programs


Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

Date: May 2014

Number: CNP-05-2014

To: Child Nutrition Program Sponsors

Attention: Food Program Director, Food Service Director

Reference: U.S. Department of Agriculture (USDA) Policy Memoranda SP 40‑2013, CACFP 11-2013, and SFSP 13-2013; SP 34-2008, CACFP 10-2008, and SFSP 09-2008; and SP 23-2008, CACFP 07-2008, and SFSP 08-2008; USDA Policy Letters “Automatic Eligibility of State-Funded PreKindergarten Participants for Free Meals in the Child and Adult Care Food Program, the National School Lunch Program, and the School Breakfast Program” July 22, 1999, and “Automatic Eligibility for Free Meals in the National School Lunch Program, School Breakfast Program, Special Milk Program and Child and Adult Care Food Program for Participants in the Head Start Program” April 14, 1995; California Department of Education Management Bulletins USDA-SNP-11-2013 and USDA-SNP-08-2008

Supersedes: California Department of Education Letter to All Head Start Programs, September 18, 1995

Subject: Questions and Answers on the Participation of Head Start Programs in Child Nutrition Programs


This Management Bulletin (MB) provides consolidated guidance on U.S. Department of Agriculture (USDA) Child Nutrition Program (CNP) policy related to the Head Start Program. It includes questions and answers (Q&A) on state and federal topics related to Head Start and Early Head Start participation in the CNPs. Be sure to review this full MB.

To read USDA Policy Memorandum SP 40-2013, CACFP 11-2013, and SFSP 13-2013, please visit the USDA Q&As Regarding the Participation of Head Start Programs in Child Nutrition Programs Web page at http://www.fns.usda.gov/qas-regarding-participation-head-start-programs-child-nutrition-programs. For more information about the Head Start Program and Early Head Start Program, please visit the Office of Head Start (OHS) Web page at http://www.acf.hhs.gov/programs/ohs/.

Background Information

The Healthy, Hunger-Free Kids Act of 2010 encourages the USDA to find ways to avoid unnecessary or duplicative paperwork in the Child and Adult Care Food Program (CACFP). As part of this effort, the USDA’s Food and Nutrition Service (FNS) established a Paperwork Reduction Work Group. One of the workgroup’s recommendations was to consolidate policy related to Head Start and Early Head Start participation in the CNPs.

The FNS issued a Policy Memorandum to all CNPs emphasizing categorical eligibility of Head Start and Early Head Start participants. The policy ensures that these populations receive healthy and nutritious meals without undue barriers.

Questions and Answers
  1. Do children participating in Head Start or Early Head Start need to complete additional income eligibility forms to qualify for free meals? 

    Children enrolled in federal and state-funded Head Start or Early Head Start Programs are categorically eligible to receive free meal benefits without further application or eligibility determination. Categorical eligibility means Meal Benefit Forms are not required.

    Eligibility determinations for the CNPs are made on an annual basis. As long as the child is enrolled in Head Start or Early Head Start at the time the annual eligibility determination is made, all reimbursable meals served to that child may be claimed at the free rate.

    Institutions, sponsors, and school food authorities may establish eligibility of all Head Start enrollees through documentation provided by the Head Start program. Forms of acceptable documentation include:

    • Approved Head Start application
    • Statement of Head Start enrollment
    • List of participants from a Head Start official
  1. If a child who is eligible for Head Start benefits also attends a child care center or day care home, is the child automatically eligible for free CACFP meals at the child care facility without further application or eligibility determination?

Yes. All CACFP reimbursable meals served to children enrolled in Head Start or Early Head Start may be claimed at the free rate by child care centers or at Tier I rates in day care homes in which they are enrolled. Documentation of acceptable Head Start eligibility must be maintained.

  1. Are the siblings or other children who are members of a Head Start child’s household also automatically eligible for free meals without further application?

Only children enrolled in Head Start are categorically eligible. Categorical eligibility based on Head Start enrollment does not extend to all children in the same household.        

  1. Can a day care home document its eligibility for Tier I reimbursement based on the provider’s own child’s enrollment in a Head Start program?

The Improving Head Start for School Readiness Act of 2007 (Public Law 110-134) extended categorical eligibility only to children enrolled in Head Start; therefore, a child’s Head Start enrollment does not extend to the provider.

This supersedes the guidance found in USDA’s Questions and Answers #4: Two-tier Reimbursement Structure for Family Day Care Homes Participating in the Child and Adult Care Food Program May 16, 1997.

  1. Are children who are enrolled in Head Start, but who are members of households that are above the Head Start income eligibility requirements, still eligible for CACFP meals at the free rate?

Yes. All reimbursable meals served to children enrolled in Head Start may be claimed at the free rate. Head Start serves primarily children from families with household incomes at or below the federal poverty level. However, a small proportion of children in families with household incomes above the poverty level may also be served.

Public Law 110-134 amended sections 9(b)(12)(A)(iii) and 17(c)(5) of the Richard B. Russell National School Lunch Act to make any child enrolled in Head Start categorically eligible for free meals without further application or eligibility determination.

  1. Are children enrolled in state-funded prekindergarten programs eligible for free meals?

Children participating in state-funded prekindergarten programs are not automatically eligible for free meals. In California, the income eligibility requirements for state-funded preschools are less stringent than the requirements for the Head Start Program. Therefore, determinations of eligibility for free meals for participants must be made on an individual basis.

  1. Are children enrolled in Indian Tribal Organization (ITO)-funded prekindergarten programs eligible for free meals?

    Participation in an ITO-funded prekindergarten program may be a basis for extending automatic eligibility for free meals only if the ITO meets all of the following criteria:  

    • The ITO-funded prekindergarten program uses income eligibility criteria which are identical to, or more stringent than, the Head Start Program.

    • The ITO-funded program is modeled after the Head Start Program and can serve some percentage of children from households with income over Head Start’s income guidelines, and it can differentiate between children receiving ITO funding based on income and children receiving funding based on other criteria.

    • In cases where the ITO-funded prekindergarten receives funding under more than one program, the ITO can differentiate between funding sources for the children in each program.

    • Income determinations for the ITO-funded program do not exceed 12 months in length.

    Once an ITO certifies that all of these conditions have been met, the California Department of Education (CDE) may request that the FNS Regional Office approve categorical eligibility for children participating in that ITO-funded prekindergarten program for up to one year. The approval may be renewed every year once the FNS Regional Office receives the ITO’s certification that the program still meets all four criteria.

    ITO-funded prekindergarten program directors should consult with their assigned CNP analyst for further guidance.

  1. Are Early Head Start participants who are pregnant considered categorically eligible for free meals?

Yes. Participants in Early Head Start who are pregnant and otherwise eligible to receive meals through a CNP are categorically eligible for free meals. Public Law 110-134 amended sections 9(b)(12)(A)(iii) and 17(c)(5) of the Richard B. Russell National School Lunch Act to establish such eligibility.

  1. Do Head Start centers need to annually verify enrollment or is the documentation valid for the entire period a child is enrolled in Head Start or Early Head Start?

Documentation of enrollment is required annually for each CACFP participant, including those enrolled in Head Start and Early Head Start. 

  1. Do Head Start centers need to document a parent’s decision to decline an offered infant formula? 

Because Head Start has more comprehensive infant formula requirements than the CACFP, Head Start centers do not need to document a parent’s decision to decline offered formula. However, in order for the infant meal to be reimbursable, it must meet the CACFP meal pattern requirements.  

  1. How should a CACFP center report meals and snacks in the Child Nutrition Information and Payment System (CNIPS) in the following scenario?

A center provides breakfast and an a.m. snack to children in a Head Start program in the morning, and a p.m. snack to children in a state preschool program in the afternoon (that includes Head Start and non-Head Start eligible children).

In California, agencies submit claims for meals and snacks in the CNIPS. In the scenario listed above, the agency must report both the breakfast and the a.m. snack served during the Head Start program under the Head Start section of the claim and report the p.m. snack served during the state preschool program under the child care section of the claim.

Reminder: All children eligible for Head Start benefits who also attend state preschool would be categorized as free (with acceptable eligibility documentation). The agency must obtain Meal Benefit Forms for children enrolled in the state preschool who are not eligible for Head Start.

  1. How should a center with the classrooms listed below report meals/snacks in the CACFP claim for reimbursement?  

    Classroom A—all Head Start children
    Classroom B—8 Head Start children and 10 preschool children
    Classroom C—all state preschool children

    The center is required to report meals and snacks as follows:

    • Classroom A: The center should report meals/snacks under the Head Start section of the claim for reimbursement. The center may use the total count method (total number of meals) versus the actual count method (meal count by child), to document the number of meals/snacks.

    • Classroom B: The center must report meals/snacks served to the 8 Head Start children under the Head Start section of the claim and report meals/snacks served to the 10 state preschool children under the child care section of the claim. The center must use the actual count method to maintain accurate meal counts.

    • Classroom C: The center must report meals/snacks under the child care section of the claim for reimbursement. The center may use the total count method to document the number of meals/snacks.
  1. If a center participating in the CACFP is issued one license to operate both Head Start and child care, is the agency required to obtain separate approval for each program type in order to submit claims for meals served to children enrolled in both programs?

Yes. In the CACFP site application portion of the CNIPS, the agency would add one site if they share the same address. However, the agency should add two different program types (found in the drop down menu on the Program Type tab). The agency should select Head Start as one program type, and select either Preschool Age Center, Infant/Toddler, or School Age Center for the second program type based on the type of license they acquired.

It is important that agencies separate Head Start programs from other program types as they have separate sections on the claim form. If only Head Start is listed as a program type, only the Head Start portion of the claim will be visible. The Child Care portion of the claim will be visible if at least one of the other three program types are listed in the site application.

Given that all meals are reimbursed at the free rate in the Head Start section of the CNIPS claim, agencies may not claim other program types in this section. The CDE reimburses other program types based on the eligibility determination of each child.

  1. What role does the Community Development Institute (CDI) play in Head Start and CACFP?

The CDI is the National Interim Management contractor for the U.S. Department of Health and Human Services OHS. The OHS has contracted with CDI, a nonprofit corporation headquartered in Denver, Colorado, to provide interim Head Start management services nationwide. For more information regarding the CDI, please visit the CDI Head Start Web site at http://www.cdiheadstart.org/.

Questions

If you have any questions regarding this MB, please contact the appropriate Nutrition Services Division Specialists for your agency.

School Nutrition Programs (SNP): A contact list of SNP Specialists is available in the Download Forms section of the CNIPS, Form ID Caseload SNP. You can also contact Susan Phun, SNP Unit Office Technician, by phone at 916-322-1450 or by e-mail at sphun@cde.ca.gov, to be directed to your SNP Specialist.

CACFP: A contact list of CACFP Specialists is available in the Download Forms section of the CNIPS, Form ID CACFP 01. You can also contact Nancy Charpentier, CACFP Unit Office Technician, by phone at 916-322-2771 or by e-mail at ncharpentier@cde.ca.gov, to be directed to your CACFP Specialist.

Summer Food Service Program (SFSP): A contact list of SFSP Specialists is available in the Download Forms section of the CNIPS, Form ID SFSP 01. You can also contact the SFSP Unit Office Technician, by phone at 916-322-8323 or by e-mail at sfsp@cde.ca.gov, to be directed to your SFSP Specialist.

Questions:   Nutrition Services Division | 800-952-5609
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