Use of Vending Machines in School Meal Programs

This Management Bulletin (MB) provides information from the United States Department of Agriculture (USDA) regarding the use of vending machines in school meal programs.

The USDA Food and Nutrition Service (FNS) is aware that there is a growing interest among school food authorities (SFAs) to use vending machines in school meal programs. The following information provides interim guidance for SFAs that are considering whether a meal vending machine could be successfully incorporated into their National School Lunch (NSLP) and School Breakfast Programs (SBP). We are including a series of questions and answers below from the USDA regarding the use of vending machines.

SFAs must be aware that any vending machine that provides a reimbursable school meal represents an extension of school food service operations. Therefore, school meal vending machines are subject to the same program regulations, procedures, menu planning requirements, competitive food rules, and Offer versus Serve requirements that are applicable to meals offered on a regular service line with a cashier. Also, as a reminder, any use of “Program” (cafeteria) funds used in obtaining and maintaining vending machines to provide reimbursable meals must be in accordance with the applicable procedures set forth in Title 7, Code of Federal Regulations, Section 210.21, concerning the procurement of supplies, food, equipment, and services.

SFAs are responsible for ensuring that vending machines used to serve reimbursable meals are operated in compliance with program regulations. For example, the SFA must ensure that vending machines can properly dispense a reimbursable meal, accurately document when a reimbursable meal has been selected and served to each student, and track each meal by each student’s meal eligibility category (e.g. free, reduced-price, and paid). Moreover, SFAs must ensure that the use of vending machines does not allow an eligible student to receive more than one reimbursable meal per service period (e.g., one meal through the traditional meal line and a second meal through the vending machine). Also, it is critical that identity confirmation procedures do not overtly identify a child as receiving a free or reduced-price meal, as this is not allowed by federal and state laws. Additionally, all reimbursable school meals, including vended meals, must be priced as a unit.

Prior to using vending machines to serve reimbursable meals, USDA requires SFAs to notify the California Department of Education (CDE) of their intent to do so. The SFA would then include the vending machines in any administrative reviews to ensure that these machines and their use comply with NSLP and SBP regulations.

The USDA recognizes that vending machines play an expanding role in the operation of the NSLP and SBP. Personnel policies, labor costs, pressure on lunch room space, class schedules, and the limited duration of lunch-time periods all contribute to the need to explore more efficient and effective methods of delivering these important nutritional benefits to students. It is also critical that SFAs ensure the proper delivery of program services to students without unnecessarily inhibiting innovation. In addition, the Nutrition Services Division (NSD) requires that SFAs include a standard operating procedure (SOP) that specifically addresses food safety considerations for vending machines in their school food safety program based on Hazard Analysis Critical Control Point (HACCP) principles (if it is not already included in the HACCP SOPs).

The CDE, NSD has developed a Policy Statement Addendum for vending machines, which can be found in the Child Nutrition Information and Payment System (CNIPS), in Download Forms. SFAs may use this form (1) to notify the NSD of their intent to utilize vending machines, and (2) as an Addendum to their current Free and Reduced-Price Meal Policy Statement covering meal count and collection procedures (MCCPs) for the vending machine. Please note that MCCPs are site specific and must be submitted to the NSD for approval as district procedures change.

Due to the developing nature of FNS guidance regarding the operation and management of vending machines in the NSLP or SBP, please direct all related questions to the NSD’s School Nutrition Programs Unit at 916-445-0850 or your Field Services Unit Child Nutrition Consultant at 800-952-5609.

Questions and Answers Regarding Vending Machines
in Federal School Meal Programs

1. Are reimbursable meals offered through vending machines subject to the Offer versus Serve (OVS) provisions?

Yes, as stated in the United States Department of Agriculture SP-03-2007 memo, vending machines offering reimbursable meals are subject to the same procedures, menu planning requirements, competitive food rules, and OVS requirements that are applicable to meals offered on a service line with a cashier.

2. If a vending machine runs out of one or more components of a reimbursable meal, are meals still reimbursable?

No. Once a component is no longer available, OVS is not properly being implemented. The vending machine must become unavailable to students for the purpose of serving reimbursable meals. A “complete meal” means a meal containing all planned components/menu items, before the exclusion of components/menu items permitted when using OVS.

3. In a school offering OVS, does predetermination of menu selections in a vending machine (resulting in a “less than complete” set of choices while others may have a different set of choices) undermine the intent of the OVS requirement?

No. This is similar to multiple service lines in which every line may not offer all items. At a minimum, any vending machine used as part of the school meal programs must be able to dispense a complete meal. We encourage schools to stock as wide a variety of meal choices as possible for students utilizing these machines, but understand that the choices may not be as robust as those offered in a traditional service line.

4. How is a student’s free, reduced-price, or paid meal eligibility tracked when using a vending machine?

In order to distribute reimbursable meals, the school must be able to determine the student’s eligibility status, regardless of whether they use a vending machine or a traditional serving line. The school district must include this process in their point of service system and procedures.

5. Do vending machines need to allow a student to add money to his/her account and/or pay the difference between the account balance and the price of the item to be purchased if the student does not have sufficient funds in his/her pre-paid account?

Vending machines do not have to accept money from students, but there does have to be a mechanism for the student who has money to participate in the meal program. This mechanism could be that (1) a student provides money to a school representative who then adds money to the student’s account so that funding is available for the meal; or (2) the district assures that the student has access to a traditional meal service line that accepts cash.

6. Are vending machines limited to the same time restrictions as other types of lunch service (10 a.m. to 2 p.m.) when serving lunch under the National School Lunch Program?

Yes.

7. Do the student identifiers (name, ID number, biometric, cashier, etc.) for a vending machine need to be the same as used in a traditional meal service line?

The reimbursable school meal vending machine must have the same number of identifiers as the traditional meal service line, but the student identifiers do not have to be the same. For example, a cashier may be an identifier in a traditional line, along with a student’s unique PIN. The vending machine used in the school would need to use equivalent student identifiers, but they could be a biometric check and a PIN.

8. What does my district or agency need to do before purchasing and setting up vending machines to dispense meals?
   1. Complete the Policy Statement Addendum for MCCPs at http://www.cde.ca.gov/ls/nu/sn/documents/psmccpvendmach.doc (The preceding link is no longer valid. The form is located in CNIPS Download Forms, Form ID SNP-NSLP-04.) and submit for pre-approval.
   2. Follow federal and State procurement procedures for the purchase of any vending machine.
   3. Ensure that the machine can maintain the confidentiality/privacy for each student’s meal eligibility status.
   4. Follow the guidance provided in this MB.