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Preventing Overt Identification of Children

Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
To: School Nutrition Program Sponsors Number: USDA-SNP-06-2013
Attention: Food Service Directors Date: October 2013
Subject: Preventing Overt Identification of Children Certified for Free or Reduced-Price School Meals
Reference: U.S. Department of Agriculture Policy Memo SP 45-2012

This Management Bulletin (MB) reiterates the U.S. Department of Agriculture’s (USDA) requirements for preventing overt identification of children eligible for free or reduced-price (F/RP) school meals. It also includes USDA’s suggestions about methods that School Food Authorities (SFA) may use to avoid as much overt identification as possible.


The USDA defines overt identification as any action that can identify a child as approved or potentially eligible to receive F/RP school meals or free milk. An SFA must ensure that it does not disclose a child’s eligibility status at any point in the process of providing F/RP meals, including notification of the availability of F/RP benefits, certification and notification of eligibility, provision of meals in the cafeteria, point-of-service (POS) meal count, and/or through the payment method.

Prohibited Actions

Title 7, Code of Federal Regulations, Section 245.8, Nondiscrimination Practices for Children Eligible to Receive Free and Reduced-Price Meals and Free Milk, prohibits SFAs from:

Direct Certification

SFAs are not required to provide applications to parents when children are eligible for free meals through direct certification, but they must ensure that the method used to distribute applications cannot overtly identify these children. If an SFA distributes applications to individual households by mail (including e-mail) or in individual student packets or provides online availability, the SFA does not need to provide applications to households in which all children are determined eligible through direct certification. If the distribution method is not individualized, the SFA must provide applications to all households (7 CFR Section 245.6[b][10]).

Free and Reduced-Price Policy Statement

The required information of the SFA’s F/RP Policy Statement is more expansive than the list below. This list refers only to descriptions and methods SFAs use to prevent disclosure of a student’s F/RP eligibility status and overt identification. It does not include other required policy statement information unrelated to application and meal payment collection or meal counting systems. The F/RP Policy Statement must:

  1. Describe the procedures the SFA uses to distribute and collect F/RP applications and how the procedures prevent overt identification

  2. Describe the method(s) the SFA uses to collect payments from students paying the full price of a meal or milk, or the reduced price of a meal; the description must include how the method(s) prevents the overt identification of the students receiving F/RP meals or free milk

  3. Describe how the SFA prevents overt identification at the point of service when serving free, reduced-price, or paid meals

  4. Describe how the cafeteria staff and all meal service procedures, including those for competitive foods, prevent overt identification of the students receiving F/RP meals or free milk

  5. Describe how an SFA that accepts both cash and electronic payments prevents overt identification of F/RP students
Food Service Area

The prevention of overt identification in the food service area, especially at the POS, is essential. An SFA must ensure that there are no separate dining areas, service times, or serving lines. This includes having different serving lines for National School Lunch Program (NSLP) meals and competitive foods. If an SFA has a food service line that sells only competitive foods and another food service line that provides only NSLP meals, this allows for overt identification because students using the NSLP line can be identified as eligible for F/RP meal benefits.

When selling competitive foods, an SFA can prevent overt identification by:

  1. Limiting competitive foods to those foods also offered as part of reimbursable meals on the reimbursable lunch lines; for example, if a burrito is part of a reimbursable NSLP meal, the SFA could also sell a burrito as a competitive food

  2. Offering competitive foods in the same lines as the SFA offers reimbursable meals, i.e., do not serve NSLP meals and competitive foods on different lines

  3. Requiring students to purchase competitive foods with a pre-paid card
Media of Exchange

The following are payment considerations to prevent overt identification:

  1. SFAs must ensure to the maximum extent practicable that the method of payment does not identify a student as eligible for F/RP meals.

  2. The USDA and the California Department of Education recommend that SFAs use prepayment systems as much as possible to limit the exchange of money, which can indicate a student’s eligibility status. Prepayment systems virtually eliminate overt identification of low-income children during the meal payment process.

  3. SFAs must make reasonable efforts to publicize and encourage use of prepayment options by students and parents. SFAs should provide multiple ways to make prepayments, such as online and at locations within the school. When a student’s prepaid balance is getting low, the SFA should notify the parents or guardian.

  4. SFAs cannot code or color any meal cards, tickets, tokens, or other payment methods in a manner that would overtly identify F/RP eligible children.

  5. SFAs must take steps to ensure that students cannot view rosters, computer screens, or other equipment used at the POS.

  6. SFAs should mask or code information on the rosters or screens to avoid students or staff who should not see information regarding a student’s eligibility status.

If you have any questions regarding this MB, please contact your School Nutrition Programs Specialist listed on form Caseload SNP in the Download Forms section of the Child Nutrition Information and Payment System. You may also call the School Nutrition Programs Unit secretary at 916-322-1450 or 800-952-5609.

Questions:   Nutrition Services Division | 800-952-5609
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