CNP Operational Guidance FAQsFrequently asked questions (FAQs) for child nutrition programs (CNP) for the start of school year 2020–21.
Summer Food Service Program (SFSP)/Seamless Summer Option (SSO)
Do School Food Authorities (SFAs) need to reapply for any of the U.S. Department of Agriculture (USDA) waivers?
If your district requires a meal pattern waiver, or if you need to revise your meal pattern waiver, you must submit a request online via the COVID-19 CNP Meal Pattern Waiver Application.
If not previously approved for an area eligibility waiver, an SSO/SFSP sponsor must complete the online Area Eligibility Waiver Application. The opening of new sites will also require you to submit a waiver application.
To participate in area eligibility for an open SSO/SFSP site or a Child and Adult Care Food Program (CACFP) At Risk site, a CNP sponsor must complete the online COVID-19 CNP Area Eligibility Waiver Application.
To participate in area eligibility for closed enrolled sites, an SSO/SFSP sponsor must complete the online COVID-19 CNP Area Eligibility Waiver Application.
Under these waiver extensions, can SFAs serve students meals on days that schools are closed, such as weekends and holidays?
Yes. Meals may be offered on weekends and holidays, consistent with SFSP or SSO regulations.
Does the extension by the USDA of the summer feeding options now mean that all children under 18 can be fed even if they are not an enrolled student in our district?
Yes. SFAs may operate open feeding sites through the SFSP or SSO and provide meals to all children ages 18 and under. SFAs can also operate closed-enrolled SFSP or SSO sites to feed only the students enrolled at that site.
Can an SFA choose to operate a closed enrolled site under the USDA waivers?
Yes, SFAs may operate closed enrolled sites through the summer programs. When choosing this option, SFAs can only provide meals to students that are enrolled within the site.
If operating a closed enrolled site, can an SFA also include student's siblings that are not enrolled within our school district?
If an SFA is operating a summer feeding site as closed enrolled, they must only feed the children that are enrolled within the site. If the site wishes to serve siblings that are not enrolled in the school district, the site type should be 'open'.
Do these waiver extensions only apply to the summer feeding sites that we previously operated, or are districts allowed to add additional feeding sites?
SFAs may add additional feeding sites to those that have operated under COVID or Summer feeding. However, under federal regulations, any sites that are within a quarter mile of one another will need to work with their county analyst on options in order to comply with the boundary requirement.
Are SFAs required to provide a meal five days a week when students are distanced learning?
Per the state meal mandate, SFAs are required to provide meals for all days in which school is in session including distance learning models.
Under SSO and SFSP, will parents be allowed to pick up meals for their children?
Yes, the USDA waivers announced on August 31, 2020 include the parent meal pickup option.
Is it mandatory for SFAs to return to the Summer Meal programs or can they continue to provide meals through the National School Lunch Program (NSLP) or School Breakfast Program (SBP)?
Implementation of the new waivers is not mandatory. The California Department of Education (CDE) recommends that SFAs utilize the meal program that best fits their needs.
Can an SFA switch from SSO to SFSP? If so, how do we do so?
It is up to the SFA to determine which of the summer programs that they wish to operate. If an SFA wishes to apply for the SFSP, they must go through the new sponsor process to be approved to operate the program. The CDE highly encourages SFAs to serve through the SSO as it streamlines the administrative requirements for those SFAs that are already approved to operate the NSLP/SBP.
If we serve meals through SSO are these exclusive to our students or are we required to serve all children ages 0-18? Does enrollment need to be confirmed, or are tallies ok again?
All SSO and SFSP claiming rules must still be followed under the current waivers. Additionally, all rules governing the site type are still in effect. So, if you have a closed site, then you only need to serve to the enrolled children; for an open site you will need to feed all eligible children coming to the site. Tallies are ok when operating an open feeding site.
When can SFAs begin operations under the SSO or SFSP?
The USDA waivers to allow Summer feeding were announced on August 31 and indicated that they were effective immediately. Agencies can begin transitioning to summer meal programs now by updating their Child Nutrition Information and Payment System (CNIPS) applications to reflect the current feeding models that they are implementing. Refer to question 16.
Will SFSP/SSO be retroactive for schools who served meals in August prior to waiver announcement?
Yes. When submitting claims for meals served between the beginning of school year 2020–21 and December 31, 2020, SFAs which have been approved to participate in SSO/SFSP pursuant to Waiver #56 may claim meals served under SFSP or SSO rather than through NSLP/SBP. SFAs may receive reimbursement for these meals at the free rate through SFSP or SSO. However, any student who paid for their meals must receive a refund for their meal payments.
Can an SFA that has already started the school year opt into these waivers or must they continue with the NSLP/SBP?
Schools may choose to operate under the SFSP or the SSO even if the school year has begun or if the agency has started meal service through the NSLP/SBP. Please ensure that your CNIPS application is updated and reflects the correct meal service model that your agency is operating. Also, complete the area eligibility waiver as needed for any sites that are below 40 percent free and reduced-price eligibility.
What about SFAs who have never participated in SSO/SFSP? Will they be able to apply?
Yes, agencies that have not previously participated in SSO or SFSP can apply to participate under this waiver. The CDE highly recommends that school districts apply through the SSO as the application process is streamlined for districts that are already approved on the NSLP/SBP.
I went in to update my site application in CNIPS, but September is not listed.
SFAs operating summer feeding for September 2020 will need to update their CNIPS site applications in the CNIPS program year 2019–20. CNIPS current year 2020–21 begins in October for summer programs.
If one of the school sites in our district returns to a form of in-person learning, can we still provide meals through the summer programs through December 2020?
Yes, the new waivers allow the district the discretion to determine if SSO/SFSP or NSLP meets their needs.
Are SFAs allowed to continue to collect applications for Local Control Funding Formula (LCFF) purposes?
Yes. While school meal applications are not required for SSO or SFSP, they will be required if schools are required to transition back to NSLP/SBP after December 31, 2020. In addition, school meal application data is used for other purposes including LCFF funding. The CDE is extending the deadline for schools to report free and reduced-price meals program record start dates in the California Longitudinal Pupil Achievement Data System (CALPADS) to December 31, 2020 to help you obtain information for purposes of LCFF. Therefore, we highly recommend continuing to collect school meal applications unless you are part of the Community Eligibility Provision or non-base year Provision 2.
Do we have to conduct verification on applications that we have already received?
We are awaiting further guidance from the USDA as to how local educational authorities (LEAs) are to proceed with verification requirements considering that operators are not required to collect meal applications for the summer meal programs.
Will SFAs with an AR this year now have an SSO review and an NSLP review?
Yes, if an SFA is already scheduled for a School Nutrition Program (SNP) Administrative Review (AR) in school year 2020–21 and is operating SSO, they will have both programs reviewed. Similarly, if an SFA already had a SNP AR in 2019–20 and they are new to SSO during August or September, they will have an SSO review that covers those months.
Will program operators have a SFSP review?
If they are new to SFSP, they will have a review in whatever year they add onto the program.
Meal Pattern/Potable Water
How does the court decision regarding the Child Nutrition Programs: Flexibilities for Milk, Whole Grains and Sodium Requirements Final Rule affect SY 2020-21?
The 2018 CNP: Flexibilities for Milk, Whole Grains and Sodium Requirements Final Rule (which allowed flavored 1 percent milk, only half of the grains to meet the whole grain-rich criteria, and sodium Target 1 levels) was vacated by US District Court in April 2020. This means that for SY 2020–21, CNP Operators no longer have those flexibilities, and must revert back to the 2012 meal pattern requirements. Specifically:
- For NSLP, SBP, and CACFP (for children over age 6) flavored milk may only be non-fat.
- For NSLP and SBP all grains served must be whole grain-rich.
- For NSLP and SBP must meet Target 2 weekly sodium levels.
For information about a meal pattern waiver refer to questions 23 and 24.
Can we use the COVID-19 Nationwide Meal Pattern Waiver if we are not able to comply with the 2012 meal pattern requirements for milk, grains, or sodium requirements?
Yes. The USDA has stated that the use of the COVID-19 Nationwide Meal Pattern Waiver (effective through June 30, 2021) is allowable if CNP Operators cannot meet the stricter 2012 meal pattern requirements brought about from this court decision for SY 2020–21. The Food and Nutrition Service understands that procurement for SY 2020–21 was underway when the court decision relating to the 2018 Child Nutrition Programs: Flexibilities for Milk, Whole Grains, and Sodium Requirements Final Rule was rendered, and therefore, Operators may have challenges meeting these reinstated requirements. CNP Operators wanting to use the meal pattern waiver for these specific flexibilities will need to submit a COVID-19 CNP Meal Pattern Waiver Application. For questions regarding the meal pattern waiver please send an email to CNPMealPatternWavier@cde.ca.gov.
Can CNP Operators waive the age/grade group requirements using the COVID-19 Nationwide Meal Pattern Waiver for SY 2020-21?
Yes. if a CNP Operator has justification that serving one age/grade group meal pattern is necessary to provide nutritious meals while minimizing exposure to COVID-19, then they may submit a meal pattern waiver, indicating which meal components will not be met. View the COVID-19 CNP Meal Pattern Waiver Application.
The USDA encourages CNP Operators, when possible, to use the overlap between the requirements in different age/grade groups to offer a single menu to multiple grade groups without the use of a meal pattern waiver. For example, Operators may offer the same breakfast menu to all children in grades K–12. Likewise, operators may offer the same lunch menu to all children in grades K–8. The meal pattern for grades 9–12 at lunch requires larger amounts of food to meet the nutritional needs of older children. If an Operator requests to serve the same lunch meal to K–12, it is encouraged for the Operator to provide extra food to the grade 9–12 students, such as an extra piece of fruit.
Are schools required to provide potable water to students eating lunch at school when lunch is served in the classroom?
Yes. When lunch is served in the classroom, schools are required to make water available during the meal service. Schools are generally required to make potable water available to students where meals are served during the meal service (7 CFR 210.10(a)(l)(i). Although lunch is not typically served in the classroom, to accommodate social distancing during the COVID-19 pandemic, when lunch is served in the classroom, the potable water requirement does apply.
Are schools required to provide potable water to students eating breakfast at school when breakfast is served in the classroom?
No. Consistent with SBP regulations for potable water (7 CFR 220.8(a)(1)) while water must be made available when breakfast is served in the cafeteria, schools are not required to make water available when breakfast is served outside of the cafeteria. Schools are encouraged to make potable water available in all meal service locations as safety permits.
If I continue to operate the NSLP/SSO through December 2020 do I need to apply for a meal pattern waiver if I cannot offer two different types of milk given limited refrigeration in our COVID-19 meal distribution process?
Yes. Under program regulations for SFSP and SSO, those meals must meet the meal pattern requirements. However, in the COVID-19 Nationwide Meal Pattern Waiver in the SFSP and NSLP SSO—EXTENSION 7, the USDA has waived meal pattern requirements for these programs during this public health emergency, through December 31, 2020, if Operators apply for a waiver. Therefore, NSLP/SSO Operators who are unable to offer a variety of fluid milk (at least two different options), would submit a Meal Pattern Waiver Application requesting milk requirements be waived. For any questions regarding the meal pattern waiver please send an email to CNPMealPatternWavier@cde.ca.gov.
CACFP At-risk/Waiver Applications/Annual Updates
For the At-risk component of the CACFP, must enrichment be offered to participants? What about on the weekends?
Yes, the activity requirement is still in effect, and must be offered to all participants who show for the afterschool meals, whether it's on a school day or on a holiday or weekend (this includes regular school vacation periods). That being said, please note that you may offer the activity strictly through distance learning.
How do we describe the enrichment in the CACFP application online, in CNIPS?
If your site or sites are already approved in the CNIPS CACFP module, you do not have to change the enrichment description. In this case, the CNIPS locks that field for the five-year cycle for each approved site. If, however, your site or sites are not yet approved in the CNIPS CACFP module, and your enrichment is going to be distance-based, you would simply provide a summary description of the activity that best reflects the activity. For example, if you plan to hand out self-study packets with arts and crafts and-or nutrition-based education exercises, just a one or two sentence description is acceptable. If you are still unsure of how to describe the activity in CNIPS, reach out to your assigned CACFP Specialist for further assistance.
For online enrichment, are take-home study packets acceptable? May we offer multiple take-home study packets at one time, to cover us for the enrichment for days or weeks at a time?
Take-home study packets are acceptable; and yes, you may offer them in bulk, as long as you continue to offer them in tandem with the afterschool meals to any participant who has not yet been offered the packet for the duration of time it is meant to cover. This means you would at a minimum need to advertise the presence of the study packet each day. For example, say you offer the study packets on Monday to cover all enrichment for that week—you should still offer them to new participants and advertise them to already enrolled participants, so everyone present for the meals knows where the packets are or how to ask for one (if for example, students misplace it).
Do we still have to document meal counts and attendance for At-risk?
Meal counts are required, as they support your claim for reimbursement.
Considering that the attendance requirement could be a challenge for many At-risk operators to document in the distance learning model, we have asked the USDA to clarify if it is still required and how operators might capture it. Stay tuned for further written clarification.
If a waiver was extended, do we need to reapply if we were approved? Has anything changed on that?
The waivers you must opt into are:
- Area eligibility for open sites for SFSP/SSO
- Area eligibility for closed enrolled sites for SFSP/SSO
- Area eligibility for CACFP At Risk sites
- Meal pattern
The above waivers require a formal notification to the CDE of your intent, as we have to approve each one case by case. If you already applied, you do not need to reapply.To participate in area eligibility for closed enrolled sites, an SSO/SFSP sponsor must complete the COVID-19 CNP Area Eligbility Waiver Application.
If your district requires a meal pattern waiver, you must submit a COVID-19 CNP Meal Pattern Waiver Application.
To participate in area eligibility for an open SSO/SFSP site or a CACFP At Risk site, a CNP sponsor must complete the online COVID-19 CNP Area Eligibility Waiver Application.
We are preparing our CACFP annual update. Much is uncertain as to whether we will be open for the full program year, given COVID-19 concerns and everything that is going on. If we are unsure if we will operate the CACFP in 2020–21, should we still submit the annual update? What if we think we will only offer the CACFP in certain months?
If you are considering to offer and claim CACFP meals at any point in the coming program year, which starts on October 1, you must submit the annual update, as not doing so could jeopardize the status of your CACFP agreement to participate. It is acceptable to (for now) only check off certain months for active meal service, or just leave all months checked and not claim for those months. The key is to ensure that your submission accurately reflects your intent to participate; and if, after your annual update is approved or reviewed, you need to adjust your meal schedule, this is acceptable. If you know that you will be unable to offer the CACFP for the forthcoming program year and do not want to be on the hook for submitting the annual update, you must send your assigned CACFP Specialist a self-cancellation form, the template for which we have available to you in the CNIPS Download Forms.
Are we allowed to serve CACFP At-risk plus SFSP/SSO, now that the USDA has extended the summer program waivers?
Yes, you may operate them simultaneously. Please remember that, unless specifically waived, all program eligibility and operating requirements are still in effect. Also, participants should not receive more than the number of reimbursable meals allowed in each program for which they are eligible.