As many school food authorities (SFA) begin planning for summer 2024 operations, the California Department of Education (CDE) is providing this communication to highlight the differences between various summer feeding options, specifically the School Nutrition Programs (SNP), the Seamless Summer Option (SSO), and the Summer Food Service Program (SFSP). Please review the eligibility requirements, relevant resources and guidance materials, and frequently asked questions pertaining to summer feeding options.
State Meal Mandate
California Education Code (EC) Section 49501.5 requires public school districts, county offices of education, and charter schools serving students in kindergarten through grade 12 to provide a nutritionally adequate breakfast and lunch, free of charge, during each school day, regardless of a student’s eligibility for free or reduced-price meals.
EC Section 49501.5 (k)(3) defines a school day as any day that pupils in kindergarten or grades 1–12, inclusive, are attending school for purposes of classroom instruction, including, but not limited to, pupil attendance at minimum days, state-funded preschool, transitional kindergarten, summer school including incoming kindergarten pupils, extended school year days, and Saturday school sessions.
SFAs must ensure compliance with the state meal mandate and both state and federal regulations when planning to serve meals during summer school programs. Meals that fail to meet state and federal requirements are subject to disallowance.
Summer Meals: School Nutrition Programs
The purpose of the SNPs is to make meals available during each school day. SFAs serving meals only to children enrolled in academic summer school programs must operate and serve meals through the National School Lunch Program (NSLP) and School Breakfast Program (SBP). If you plan to operate the NSLP and SBP over the summer months, please update the appropriate SNP site applications in the Child Nutrition Information and Payment System (CNIPS)
. SFAs must ensure the months of operation in items A1 and B1 and meal service times in items A2 and B2 of the SNP site applications are updated to reflect summer school operations.
Please note, the current school year (SY) 2023–24 SNP CNIPS application only reflects operations through June 2024. Summer school operations under SNP for July and August 2024 will need to be represented in the SY 2024–25 CNIPS application, which will be available in July.
All summer meals served through the SNPs can be reimbursed at the free rate under the California Universal Meals Program (UMP). Please note that summer meals served through the SNPs must still be claimed by eligibility type. Meals that fail to meet state and federal requirements are subject to disallowance.
Summer Meals: Seamless Summer Option
The SSO allows SFAs to provide free summer meals in area eligible communities during the traditional summer vacation periods. Under the SSO, SFAs are not required to make eligibility determinations and will claim all meals at the free rate. To operate the SSO, the site must comply with all SSO administrative requirements and provide area eligibility data that demonstrates the site is located in a needy area, meaning the site is located where 50 percent or more of the children residing in the area are eligible for free or reduced-price school meals.
Please note, school sites eligible to operate the SSO may serve meals to students attending summer school classes only if the site is also open to the community and follows all normal SSO administrative requirements. Meals served under the SSO are eligible to receive Proposition 98 state meal reimbursement.
SSO site applications must be submitted and approved in the CNIPS prior to the start of SSO operations.
Summer Meals: Summer Food Service Program
SFAs also have the option to operate the SFSP during the summer months at eligible sites. SFSP is its own Child Nutrition Program, and as a result, has different administrative and meal pattern requirements than the SSO or SNPs. For information on the SFSP meal pattern requirements, application process and applicable deadlines, please visit the Summer Food Service Program Information web page.
SFAs choosing to operate and serve meals under the SFSP to enrolled summer school students must ensure that SFSP meals meet the SNP meal pattern requirements in order to satisfy the state meal mandate. Meals served under the SFSP do not receive additional state meal reimbursement. For information on the SNP meal patterns please visit the NSLP and SBP Meal Patterns web page.
Beginning in Summer 2024, all SFAs will also be required to submit a budget detail and management plan for the operation of the SFSP. SFAs that wish to operate a streamlined summer option should consider the SSO.
Area Eligibility
All SSO and SFSP sites must establish area eligibility to serve and claim meals under the respective programs. Area eligibility can be determined through school or census data, and eligibility is good for a duration of five years.
School data may be used to establish area eligibility, excluding camps, and must indicate that the proposed meal site is in a school attendance area where at least 50 percent of the children are eligible for free or reduced-price meals. To establish area eligibility for summer 2024, please use the current year data located on the CDE Free or Reduced-Price Meal (Student Poverty) Data web page.
Area eligibility can also be determined by using a Census Block Group (CBG) or Census Tract (CT). CBG and CT data are available through the Food and Nutrition Service (FNS) Mapper on the USDA FNS Area Eligibility web page
.
For additional information on area eligibility, please visit the Area Eligibility in Child Nutrition Programs Management Bulletin web page.
SSO and SFSP Site Types
The type of SSO or SFSP site designation will depend on the population being served at the summer feeding site. There are five different types of summer site designations that an SFA may operate. When submitting applications for SSO or SFSP, please review the different summer site types, eligibility, and outreach requirements. Below you will find details on the various summer site types:
- Open sites operate in communities where 50 percent or more of the children residing in the area are eligible for free or reduced-price meals. Program operators must provide area eligibility data that demonstrates the site is in a needy area. Open sites, including open school sites, must make meals available to all children in the community that are ages 18 and under. If a school is serving only enrolled summer school students, it is not considered an open site and must operate the SNPs instead of the SSO.
- Restricted-open sites have the same requirements as open sites. SFAs may request this type of site after experiencing safety, security, or control problems. This type of site remains open to the community at large, but only serves meals on a first come first serve basis. A written justification is required when requesting to operate this type of site.
- Closed-enrolled sites can be established where groups of needy children live in a pocket of poverty, where identified low-income children are transported to a congregate meal site located in a non-area eligible location. Closed-enrolled sites can also be established if an enrolled program provides recreational, cultural, religious, or other types of organized activities for a specific group of children. Eligibility must be determined through the collection of meal applications and direct certification, and it must be determined that 50 percent of the enrolled children are eligible for free or reduced-price meals.
- Note that schools serving only enrolled summer school students are not eligible to operate as closed-enrolled
- Schools offering only expanded learning opportunity program (ELOP) activities may operate as closed-enrolled and can determine eligibility as a traditional closed-enrolled site or through area eligibility.
- Note that schools serving only enrolled summer school students are not eligible to operate as closed-enrolled
- Migrant sites serve children from families of migrant farm workers, and a certification from a migrant organization is required when requesting to operate this type of site.
- Camp sites must determine eligibility for the enrolled children attending the camp through the collection of meal applications, and only the meals served to children who qualify for free or reduced-price meals may be claimed under the SSO at these site types.
For additional information on all site types and associated requirements please visit the Site Type, Eligibility, and Outreach Requirements web page.
Additionally, all summer feeding sites must comply with the quarter-mile site proximity reporting requirements. For more information on this, please visit the Summer Meal Site Proximity Reporting Requirements Management Bulletin.
Non-Congregate Meal Service Option in Rural Areas for SSO and SFSP
The Interim Final Rule, Establishing the Summer EBT Program and Rural Non-Congregate Option in the Summer Meal Programs
, allows for non-congregate meal service option for SSO and SFSP operators in rural areas where no congregate meal service is available.
SFAs interested in operating a non-congregate meal service in rural areas should first determine if the proposed site is considered rural per federal regulations. The USDA Rural Designation Tool
is available to assist operators in determining if sites are rural.
Additional guidance is still expected from the USDA this spring. To assist operators with preparing for non-congregate meal service in rural areas, the CDE will issue a management bulletin and a program integrity checklist.
Frequently Asked Questions
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Are SFAs required to serve both breakfast and lunch during summer school?
Yes, the state meal mandate and SNP meal standards applies during summer school days, and the SFA is required to make both a nutritionally adequate breakfast and lunch meal services available to all enrolled students.
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Will UMP funding be available for NSLP and SBP meals served during summer school?
Yes. SFAs participating in the NSLP and SBP for summer 2024 can receive the UMP reimbursement rates for all eligible meals served. Meals served under the SNPs must be claimed by eligibility type (free, reduced-price, paid). For more information on reimbursement rates please visit the 2023–24 CNP Reimbursement Rates web page.
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Our local educational agency (LEA) is offering ELOP enrichment activities instead of summer school. Does this count as a school day and can we serve NSLP and SBP meals?
Since ELOP activities are not considered instructional minutes, LEAs cannot serve or claim meals under the SBP and NSLP, and as a result, these meals would not be eligible for state or federal reimbursement. If a school site is offering both academic summer school and ELOP activities, then the site could serve and claim meals under the SBP and NSLP for all enrolled students during that school day. In this situation, meals served would be eligible for state and federal reimbursement so long as all meal requirements are met. For more information, please visit the Expanded Learning Opportunities Program FAQ web page.
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Can a school that is providing only ELOP enrichment activities participate as a closed enrolled SSO site?
Yes, sites serving only enrolled ELOP students may operate as closed-enrolled SSO sites. ELOP closed-enrolled sites may use individual eligibility determinations demonstrating 50 percent of the students enrolled in the program are eligible for free or reduced-price meals or establish area eligibility. Individual eligibility determinations can be made through the collection of meal applications or direct certification but cannot be made through alternative income forms.
For additional SSO questions and answers, please visit the SSO FAQ web page.
Contact Information
If you have any questions regarding SNP, please contact your SNP County Specialist. A current list of SNP Specialists is available on the SNP Specialist Directory web page.
For questions regarding the SSO, please email SSFO@cde.ca.gov.
For questions regarding the SFSP, please email SFSP@cde.ca.gov.