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Meals for Students in Schools Not on NSLP


Nutrition Services Division Management Bulletin

To: School Nutrition Program Sponsors

Number: 03-106

Attention: Food Service Director

Date: May 2003

Subject: Meals Served to Students in Schools Not Participating in the National School Lunch Program

Reference: United States Department of Agriculture, Food and Nutrition Services, Schools Policy Memo 03 01; Title 7, Code of Federal Regulations sections 210.2 and 220.2; FNS Instruction 786-8, Rev. 1


This Management Bulletin provides a series of questions and answers from the United States Department of Agriculture (USDA) regarding reimbursement for meals served in special schools or institutions that do not participate in the National School Lunch Program (NSLP) or School Breakfast Program (SBP).

Questions and Answers
  1. When a public school district places students in special schools or institutions, hereafter called "pupil placement," are the meals served to those students eligible for reimbursement?

    Yes, but only if the school that serves students the meal is an eligible site and participates in the NSLP and/or SBP.

    Note: A placement school, home district, or another participating school may not claim reimbursement for a meal if the school serving the meal is not eligible or chooses not to participate in the NSLP and/or SBP. This applies even when the home district or another school participating in the NSLP and/or SBP provides the meal to an ineligible school, which then serves the meal to a child.

  2. What is an "eligible" school?

    The Richard B. Russell National School Lunch Act [42 U.S.C. 1760(d)(3)], the Child Nutrition Act of 1966 [42 U.S.C. 1784(3)], and NSLP and SBP regulations [7 CFR 210.2 and 220.2] define an "eligible" school as any public or non-profit private school of high school grade or under and any public or licensed nonprofit private residential child care institution. For a school and/or institution to be eligible, the California Department of Education must recognize it as part of California’s educational system. A "for-profit" school/institution is not eligible to participate in the NSLP and/or SBP.

  3. What is "pupil placement?"

    Pupil placement is when a public school district contracts with an outside school to provide necessary educational services unavailable within the district for a particular student. For example, a public school district may place a student with discipline problems in an alternative school or a student with a disability in a specialized school.

  4. Are there special considerations for "pupil placement" for students with disabilities?

    No. As previously stated, the school or district may claim reimbursement for meals only when the school that serves the meal to the student participates in the NSLP and/or SBP.

  5. Are there any provisions that accommodate off-site consumption?

    Yes. USDA's Food and Nutrition Service Instruction FNS 786-8, Revision 1, provides citations describing when a participating school may claim meals for reimbursement for off-site consumption. These situations are limited to meals served on supervised field trips and work-study programs. The home school or district cannot provide and claim a sack lunch everyday for a student in pupil placement at a nonparticipating or ineligible school.

  6. What alternatives should schools or districts consider for students placed in nonparticipating NSLP and/or SBP schools?

    If a school district places students in a school not participating in the NSLP and/or SBP, the district may wish to expand its contract to include the cost of providing meals for its students in pupil placement. However, such meals are not reimbursable under the NSLP and/or SBP.

    Please share this bulletin with your district/agency management and business personnel as appropriate.
Contact Information

If you have any questions regarding this subject, please contact your School Nutrition Programs (SNP) County Specialist. The SNP County Specialist list is available in the Download Forms section of the Child Nutrition Information and Payment System, Form ID Caseload. You can also contact the SNP Office Technician (OT), by phone at 916-322-3005 to be directed to your SNP County Specialist.

Questions:   School Nutrition Programs Unit | 800-952-5609
Last Reviewed: Wednesday, September 22, 2021
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