Interagency Agreements in School Food Service

This Management Bulletin (MB) provides guidance on the interagency agreement requirements when administering the federal School Nutrition Programs (SNP) at unaffiliated schools. School food authorities (SFA) must execute an interagency agreement when adding an unaffiliated school to their SNP Permanent Single Agreement (PSA) with the California Department of Education (CDE). An interagency agreement establishes the terms and conditions by which an SFA provides meals to and claims reimbursement for meals served to students in an unaffiliated school. An unaffiliated school is one that is not under the SFA’s administrative jurisdiction, such as a charter school, private school, or a nonpublic school.

In order to participate in the SNPs under an SFA, unaffiliated schools must meet specific eligibility criteria. The SFA must obtain and submit to the CDE:

• Evidence that the unaffiliated school meets the definition of a school under Title 7, Code of Federal Regulations (7 CFR), sections 210.2, 215.2, and 220.2 by providing the following:
  
  
  • Public schools: Entry of the County-District-School code on the Child Nutrition Information and Payment System (CNIPS) site application
    
    
  • Charter schools: Entry of the charter school number on the CNIPS site application
    
    
  • Private schools: A copy of the private school affidavit—the private school can provide this information
    
    
  • Residential Child Care Institutions (RCCI): Copy of their facility license issued by the California Department of Social Services, Licensing and Certification Division. The license must show that the facility is licensed as a group home for the care of children.
    
    
• A letter from the Internal Revenue Service certifying that the unaffiliated charter school, private school, or RCCI site is exempt from federal taxes under Internal Revenue Code 501(c)(3). This is not necessary for public schools and programs operated by a county office of education.
  
  
• A copy of the current and valid health permit for the new site being added.

The SFA must submit a fully executed copy of their interagency agreement to the CDE with the unaffiliated school’s proof of eligibility. Upon CDE approval, the SFA may add site applications to their CNIPS account for each site from the unaffiliated school at which they will provide meal service. The CDE must approve all site applications in the CNIPS prior to an SFA claiming reimbursement for those sites.

Additionally, if at the time of application the unaffiliated school is participating under a different SFA’s PSA, then that SFA must submit a completed site drop form for each site to the CDE. The site drop form is located in the CNIPS Download Forms section, Form ID SNP-01. The CDE cannot approve an SFA’s request to add currently participating unaffiliated schools to its PSA until this step is complete.

The CDE recommends that SFAs use the CDE’s Sample Interagency Agreement template located in the CNIPS Download Forms section, Form ID SNP-09 Interagency Agreement. SFAs may develop their own interagency agreement that, at a minimum, must clearly specify the length of time it is effective and each party’s responsibility to perform the following:

• Point-of-service meal counts
• Management of the free and reduced-price (F/RP) meal application process
• Approval, denial, and notification of F/RP eligibility determinations
• Verification processes
• Payment of any over claims identified during reviews or audits
• Performing edit checks
• Meal count and claiming responsibility

The CDE reminds sponsors that National School Lunch Program and School Breakfast Program requirements in 7 CFR, parts 210 and 220, apply in full to all sites at which a sponsor operates the SNP for an unaffiliated school. SFAs need to have a copy of their interagency agreements, signed by both parties, available upon request by the CDE.

Contact Information

If you have any questions regarding this subject, please contact your SNP Specialist. A list of SNP Specialists is available in the Download Forms section of the CNIPS, Form ID Caseload. You can also contact the SNP Unit by email at SNPInfo@cde.ca.gov to be directed to your SNP Specialist.