Reimbursement for Off-Site Meal Consumption

This management bulletin (MB) supersedes MB 03-106 and provides guidance to school food authorities (SFA) operating the National School Lunch Program (NSLP) and School Breakfast Program (SBP) on reimbursement for meals consumed or served off site.

Background

The Richard B. Russell National School Lunch Act (NSLA), and the Child Nutrition Act of 1966, require that meals reimbursed under the NSLP and SBP be served in schools or on school-related premises. Per USDA Policy Memo SP 17-2025, NSLP and SBP meals may be served and claimed for reimbursement when served off site under specific circumstances.

The guidance outlined in this MB is specific to providing NSLP and SBP meals to students who would normally be on site for the regularly scheduled meal service(s) but are participating in an off-site school function or extracurricular activity that prevents them from participating in the traditional meal service(s). Guidance for serving non-congregate meals in lieu of a traditional, congregate meal service during disasters or school closures is separate and can be found on the California Department of Education (CDE) Disaster Guidance for Child Nutrition Programs web page at https://www.cde.ca.gov/ls/nu/disasterguidance.asp.

Providing Meals to be Consumed Off-Site

Students attending schools that participate in the NSLP or SBP may be provided meals to consume off site if they leave campus during the day for approved school functions or extracurricular activities. These off-site activities may include field trips, dual credit classes at a local college, work-study programs, extracurricular events, and release time for religious education programs.

Meals may only be provided if the off-site activity occurs during standard meal periods, as defined in 7 CFR, sections 210.10(l)(1) and 220.8(l)(1). For instance, SFAs may not provide meals to students who leave at the end of the school day for an off-site activity if it takes place outside the standard lunch period. Similarly, non-congregate meals cannot be provided to all students for early dismissal days. This guidance applies specifically to individual students or groups of students who would normally be on campus during meal service but are temporarily off-site for approved school functions or extracurricular activities. All off-site meals must comply with USDA meal pattern requirements based on the grade group served and all federal and state food safety standards.

Please note, all SFAs required to provide breakfasts and lunches under the California Universal Meals Program (UMP) must ensure compliance with the state meal mandate and ensure access to meals on school days for those students who must attend an off-site activity during the standard meal period. SFAs not required to provide meals under the UMP may choose to provide meals to students who are scheduled to be off site during scheduled meal periods, but it is not required.

Serving Meals to Children in Work-Study Programs

Schools approved to operate the NSLP and SBP may prepare and pack meals to be taken with students attending work-study programs. In these instances, the home-base school will still count and claim the meal for reimbursement. When students participate in work-study programs that are located at another school site that also participates in the NSLP or SBP, either the home-base school or the work-study school may serve and claim the students’ meals. However, schools must coordinate to ensure that only one breakfast and one lunch per student per day is claimed for reimbursement. For example, if the home-base school provides a lunch for the student to take to the work-study site, the work-study school should not serve and claim an additional lunch.

If a work-study program is held at a non-participating or ineligible school or site, then meals provided by the work-study program are not reimbursable under the NSLP or the SBP.

Students applying for free or reduced-price meals should submit their application through their home-base school, which is typically more familiar with their individual circumstances. If the work-study school serves and claims the meals, it must retain a copy of the student’s eligibility documentation (e.g., free/reduced-price meal application or direct certification records). In all cases, schools must maintain accurate and detailed records, including meal counts by category (free, reduced-price, and paid), documentation of eligibility, and coordination logs to prevent duplicate meal service.

Contact Information

If you have any questions regarding the subject, please contact your county’s School Nutrition Programs (SNP) Specialist. A list of SNP Specialists is available on the CDE SNP Specialist Directory web page at https://www.cde.ca.gov/ls/nu/sn/snpcontacts.asp. You may also email the SNP Unit at SNPInfo@cde.ca.gov and request to be directed to your SNP Specialist.