PLE: Guidance for School Year 2019-20Management Bulletin: SNP-11-2019: Updated Guidance for School Year 2019-20.
Nutrition Services Division Management Bulletin
Purpose: Policy, Action Required, Beneficial Information
To: All School Nutrition Program Sponsors
Attention: Food Service Directors, School Business Officials
Date: May 2019
Reference: Healthy, Hunger-Free Kids Act of 2010, Section 205; Title 7, Code of Federal Regulations (7 CFR), Section 210.14(e); USDA 2017 Eligibility Manual for School Meals; and USDA Policy Memorandum SP 27-2019.
Subject: Paid Lunch Equity: Guidance for School Year 2019-20
This management bulletin provides school food authorities (SFA) with updated information from U.S. Department of Agriculture (USDA) Policy Memorandum SP 27-2019 regarding guidance for the Paid Lunch Equity (PLE) requirements in Section 205 of the Healthy, Hunger‑Free Kids Act of 2010 for School Year (SY) 2019–20.
In Section 760 of the Consolidated Appropriations Act, 2019 (Public Law 116-6 [the Act]), Congress provides that only SFAs that had a negative balance in the nonprofit school food service account as of December 31, 2018, shall be required to establish prices for paid lunches according to PLE regulations.
This management bulletin provides notice that any SFA with a positive or zero balance in its nonprofit school food service account as of December 31, 2018, is exempt from PLE pricing requirements found at 7 CFR, Section 210.14(e), for 2019–20. An SFA that can demonstrate a positive or zero balance in its nonprofit school food service account as of December 31, 2018, and will not increase paid lunch prices at the level required by the USDA, must submit their exemption request to the California Department of Education (CDE).
SFAs that are exempt from PLE requirements in SY 2019–20 are able to set paid lunch prices at the price the SFA determines to be appropriate and may reduce their paid lunch prices. Since this exemption currently only applies to SY 2019–20, SFAs should consider the effect reducing prices might have if they are not exempt from PLE requirements in SY 2020–21.
The USDA’s weighted average price requirement for SY 2019–20 is $3.00. The USDA SY 2019–20 PLE tool is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) form ID—USDA 2019–20 PLE Tool. Instructions for completing the tool are available in CNIPS Download Forms form ID—Instructions for the USDA 2019–20 PLE Tool.
The USDA published the interim rule pertaining to PLE pricing requirements in June 2011, and the CDE Nutrition Services Division (NSD) has since communicated PLE pricing requirements and updates to SFAs through various communication channels including emails, management bulletins, training seminars, and statewide conferences.
The USDA Food and Nutrition Service provides annual guidance and a PLE calculator tool to ensure compliance with PLE pricing requirements. Due to the complexity of PLE pricing requirements, the CDE strongly encourages SFAs to read the USDA PLE policy memos, use the USDA PLE calculation tools to comply with pricing requirements and view the PLE training video. For further background information on PLE and to view the PLE training video, please refer to the CDE Cafeteria Fund Guidance web page at https://www.cde.ca.gov/ls/nu/sn/cafefundguide.asp.
USDA PLE policy memos are available on the USDA School Meals Policy Memos web page at http://www.fns.usda.gov/school-meals/policy.
Determining School Food Authority Action on Paid Lunch Equity Exemption
Each SFA must determine if they comply with PLE requirements for SY 2019–20. Listed below are scenarios to assist SFAs in determining compliance:
- The SFA is in compliance if:
- The charge is at least the required paid lunch price as determined by completing the USDA PLE Tool for SY 2019–20.
- All sites are authorized to participate in a Provision that provides meals at no cost to all students in SY 2019–20, such as Provision 2 or the Community Eligibility Provision.
- A residential child care institution’s day students (if any) will be charged at least the required paid lunch price as determined by completing the USDA PLE Tool for SY 2019–20.
- A PLE exemption for SY 2019–20 was filed with the CDE and an acknowledgement email was sent to the SFA. Note: PLE exemptions must be submitted to the CDE for each school year the SFA would like an exemption from raising paid lunch prices at the level required by the USDA.
- If an SFA had a positive or zero account balance as of December 31, 2018, and will not increase paid lunch prices at the level required by the USDA, the SFA should consider the effect the prices might have on SY 2020–21 and then notify the CDE by submitting a PLE exemption.
- If an SFA had a negative account balance as of December 31, 2018, the SFA must follow PLE requirements as defined in 7 CFR, Section 210.14(e), when establishing paid lunch prices in SY 2019–20.
Filing a Paid Lunch Equity Exemption for School Year 2019–20
To file a PLE exemption, an SFA must submit an email to SNPCAFEFUNDQUESTIONS@cde.ca.gov at the beginning or prior to the start of SY 2019–20 with the subject line, PLE Exemption for SY 2019–20, and must include the following:
- SFA name and the CNIPS identification number.
- A record of a positive or zero balance in the nonprofit school food service account as of December 31, 2018.
- This documentation may include any financial statement or accounting report for the period ending December 31, 2018 (e.g., trial balance, income statement, and cash flow statement). Attach the documents and identify the balance on December 31, 2018. Provide a brief explanation describing the positive balance in the nonprofit food service account for the period ending December 31, 2018.
- Name, title, phone number, and email address of the person submitting the PLE exemption.
- Statement from the SFA that they agree to cover costs with allowable nonfederal funds if the balance is in the negative for SY 2019–20.
Upon verification of a positive or zero account balance in the SFA’s nonprofit school food service account, the CDE will send a confirmation email to the SFA for the PLE exemption for SY 2019–20.
If you have any questions regarding this subject, please contact the CDE NSD Resource Management Unit by email at SNPCAFEFUNDQUESTIONS@cde.ca.gov.