Professional Standards in the SNP

The USDA established minimum Professional Standards for personnel who manage and operate the National School Lunch Program (NSLP) and the School Breakfast Program (SBP). These standards address Section 306 of the Healthy, Hunger-Free Kids Act of 2010 (PL 11-296) by ensuring that school nutrition personnel have the knowledge, training, and tools needed to create nutritious, safe, and enjoyable school meals. The Professional Standards for personnel in SNPs became effective July 1, 2015, per 80 FR 11077.
The Professional Standards include:

• Minimum hiring standards for new SNP Directors based on local educational agency (LEA) size, as measured by the annual student enrollment in October, and
  
  
• Minimum annual training requirements for SNP professionals
  
  

The Professional Standards apply to all food service personnel who manage or work in the NSLP and the SBP in public, charter, and private schools as well as residential child care institutions and food service management companies (FSMCs) that operate SNPs.
For more information about Professional Standards requirements, visit the California Department of Education’s (CDE) Professional Standards web page at https://www.cde.ca.gov/ls/nu/pd-ps.asp

The definitions for SNP directors, managers, and staff are based on the individual’s role, rather than the title, as follows:

• Director: Manages day-to-day operations of the school food service for all participating schools under the jurisdiction of the local educational agency (LEA).
• Manager: Manages day-to-day operations of the school food service for one or more participating schools, but not all of the participating schools under the jurisdiction of the LEA.
• Staff: Has a nonmanagerial role in day-to-day operations of the school food service.
  

Refer to the USDA Memo SP 05-2020, Questions 5, 6, 26, and 29 for additional details. https://www.fns.usda.gov/schoolmeals/professional-standards-qas

The following requirements apply to SNP Directors hired on or after July 1, 2015:

1. Minimum Education: Federal regulation 7 CFR Section 210.30(b)(1) establishes minimum education standards for hiring SNP Directors in three local educational agency (LEA) size categories based on the annual student enrollment in October:
   • 2,499 students or less
   • 2,500–9,999 students
   • 10,000 or more students

For minimum education requirements for each LEA enrollment size category, refer to the California Department of Education's (CDE) California Requirements for Hiring a New Director web page at https://www.cde.ca.gov/ls/nu/pd-pshiring.asp. This information is also available on the form titled Professional Standards 001 - California Hiring Requirements for New School Nutrition Program Directors, which is located in the Child Nutrition Information and Payment System (CNIPS), Download Forms section.

The following terms are important to understand when assessing minimum hiring requirements for Professional Standards:

• equivalent educational experience – this term refers to college credits completed by an individual who does not possess a bachelor’s or an associate degree
  
  
• related field of education – this term refers to college majors, other than those listed in the minimum education requirements, that would provide an applicant specific knowledge and skills that are relevant for an SNP Director
  
  
• relevant SNP experience – this term refers to previous work experience in the National School Lunch Program (NSLP) and School Breakfast Program (SBP), and/or experience in other child nutrition programs within a school setting such as the Child and Adult Care Food Program or the Summer Food Service Program
  
  
• relevant food service experience – this term refers to work in the food service industry, including, but not limited to hospitals, healthcare facilities, nursing homes, restaurants, cafeterias, free meal centers, and university dining services

USDA Memo SP 05-2020, Questions 10–13 at https://www.fns.usda.gov/cn/questions-answers-regarding-professional-standards-state-and-local-school-nutrition provides an explanation of these terms.

2. Minimum prior training in food safety: For LEAs of all student enrollment size categories, newly hired SNP Directors must complete, or have completed, at least eight hours of food safety training within five years prior to their start date or within 30 days after their start date. Additionally, note that following the hire, California also requires SNP Directors to complete eight hours of food safety training or certification every five years, as permitted by 7 CFR Section 210.30(b)(1)(v).

Yes. Federal regulations state that SNP Directors hired before July 1, 2015, are exempt from the hiring standards and are grandfathered in based on their current position (USDA Memo SP 05-2020, Question 1). The USDA does not require existing SNP Directors to meet the new hiring standards while they are employed in their existing position or if they move to another position within the same or smaller LEA size category as defined in Question 3. However, if an existing SNP Director transfers to an LEA in a larger enrollment category, they must meet the hiring standards for that student enrollment category. The Professional Standards hiring requirements for all new SNP Directors to maintain the food safety certification or complete eight hours of food safety training every five years while employed in the SNP also applies to SNP Directors hired before July 1, 2015.1. (7 CFR Section 210.30[b][1][v])

Yes. The flexibilities for the Professional Standards hiring requirements are described below. Unless otherwise indicated, prior approval by the California Department of Education (CDE) is not required to use the flexibilities listed.

Hiring flexibilities for local educational agencies (LEA)s with less than 500 students

May hire an SNP Director who has less than the required years of food relevant food service experience, provided the applicant has the minimum education specified in the hiring standards for LEAs with 2,499 or fewer students. (7 CFR Section 210.30[b][1][iv][A])

Hiring flexibilities for LEAs with 2,499 or fewer students

• May hire a new SNP Director who has relevant food service experience, rather than SNP experience. (7 CFR sections 210.30[b][1][i][B-D])
• May hire a new SNP Director with paid or unpaid relevant food service experience. Unpaid experience must be documented and considered on a case-by-case basis by the LEA. (7 CFR sections 210.30[b][1][i][B-D])
• When an LEA has been issued a finding related to Professional Standards during an Administrative Review (AR) and the LEA is operating under a CDE-approved Corrective Action Plan (CAP), the LEA may use the nonprofit school food service account, also known as the cafeteria fund or Fund 13, to pay the salary of an SNP Director who does not meet the hiring standards. (7 CFR Section 210.30[b][1][i])

Hiring flexibilities for LEAs with 2,500 or more students

May hire an SNP Director with 10 or more years of SNP experience and either a high school diploma or GED. Candidates need not have earned a bachelor’s or an associate degree. (7 CFR Section 210.30[b][1][ii])

Local educational agencies (LEA)s must keep documentation supporting compliance with Professional Standards, including any hiring flexibilities applied, and make it available to the California Department of Education (CDE) during the SNP Administrative Review (AR) and upon request.

Each school year the SNP Director must self-certify by completing the Professional Standards Certification Form assuring that (1) they meet the hiring standards and training, requirements, (2) each employee has completed the applicable annual training requirements, and (3) each employee tasked with SNP procurement has completed annual procurement training. (7 CFR sections 210.30[h]) This form is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS), listed as Professional Standards 003 -Professional Standards Certification Form, accessed at https://cnips.cde.ca.gov/Splash.aspx.

Acceptable documentation of education includes:

• a degree or diploma noting the educational level conferred, or
• college transcripts to validate equivalent educational experience when a degree is incomplete

Acceptable documentation of relevant work experience includes:

• the duration of employment and description work performed, or
• for LEAs with 2,499 or fewer students considering a candidate with unpaid food service work, a letter stating the nature and timeframe of the volunteer work completed

Acceptable documentation of fulfillment of the food safety training hiring requirement includes:

• a certificate of completion, or
• training sign-in sheet that shows the date of the training and the training agenda that includes the title, topic(s) covered, and instruction time

LEAs are encouraged to use the optional Director Qualifications Assessment Tool (Professional Standards 002) available in the Download Forms section of the CNIPS, accessed at https://cnips.cde.ca.gov/Splash.aspx when engaged in the hiring process to ensure potential candidates would, if hired, meet the Professional Standards requirements.

LEAs must keep records for three years, plus the current school year, except that if audit findings have not been resolved, then records shall be retained for as long as required for resolution of the findings raised by the audit.

See training documentation requirements below in Question 13.

Each school year, local educational agencies (LEA)s must ensure that SNP Directors, managers, and staff, including food service management company (FSMC) staff complete continuing education and meet the training requirements.

The annual training requirement is:

• 12 hours for directors (including acting directors)
• 10 hours for managers
• 6 hours for school nutrition staff who work 20 hours or more per week
• 4 hours for part-time employees who work less than 20 hours per week

LEAs should offer trainings at no cost to school food service staff and are encouraged to hold these trainings during normal working hours or at a time of minimal disruption. SNP employees may earn up to two of the annual training hours by attending conference exhibits on job-related topics or observing product demonstrations.

LEAs may choose to demonstrate compliance with the training standards across two school years, provided that some training hours are completed in each school year. (7 CFR Section 210.30[f])

Yes. The training standards apply to all school nutrition personnel, including food service management company (FSMC) staff, and acting SNP Directors regardless of the funding source used to support their position. The SNP Director should reference the duties of each position to determine the annual training requirements. While there is no specific annual training requirement for acting or temporary staff, substitute workers, and volunteers, and interns, it is strongly encouraged that LEAs provide job-related food safety training to all personnel handling food, including acting, temporary, or substitute workers and volunteers.

Training topics must support SNP operations and be job-related. Training content should align with the Key Areas of training (Nutrition, Operations, Administration, and Communication and Marketing) detailed on USDA’s Professional Standards Learning Objectives & Training Topics web page, https://www.fns.usda.gov/tn/professional-standards/training-objectives-topics.    

Examples of acceptable topics include, but are not limited to, free and reduced-price meal eligibility; application, certification, and verification procedures; meal counting and claiming procedures; identification of reimbursable meals at the point of service; nutrition; health and food safety standards; use of USDA Foods in menu planning; and inventory rotation and control. Participation in the California Department of Education's (CDE)’s monthly Tuesday @2 School Nutrition Town Hall webinars also credit towards the Professional Standards ongoing training requirements. However, time spent on advocacy-type discussions does not count towards annual training.

Local educational agencies (LEA)s may use a variety of training formats. Interactive, hands-on learner-centered training is encouraged; live and prerecorded webinars, online classes, face-to-face training, conference calls, staff in-service days, professional association chapter meetings and conferences are all acceptable training formats. SNP employees may earn up to two of the annual training hours required by attending conference exhibits on job-related topics or observing product demonstrations.

Ensure that appropriate documentation is maintained. See additional information on documentation, Question 13 below.

To be credited, training must support SNP operations and be job-related. Only the instruction and discussion time devoted to topics that align with the USDA’s Professional Standards Learning Objectives and Training Topics are creditable (https://www.fns.usda.gov/tn/professional-standards/training-objectives-topics). Time spent on opening remarks, introductions, lunch, breaks, networking, advocacy training, or motivational presentations does not count toward the annual training requirement.

Training activities lasting 15 minutes or more may be recorded using USDA’s Professional Standards Trainings and Tracker Tool. (https://www.fns.usda.gov/schoolmeals/professional-standards-qas)

An SNP Director or manager who presents a training session to staff can claim credit for training delivery time but not the time spent on preparing the training. If the director or manager presents the same training multiple times in a school year, it may be counted only once. If, however, each training session addressed a different aspect of a single topic, those sessions could be considered different training classes. (https://www.fns.usda.gov/schoolmeals/professional-standards-qas)

Employees hired on or after January 1 of the school year must complete only half of the training hours required for that school year.

Training Requirements:

• Ongoing food safety training or certification every five years for new and current SNP Directors: All new SNP Directors shall either maintain the food safety certification or complete eight hours of food safety training every five years while employed in the SNP. In California, this requirement also applies to SNP Directors hired before July 1, 2015. (USDA Memo SP 05-2020, Question 9 at https://www.fns.usda.gov/schoolmeals/professional-standards-qas and 7 CFR Section 210.30[b][1][v])
• Annual training requirements for acting SNP Directors: Acting SNP Directors are required to complete the annual training requirements. (7 CFR Section 210.30[c]) It is strongly recommended that acting SNP Directors take food safety training related to the job duties.
• Training requirements for acting or temporary staff, substitute workers, interns, and volunteers: While there is no specific requirement for annual training hours, documentation, and recordkeeping for acting or temporary staff, substitute workers, and volunteers, it is strongly encouraged that local educational agencies (LEA)s to provide job-related food safety training to all personnel handling food, including acting, temporary, or substitute workers and volunteers. (7 CFR Section 210.30 [f])
• Annual procurement training requirement: Each employee tasked with SNP procurement has completed annual procurement training by the end of each school year. (7 CFR Section 210.21[h])
  
  

Training Flexibilities:

• LEAs may meet the federal training standard requirement across two school years: LEAs may choose to demonstrate compliance with the training standards across two school years, provided that some training hours are completed in each school year. (7 CFR Section 210.30[f])
• Credit for conference exhibits or product demonstrations: SNP employees may earn up to two of the annual training hours by attending conference exhibits on job-related topics or observing product demonstrations. (https://www.fns.usda.gov/schoolmeals/professional-standards-qas)

Though not a part of the Professional Standards requirements, it is important to note two additional food safety-related requirements:

At least one employee at each food facility or site must be food safety certified. The individual who is certified is at the discretion of the LEA (California Health and Safety Code Section 113947.1).

• LEAs must develop a written food safety program based on Hazard Analysis Critical Control Points principles, which applies to any facility or part of a facility where food is stored, prepared, or served. (7 CFR Section 210.13[c])

Each school year, the SNP Director must sign and date a self-certification statement attesting that: (1) the SNP Director meets the hiring standards, and (2) each employee, including the SNP Director, has completed the applicable annual training requirements, and (3) each employee tasked with Program procurement has completed annual procurement training. (7 CFR Section 201.30[h]) This form is available in the Download Forms section of the Child Nutrition Information and Payment Syste (CNIPS), listed as Professional Standards 003 -Professional Standards Certification Form and accessed at https://cnips.cde.ca.gov/Splash.aspx.

SNP Directors must keep a record of training that employees complete to fulfill annual training requirements. Directors may use the USDA Professional Standards Trainings and Tracker Tool or another method of their choice as long as that method captures the following information:

• Trainee’s first and last name
• Job category (director, manager, full-time staff, or part-time staff)
• Title of the training
• Date training completed
• Credited training hours

Professional Standards Learning Objective (LO) code, as listed on the USDA Professional Standards Learning Objectives & Training Topics web page, accessed at https://www.fns.usda.gov/tn/professional-standards/training-objectives-topics.

Note: Key area and training topic are optional as they can be inferred from the LO code.

Please note that the following food safety policies remain in effect in California:

• At least one employee at each food facility or site must be food safety certified. The individual who is certified is at the discretion of the school food authority SFA (California Health and Safety Code, Section 113947.1).
  
  
• SFAs must develop a written food safety program based on Hazard Analysis Critical Control Points principles, which applies to any facility or part of a facility where food is stored, prepared, or served (7 CFR, Section 210.13[c]).

Local educational agencies (LEA)s must also maintain supporting documentation. Acceptable documentation for completed training and planned or scheduled training includes the following:

• Certificates of completion
• Training sign-in sheets and training agenda
• Training handouts and notes
• Registration for planned or scheduled training

LEAs should keep training records for three years, plus the current school year, unless under audit, then records should be maintained until the audit is closed.

See also Professional Standards administration requirements in Question 15 below.

Training is available from many sources, including the California Department of Education (CDE), the USDA, the Institute of Child Nutrition, and professional organizations, such as the National School Nutrition Association and the California School Nutrition Association. Directors may also develop their own training for staff or attend training led by another local educational agency LEA.

Visit the CDE Professional Standards web page at http://www.cde.ca.gov/ls/nu/pd-ps.asp to access these resources in a user-friendly format.

Local educational agencies (LEA)s must maintain all documentation and certifications for the school years that coincide with the time period specified for their next SNP administrative review (AR). During the AR, as part of the general area of review, the California Department of Education (CDE) will examine the LEA’s records, including an accurate list of employees from sites selected for the AR, the central kitchen, if applicable, and the administrative staff involved in the SNP operations. The list should include name, date hired, title or position, core duties, employment status, time base, Professional Standards employee category (director, manager, or staff), and school or site where they work.

In the event of noncompliance, the CDE will provide technical assistance and work with the LEA on an acceptable corrective action plan (CAP). (https://www.fns.usda.gov/schoolmeals/professional-standards-qas)

Training: While the nonprofit school food service account can be used to pay for training, the California Department of Education (CDE) encourages local educational agencies (LEA)s to use free and low-cost training resources. Training expenses must be reasonable, allocable, and necessary in accordance with the cost principles set forth in Title 2 CFR Part 225, Cost Principles for State, Local and Indian Tribal Governments (OMB Circular A-87). (7 CFR Section 210.30[g])

Education: LEAs must not use nonprofit school food service account funds to pay for the cost of an employee to earn college credits to meet the SNP Director hiring requirements under 7 CFR Section 210.30(b)(1).

Salaries: When a new SNP Director, hired on or after July 1, 2015, of an LEA with 2,500 or more students does not meet the hiring standards, the LEA may not use nonprofit school food service account funds to pay the director’s salary. In this situation, the LEA’s general fund account may be used to pay the SNP Director’s salary as long as the individual is actively implementing a CDE-approved corrective action plan (CAP) to meet the minimum hiring standards, as discussed in Question 5 above.

However, 7 CFR Section 210.30(b)(1)(i) allows LEAs with 2,499 or fewer students to use nonprofit school food service account funds to pay the salary of an SNP Director hired on or after April 30, 2019, who does not meet the Professional Standards hiring requirements as long as they are actively implementing a CDE-approved CAP. In addition, if the LEA is complying with this plan, the director could be hired as permanent staff, rather than as interim or acting staff. Refer to USDA Memo SP 05-2020, Questions 17 and 19 at https://www.fns.usda.gov/schoolmeals/professional-standards-qas. These flexibilities are not retroactive.

If the local educational agency (LEA) enlists the support of an FSMC, then FSMC employees must comply with the Professional Standards hiring and training requirements. To verify compliance, LEAs must collect and maintain documentation as described in Question 13 above, verifying the training hours and topics the FSMC employees complete annually during each school year. Contracts with FSMCs that do not include compliance with Professional Standards hiring, training, and documentation requirements should be amended. (https://www.fns.usda.gov/schoolmeals/professional-standards-qas)