PLE: Updated Guidance for SY 2015-16 and 2016-17
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: January 2015
Reference: U.S. Department of Agriculture Interim Rule: School Food Service Account Revenue Amendments Related to the Healthy, Hunger‑Free Kids Act of 2010, Policy Memoranda SP 39-2011-Revised; SP 15-2012; SP 18-2012; SP 22-2012; SP 28-2012; SP 19-2013; SP 25-2013; SP 34‑2013; SP 58‑2013, SP 1-2014; SP 15-2014 and SP 28-2014 http://www.fns.usda.gov/school-meals/policy/
Subject: Paid Lunch Equity: Updated Guidance for School Years 2015–16 and 2016–17
This Management Bulletin (MB) provides school food authorities (SFA) (local educational agencies participating in the School Nutrition Programs) with updated information from U.S. Department of Agriculture (USDA) Policy Memorandum
SP 19-2015 regarding updated guidance for the Paid Lunch Equity (PLE) pricing requirements in Section 205 of the Healthy, Hunger Free Kids Act (HHFKA) of 2010 for School Years (SY) 2015–16 and 2016–17.
The USDA published the interim rule pertaining to PLE pricing requirements in June 2011, and the California Department of Education (CDE) Nutrition Services Division (NSD) communicated PLE pricing requirements and updates to SFAs through e-mails, MBs, training seminars, and statewide conferences. For further background information on PLE, please refer to the National School Lunch Program: School Food Service Account Revenue Amendments Related to the HHFKA of 2010 Web page at https://www.fns.usda.gov/school-meals/fr-061711.
The USDA Food and Nutrition Service (FNS) 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 and use the USDA PLE calculation tools to comply with the PLE pricing requirements.
These PLE documents are available on the USDA School Meals Policy Memos Web page at http://www.fns.usda.gov/school-meals/policy.
Please search for the term “Paid Lunch Equity.” For further guidance on the PLE pricing requirements, please review the information also available on the CDE Cafeteria Fund Guidance Web page at http://www.cde.ca.gov/ls/nu/sn/cafefundguide.asp.
Paid Lunch Equity Exemption
For SYs 2015–16 and 2016–17, the FNS extended the exemption to the PLE pricing requirement for certain SFAs in strong financial standing (e.g., the cafeteria fund would exceed its three-month average operating balance if it were to raise its lunch prices). The USDA is extending the PLE exemption for another two years to continue gathering feedback and experience with the exemption. The FNS will use this information to inform future policy considerations including the final rule.
To qualify for the exemption from the PLE pricing requirements, the SFA must:
- Have certification from the CDE as meeting the new meal pattern requirements.
- Demonstrate that the required increase to the average paid lunch price or revenue contributions would cause the SFA to exceed their net cash resource (NCR) limitation as defined in Title 7, Code of Federal Regulations, Section 210.14(b).
- Complete the Factors for Consideration form to determine if other necessary or appropriate uses for the SFA’s cafeteria fund exist. This form is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS) Form ID SNP-49.
Requesting an Exemption
All SFAs, even if the CDE granted an exemption in SY 2013–14 or SY 2014–15, must request an exemption annually in SY 2015–16 and SY 2016–17. Additionally, all SFAs must provide the CDE with proper documentation to be considered for the exemption. In order for the CDE to consider the SFA’s request for an exemption from the PLE pricing requirements, the CDE must evaluate all aspects of food service operations including, but not limited to, meal costs and compliance with nonprogram food revenue requirements (e.g., the Smart Snacks in Schools standards).
SFAs must submit their request for a PLE exemption to Leona LaRochelle by e-mail at SNPCAFEFUNDQUESTIONS@cde.ca.gov.
The subject line of the e mail should state the following: PLE Exemption Request for (enter SFA name and the CNIPS identification number).
The SFA must attach the following documents to the e mail request:
- A copy of the CDE certification letter confirming that the SFA has met the new meal pattern requirements
- A copy of the USDA PLE tool or similar calculation spreadsheet that the SFA used to calculate their PLE requirements
- Balance sheets demonstrating the SFA’s NCRs before and after their overall price increase
- A completed PLE Exemption Request: Factors for Consideration form (SNP-49)
After receiving the SFA’s completed PLE exemption request, the CDE will review the request and advise the SFA of its determination.
If you have any questions regarding this MB, please contact the CDE NSD Resource Management Unit by e-mail at SNPCafeFundQuestions@cde.ca.gov.