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Reimbursement for Snacks in After School Care Programs

 

Sections 107 and 108 of Public Law 105-336, the Child Nutrition Reauthorization Act of 1998 enhance nutrition benefits for all children with a special emphasis on older children by authorizing reimbursement for snacks served to children through age 18, (and to individuals, regardless of age, who are determined by the State agency to be mentally or physically disabled), who participate in programs organized to provide after school care. The intent of these provisions is to assist schools to operate organized programs of care which include education or enrichment activities known to help reduce or prevent children’s involvement in juvenile crime or other high risk behavior.

This authority may be exercised by schools through the National School Lunch Program (NSLP). These legislative provisions became effective October 1, 1998, and this memorandum authorizes retroactive claims to that date for programs determined eligible by State agencies under the provisions established in this document.
 

This memorandum is intended to provide preliminary guidance to enable State agencies and schools to implement after school care programs for children in advance of publication of a final rule, since the provisions took effect October 1, 1998.
 

National School Lunch Program

Eligible Programs

To be eligible to qualify for reimbursement under the NSLP, after school care programs must meet the following criteria:
 
  • They must be run by a school that is eligible to operate the NSLP.

The purpose of these programs must be to provide care in after school settings. This does not mean that the program must offer formal child care as recognized by a licensing authority. There is no Federal requirement for after school care sites operating under this provision to have either Federal, State or local licensing or approval as a condition of eligibility.  However, to qualify under this provision, these programs must be organized to provide children with regularly scheduled activities in a setting that is structured and supervised. By "regularly scheduled" we do not mean that the program must occur daily. Moreover, while eligible programs would not need to establish formal enrollment procedures, they must have a means of determining that children are present on a given day, such as a roster or sign-in sheet.
 

  • Eligible programs must include education or enrichment activities in organized, structured and supervised environments.  It must be stressed that any extracurricular activities such as the school choir, debate team, drama society, etc., can qualify to participate under this provision only if their basic purpose is to provide after school care as defined above.
     
  • It must be emphasized that under no circumstances can organized athletic programs engaged in interscholastic sports be approved as after school care programs under this provision. In the Conference Report that accompanied P.L. 105-336, the Conference Committee declared its intent that support under this provision would not be provided to members of athletic teams. However, while athletic teams participating in interscholastic sports programs may not be approved, programs which include supervised athletic activity along with education or enrichment activities may participate. The key would be that they are open to all and do not limit membership for reasons other than space or security considerations, or where applicable, licensing requirements.
     
Eligible Sites
Any school that is eligible to operate the NSLP may be reimbursed for snacks served on or after October 1, 1998, to eligible children in eligible after school care programs. The after school program must be operated by the school and not some other organization, although the school does not have to use the school’s personnel or regular school facilities. However, the school must retain final administrative and management responsibility for the program, including the program site. Furthermore, the LEA for the school must be the party that enters into the agreement with the State agency and must assume full responsibility for meeting all program requirements. The school may then, if it wishes, arrange with another organization to perform the day-to-day operations. For example, the PTA could operate the program under an arrangement with the school. Federal law requires that facilities must meet State or local health and safety standards.
 
Residential child care institutions (RCCIs) and boarding schools are not eligible to operate the after school care component of  the NSLP. RCCIs and boarding schools, by their definitions, have children in residence. These arrangements are inconsistent with the law’s concept of after school care.
 
Reimbursement
Under this provision, schools may claim reimbursement for one snack, per child, per day. Children are eligible to participate through age 18, and if a student’s nineteenth birthday occurs during the school year, reimbursement may be claimed for snacks served to that student during the remainder of the school year. Reimbursement may also be claimed for individuals, regardless of age, who are determined by the State agency to be mentally or physically disabled.
 
Sites located in areas served by a school in which at least 50 percent of the enrolled children are certified eligible for free or reduced price meals are eligible to receive reimbursement at the free rate for snacks served to all children eligible for snacks, regardless of each individual child’s eligibility for free or reduced price lunches and breakfasts. Sites which are not in areas served by a school in which at least 50 percent of the enrolled children are certified eligible for free or reduced price meals must count meals and claim reimbursement by type (free, reduced price and full price), and must have documentation of eligibility for all meals served free or at a reduced price. (Under no circumstances may a school charge children for snacks claimed at the free reimbursement rate.) Charges for reduced price snacks may not exceed 15 cents.
 
This provision was effective October 1, 1998. Therefore, schools which served snacks to eligible children in eligible sites and programs prior to issuance of this memorandum and maintained appropriate program records may claim reimbursement retroactively to that date or the date they began operation if they began operating after October 1, 1998. Valid retroactive claims for meals served during this period will be paid without regard to the normal 60-day time limit on submission of claims, if they are submitted prior to July 1, 1999. Please note; In order to accept retroactive claims the SA will need to determine if snacks were paid for by a source other than school food services.
 
Times of Operation
This change in the law applies only to programs that provide care for children after their school day has ended. Under no circumstances may snacks be reimbursed in programs operated before or during the child’s school day. Schools are not eligible to receive reimbursement under this provision for snacks served on weekends or holidays including vacation periods.
 
However, children’s eligibility is based on when their scheduled school day ends and not on whether or not the school continues in session. For example, if a kindergarten program ends at noon but the children remain in school under a care program as described above, snacks served to these children may be reimbursed under this provision. The same would be true for older children enrolled in schools that have split sessions. If children enrolled in the early session remain on campus to participate in an approved after school care program, they may receive reimbursable snacks even though the school continues to operate a later academic session.
 
Content of Meals
Snacks served under this provision must meet the meal pattern for snacks (see meal pattern chart). Portions for children ages 13 through 18 shall be no less than the portions stipulated for children ages 6 through 12. We recommend that schools offer larger portions for older children (ages 13-18) based on their greater food energy requirements.
 
Additional Requirements
Schools wishing to participate under this provision must provide sufficient information to enable the State agency to determine whether or not the program is eligible and, if so, whether or not it qualifies for free reimbursement for all meals based on area eligibility. Upon approval, the State agency must amend its agreement with the school food authority to provide for the requirements of an after school meal service. We wish to emphasize that all relevant provisions in the agreement apply to the after school care activities, including the requirement to comply with program regulations. Finally, the State agency must review these operations as part of its general oversight of the NSLP.
 
Record Keeping
The intent is to keep any record keeping burden to the minimum necessary to ensure that Federal reimbursement is properly paid. At a minimum, LEAs participating under this provision must maintain the following records:
 
If all meals are claimed free, documentation that the site is located in an area served by a school in which at least 50 percent of the enrolled students are certified eligible for free or reduced price meals.  For all other sites, documentation of free and reduced price eligibility for all children for whom free and reduced priced snacks are claimed.  Meal counts (total for sites qualifying for free reimbursement for all children; meal counts by type for other sites).  Documentation of individual children’s attendance on a daily basis.  Documentation of compliance with meal pattern requirements and the On-Site School Review form.
 
Participation
If your LEA is sponsoring an after school care program and you wish to participate in the snack program, please contact our office at (573) 751-3526. DESE’s Information Technology Section is developing a computer program to pay LEAs reimbursement for snacks; therefore, it may be several months before claims for the after school snacks can be processed.
 
Organizations Other Than Schools
Public and private non-profit organizations such as Boys and Girls Clubs, YMCA, etc., that sponsor after school programs may claim reimbursement for snacks through the Missouri Department of Health’s Child and Adult Care Food Program (CACFP).  To be eligible to participate under the CACFP the site must be located in an area served by a school in which at least 50 percent of the enrolled children are certified eligible for free or reduced price meals. Unlike the after school component of the NSLP, all sites in the CACFP serving children 13 years of age or older must be area eligible. There is no provision for individualized means testing.
 
Public and private non-profit organizations may contact the Missouri Department of Health, Child and Adult Care Food Program at 1-800-733-6251, concerning participation in the after school care snack program.