The purpose of the memo is to provide information to school
food authorities/local education agencies (SFA/LEA) regarding the option to
participate in the United States Department of Agriculture (USDA) Special
Assistance Alternative called Provision 2.
This provision allows school districts to serve reimbursable school
meals at no charge to all students.
Provision
2 Alternative:
This
is a four (4) year cycle with the first year considered the “base year” and the
following three (3) years considered “non-base years”.
For
the entire four (4) year Provision 2 cycle, NO changes can be made in student
populations or facilities that will impact/change economic distribution of the
students established in the "base year”.
Before
applying for Provision 2 status, carefully review the USDA Guidance for
Provision 2
Districts
must have prior approval from the Division of Elementary and Secondary
Education (DESE), Child Nutrition Unit (CNU) prior to beginning Provision 2.
There
is no requirement that a minimum percentage of children enrolled are eligible
for free or reduced price meals. However, the school must be prepared to pay
the difference between Federal reimbursement and the cost of providing all
meals at no charge from sources other than Federal funds.
Base
Year:
During
the base year student eligibility status is determined in the same manner as
regular pricing schools (Free and Reduced Meal Applications, Direct
Certification, Categorically eligible). During the base year:
- A public notification is required to inform the public and student households that during the "base year" all students in the Provision 2 schools/district will eat at no charge regardless of whether the meal applications are returned for approval or denial.
- Free and Reduced Meal Applications are distributed and approved by eligibility category (Free 01, Reduced 02, and Paid 03) and coded in eSchool and the Point of Service System (POS).
- Districts must access the Direct Certification Portal and code all enrolled students listed as an “Exact Match” as 04.
- Meals are served and counted at the point of service by eligibility category;
- All students are provided meals (breakfast and lunch) at no charge to the household; however,
- Meals are claimed/reimbursed using Free, Reduced, and Paid rates based on the actual meal participation.
- Districts will conduct the verification of eligibility process on approved applications.
- Retain specified base year records for the entire period that the school operates under Provision 2 (base year plus all extensions), plus five(5) years, or longer if there are audit findings and until resolution of the findings.
Non-Base
Years:
No new
student eligibility determinations are made using household meal applications. The
district is required to access the Direct Certification Portal and code
students appearing as an “Exact Match” as 04 in eSchool and the POS. All other students are coded as FREE 01.
Counting
and Claiming:
Claiming
percentages are determined during the base year based on participation. Those percentages are applied in the three (3)
non-base years following implementation. The district will receive a separate
Free, Reduced and Paid claiming percentage for breakfast and lunch.
Meal
counts are taken at the point of service and claiming percentages are applied
to aggregate counts to determine the meals claimed/reimbursed. Federal
reimbursement is determined by multiplying the claim rate and the total number
of meals served each month by each claiming percentage.
Financial
internal controls must be in place to prevent an over-claim or under-claim
payment and to substantiate meal counts. School districts that have internal
control findings through legislative audit or administrative review visits may
not be allowed to use the Provision 2 alternative.
Extensions:
Districts
may apply for one (1) four (4) year extension utilizing the same claiming rates
if the economic conditions of the area have not changed. If economic conditions
worsen, the district may choose to establish a new base year, move to another
provision, or return to taking applications. The district does not have to wait
until the end of the four year cycle to make that change. Districts may apply
for additional 4 year cycle extensions if conditions have not changed.
District
Obligation:
Since
no student payments can be collected from the paid or reduced students in
Provision 2 schools, there will be a revenue reduction to the district child
nutrition program.
If reimbursements and/or other
program income are not sufficient to cover total nonprofit school food service
program costs, the LEA must pay,
with funds from non-Federal sources, the difference between the cost of serving
lunches and/or breakfasts at no charge to all participating children and the
Federal reimbursement (7 CFR 245.9(b)(2)).
To receive Provision 2 information, please provide a
written request for information to Donna Ratliff at donna.ratliff@ade.arkansas.gov