Child Nutrition Technical Assistance

Child Nutrition Technical Assistance

Restart Technical Assistance for School Year 2020-2021  

Introduction  

Each child is unique and has basic needs – including nutrition – that must be met to enable learning. As schools resume child nutrition program operations for school year 2020-2021, schools must change traditional meal service operations and practices to help diminish the spread of the coronavirus (COVID-19) while continuing to provide nutritious meals. To achieve this goal, the Ohio Department of Education has developed this technical assistance resource to provide  schools important updates and information to operate successful child nutrition programs for the 2020-2021 school year. 
 

U.S. Department of Agriculture (USDA) Nationwide Waivers 

The U.S. Department of Agriculture (USDA) issued five nationwide waivers regarding child nutrition programs for school year 2020-2021, effective through June 30, 2021.  
 
  1. Non-congregate Feeding Nationwide Waiver - This nationwide waiver allows National School Lunch Program, School Breakfast Program and Child and Adult Care Food Program sponsors to serve non-congregate meals. 
  1. Meal Times Nationwide Waiver - This nationwide waiver suspends meal-time requirements and restrictions, allowing sponsors to provide multiple meals, such as breakfast and lunch, at the same time, for up to one week for the National School Lunch Program, School Breakfast Program and the Child and Adult Care Food Program. 
  1. Meal Pattern Nationwide Waiver - This nationwide waiver permits the state agency to waive specific meal pattern requirements as needed to support access to nutritious meals when certain foods are not available due to COVID-19. 
  1. Parent and Guardian Meal Pickup Waiver - This nationwide waiver allows parents and guardians to pick up meals for their children. The Ohio Parent, Guardian or Agency Meal Pickup Without Children Present policy provides additional information and guidance for sponsors to make a good faith effort to ensure food is being picked up for children. 
  1. Offer Versus Serve Flexibility for Senior High Schools Nationwide Waiver – This nationwide waiver allows senior high schools to waive the offer versus serve requirement and allow sponsors to offer complete meals.  
  1. Child Nutrition Monitoring Waivers – These nationwide waivers apply to on-site monitoring requirements in the National School Lunch Program, School Breakfast Program, Child and Adult Care Food Program and Summer Food Service Program.  

  2. Meal Times for Summer Nutrition Programs Waiver - This nationwide waiver suspends meal-time requirements and restrictions, allowing sponsors to provide multiple meals, such as breakfast and lunch, at the same time, for up to one week for the Summer Food Service Program and the National School Lunch Program Seamless Summer Option through Sept. 30, 2020.

  3. Non-congregate Feeding Waiver – This nationwide waiver allows Summer Food Service Program sponsors to serve non-congregate meals through Sept 30, 2020. Please note that the NSLP SSO follows the NSLP regulations for congregate feeding; therefore the Nationwide Waiver to Allow Non-congregate Feeding - Extension 2 applies to SSO operations for the duration of summer 2020.

  4. Area Eligibility Waiver – This waiver permits school food authorities in good standing to operate open sites under either the Seamless Summer Option or Summer Food Service Program. Ohio’s Area Eligibility During the Coronavirus Outbreak policy provides additional information and guidance. This wavier is extended through Sept. 30, 2020.

  5. Meal Pattern Flexibility in the SFSP - This nationwide waiver permits the state agency to waive specific meal pattern requirements as needed to support access to nutritious meals when certain foods are not available due to the coronavirus pandemic. Please note that the NSLP SSO follows the NSLP regulations for congregate feeding; therefore the Nationwide Waiver to Allow Meal Pattern Flexibility in the Child Nutrition Programs – Extension 4 applies to SSO operations for the duration of summer 2020. Sponsors experiencing difficulties providing all meal components due to a food shortage must submit a Child Nutrition Programs Food Shortages During Coronavirus Application.

  6. Parent and Guardian Meal Pick-up Waiver – This nationwide waiver allows parents and guardians to pick up meals for their children. Ohio’s Parent, Guardian or Agency Meal Pick-up Without Children Present policy provides additional information and guidance for sponsors to make a good faith effort to ensure food is being picked up for children through Sept. 30, 2020.
 
For a summary of USDA waivers issued to date, refer to the USDA Waivers Summary in the Claims Reimbursement and Reporting System (CRRS) Download Forms. 

Ohio Department of Education Requested Waivers  

The Ohio Department of Education is requesting the following school year 2020-2021 waivers from the USDA. 
  1. Potable Water Waiver: a waiver to the requirements under 7 CFR 210.10(a)(i) and 7 CFR 220.8(a)(1) that schools must make potable water available and accessible without restriction to children at no charge in the place(s) where breakfasts and lunches are served during the meal service. 
  1. Unanticipated School Closures Waiver: a waiver to the requirements under 7 CFR 225.6)(e)(15) and 7 CFR225.6(d)(1)(iv) allowing school food authorities and sponsors to serve meals during unanticipated school closures at a school location. 
  1. Non-Congregate Meals Waiver for Seamless Summer and Summer Food Program Sponsors: a waiver to the requirements at 42 U.S.C. 1753(b)(1)(A), 42 U.S.C. 1761(a)(1)(D) and 7 CFR 225.6(e)(15) to serve meals through the National School Lunch Program, School Breakfast Program and Summer Food Service Program in a congregate setting. 
  1. Activity Requirements in the Afterschool Care Child Nutrition Programs Waiver: a waiver to the requirements under sections 17(r)(2)(B) and 17A(a)(2)(C) of the Richard B. Russell National School Lunch Act, 42 U.S.C. 1766(r)(2)(B) and 42 U.S.C. 1766a(a)(2)(C), respectively, where afterschool meals and snacks must be served in a school or program with an educational or enrichment purpose and FNS regulations at 7 CFR 210.10(o)(1)(ii) and 7 CFR 226.17a(b)(1)(ii) and (iii) stating eligible schools and at-risk afterschool care centers to serve afterschool meals and snacks in a structured and supervised environment, with an educational or enrichment activity. 
  1. Seamless Summer Option and Summer Food Service Program During Online Instruction Waiver: waiver to the requirements at 7 CFR 225.6(e)(15) and 7 CFR 225.6(d)(1)(iv) allowing school food authorities to serve meals to students receiving online instruction through the Seamless Summer Option or the Summer Food Service Program. 
  1. Paid Lunch Equity Waiver: waiver to the requirements under Paid Lunch Equity (PLE) provisions in Section 12(p) of the Richard B. Russell National School Lunch Act, 42 U.S.C. 1760(p) and implemented in National School Lunch Program regulations at 7 CFR 210.14(e)7 CFR 225.6(e)(15) and 7 CFR 225.6(d)(1)(iv). 
  1. Vegetable Subgroup Waiver: waiver to the requirements under 210.10(c)(2)(iii) in requiring vegetable subgroups to be met over the course of a week. 
  1. Fresh Fruit and Vegetable Program (FFVP) Snacks to be Distributed in a Non-Congregate/Off-Site Method and along with National School Lunch Program (NSLP) and/or School Breakfast Program (SBP) Meals Waiver: waiver to the requirements under section 19 of the National School Lunch Act [42 U.S.C. 1769a] which requires schools participating in the Fresh Fruit and Vegetable Program to make fresh fruits and vegetables available to students and be offered separately from the meals, and to 42 USC 1753(b)(l)(D) which requires students to consume meals on site. 
  1. Parents and Guardians to Pick Up Fresh Fruit and Vegetable Program (FFVP) Snacks for Children Waiver: waiver to the requirements under section 19 of the National School Lunch Act [42 U.S.C. 1769a] which requires schools participating in the Fresh Fruit and Vegetable Program to make fresh fruits and vegetables available to students. 
  1. Age/Grade Group Menu Pattern Requirements for Take Home Meals in the National School Lunch Program Waiver: waiver to the requirements under 7 CFR 210.10 which requires schools to offer each child the quantities specified in the meal pattern for each age/grade group served in school. 
  1. Non-congregate Feeding in the Summer Food Service Program and Seamless Summer Option in September 2020 Waiverwaiver to the requirements under 42 U.S.C. 1753(b)(1)(A), 42 U.S.C. 1761(a)(1)(D), and 7 CFR 225.6(e)(15), to serve meals through the National School Lunch Program, School Breakfast Program, and Summer Food Service Program in a congregate setting. 
  1. Parent and Guardian Pickup in the Summer Food Service Program and Seamless Summer Option in September 2020 Waiverwaiver to the requirements under 42 U.S.C. 1761(f)(3) and program regulations at 7 CFR 210.10(a), 220.2 (Breakfast) and 220.8(a) and 226.2 (Meals), meals must be served to eligible children. 
For a summary of Ohio requested waivers and status, refer to the USDA Waivers Summary in the CRRS Download Forms. 

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Accommodations for Children with Disabilities in the School Meals Programs  

The USDA School Meal Programs aim to provide all participating children, regardless of background, with the nutritious meals and snacks they need to be healthy. School food authorities must provide accommodations for disabilities when supported by the proper documentation regardless of the current circumstances. Meals must be served in a manner that offers a safe environment for children with food allergies or other disabilities. Strategies for providing safe and appropriate meals may include: 
  • Cleaning and sanitizing surfaces prior to the meal service. 
  • Training staff on proper handwashing. 
  • Working closely with school staff involved in the meal service to ensure there is proper communication of what is needed to provide safe meals when necessary. 
  • Documenting food safety plans into standard operating procedures to ensure safety in the production and service of meals to children with allergies. 
  • Publishing planned meals and identifying allergens, if able. 
  • Identifying secure methods to receive and communicate personally identifying student information with families and school staff. 

Claims Reimbursement and Reporting System (CRRS) Application  

School food authorities must submit a school meals program application in the CRRS. Applications must be approved before a sponsor can operate and claim meals for reimbursement. Remember that changes to the school meals application may be made if situations change throughout the year. 
 
School food authorities should indicate any changes in the meal service including non-congregate feeding, meal service times and offer versus serve waivers in each site application. School food authorities are encouraged to be as detailed as possible in the site application about any modifications to the traditional meal service.  

School Nutrition Program Operations During COVID-19 Survey  

School food authorities conducting an alternative meal service must complete the 2020-2021 School Nutrition Program Operations During COVID-19 surveyIf a school food authority wishes to exercise any waiver including non-congregate meals, parent or guardian pickup of non-congregate meals, meal service time flexibility or offer versus serve, then the school food authority must complete and submit the application.  

Maintaining Documentation  

All school food authorities, regardless of learning method, must maintain all required documentation for the National School Lunch Program and School Breakfast Program. Refer to the Administrative Review Checklist in the CRRS Download Forms for a comprehensive list of required documentation 

Meal Service  

Meals must meet the regular menu planning requirements of the National School Lunch Program and School Breakfast Program. Weekend meals are not permitted under the National School Lunch or School Breakfast ProgramFor additional information and considerations, refer to the Meal Service Considerations in the CRRS Download Forms. The following are various requirements for the meal service depending on the three learning environments as described below.  
 
Classroom Learning: Meal service for students in the school building full-time may occur in the cafeteria, hallway kiosks or classroom. Schools must consider current social distancing requirements and recommendations when planning their meal service. 
 
Blended LearningMeal service in a blended learning environment will include aspects of classroom and remote learning meal service. Meal service for students in the school building may occur in the cafeteria, hallway kiosks or classroom. Meal service during remote learning must be non-congregate, meaning the meal is consumed offsite. Non-congregate meal service options include take home meals, home delivery, curbside pick-up, bus stop pick-up or other methods.  
 
Remote Learning: Meal service must be provided non-congregate, meaning the meal is consumed offsite. Non-congregate meal service options include home delivery, curbside pickup, bus stop pickup or other methods.  

Meal Pattern Requirements  

Meals must meet the menu planning requirements of National School Lunch Program and the School Breakfast Program. Senior high schools (grades 9-12) should consider the feasibility of offer versus serve. Offer versus serve is a provision in the National School Lunch Program and School Breakfast Program that allows students to decline some of the food offered. The goals of offer versus serve are to reduce food waste in the school meals programs while permitting students to decline foods they do not intend to eat. Ia senior high school wishes to waive the offer versus serve requirement, they must complete and submit the 2020-2021 School Meals Program Operations during COVID-19 survey indicating as such. Schools must continue to follow the age and grade group meal patternsThe use of USDA Foods is highly encouraged to help lower commercial food expenditures. USDA Foods is beneficial in lowering food costs while providing nutritious meals to students. Refer to the USDA Team Nutrition for recipe ideas and network and share recipe ideas with other schools. Meal planning differs for the learning environments and is described in further detail below.  
 
Classroom Learning: Schools should consider meals that may be easily consumed in other places than the cafeteria. 
 
Blended LearningSchools must consider the feasibility of developing menus that can be used for both congregate and non-congregate meal service. If infeasible, schools will need to maintain separate menus for congregate and non-congregate meal service.  
 
Remote Learning: Schools must serve non-congregate meals, meaning meals are consumed offsite. If schools opt for multi-day distribution, schools should consider providing bulk meal packaging rather than individually packaged items. If the school food authority allows for pickup at a different location than the student’s assigned school, the school food authority should make every effort to make all age and grade group meals available at the location.  
 
Offer versus serve will not apply and all meals must be unitized, meaning a complete reimbursable meal that meets the requirements of the menu planning method used, including milk, must be distributed. Shelf-stable milk may be used. (NoteIf a school encounters a situation where it runs out of an item that prevents the achievement of a reimbursable meal, it should immediately notify the Ohio Department of Education, but then continue to serve meals.) 

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Traditional Meal Counting and Claiming  

Schools must count and claim meals by the enrolled student’s free, reduced or paid status. Schools may check off names on student rosters, use a portable point of sale system, scan the student identification card or any other approved method. When choosing a point of sale approach, schools must prevent the overt identification of children approved for free or reduced meals. Schools must ensure that rosters, check sheets, and point of sale computer systems are masked or coded in a way that prevents overt identification of a student’s eligibility status. Schools may need to alter their meal counting and claiming based on the learning environment described in further detail below.  
 
Classroom LearningSchools must maintain a point of service count by individual student.  
 
Blended Learning: Schools must count and claim the school lunch and breakfast program meals in the same method as they would if enrolled children were present in school. Schools may use different methods for counting classroom learning students and remote learning students as long as one meal per enrolled student, per meal type (breakfast, lunch or afterschool snack) is counted and claimed. For example, schools may use their electronic point of sale software for classroom learning meals but use a roster system for remote learning meals 
 
Remote Learning: Schools must count and claim non-congregate school lunch and breakfast meals in the same method if enrolled children were present in school.  

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Community Eligibility Provision and Provision 2 Meal Counting and Claiming  

Schools must maintain accurate meal counts and claims. Meal counts may be taken using a check sheet or clicker if the school can confirm the enrolled student attends the school for both congregate and non-congregate meals. For meals served non-congregate, the school should verify the enrolled student by the student identification card or any other approved method.  

USDA Foods Program in Schools 

The USDA Foods Program is a key component of the National School Lunch Program that helps to balance the food service budget. The USDA provides financial support for foods through a calculated Planned Assistance Level (PAL) expressed in dollars. Schools can utilize USDA Foods in their meal patterns regardless of the learning method (classroom, blended or remote) and may be used in any meal (breakfast, lunch or snack). The USDA Foods items support domestic agriculture and meet the Buy American provision. Schools may spend their planned assistance level for the 2020-2021 school year through demand order items, direct diversion or through the USDA Department of Defense Fresh Fruit and Vegetable Program. Schools order demand order items and direct diversion items through the Commodity Allocation Tracking System (CATS) 
 
Demand Order: Schools, through their monthly order forms, can utilize USDA Foods demand order items (formerly known as brown box). A wide variety of foods are offered, including canned or frozen fruits and vegetables, that meet the Buy American Provision and help support the American agricultural industry.  Through demand ordering, the U.S. Department of Agriculture (USDA) offers items to help with grab and go service style menus, such as orange juice cups and a variety of fruit cups.  
 
Direct Diversion: Direct diversion allows a school to send raw USDA Foods to a vendor for further processing into end products. Direct diversion allows schools to order end products that meet the meal pattern, are easy to prepare and cost less than the market price. Schools wishing to divert pounds to a vendor can contact the processor directly or contact a broker to help forecast needs. Schools wishing to divert USDA Foods to a vendor for further processing into end products must use proper procurement procedures.  
 
Schools participating in the USDA Foods program through the Ohio Department of Education should contact Christine Farmer or Justin Chapman with any questions or concerns.  
 
Schools participating in the USDA Foods program through the Southwestern Educational Purchasing Council (SWEPC) should contact their SWEPC administrator with any questions.  

USDA Department of Defense Fresh Fruit and Vegetable Program (FFVP) 

The USDA Department of Defense Fresh Fruit and Vegetable Program allows schools to divert PAL to purchase fresh produce from the USDA to serve in their schools. All produce is domestically grown and includes seasonal and local items. Orders are placed in the Fresh Fruit and Vegetable Order Receipt System (FFAVORS). To allocate funds to the Department of Defense, please complete the Department of Defense FFVP Transfer Request form and email the completed form to Christine Farmer, USDA Foods Program Specialist.     

Multi-Day Distribution  

School food authorities are permitted to offer up to one week of meals at a time (weekdays only). Weekend meals are not permitted in the National School Lunch Program and School Breakfast Program. Meals must be served non-congregate, meaning the meal is consumed off-site. School food authorities participating in multi-day distribution must claim the meals served based on the day the child is intended to consume the meals. School food authorities must detail their multi-day distribution approach for each site in the CRRS Site Application.  
 
Note: Meals served for consumption in the school building do not qualify for non-congregate feeding and may not be included in the multi-day distribution plan. For example, if students attend school in-person Monday and Tuesdayare served breakfast and lunch in-school both days and attend remotely Wednesday through Friday, the school may offer three breakfasts and three lunches as part of a multi-day distribution approach for the days of remote learning.  

Meal Pickup without Children Present  

Parents or guardians are permitted to pick up non-congregate meals without children present. School food authorities should make a good faith effort to ensure food is being picked up for children when allowing meal pickup without children present. The Ohio Parent, Guardian or Agency Meal Pickup Without Children Present policy provides additional information and guidance. The USDA published a Best Practices for Parent Pick-Up of Meals and Snacks to assist schools.  
 
Note: Schools serving meals in the school building full-time are not permitted to allow meal pickup without children present. Only schools participating in non-congregate feeding may allow parent or guardian pickup without children present.  

School Bus Safety and Meal Delivery 

Schools considering non-congregate meal distribution via school district buses must continue to abide by rules and regulations as established in the Ohio Pupil Transportation Operation and Safety Rules. Bus drivers play an important role in safely transporting students to and from their homes. It may be difficult for a driver to distribute meals and accurately count and claim meals while ensuring safety of students.  

Food Shortages  

National School Lunch Program and School Breakfast Program meals must meet the regular menu planning requirements unless the school food authority is experiencing a food shortage. School food authorities experiencing difficulties providing all the meal components due to a food shortage must submit the Child Nutrition Programs Food Shortages During COVID-19 survey. Upon receipt, the assigned education program specialist will work with the school food authority on meal pattern flexibilities.  

Equipment Needs  

Schools should consider additional resources and equipment that may be needed for alternative serving methods, whether non-congregate or meals in the classroom or any other approved method.  
  • Schools must ensure sufficient supply of masks, gloves and cleaning supplies for the meal service  
  • Schools may need “wayfinding” disks or stickers to mark social distancing guidelines. 
  • Schools may need additional hot and cold food carts to transport meals from the preparation area to the meal distribution location whether in the school or for non-congregate meals 
Schools may need additional meal packaging equipment and supplies such as take-home containers, paper bags and a variety of cup sizes with lids and baggies, especially if meals are served in the cafeteria and taken to the classroom or other area in the school for consumption.   

Schools Opting Not to Serve Meals  

Schools and districts should make all decisions in the best interest of the health and safety of students and the community. The USDA child nutrition programs should be offered to students attending school, whether through classroom learning, blended learning or remote learning to the maximum extent feasible.  

Resources  

The Reset and Restart Education Planning Guide for Ohio Schools and Districts is designed to help schools and their partners understand guidelines and considerations for reopening school buildings during the continued presence of COVID-19 in a way that protects the health and safety of vulnerable members of school communities.  
 
The COVID-19 Health and Prevention Guidance for Ohio K-12 Schools provides a framework for districts and school leaders to reopen school buildings while also helping their students and staff reduce the risk of exposure and prevent the spread of COVID-19 in their communities.  
  
School food authorities should continue to check the CRRS Download Forms for updated resources and guides to assist schools. Resource guides are updated regularly.  
 
For more information and questions, email child.nutrition@education.ohio.gov or contact an Education Program Specialist. 
 

Last Modified: 8/24/2020 9:26:50 AM