Ensuring Integrity in Non-Congregate Meal Service in the SFSP

USDA Guidance

Parent or Guardian Pick-up

Considerations for Developing State Agency Policies

Verification of participant eligibility and preventing duplicate meals are two important integrity concerns for the parent or guardian pick-up option. During the application process, State agencies must confirm sponsor procedures ensure meals are distributed only to parents or guardians for eligible children. This could include requiring children to be present with a parent or guardian at the first meal pick-up. Sponsors, as a best practice, are expected to also request documentation from the parent or guardian picking up the meals, either before or during meal service. Such documentation may include:

• An official letter or email from a school confirming student enrollment,
• Student ID cards,
• Individual student report cards,
• Attendance record from the parent portal of the school website, or
• Other official third-party records that confirm a child is eligible.

In addition to ensuring that meals are provided only to eligible children, sponsors must have effective procedures to prevent the issuance of duplicate meals, which may differ depending on site characteristics. Examples of procedures include:

• Requiring sign-in sheets for participants at the site and periodically cross
  referencing them across sponsors with multiple sites in close proximity.
• Utilizing technology to capture meal service participation, like QR codes, an online
  registration system, or other methods to electronically capture participation.
• Restricting meal service times to defined periods of time instead of permitting
  extended or all-day distribution times to ensure sponsors and State agencies can
  effectively monitor meal service times and conduct full reviews of the meal
  service.
• Requiring pre-registration and having names on rosters to confirm when meals
  are distributed.

Site Caps

How to Assess Requests for Site Cap Increases

A sponsor may request a site cap increase if they feel the estimate provided as part of their application was too low. State agencies should establish a process for considering requests to increase site caps that ensures any increase aligns with the target population for the site. Below are methods and factors a State can consider when evaluating these requests. Please note, this is not an exhaustive list, and State agencies are not limited to the examples below.

• Utilizing datasets (like Census data or school data) and monitoring tools (on-site
  and off-site) to help assess whether a proposed increase is reasonable.
• Conducting meal service reviews to observe whether the proposed increase is
  justified.
• Considering the following questions when reviewing sponsor site cap requests:
  • Is the rationale for the requested site increase reasonable?
  • Is the site increase significant (i.e., more than a 5% increase)?
  • Are other sites in the area serving a similar number of meals?
  • Is the site increase justifiable based on the number of children that reside in the
    area?
  • Has the site previously requested an increase?
  • What is the target population of the site?
  • Does the site intend to serve children who live within the bounds of the rural area
    and is the site cap reflective of serving those children?

Site Proximity

Considerations for Developing State Agency Policies

State agencies should develop policies regarding site proximity for congregate and non congregate sites. Each proposed site must be evaluated individually and thoroughly by the State agency, and in the context of other sites serving the area. Previous guidance on proximity of sites can be found in SFSP 15-2023, Best Practices for Determining Proximity of Sites in the Summer Food Service Program, September 28, 2023.

State agencies should consider the following factors related to site proximity when reviewing applications:

• The distance between all proposed sites and site location:
  • Consider population density and the ability for participants to access the sites
    based on geography.
  • If two proposed sites are in close proximity, request documentation to explain the
    need:
    • Maximum distance someone might travel in a rural area.
    • Adjacent site types are closed-enrolled or camps.
  • Ensure that sponsors operating sites in close proximity have a way to contact
    each other to prevent meal duplication or otherwise build in an obvious indicator
    of meal duplication, such as color-coding meal bags for different sites.
  • Use mapping tools such as Capacity Builder, Google maps, Apple maps, or
    MapQuest to confirm site proximity for proposed sites.
  • In situations where a sponsor proposes a non-congregate site located adjacent
    to a suburban or urban area, ensure that the purpose of such site is to serve
    children who live within the bounds of the rural area and duplicate meals are not
    served.
• The population to be served:
  • Require sponsors to provide detailed information on the population of children
    that will be served at each site.
  • Generally, State agencies must ensure that the same population will not be
    served at more than one site. While it is allowable to approve meal sites in close
    proximity if they offer meals that attract different groups of children, any service
    institution may only serve two meals, or one meal and one snack, per child per
    day.
  • Sites that appeal to specialized groups of children may include:
    • Specific age groups, such as when one site attracts primarily young
      children, while another site attracts primarily teens.
    • Children with special dietary requirements, such as kosher or halal meals.
• The meals that will be distributed:
  • In approving sites that are in close proximity, ensure the same population of
    children are not receiving more than the maximum allowable meals (for most
    sites, two meals or one meal and one snack per day).
    • For example, if one site proposes to distribute breakfasts and lunches and
      another site in close proximity proposes to distribute suppers and snacks,
      the State agency must consider whether the sites are, for practical
      purposes, operating as a single site to serve meals in excess of the
      maximum allowed per child for a single day.
• Meal service times:
  • Consider restricting meal service times to defined periods of time instead of
    permitting extended or all-day distribution times.
  • Sites in close proximity that have the same or short meal service times could
    help prevent children traveling to multiple sites and receiving duplicate meals.
  • In addition, this will help ensure that sponsors and State agencies can effectively
    monitor meal service times and conduct full reviews of the meal service.
  • Require sponsors that operate an open non-congregate site near a closed
    enrolled congregate site to schedule their meal service times to start and finish
    before the closed-enrolled site’s meal service ends, to prevent meal duplication.

Monitoring Home Delivery

State Agency Home Delivery Monitoring Requirements

Monitoring requirements of home delivery routes are similar to monitoring requirements for other rural non-congregate sites. State agencies must still establish which sites need pre-approval visits, such as those that did not participate in the program in the prior year, existing sites that are new to non-congregate meal service, and those that exhibited operational problems in the prior year.

During a sponsor review, the State agency is required to conduct reviews of at least 10 percent of each reviewed sponsor's sites, or one site, whichever number is greater. The review sample must include sites representative of all meal service models and meal distribution methods operated by the sponsor; this includes home delivery routes.

Preparing for an On-site Review of Home Delivery

Prior to conducting an on-site review of a sponsor’s home delivery route, the State agency should:

• Ensure the sponsor has written parental consent for home delivery.
• Ensure that the entire home delivery route meets the definition of rural.
• Verify the days of operation and that the delivery route time match the State
  agency’s approved meal service time.
  • For example, if the approved meal service time is from 8 a.m. -2 p.m., the
    first delivery would occur no earlier than 8 a.m. and the last delivery would
    occur no later than 2 p.m.
• Verify the approved meal distribution method (i.e., bulk distribution, unitized
  meals, multi-day meal issuance).
• Verify the individual responsible for completing the point-of-service meal counts
  on the delivery route and ensure the sponsor has a record of their training for the
  current program year.
• Review tracking technology and/or photo evidence of meal deliveries, if available.

 

Read the full USDA memo: Ensuring Integrity in Non-Congregate Meal Service in the Summer Food Service Program (SFSP-04-2026).