Off-Site Monitoring in FY27
November 5, 2026
USDA has the authority to waive statutory or regulatory program requirements for Child Nutrition Programs. State Agencies can submit a 12(l) waiver application to USDA in order to allow for flexibilities, including off-site monitoring, in their state.
Beginning in Fiscal Year 2024, USDA began processing annual waivers from State agencies to allow sponsoring organizations to use off-site monitoring for a certain number of site visits. In FY25, State agencies submitted a variety of waivers that were approved by USDA, allowing up to two site visits to be conducted off-site if certain parameters were met. Almost every FY25 waiver was limited to monitoring family day care homes, however Texas had a waiver approved to conduct off-site visits for homes and centers.
In FY26, State agencies used an off-site monitoring waiver request template from USDA to submit waiver requests. The waiver template only applied to the monitoring of family day care homes and permits only one off-site visit for the fiscal year. For FY27, State agencies are continuing to use the waiver request template.
Why It Matters
Off-site monitoring waivers provide much-needed flexibility to sponsoring organizations. Sponsors who have implemented an off-site monitoring waiver report that it saves money, allows more time for technical assistance and training, maintains program integrity and increases access to providers in remote, hard-to-reach and high-crime areas.
FY27 Offsite Monitoring Waivers
At least 16 States have submitted their waiver request using the USDA template:
- Alaska
- Colorado
- Illinois
- Iowa
- Kansas
- Missouri
- New Hampshire
- New York
- Ohio
- Oregon
- Pennsylvania
- Texas
- Washington
- West Virginia
- Wisconsin
- Wyoming
States With Special Conditions
While every state has submitted a waiver using USDA’s waiver template to allow one off-site monitoring visit for family child care homes, two States included additional limitations to off-site monitoring in their waiver request.
Washington's request would restrict off-site monitoring to rural providers. In their waiver request, the Washington State Office of Superintendent of Public Instruction defines rural to mean:
- any area in a county that is not part of a Metropolitan Statistical Area based on the Office of Management and Budget's Delineations of Metropolitan Statistical Areas;
- any area in a county classified as non-metropolitan based on the USDA Economic Research Service's Rural-Urban Continuum Codes and Urban Influence Codes;
- any census tract classified as non-metropolitan based on the USDA Economic Research Service's Rural-Urban Commuting Area codes;
- any area of a Metropolitan Statistical Area that is not part of a Census Bureau defined urban area;
- any area of a State that is not part of an urban area as determined by the Secretary
- any subsequent substitution or update of these classification schemes created by Federal governing bodies; or
- any 'pocket' within a Metropolitan Statistical Area that, at the option of the State agency and with FNS Regional Office approval, is determined to be rural in character based on other data sources.
Wyoming's request would apply only to day care homes that are in good standing and are located 50 miles or more from the sponsoring organization's office.
USDA Waiver Authority
Under Section 12(l) of the Richard B. Russell National School Lunch Act (NSLA), the Secretary of Agriculture is given the authority to waive any requirements within the NSLA for a State or eligible service provider that requests a waiver if:
- the Secretary determines that the waiver of the requirement would facilitate the ability of the State or eligible service provider to carry out the purpose of the program;
- the State or eligible service provider has provided notice and information to the public regarding the proposed waiver; and
- the State or eligible service provider demonstrates to the satisfaction of the Secretary that the waiver will not increase the overall cost of the program to the Federal Government, and, if the waiver does increase the overall cost to the Federal Government, the cost will be paid from non-Federal funds.