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Quarterly Policy Update: July 2025

In the last few months, the new USDA administration has begun to make changes that include deregulation and rescission of guidance, as well as a reorganization of USDA structure. USDA has also released reimbursement rates and the second iteration of their Study of Nutrition and Activity in CACFP. During this time, the Office of the President has released it’s Make America Healthy Again Assessment and proposed budget for FY26, both of which could have effects on child nutrition programs.

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Head Start One-Time Supplemental Nutrition Funds

The Office of Head Start announced that Head Start grant recipients can request supplemental funds to promote nutrition services and healthy eating for enrolled children and families. This funding was created in response to hearing that lack of funding is a barrier to improving or expanding nutrition services in Head Start programs.

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CACFP: A Critical Support for Child Care

The CACFP has many benefits – it supports child care providers and ensures that children and adults in care receive nutritious meals. The CACFP is also critical in supporting child care businesses by decreasing costs that can be reallocated towards program improvement, staff wages, or lower tuition rates.

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USDA and HHS Notice: CNPs and Head Start as Federal Public Benefit

USDA and HHS each released a notice stating that many programs under the jurisdiction of both departments are now interpreted as “Federal Public Benefits,” including all CNPs and Head Start. The notices aim to address whether citizenship or qualified immigration status must be verified in order for a child to participate in these federal programs.

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USDA Rescinds Guidance on Interpretation of Discrimination Based on Sex 

The USDA released a memorandum rescinding 2022 guidance regarding the interpretation of discrimination based on “sex.” The 2022 guidance redefined the definition of “sex” to include gender identity and sexual orientation. Therefore, the rescission of this guidance will revert USDA’s definition back to its previous interpretation and omit mention of gender identity and sexual orientation.

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Off-Site Monitoring in FY25

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. In Fiscal Year 2025, at least nine States have applied and been approved for an off-site monitoring waiver.

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President’s Budget: Proposed Cuts to Child Nutrition Grants and Training

The White House released the President’s Budget for Fiscal Year 2026, which includes cuts to discretionary spending for Child Nutrition Programs (CNPs). While the budget maintains full funding for Child Nutrition Programs, like the CACFP and SFSP, the cuts to discretionary spending include the Patrick Leahy Farm to School Grant and the Institute for Child Nutrition (ICN), a National Ally of NCA.

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