Note: Waivers from the USDA are rapidly changing and expanding. Please visit their website for the latest on national and state-level waivers.
Nearly 22 million students nationwide rely on free and reduced-price meals at school, but school closures from COVID-19 have put school meal programs at risk of failing to meet the needs of eligible children. While most decisions about school meals are made locally, states can play a critical role in supporting communities and schools during emergency conditions by giving them the flexibility to deliver meals to students in a comprehensive, safe, and sustainable way.
Most states already have laws that address how schools should respond in the event of a contagious disease outbreak; however, very few address continuation of meal services. One exception is an Oregon regulation that allows students eligible for free and reduced-price school meals to receive benefits under the Pandemic-related Supplemental Nutrition Assistance Program (PSNAP) during school closures due to pandemics.
The Centers for Disease Control and Prevention (CDC) recommends that as school districts ensure continuity of meal programs amid school closures, they avoid distributing food in settings where people gather in crowds. The U.S. Department of Agriculture (USDA) has approved all state requests to transition to the Summer Food Service Program and Seamless Summer Option to provide meals to students affected by school closures at no additional cost. USDA has also enacted national waivers to allow for meals to be served outside of group settings and to permit children to not be physically present to receive meals. Given these new flexibilities, the following options are available to school districts to support meal distribution to students under age 18:
States can help communities support all children by allowing them broader flexibility to implement programs based on their unique needs:
- Support communities in ensuring that school meals meet the nutritional needs of children and youth. While nationwide waivers allow states to grant local flexibility in the foods used to make meals, meal programs should otherwise meet nutrition standards to the greatest extent possible. States can guide communities toward best practices in meeting students’ nutritional needs in these exceptional circumstances.
- Support community efforts to deliver multiple meals at a time during emergency conditions. Under USDA rules, meal programs may provide students with up to two meals per day. With state approval, however, schools can distribute up to a week’s worth of food at a time. Rapid response strategies, as well as state policies regarding school meals during emergency conditions, could help states quickly interpret federal policy changes and issue approvals to accommodate the shifting needs of schools and communities.
- Encourage school districts to make comprehensive plans for staffing. Some districts have struggled with finding enough staff to provide food service and delivery. States should encourage school districts to prioritize staffing meal sites with employees who have already passed background checks—including bus drivers, teachers, or librarians—when food service staff are unable or unwilling to work. States should also develop guidelines for volunteer involvement, such as using volunteers to support program tasks that are not in direct contact with children and families.
- Help school districts keep meal programs fiscally sustainable, especially in schools without community eligibility. At this time, the USDA has not waived its normal recordkeeping requirements for summer meal programs, meaning that program participation should be limited to students eligible for free and reduced-price meals if meals are to be federally reimbursed. However, meeting federal recordkeeping and eligibility verification requirements may present COVID-19 transmission risks. For example, pick-up sites might require student identification or PIN numbers upon meal delivery. States may also request waivers to distribute meals to parents and guardians of eligible students instead of serving meals to children directly, which would require parents to show proof of guardianship at the pick-up site. Given the need for social distancing and minimizing contact, states should support innovative solutions to meet this approach. In some cases, school districts may choose to distribute food regardless of verification to reach as many children as possible. States should consider providing supplemental funding in the absence of recordkeeping or offer alternative recordkeeping options to help communities ensure that meal programs remain sustainable. For communities without community-level eligibility for free lunch, recordkeeping and sustained funding could be especially onerous.
- Monitor meal program needs and ensure that program operators are documenting all program costs. States can help school districts by providing guidance on properly documenting allowable program costs, including direct food costs, food service labor, and administrative costs. Although costs associated with meal delivery routes are not typically reimbursed under summer meal programs, the USDA has outlined other potential mechanisms to pay for meal delivery.
States can implement these recommendations to support communities immediately. In the long run, food distribution should be built into school pandemic planning policies and guidance. As schools across the country work diligently and creatively to feed their students during this challenging time, states must provide the necessary flexibilities and supports to make meal service as accessible as possible.