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In September 2022, USDA released final rules for the Summer Food Service Program (SFSP), “Streamlining Program Requirements and Improving Integrity in the Summer Food Service Program.” Many changes were implemented by the Oregon Department of Education Child Nutrition Programs (ODE CNP) and sponsors in Summer 2023 as a result of the final rules.
In preparation for Summer 2024, ODE CNP found that sponsors had not been notified of an important change regarding written policies and procedures. The streamlined rules include the regulatory change requiring written policies and procedures. The written policies and procedures must assign Program responsibilities and duties and ensure compliance with civil right requirements and include a financial system with management controls specified in written operational policies.
Per 7 CFR 225.6(d), ODE CNP may only approve the application and renewal of those sponsors that meet the three performance standards: Financial Viability, Administrative Capability and Program Accountability. The performance standards are often referred to as VCA. All three performance standards are to be reviewed through initial application, annual renewal, and administrative review. Many of the questions and information gathered through CNPweb, and offline forms, such as the budget, collect the required information to support VCA. However, ODE CNP has not collected or required written policies and procedures, outside of corrective actions in the past.
Effective immediately, per 7 CFR 225.6(d), all SFSP sponsors are required to have the following:
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7 CFR 225.6(d)(2)(ii) – Written policies and procedures that assign Program responsibilities and duties to ensure compliance.
Examples include: site monitoring, recordkeeping, annual training, point-of-service meal counts, menu development -implementation and review, and civil rights policy and procedures.
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7 CFR 225.6(d)(3)(i) - A financial system with management controls specified in written operational policies that will ensure that:
- All funds and property received are handled with fiscal integrity and accountability;
- Examples include: Identify and describe the accounting report or account codes that will document all SFSP revenue and expense
- All expenses are incurred with integrity and accountability;
- Examples include: Identify how source documents will be maintained for all SFSP transactions, and how time and attendance reports of labor charged to SFSP will be maintained.
- Claims will be processed accurately, and in a timely manner;
- Examples include: Identify the timeline and positions responsible for submitting claims
- Funds and property are properly safeguarded and used, and expenses incurred, for authorized Program purposes; and
- Examples include: Describe how only allowable SFSP funds approved on budget will be charged to SFSP and how budget will be review to actual expenses to ensure unallowable costs are not charged
- A system of safeguards and controls is in place to prevent and detect improper financial activities by employees.
- Example include: Identify and describe how information regarding the Nonprofit Food Service (NPFS) Account is communicated and documented between Finance and Program staff and their roles in maintaining NPFS
- For more information on SFSP Financial Management requirements, please visit the ODE CNP memo, Summer Food Service Program (SFSP) Financial Management Requirements, that was issued on June 3, 2021.
Written policies and procedures must outline the key functions of the operation of the Summer Food Service Program, including documenting the positions responsible for the process. The polices should align with the Management Plan in CNPweb. Additionally, they must reflect current practices.
ODE CNP is developing several templated policies and procedures to help sponsors get started on written procedures. The first one available is the SFSP Financial Management Procedure. Additional templates will be posted on the public ODE CNP Summer Food Service Program page under “Program Forms and Templates” as they are available.
Additionally, sponsors who operate other Child Nutrition Programs may have written policies and procedures that do not explicitly state the Summer Food Service Program but may apply to the Program. ODE CNP recommends that the sponsor revises or creates an addendum to existing CN Programs policies that also apply to SFSP.
Based on the requirement of written policies and procedures, ODE CNP will be implementing the following application and administrative review processes:
Financial Management Policies & Procedures
- For all new applicants, the organization must submit written financial management policies and procedures along with their budget and supporting documentation to ODE CNP.
This has been implemented as of March 1, 2024, and is required of all new applicants.
- For renewing sponsors, ODE CNP will request the fiscal management policies and procedures during an administrative review.
In the sponsor’s first review after March 1, 2024, if a financial management policy and procedure is not available or does not meet the requirements, as listed above, ODE CNP will issue technical assistance with guidance on the procedure.
For the second review after March 1, 2024, if a financial management policy and procedure is not available or does not meet the requirements, a finding will be issued with required corrective action.
Other required written policies or procedures that assign Program responsibilities and ensure
- For all new applicants, ODE CNP will review the sponsor’s written policies and procedures to support the management plan through the pre-approval process.
- For renewing sponsors, ODE CNP will continue to review these during the administrative review process. Often, sponsors will already have written policies and procedures as a result of previous corrective actions, or through the implementation process. If ODE CNP determines that a written policy or procedure needs to be revised or developed, technical assistance will be provided. If procedures are not implemented fully or accurately, this may result in findings and corrective actions will be assigned.
ODE CNP understands that SFSP policies and procedures will vary by sponsor based on organizational structure and will be evaluated in such manner. While ODE CNP has provided templates to help support sponsors, it is not a requirement that sponsors use the templates. Sponsors creating their own written procedures are encouraged to use the template as a guide to ensure that the sponsor’s procedures include all required elements.
If you have any questions or concerns, please contact your assigned Child Nutrition Specialist.
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