Provision 2 is an option in the Federal School Breakfast Program (SBP) and National School Lunch Program (NSLP) for schools to provide free meals to all students, reduce the paperwork, and simplify the logistics of operating school meals programs. Any school that participates in the SBP or NSLP may opt for Provision 2. (Section 11(a)(1), 42 USC 1759(a); 7 CFR 245; Provision 2 of the National School Lunch Act).

Participating schools may choose to apply the provision to SBP, NSLP, or both.

Schools participating in Provision 2 must serve meals to all participating children at no charge for up to 4 consecutive years with the ability to extend for additional four year cycles. In return, Provision 2 allows schools to reduce some of the administrative burdens associated with the distribution of free and reduced price meal applications and the determination of eligibility. It also eliminates meal counts by type after the first year of the program (the “base year”). During the base year, there is no change in traditional procedures and administrative burden. However, the school must provide free meals for all of its students. The largest benefit comes during years 2, 3 and 4 of the cycle because the school makes no new eligibility determinations and continues to serve all children meals at no charge. The school takes count of only the total number of reimbursable meals served each day, instead of meals by type. Reimbursement during these years is determined by applying the percentages of free, reduced price and paid meals served during the base year to the total meal count for the claiming period in subsequent years. The school must make up the difference between federal reimbursement and meal cost. Extensions of four additional non-base years may be granted to systems if appropriate data is submitted to the state agency.

Though the school must provide free meals to all children under Provision 2, the lower administrative costs often outweigh the costs of feeding additional students at no charge (Provision 2 Guidance, USDA, Summer 2002).

Why Provision 2?

To simplify paperwork
  • Applications – Collect applications only once every four years, at most.
  • Claims – Record and track meal categories only once every four years, at most.
  • Verifications – Conduct verifications only once every four years, at most.
To streamline meal service
  • No more cashiers – All students eat at no charge.
  • No more student PIN numbers, lunch tickets or ID cards – Collect only total meal counts.
  • Faster serving lines – Students spend more time eating, less time in line.
To decrease school food service costs
  • Significant administrative savings – Reduce labor costs associated with collecting, tracking and recording of applications, meal categories, payments and verifications.
  • Free employees for other areas of food service – Employee hours spent on administration can be shifted to meal preparation and service.
  • Economies of scale – Higher meal participation leads to lower per-meal costs.
To promote good nutrition and help improve student performance
  • Provision 2 increases student participation in school meals.
  • Children who eat school meals have more nutritious diets than children who don’t, regardless of income level.
  • Better nutrition in children leads to better academic performance, behavior and learning environments.
  • Providing school meals at no charge promotes the value of good nutrition to all students.

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FOOD RESEARCH AND ACTION CENTER (http://frac.org)

Participation “Pros”

 

Students at Provision 2 sites receive meals (SBP and NSLP) free of charge, regardless of the eligibility determination made in the base year, for the entire length of time that site participates.

This decreases the financial burden on previously identified “reduced” and “paid” status households, allows equal access to SBP and NSLP for all students, and further simplifies the point of service (POS) procedure for school food service staff (payment collected, charges, etc).

Increased participation observed with school meal programs (SBP and NSLP) participating in Provision 2

Increased participation assures that a larger percent of children are receiving nutritious meals which aides in learning and decreasing behavioral problems. They also increase exposure to new food, which promotes lifelong healthy eating. Increased participation also yields higher reimbursement which helps offset costs associated with the school no longer collecting money from households that would normally pay for a “reduced” price or “paid” meal.

Simplified counting and claiming system used in non-base years (years 2, 3, and 4, plus any extensions)

Participating schools are only required to collect meal count totals for meals under the provision (SBP and NSLP) at the POS, without regard to eligibility status, allowing for faster serving times and eliminating the need for ID cards, tokens, etc. Claiming in all non-base years is based on percentages established in the base year (i.e., the percent of total lunches claimed as free in September of the 2012 base year is determined to be 85% [8,500 of the 10,000 meals were free]. This percentage then gets applied to the total amount of lunches served in September 2013, 2014, and 2015 [plus additional years if extension is granted] to determine how many should be claimed as “free.”

No new eligibility determinations made in non-base years at participating sites

Staff is not tied up with distribution, collection, and processing of meal benefit applications; updating eligibility based on Direct Certification runs; or the verification process at participating sites.

4-year cycle with opportunity for system to apply for extensions (four additional non-base years added) if able to prove that the income level of each school’s population has remained stable, declined, or had only negligible improvements.

Participation “Cons”

 

When participating in Provision 2, it becomes the school system’s responsibility to cover the difference (using non-federal sources) between federal reimbursement and the cost of providing meals at no charge.

Participating schools no longer receive money in exchange for student meals, regardless of status determinations made in the base year.

Room for Expansion = Cost Considerations

As meals become available to students free of charge, schools will begin to see increases in meal participation. This is great for multiple reasons; however, the question “is there sufficient room for this significantly increased participation?” emerges.

Errors made in the base year (i.e., errors made in eligibility determinations or counting/claiming procedures) have the potential to be compounded over multiple years.

These errors can cost a system a lot of money. As “base year” information (determinations made, claiming percentages, etc.) is the data that will be applied to all following non-base years, this data needs to be as exact as possible. Also, for the purposes of receiving the most reimbursement in non-base years, systems actively (and frequently) need to remind households to submit their meal applications (as free status meals yields the highest reimbursement). In addition, SFS staff needs to be well trained and assurances need to be made that the POS system captures all reimbursable meals, by status, and does so correctly. Assuring that all of this takes place requires forethought and considerable time.

Having a base year only once every 4 years (or less frequently, when extensions are granted)allows for SFS staff to get out of practice with the distribution, processing, and approval of meal applications.

It is also often difficult to obtain completed applications from households as parents get out of the yearly routine of application submission.

Resistance to Change

Most of us are resistant to something that we don’t understand; therefore, it is essential that individuals planning to implement Provision 2 engage parents, students, teachers, cafeteria workers, principals, etc., in the process.

Is Provision 2 Right for My School?

Schools with high percentages of low-income students are often able to use Provision 2 for both SBP and NSLP without losing money. Schools must evaluate whether the savings in administrative costs associated with reducing application burdens and simplifying meal counting and claiming procedures under Provision 2 offset the costs of providing meals to all children at no cost. Many schools are able to realize cost savings when at least 75% of their students qualify for free or reduced priced meals.

Some schools have opted to use Provision 2 for breakfast only when the percentage of free and reduced-price students is as low as 60%. When schools use Provision 2 for SBP only, they have to continue collecting school meal applications, but the school still benefits from not having to do individual counting and claiming at breakfast. This saves time in the lines, increases breakfast participation by low-income students and makes it easier for schools to provide breakfast in the classroom.

Schools that rely on “at-risk” funding will need to assess how the alternative method for determining at-risk will affect their funding (see “How will this policy change affect my ‘at-risk’ funding?” – pocket) (http://frac.org/community-eligiblity/).

Schools must also consider their ability to handle the larger number of students likely to participate in the meal programs, ability to implement new procedures, and administer a new program.

The Food Research Action Center has developed cost-benefit analysis worksheets and can assist schools in determining whether Provision 2 is right for them (http://frac.org/newsite/wp-content/uploads/2009/05/provision2.pdf).

Factors to Consider:
  • Revenue gained by increased participation
  • Revenue lost from paid and reduced receipts
  • Administrative and cost savings from simplified procedures
  • Ability to conduct efficient program
  • Ability to accommodate increased participation

provision2_healthyLunchB&W

How Do I Implement Provision 2?

The USDA’s regulations concerning Provision 2 can be found in Title 7, Code of Federal Regulations, Part 245. Other information about Provision 2 is posted on the USDA website at http://fns.usda.gov/cnd/governance/prov-1-2-3/prov2guidance.pdf. The following is an overview of the information contained therein.

Before Implementation

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Base Year

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Non-Base Year

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End of Provision 2 Cycles

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Time Line

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Other Issues

You can find additional information on the below issues in the USDA Provision 2 Guidance here: http://www.fns.usda.gov/cnd/Governance/prov-1-2-3/Prov2Guidance.pdf.

CHAPTER 4 – Changes in the School Year

  • Change in Facility p. 36
  • Change in Population p. 37
  • Change in Operating Days p. 38
  • Change in Scheduling p. 38
  • Visiting Students p. 38

CHAPTER 5 – Afterschool Snacks and Summer School p. 40

CHAPTER 6 – Provision Transfers

  • Returning to Standard Procedures p. 42

CHAPTER 7 – State Monitoring p. 45

CHAPTER 8 – Recordkeeping p. 47

GLOSSARY – p. 50

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Provision 2 FAQs

 

What is Provision 2?

Provision 2 is an option in the federal School Breakfast Program (SBP) and National School Lunch Program (NSLP) for schools to reduce the paperwork and simplify the logistics of operating school meals programs.

Who can participate in Provision 2?

Any school that participates in the SBP and NSLP may opt for Provision 2.

Do all school sites under a Louisiana Education Authority (LEA) have to participate in Provision 2?

No. The LEA does not have to apply Provision 2 to all sites. The LEA may select to apply Provision 2 to sites where the greatest benefits would be received.

Does Provision 2 have to apply for both the SBP and the NSLP at selected sites?

No. The LEA has the option to apply to school breakfast only, school lunch only, or both at participating sites.

What is the requirement to participate in Provision 2?

The LEA must participate in the SBP, the NSLP, or both. There is no requirement that a minimum percentage of children enrolled are eligible for free and reduced price meals. However, Provision 2 may be a good alternative for schools in the LEA with a very high percentage of children eligible for free and reduced price meals.

When can a LEA begin implementation of Provision 2?

Provision 2 must be implemented at the beginning of the school year. However, the state agency may allow a school to delay implementing Provision 2 for a period not to exceed the first claiming period of the base year.

What is delayed implementation?

This is a request that LEAs may submit to the state agency if they choose to begin implementation of Provision 2 at a date later than the start of the school year. This allowance must not exceed the first claiming period of the school year.

What is considered the first claiming period?

Generally, claims for reimbursement are filed for meals served in each month. Regulations allow that, if the first or last month of program operations for any school year contains 10 operating days or less, such month may be combined with the claim for reimbursement for the adjacent month. As an example, if a Provision 2 school starts mid-August with 8 operating days and there are 15 operating days in September, these two months could be considered the first claiming period (for a total of 23 operating days). In this example, the state agency could approve delayed implementation of Provision 2 from the start of school date in August through the month of September – 23 operating days.

What is the benefit of delaying implementation of Provision 2?

During delayed implementation, LEAs are temporarily allowed to charge students for meals based on their current eligibility determination. This encourages a greater number of families to turn in meal applications. This will help to identify the maximum number of students eligible for free or reduced meals which is particularly important for LEAs in the non-base years.

How long will the state agency approve an LEA to participate in Provision 2?

Provision 2 operates on a 4-year cycle. During the first year of Provision 2, known as the base year, the school serves all children meals at no charge regardless of each child’s free, reduced-price, or paid eligibility category, but otherwise operates the meal programs under standard procedures. The remaining 3 years are considered non-base years. During this time, all children continue to receive free meals and LEAs benefit from a simplified counting and claiming system.

Once approved for Provision 2, are LEAs locked into a 4-year cycle?

No. LEAs may revert back to standard operating procedures at any time after first notifying the state agency.

What are an LEA’s responsibilities during a base year of Provision 2?

During the first year (base year) of Provision 2, there is no change in traditional procedures and administrative burden for LEAs. Participating sites must do the following:

  1. Obtain state agency approval to operate the SBP and NSLP using Provision 2 procedures in some or all schools in the LEA;
  2. Offer reimbursable breakfasts and lunches at no charge to all children, regardless of the children’s eligibility status;
  3. Notify the public of the availability of school meals and distribute free and reduced price meal applications (if not using delayed implementation);
  4. Make free and reduced price eligibility determination and ensure that applications from the Provision 2 school(s) have an equal chance of being selected for Verification in accordance with the LEA’s verification procedures;
  5. Count meals at the point of service (POS) and claim those meals according to the eligibility status of the children served;
  6. Calculate monthly or annual claiming percentages for use in the non-base years; and
  7. Retain specific base year records for the entire period that the school operates under Provision 2 (base year plus all extensions), plus three years or longer, if there are audit findings and until resolution of the findings.

If a site opts to delay implementation of Provision 2, do they stop collecting free and reduced price meal applications once Provision 2 begins?

No. All sites implementing Provision 2 continue to collect free and reduced price meal applications for the remainder of the base year.

What are the key differences between the non-base years and base years of Provision 2?

In non-base years, LEAs:

  1. Do not collect free and reduced price meal applications;
  2. Do not perform Verification at participating sites;
  3. Benefit from a simplified POS where counts are recorded without regard to eligibility status; and
  4. Monthly claims are based on percentages calculated in the base year.

In base years, LEAs:

  1. Collect free and reduced price meal applications;
  2. Perform Verification selecting among all sites;
  3. Count meals served according to eligibility status at the POS; and
  4. Monthly claims are based on actual eligibility totals for the month.

What happens if new students are accepted at a Provision 2 site in a non-base year?

They are simply included in the total meal count collected at the POS when they participate in meal service. Free and reduced price meal applications are not distributed or collected from these families. Remember: Applications are only processed in base years.

What are the public notification requirements for Provision 2?

When your school is implementing Provision 2, you must notify the media and distribute a letter to parents/guardians about the availability of school meals at no charge under the NSLP and, if applicable, the SBP. This would normally occur at the beginning of the school year unless you are delaying implementation. The LEA may use the non-pricing public release which indicates that the school will not be charging any child regardless of eligibility category for meals.

The LEA must also distribute free and reduced price meal applications. The LEA should modify the letter to parents/guardians, to request that households (HHs) eligible for free and reduced-price meals complete the application, allowing LEAs to obtain proper reimbursement in order to continue providing meals to all children at no charge.

If an LEA delays implementation, what are the public notification requirements?

If you delay implementation of Provision 2, you may delay informing HHs that schools will implement Provision 2; however, you must follow the standard public notification requirements for the period of time the school is not under Provision 2. The LEA may want to use the standard media release and letter to parents/guardians with a free and reduced-price application.

At or about the start of Provision 2 implementation (which must occur at the close of the first claiming period or sooner), schools must promptly notify the public and HHs of the availability of Provision 2 benefits. The public notification may be done through a media release. Each HH must also be informed in writing of the availability of meals at no charge. This notice must be provided to all HHs regardless of eligibility category.

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DEPARTMENT OF EDUCATION LOUISIANA BELIEVES