Will community-based afterschool programs be able to provide meals to students and families this fall?

Last spring and throughout the summer as communities, schools and afterschool program providers worked to respond to the impact of COVID-19, providing meals to families in need became a critical part of the response. The U.S. Department of Agriculture’s (USDA) timely leadership in allowing flexibility and issuing waivers at the national level (as well as approving state waiver requests) allowed millions of families to access healthy meals in absence of the free and reduced-price meals that children would have normally received at school through the National School Lunch Program (NSLP) and School Breakfast Program (SBP). Community-based programs, park and recreation departments, Boys and Girls Clubs, YMCAs and many other partners stepped up to complement the work done by school nutrition programs in making sure families got the meals they needed as a result of the flexibility granted by USDA. In fact, a survey of afterschool providers released last week found that 48% of providers served or delivered meals to families.

As the new school year gets underway and many school districts consider opening in virtual and hybrid models, community-based providers are again prepared to step in and help ensure families in need have access to healthy meals. However, while USDA has opted to extend several nutrition waivers through the 2020-2021 school year, the current waiver limitations will drastically impede the ability of sponsors – specifically nonprofit and community sponsors – to maintain the same level of meal service in the fall that was provided during the spring and summer.

A wide range of national organizations have come together to urge USDA to maintain the flexibility and waivers from last spring and summer that support both school nutrition departments and non-school sponsors, and which allow for a continuation of the meal service seen over the last three months. While an ongoing dialogue continues with Congress, USDA, and stakeholder groups, time is of the essence to resolve these challenges. The specific waivers in question are outlined below.

Summer Food Service Program (SFSP) Waiver

Many community-based organizations, local government agencies, and other non-school sponsors have been serving three meals and a snack each day since schools went to a virtual model in March 2020 by operating both Child and Adult Care Food Program (CACFP) At-Risk Meal Program and the Summer Food Service Program (SFSP) at community-based sites. While USDA has extended several waivers for the upcoming school year – such as those that allow NSLP, SBP, and CACFP meals to be picked up and consumed at home – the flexibility to continue operating SFSP is not currently included. By not allowing Summer Food Service Program as a program option moving forward, non-school sponsors will no longer be able to provide three meals and a snack a day, as they are limited to the more restrictive CACFP At Risk Afterschool Meals Program.

Non-school sponsors played an essential role during unanticipated school closures and have always played a critical role in feeding children when schools are closed. With children likely to spend even more time out of school buildings in the fall, and some possibly spending their virtual class day at an in-person afterschool program possibly up to 8 hours a day, it is important to recognize that there may be gaps in the meals provided by schools. Additionally, if bussing or other services are scaled back, it may be easier for families to get to a community site instead of a school building if school is out for multiple days in a row. Ideally USDA will allow non-school sponsors to utilize both the Summer Food Service Program and Child and Adult Care Food Program on days when school is not physically in session or remote for some or all students at the school, to ensure continued access to meals.

Area Eligibility Waiver

Another barrier to providing meals is the expiration of the Area Eligibility Waiver. Allowing sites to provide meals in communities that do not meet the 50% area eligibility threshold has been essential to reaching children that may be newly eligible during the summer months. This is especially important considering the ongoing economic impact of COVID-19 on families and communities. Currently, all state-approved area eligibility waivers for SFSP and SSO have only been extended through August 31. Extending the area eligibility waiver – in conjunction with the option to use SFSP or SSO when children are not at school – through the 2020-2021 school year will help not only reduce barriers to participation during remote school days, but also the administrative burden on sponsors and schools. We are calling on USDA to extend the area eligibility waiver through the 2020-2021 school year while also allowing the use of SFSP/SSO. 

We are calling on USDA to extend the area eligibility waiver through the 2020-2021 school year while also allowing the use of SFSP/SSO. 

Afterschool Activity Waiver

Finally, USDA need to extend the Afterschool Activity Waiver. While the non-congregate waiver extension includes CACFP, it is unclear whether this applies to the Afterschool Meal Program, which requires that an enrichment of educational component be provided alongside meals. Although some school and community-based programs will be able to resume programming in the fall, it is unrealistic to assume that they will be operating at full capacity. To ensure access to the suppers and snacks provided through CACFP, it is imperative that the afterschool activity be waived when programming isn’t possible. Waiving the afterschool activity requirement is also critical for those schools that plan on providing suppers through non-congregate methods on days when school is and is not in session. USDA should waive the afterschool activity requirement for those sponsors and schools participating in the CACFP Afterschool Meal Program, or schools serving NSLP snacks.

Authority to issue these waivers was provided to USDA through the Families First Coronavirus Response Act that was signed into law in mid-March, however as Congress weighs a new Covid-19 package, discussion continues to determine if USDA needs additional authority and/or access to additional mandatory funding in order to meet the pressing nutrition needs of families in need. We will continue to monitor this evolving process.