Provision 2 Alternative

1. Provision 2 Alternative Patricia Winders Arkansas Department of Education, Child Nutrition Unit March 3, 2011

2. Provision 2 Alternative • Overview • Incorporated by Congress to help reduce paperwork and administrative burden • Federal Regulations found in 7 CFR 245 • Provision 2 Guidance on http://fns.usda.gov • Base Year • Non-Base Year

3. Provision 2 Alternative • General Information • Meals at NO CHARGE for 4 consecutive years • No maximum or minimum requirement for percentage of free and reduced eligibles (Recommend that districts have 70% or more) • Revenue not received from Paid and Reduced Price students in Provision 2 schools must be paid by Local District funds to the Non-Profit Foodservice account

4. Provision 2 Alternative • General Information • Schools may return to standard meal counting procedures at any time with State Agency approval • 4-year extensions may be granted

5. Provision 2 Alternative • Base Year • 1st year on Provision 2 Alternative • MUST have prior approval from school board and State Agency • All standard meal application procedures are followed • Media release/Letter to household required • Eligibility determinations follow standard procedures

6. Provision 2 Alternative • Base Year • Reimbursable meals MUST be counted at the point of service • Federal reimbursement is based on point of service meal count • Verification procedures are standard. Verification Summary Report is required.

7. Provision 2 Alternative • Base Year • Must maintain base year records Entire time district is under Provision 2, plus 5 years • Longer if audit findings and until audit findings are resolved • Must have approved Agreement and Policy Statement with the State Agency • Districts/Schools claim meals based on claiming percentages established by ADE CNU during the base year audit of applications.

8. Provision 2 Alternative • Non-Base Year • Continuation of Base Year • Verification Summary Report is required. Verification activities are not performed • Point of service count of reimbursable meals required. • Counts are not by type, free, reduced or paid.

9. Provision 2 Alternative • Key Issues to Consider When Requesting to Participate in the Provision 2 Alternative • All meals served at no charge to students. • All students are on equal status within the cafeteria/school environment • When household meal applications are distributed • Public notification • Letter to parents

10. Provision 2 Alternative • Revenue reduction to the district child nutrition program • For three years after the base year • Households cannot be required to complete application in order to participate • Simplified meal counting system at the point of service • NO changes can be made in student populations or facilities that impact or change the economic distribution of students from the base year data

11. Provision 2 Alternative • Financial internal controls must be in place to substantiate the meals counts and claims for reimbursement.

12. Provision 2 Alternative • Commissioner’s Memo FIN-11-059 Provision 2 USDA Alternative for Feeding Students at No Charge in High Poverty Population Areas • Provides resources to assist with the decision to request to participate in the Provision 2 Alternative • Revenue Reduction and Cost Differential Estimate • Sample Provision 2 Addendum to the Federal Child Nutrition Agreement and Policy Statement • Provision 2 Calendar and Implementation Timeline • Provision 2 Questions and Answers • USDA Provision 2 Fact Sheet • http://cnn.k12.ar.us

13. Provision 2 Alternative • Contact Patricia Winders or Donna Ratliff at (501) 324-9502 or patricia.winders@arkansas.gov donna.ratliff@arkansas.gov