Use of Federal Food Programs for GSRP
GSRP students are eligible to participate in the National School Nutrition Programs (SNP) and Child and Adult Care Food Program (CACFP) where applicable. Children who attend GSRP in a classroom operated by the ISD or an LEA which is housed in a public-school building providing free meals for all students, are eligible for free breakfast and lunch. Food program eligibility documentation must continue to be collected as required by the SNP.
GSRP children receiving meals through CACFP are not categorically eligible to receive free meals through this program due to an income requirement less stringent than that of the federal Head Start Program. All families of GSRP children receiving meals or snacks through a federal food program should expect to complete and return the appropriate eligibility documentation (i.e., SNP-Free and Reduced Meal Family Application, CACFP Household Income Eligibility Statements). Participating programs must retain this paperwork as required by the applicable food program.
Programs are required to follow the following Child care Licensing Rule; Rule 400.330(8) A child shall be served meals and snacks in accordance with the following schedule:
- Two and a half hours to 4 hours of operation: a minimum of 1 snack.
- Four hours to 6 hours of operation: a minimum of 1 meal and 1 snack.
- Seven hours to 10 hours of operation: a minimum of 1 meal and 2 snacks or 2 meals and 1 snack.
GSRP funds may only be used to cover the costs of providing classroom meals and snacks that are over and above the reimbursement received from the SNP and/or the CACFP as applicable.
Exception:
All LEA GSRP subrecipients are required to take part in SNP for breakfast and lunch or CACFP for all meals/snacks. An LEA may choose to use SNP for meals, and CACFP for snack only, however, is not required to do so if participation is cost prohibitive.
CBOs that are eligible must participate in CACFP, unless participation is cost prohibitive. Participation may be cost prohibitive when a program has only a small number of children who are eligible for free or reduced reimbursement levels, or when a part-day program offers snack only. In these cases, the administrative cost to participate may exceed reimbursement. To assist in determining if CACFP participation would be cost prohibitive, the ISD should work with the CBO partner to complete the GSRP CACFP Application Decision Tree in the resources for this section.
For some CBOs, engaging with a CACFP sponsor may be beneficial. A CACFP sponsor manages the administrative aspects of participation for a nominal percentage of the reimbursement. This may make participation more accessible allowing for the program to benefit from the federal reimbursement with significantly less administrative burden. A CBO interested in sponsorship should contact CACFP at the Michigan Department of Education (MDE) for more information.
Redetermination of the cost/benefit of participation in CACFP should be conducted any time a significant change to the program structure occurs (e.g., a substantial increase/decrease in enrollment, the addition of a GSRP classroom or before- and after-school-care program) that alters the number of eligible children served meals/snacks.
A for-profit CBO may be ineligible to participate in CACFP based on the number of free/reduced eligible children enrolled. ISDs are advised to work with for profit CBO partners to complete the GSRP CACFP Application Decision Tree in the resources for this section prior to the CBO applying to participate in CACFP. However, if a CBO applies and is deemed ineligible, the CBO will receive a letter from MDE that the center may provide the ISD as documentation of ineligibility. A CBO that is not eligible to participate in CACFP must still provide meals and snacks at no cost to families, with the full cost of doing so attributed to the GSRP budget. See also “Reimbursement to CBOs Not Eligible for CACFP” on the following page.
The reimbursement process between ISDs and subrecipients should not be prohibitive to the SNP and CACFP federal programs that expect children to be provided healthy meal and snack options. The GSRP Monthly Food Service Invoice template found in the resources for this section outlines the information required of subrecipients seeking reimbursement who are eligible for SNP/CACFP. Another template is available for those who cannot participate in either food program. Subrecipients are not required to use a template for reimbursement purposes; however, they will be required to provide all the information outlined on the template.
CBOs that do not have a kitchen or food preparation area must exhaust all potential options before requiring families to provide meals. Efforts should be documented and discussed with the assigned MiLEAP consultant. In the event a CBO is unable to provide meals, or if potential options exhaust a significant portion of the GSRP budget, it should be communicated to families at the time of enrollment that they are responsible for providing meals. In the event a family is unable to provide meals, the site should have a system in place to ensure children are fed.
It is also recognized some families prefer to provide meals. If a family wants to provide meals for their child, the family should complete the Parent Request to Provide Food form located in the resources section. Requesting all families to complete the Parent Request to Provide Food form is not allowable.
Federal Food Program Disqualification
Programs that have been disqualified from federal food program participation may also be ineligible to continue as or become a GSRP subrecipient. ISDs should confirm existing subrecipients’ ongoing participation in the applicable federal food program annually. ISDs should ensure that potential subrecipients are actively participating or have applied to participate in the applicable federal food program and that no existing disqualification is in place prior to entering into an agreement to provide GSRP. In the event of a disqualification, the ISD must notify the assigned GSRP Consultant to determine next steps.
Calculating Meal/Snack Reimbursement
School Nutrition Program (SNP)
LEA subrecipients providing free meals to district K-12 students through Michigan School Meals must also provide free meals to children enrolled in district-run GSRP classrooms. LEA subrecipients that do not participate in Michigan School Meals, must adhere to the provisions below depending on the applicable federal food program.
To receive reimbursement from GSRP funds, LEA subrecipients using SNP must provide the ISD with the School Food Authority (SFA) prices for breakfast and lunch as specified in the LEA’s annual SNP contract. These prices consider actual food costs as well as the other costs involved in providing the meals. In K-12 the difference between the SFA price and the reimbursement is the cost of free, reduced, and paid meals normally paid by the children. In the case of GSRP, that cost is billed to the GSRP program instead of paid by the children.
Invoices for meal reimbursement must indicate the total number of meals served during the period for each type of meal (breakfast, lunch) in each reimbursement category: free, reduced, paid. Totals for each category are then multiplied by the meal free, reduced, and paid amounts as charged directly to children in K-12. This amount will be billed to GSRP and all documentation kept for auditing.
SNP Adult Meals
The program bears the full cost of adult meals when classroom staff eat school meals with children. Adults may choose to bring their own meal to be eaten away from the children during a staff person’s lunch period. If one or more classroom staff choose to provide their own meals, the program should pay for at least one adult meal to provide sufficient food for adults to sample foods alongside children. Adult meal costs should not exceed the adult meal price established for the district by the LEA.
SNP Snacks
The cost of snacks should be established annually with an ISD-subrecipient agreed upon amount as applicable for each LEA subrecipient and should reflect the reasonable average cost of providing an appropriate nutritious snack that meets food program guidelines. Snack reimbursement for LEA programs not using CACFP is based on the number of snacks provided in a month multiplied by this amount. Adult snacks are added to the cost of providing snack for children.
SNP Other Food Service Costs
Occasionally, materials and other equipment not included in meal costs are required in the course of providing food service specific to GSRP, such as child-sized serving containers and utensils, storage containers, or additional supplies to be kept in the GSRP classroom. In such cases, these costs may be itemized and billed to GSRP. GSRP owns all equipment purchased with grant funds. If meals/snacks must be delivered to GSRP, and delivery constitutes a service over and above the ordinary service provided to K-12 programs factored into the SFA price for the district, a delivery charge may also be itemized and charged beyond the meal cost itself. Most often, “delivery” refers to the need to transport meals/snacks to an off-site location or building that does not otherwise house K-12 classrooms also receiving meal/snack delivery. All GSRP expenses related to the provision of meals and snacks, for all subrecipients and the ISD, are to be classified under the function code 118.
Child and Adult Care Food Program (CACFP)
GSRP funds may only be used to cover the difference between the cost of providing classroom meals and snacks and the reimbursement from the CACFP. Qualifying breakfasts, lunches and snacks served to GSRP children must be claimed for federal reimbursement. The cost of meals and snacks provided through CACFP should be established annually with an ISD-subrecipient agreed upon amount as applicable for each subrecipient and should reflect the reasonable average cost of providing an appropriate nutritious breakfast/lunch/snack that meets food program guidelines. GSRP’s portion can then be documented utilizing the GSRP Monthly Food Service Invoice template found in the resources for this section (or a similar tool) showing the difference between the full cost of providing meals/snacks for a month and the amount of the CACFP reimbursement. GSRP may be charged for the difference remaining after CACFP reimbursement.
The cost of meals/snacks for the GSRP teaching team members, who are expected to join the children in family style meals, cannot be charged to the teaching team and are included in the GSRP portion of the costs for the provision of meals/snacks.
Occasionally, materials and other equipment not included in meal costs are required in the course of providing food service specific to GSRP, such as child-sized serving containers and utensils, storage containers, or additional supplies to be kept in the GSRP classroom. In such cases, these costs may be itemized and billed to GSRP. GSRP owns all equipment purchased with grant funds. All GSRP expenses related to the provision of meals and snacks, for all subrecipients and the ISD, are to be classified under the function code 118.
Reimbursement to CBOs Not Eligible for CACFP
Private for-profit centers that receive compensation under Title XX of the Social Security Act may qualify to take part in CACFP. At least 25% of the enrolled children or 25% of the licensed capacity must be Title XX beneficiaries or eligible for free (Category A) or reduced-price meals (Category B).
A CBO may be deemed not eligible to participate based on the GSRP CACFP Application Decision Tree in the resources for this section. A CBO may also elect to apply for the program, and if found ineligible, will receive a letter from CACFP staff that the center may provide to the ISD documenting the lack of eligibility. In either case, the full cost of providing meals/snacks is then attributed to the GSRP budget. Programs that are ineligible must still have records to justify the charge for providing meals/snacks to children enrolled in GSRP. Eligibility for participation in CACFP should be redetermined any time a significant change to the program structure occurs (e.g., a substantial increase/decrease in enrollment, the addition of a GSRP classroom or before- and after-school-care program) that alters the number of eligible children served meals/snacks.
Records to maintain for ISD Reimbursement include:
- Menus for foods served for all GSRP enrolled children;
- Meal attendance for all meals/snacks served to GSRP enrolled children;
- Center attendance for GSRP participants (may differ from meal attendance);
- Enrollment forms for GSRP children;
- Receipts for monthly food and non-food expenditures;
- Prorated portion of direct labor costs related to preparing and serving meals; and,
- Claim form (Template available in the resources for this section).
The ISD should specify in writing its process for subrecipient reimbursement. All GSRP expenses related to the provision of meals and snacks, for all subrecipients and the ISD, are to be classified under the function code 118.
