CACFP Policy Memo Number 67
DOH-CACFP: Number 67 (06/02)
TO: CACFP Sponsoring Organizations Serving School Age Children
FROM: Jeanne Colegrove, State Director, Child and Adult Care Food Program
SUBJECT: Using National School Lunch Program (NSLP) Income Eligibility Data in CACFP Programs
In an effort to reduce paperwork for families that qualify for more than one government child nutrition program, schools participating in the National School Lunch Program (NSLP) may provide income eligibility information to Child and Adult Care Food Programs serving school age children. CACFP programs serving pre-K and school age children may now request a copy of the Application for Free or Reduced Price Meals from schools participating in NSLP instead of asking parents to complete CACFP's Income Eligibility Application (DOH-3688).
II. State Education Department and School Responsibilities
The New York State Education Department has issued a policy to all School Food Authorities indicating that information from the Application for Free and Reduced Price Meals can be disclosed to government programs. [Disclosure of Free and Reduced Price Data, August 2000]. Since both the National School Lunch Program and CACFP are authorized under the Child Nutrition Act, parental consent is not required for sharing the income eligibility information between these programs, even if the programs are operated by different organizations. For example, if a YMCA operates a program in an elementary school, the elementary school may provide a copy of the Application for Free and Reduced Price Meals to the YMCA for all children enrolled in that program.
- School districts are not required to provide this information to CACFP programs. If they choose to do so, there must be a written agreement between the School Food Authority and the CACFP program receiving the information. The State Education Department provided a prototype agreement to School Food Authorities in their August 2000 policy "Disclosure of Free and Reduced Price Data".
- The program receiving the data certifies in the agreement that it is currently approved to participate in CACFP and that the data will be used in the administration of the program only. They also detail who will receive the data, how the confidentiality of the data will be insured, and how the program will use the information received.
- The School Food Authority provides a copy of the agreement to the school, authorizing the release of the Application for Free and Reduced Price Meals to CACFP-participating programs.
III. CACFP Program Responsibilities
- The CACFP Program must receive a copy of the actual Application for Free or Reduced Price Meals.
- The CACFP program must evaluate the information on the Application for Free or Reduced Price Meals in the same manner they would evaluate the CACFP Income Eligibility Application.
- For homes, the information could be used to qualify a provider's own children or an enrolled participant for Tier 1 if they are located in a Tier 2 area.
- For centers, the information would be used to determine the reimbursement rate as free, reduced, or paid.
- The CACFP program assumes financial and legal responsibility for using the forms from the School Food Authority.
- The CACFP program ensures that only persons directly connected with the administration or enforcement of CACFP, and whose job responsibilities require the use of income eligibility information, will have access to this income information. The CACFP program assumes responsibility for any penalty for misuse of this information as if they had collected the information directly from the family.
The availability of Applications for Free and Reduced Price Meals from schools will assist participating CACFP centers and providers serving pre-K and school age children in reducing the paperwork needed to determine reimbursement rates while still complying with CACFP regulations. Implementation of this policy also reduces the burden of program participation on enrolled families, in that one Application for Free and Reduced Price Meals can be used by more than one government nutrition program. As always, any family that does not submit an application must be included in the paid reimbursement rate.
If you have any questions about this information, please contact CACFP at 1-800-942-3858 or 518-402-7400.