SP 15-2018, CACFP 12-2018, SFSP 05 ... - NH Dept of Education



January 10, 2019Waiver Request to continue SP 10-2017, SFSP 06-2017 (OVS)State agency submitting waiver request and responsible State agency staff contact information: New Hampshire Department of Education Cheri White101Pleasant StreetConcord, NH 03301603-271-3860Cheri.white@doe. Region: NortheastEligible service providers participating in waiver and affirmation that they are in good standing: The New Hampshire Department of Education, Bureau of Student Wellness, Office of Nutrition Programs and Services is requesting a state – wide waiver to allow the use of Offer Vs Serve by non-school food authorities (non-SFAs) and by School Food Authorities (SFAs) utilizing the Summer Food Service Program meal pattern. Please note that this waiver has been implemented in past years and we are simply asking for the same flexibility used under this national waiver request. NH has allowed OVS due to a number of sites that had significant levels of food waste without OVS. During Summer 2019, New Hampshire had 17 non-school sites offering meals with Offer Vs. Serve and 12 school sites offering meals with Offer Vs. Serve (OVS). These sites are dispersed evenly over NH and include SFSP in schools, institutions and camps in the state. It is affirmed that all Offer Vs. Serve sites that claimed were in good standing for Summer 2019.Description of the challenge the State agency is seeking to solve, the goal of the waiver to improve services under the Program, and the expected outcomes if the waiver is granted. [Section 12(l)(2)(A)(iii) and 12(l)(2)(A)(iv) of the NSLA]: Offer versus Serve (OVS) allows all Summer Food Service Program (SFSP) sponsors to better manage food cost and reduce food waste as they continually work on increasing acceptability of summer meals by participants. It is noted that regulations authorize the OVS option for school food authority sponsors under section 13(f)(6) of the NSLA, 42 USC 1761(f)(6), and 7 CFR 225.16(f)(1)(ii). Therefore, schools continue to be able to use OVS regardless of waiver approval or disapproval. However, this regulation requires that the National School Lunch meal pattern be used if a school would like to use OVS in the SFSP. Many schools would like to utilize the SFSP meal pattern instead and therefore require a waiver to do so. In previous summers, all SFA Sponsors used the SFSP meal pattern. New Hampshire has trained all SFSP sponsors on the proper way to implement OVS. in New Hampshire.Also, NH would like to extend the OVS flexibility to non-SFA sponsors as it has in previous years. Specific Program requirements to be waived (include statutory and regulatory citations). [Section 12(l)(2)(A)(i) of the NSLA]: Section 13(f)(6) of the NSLA, 42 USC 1761(f)(6), and 7 CF 225.16(f)(1)(II). Memo Code SFSP 01-2019. Detailed description of alternative procedures and anticipated impact on Program operations, including technology, State systems, and monitoring: Rescinding this allowance would mean that schools would need to utilize the National School Lunch meal pattern which is not desired by NH school SFSP sponsors. Summer staff in schools are not always the same people that prepare meals during the school year; therefore retraining of staff will need to occur. The past flexibility from USDA has been in place for quite a few years and food service staff is used to the SFSP meal pattern. Training for non-school sponsors who already implement OVS will also lead to confusion and a decrease in meal pattern compliance. Sponsor training and monitoring of the sites will need to be changed if this allowance is rescinded. During the mandatory SFSP annual training, NH has historically included OVS in meal pattern training. If the waiver is allowed, PowerPoint slides and information given to sponsors will continue to include OVS in the SFSP meal pattern in order to ensure that all sponsors comply with the OVS requirements. Description of any steps the State has taken to address regulatory barriers at the State level. [Section 12(l)(2)(A)(ii) of the NSLA]: New Hampshire has allowed OVS for all SFSP sponsors since this flexibility was established via USDA policy memo in 2011. NH’s annual training for sponsors has included information on OVS and there are 28 sites that utilized this option in 2019 as a way to decrease waste and therefore food costs, which helped to ensure viability among sponsoring organizations. Compliance to OVS is monitored during summer administrative reviews. Anticipated challenges State or eligible service providers may face with the waiver implementation: This waiver has been in place due to past approved flexibility therefore sponsors and sites have OVS in place. It would be challenging to remove it. If removed, it will likely mean that sites would need retraining and sponsors and the State Agency would see an increase in meal pattern non-compliance issues. Description of how the waiver will not increase the overall cost of the Program to the Federal Government. If there are anticipated increases, confirm that the costs will be paid from non-Federal funds. [Section 12(l)(1)(A)(iii) of the NSLA]: If the waiver were to be granted, there would be no increase in the overall cost of the Program to the Federal Government. New Hampshire would continue to do the work in the same way it has since USDA allowed the flexibility in 2011. The contrary will likely occur due to the sponsor savings from less food waste. Anticipated waiver implementation date and time period: Summer 2020 (June through August) and future years if extensions are allowed. Proposed monitoring and review procedures: Monitoring and review procedures would not change and would be completed per regulatory requirements. New Hampshire will offer training and technical assistance regarding the OVS ruling accordingly. Proposed reporting requirements (include type of data and due date(s) to FNS): We can submit our Administrative Review findings if necessary and documentation of OVS training. Reporting would not change and would be completed per regulatory requirements. However, NH will report on the number of sponsors and sites that utilized the waiver flexibility by November 30, 2020. Link to or a copy of the public notice informing the public about the proposed waiver [Section 12(l)(1)(A)(ii) of the NSLA]: Please scroll to the bottom to find the waiver request.?Signature and title of requesting official: _____ Cheri F. White, MS, SNS_______________________________Title: AdministratorRequesting official’s email address for transmission of response: Cheri.white@doe. Phone: 603-271-3860NH Dept. of Education101 Pleasant St.Concord, NH 03301-60960463550TO BE COMPLETED BY FNS REGIONAL OFFICE:FNS Regional Offices are requested to ensure the questions have been adequately addressed by the State agency and formulate an opinion and justification for a response to the waiver request based on their knowledge, experience and work with the State.Date request was received at Regional Office: February 22, 2019X Check this box to confirm that the State agency has provided public notice in accordance with Section 12(l)(1)(A)(ii) of the NSLARegional Office Analysis and Recommendations: NERO has reviewed the New Hampshire Department of Education’s request to waive the restriction on the use of offer-vs-serve by non-School Food Authorities and by School Food Authorities who follow the SFSP meal pattern. The NHDOE has made use of this flexibility in past summers and denial would impose a serious burden on the State Agency and local sponsors. We believe this request adequately addresses the waiver requirements laid forth in Section 12(l) of the National School Lunch Act. NERO considers the State Agency to be in good standing. ................
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