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Summer Meals: Actions Needed to Improve Participation Estimates and Address Program Challenges

GAO-18-369 Published: May 31, 2018. Publicly Released: Jul 02, 2018.
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Highlights

What GAO Found

Nationwide, the total number of meals served to children in low-income areas through the Summer Food Service Program (SFSP) increased from 113 to 149 million (about 32 percent) from fiscal year 2007 through 2016. The U.S. Department of Agriculture (USDA) directs states to use the number of meals served, along with other data, to estimate the number of children participating in the SFSP. However, participation estimates have been calculated inconsistently from state to state and year to year. In 2017, USDA took steps to improve the consistency of participation estimates, noting they are critical for informing program implementation and strategic planning. However, GAO determined that the method USDA directs states to use will continue to provide unreliable estimates of participation, hindering USDA's ability to use them for these purposes.

Children eating breakfast and playing ball at summer meal sites

Other federal and nonfederal programs help feed low-income children over the summer to some extent, according to states GAO surveyed and SFSP providers and others GAO interviewed. For example, in July 2016, USDA data indicate about 26 million meals were served through a separate federal program that allows school meal providers to serve summer meals. Some children also received summer meals through nonfederal programs operated by faith-based organizations and foodbanks, though GAO's state survey and interviews with providers and national organizations indicate the reach of such efforts is limited.

States and SFSP providers reported challenges with meal sites, participation, and program administration; USDA has taken steps to address these areas. Specifically, in GAO's survey, a majority of states reported challenges with availability and awareness of meal sites, as well as limited program participation and administrative capacity. National, state, and local officials have taken steps to address these issues, such as increasing outreach and offering activities to attract participation. In addition, 17 states in GAO's survey and providers in the states GAO visited reported a challenge with ensuring meal sites are in safe locations. To address this safety issue, USDA has granted some states and sponsors flexibility from the requirement that children consume meals on-site. However, USDA has not broadly communicated the circumstances it considers when granting this flexibility. Further, some states and sponsors that have requested this flexibility reported difficulty obtaining data to show these circumstances exist, hampering their ability to ensure safe meal delivery.

Why GAO Did This Study

The SFSP, a federal nutrition assistance program, is intended to provide food to children in low-income areas during periods when area schools are closed for vacation. In the last decade, federal expenditures for SFSP have increased as the program has expanded, according to USDA data. GAO was asked to review the SFSP.

This report examines (1) what is known about SFSP participation, (2) other programs that help feed low-income children over the summer, and (3) challenges, if any, in providing summer meals to children and the extent to which USDA provides assistance to address these challenges. GAO reviewed relevant federal laws, regulations, and guidance; analyzed USDA's SFSP data for fiscal years 2007 through 2016; surveyed state agencies responsible for administering the SFSP in 50 states and the District of Columbia; visited a nongeneralizable group of 3 states and 30 meal sites, selected based on Census data on child poverty rates and urban and rural locations; analyzed meal site data from the 3 states; and interviewed USDA, state and national organization officials, and SFSP providers, including sponsors and site operators.

Recommendations

GAO is making four recommendations, including that USDA improve estimates of children's participation in SFSP and communicate the circumstances it considers when granting flexibilities to ensure safe meal delivery. USDA generally agreed with GAO's recommendations.

Recommendations for Executive Action

Agency Affected Sort descending Recommendation Status
Food and Nutrition Service The Administrator of FNS should disseminate information about existing flexibilities available to state agencies to streamline administrative requirements for sponsors participating in the SFSP and other child nutrition programs to help lessen the administrative burden. For example, FNS could re-distribute existing guidance to state agencies that explains available flexibilities and encourage information sharing. (Recommendation 4)
Closed – Implemented
The Department of Agriculture's Food and Nutrition Service (FNS) has addressed this recommendation. In March 2022, the final rule regarding, "Streamlining Program Requirements and Improving Integrity in the Summer Food Service Program (SFSP)", 85 FR 4064, is on the spring regulatory agenda and in clearance with USDA with publication targeted for the summer. The rule amends the SFSP regulations to strengthen program integrity by codifying in regulations the changes that have been tested through policy guidance and by streamlining requirements among Child Nutrition Programs. Further, FNS stated that the rulemaking aims to clarify, simplify, and streamline program administration in order to facilitate compliance with program requirements. The rule disseminates information about existing flexibilities available to state agencies to streamline administrative requirements for sponsors participating in the SFSP and other child nutrition programs.
Food and Nutrition Service The Administrator of the Food and Nutrition Service (FNS) should improve its estimate of children's participation in the SFSP by focusing on addressing, at a minimum, data reliability issues caused by variations in the number of operating days of meal sites and in the months in which states see the greatest number of meals served. (Recommendation 1)
Open
In August 2023, the Department of Agriculture's Food and Nutrition Service (FNS) acknowledged that due to the way in which SFSP average daily attendance (ADA) is collected and aggregated at the State level, variation in operating days is not fully captured in the current measures. In addition, FNS stated that use of a single month may have the unintended effect of limiting the agency's ability to assess variations in days of operation and months of highest participation due to variation in the end of the school year across states. In response to the Consolidated Appropriations Act 2023, which authorized a permanent, non-congregate meal service through SFSP for rural areas with no congregate meal service, the agency stated its plans to modify the SFSP reporting form to reflect these changes to the SFSP. The agency stated that modifications will include updates to its measure of the ADA that should enable the agency to increase the accuracy of the estimates for children's participation in the SFSP. Additionally, FNS stated that, as part of the Interim Final Regulations scheduled for publication in late December 2023, the agency plans to publish an Agency Information Collection, update instructions for calculating ADA, and update its internal reporting system. We continue to maintain that it is important for FNS to improve its estimate of children's participation in the SFSP. We will continue to monitor the agency's progress with modifying its metrics to improve its estimate of children's participation in the SFSP.
Food and Nutrition Service The Administrator of FNS should communicate to all SFSP stakeholders the circumstances it considers in approving requests for flexibility with respect to the requirement that children consume SFSP meals on-site in areas that have experienced crime and violence, taking into account the feasibility of accessing data needed for approval, to ensure safe delivery of meals to children. (Recommendation 2)
Closed – Not Implemented
In May 2022, the Department of Agriculture's Food and Nutrition Service (FNS) stated that it provided detailed information on the SFSP waiver process, including a section on its updated waiver template and helpful tips in its May 2018 webinar. However, the May 2018 guidance did not directly acknowledge that FNS included areas with crime and violence as exceptional circumstances for purposes of the demonstration, and neither the guidance nor the webinar provided new information about the circumstances FNS considered when granting the flexibility for such areas. FNS also stated that since 2020, the COVID-19 pandemic has fundamentally altered SFSP operations and, in response, the agency has allowed non-congregate summer meal service through its approval of nationwide and state waivers. FNS stated that it has discontinued it Demonstration Project for Non-congregate Feeding given the significant and ongoing changes in SFSP as a result of the COVID-19 pandemic and the availability of these waivers. FNS also stated, at this time, that it would be inappropriate and confusing to program operators to provide specific guidance on the circumstances the agency would consider in approving requests for non-congregate meal service in response to crime activity near sites. GAO recognizes that the COVID-19 pandemic had a significant impact on SFSP operations. and with the changes in operations and discontinuation of its project, this recommendation is no longer applicable.
Food and Nutrition Service The Administrator of FNS should evaluate and annually report to Congress, as required by statute, on its use of waivers and demonstration projects to grant states and sponsors flexibility with respect to the requirement that children consume SFSP meals on-site in areas experiencing crime or violence, to improve its understanding of the use and impact of granting these flexibilities on meeting program goals. (Recommendation 3)
Closed – Implemented
In January 2020, FNS transmitted a report to Congress entitled "Status of Demonstration Projects Authorized Through the Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2010, P.L. 111-80." This report discussed the status of each demonstration project carried out under 749(g) of P.L. 111-80 in the previous fiscal year, which includes the Demonstration Projects for non-congregate feeding for outdoor summer meal sites experiencing excessive heat. The report discussed requests that were approved to serve non-congregate meals to children in exceptional circumstances related to crime from 2013-2017, as well as the type of crime activity that eligible sites experienced. FNS stated that although 14 requests were approved during this time period, states reported that no sponsors used the demonstration authority to serve non-congregate meals in response to crime activity because sponsors lacked the capacity to implement the demonstration effectively. By submitting this report to Congress in 2020 on its use and impact of demonstration projects granting states and sponsors flexibility with respect to children consuming SFSP meals on-site in areas experiencing crime of violence, FNS has addressed this recommendation.

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Topics

Child nutritionChildrenFood programs for childrenFederal assistance programsInternal controlsLow-income childrenNutrition assistanceNutrition servicesParticipation ratesProgram managementProgram implementationStrategic planningPublic health emergencies