Beginning in summer 2024, the United States Department of Agriculture (“USDA”) is implementing a new three-pronged approach to combating food insecurity over the summer in school-aged children. Around 29 million children in the United States participate in the National School Lunch Program (“NSLP”), and around 15 million children participate in the School Breakfast Program (“SBP”). These two programs, operated through USDA’s Food and Nutrition Service (“FNS”), provide free or reduced-price meals to eligible children at participating schools. NSLP and SBP have been effective tools to help fight food insecurity for eligible children. However, the programs only operate during the school year, which has left a gap for certain food insecure children during the summer months. Starting in 2024, USDA will be implementing two new permanent nutrition programs specifically aimed at helping food insecure children during the summer – Summer EBT and Non-congregate meal service.
Background on Summer Nutrition Programs
Historically, there were two programs created through the Richard B. Russell National School Lunch Act that provided meals to children at risk of food insecurity during the summer months – the Summer Food Service Program (“SFSP”) and the Seamless Summer Option (“SSO”). Additionally, during the summer NSLP and SBP are available to schools hosting an academic summer school but only to serve meals to students enrolled in the academic program. Both SFSP and SSO are federally funded but administered through State agencies, and both offer free meals at locations like schools, camps, churches, community centers, parks, or other public sites. Though these programs are similar in purpose, there are a few differences between the two.
Summer Food Service Program
SFSP runs through approved sponsors providing free, nutritious meals and snacks at a central site to children and teens in low-income areas. The approved sponsors include school districts, local government agencies, camps, or private nonprofit organizations. Through State agencies, USDA will reimburse approved sponsors for the provided meals and snacks. Sites occur in a variety of settings including schools, parks, community centers, libraries, and churches. Meal sites can be “open” to all children in the community if they are located in an area where at least 50% of the children are eligible for free or reduced-price school meals or “closed” and serving only enrolled children if at least 50% of enrolled children are eligible for free or reduced-price school meals. Both open and closed enrolled sites serve free meals to all children. Residentials and day camps can participate in SFSP without showing a certain percentage of eligible children. Additionally, migrant sites may participate and operate as an open site if they are certified by a migrant organization or sponsor and demonstrate they predominantly serve migrant children. Children who come to eat a SFSP provided meal must remain on site to consume their food.
Seamless Summer Option
In contrast to SFSP, SSO is only administered locally by school food authorities (SFAs) who are currently administering the NSLP or SBP during the regular school year. SSO allows administering SFAs to operate under certain NSLP and SBP standards and processes during the summer. Like SFSP, SSO can be operated at a variety of meal sites, and children must consume the provided meal onsite. For a more detailed comparison of the traditional summer feeding programs, click here for USDA chart “Comparison of Programs SFSP/NSLP/Seamless Option.”
2024 updates to summer nutrition programs
In December 2022, Congress passed the Consolidated Appropriations Act, 2023. This bill updated the summer nutrition programs by allowing non-congregate meal service and creating a permanent Summer EBT program. Traditionally, the SFSP and SSO programs required children participating to remain at the meal service site while they consume their meal or snack. The updates now allow children in rural areas to take their meals off-site for consumption. Additionally, the update established the permanent, nationwide Summer Electronic Benefits Transfer for Children Program (Summer EBT). In December 2023, USDA published an interim final rule amending the regulations for SFSP and SSO to include non-congregate meals and establishing regulations for the administration of the Summer EBT Program. USDA has branded the new summer nutrition opportunities as a three-pronged approach that “can now reach more kids than ever before.” The three nutrition opportunities are classified as: Summer EBT, Group Meal Service, and Non-Congregate Meal Service.
Group Meal Service
“Group meal service” is the term USDA has given to the traditional summer meal service it provides to eligible children – SFSP and SSO. These programs will continue to provide meals at sites locally administered by SFAs or sponsors where children will be required to consume the meal onsite under supervision.
Non-Congregate Meal Service
The next updated nutrition opportunity tackles one of the greatest challenges with SFSP and SSO – the “congregate meal service model.” This model of service required eligible children participating in the programs to consume the provided meals at the site under program supervision. This created a barrier for children in rural areas where there was no congregate meal serve available. The update to the Summer Nutrition plans creates a “non-congregate meal service” opportunity for eligible children in rural areas. Non-congregate refers to a food service where meals are provided to children for off-site consumption. The interim final rule updates the definition of rural to include:
- Any area in a county which is not a part of a Metropolitan Statistical Area based on the Office of Management and Budget’s Delineations of Metropolitan Statistical Areas;
- Any area in a county classified as a non-metropolitan area based on USDA Economic Research Service’s Rural-Urban Continuum Codes and Urban Influence Codes;
- Any census tract classified as a non-metropolitan area based on USDA Economic Research Service’s Rural-Urban Commuting Area codes;
- Any area of a Metropolitan Statistical Area which is not part of a Census Bureau-defined urban area;
- Any area of a State which is not part of an urban area as determined by the Secretary;
- Any subsequent substitution or update of the aforementioned classification schemes that Federal governing bodies create; or
- Any “pocket” within a Metropolitan Statistical Area which, at the option of the State agency and with FNSRO approval, is determined to be rural in character based on other data sources.
Sponsors that are approved to operate non-congregate meal service sites may choose between three options for distributing meals to eligible children. First, sponsors could choose to distribute the maximum number of reimbursable meals allowed over a 10-calendar day period. Second, sponsors could choose to distribute meals to a parent or guardian of eligible children. Last, sponsors could distribute bulk meal components, providing food items in bulk that meet the minimum amounts of each food component for a reimbursable breakfast, lunch, supper, or snack.
Summer EBT
The next updated USDA opportunity for child nutrition is the Summer EBT Program. Summer EBT is a program that provides electronic benefits to low-income families with school-aged children for buying groceries during the summer months. Similar to the Supplemental Nutrition Assistance Program (SNAP), participants will have an Electronic Benefit Transfer (EBT) card with funds loaded electronically to use for purchasing groceries. Though Summer EBT is launching as a permanent program in summer 2024, USDA operated a similar program as a demonstration project from summer 2011 to 2023 in certain states and tribal organizations. Likewise, from spring 2020 through summer 2023 the Pandemic Electronic Benefit Transfer program operated in many states and territories and provided similar grocery-buying benefits to eligible households. The permanent Summer EBT program beginning in summer 2024 will allow participating states, territories, and Indian Tribal Organizations (ITO) to provide benefits to eligible households for purchasing food from authorized retailers during the summer months. Summer EBT is not a program meant to replace participation in SFSP or SSO but aims to work with all USDA nutrition programs to provide children with food in the summer.
Under Summer EBT eligible households will be given $40 per month for each eligible child. A child can become eligible for Summer EBT either automatically or through an application. Automatic eligibility is primarily triggered for children who are already eligible for free or reduced-price meals through NSLP and SBP. This includes both children who have been certified eligible through a school NSLP/SBP application, and children who are categorically eligible. Categorically eligible refers to children in households participating in SNAP, Temporary Assistance for Needy Families, and the Food Distribution Program on Indian Reservations, and children who are homeless, migrant, or in foster care. Additionally, automatic eligibility can occur for children attending special provision schools, children enrolled in schools not participating in NSLP or SBP, and children who are homeschooled or attending virtual school if they are categorically eligible. Children who are not automatically eligible are still able to receive Summer EBT if they qualify through an application process which participating States, territories, and ITOs are required to create.
Summer EBT participants in a State-administered program are able to use their benefits at retail stores approved for participation in SNAP to purchase SNAP-eligible food, as defined by the Food and Nutrition Act. Children participating in an ITO-administered program can use their benefits to purchase supplemental foods at any Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)-authorized retailer. Determined by the administering ITO, supplemental foods are foods that nutritional research has found to contain nutrients often lacking in the diets of children. Additionally, participants in a territory-administered program that operates a Nutrition Assistance Program (NAP) will be able to purchase NAP-authorized foods at NAP-authorized retailers.
States, territories, and certain tribes can choose to participate or not in Summer EBT. Though the cost of benefits are fully funded by the federal government, USDA will only pay up to 50% of the administrative costs associated with running the program, and the administering state, territory, or ITO agency must pay the other half. 36 states, 5 territories, and 3 ITOs have announced their intent to launch the program for summer 2024. The remaining states, primarily in the south, have chosen to opt out. Reasons for doing so have included concerns about administrative costs, technical challenges, and the adequacy of other summer nutrition programs. States will have the opportunity to participate in future years.
Conclusion
Millions of school-aged children are fed every school year through USDA’s NSLP and SBP. Traditionally, USDA used both SFSP and SSO to continue to feed those children during the summer months. By establishing non-congregate meal service and Summer EBT, USDA is expanding opportunities to feed eligible children during the summertime.
Click here to view NALC Reading Room “Nutrition Programs.”
Click here to view Food Research & Action Center’s “A Guide to Summer EBT Eligibility”
Click here to view USDA Factsheet “Summer Food Service Program.”
Click here to view USDA Factsheet “The National School Lunch Program”
Click here to view Congressional Research Service Report “School Meals and Other Child Nutrition Programs: Background and Funding.”
Click here to view Congressional Research Service Report “Summer Food for Childre: An Overview of Federal Aid.”