The updated United States Department of Agriculture (USDA) Food and Nutritional Service (FNS) policy SP 46-2016: Unpaid Meal Charges - Local Meal Charge Policies requires all school food authorities (SFA) operating National School Lunch Programs and/or School Breakfast Programs must have in place a written policy to address situations where children participating at the reduced price or paid rate do not have money to cover the cost of a meal at the time of the meal service. The policy must be clearly communicated to families and all school or district-level staff members responsible for policy enforcement.

In addition, in accordance with Senate Bill 423 and USDA, the following guidelines shall be in place:

• Students eligible for free or reduced-price meals during the previous school year, will continue to receive the same benefits until a new applications is processed or up until thirty days of the new school year;

• Students shall not be denied a meal within seven days after the meal account reaches a zero balance;

• Students who are unable to pay for their meal at the time of the meal service shall be allowed to charge a meal for the first twenty one days of school;

• Children who qualify for free meals may never be denied a meal, even if they have accrued a negative balance from other purchases in the cafeteria, and

• Students submitting new applications and approved for free or reduced-price meals will receive retroactive credit to clear charges based on application submission date but not the month prior. Applications shall be date stamped with the application submission date.

Schools shall prohibit the charging of àla carte or extra items by any child with a negative balance, regardless of the child’s eligibility status.

Policy Communications

Clearly communicating meal charge policies prevents confusion for families and promotes effective financial management of the school meal programs. Schools must ensure the policy is provided in writing to all families at the start of each school year and to families transferring to the school during the school year. Schools are encouraged to use multiple methods to disseminate the policy on an ongoing basis throughout the school year. For example, schools may:

• Include a letter to households explaining the meal charge policy when sending out “back to-school”packets with student registration materials;

• Post the policy on school or district websites;

• Include the policy in print versions of student handbooks if provided to families annually;

• Share the policy with the family the first time the policy is applied to a specific child;

• Mention the charge policy on reminder calls and include the policy in written notices of low or negative account balances; and

• Include the written policy when using existing notification methods to inform households about applying for free or reduced price meals, such as distributing household applications at the start of the school year.

Schools also must provide the unpaid meal charge policy to all school or district-level staff responsible for policy enforcement. This includes school staff responsible for collecting payment for meals at the point of service, staff involved in notifying families of low or negative balances, and staff involved in enforcing any other aspects of the policy. School social workers, school nurses, liaisons for homeless, migrant, and/or runaway students, and other staff members assisting children in need also should be informed of the policy.

Payment Reminders

Proactively remind families of their child’s low account balance. When sending payment reminders, schools are encouraged to communicate in a variety of ways to ensure the reminder reaches all families:

· Written –SFA may send discreet payment notices directly to a family’s email account. General payment reminders for all families may be included in the school newsletter, on the lunch menu, or with student “take-home folders;”

· Verbal - School officials may call families on the telephone to remind them to refill their child’s account. Schools may choose to communicate payment reminders using a “robo-call”system to contact families on a weekly or bi-weekly basis, as needed;

· Automated –SFA using an online payment system may send automated alerts when a child’s balance reaches a low level, such as $5 or $10. With household authorization, schools may also send automated text message alerts;

· In Person - A trusted school official may reach out to families with unpaid meal debt in person. Meal charges may be a sign of other challenges facing a family. Having a trusted school official assess the situation firsthand can help the school determine the appropriate response for each individual family; and

· With Other Payment Reminders - Schools may include all outstanding payments, including fees for books, school uniforms, and unpaid meal charges, when sending notices to families. This streamlines communications and helps families track their payments.

In addition to the requirement to keep free and reduced price eligibility status confidential, keep low or negative account balances confidential, staff should not notify children of their meal charge debt in front of other students. Whenever possible, FNS encourages schools to communicate low accounts balances with the family privately ahead of time, or to notify children of their low or negative balance before they get to the serving line. In addition, schools must ensure that rosters, computer screens, or other equipment used at the point of service cannot be viewed by anyone who does not need access to the information, especially other children. The information should be masked or coded to prevent children or other visitors from viewing any student’s account balance or status.

Unpaid Meal Charges and Bad Debt

Schools must make reasonable efforts to collect meal charges classified as delinquent debt.

When officials determine delinquent debt is uncollectable and no further collection efforts will be made, the debt must be reclassified as “bad debt.”Bad debt resulting from unpaid meal charges may not be absorbed by School Food Services Branch (SFSB) and must instead be restored using non-Federal funds. These funds may come from the school district’s general fund, special funding from State or local governments, and other non-Federal sources.

The following records should be maintained to document the appropriate establishment and handling of bad debt:

· Evidence of efforts to collect unpaid meal charges in accordance with the unpaid meal charge policy;

· Evidence the collection efforts fell within the time frame and methods established by the meal charge policy;

· Financial documentation showing when the unpaid meal charge(s) became an operating loss; and

· Evidence any funds written off as bad debt were restored to SFSB using non Federal sources.