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Food and Nutrition Programs

School Meal Access for Early College Learners

To:Sponsors of the National School Lunch Program
From:Robert Leshin, Director, Office for Food and Nutrition Programs
Date:January 12, 2023

Providing supports to accelerate student learning is a priority for the Department of Elementary and Secondary Education (DESE). An important initiative for this work is expanding Early College programs. Early College learners are dual enrolled in both school districts and designated state and community colleges and many early college learners spend most, if not all their time, on college campuses. The program has grown from approximately 1,000 students in 2019 to over 5,000 students in current designated Early College programs across the state and an anticipated 7,000 participants by SY 2023-2024. This memorandum provides guidance on how dual enrolled students can retain access to school meals and designated state and community colleges can receive federal funds for serving reimbursable meals to these students.

Designated Early College Programs

A list of all designated Early College Programs including all partner school districts and state and community colleges can be found at Early College Designated Programs webpage.

State Community Colleges Serving Reimbursable Meals

The United States Department of Agriculture (USDA) has recently clarified that designated state and community colleges hosting dual enrolled Early College learners can operate as a site under a school district sponsoring the USDA National School Lunch Program (NSLP). As an approved NSLP site, state and community colleges preparing and serving breakfast, lunch and/or snack can receive USDA reimbursement from the Early College learner's school district for each reimbursable meal served on campus to the Early College learner.

The school district sponsoring the NSLP where the Early College learner is dual enrolled is responsible for oversight of a state or community college NSLP site as the site will be a part of its NSLP agreement. Oversight includes ensuring all meals are compliant with NSLP meal patterns and an accurate meal counting and claiming system is in place. The school district will be responsible for receiving correct meal counts from the state or community college site, claiming these meals through their monthly NSLP claims, and receiving reimbursement of USDA funds from DESE. An operational and financial agreement between the school district and state or community college should be created to clarify the roles and responsibilities of all parties.

Factors to Consider for Providing NSLP Meals to Early College Learners

The decision to provide NSLP reimbursable meals to Early College learners should be jointly made by both the school district and the partner state or community college. The state or community college must have the capacity and capability to prepare and serve NSLP reimbursable meals, conduct proper meal counting and adhere to other NSLP site level requirements. The school district will have the ultimate responsibility for oversight of the site level activities and therefore will need to have the capacity and capability to ensure campus dining adheres to all NSLP site level requirements and provide required site level monitoring for meals served to Early College learners. Monitoring may include but is not limited to:

  • Ensuring duplicate meals are not served to dual enrolled Early College learners and claimed for reimbursement at the NSLP sponsoring school district and designated state or community college, and
  • Only district enrolled student meals are counted and claimed for reimbursement.

Early College Learners from Multiple School Districts at a State or Community College

Currently, three (3) state and community colleges host students from multiple school districts. Per NSLP regulations, each school district is responsible for claiming meals for their enrolled students. A state or community college with dual enrolled Early College learners from multiple school districts must enter into separate arrangements with each school district in order to receive NSLP reimbursement for offering school meals to Early College learners.

A school district that is able and willing to take on the administrative and oversight responsibilities for serving, counting, and claiming reimbursable meals for all high school students attending a specific state or community college's Early College program as part of their own NSLP agreement can add these students to their NSLP agreement. This would simplify the process for the state and community college. If this option is chosen, agreements must be put in place between all the participating school districts clarifying the roles and responsibilities of all parties.

Universal Free School Meals and Student Eligibility

Per the Fiscal Year 2023 (FY23) State Budget, school meals (breakfast and lunch) are universally free for all K-12 students enrolled in school districts sponsoring the NSLP through June 30, 2022. It is uncertain at this time whether universal free meals for all students statewide will continue past this school year. Early College learners dual enrolled at an approved Community Eligibility Provision (CEP) or Provision 2 school (Special Provision schools) are entitled to free breakfast and lunch through those USDA programs separate from state legislation. Students not enrolled at a Special Provision school are still entitled to free meals per the FY23 State Budget but must have meals counted and claimed by individual student eligibility. If the state sponsored universal free school meals is not extended past June 30, 2022, and a dual enrolled Early College learner is not attending an approved Special Provision school, additional counting and cash collection systems may need to be implemented.

If you have questions about serving meals to dual enrolled Early College learners including setting up a college site in the DESE Security Portal, please contact your assigned DESE School Nutrition Program Consultant.

This institution is an equal opportunity provider.

Last Updated: January 12, 2023

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