Second Harvest of South Georgia has requested the following waiver for its Summer Food Service Program through USDA. Please contact Winona Green at WGreen@FeedingSGA.org with questions.
February 5, 2019
2 Martin Luther King, Jr. Drive, SE
Suite 754, East Tower
Atlanta, GA 30334
RE: Child Nutrition Program Waiver Request – SFSP First Week Monitoring
Dear Ms. Adams:
As an administrative sponsor for the Summer Food Service Program in South Georgia, we respectfully request continuance of the recently rescinded waiver pertaining to monitorings. As requested in USDA Policy Memorandum CACFP 12-2018/SFSP 05-2018, below is a detailed explanation of the need for the waiver.
• Description of the challenge that the waiver would solve, the goal of the waiver to improve services under the program, and the expected outcomes if the waiver is granted:
Recently, USDA rescinded a previous waiver which waived the first week site visit requirement for returning sites that operated successfully during the previous summer and had no serious deficiency findings. (SFSP Memorandum 12-2011: Waiver of Site Monitoring Requirements in the Summer Food Service Program, April 5, 2011)
CHALLENGE: The rescission of this waiver creates a hardship for rural area sponsors like Second Harvest of South Georgia. We anticipate that this will create a barrier to accessible meals for children in need. It will not only prevent us from expanding the program in an area with among the highest rates of child food insecurity in the nation, but it will cause a decrease in the number of sites (and therefore children) that we are able to serve.
We serve a 30 county area that spans nearly 13,000 square miles. Last summer, we operated nearly 20 sites and are looking to increase that number this upcoming summer. In a rural area like ours, our sites can be located great distances from one another. The drive time from our branch to a site can be upwards of 1 ½ hours one way. Scheduling first week monitorings for that many sites while accommodating approved meal service times and driving time requires additional costs for staffing, vehicle rentals, fuel, etc. Our programmatic costs go up drastically while our reimbursement rates will remain the same.
This regulation may be feasible for sponsors in urban areas where all sites are in close proximity, but it puts an disproportionate, and frankly discriminatory, burden on rural sponsors. It creates an disincentive to growing the programs in rural areas.
GOAL: The goal of continuing this waiver is to decrease the administrative burden on rural sites, thereby encouraging rural sponsors to add additional sites.
OUTCOMES: By continuing the first week site visit waiver for returning sites, rural area sponsors like Second Harvest of South Georgia will be more likely to increase the reach of their programs and, in turn, feed more children in need in areas where SFSP sites are few and far between. In Southwest Georgia where the rates of child food insecurity are among the highest in the nation, waiving the requirement for first week site visits will make it possible for us to grow our program.
• Specific program requirements to be waived:
Regulatory Citation: 7 CFR 225.15 (d)
(2) Sponsors shall visit each of their sites at least once during the first week of operation under the Program and shall promptly take such actions as are necessary to correct any deficiencies.
(3) Sponsors shall review food service operations at each site at least once during the first four weeks of Program operations, and thereafter shall maintain a reasonable level of site monitoring. Sponsors shall complete a monitoring form developed by the State agency during the conduct of these reviews.
• Detailed description of alternate procedures and anticipated impact on program operations:
If granted a continuance of the rescinded waiver, Second Harvest of South Georgia (and other sponsors) will conduct site visits to returning sites with no serious deficiency findings within the first four weeks of operation.
• Description of any steps the State has taken to address regulatory barriers at the State level.
To be determined by DECAL
• Anticipated challenges State or eligible service providers may face with waiver implementation.
We do not anticipate any challenges to implementing the waiver since it was in place until recently.
• Description of how the waiver will not increase the overall cost of the program to the federal government.
The waiver will not increase program costs to the federal government. The waiver has been in place until recently. Without the waiver, sponsors like Second Harvest of South Georgia will see increased costs associated with labor, vehicles, fuel, etc.
• Anticipated waiver implementation date and time-period:
We request that the waiver be reimplemented immediately for the upcoming SFSP operational period.
• Proposed monitoring and review procedures:
We will conduct monitoring and review procedures in accordance with SFSP Administrative Guidance published by USDA.
Thank you for your assistance in pursuing this waiver. We are grateful for your continued partnership in feeding the children of South Georgia. If I can provide additional information necessary to submit the request for waiver to SERO, please do not hesitate to contact me.
Franklin J. Richards, II