Assessing Proposed Nutrition Education Costs

This Management Bulletin (MB) provides guidance on the U.S. Department of Agriculture (USDA) Policy Memorandum SP 07-2015: Assessing Proposed Nutrition Education Costs in the National School Lunch Program and School Breakfast Program. The policy memo provides guidance on the process state agencies and school food authorities (SFA) must follow when considering use of revenues from the nonprofit school food service account (cafeteria fund) for nutrition education-related expenses. SP 07-2015 is located on the USDA Food and Nutrition Service Documents & Resources web page at https://www.fns.usda.gov/resources.

Background

The California Department of Education (CDE) is required to ensure that all cafeteria fund revenues are used solely for the operation or improvement of the school food service. When an SFA is deciding whether or not to spend cafeteria funds on nutrition education materials or activities, the SFA must first consider all free alternatives. If the SFA concludes that the only alternative is to use cafeteria funds, the SFA must submit a request for prior approval for the purchase to the CDE. The CDE will review each request for approval on a case-by-case basis.

Assessing Allowability of Costs Associated with Nutrition Education Activities

The CDE will consider the following when assessing the allowability of the SFA’s use of cafeteria funds for nutrition education materials or activities:

• Title 7, Code of Federal Regulations, Section 210.14(a)

• Title 2, Code of Federal Regulations, Sections 200.402 to 200.411

• USDA Policy Memo SP 07-2015

• A written justification indicating the SFA’s reasonable need for the nutrition education materials or activities

Policy and Procedure

Based on the guidance in the USDA Policy Memo SP 07-2015, the CDE developed the following procedures for SFAs requesting to use cafeteria funds for nutrition education materials and activities:

1. At least three months prior to the anticipated cafeteria fund expenditure on the nutrition education materials or activities, the SFA is required to:
   
   
   1. Complete and submit Form ID SNP 63, Nutrition Education Expenditure Request, available in the Download Forms section of the School Nutrition Programs (SNP) module of the Child Nutrition Information and Payment System Web site located at https://www.cnips.ca.gov/.
      
      
   2. E-mail the completed form to NutrEdExpenditure@cde.ca.gov.
      
      
2. The CDE will review each request and then notify the SFA of approval or denial by e-mail.
   
   
3. The SFA is responsible for maintaining documentation of the CDE’s prior approval of the expenditure for three years and must have the approval available during their administrative review. Failure to provide this prior approval may result in the entire cost being disallowed.

Guidance on Justification for the Nutrition Education Materials or Activities

The SFA’s justification for the use of nutrition education materials or activities within the SNPs is an important factor in the CDE review process. The SFA is required to provide a thorough explanation that supports their responses to the questions in Form ID SNP 63.

As specified in Form ID SNP 63, Question 5, the justification should include supporting data and citations from available studies. If there is no data available to support the effectiveness of the proposed nutrition education materials or activities, then the SFA should include an evaluation parameter to measure the effectiveness of the proposed intervention. The SFA can use this information to support future requests.

Resources

Nutrition education is an integral part of the SNPs. The CDE’s Resources to Support Nutrition Education Activities includes examples of free or low-cost ways to support nutrition education activities, and web links to access free downloadable nutrition education materials and curricula.

Note: None of the low-cost items on the resource list are preapproved; approval to expend revenue from the cafeteria fund requires a justification from the SFA as explained above.

More Information

The CDE is implementing the policy and procedure outlined above according to USDA guidance in Policy Memo SP 07-2015. Based on the review process experience and feedback from SFAs, the CDE may evaluate and revise the policy and procedures. Your feedback is always important to the CDE. If you have any questions regarding this subject or if you have feedback, please contact Heather Reed, Nutrition Education Consultant, by phone at 916-323-3581 or by e-mail at NutrEdExpenditure@cde.ca.gov.

If you have any questions regarding cafeteria fund policy or regulations, please contact the Resource Management Unit by e-mail at SNPCafeFundQuestions@cde.ca.gov.

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Resources to Support Nutrition Education Activities

Note: The school food authority (SFA) must seek prior approval from the California Department of Education (CDE) before using cafeteria funds to purchase any item on this list.

1. SFAs must consider free methods and resources to deliver nutrition education activities before requesting to use cafeteria funds. For example, SFAs may:
   
   
   1. Use free posters and pamphlets
      
      
   2. Use volunteers, such as college students or individuals from the community
      
      
   3. Use U.S. Department of Agriculture (USDA) Foods for tasting in the cafeteria when that food is being showcased for nutrition education in the classroom
      
      
   4. Collaborate with local health department or University of California Cooperative Extension office staff
      
      
   5. Apply for a grant to support nutrition education activities for obesity prevention
      
      
   6. Seek Parent–Teacher Association support for fundraising or grant writing
      
      
   7. Request funds from local businesses to support a garden program or other nutrition education efforts for childhood obesity prevention
      
      
   8. Request that the school district 1. include key nutrition goals and food service activities in the Local Control and Accountability Plan (LCAP) to allow enhancement and expansion of the nutrition service, and 2. allocate LCAP funds to ensure that students have quality nutrition services and education necessary for their academic success.
      
      To learn more, read CDE’s webpage on the LCAP, http://www.calpronet-sj.org/modules15_16/LCFF_Flyer.pdf [Note: the preceding web address is no longer valid. Please visit https://www.cde.ca.gov/re/lc.]
      
      
2. Free or low-cost downloadable nutrition education materials may be available from the resources below:
   
   

1. The California Healthy Kids Resources Center has free resources for Local Education Agencies. http://www.californiahealthykids.org
   
   
2. The Dairy Council of California Healthy Eating Curriculum web page at https://www.healthyeating.org/products-and-activities/curriculum
   
   
3. The USDA Dig In! Standards-based Nutrition Education from the Ground Up web page at
   https://www.fns.usda.gov/tn/dig-standards-based-nutrition-education-ground
   
   
4. The California Department of Public Health Harvest of the Month web page at https://harvestofthemonth.cdph.ca.gov/Pages/default.aspx [Note: the preceding web address is no longer valid.]
   
   
5. The Choose MyPlate 10 Tips Nutrition Education Series web page at https://www.choosemyplate.gov/ten-tips [Note: the preceding web address is no longer valid.]
   
   
6. The USDA’s Start Simple with MyPlate website has free materials and resources. https://www.myplate.gov/tip-sheet/start-simple-myplate
   
   
7. The CDE Nutrition Education in California Schools web page at http://www.cde.ca.gov/ls/nu/he/nutritionedcaschools.asp
   
   
8. The CDE Nutrition Education Resource Guide web page at https://www.cde.ca.gov/ls/nu/he/nerg.asp
   
   
9. The San Jose State University California Professional Nutrition Education and Training Center Nutrition Education Links web page at http://www.calpronet-sj.org/ [Note: the preceding web address is no longer valid.]
   
   
10. The USDA Supplemental Nutrition Assistance Program Education (SNAP-Ed) Connection web site at https://snaped.fns.usda.gov/
    
    
11. The USDA SNAP-Ed Interventions Toolkit for States web page available at https://snaped.fns.usda.gov/ [Note: the preceding web address is no longer valid.]
    
    
12. The University of California, Davis, Center for Nutrition in Schools web site at https://cns.ucdavis.edu/
    
    
13. The USDA Team Nutrition web site at https://www.fns.usda.gov/tn
    
    
14. The Whole Grain Council Educational Materials web page at https://wholegrainscouncil.org/resources/school-lesson-plans-and-educational-materials/educational-materials