Arkansas Department of Education Division of Elementary and Secondary Education USDA Special Provisions for Student Feeding

Memo Information

Memo Number
Memo Date
Memo Type
Child Nutrition
Regulatory Authority
Superintendents, Co-op Directors, Financial Managers, Bookkeepers, Federal Program Coordinators, and Child Nutrition Directors
Response Required
Federal Programs; Superintendents; General Business Managers; Bookkeepers; Child Nutrition Directors/Managers

Primary Contact Information

Memo Reference

No references available.

Memo Text



The purpose of this memo is to provide information on each special provision option available through the United States Department of Agriculture (USDA) to assist school districts in making informed decisions about the programs available.  Districts choosing to investigate the available special provisions for possible use in the feeding of children at no charge to the household should contact the Arkansas Department of Education (ADE), Child Nutrition Unit (CNU) to discuss the options available.  Technical assistance will be provided to each district on an individual basis to determine which special provision option, if any, would benefit both the students and the district.  


USDA offers four special provisions for the feeding of students: Provision 1, Provision 2 (P2), Provision 3, and the Community Eligibility Provision (CEP).  Provision 1 provides meals at no charge for most of the students in the district.  Provision 2, 3, and CEP provide an opportunity for students to receive two meals (breakfast and lunch) at no charge to the household.


Provision 1 - Free eligibility is certified for two years.  Schools must have at least 80% of the children enrolled in the district eligible for free or reduced lunch prices.  At the point of service, students are counted as free, reduced or paid for the two year period.  There is no obligation for a school district to provide meals at no charge to students who do not qualify for free meals.


Provision 2 – This is a four year cycle with the first year considered the “base year”. During the base year, student eligibility status is determined in the same manner as regular pricing schools (Free and Reduced Meal Applications, Direct Certification, Categorically eligible).  During the base year, meals are served and counted at the point of service by eligibility category using standard counting and claiming.  All students are provided meals at no charge to the household; however, the meals are claimed at the free, reduced, and paid rate based on individual student meal status and actual meal participation. 


During the next three years, no student eligibility determinations are made, and meal counts at the point of service are now claimed based on free, reduced, or paid claiming percentages. Claiming percentages are determined during the base year and applied for the three (3) years following implementation.  Federal reimbursement is determined by multiplying the claim rate and the total number of meals served each month.  Those percentages are validated by the Child Nutrition Unit (CNU).  With changes in student enrollment, the percentages may vary a small amount each year.


Districts may apply for four (4) year extensions utilizing the same claiming rates if the economic conditions of the area have not changed.  If economic conditions worsen, the district may choose to establish a new base year, move to another provision, or return to standard pricing.  The district does not have to wait until the end of the four-year cycle to make that change. 


Districts may be required to supplement the child nutrition program if the federal reimbursement does not cover all expenses.  The supplemental funds must come from non-Federal funds. The funds deposited in the non-profit child nutrition account are not loans to the program and cannot be repaid to the district.


Provision 3 – In provision 3, a base year is established using student meal eligibility determination and meal counts by category.  Districts receive the same level of federal funding and commodity assistance, adjusted to reflect changes in enrollment and inflation, for the next four (4) years.  Schools electing this alternative must pay the minimum difference between the Federal reimbursement and the cost of providing all student meals at no charge to the child nutrition program from non-Federal funds.  Additional money may be necessary if the federal reimbursement does not cover all expenses.  These monies are not loans to the program and cannot be repaid to the district.


Community Eligibility Provision (CEP) – School districts report the number of students enrolled and those considered “identified” on April 1st of the school year preceding adoption.  Identified students are those certified as free eligible based on Direct Certification lists, living in the same household as a student on the Direct Certification list, or students identified on a list as other categorically eligible (homeless, migrant, foster, runaway, Head Start or Even Start).  Schools with a minimum of 40% of the student enrollment designated as Identified Students are eligible to participate in CEP.  Meals are counted at the point of service and claimed for reimbursement based on the formula provided by USDA.  The claiming percentage will be sent directly to the school district by the CNU.  Meals are served to students at no charge to the household.  If the federal reimbursement received is not sufficient to maintain the financial solvency of the child nutrition program, the district must supplement the child nutrition program through the use of non-Federal funds.  Additional money may be necessary if the federal reimbursement does not cover all expenses.  These supplemental funds are not loans to the program and cannot be repaid to the district. CEP is renewable for up to three (3) years.  After that, a new base year must be established.  If a district sees an increase in the Identified Student Population (ISP), after the implementation, the district may choose to begin a new base year.


Many districts have found that Provision 2 (P2) or Community Eligibility Provision (CEP) have been beneficial for their local communities.  Any district investigating these special provisions as possible ways of providing meals at no charge to the student are encouraged to contact CNU for more information.  After choosing to participate in any of these special provisions, CNU will validate the student eligibility data. The validated data will then be used to determine meal claiming rates. 


Additional information is available through CNU.  Contact the district’s area specialist, Donna Ratliff, or Susie Ward at 501-324-9502.



No attachments available

Print Memo

Share this memo