Effective July 1, 2018, all public, non-public and charter school food authorities (SFAs) that require students to pay for a school breakfast and/or lunch meal must develop a written plan to ensure that a student who has unpaid meal charges is not shamed or treated differently than a pupil who does not have unpaid school meal charges.
On May 1, 2018, the New York State Education Department published a memorandum regarding the amendment to New York State Education Law 908 to include Prohibition Against Meal Shaming. The Prohibition Against Meal Shaming plan should be reasonable, well-defined and maintain the integrity and dignity of students and households. This new legislation requires SFAs to provide students with the reimbursable meal of their choice and specifically identifies other prohibited actions to decrease student distress or the embarrassment associated with not having adequate funds to pay for a school meal or having outstanding school meal debt.
SFAs are required to submit their completed plans to the New York State Education Department (SED) electronic mailbox via firstname.lastname@example.org by July 1, 2018. After submission of the plan, the SFA must adopt and post the plan on its school’s website.
SFAs must also demonstrate that all applicable staff are trained and fully understand how to properly implement the SFA policy. SED has developed a comprehensive webinar and corresponding guidance materials to assist SFAs to train their school personnel. The webinar will be posted on www.cn.nysed.gov and links will be provided for SFAs to access the webinar and resources. SED staff is also available to provide technical assistance for SFAs that need additional guidance to help affected parents or guardians qualify their children for free or reduced-price meals, if applicable.
The new State plan has several of the same or similar requirements as the Federal National School Lunch Program (NSLP) Unpaid Meal Charge policy that took effect July 1, 2017. SFAs may opt to amend this policy to include the new State criteria or can develop a separate State specific plan. SED has also created a template plan that SFAs can use to meet both the State and Federal requirements. The template can be accessed here.
See the publication on NYSED’s website for further information and the specific criteria that is required to be in the plan.
Shari Diamond, CIA
Shari has been with Cerini & Associates, LLP since 2008 where she works primarily with the firm’s school district clients providing internal audit and claims audit services. She has over twenty years’ experience performing internal audits, risk assessments, and compliance reviews, as well as recommending processes to strengthen the internal controls environment while increasing efficiencies. Her prior experience at PWC and Northrop Grumman included performing Information Technology audits.