Summer Meals: Actions Needed to Improve Participation Estimates and Address Program Challenges

The SFSP, a federal nutrition assistance program, is intended to provide food to children in low-income areas during periods when area schools are closed for vacation. In the last decade, federal expenditures for SFSP have increased as the program has expanded, according to USDA data. GAO was asked to review the SFSP.

This report examines (1) what is known about SFSP participation, (2) other programs that help feed low-income children over the summer, and (3) challenges, if any, in providing summer meals to children and the extent to which USDA provides assistance to address these challenges. GAO reviewed relevant federal laws, regulations, and guidance; analyzed USDA's SFSP data for fiscal years 2007 through 2016; surveyed state agencies responsible for administering the SFSP in 50 states and the District of Columbia; visited a nongeneralizable group of 3 states and 30 meal sites, selected based on Census data on child poverty rates and urban and rural locations; analyzed meal site data from the 3 states; and interviewed USDA, state and national organization officials, and SFSP providers, including sponsors and site operators.

Nationwide, the total number of meals served to children in low-income areas through the Summer Food Service Program (SFSP) increased from 113 to 149 million (about 32 percent) from fiscal year 2007 through 2016. The U.S. Department of Agriculture (USDA) directs states to use the number of meals served, along with other data, to estimate the number of children participating in the SFSP. However, participation estimates have been calculated inconsistently from state to state and year to year. In 2017, USDA took steps to improve the consistency of participation estimates, noting they are critical for informing program implementation and strategic planning. However, GAO determined that the method USDA directs states to use will continue to provide unreliable estimates of participation, hindering USDA's ability to use them for these purposes.

Other federal and nonfederal programs help feed low-income children over the summer to some extent, according to states GAO surveyed and SFSP providers and others GAO interviewed. For example, in July 2016, USDA data indicate about 26 million meals were served through a separate federal program that allows school meal providers to serve summer meals. Some children also received summer meals through nonfederal programs operated by faith-based organizations and foodbanks, though GAO's state survey and interviews with providers and national organizations indicate the reach of such efforts is limited.

States and SFSP providers reported challenges with meal sites, participation, and program administration; USDA has taken steps to address these areas. Specifically, in GAO's survey, a majority of states reported challenges with availability and awareness of meal sites, as well as limited program participation and administrative capacity. National, state, and local officials have taken steps to address these issues, such as increasing outreach and offering activities to attract participation. In addition, 17 states in GAO's survey and providers in the states GAO visited reported a challenge with ensuring meal sites are in safe locations. To address this safety issue, USDA has granted some states and sponsors flexibility from the requirement that children consume meals on-site. However, USDA has not broadly communicated the circumstances it considers when granting this flexibility. Further, some states and sponsors that have requested this flexibility reported difficulty obtaining data to show these circumstances exist, hampering their ability to ensure safe meal delivery.

GAO is making four recommendations, including that USDA improve estimates of children's participation in SFSP and communicate the circumstances it considers when granting flexibilities to ensure safe meal delivery. USDA generally agreed with GAO's recommendations.

In fiscal year 2016, the U.S. Department of Agriculture (USDA) spent  $478 million to provide more than 150 million meals to children through  the Summer Food Service Program (SFSP). As a federal nutrition  assistance program, the primary purpose of the SFSP is to provide food  service to children in low-income areas during periods when area schools  are closed for vacation. USDA’s Food and Nutrition Service (FNS)  oversees the SFSP, which is administered by the states and operated by  a variety of public and private nonprofit organizations and government  entities that sponsor meals at sites such as schools, camps, parks,  churches, and libraries. In the last decade, federal expenditures have  increased as the program has expanded, according to FNS data. As  Congress considers proposals intended to modify child nutrition  programs, you asked that we examine issues related to the SFSP.  1.  What is known about participation in the Summer Food Service  Program and how it has changed in the last 10 years?  2.  What other programs help feed low-income children over the  summer?  3.  What challenges exist, if any, in providing summer meals to children,  and to what extent does FNS provide assistance to states and  sponsors to address these challenges?

To address our first objective about participation in the SFSP, we  analyzed FNS’s national data on SFSP meals served for fiscal years  2007 through 2016. For context on these trends, we analyzed, and  compared to the SFSP data, FNS’s data on lunches served through the  National School Lunch Program (NSLP), the largest child nutrition  assistance program, for the same time period. To assess the reliability of  SFSP and NSLP data, we (1) performed electronic testing of relevant  data elements, (2) reviewed existing information about the data and the  system that produced them, and (3) interviewed agency officials  knowledgeable about the data. We determined that these data were  sufficiently reliable to identify the number of meals served in each  program and assess change over time.

We also reviewed FNS’s method for estimating the number of children  participating in the SFSP using these data and discuss the reliability of  this method in the body of the report. From our three selected states, we  also analyzed site-level data on meals served and days of operation for 2  months during the summer of 2016, including the month with the largest  number of SFSP meals served in each state. We assessed the reliability  of these data by (1) performing electronic testing of relevant data  elements, (2) reviewing existing information about the data and the  system that produced them, and (3) interviewing agency officials  knowledgeable about the data. We determined these data to be  sufficiently reliable for the purposes of this report.

To obtain information specific to our second objective on other programs  that help feed children in the summer, we also analyzed FNS data on  meals served through the NSLP and School Breakfast Program (SBP) in  July 2016 because FNS used these data to estimate meals served  through the Seamless Summer Option in summer 2016. To assess the  reliability of these data, we (1) performed electronic testing of relevant  data elements, (2) reviewed existing information about the data and the  system that produced them, and (3) interviewed agency officials  knowledgeable about the data. We determined that these data were  sufficiently reliable to describe the number of meals served through the  Seamless Summer Option.

In addition, we relied on several methods to address all three objectives.  At the federal level, we reviewed relevant federal laws, regulations, and guidance, and interviewed FNS officials in headquarters and its seven  regional offices. We also surveyed the state agencies responsible for  administering the SFSP in the 50 states and District of Columbia. We  administered our web-based survey between August and October 2017  and received a 100 percent response rate. Further, we visited three  selected states—Arizona, Illinois, and Massachusetts—between June  and July 2017. In each state, we interviewed state agency officials  responsible for administering the SFSP, as well as selected SFSP  providers, and we observed SFSP meal service at a total of 30 meal  sites. We selected states and local areas within those states based on a  high proportion of children in poverty, a mix of urban and rural densities, a  mix of sponsor and site types, and diverse locations in the country. We  visited a wide variety of site locations including, but not limited to,  schools, parks, community recreation areas, and libraries. To gather  additional information, we interviewed a broad range of regional and  national organizations involved in the SFSP, such as the Boys and Girls  Club of America, Catholic Charities, and Feeding America. Additional  information on the report’s scope and methodology is included in  appendix I.

We conducted this work from January 2017 through May 2018 in  accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Created in 1968, the SFSP is authorized under the Richard B. Russell  National School Lunch Act and generally provides free meals to children  age 18 and under in low-income areas during certain periods when  school is not in session. Specifically, the SFSP operates during school  summer vacation periods between May through September, vacation  periods in any month for programs operating on a continuous school  calendar, and certain other times for areas affected by an unanticipated  school closure, such as for a natural disaster. However, the majority of  SFSP meals are served to children during the summer months.

In fiscal years 2007 through 2016, federal expenditures on SFSP  increased, according to FNS data, though there was a slight decrease  between fiscal years 2015 and 2016 (see fig. 1).

The SFSP is administered at the federal level by FNS through its national  and regional offices. FNS is responsible for issuing regulations,  instructions, and guidance; reviewing states’ program management and  administration plans; overseeing program administration; and reimbursing  states for meals served that meet program requirements. At the state  level, the program is administered by state agencies and locally operated  by state-approved sponsors, such as school districts, local government  entities, or private nonprofit organizations. State agencies are  responsible for approving, providing training to, and inspecting and  monitoring sponsors and meal sites. Sponsors, in turn, are responsible for  monitoring their SFSP meal sites, managing the meal service, and  providing training to administrative staff and site operators. A sponsor  may operate one site or multiple sites. Sites are physical locations in the  community where children receive and consume meals in a supervised  setting. According to FNS guidance, sites may be located in a variety of  settings, including schools, parks, community centers, health clinics,  hospitals, apartment complexes, churches, and migrant camps.

States may approve different types of SFSP meal sites, including open  sites, closed enrolled sites, and camps. Open sites operate in an area  where at least half of the children are eligible for free or reduced-price  school meals (referred to as “area eligible”), according to data from  entities such as schools or the U.S. Census Bureau. Children are  generally eligible for free or reduced-price school meals if their  households have incomes at or below 185 percent of federal poverty  guidelines. At open sites, meals are made available to all children in the area, and all meals served that meet program requirements are  reimbursable. Closed enrolled sites, on the other hand, are open only to  enrolled children, as opposed to the community at large. At closed  enrolled sites, meals served to all children in attendance are reimbursable  as long as at least half of the enrolled children are eligible for free or  reduced-price school lunch. Unlike other types of sites, camps are  reimbursed only for meals served to children who have been individually  determined to be eligible for free or reduced-price school meals.

SFSP meals must meet certain requirements in order to be eligible for  federal reimbursement; for example, the meals must be served and  consumed on-site at an approved site. Federal reimbursements for  summer meals are provided for each breakfast, lunch, supper, or snack  served to an eligible child at an eligible site that also meets federal  requirements for menu components, scheduled meal times, and  nutrition. For example, to meet nutritional requirements, a lunch or a  supper must, at a minimum, include four components: 2 ounces of meat  or a comparable serving of a meat alternate, 3/4 cup of fruits and/or  vegetables (at least two kinds), a slice of bread or a comparable serving  of another grain, and a cup of milk. In 2017, the federal reimbursement  rate was $3.83 or $3.77 for each eligible SFSP lunch or supper served,  depending on the type of meal site. Each site may serve up to two  meals or one meal and one snack per day.

Some flexibilities are available to FNS in implementing the SFSP  program, under its waiver and demonstration authorities. Specifically, the  National School Lunch Act authorizes the Secretary of Agriculture to  waive, upon request of a state or eligible service provider, certain  program requirements established under the National School Lunch Act  or the Child Nutrition Act of 1966, as amended, including some for the  SFSP. In order to grant a waiver request, the Secretary must determine  that the waiver would facilitate the state or service provider’s ability to  carry out the purpose of the program, and that the waiver will not increase  the overall cost of the program to the federal government, among other  things. In the event a waiver request is submitted, the Secretary is  required to act promptly and state in writing whether the waiver request is  granted or denied, and why. The Secretary is also required to periodically  review the performance of waiver recipients, and submit an annual report  to Congress summarizing the use of waivers and their effectiveness,  among other details.

In addition to this waiver authority, the Secretary is also authorized to  carry out demonstration projects to develop and test methods of providing  access to summer meals for low-income children in urban and rural  areas, to reduce or eliminate the food insecurity and hunger of low-income children and improve their nutritional status. The Secretary is  required to provide for an independent evaluation of the demonstration  projects carried out under this authority, and submit an annual report to  Congress on the status of each project and the results of the  evaluations.

Number of SFSP Meals Served Has Generally Increased since 2007, but Estimates of Children Participating in the SFSP Are Unreliable

Number of SFSP Meals Served Has Increased by 32 Percent since Fiscal Year 2007

The total number of SFSP meals served nationwide during the summer— one indicator of program participation—increased from 113 million meals  in fiscal year 2007 to 149 million meals in fiscal year 2016, or by 32  percent, according to our analysis of FNS data. The number of SFSP  meals served has generally increased from year to year over this 10-year  period. Most recently, meals decreased by 6 percent from 156 million  meals in summer 2015 to 149 million meals in summer 2016, according to  our analysis of FNS data (see fig. 2). Factors that may have affected  year-to-year fluctuations include changes in funding for summer  programs, sponsor participation, weather, and the number of weekdays  available for sites to serve meals within a given summer, according to  FNS and state agency officials we interviewed. For example, state  agency officials in one of the three selected states we visited said they  believe that reductions in state and local funding for summer programs  that also provide meals, and turnover of sponsors, including losing one of  the state’s largest sponsors in a recent summer, affected the total number  of SFSP meals served in their state in 2016.

According to our analysis of FNS data, SFSP lunches served in the  summer months increased by over 17 million from fiscal year 2007  through fiscal year 2016, accounting for almost half of the total increase in  the number of SFSP meals served in that period. However, when  comparing across each of the meal types, supper and breakfast had the  largest percentage increases over the 10-year period, 50 and 48 percent,  respectively (see table 1). In comparison, the number of SFSP lunches  served increased by 26 percent from fiscal years 2007 through fiscal year  2016.

From fiscal year 2007 through fiscal year 2016, there were increases in  the numbers of meals served in both SFSP and NSLP, the largest child  nutrition assistance program. Specifically, SFSP lunches served in July  increased from 32 million to 40 million, or 24 percent, from fiscal year  2007 to 2016, and NSLP lunches served in March increased from 328  million to 376 million meals, or 15 percent, according to our analysis of  FNS data. Although the programs generally serve similar populations,  different factors likely affected the number of meals served by each  program, in part because NSLP serves children in schools during the  school year and SFSP serves children in a variety of settings during the  summer months.

Estimates of Children Participating in SFSP Have Been Calculated Inconsistently and Are Unreliable

Although states report the actual number of SFSP meals served to FNS,  they estimate the number of children participating in SFSP, and  information obtained from our state survey and FNS indicate that these  participation estimates have been calculated inconsistently. FNS  instructs state agencies on how to calculate a statewide estimate of  children’s participation in the SFSP, referred to as average daily  attendance (ADA), using sponsor-reported information on the number of  meals served and days of operation in July of each year. However,  states’ methods for calculating ADA have differed from state to state and  from year to year, according to our review of states’ survey responses  and FNS documents. For example, although FNS directed states to  include the number of meals served in each site’s primary meal service— which may or may not be lunch—some states, according to our survey  and FNS data, were calculating ADA using only meals served at lunch.  FNS officials told us that these states were therefore not following the  agency’s instructions. Further, some states have changed their methods  for calculating ADA over time—five states reported in our survey that the  method they used to calculate ADA in fiscal year 2016 differed from the  one they used previously.

While FNS clarified its instructions in May 2017 to help improve the  consistency of states’ ADA calculations moving forward, ADA remains an  unreliable estimate of children’s daily participation in SFSP for at least  two reasons, according to our analysis. (See sidebar for the revised ADA  calculation instructions.) First, ADA is based on summary data that does  not account for existing variation in site days of operation, and second, it  is based on July data, which does not reflect the month with the greatest  number of meals served in every state.

According to our analysis, ADA is an unreliable estimate of children’s  participation in SFSP because it currently does not account for  existing variation in the number of days that each site serves meals to  children. Specifically, because FNS’s instructions indicate that sites’  ADAs are to be combined to provide a statewide ADA estimate,  differences in the number of days of meal service are disregarded. As  a result, ADA does not reflect the average number of children served  SFSP meals daily throughout the month. Our analysis of site-level  data from one of the selected states illustrates this limitation. In this  state, multiple sites reported an ADA of 60 for July, yet two of those  sites served meals to children on only 1 day of the month and another  site served meals to children on 20 days. Although 120 children  were served SFSP meals only 1 day in July across two of these sites,  the combined ADA across all three sites, which we calculated  following FNS’s instructions, inaccurately suggests an average of 180  children were participating in SFSP at these sites on a daily basis in  July.

According to our analysis, ADA is also an unreliable estimate of  children’s participation in SFSP because it currently does not account  for state variation in the month with the greatest number of SFSP  meals served, potentially leading to an underestimate. According to  FNS officials, the agency instructs states to calculate ADA for July  because officials identified this as the month with the largest number  of meals served nationwide. However, because of reasons such as  state variations in school calendars, July is not the month with the  largest number of meals served in every state. In one of the selected  states, Arizona, using July to calculate ADA cuts the estimate almost  in half. Specifically, we followed FNS’s instructions and calculated  that Arizona’s ADA was 14,987 in July 2016 compared to 26,772 in  June 2016. Nationwide, in summer 2016, 26 states served more  SFSP meals in June or August than in July, according to our analysis  of FNS data. However, without site level data on meals served and  operating days, the extent to which these states had higher ADAs in  June or August as compared to July is unknown.

In its May 2017 memo to states revising the ADA calculation instructions,  FNS said that it is critical that the agency’s means of estimating children’s  participation in the SFSP is as accurate as possible because it helps  inform program implementation at the national level and facilitates  strategic planning and outreach to areas with low participation. In  addition, Standards for Internal Control in the Federal Government state  that agencies should maintain quality data and process it into quality  information that is shared with stakeholders to help achieve agency  goals.

Although FNS has also collected information on other data that states  collect on the SFSP, the agency has not yet used this information to help  improve its estimate of children’s participation in the program. In 2015,  FNS published a Request for Information, asking whether states or  sponsors collect any SFSP data that are not reported to FNS. While  FNS received responses from only 15 states, these responses suggest  that some states collect additional data, such as site-level data that may  allow for an improved estimate of children’s SFSP participation,  potentially addressing the issues we found in our analysis. In response to  the information FNS received, they followed up with up to 9 of the 15  states in 2016 and 2017 to explore the feasibility of collecting additional  data and improving estimates of children’s participation. Although they  took these steps, FNS officials told us they are cognizant of the burden on  states and site operators that would be associated with additional  reporting requirements. At this time, the agency has not taken further  action to improve the estimate, such as addressing the reliability issues  caused by variation in the number of operating days of meal sites and in  the months with the greatest number of meals served by state. As a  result, FNS’s understanding of children’s participation in the SFSP  remains limited, which impairs its ability to both inform program  implementation and facilitate strategic planning and outreach to areas  with low participation.

Other Federal and Nonfederal Programs Help Feed Low- Income Children over the Summer to Some Extent

Other Federal Programs Provide Meals and Nutrition Assistance Benefits over the Summer

Other federal programs that operate solely in the summer, as well as  those operating year-round, help feed low-income children in the summer  months. These programs include the NSLP Seamless Summer Option,  which provides nutrition assistance benefits solely in the summer, and  several federal programs that operate year-round.

In July 2016, in addition to the 70 million meals provided through the  SFSP, 26 million meals were provided to low-income children through  school food authorities participating in the NSLP’s Seamless Summer  Option, according to FNS data. The Seamless Summer Option was  established in 2004, and according to FNS, streamlines administrative  requirements to encourage school food authorities providing free or  reduced-price meals during the school year under the NSLP and SBP to  continue providing meals to low-income children when school is not in  session. For example, officials from a national organization involved in  summer meals told us the Seamless Summer Option makes it easier for  school food authorities to provide summer meals because they continue  working with the same state agency, reporting the same information to  the state, and operating without having to transition to a separate  program. Nonetheless, school food authorities can choose to provide free  summer meals to children through either the SFSP or Seamless Summer  Option, and the majority of states (34) reported in our survey that a  greater proportion of school food authorities participated in the SFSP than  the Seamless Summer Option in summer 2016. According to FNS and  selected state officials, this may be related to the generally lower meal  reimbursement rates school food authorities participating in the Seamless  Summer Option receive compared to the rates received by those  participating in the SFSP.

In summer 2016, the Seamless Summer Option added to the geographic  availability of summer meal sites in two of the three states we visited as  part of our review. School food authorities provided summer meals  through the Seamless Summer Option in Arizona and Illinois, but not in  Massachusetts, based on our analysis of data provided by these states.  In Arizona and Illinois, school food authorities participating in the  Seamless Summer Option added 643 and 298 summer meal sites,  respectively, in the month with the largest number of SFSP meals served  in each state (see fig. 3). In addition, some of the Seamless Summer  Option sites in these two states provided meals to children in areas where  there were no SFSP sites. For example, Seamless Summer Option sites  provided meals in areas near the northeastern and southwestern corners  of Arizona that lacked nearby SFSP sites.

In addition to the SFSP and the Seamless Summer Option, the Summer  Electronic Benefit Transfer for Children (Summer EBT) demonstration  provided nutrition assistance benefits to 209,000 low-income children in  summer 2016 in select areas across 6 states and 2 Indian Tribal  Organizations, according to FNS officials. Since the summer of 2011,  Summer EBT benefits have been provided to eligible households on an  electronic benefits transfer card, which households use to purchase  eligible foods at authorized retailers. Specifically, the demonstration has  provided monthly benefits of $30 or $60 per eligible child to households  with children in areas with a perceived high level of need, based on the  demonstration grantees’ assessments of the percentage of children  eligible for free or reduced-price school meals and the availability of the  SFSP. Consistent with this, three of the states that participated in  Summer EBT in 2016 reported through our survey that these benefits  helped children who were unable to access summer meals through the  SFSP or the Seamless Summer Option. Further, according to an FNS- funded evaluation, Summer EBT improved food security among low- income children who participated in the demonstration. Specifically, the  evaluation found the receipt of these benefits reduced the number of  children in the demonstration experiencing very low food security  between 2011 and 2013 by one-third.

Some low-income children also receive nutrition assistance in the  summer through federal programs that operate year-round. According to  FNS data, in June 2016, 5.8 million infants and children participated in the  Special Supplemental Nutrition Program for Women, Infants, and  Children (WIC) and 3 million children participated in the Child and Adult  Care Food Program (CACFP). In addition, an average of 19.2 million  children participated each month in the Supplemental Nutrition Assistance  Program (SNAP) in fiscal year 2016, according to FNS data. These  benefits are provided year-round, including when school is in session and  children may also be eligible to receive school meals. In our previous  work on federal domestic food assistance programs, we reported that no  one program alone is intended to meet a household’s full nutritional  needs. At that time, several officials and providers told us that the  variety of food assistance programs offers eligible individuals and  households different types of assistance and can help households fill the  gaps and address the specific needs of individual members. For example,  a mother with two children may rely on SNAP for her household’s basic  groceries, the NSLP to feed a school-age child during the school year,  and WIC to obtain supplemental foods for herself and an infant.

Nonfederal Programs Also Help Feed Low-Income Children in the Summer, but States and Local Organizations Reported That These Have Limited Reach

Some low-income children also receive summer meals through  nonfederal programs, according to our state survey and interviews with  organizations involved in summer meals. Twenty-seven states reported in  our survey that they were aware of other state- or non-state-funded  programs that provided children of low-income households with meals in  their states during the summer months.

According to our analysis of state survey responses, local faith-based  organizations and foodbanks were the most common types of entities  operating these types of programs. Similarly, officials from FNS and two  regional organizations we interviewed said they were aware of children  receiving summer meals through nonfederal programs operated by faith- based and other community organizations. In addition, SFSP site  operators at 6 of the 30 meal sites we visited in the selected states told us  nearby foodbanks and faith-based organizations may also be providing  children with free meals to some extent. For example, one of the meal  sites we visited was operated by a foodbank that, in addition to the SFSP,  provided food boxes to those in need and distributed food to other local  community organizations to provide to persons in need of immediate  assistance, including families with children.

Although FNS and the majority of states do not collect data on nonfederal  programs, results from our state survey and interviews with SFSP  providers and organizations involved in summer meals indicate the reach  of nonfederal programs is limited. In our survey, states reported that the  geographic coverage of these nonfederal programs varied by state, with  11 states indicating that they operated in some portions of the state—the  most common state response. In addition, 16 states reported that they were not aware of any nonfederal programs providing summer meals to  children in their state (see fig. 4). Similarly, SFSP site operators at 24 of  the 30 meal sites we visited were unaware of nonfederal programs  providing meals to children in the areas in which they operated. In  addition, officials from several national organizations involved in summer  meals told us children have very few options for receiving summer meals  beyond the federal summer meals programs. Specifically, officials from  one national organization explained that food is often a significant part of  the cost of a summer activity program for children and suggested that is  one reason why organizations choose to participate in the SFSP.

Although the SFSP provides for federal reimbursement of eligible meals  and certain administrative and operating costs, nonfederal programs that  provide children with summer meals may choose not to participate in the  SFSP for several reasons, according to officials we interviewed from  several organizations involved in summer meals. For example, some  nonfederal program providers may not participate in the SFSP because  they are unaware the program exists. Additionally, some nonfederal  program providers may be aware of the SFSP, but choose not to  participate because they do not want to follow certain program  requirements, such as the nutrition or meal pattern standards. In addition,  some providers may not participate in the program because they do not  think they can handle certain aspects of the administrative workload  associated with the SFSP. For example, a state official we interviewed  told us the administrative workload associated with the SFSP can be  particularly challenging, especially for smaller sponsors. Similarly, officials  from a regional organization involved in summer meals told us one of the  providers they work with who operated 10 meal sites chose to leave the  SFSP because the paperwork required to operate the sites was too  administratively burdensome for their volunteer site operators.

States and SFSP Providers Face Challenges with Meal Sites, Participation, and Program Administration, and FNS Actions Have Addressed Some, but Not All Areas

States and SFSP providers reported challenges with meal sites,  participation, and administration, though federal, state, and local entities  have taken steps to improve these areas. Half or more of states reported  in our survey that SFSP issues related to meal site availability, such as in  rural areas, increasing children’s participation, and program  administration were moderately to extremely challenging (see fig. 5).  Overall, 41 states reported facing at least one challenge with the SFSP,  while 9 reported facing none.

Challenges with the Availability of Meal Sites

Availability of transportation, low population density, and limited meal  sites pose challenges for SFSP in rural areas, according to states we  surveyed, selected national organizations, and state and local officials in  the three selected states we visited. More than two-thirds of states in our  survey reported they faced a moderate to extreme challenge with limited  options in rural areas to transport children to summer meal sites (37), as  well as with the distance to summer meal sites in rural areas resulting in  low child turnout that affects the financial viability of site sponsorship (36).  As officials from one national organization explained, it may not be cost- effective for sponsors to operate in remote or rural areas if there are not  enough meal sites or children participating in the program. Similarly, a  sponsor in one of the selected states indicated that there are large parts  of the state where the distances between meal sites are substantial, and  travel between them takes several hours. An official from one of the  selected states said transportation challenges can lead to underserved  rural areas, including Indian reservations. Of the three states we  reviewed, each had rural areas with few or no federally funded meal sites  in summer 2016. However, a majority of the children in some of those  areas were eligible for free or reduced price school meals, according to  Census data provided by FNS, and would therefore be “area eligible” for  the purposes of SFSP. For example, as shown in figure 6, “area eligible”  locations in rural western parts of Arizona did not have any SFSP or  Seamless Summer Option meals sites in June 2016, the month with the  greatest number of summer meals served in that state.

States and SFSP providers have responded to challenges with meal sites  in rural areas by using other meal delivery approaches—efforts that FNS  has supported through information sharing and grants. For example,  according to one national organization involved in summer meals, some  SFSP providers offer vans or buses to transport children to meal sites or  partner with local bus authorities to give children free rides to meal sites.  Instead of transporting children to sites, other sponsors transport meals to  children through mobile meal delivery, an alternative summer meal model  used in 48 states according to our survey. In this model, sponsors deliver  meals by bus, using a route with state-approved stops in a community,  and children consume the meal at the stop under a supervised setting.  According to FNS officials and representatives from national  organizations, this approach can be particularly helpful for providing  summer meals to children in rural areas. State officials in two selected  states told us they use mobile meal delivery to help fill gaps in meal  service and help children overcome the lack of transportation or  resources in their community. To serve children in very remote areas  with limited resources, a sponsor in one of the selected states reported  piloting a model involving delivering frozen meals every other week to  such areas and supplying equipment, such as freezers and microwaves,  to support meal service. To help sponsors address challenges related to  meal sites in rural areas, FNS has shared information on alternative  delivery models through its SFSP toolkit and webinars and has also  provided related grant funding. For example, in summer 2011 and 2012,  FNS funded the Meal Delivery demonstration project to provide meals to  children in rural areas where low population density, long distances, and  transportation issues made it difficult for children to get to SFSP sites,  making site and sponsor operation financially unsustainable. The  demonstration project funded meals to children in rural areas of  Delaware, Massachusetts, and New York, providing food delivery to  homes or drop-off sites near homes of eligible children.

More than half the states (30) in our survey reported they faced a  moderate to extreme challenge reaching low-income children in  communities that are not area eligible. Areas in which fewer than 50  percent of children qualify for free or reduced-price meals during the  school year are not eligible to have open summer meal sites at which all  children who come to the site can receive a free meal. As a result, some  children who are eligible for free and reduced-price meals during the  school year do not have open summer meal sites located in close  proximity to their residences, according to several national organization  officials and SFSP providers. Eligible children in these areas may instead  be limited to other types of SFSP sites, such as closed enrolled summer  meal sites, or nonfederal programs providing meals, if available. For  example, in one of the selected states, a sponsor of SFSP sites funded  meals without federal support at one site that they operated as an open  site in order to serve low-income children residing in low-income housing.  These children did not otherwise have access to a federally funded  summer meals site, according to these officials, because the broader  area was part of a school district that had a greater than 50 percent  proportion of children from higher-income families.

Recognizing that some children may reside in an area that is not area  eligible but is immediately adjacent to such an area, FNS has allowed  additional flexibility in establishing area eligibility for open meal sites.  Specifically, in 2014 and 2016 policy memos, FNS expanded the ways in  which states and sponsors can use Census data to establish area  eligibility. For example, FNS has allowed states and sponsors to average  Census data across adjacent geographic areas to determine area  eligibility. FNS noted that these additional flexibilities help ensure meal  sites can be located in more areas in which poor economic conditions  exist.

Nearly all states (50) reported in our survey that the availability of meal  sites throughout the summer months was a factor critical to the success  of the SFSP, yet more than half the states (27) also reported they faced a  moderate to extreme challenge with limited meal site days of operation.  Nineteen of the 40 states that provided information about site days of  operation reported 1 day as the shortest length of operation for SFSP  sites in their state in fiscal year 2016. Limited meal site days of  operation was a significant challenge in one of the three selected states  we visited, as almost one-quarter of sites operated for only 1 to 2 weeks  across a 2-month period in summer 2016, and an additional half of sites  operated for 3 to 4 weeks across that same period, according to our  analysis of state data. In contrast, in the other two selected states, the  majority of sites (64 and 76 percent, respectively) operated for 5 or more  weeks during a 2-month period. SFSP sites may have limited days of  operation for various reasons, such as constraints with program  administration and costs, according to interviews with a national  organization official and a sponsor in one of the selected states.

Some SFSP providers and national organizations involved in summer  meals have responded to these challenges by working to extend the days  of operation of meal sites—efforts that FNS has supported through  related grant funding. Officials from one meal site located at a school in  one of the selected states told us that 2017 was the first year the site  stayed open an additional 4 weeks after summer school classes ended in  an effort to expand participation, an extension made possible through  support from an experienced sponsor. In addition, officials from a national  organization involved in sponsoring summer meals told us they  encourage their local sites to operate in August—a month where there  are generally fewer summer meal service offerings—to meet children’s  needs. At the federal level, under its demonstration authority, FNS funded  the Extending Length of Operation Incentive project, a grant which  provided an additional 50-cent reimbursement for all lunch meals served  at sites in Arkansas in 2010 that offered meals for 40 or more days.

Challenges with Children’s Participation

Awareness of the SFSP Program and Meal Sites

Two-thirds of states (34) reported through our survey that they also faced  a moderate to extreme challenge with a lack of awareness of summer  meal sites among children and families, a challenge also mentioned by  SFSP providers in the selected states. Meal site operators in one  selected state noted that making families aware that all children may  receive a meal for free at open sites can be a challenge. For example,  one sponsor operating a meal site in a school said the perception among  some is that the meal program is only for children attending summer  school, and not for others in the community. Although that site had  outside banners and advertising to help address that misperception,  another SFSP provider explained that having sufficient funds to market  the SFSP and increase awareness among families is also a challenge.

To address these challenges, state agencies, some SFSP providers, and  FNS have taken steps to help promote awareness of the SFSP. For  example, nearly all states (47) reported in our survey that they have  increased their outreach efforts for the SFSP in the last 5 years. More  than half of states (36) also reported increases in overall SFSP  participation during that time, which they believe were related to their  outreach efforts. The majority of states in our survey reported conducting  outreach on the SFSP to groups including children, parents and  guardians, and schools, among others, using methods such as flyers,  email, newspapers, and social media (see fig. 7). Further, state agency  officials and sponsors in the selected states reported that they have  developed partnerships with state and local advocacy groups and  community leaders, among others, to promote the SFSP. For example,  one state agency official said they partner with local advocacy  organizations to field calls from parents seeking information about  summer meal sites through their hunger hotline. FNS has promoted the  use of such partnerships, as well as traditional and social media, to raise  awareness of the SFSP. In addition, FNS developed the Summer Meals  Site Finder, an online mapping tool that provides information on summer  meal sites nationwide.

Attracting children of all ages to SFSP meal sites can also be a challenge,  according to states and SFSP providers. More than half of the states (31)  reported in our survey that they faced a moderate to extreme challenge  with limited youth and teen participation at summer meal sites, and an  official from a national organization involved in the SFSP explained that it  is difficult to attract children to a meal site when the site is focused solely  on food. Similarly, 46 states in our survey reported that providing age- appropriate programming and enrichment activities for children at  summer meal sites is a factor critical to the success of the SFSP.  However, some meal sites may lack the resources to add activities,  according to some SFSP providers in the selected states as well as FNS  and national organization officials. Attracting teens can be particularly  challenging, in part because of meal service time periods, a lack of age- appropriate activities, and stigma, according to national organizations and  providers we interviewed. For example, early morning meal sites  generally attract younger kids as teens may be apt to sleep later in the  summer, and teens may also perceive a stigma in participating in a free  meal program and may face peer pressure not to eat. In addition, meal  offerings at SFSP sites may also present challenges to teen participation.  Specifically, because FNS bases minimum portion size requirements for  meals on the needs of younger children, meals are not always adequate  to meet the nutritional needs of teens, according to one sponsor we  interviewed. Across the 30 meal sites in the 3 states we visited in  summer 2016, we observed variety in the meals served during different  meal services. (see fig. 8.)

States and SFSP providers have collaborated with others and sought  specific types of sites to help provide enrichment activities and attract  certain age groups—efforts that FNS has supported through information  sharing and related grant funding. Sponsors in the selected states said  they have focused on partnerships with groups such as those focused on  youth development, churches, libraries, and police or fire departments, to  offer age-appropriate activities for children (see fig. 9). For example,  programs with local police departments, such as Cops N Kids in one  selected state, or libraries in two selected states, provided meal services  in combination with youth development or other enrichment activities.  (See sidebar for highlights on the Cops N Kids program.) One national  organization official said activities at SFSP sites can help take away the  stigma around the program because children are not just there for the  meal. Efforts to rebrand the SFSP as a community event where entire  families can participate at the meal site also can have this effect, which is  why some sponsors in the selected states said they partnered with  foodbanks to donate meals for adults. In addition, a sponsor in one  selected state told us they adjusted their meal offerings to match the  needs of children of different age groups, for example, by serving meals  to younger children earlier in the day and meals to teens later in the  day. To support participation from children of all ages, FNS has shared  information on age-appropriate activities through its SFSP toolkit and  provided related grant funding. For example, in 2010, FNS funded the  Activity Incentive demonstration project, in which sponsors in Mississippi  were provided with mini-grants to increase enrichment and recreational  activities, such as education, tutoring, sports and games, arts and other  activities, to draw children to meal sites.

More than half the states reported in our survey that they faced a  moderate to extreme challenge with limited state agency staffing (27), a  limited amount of federal funding for SFSP administration (27), as well as  ensuring sponsor participation to meet needs (28). In addition, 28 states  reported in our survey that they faced a moderate to extreme challenge  with sponsors not following program requirements. Limited staffing can  affect a state agency’s ability to conduct efforts aimed at increasing  participation, identifying potential sponsors, and reviewing and monitoring  sponsors, according to national organization and state officials we  interviewed. For example, increases in sponsors and sites requires  additional staff and time to conduct pre-approval visits, sponsor and site  reviews, vendor reviews, and technical assistance visits, which directly  affects the amount of funding needed to support staff salaries and travel  reimbursement, according to one state in our survey. However, because  the SFSP administrative funds FNS provides to states are based on the  number of meals served in the previous year, increasing the number of  staff to help increase SFSP participation is difficult, according  to a national organization official we interviewed. States reported a  moderate to extreme challenge with the following issues related to  ensuring sponsor participation: a lack of sponsors to meet summer meal  needs, a lack of awareness of the summer meal program among potential  sponsors or sites, completing federal requirements for monitoring of  SFSP sponsors, and identifying potential sponsors.

State agencies responsible for administering the SFSP reported relying  on other resources and partners to help with program administration— strategies that FNS has supported through information sharing and its  online tools. As discussed earlier, all three selected state agencies we  interviewed told us they partner with advocacy groups to help expand and  conduct outreach on the SFSP. Additionally, more than half the states in  our survey reported several factors—which may ease the administrative  burden on states—as critical to the success of the SFSP, including  partnerships with SFSP sponsors (49) and retaining sponsors and sites  over multiple summers (51). To support states’ use of alternative funding  sources to help administer the SFSP, FNS has shared information on  federal, state, and private funding and grant opportunities. FNS also  developed the online Capacity Builder tool, which 35 states reported in  our survey was moderately to extremely useful in identifying or confirming  meal site eligibility in fiscal year 2017.

States and SFSP Providers Also Reported Challenges with Meal Site Safety and Duplicative Paperwork, and FNS’s Efforts to Address These Areas Are Limited

Seventeen states reported in our survey that ensuring summer meal sites  are in safe locations was moderately to very challenging, a challenge that  some states and SFSP providers have taken steps to help address.  State officials and SFSP providers in the selected states reported that  when crime has occurred near a site, there are concerns about ensuring  children’s safety while they are consuming meals at the site, as well as  the safety of site staff delivering meals. Some sponsors noted, in  particular, parents’ concerns for the safety of their children at meal sites in  light of criminal activities in the surrounding area. To ensure children  continue to have access to meals, some sponsors noted that in the event  of an immediate threat at an outdoor meal site, site staff are sometimes  able to bring children to a nearby indoor space instead. States and SFSP  provider officials in two selected states told us they have also used other  strategies, including partnerships with local law enforcement agencies, to  help address safety concerns during the meal service and ensure children  have access to meals. For example, national organizations involved in  summer meals and sponsor officials in the selected states said they  encourage partnerships with local police departments to use police  escorts at meal sites or to follow mobile meal routes in situations where  safety at the meal site is a concern. When violence or crime has occurred  near a site, some states and SFSP sponsors have also sought flexibility  from FNS with respect to the federal requirement that children consume  summer meals on site, according to state and local officials.

FNS has used its available authorities to grant some states and sponsors  flexibility with respect to the requirement that children consume summer  meals on site, such as when safety at the site is a concern; however, FNS  has not clearly communicated to all states and sponsors the  circumstances it considers when deciding whether to grant this  flexibility. According to our review of letters FNS sent to multiple states  approving their requests for this type of flexibility, the agency identified a  consistent set of circumstances that needed to be met for it to grant this  flexibility. These circumstances were described in the letters the agency  sent to states and generally included verification that violent crime  activities occurred within both a 6-block radius of the meal site and 72  hours prior to the meal service. FNS’s letters to states indicate that  when documentation was provided to the agency showing that these  circumstances existed at a summer meals site on a particular day or  days, meals consumed by children off site on those days were eligible for  federal reimbursement. Although FNS has issued guidance on the  general processes for requesting flexibility from program requirements  under its waiver and demonstration authorities, these guidance  documents do not detail the specific circumstances that the agency  considers when deciding whether to grant flexibility from the on-site  requirement due to safety concerns. FNS has communicated this  information only in its responses to specific state and sponsor requests,  and it has not communicated these circumstances more broadly to all  states and sponsors. FNS officials explained that they review state and  sponsor requests for flexibility due to safety concerns on a case-by-case  basis. However, they also acknowledged that the set of circumstances  used for approval of state and sponsor requests for flexibility, which we  identified in their letters to states, has been used repeatedly.

Further, states and sponsors reported challenges obtaining the specific  data needed for approval of a site for this type of flexibility, hampering  some providers’ efforts to ensure safe delivery of meals. For example,  state agency and sponsor officials in one selected state said obtaining the  crime data needed to qualify for the flexibility can be an administrative  burden on sponsors, and these data are not consistently available in a  timely manner. According to state agency and sponsor officials in one of  the selected states, daily crime statistics are not available in all areas,  and while a sponsor can sometimes access current data on crime in a  city, the most recent available data on crime in suburban areas are  sometimes one year old. FNS is aware of state and local challenges  obtaining the necessary crime data, according to our discussions with  FNS officials. FNS officials acknowledged that while they have granted  some state and sponsor requests to allow children to consume meals off  site in certain areas where violence or crime has occurred, some  sponsors were unable to implement the flexibility because they could not  obtain the necessary crime data.

To help achieve agency objectives and address related risks, the  Standards for Internal Control in the Federal Government state that  agencies should communicate key information to their internal and  external stakeholders. Although FNS officials told us they do not have  one set of circumstances under which they approve these requests, our  review found only one set of circumstances under which this type of  flexibility has been approved. However, FNS has not broadly  communicated the circumstances it considers in deciding whether to  approve requests for flexibility with respect to the requirement that  children consume summer meals on site in areas with violence or crime.  Unless FNS shares this information with all states and sponsors, states  and sponsors will likely continue to be challenged to use this flexibility,  hindering its usefulness in ensuring safe summer meal delivery to  children.

In addition, FNS has issued reports to Congress evaluating some of its  demonstration projects, as required under its statutory authorities, but the  agency has not issued any such reports to Congress specifically on the  use of flexibilities with respect to the on-site requirement in areas where  safety is a concern. As previously discussed, the agency is required to  annually submit certain reports to Congress regarding the use of waivers  and evaluations of projects carried out under its demonstration  authority. Furthermore, Standards for Internal Control in the Federal  Government state that management should use quality information to  make informed decisions and evaluate the entity’s performance in  achieving key objectives and addressing risks. Yet, FNS has not  evaluated nor reported on the use of waivers and demonstration projects  in cases where safety was a concern. Although FNS requests reports  from state agencies or sponsors that have received flexibility with summer  meals delivery under FNS’s demonstration and waiver authorities, FNS  officials told us they have not assessed whether their use of these  flexibilities to address safety issues has been effective in ensuring safe  meal delivery. FNS officials told us that they have not evaluated or  reported on these flexibilities, in part, because they have limited  information on their outcomes. Without understanding the impact of its  use of these flexibilities, neither FNS nor Congress knows whether these  flexibilities are helping provide meals to children.

In addition to the challenges with safety at meal sites, sponsors also  sometimes face administrative challenges when participating in multiple  child nutrition programs that are operated by different state agencies or  divisions within the same agency, according to officials from national and  regional organizations and sponsors we interviewed. For example,  officials from national organizations involved in summer meals told us the  management of each child nutrition program and processes related to  applications, funding, and oversight are fragmented in many states. For  example, a sponsor in one of the selected states told us aspects of the  SFSP and CACFP sponsor applications are highly duplicative and  estimated it took 42 hours last year to complete duplicative paperwork.  Another sponsor that provides school meals during the school year told  us they had to fill out 60 additional pages of paperwork to provide  summer meals, which coupled with having a state contact for the SFSP  that was different from the one they worked with for the NSLP, was a  significant burden for them. Officials from one national organization told  us a lack of interoperability of some state agencies’ data systems has  caused challenges and administrative burden for some sponsors. For  example, in some states, different agencies oversee child nutrition  programs, yet are unable to share data on sponsor approval, and  therefore, sponsors are required to submit similar information to both,  according to these officials. Duplicative paperwork can be particularly  burdensome for some SFSP providers, as national organization officials  and SFSP providers in the selected states said completing SFSP  application paperwork can be especially challenging when a sponsor has  staff shortages or no dedicated SFSP staff.

Some selected states have worked with SFSP sponsors to help minimize  the administrative burden. For example, state agency officials from one of  the selected states said they have connected less-experienced sponsors  to more-experienced sponsors in the community to help them with  program administration. In one case, an experienced SFSP sponsor  partnered with a small sponsor new to the program to help with SFSP  administration, including helping them understand program rules and  paperwork requirements. One SFSP sponsor also noted that their state  agency took additional steps to ease administrative burden, such as  making the forms for the CACFP more consistent with those for the SFSP  and streamlining certain requirements for large and experienced  sponsors, which the sponsor found helpful.

At the federal level, FNS has established program and policy  simplifications to help lessen the administrative burden on sponsors  participating in multiple child nutrition programs, though the persistence of  these challenges indicate that information about these simplifications has  not reached all relevant state agencies. While FNS officials told us that  some of the duplicative requirements may be a function of differences in  statute, FNS provided guidance to states in 2011 and 2014 on simplified  application procedures for institutions participating in CACFP that also  wish to apply for SFSP. FNS noted in its guidance that in states where  CACFP and SFSP are administered by different state agencies, state  agencies are encouraged to work together to share information and  streamline the application and agreement process as much as possible.  FNS also addressed these simplifications in a state agency meeting in  November 2017. Additionally, FNS provided guidance to states in 2012  on simplified application and review procedures for school food  authorities participating in the NSLP that wish to also participate in the  SFSP. Although FNS has shared this information with states in an  attempt to make them aware of streamlining options, FNS officials noted  that some states may choose not to implement them.

Standards for Internal Control in the Federal Government state that  management should externally communicate the necessary quality  information to achieve the entity’s objectives, as well as periodically  evaluate the methods of communication to ensure communication is  effective and appropriate. FNS’s existing guidance addresses options  for streamlining administrative requirements for sponsors participating in  multiple child nutrition programs. However, information on program and  policy simplifications available for sponsors participating in both NSLP  and SFSP has not been shared with states recently, and challenges in  this area persist, indicating this information has not reached all relevant  state agencies. Without further efforts from FNS to disseminate  information on current options for streamlining administrative  requirements across child nutrition programs, overlapping and duplicative  administrative requirements may limit children’s access to meals by  discouraging sponsor participation in child nutrition programs.

The purpose of the SFSP is to continue to provide children in low-income  areas with nutritious meals over the summer when school is no longer in  session, and to that end, the program provided 149 million SFSP meals to  children in fiscal year 2016. Although meals served are one indicator of  participation, FNS’s current estimates of children participating in SFSP  are unreliable. Without additional understanding of children’s participation  in the SFSP, FNS lacks information critical for informing program  implementation, strategic planning, and outreach.

The majority of states nationwide and SFSP providers in the three states  we visited reported experiencing a number of challenges with the SFSP,  and FNS has taken important steps to address these challenges. Two key  challenges identified by officials in the selected states and national  organizations we interviewed are ensuring summer meal sites are in safe  locations, and meeting administrative requirements when participating in  multiple child nutrition programs. FNS has taken steps to address these  challenges by providing flexibilities in how meals are delivered to children  and streamlining options for those providers participating in more than  one child nutrition program. However, a lack of clarity concerning the  circumstances under which FNS grants flexibilities in areas of violence  and crime, and a lack of information on its use of these flexibilities and  their impact on program administration, hinder efforts to ensure program  goals are met. Furthermore, absent a reminder to states regarding  existing options for streamlining administration across multiple nutrition  programs, some providers may continue to be discouraged from  participating in these programs due to duplicative and burdensome  administrative requirements, which may ultimately limit the provision of  nutritious meals to children.

We are making the following four recommendations to FNS:  The Administrator of FNS should improve its estimate of children’s  participation in the SFSP by focusing on addressing, at a minimum, data  reliability issues caused by variations in the number of operating days of  meal sites and in the months in which states see the greatest number of  meals served. (Recommendation 1)

The Administrator of FNS should communicate to all SFSP stakeholders  the circumstances it considers in approving requests for flexibility with  respect to the requirement that children consume SFSP meals on-site in  areas that have experienced crime and violence, taking into account the  feasibility of accessing data needed for approval, to ensure safe delivery  of meals to children. (Recommendation 2)

The Administrator of FNS should evaluate and annually report to  Congress, as required by statute, on its use of waivers and demonstration  projects to grant states and sponsors flexibility with respect to the  requirement that children consume SFSP meals on-site in areas  experiencing crime or violence, to improve its understanding of the use  and impact of granting these flexibilities on meeting program goals.  (Recommendation 3)

The Administrator of FNS should disseminate information about existing  flexibilities available to state agencies to streamline administrative  requirements for sponsors participating in the SFSP and other child  nutrition programs to help lessen the administrative burden. For example,  FNS could re-distribute existing guidance to state agencies that explains  available flexibilities and encourage information sharing.  (Recommendation 4)

We provided a draft of this report to the Secretary of the USDA for review  and comment. FNS officials provided technical comments, which we  incorporated as appropriate. In addition, in oral comments, FNS officials,  including the Deputy Administrator for Child Nutrition Programs, generally  agreed with the recommendations in the report.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the Secretary of the  USDA and interested congressional committees. The report will also be  available at no charge on the GAO website at www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-7215 or larink@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made key contributions to this report are  listed in appendix IV.

This appendix discusses in detail our methodology for addressing three  research objectives: (1) What is known about participation in the Summer  Food Service Program (SFSP) and how has it changed in the last 10  years? (2) What other programs help feed low-income children over the  summer? and (3) What challenges exist, if any, in providing summer  meals to children, and to what extent does the U.S. Department of  Agriculture’s (USDA) Food and Nutrition Service (FNS) provide  assistance to states and sponsors to address these challenges? In  addition to the methods we discuss below, to address all three research  objectives, we reviewed relevant federal laws, regulations, and guidance;  interviewed FNS officials in its headquarters and seven regional offices;  and interviewed a broad range of regional and nationwide organizations  involved in the SFSP. In addition, we coordinated with officials in USDA’s  Office of Inspector General on their ongoing work in this area.

To address our first objective about participation in the SFSP, we  analyzed FNS data on meals served for fiscal years 2007 through 2016.  Specifically, we analyzed the total number of meals served nationwide  through the SFSP from fiscal year 2007 through fiscal year 2016. Each  month, states report to FNS the number of meals served by meal type  (breakfast, lunch, snack, and supper) and the number of meals served by  meal and sponsor type (e.g., government, nonprofit, etc.) using the FNS- 418 form. To add context on these trends, we also analyzed and  compared the number of SFSP lunches served in July with the number of  free and reduced-price lunches served to children in March through the  National School Lunch Program (NSLP), the largest child nutrition  assistance program, from fiscal year 2007 through fiscal year 2016.  Each month, states report to FNS the number of meals served through  the NSLP using the FNS-10 form. To assess the reliability of SFSP and  NSLP data, we (1) performed electronic testing of relevant data elements,  (2) reviewed existing information about the data and the system that  produced them, and (3) interviewed agency officials knowledgeable about  the data. Electronic testing included, but was not limited to, checks for  missing data elements, duplicative records, and values outside a  designated range or valid time period. We determined that these data  were sufficiently reliable to identify the number of SFSP meals served and  assess change over time.

To further examine what is known about participation in the SFSP, we  also reviewed FNS’s data on estimates of children’s participation in the  program and determined that these estimates have been calculated  inconsistently and are unreliable. To assess the reliability of these data,  we reviewed documentation about the estimates, interviewed FNS  officials, and asked states about the estimate calculation in our survey. As  described in our findings, FNS does not collect data on the number of  children participating in the SFSP. Instead, FNS relies on states’  estimates of children’s participation, which are based on other data  reported by sponsors, such as the number of meals served and meal  service days in July.

To address our second objective about other programs that help feed  children in the summer, we reviewed FNS’s estimate of the number of  meals served through the NSLP’s Seamless Summer Option in fiscal year  2016. FNS does not collect data on the number of meals served through  the Seamless Summer Option. Instead, FNS annually estimates the  number of Seamless Summer Option meals served nationally by  aggregating the number of free and reduced-price breakfasts, lunches,  and snacks served through the School Breakfast Program (SBP) and  NSLP in July. As previously noted, states report these data monthly to  FNS. Although FNS does not know the actual number of meals served  through the Seamless Summer Option, agency officials told us they  believe the number of summer meals provided through the NSLP is small  relative to the number of meals served through the Seamless Summer  Option during the summer months. They noted that their use of July  NSLP data to estimate the Seamless Summer Option meals likely  overestimates the number of these meals for July and underestimates the  number of these meals for the entire summer. To assess the reliability of  the July NSLP data, we (1) performed electronic testing of relevant data  elements, (2) reviewed existing information about the data and the  system that produced them, and (3) interviewed agency officials  knowledgeable about the data. Electronic testing included, but was not  limited to, checking for missing data and data that fell outside of a  reasonable range or date for the specific time period (July). We  determined that these data were sufficiently reliable to describe the  number of meals served.

In addition to the data FNS requires states to report, some states collect  summer meals data at the meal site level and we used such data from the  three selected states to address all three objectives. For objective one, to  examine the number of meals served and days of operation at each  summer meals site, we analyzed site-level data for 2 months from  summer 2016, including the month with the largest number of SFSP  meals served in each selected state: Arizona (June and July 2016),  Illinois (July and August 2016), and Massachusetts (July and August  2016). Each state also provided us with data on the number and types of  meals served at each SFSP site, the site location, and the duration of  time each site operated over the summer. Using the data provided by the  states, we calculated the average daily attendance (ADA) for each meal  site based on FNS’s instructions and examined the variation in ADA  across sites and months. For our second objective on other programs,  these selected states provided similar site level data for the state’s  Seamless Summer Option sites, if applicable. We assessed the reliability  of these data by (1) performing electronic testing of relevant data  elements, (2) reviewing existing information about the data and the  system that produced them, and (3) interviewing agency officials  knowledgeable about the data. We determined that the data were  sufficiently reliable for the purposes of this report.

For both our second objective on other programs and third objective  about challenges in providing summer meals to children, we also  examined meal site availability in the three selected states by mapping  the locations of meal sites. On the maps, we included fiscal year 2016  area eligibility data from FNS’s Capacity Builder mapping tool, as  provided by FNS. The site area eligibility data from FNS’s Capacity  Builder is based on the U.S. Census Bureau’s 5-Year American  Community Survey (ACS) estimates of children ages 0-12 and 0-18  eligible for free and reduced-price meals by Census block group and  tract. According to FNS officials, FNS obtains 5-Year ACS estimates  annually from the U.S. Census Bureau and updates its site area eligibility  in the Capacity Builder accordingly. For fiscal year 2016, FNS used 2009- 2013 ACS data to identify and include site area eligibility in its Capacity  Builder.

To help inform all of our research objectives, we conducted a survey of  the state agencies that oversee the SFSP in the 50 states and the District  of Columbia. We administered our web-based survey between August  and October 2017 and received 100 percent response rate. The survey  included questions about participation in the SFSP, factors critical to the  overall success of the SFSP, outreach efforts, federal technical  assistance, barriers and challenges in providing summer meals,  alternative summer feeding models, the NSLP’s Seamless Summer  Option and the federal Summer Electronic Benefit Transfer for Children  demonstration, and nonfederal programs that provide children of low- income households with meals during the summer months. The survey  also requested data on SFSP sites participating in the program in fiscal  year 2016 and the method state agencies used to calculate ADA in SFSP  on the FNS-418 form in fiscal year 2016.

Because this was not a sample survey, there are no sampling errors.  However, the practical difficulties of conducting any survey may introduce  nonsampling errors, such as variations in how respondents interpret  questions and their willingness to offer accurate responses. We took  steps to minimize nonsampling errors, including pretesting draft  instruments and using a web-based administration system. Specifically,  during survey development, we pretested draft instruments with SFSP  staff from four states (Michigan, New Mexico, North Carolina, and South  Dakota) in May 2017. We selected the pretest states based on  information provided by officials from FNS’s regional offices and national  organizations involved in summer meals about state administration of  summer meals programs, with the goal of selecting a group of states with  varied experiences. In the pretests, we were generally interested in the  clarity, precision, and objectivity of the questions, as well as the flow and  layout of the survey. For example, we wanted to ensure definitions used  in the surveys were clear and known to the respondents, categories  provided in close-ended questions were complete and exclusive, and the  ordering of survey sections and the questions within each section were  appropriate. We revised the final survey based on pretest results. Another  step we took to minimize nonsampling errors was using a web-based  survey. Allowing respondents to enter their responses directly into an  electronic instrument created a record for each respondent in a data file  and eliminated the need for and the errors associated with a manual data  entry process. We did not fully validate specific information that states  reported through our survey.

To help inform all of our objectives and gather information about the  SFSP directly at the local-level, we conducted 30 site visits in three  states: Arizona (12 sites), Illinois (8 sites), and Massachusetts (10 sites)  between June and July 2017, and interviewed organizations involved with  the SFSP in each site visit state. We used U.S. Census Bureau data to  select states and local areas within those states based on a high  proportion of children in poverty, a mix of urban and rural locations, as  well as a mix of sponsor and site type and diverse locations. We visited a  wide variety of site locations including, but not limited to, schools, parks,  community recreation areas, and libraries.

At each SFSP site, we gathered information on local level factors related  to SFSP participation and administration by interviewing the organization  sponsoring the site, the site operators and staff, and those participating at  the site using semi-structured questions. While interviewing SFSP  sponsor organizations, we collected information on the sponsors’ roles in  the SFSP, characteristics of the sites the organizations sponsored,  outreach efforts, any challenges or barriers to SFSP administration and  any efforts to address such challenges, relationships with the state  agencies that administer the SFSP, relationships with FNS (national and  regional offices), and the availability of nonfederally funded programs that  provide meals to low-income children over the summer. During the  interviews with site operators and staff, we collected information about  site operation (e.g., site operating days, meals offered, etc.), any  challenges to providing SFSP meals to children and any efforts to  address such challenges, outreach efforts, and the proximity of the next  closest meal site. The information we collected from those participating at  the sites included their perspectives on the SFSP food, site food  consumption habits, ease of travel to the site, and access to other SFSP  sites. At each site, we made observations as to how the food was  provided to the children, food consumption and waste, the approximate  age range of the children being served, and availability of programs or  activities (e.g., recreational sports).

Using semi-structured questions, we also interviewed the state agencies  responsible for administering the SFSP in the site visit states to gather  further information on how the SFSP is administered in each state,  statewide participation in the program, related data collection activities,  any challenges to administering the program and any efforts to address  such challenges, related outreach efforts, alternative meal delivery  models being employed by SFSP sponsors, FNS guidance or technical  assistance, and the availability of nonfederally funded programs that  provide meals to low-income children over the summer.

Appendix II: Select Questions and Responses from GAO’s Summer Food Service Program (SFSP) Survey

For states that indicated there were other challenge(s), we provided an open-ended question that  requested a description of the challenge(s) and 14 states provided descriptions of other challenges,  not shown here.

For states that indicated there were other challenge(s), we provided an open-ended question that  requested a description of the challenge(s) and 8 states provided descriptions of other challenges,  not shown here.

Appendix III: Area Eligibility and Summer Meal Sites in Selected States

Appendix IV: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Rachel Frisk (Assistant Director),  Claudine Pauselli (Analyst-in-Charge), Melissa Jaynes, and Matthew  Nattinger made key contributions to this report. Also contributing to this  report were Susan Aschoff, Sarah Cornetto, Ying Long, Jean McSween,  Mimi Nguyen, Almeta Spencer, and Ashanta Williams.