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State compliance manager summarizes USDA memos, waivers and Medicaid direct-certification rules
Summary
Rhonda Mead, senior compliance and data manager, reviewed administrative and procurement reviews, clarified how Medicaid data intersects with direct certification for free/reduced-price meals, and summarized three recent USDA policy memos and approved prospective waivers for non‑congregate service.
Rhonda Mead, senior compliance and data manager for Tennessee school nutrition, briefed participants on administrative and procurement reviews for the year and walked through recent USDA policy memos and available waivers. She also clarified how Medicaid/TennCare data are used for direct certification for free and reduced-price meal eligibility.
Mead said reviews have begun and that lead reviewers will contact SFAs that have not yet scheduled reviews. "We have fully completed 19 CEP/ISP validation reviews, and we have 17 more in progress," she said, and added that some closing letters had recently arrived after the slide was created.
On direct certification, Mead explained the mechanics: "In order to be directly certified for free or reduced price meals because of participation in Medicaid, the student must be found on the data list downloaded from TMAC. ... Medicaid varies depending on different conditions and groupings. Some groups can receive Medicaid and be at 250% of the federal poverty level." She emphasized that some students who have TennCare or Medicaid benefits may not meet the income thresholds for free or reduced-price meals and therefore may not appear on the direct-certification list.
Mead summarized three USDA policy memoranda: SP 16-20-25 (Fresh Fruit and Vegetable Program funding for FY2026), SP 17-20-25 (reimbursement for off-site meal consumption), and SP 18-20-25 (fees for electronic payment services). She highlighted key points from SP 17-20-25: meals provided for off-site, school-related activities must occur during typical meal times, meet meal-pattern requirements and observe food-safety considerations, and SFAs must ensure a child receives only one reimbursable breakfast and lunch per school day.
Regarding electronic payment services, Mead said SP 18-20-25 allows SFAs to charge families fees for third‑party electronic payment services only if the district also provides a free, accessible method to add money to student meal accounts and clearly notifies families about options and fees. She advised districts to maintain methods to accept cash or check so families without bank access can deposit funds.
Mead said the department requested and received USDA approval for prospective waivers that allow non‑congregate meal service, flexible meal times, parent/guardian pick-up and other flexibilities under the Seamless Summer Option and NSLP/SBP during unanticipated closures or when virtual learning is occurring "when safe and practical," noting the department is updating guidance following a state-law change about virtual learning requirements. She encouraged districts to contact their regional consultant to pursue waivers, which require a general waiver form submission.
No formal votes or motions were taken during the compliance briefing; the presentation provided procedural guidance, federal-policy summaries and instructions for follow-up with regional staff.
