Tennessee DOE explains rules, applications for rural noncongregate summer meals

NASHVILLE — The Tennessee Department of Education on a statewide training described operational and reporting rules for the Seamless Summer Option (SSO) rural noncongregate feeding model and said sponsors must complete a new supplemental application before their TMAC site applications can be approved.

Rhonda Mead, senior data and compliance manager for the department’s School Nutrition Program, led the training and said the supplemental online form is required so the state can collect data the TMAC application does not capture for monthly reporting to the U.S. Department of Agriculture (USDA). “We have reporting requirements that are due to USDA that are not captured within your TMAC site application,” Mead said.

The guidance matters because it affects how school food authorities (SFAs) can distribute meals to children under 18 during summer months and how they will be reimbursed. Rural noncongregate operations change where and how meals can be distributed, what records sponsors must keep and how claims must be filed.

Mead reviewed the major requirements attendees need to meet to operate rural noncongregate SSO sites. A site must be both area eligible (poverty indicators such as school-level free/reduced-price meal percentages or qualifying census block data) and classified as rural under USDA mapping. For school-attendance-area eligibility, a site may qualify if it is in the attendance area of a school where at least 50% of enrolled students are eligible for free or reduced-price meals; Community Eligibility Provision (CEP) sites must use the individual site’s identified student percentage multiplied by 1.6, not a group average.

Sponsors may also use USDA and third-party census maps to check eligibility. Mead noted map tools recently changed their color schemes and urged sponsors to verify addresses in multiple ways if a site falls near a rural/nonrural boundary. She said the department will consider rural pocket requests but that none submitted last year were approved by USDA and cautioned sponsors not to rely on pocket approvals.

Mead described several permitted noncongregate models and key limits:

- Unitized meals (individually portioned) may be provided for up to 10 days at once on a case-by-case basis; the department discouraged routine 10-day distributions because of tracking complexity. - Bulk meal packages (components provided in larger quantities) generally may not exceed five calendar days without state-agency approval; the supplemental application asks whether a site will provide bulk meals and which components will be bulk. - Conditional noncongregate sites may be established in rural areas that are not area eligible, but sponsors must maintain individual child eligibility records and provide non-federal funds for paid meals so the program does not “overtly identify” eligible students. Mead said she is still clarifying how USDA intends this to work in practice.

Meal-pattern and food-safety requirements remain the same as other SSO and National School Lunch Program (NSLP) rules. Sponsors must follow USDA meal-pattern regulations (7 CFR parts 210 and 220) for required components, portion sizes and vegetable subgroup requirements; at least one milk option must be unflavored. Meal counts must be taken at the point of service; only one reimbursable meal may be claimed per child per meal service. Sponsors operating noncongregate sites must complete separate production records for each reimbursable meal type distributed (for example, separate records for breakfast and lunch when both are included in a pack).

Mead walked through methods to maintain program integrity when distributing multiple-day packs: tally sheets that record one tally per child per distribution (then multiplied by consumption days), rosters or sign-in sheets, QR-code sign-in options and parent/guardian verification. Parent or guardian pickup is permitted but the department said proxy pickup is not allowed; home delivery is permitted only with written parental consent, must be offered to all eligible students (not a subset), and each delivery address along a route must itself be classified as rural.

Monitoring and reporting: each noncongregate site must be monitored at least once while operating, and state administrative reviews will include noncongregate operations if the SFA operated SSO in the summer following its regular review. Mead said SFAs operating rural noncongregate must submit site-based claims (not consolidated SFA-level claims) while the noncongregate operation is active; SFAs may revert to consolidated claiming at the school year start if appropriate.

Application process: Mead said the state is switching the supplemental form from a fillable PDF to a web form with conditional logic that will show bulk, parent-pickup and home-delivery questions only when applicable. The supplemental application will be reviewed by departmental staff (Mead said the supplemental forms will be received and reviewed by Latrice), and once approved SFAs can have their TMAC noncongregate site application approved. The supplemental form includes an attestation for bulk-meal requirements. Mead estimated the form’s approval by department leadership within days of the training but cautioned the vendor-driven TMAC screens will change again within the coming months as the department updates reporting fields.

Policy references and resources mentioned during the training included USDA implementation memos and the federal regulation definition of rural (7 CFR 225.2), recent USDA policy memos cited by Mead (labeled in the presentation as SP 05-2024, SP 06-2024, SP 13-2024, SP 15-2024 and SP 08-2025), USDA online rural and census maps and No Kid Hungry resources for program-integrity tools. Mead said the department will post the training slides and a recording on the department’s Teach All site and review the material again at regional trainings.

“Noncongregate feeding is clear as mud, just like a lot of things we enjoy with USDA requirements,” Mead said near the end of the session, and invited attendees to email follow-up questions.

Contacts and next steps: the department asked SFAs to submit a supplemental application for each rural noncongregate site, to convert to site-based claims while operating noncongregate feeding, and to work with regional consultants for questions on area eligibility and monitoring. Mead gave her contact information during the session and said the training will be repeated in regional meetings and posted online.