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. Although almost half of the total increase in meals served in the summer months was due to increases in lunches, 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). The increase in SFSP meals over this time period was generally consistent with increases in the number of meals served in the National School Lunch Program (NSLP), the largest child nutrition assistance program, during this period. Although states reported the actual number of SFSP meals served to FNS for reimbursement purposes, they estimated the number of children participating in SFSP, and these participation estimates have been calculated inconsistently, impairing FNS’s ability to inform program implementation and facilitate strategic planning and outreach to areas with low participation. Specifically, state agencies calculated 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, according to our review of states’ survey responses and FNS documents, states’ methods for calculating ADA have differed from state to state and from year to year. 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 calculated ADA using only meals served at lunch. In addition, 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, even if consistently calculated, remained an unreliable estimate of children’s daily participation in SFSP for at least two reasons. First, ADA did not account for existing variation in the number of days that each site serves meals to children. Specifically, because FNS’s instructions indicated that sites’ ADAs were to be combined to provide a statewide ADA estimate, differences in the number of days of meal service at each site were disregarded. As a result, ADA did not reflect the average number of children served SFSP meals daily throughout the month. Second, ADA was an unreliable estimate of children’s participation in SFSP because it did not account for state variation in the month with the greatest number of SFSP meals served. According to FNS officials, the agency instructed states to calculate ADA for July because officials identified this as the month with the largest number of meals served nationwide. However, according to our analysis of nationwide FNS data, in summer 2016, 26 states served more SFSP meals in June or August than in July. Although FNS had taken some steps to identify other data that states collect on the SFSP, at the time of our May 2018 report, FNS had 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 collected any SFSP data that were not reported to FNS, and received responses from 15 states. The responses suggested some states collected additional data, such as site-level data, that may allow for an improved estimate of children’s SFSP participation, potentially addressing the issues identified in our analysis. FNS also followed up with several of these states in 2016 and 2017 to explore the feasibility of collecting additional data and improving estimates of children’s SFSP participation. FNS stated in a May 2017 memo to states 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. Yet, at the time of our report, FNS had not taken further action to improve the estimate. In our May 2018 report, we concluded that FNS’s limited understanding of children’s participation in the SFSP impaired its ability to both inform program implementation and facilitate strategic planning and outreach to areas with low participation. To improve FNS’s estimate of children’s participation in the SFSP, we recommended that FNS focus 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. FNS generally agreed with this recommendation. Other federal and nonfederal programs that operate solely in the summer, as well as those operating year-round, helped feed low-income children in the summer months. For example, in 2016, FNS data indicated about 26 million meals were served through the NSLP’s Seamless Summer Option, a separate federal program that streamlines administrative requirements for school meal providers serving summer meals. Some children also received summer meals through nonfederal programs operated by entities such as faith-based organizations and foodbanks, though the reach of these efforts was limited, according to our state survey and interviews with providers and national organizations at the time of our report. For example, of the 27 states that reported in our survey awareness of the geographic coverage of these nonfederal programs, 11 states indicated that they operated in some portions of the state—the most common state response. States and SFSP providers reported challenges with issues related to meal site availability, children’s participation, and program administration, though federal, state, and local entities had taken steps to improve these areas. For example, a lack of available transportation, low population density, and limited meal sites posed challenges for SFSP implementation in rural areas, according to states we surveyed, selected national organizations, and state and local officials in the three states we visited. In response, state and local entities took steps, such as transporting meals to children by bus, to address these issues—efforts that FNS supported through information sharing and grants. States and SFSP providers also reported challenges with meal site safety, and FNS’s efforts to address this area were limited. Seventeen states reported in our survey that ensuring summer meal sites are in safe locations was moderately to very challenging. Some states and sponsors took steps to help address this issue, and FNS also 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, our review of FNS documentation showed FNS had not clearly communicated to all states and sponsors the circumstances it considers when deciding whether to grant this flexibility. These circumstances—described in letters the agency sent to requesting states—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. Although FNS officials explained that they reviewed state and sponsor requests for flexibility due to safety concerns on a case-by-case basis, they also acknowledged that the set of circumstances they used to approve state and sponsor requests for flexibility, which we identified in their letters to states, had been used repeatedly. Further, states and sponsors reported challenges obtaining the specific data needed for approval of a site for this type of flexibility, including inconsistent availability of timely data, which hampered some providers’ efforts to ensure safe delivery of meals. We concluded that unless FNS shared information with all states and sponsors on the circumstances it considered when deciding whether to grant flexibility with respect to the requirement that children consume summer meals on site, states and sponsors would likely continue to be challenged to use this flexibility, hindering its usefulness in ensuring safe summer meal delivery to children. We therefore recommended that FNS 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. FNS generally agreed with this recommendation. We also found that while FNS had issued reports to Congress evaluating some of its demonstration projects, as required under its statutory authorities, the agency had not issued any such reports to Congress specifically on the use of flexibilities with respect to the on-site requirement in areas where safety was 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. FNS officials told us that they had not evaluated or reported on these flexibilities, in part, because they had limited information on their outcomes. We concluded that without understanding the impact of its use of these flexibilities, neither FNS nor Congress knew whether these flexibilities were helping provide meals to children—the goal of the program. Accordingly, we recommended that FNS 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 understanding of the use and impact of granting these flexibilities on meeting program goals. FNS generally agreed with this recommendation. Although FNS had established program and policy simplifications to help lessen the administrative burden on sponsors participating in multiple child nutrition programs, challenges in this area persisted, indicating that information had not reached all relevant state agencies. According to officials we spoke with from a national organization involved in summer meals, management of each child nutrition program and the processes related to applications, funding, and oversight were fragmented in many states. For example, in one of the states we visited, a sponsor that provided school meals during the school year told us they had to fill out 60 additional pages of paperwork to provide summer meals, which they described as significant burden. FNS officials told us that some of the duplicative requirements might have been a function of differences in statute, and although FNS provided guidance to states on simplified procedures for sponsors participating in more than one child nutrition program, some states might have chosen not to implement them. We concluded that without further efforts from FNS to disseminate information on current options for streamlining administrative requirements across multiple child nutrition programs, overlapping and duplicative administrative requirements may limit children’s access to meals by discouraging sponsor participation in child nutrition programs. We recommended that FNS disseminate information about the existing streamlining options, and FNS generally agreed with this recommendation. Chairman Rokita, Ranking Member Polis, and Members of the Subcommittee, this concludes my prepared statement. I would be pleased to respond to any questions you may have at this time. If you or your staff have any questions about this testimony, please contact Kathryn A. Larin 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 statement. Individuals who made key contributions to this testimony include Rachel Frisk, Melissa Jaynes, and Claudine Pauselli. This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.

Summary: This testimony summarizes information contained in GAO's May 2018 report entitled Summer Meals: Actions Needed to Improve Participation Estimates and Address Program Challenges , GAO-18-369 . It addresses (1) what is known about SFSP participation, (2) other programs that help feed low-income children over the summer, and (3) challenges in providing summer meals to children and the extent to which USDA provides assistance to address these challenges. For its May 2018 report, GAO reviewed relevant federal laws, regulations, and guidance; analyzed USDA's SFSP data for fiscal years 2007 through 2016; and surveyed state agencies responsible for administering the SFSP in 50 states and the District of Columbia. GAO also 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, and analyzed meal site data from these 3 states. In addition, GAO interviewed USDA, state, and national organization officials, as well as 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, according to GAO's May 2018 report. GAO noted that the U.S. Department of Agriculture (USDA) directed states to use the number of meals served, along with other data, to estimate the number of children participating in the SFSP. However, GAO found that participation estimates had 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 directed states to use would continue to provide unreliable estimates of participation, hindering USDA's ability to use them for these purposes. Other federal and nonfederal programs helped feed low-income children over the summer to some extent, according to states GAO surveyed and SFSP providers and others GAO interviewed for its May 2018 report. For example, GAO found that in July 2016, about 26 million meals were served through a separate federal program that allowed school meal providers to serve summer meals, according to USDA data. Some children also received summer meals through nonfederal programs operated by faith-based organizations and foodbanks, though GAO's state survey and interviews with SFSP meal providers and national organizations indicated the reach of such efforts was limited. In GAO's May 2018 report, states and SFSP meal providers reported challenges with issues related to meal sites, participation, and program administration, though USDA, state, and local officials had taken some steps to address these issues. Seventeen states in GAO's survey and several providers in the states GAO visited reported a challenge with ensuring meal sites were in safe locations. To address this issue, USDA granted some states and providers flexibility from the requirement that children consume meals on-site. However, GAO found that USDA had not broadly communicated the circumstances it considered when granting this flexibility or reported to Congress on the use of flexibilities with respect to the on-site requirement in areas where safety was a concern, per requirements. As a result, neither USDA nor Congress knew whether these flexibilities were helping provide meals to children and meeting program goals. Further, officials from national and regional organizations GAO interviewed, as well as providers GAO visited, reported challenges related to the administrative burden associated with participating in multiple child nutrition programs. Although USDA had established program and policy simplifications to help lessen related burdens, the persistence of challenges in this area suggested that information had not reached all relevant state agencies, potentially limiting children's access to meals by discouraging provider participation. In its May 2018 report, GAO made four recommendations, including that USDA improve estimates of children's participation in SFSP, communicate the circumstances it considers when granting flexibilities to ensure safe meal delivery, evaluate and annually report to Congress on its use of waivers and demonstration projects when granting these flexibilities, and disseminate information about existing flexibilities available to streamline administrative requirements for providers participating in multiple child nutrition programs. USDA generally agreed with GAO's recommendations.