Recently, USDA received anecdotal information concerning technical problems and improper use of commercial software resulting in the submission of inaccurate claims for reimbursement in the School Nutrition Programs.  Additional information indicates that the commercial software may also be linked to breaches in the confidentiality of students' meal application information.

        School food authorities (SFAs) are encouraged to use technology to improve their management of the Child Nutrition Programs, including the School Nutrition Programs.  We recognize that technology can improve efficiency and accuracy.  However, pursuant to federal law, each SFA is fully responsible for proper program management, accurate income eligibility applications and claims, maintenance of confidential information in a secure manner, and ensuring that computer and software programs function properly.

        The National School Lunch (the Act) limits the use and disclosure of confidential student application and eligibility information.  Additional, the Act provides that reimbursement may be made only for meals actually served to eligible participants.  Your system must be able to determine the eligibility category accurately for all meals claimed by category.

        A program where parents apply on-line to a third-party website that processes the application and transmits the data to the district may result in inaccurate and/or unallowable free and reduced price approvals.  Districts using these systems should discuss this with their vendor and confirm with the State Agency whether the process they are using complies with federal law.

        This memo is a reminder that each SFA is responsible for guaranteeing the accuracy of any electronic application technology (including electronic signatures) and of its claims for reimbursement, as well as for ensuring that free and reduced price eligibility information remains confidential.  We recommend that you take the time to evaluate your system to ensure it is capturing your data accurately and completely.  Any questions about your system should be referred to the vendor.

        Thank you for your attention to this matter.