THE STATE EDUCATION DEPARTMENT / THE UNIVERSITY OF THE STATE OF NEW YORK / ALBANY, NY 12234
Office of P-20 Education Policy
SFAs have asked if the American Recovery and Reinvestment Act (ARRA) Food Service Equipment Assistance Grant, the National School Lunch Program (NSLP) Equipment Assistance Grants and the Fresh Fruit and Vegetable Program (FFVP) grant are included in the child nutrition cluster.
The child nutrition cluster consists of the: School Breakfast Program CFDA 10.553, National School Lunch Program CFDA 10.555, Special Milk Program CFDA 10.556 and the Summer Food Service Program CFDA 10.559.
The FFVP, which is coded CFDA 10.582, and the ARRA Food Service Equipment Assistance Grant, coded CFDA 10.579, and the NSLP-Equipment Assistance grants coded CFDA 10.579 are not part of the child nutrition cluster.
This is because clustered programs must both be closely related and share common compliance requirements. (See definition of "Cluster of programs" at 7 CFR section 3052.105.) The programs in the CN Cluster are there because they share a common business model: They exist to provide nutritious meals to eligible children; and are open-ended entitlement programs funded according to the number of eligible meals (by category and type) that they serve. The FFVP, the NSLP Equipment Assistance Grant and the ARRA food service equipment assistance do not work that way. They are close-ended grants with fixed budgets.
Since these grants are separated from the child nutrition cluster, receiving funds from one and/or both of these programs may put the SFA above the $500,000 threshold which will require the SFA to conduct an organization-wide audit in accordance with OMB Circular A-133, instead of a program specific audit. Any recipient that expends $500,000 or more in Federal funds must conduct a Single Audit in accordance with A-133.
This additional audit requirement may require you to reconsider your interest in applying for or accepting these grant funds.