Meal Charge Policies (MI)

To Whom It May Concern:

I. Background Information

On July 8, 2016, the U.S. Department of Agriculture (USDA) Food and Nutrition Service sent a memorandum to all state directors of child nutrition programs entitled, "Unpaid Meal Charges: Local Meal Charge Policies." That memorandum is available here: https://fns-prod.azureedge.net/sites/default/files/cn/SP46-2016os.pdf.

The memorandum set a July 1, 2017 deadline for all school food authorities (SFAs) operating the National School Lunch Program (NSLP) or School Breakfast Program (SBP) to have a written meal charge policy. This policy would apply to children who lack money for school meals at the full or reduced rate. Policies may be set by the state or by SFAs. According to the USDA's memorandum, "Policies developed at the SFA level must be provided to the State agency during the Administrative Review."

II. Requested Records

Pursuant to the Michigan Freedom of Information Act, I hereby request the following records:

1. A copy of any state-level meal charge policies to be implemented by all school food authorities (SFAs) operating the National School Lunch Program (NSLP) or School Breakfast Program (SBP) in the state.
2. Copies of meal charge policies developed by school food authorities and provided to the state, as directed by the USDA's July 2016 memorandum.
3. Copies of any spreadsheets that list the state's Local Educational Agencies (LEAs) that currently participate in the Community Eligibility Provision (CEP), Provision 2, or Provision 3 on a districtwide basis. Two examples are available at http://www.state.nj.us/agriculture/divisions/fn/pdf/Approved%20CEP%20LEAs%20SY_2017-2018.pdf and https://dpi.wi.gov/sites/default/files/imce/school-nutrition/pdf/cep-participating-schools-and-districts-1718.pdf. I prefer these in electronic, machine-readable file formats, such as CSV or XLS, though PDF works if those are not possible.

I do not need multiple documents or versions if they repeat the same information, and I am sensitive to the possibility that my second item (copies of SFA-developed policies) may take awhile in the search phase depending on how your state agency received and stored those records. I am willing to discuss these and any other issues further to make fulfillment more manageable for your office. I prefer being contacted through the email address listed in my submission, but I am willing to talk directly by email (alexander.rony@sierraclub.org) or phone (415-977-5739) if needed.

I would prefer the request be filled electronically, by e-mail attachment if available or CD-ROM if not. For databases, please export to a flat file.

III. Fees

If there are any fees for searching or copying these records, please inform me in advance of fulfilling the request. I am willing to pay up to $10.

I would also like to request a waiver of all fees in that the disclosure of the requested information is in the public interest and will contribute significantly to the public's understanding of how schools receiving federal nutrition assistance treat children who don't have enough money for food. This issue, and the related "lunch shaming" practices designed to force parents to pay their children's meal debt, have been top news stories for the past year throughout the country.

The Sierra Club is a national environmental nonprofit with no commercial interest in obtaining the requested information. Instead, our organization intends to analyze and disseminate the requested information free of charge so that the public has a single, clear location to identify meal charge policies around the nation. The Sierra Club and its supporters have demonstrated interest and expertise in the subject area by sending tens of thousands of letters to Congress about lunch shaming and anti-hunger programs, and by researching and identifying hundreds of meal charge policies across the nation.

In addition, I ask to be categorized as a representative of the news media. The bulk of my professional duties at the Sierra Club entails planning and writing content about public policy, including analyzing public record responses, coordinating public dissemination plans, and composing mass communications to our supporters. Here are a few examples of my work, or articles based on my work:

https://www.sierraclub.org/planet/2017/09/thousands-usda-research-jobs-stalled-during-hiring-freeze
https://sierraclub.org/planet/2017/04/hiring-freeze-prevented-epa-filling-hundreds-jobs
https://www.washingtonpost.com/news/to-your-health/wp/2017/05/19/nearly-700-vacancies-at-cdc-because-of-trump-administration-hiring-freeze/

The Sierra Club has the ability and intention to disseminate the information it receives through this request. The information may be shared through emails to an audience reaching into the millions, Facebook and Twitter posts reaching tens of thousands of followers, articles on our often-visited website, and analysis provided to the media.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response.

Sincerely,

Alexander Rony
Sierra Club

Thanks so much for your help with this request, David! I really appreciate it. I received the uploaded files. I saw the various district meal charge policies, but I didn't see any documents related to my third requests (participating LEAs in CEP or Provision 2). Normally I would get this straight from the department website (https://www.michigan.gov/mde/0,4615,7-140-66254_80468---,00.html), but the link to the "Current List of Community Eligibility Provision Schools" is broken (https://www.michigan.gov/documents/mde/CEO_WEBSITE_PUBLIC_BUILDING_LIST_2014_446672_7.pdf). I've informed the department about the broken link through the website, but I was hoping that you received this document as part of the search process.

Sincerely,
Alexander Rony

Thanks David. I take it that this means that there are no similar documents that detail which LEAs (local educational agencies) are participating on a districtwide basis? If that's correct, then this fulfills my request.

Best,
Alexander

Thanks for following up. I'm looking for LEAs participating district-wide, so this still doesn't fit my needs. However, I'm willing to wait until the data person returns and/or take this directly to the Department and out of the Michigan Freedom of Information Act space.

Alexander