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					                                              United States Department of Agriculture
                                                     Food and Nutrition Service

                                                          Southeast Region

Reply to
Attn. of:   SA 9-3 Gen.

Subject:    Policy Number 225.06-07: Determining Eligibility of Summer Food Service
            Program (SFSP) Sites Serving Migrant Children

     To:    All State Directors:
                Summer Food Service Program (SFSP)
            Southeast Region

            This memorandum is a restatement of policy previously issued as SFSP Policy Memorandum
            93-03, on April 9, 1993. Any changes made to the original text are in bold.

            The regulations governing the SFSP (Part 225.6(c)(2)(ii)) require that all sites, other than camps
            or homeless feeding sites, must have documentation which demonstrates that the site is serving
            an area in which poor economic conditions exist. The regulations further specify that sites which
            serve children of migrant workers may meet this documentation requirement by providing the
            State agency with "... data from an organization determined by the State agency to be a migrant
            organization, which supports the eligibility of those children as a group."

            In the past, we have interpreted this requirement to mean that a State migrant organization must
            have actual statistical data which show that the families served by a specific site are income
            eligible for participation in the SFSP. However, it has become increasingly apparent that few
            State and local migrant organizations have such "data" available. Furthermore, due to the
            variable nature of migrant farmworker employment, equations for converting weekly or monthly
            salaries into annual income are inappropriate, thus making it difficult to determine the annual
            income of a migrant farmworker.

            Because of the difficulties inherent in documenting the income of small groups of migrants, and
            the discernible poverty of migrant farmworkers as a whole, we have decided that it is more
            appropriate to use National data to support the eligibility of sites which primarily serve children
            of migrant farmworkers. The most recent National study of this issue provides sufficient
            evidence to support our belief that migrant sites meet the law's definition of being in "areas in
            which poor economic conditions exist" (i.e., at least 50 percent of the children they serve would
            qualify for free or reduced price meals under the National School Lunch Program).

                                     61 Forsyth Street, S.W., Room 8T36, Atlanta, GA 30303-3415
FORM FCS-603 (3-96)
State Directors                                                                            Page 2

The Department of Labor's "Findings From the National Agricultural Workers Survey (NAWS)
1990: A Demographic and Employment Profile of Perishable Crop Farm Workers," provides
National statistics which confirm the poverty of the majority of migrant worker families. This
nationwide study found that the median family income for migrant workers, in all family sizes, is
between $7,500 and $10,000, and that one-half of migrant worker families have incomes below
the poverty level. Migrant worker families with children are even more likely to live in poverty--
54 percent have incomes below 100 percent of poverty, thus placing more migrant families well
below the SFSP's income requirements for children at enrolled sites. Furthermore, the study
found that only 18 percent of migrant workers are recipients of needs-based social services;
therefore, their use of categorical eligibility as families which participate in the Food Stamp
Program or Aid to Families with Dependent Children would be infrequent.

This data, corroborated by several Federal agencies that work directly with migrants, documents
the general poverty of migrant families. Therefore, we will no longer require migrant
organizations to supply income "data" for a particular group of migrants. Instead, a site serving
migrant children may be eligible for participation in the program, if the site or sponsor has
certification from a migrant organization which attests that the site serves children of migrant
farmworker families. If the site also serves nonmigrant children, the sponsor must certify that the
site predominantly serves migrant children.

If you have any questions or comments, please contact our office.

Regional Director
Special Nutrition Program
DRAFT DATE:05/04/98
DATE FINAL:05/06/98