Florida Department of Education
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Office of Early Learning
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TECHNICAL ASSISTANCE PAPER #06-04
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SELECTED QUESTIONS AND RESPONSES:
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SUMMER VOLUNTARY PREKINDERGARTEN (VPK) EDUCATION
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PROGRAM PLANNING
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Introduction
This publication is intended to assist school districts and early learning coalitions
in their Summer VPK planning efforts. Questions on the following topics have
been compiled from conference calls, as well as e-mails and phone calls
received from individuals.
Administration of Medication
Attendance Policies
Children with Disabilities or Other Special Needs
Class Size
Contracting with Private Providers
Discipline Policies
Immunization
Obligation to Serve Children
Summer Food Service Program
Appendix A, School District Medicaid Contact List
Administration of Medication
1. What are the procedures that must be established and staff that are
required to insure appropriate administration of medication for children
in VPK?
The district’s procedures, as stated in their approved School Health Services
Plan, must be followed.
Attendance Policies
2. Can a school district have specific attendance policies for their summer
VPK program?
Yes. Section 1002.71(6)(a), Florida Statutes (F.S.), requires that parents,
“…must agree to comply with the attendance policy of the private
prekindergarten provider or district school board…. Upon enrollment of the
child, the private prekindergarten provider or public school… must provide the
child’s parent with a copy of the…attendance policy….” Additionally, Agency
for Workforce Innovation’s (AWI) form VPK-01, (available at:
http://www.floridajobs.org/earlylearning/documents/VPKForm01.pdf), includes
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Office of Early Learning – TAP# 06-04
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Attendance Policies (cont.)
a statement for the parents to sign verifying that they will “…follow the
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provider’s or school’s attendance policy….”
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3. How many absences may a child participating in the Summer VPK
program have before such absences affect funding?
AWI’s
Uniform Attendance Policy for Funding the VPK Program, OEP-PI-
0029-05,
(available at
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http://www.floridajobs.org/earlylearning/documents/OELPI002905_001.pdf)
establishes a startup period of five instructional days. If a student attends the
VPK program during any day of the startup period, the private
prekindergarten provider or public school is paid for all five of those
instructional days. In addition, beyond the startup period, the uniform
attendance policy allows a provider or school to receive payment when a
student is absent from the program for up to 15 percent of the instructional
days. Further, if a student is absent due to extraordinary circumstances, the
provider or school may receive payment for up to 20 percent of the
instructional days. For a student who begins attendance in the VPK program
after the five-day startup period (i.e., delayed enrollment), this program
instruction allows the provider or school to receive payment for a pro rata
share of the authorized absences, based on the number of instructional days
remaining when the student begins attendance in the program.
Children with Disabilities or Other Special Needs
4. Is the district obligated to provide specially designed instruction and
related services to children with disabilities in the VPK program?
No. VPK is not intended to be “special education” and does not provide for
specially designed instruction or related services. If a child has an Individual
Educational Plan (IEP), those services will be provided by the district during
the regular school year and/or through extended school year (ESY) services.
However, the district must make the summer VPK program accessible to a
child with an IEP or special needs. For example, ramps must be available for
a child in a wheelchair, large print or other special materials must be provided
for a child with a visual impairment, special supports that are listed on a
health plan must be addressed including positioning equipment or specialized
dietary restrictions, and specialized communication or visual supports must
be provided for a child with communication disorders. For additional
information, please review the Technical Assistance Paper regarding VPK
and Programs for Children with Disabilities at:
http://info.fldoe.org/docushare/dsweb/Get/Document-3114/tap05_02a.pdf and
the Fact Sheet for Parents of Preschool Children with Disabilities or other
Special Needs at:
http://info.fldoe.org/docushare/dsweb/Get/Document-616/fact_sheetatt.pdf .
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Children with Disabilities or Other Special Needs (cont.)
5. What fund source should be used to pay for supports or services that
have been determined necessary in order for a child to access the VPK
program?
Such supports or services must be paid for with VPK funds. However,
districts are encouraged to work with their local health departments to provide
health services needed by children who are Medicaid eligible. A listing of the
school district contacts is included as Appendix A.
Class Size
6. Can school district summer VPK programs have 20 children and two
qualified teachers in a classroom to meet the child:teacher ratio
requirement of section 1002.61(4), (6) (F.S.)?
Yes. VPK programs are not subject to the class size requirements and are not
included in those calculations.
Contracting with Private Providers
7. Do the requirements, in section 1002.61(3)(a), F.S., for each district
school board to, “…determine which public schools in the school
district are eligible to deliver the summer prekindergarten program…”
and to, “…use the educational facilities available in the public schools
during the summer term for the summer prekindergarten program”
prohibit districts from contracting with private providers for the summer
program?
No. Nothing should be construed to limit the school district’s options for
contracting with private providers to meet their requirement, under section
1002.53(6)(b), F.S., to, “…provide for the admission of every eligible child
within the district whose parent enrolls the child in a summer prekindergarten
program delivered by a public school.”
8. If a district provider initially has ten or more VPK students but
enrollment drops to less than ten, can the district contract with a private
provider and transfer their students to them for the remainder of the
program?
Yes. If a district provider’s enrollment is not sufficient to make the summer
VPK program cost effective, an alternative is to contract with a private
provider. It is advisable to inform parents of the possibility of this occurring
when they register their child for Summer VPK.
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Discipline Policies
9. Should a school district have specific discipline policies for their
summer VPK program?
Yes. Nothing in the implementing legislation prohibits the development and
enforcement of such policies. However, such policies should be carefully
crafted given the age of these children.
Immunization
10.Must a child who turns five during his or her VPK program have the
immunizations required for entry into kindergarten in order to continue
in the VPK program?
No. Although a child must have a valid Certification of Immunization Form
(DH 680) to attend VPK, additional immunizations would not be required until
the child enters kindergarten.
Obligation to Serve Children
11.Are school districts required to provide a Summer VPK program to
every eligible child within the district?
Yes. Although section 1002.61(6), F.S., states, “Notwithstanding ss.
1002.55(3)(e) and 1002.63(7), each prekindergarten class in the summer
prekindergarten program…must be composed of at least 4 students but may
not exceed 10 students,” section 1002.53(6)(b), F.S., states, “Each school
district may limit the number of students admitted by any public school for
enrollment in the program; however, the school district must provide for the
admission of every eligible child within the district whose parent enrolls the
child in a summer prekindergarten program delivered by a public school.” An
option for meeting this requirement is for the school district to contract with a
private provider to provide VPK services (see questions 7 and 8).
Summer Food Service Program (SFSP)
Although compliance with section 1002.61, F.S., does not address a summer
food service program for VPK students, the Ms. Willie Ann Glenn Act’s
requirements stipulate that each school district must sponsor a summer nutrition
program beginning in the summer of 2006 and must operate sites with specific
guidelines based on each school’s percentage of students eligible for
Free/Reduced Lunch.
12.Is a school district required to operate a summer food program if they
only run a VPK program in the summer?
In accordance with section 1006.0606, F.S., Ms. Willie Ann Glenn (WAG) Act,
each school district shall develop a plan by May 1, 2006, to sponsor a
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Summer Food Service Program (cont.)
summer nutrition program beginning in the summer of 2006 to operate sites in
the school district as follows:
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Within five miles of at least one elementary school at which 50% of more
of the students are eligible for free or reduced-price school meals and for
the duration of 35 consecutive days;
and
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Within ten miles of each elementary school at which 50% or more of the
students are eligible for free or reduced-price school meals.
To comply with this act and the requirements for VPK (s.1002.61, F.S.), it
may be advantageous to determine the site(s) that qualify for the WAG Act,
and then incorporate your VPK sites there as well. Then all children receiving
a meal could receive a free meal, which the district could claim for
reimbursement.
For additional information regarding the WAG Act, please contact the DOE
Food & Nutrition Management office at 1-800-504-6609. For more
information regarding the SFSP, you may call the number listed above and/or
access the following link: http://www.fns.usda.gov/cnd/summer/about/faq.html
13.Can the site running 35 days in accordance with the Willie Ann Glenn
Act be a non-school site operated by the school district?
Yes. The site operated in accordance with this act may be operated by the
school district in a school or non-school site. Any not-for-profit entity may
serve as a site or sponsor.
14.How would VPK be affected by the Seamless Summer program?
Under the Seamless Summer program option, which is under the NSLP, all
sites must be “open sites,” which means students who are 0-18 years-of-age
and students who may or may not be receiving educational services must be
served meals. Seamless Summer is an option to consider, versus the
National School Lunch Program (NSLP) or SFSP, because it reduces the
amount of paperwork and time necessary to determine eligibility on a one-to-
one basis. For more information regarding Seamless Summer, please
reference the following link:
http://www.fns.usda.gov/cnd/seamless_summer.htm
15.A school district provides summer education for four weeks and a
recreation department goes in conjunction with the district to extend
their educational program three weeks. If the SFSP was only contracted
for 6 weeks, can a waiver for the seventh week be requested?
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Summer Food Service Program (cont.)
There are no federal guidelines that stipulate how long a site must run under
SFSP or Seamless. The only stipulation in reference to length of operation is
in the WAG Act which states one site must operate 35 consecutive days.
A site may be under the operation of a school district for the first few weeks,
and then the same site can later operate under another sponsorship to equal
the 35 consecutive days. The state agency cannot grant waivers to the 35
consecutive day requirement under the WAG Act.
Note
: A site cannot operate under more than one sponsorship at the same
time.
16.If a school district is contracted to provide meals for a local Parks and
Recreation Department through the SFSP, and if the Parks & Recreation
Department is willing to provide meals for VPK students, would the
school district be in compliance with the WAG Act?
Yes, as long as the mileage requirement(s) is met.
17.Are the criteria used to determine eligibility for SFSP or Seamless
Summer different than the criteria used to determine eligibility under the
NSLP?
Yes. Eligibility under NSLP is based on the individual child’s family income.
Under NSLP it is determined whether a child will qualify for a free meal,
reduced-price meal, or paid. Under Seamless and SFSP, the “site” becomes
qualified. Sponsors can qualify a site by using census data, DOE Survey 3
data, or by taking income applications. If the sponsor uses the census data
or the survey 3 data and the site qualifies, ALL children will receive a free
meal.
18.Since additional sites are now required under the WAG Act, and with the
influx of VPK students, who will be responsible for the food and labor
costs?
That depends on the program; however, funding for summer meals for VPK
students is not provided for in statute. The rules and procedures to follow
regarding filing claims for reimbursement under NSLP, SFSP, and Seamless
Summer are the same for VPK or non-VPK students.
19.Are the sites used under the SFSP or Seamless Summer limited to those
who qualify under these programs?
If the question is referring to “children who qualify,” the answer is yes.
Children who qualify (if the site is open, then all children under 18-years-old
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Summer Food Service Program (cont.)
qualify) would receive a free meal. The sites can only serve children who
qualify (age, income if closed enrolled site, etc).
If the question is referring to “sites that qualify,” the answer is yes. The sites
have to qualify to operate under seamless and SFSP.
20.Are the nutritional requirements different for VPK students with regard
to fats and calories?
No, the nutritional requirements do not change for VPK students in the
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summer.
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21.Does Offer vs. Serve (OVS) have to be implemented for VPK students?
No, this is optional for lower grades. It is only a requirement for lunch at
senior high schools during the school year under NSLP. For more
information regarding OVS, please refer to:
http://teamnutrition.usda.gov/Resources/offer_v_serve.html
22.Can a vended program satisfy the requirements of the WAG Act?
Yes, as long as the “vended program” means a sponsor which purchases
from a food service management company or school district the unitized
meals, with or without milk, which it will serve at its sites. “Vended” does not
mean a vending machine.
23.Are there any circumstances that would allow private VPK providers to
participate in the NLSP, SFSP, or Seamless Summer?
A private provider currently receiving funds through other federal programs
administered by the Department of Health would need to discontinue
participation in these programs to prevent “double dipping.” For more
information, please contact either of the following staff at the Department of
Health:
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Dale Kishbaugh: dale_kishbaugh@doh.state.fl.us; or call (850) 245-4362.
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Phil Reeves: phil_reeves@doh.state.fl.us; or call (850) 245-4360.
24.If an income eligibility form is received for a child during the summer
and the child qualifies for Free/Reduced Price Lunch, does the child’s
eligibility carry over through the next school year?
No. According to federal guidelines, the family would still have to fill out an
income application at the beginning of the school year.
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Summer Food Service Program (cont.)
25.If a school district offers VPK in an area that doesn’t fulfill the mileage
requirement(s) under the WAG Act, can the schools which house VPK
still participate in a summer meal program?
Yes, although the school district may still have to determine whether the
school qualifies by using census data, DOE Survey 3 data, or individual
income applications.
26.If a VPK site does not qualify under Seamless or SFSP, can a parent or
student be required to pay for lunch if lunch time is part of the
instructional day?
No. Because participation in the 300-hour summer VPK program is free and
voluntary, a district may not charge parents for lunch or require parents to
bring food products to the VPK program if meals or snack time are reported
for funding purposes as instructional time. If lunch and/or snack are not
reported as VPK instructional time, the district may charge for the cost of the
meal. However, the district cannot require the parent/child to participate in
the meal as a condition of enrollment. If a parent/child chooses not to
participate, the parent’s ability to have his or her child served by the provider
or school exclusively in the VPK program must not be affected.
Districts are encouraged, if at all possible, to determine the site(s) that
qualify for Seamless Summer or SFSP, and then incorporate their VPK sites
there as well. Then all children receiving a meal could receive a free meal,
which could be claimed for reimbursement. For more information regarding
“Program Instruction,” please refer to AWI’s policy number OEL-PI-0000-06:
http://www.floridajobs.org/earlylearning/IMPI.html.
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