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Attached is a revised Letter of Credit and Notice of Program Limita-
tions, Fiscal Year 1971, for the South Dakota State agency reflecting
adjustments in the Section 32 bloc grant, Special Assistance, and Non-
food Assistance accounts. The net result of these adjustments will be
the indicated reduction of Section 32 bloc grant funds in the amount
of $337,858.

Other actions as follows will be required and are hereby authorized:

Transfer the unneeded $337,858 of Special Assistance funds to
the Nonfood Assistance account. (This will release the same
amount of Section 32 funds previously used for Nonfood Assistance.)
Reduce the amount of Section 32 bloc grant funds for use in Non-
food Assistance by the $337,858 transferred from Special Assistance.

of the $548,181 of Section 32 bloc grant funds now authorized, $262,524
is approved for the Section 4 needy schools to implement the March 9
memorandum, $6,136 for School Breakfast and $279,521 for Nonfood Assistance.

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The current authorization of $405,419 of Nonfood Assistance funds supplemented by $279,521 of Section 32 bloc grant funds should substantially reduce the number of no program schools in South Dakota.

You should adjust your fiscal records to show the use of the transferred Special Assistance funds in payment of claims previously paid with Section 32 bloc grant funds if necessary. We suggest you confirm, to us, the action taken to adjust your accounts so that we can be abreast of the fiscal status of program accounts.

Please make the usual distribution of these forms.

Sincerely,

R.V. Finco

R. V. CARGO

Administrative Officer

Child Nutrition Programs
Attachments

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The Letter of Credit cited above held in your favor by the Federal Reserve Bank named has been revised to reflect the changes shown below for the programs specified.

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Under no circumstances shall Form FNS-218, Payment Voucher on Letter of Credit, be issued which would result in overdrawing the Amount Cumulatively Authorized for any program for the current month. If a Payment Voucher is issued in an amount in excess of the monthly limitation for the specific program, you will be fully responsible for such excess amount.

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DIRECTOR, CHILD NIITUTIÓN DIVISION

Abalstand Baryton

CERTIFYING OFFICERS VALIDATION

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In accordance with the authorization of the Fiscal Assistant Secretary, Treasury Department, there is hereby authorized for the account and responsibility of the issuing agency a letter of credit:

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The unpaid balance of this letter of credit will remain available until you are advised in writing by the Treasury Department that this letter has been revoked. OR

The unpaid balance of this letter of credit is revoked at the end of each period indicated and the full amount reestablished at the beginning of the following period until you are advised in writing by the Treasury Department that this letter has been revoked.*

The amount of this letter of credit is hereby certified to be drawn against, upon presentation to you of Form TUS 5401, Payment Voucher on Letter of Credit, by the official (s) of the recipient organization whose sig. nature(s) appear(s) on the Standard Form 1194, Authorized Signature Card for Payment Vouchers on Letter of Credit, attached hereto or previously or subsequently furnished you through the Treasury Department.

The amount of each payment voucher paid by a Federal Reserve Bank or branch to a designated commercial bank for credit to the account of the recipient organization shall constitute payment to the recipient organization by the United States.

I certify to the Treasury Department that the payments authorized herein. are correct and proper for pay. ment from the appropriations or funds legally committed and available for the purpose, when paid in accordance with the terms and conditions cited above.

*This Letter of Credit is Irrevocable to the extent the recipient organization has obilyated funds in good faith thereunder in executing the authorizel Paderni Program in accordance with the grant, contract, or other agreement.

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TENNESSEE

BOARD OF EDUCATION,

MEMPHIS CITY SCHOOLS, Memphis, Tenn., August 16, 1971.

Hon. CLIFFORD M. HARDIN,
Secretary of Agriculture,
The Mall, Washington, D.C.

DEAR SIR: As Director of Food Services for a major metropolitan school system, I have been very appreciative of the support School Food Service has received from the federal government. This support has enabled the Memphis City Schools to receive additional local tax monies which otherwise we probably would not have received.

While I was listening to Assistant Secretary Lyng's speech at the American School Food Service Association National Convention, I became concerned about two of his points for this coming school year. Mr. Lyng stated that USDA would not allow block certification of schools for free or reduced price lunches and that school food service operations would have to become more fiscally responsible in the future.

This past year we operated an experimental program in six of our schools in which block certification was used to give free lunches to approximately 8,200 students. In order to more effectively evaluate the totally free lunch program we conducted several surveys to test the advantages of block certification of schools with high densities of poverty. Below are some of the summary statements from the surveys as they relate to fiscal accountability.

1. The cost of lunch tickets or books in the six block certified schools during 1970-71 would have been between $500 and $1,000.

2. The labor cost per plate was $.0306 less in the six block certified schools than the system wide median. This was a savings of over $44,000.

3. In 1969-70 the cafeterias in the six block certified schools were vandalized 38 times with over $2,800 in food stolen or spoiled. During 1970-71 there were only 16 break-ins for a total of $1,300 in losses.

4. We found that in 74 of our schools over 15% of the cafeteria manager's time was spent on paper work, necessitated by free or reduced priced lunches. This loss of operational supervision is extremely expensive.

We also have the results of a teacher-administrator questionaire and a parent questionaire which offer support for our block certification schools.

When a school has a designated percentage of the enrollment eligible for free or reduced price lunches, it is more efficient to block certify the entire school. For approximately $215,000 a year we could block ceritfy all schools which have 80% of the enrollment receiving free or reduced priced lunches. This is a very reasonable expenditure for the dividends which will be rewarded through better nutrition for all students in these schools, more cafeteria supervision, more classroom instructional time, less administrative paperwork and no discrimination practices to the child receiving the free or reduced price lunch.

Sincerely,

TED MCCLOUD,

Director, School Food Service Division.

BOARD OF EDUCATION,
MEMPHIS CITY SCHOOLS,

Memphis, Tenn., August 25, 1971.

HERBERT D. ROREX,

Director, Child Nutrition Division, Food and Nutrition Service,
Washington, D.C.

DEAR MR. ROREX: This is in response to the Notice of Proposed Rule Making, published August 13, 1971, in the Federal Register to amend the regulations governing the operations of Federal-State Child Nutrition Programs.

We have some general comments to make on the proposed changes in existing regulations as well as specific comments and suggestions in individual sections.

Comments and Suggestions

1. Section 210.4, new paragraph (f): (a) We object to the establishment of a "base" system to control the distribution of funds to the states. Such a system will even further complicate the financial problems encountered by local school districts last year due to late receipt of federal funds. (b) We agree in principle with the use of Section 32 funds for use as general cash assistance as indicated in the proposals. However, we believe that all states should share in these funds on an equitable basis taking into consideration the need of the individual state as measured by per capital income.

The proposed regulations as outlined will be detrimental to the states with low per capita income and the states that have been successful in providing lunches to a high percentage of children. Each state should receive from Section 4 and/or Section 32 a sufficient apportionment to guarantee a minimum rate of 5¢ per Type A Lunch and where the state's assistance need rate is above 5¢ such state shall be guaranteed a rate per meal equal to the assistance need rate for that state as defined by USDA. (c) We recommend that each state's apportionment from Section 11 and 32 funds guarantee a rate of 40¢ for each free and reduced price meal served to eligible children.

2. Section 210.11, paragraph (c) revised: We very strongly object to setting the maximum rate for special assistance at 30¢ especially when it must be considered in conjunction with the "base" system so that the state wide average rate for special assistance cannot exceed 30¢ for the full year. The impact of this provision will seriously endanger continuance of free and reduced price lunches to children who qualify.

3. Section 210.11, paragraph (d) revised: Specify 40¢ in lieu of 30¢ on line 2. In the event that the regulations are issued as presently proposed, we very strongly believe that the great progress achieved last year in reaching millions of additional needy children cannot be maintained and that the total goal of providing free or reduced price lunches to all needy children most certainly will not be met.

Last year the Memphis City Schools fed over 7,000,000 free and reduced priced meals. This total is almost 60% of total participation. We estimate our production cost for a Type A Lunch to be 55¢. During the 1970-71 year, over 80% of the schools on the National School Lunch Program operated at a loss.

The new minimum income guidelines from USDA will add approximately seven percent more free lunches to our daily served of 42,000. Food bids for the 1971-72 school year are up approximately 10% over last year. We are negotiating a new union contract with our cafeteria workers. We lost $750,000 of local taxes this year which was earmarked for free lunches during 1970-71.

We cannot continue our free lunch program as it is presently operated, if USDA puts its proposed regulations into effect. To operate a continuation program would necessitate additional federal support. Sincerely,

JOHN P. FREEMAN, Superintendent.

TEXAS

THE UNIVERSITY OF TEXAS AT AUSTIN,

Hon. GEORGE MCGOVERN,

SCHOOL OF LAW, Austin, Tex., August 30, 1971.

Chairman, Senate Select Committee on Nutrition and Human Needs, Old Senate Office Building, Washington, D.C.

DEAR SENATOR MCGOVERN: We are constantly seeking to add to and improve our library collection which touches on all aspects of law and the legal profession. The publication listed below would be a valuable addition to our collection. Nutrition and human needs; hearings, 90th Congress, 2nd session and 91st Congress, 1st session. Part 13B.

We would greatly appreciate your sending us a copy of the above mentioned publication. If we can in return perform a service for you, please do not hesitate to call on us.

Sincerely yours,

(Miss) LINDA C. MCBLOOM, Documents Librarian.

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