VT’s Universal Summer Meal Model Under Review

“No registration is required, children do not need to be present, and we do not have any residency requirements (meaning you should feel free to tell your friends in other communities!).”

That’s how the Burlington School District described its summer meals program in a 2025 outreach letter to families. The line, intended to boost participation, also raises a broader policy question: should federally funded summer meals be treated as a community free-for-all—or prioritized for those in greatest need?

Whether it came from a community email or a Front Porch Forum post, the message was clear: Burlington families—or anyone else—could pick up free seven-day summer meal boxes for every child in their household, no questions asked. But that guidance doesn’t fully align with what’s posted on the Burlington School District’s website—or with what the Vermont Agency of Education says federal rules actually require. While AOE confirmed that Burlington qualifies as an “area-eligible” open site under USDA summer meal rules, at no point did officials clarify whether the district’s four meal box pickup locations were officially approved to operate as non-congregate sites under state-level waivers.

That detail matters. Non-congregate sites must meet strict federal requirements for oversight and documentation—especially when children aren’t present and no registration is required. AOE insists that sponsors are required to enforce site caps, maintain point-of-service records, and verify distribution. But when meals are handed out freely to anyone who shows up, without registration or eligibility checks, it’s unclear how those rules are being upheld—or how taxpayer-funded food is being tracked.

Under the Hood of Vermont’s Summer Meal Effort

Vermont’s primary approach to summer food assistance is the distribution of prepared boxed meals. Under the USDA’s Summer Food Service Program (SFSP), local sponsors such as school districts and nonprofit organizations receive federal reimbursements to provide meals to children at no cost to families. Federal reimbursements vary by meal type and site, but typically range from $3.03 for breakfast to $5.40 for lunch or supper. Based on the meal mix, Vermont’s 2024 program likely received an average reimbursement of around $4 per meal.

Based on that rate, Vermont’s summer 2024 effort—which included roughly 1.06 million meals served—would have drawn approximately $4.2 million in federal funding. The Vermont Agency of Education (AOE) confirmed in an email that nearly all funding for the program comes from federal sources, with limited state contributions—around $51,000 total in 2024, or roughly 5 cents per meal.

What’s In The Box?

Along with adding the Summer EBT in 2025, Vermont continued offering boxed meals through local pickup sites, a model that has been in place since 2023. Many sites operated as “open sites,” where meals were available to any child aged 18 or under, with no requirement for residency or income verification. Under USDA rules, this is allowed in areas where at least half of local students qualify for free or reduced-price lunch.

TikTok reviews from 2025 show examples of the meal boxes distributed through these sites. Typical contents included a gallon of milk, some fruit, and a mix of prepackaged items such as muffins, cereal, crackers, and snack bars. Some boxes included limited amounts of meats or cheese.

While meals must meet USDA standards on paper, Vermont’s summer boxes do not appear to be adjusted based on the age or dietary needs of the child receiving them. The AOE confirmed that no data is collected on how many meals go uneaten. There is no indication that meals are tailored to age or dietary needs.

Records of Waste?

The Vermont Agency of Education confirmed that it does not collect data on how many meals go uneaten, returned, or discarded. What’s publicly reported—1.06 million meals in 2024—reflects only those that were documented as “served” at the point of pickup. Meals that were prepared but never claimed are not included in that figure.

Under federal rules, only meals that are properly documented at the point of service can be reimbursed. If a sponsor prepares more meals than they can claim, those extra meals are disallowed—and unreimbursed. AOE says the state kicks in approximately five cents per meal, leaving federal funds to cover the rest.

But when meals are prepared and go unclaimed, someone still pays for the ingredients, packaging, and labor. If it’s not reimbursed federally, and it’s not covered by the state, then by process of elimination—it’s likely coming from local taxpayer funds. Without any waste tracking or public reporting, there’s no way to know how much food goes uneaten—or how much public money quietly disappears with it.

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How Many Were Eligible?

Determining how many Vermont children actually received these meals is complicated. The state’s total child population is approximately 113,000, and around 44,000 children are estimated to qualify for income-based assistance such as SNAP. However, the 1.06 million meals reported for summer 2024 averages out to about 11,700 meals per day. Depending on whether children received one, two, or three meals daily, this suggests that between 3,900 and 5,800 children were served on a typical day — well below the total number of low-income children in the state.

Under USDA guidelines, Vermont’s “area-eligible open site” policy allows meals to be distributed without checking income or residency, so long as the location meets certain census or school-based criteria. As a result, there is no financial means-testing for children to receive meals at open sites, regardless of household income.

According to USDA policy, any child aged 18 or under may receive free meals at an “area-eligible open site”—even if they live in a different town or do not qualify for free or reduced-price lunch. So long as the meal site is located in a qualifying area—where at least 50% of local students meet the income threshold—residency and income checks are not required.

Social media content — including the aforementioned TikTok meal kit reviews — shows families in higher-income areas participating in the program. While this does not violate any rule, it highlights the program’s structural trade-off: in aiming for accessibility, the policy may not effectively reach all of the children who are most in need.

This open eligibility model is not illegal—in fact, it’s encouraged under current USDA rules for areas where 50% or more of local schoolchildren qualify for free or reduced-price lunch. However, it complicates efforts to measure true need and effectiveness.

Unanswered Costs

As agencies like NIH and NSF face tighter budget caps, food assistance programs are coming under closer scrutiny. Vermont received about $4.2 million in federal reimbursements for summer 2024, while contributing nearly $52,000 in state funds. But if only meals documented at pickup are reimbursed, and the state contributes just a nickel per meal, it remains unclear who covers the cost of any waste—especially if the state isn’t tracking it. As Burlington Superintendent Tom Flanagan put it, “No registration is required, children do not need to be present, and we do not have any residency requirements (meaning you should feel free to tell your friends in other communities!).” That’s a generous model—but even at five cents per meal, a million nickels still come from somewhere.

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Dave Soulia | FYIVT

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