Answer: NCHE has a brief, which was developed in collaboration with USDA, that addresses this question:
“There can be no delay in providing free meals to students who meet the relevant nutrition program eligibility criteria due to unpaid fees. In this case, the district may waive the fees, pay the fees with funds such as donations from PTOs or PTAs, or follow any of the district’s standard unpaid meal fee procedures that do not delay or disrupt the student’s receipt of free meals. Regardless of how the fees are handled, Section 722(g)(1)(I) McKinney-Vento Act requires the elimination of barriers to a student’s full participation in school. Therefore, unpaid fees and actions taken to collect them may not pose a barrier to the student’s full participation in classes, extra-curricular activities, field trips, graduation ceremonies, and other school activities.”
McKinney-Vento students are automatically eligible for free school meals. Also, if a student has fees or fines from a time when they were experiencing homelessness, but were not yet identified, those fees must be forgiven. The district can seek retroactive reimbursement.