Severe Need Breakfast Reimbursement in the SBP

This management bulletin clarifies and replaces guidance issued in management bulletin USDA-SNP-24-2009, Final Rule: Severe Need Assistance in the School Breakfast Program (SBP), regarding the U.S. Department of Agriculture 2009 Final Rule for the SBP Severe Need Assistance. Please note that severe need eligible schools are defined as those schools that served at least 40 percent free and reduced-price (F/RP) lunches two school years prior. These schools are eligible for a higher rate of severe need breakfast reimbursement.

Existing school sites participating in the SBP with two year lunch history described above will automatically receive severe need reimbursement through the Child Nutrition Information and Payment System (CNIPS).

Severe Need Breakfast Reimbursement Eligibility

When determining eligibility for the higher breakfast reimbursement rate for schools identified as severe need, two factors require clarification:

1. New School Site Eligibility: When and how do new schools without a prior two-year lunch history qualify for the severe need rate of reimbursement?
   
   
2. Severe Need Breakfast Reimbursement Request and Claiming Timelines: When must school food authorities (SFA) that are adding new schools that may qualify for the severe need reimbursement rate submit the Severe Need Reimbursement Request to the California Department of Education (CDE) for approval?

New School Site Eligibility

The following section defines when schools without a two-year lunch history may qualify for severe need breakfast reimbursement.

1. Schools currently eligible for severe need reimbursement (severe need schools) that change their name or move to a new building with no change in student population are automatically eligible for severe need breakfast reimbursement. This includes schools that were previously sites under another SFA and are now sites under their own SFA. Contact your School Nutrition Programs (SNP) county specialist for assistance.
   
   
2. New schools that are created when two or more currently eligible severe need schools combine their entire student populations are eligible for severe need reimbursement. Contact your SNP county specialist for assistance and complete form SNP-08 as identified below.
   
   
3. New schools that are created when a portion of their student populations move to a new site may qualify for severe need breakfast reimbursement if 40 percent or more of the lunches they served for the first three claiming periods of the current school year were to students eligible for free or reduced-price meals. Contact your SNP county specialist for assistance and complete form SNP-08 as identified below.

Severe Need Reimbursement Request and Claiming Timelines

The following section describes the required steps and timeline for the SFA to submit a request to the CDE for approval of severe need breakfast reimbursement for an eligible school site. The SFA must submit CNIPS Form SNP-08 for CDE approval when:

• Two or more severe need schools combine their entire student populations to form a new school
  
  
• A portion of the student population moves from one site to a new site forming a new school or schools
  
  
• A new or existing school with a high percentage of students eligible for F/RP meals and without a two-year prior lunch history is adding the SBP

SFAs must use the CNIPS Form SNP-08 located in the Download Forms section of the CNIPS to demonstrate that the new school served at least 40 percent of their lunches for free or at a reduced price in the first three reimbursement claiming periods of the current school year. If SFAs submit Form SNP-08 during the fourth claiming period of the school year, the CDE may retroactively approve severe need reimbursement for these new schools to encompass the first three lunch claiming periods that were used to establish the school’s severe need breakfast eligibility.

As first described above, SFAs must submit the CNIPS Form SNP-08 for CDE approval during the fourth claiming period of the school year in order to be approved retroactively for the first three claiming periods. For example, if August, September, and October are the first three claiming periods of the school year, the SFA must submit the request for severe need reimbursement during the month of November (the fourth claiming period). However, if SFAs operate 10 days or fewer in August and choose to combine their August and September claims, they must submit Form SNP-08 during the month of December, which is the fourth claiming period in this instance.

If the CDE approves a new SFA to participate in the National School Lunch Program (NSLP) and SBP midyear, the SFA would submit Form SNP-08 during their fourth claiming period of the year. For example, if an SFA is approved to participate in the NSLP and SBP in December, they would submit Form SNP-08 in March (the fourth claiming period).

However, if an existing SFA submits the form after the fourth claiming period, they must still use the first three claiming periods of the SFA’s school year to qualify for severe need reimbursement. For example, if an SFA that annually operates from September through June submits Form SNP-08 in April, the SFA must still use its first three claiming periods (September–November) to qualify for severe need. In this case, however, the CDE will only approve the severe need reimbursement rate for the month in the school year –and after– the time the CDE receives an approvable request from the SFA.

The CDE will not review or approve severe need reimbursement requests that SFAs submit before the fourth claiming period of the school year. School days during July designated by the SFA as summer school for the prior school year are not counted toward the first three claiming periods.

Send completed SNP-08 forms to your assinged SNP County Specialist. SNP County Specialists can be found in the CNIPS, Download Forms.

Once the CDE approves an SFA’s Form SNP-08, the SNP County Specialist will adjust the SFA’s CNIPS Site Application, Item 13, under the heading “Participation Information.” This will activate the severe need reimbursement rate. The SNP County Specialist then approves the CNIPS application and contacts the SFA’s assigned Fiscal Analyst in the CDE Child Nutrition Fiscal Services (CNFS) Unit. The CNFS Analyst will contact the SFA’s claims preparer, as identified on the SFA’s current CNIPS Application, to provide instructions for submitting reimbursement claims for the sites newly approved for the severe need rate.

Severe Need Reimbursement Process

Basic breakfast and severe need breakfast reimbursement are paid from two separate funding sources. Therefore, if the approval for severe need reimbursement results in the SFA no longer having any sites eligible for the basic breakfast rate, the CDE will send the SFA an invoice for any funds the CDE paid the SFA at the basic breakfast rate for the retroactive period. However, the CDE will offset the funds owed from the basic breakfast rate with severe need reimbursement from future claims. If for any reason the CDE is unable to recover any invoiced funds with severe need reimbursement, the CDE will notify the SFA of the balance due.

Note: SFAs must annually qualify for severe need breakfast reimbursement at each eligible site. SFAs without a two-year history must annually submit Form SNP-08 for each school approved through the process defined in this management bulletin, until each school establishes the required two-year lunch history. In subsequent years, Form SNP-08 will not be necessary as long as the school served 40 percent or more lunches to children eligible for F/RP meals. The school will continue to qualify based on the second preceding year’s lunch history, which the CNIPS will automatically calculate and populate into the appropriate data fields.

Contact Information

If you have any questions regarding this subject, please contact your county’s SNP Specialist. A list of SNP Specialists is available in the Download Forms section of the CNIPS, Form ID Caseload.

If you have any questions about meal reimbursement claims, please contact your agency’s assigned Nutrition Fiscal Analyst. A directory of these analysts can be found on the CDE Nutrition Services Web page at http://www.cde.ca.gov/fg/aa/nt/.