Reimbursement Claim Clarification

This management bulletin (MB) clarifies submission deadline requirements for a reimbursement claim One-time Only Exception (OTO) and supersedes CNP-07-2017 issued in November 2017.

In accordance with Title 7, Code of Federal Regulations (7 CFR), sections 210.8(b)(1) and 225.9(d)(6), a final claim for reimbursement shall be postmarked or submitted to the state agency no later than 60 days following the last day of the full month covered by the claim. Claims not postmarked or submitted within 60 days shall not be paid with program funds unless otherwise authorized by the U.S. Department of Agriculture (USDA) Food and Nutrition Service.

In accordance with USDA’s All Points Bulletin: SPS 92-40, issued on April 22, 1992, and Guidance for Local and State Agencies on 60-Day Claim Submission and 90-Day Reporting Requirements for Child Nutrition Programs, issued in April 2018, the California Department of Education (CDE) has the discretion to approve an OTO for reimbursing a valid late monthly claim once every 36 months per program to sponsors operating the National School Lunch Program, School Breakfast Program, Afterschool Snack Program, Seamless Summer Option, Special Milk Program, Fresh Fruit and Vegetable Program (FFVP), and/or the Summer Food Service Program (SFSP).

If a sponsor submits an approvable corrective action plan (CAP), the CDE may approve one monthly claim only if the sponsor has not been granted an exception for that program during the previous 36-month period. For example, if a sponsor submits an OTO for a May 2019 claim in April 2022, it could be approved. If a sponsor submits an OTO for a May 2019 claim in June 2022, it would not be approved because it is beyond the 36 month period. The CAP form to accompany a request for an OTO is located in the Child Nutrition Information and Payment System (CNIPS) Download Forms section of each program (SNP 37, SNP 37 FFVP, and SFSP 27a).

If the CDE approves the OTO request, the sponsor must certify and submit the OTO reimbursement claim in the CNIPS no more than 15 days after receiving approval from the CDE. For approved late claims that fall within the prior federal fiscal year (October 1–September 30), reimbursement is based upon the availability of funds from the USDA.

Please note, a claim in pending status is not submitted, but must be in an accepted status in the CNIPS. In order to submit an approved OTO claim, sponsors must proceed to the certification screen for the applicable month in the CDE CNIPS claim entry module to finish submission.

For example, the ABC Agency does not submit its January 2022 claim for reimbursement by the April 1, 2022, claim submission deadline and the agency has not submitted a one-time request in the past 36 months. If ABC Agency decides to use its OTO, it must submit the request to the CDE’s Nutrition Services Division (NSD). If the NSD approves the ABC Agency’s OTO request, it must submit the claim in the CNIPS no more than 15 days after receiving approval from the NSD by proceeding to the certification screen for the applicable month in the CNIPS claim entry module.

As outlined in the USDA’s 60-90 Day Reporting in Child Nutrition Programs Guidance, this policy is not applicable when the sponsor has a Certified Public Accountant audit supporting a late adjusted claim.

Contact Information

If you have any questions regarding the OTO process, please contact Mia Gardner, Analyst, Program Integrity Unit, by phone at 916-327-5457 or by email at mgardner@cde.ca.gov.

Kim Frinzell, Director

Nutrition Services Division