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Thirty-Day Eligibility Carryover


Nutrition Services Division Management Bulletin

To: School Nutrition Program Sponsors

Number: 06-108

Attention: Food Service Director

Date: March 2006

Subject: Thirty-Day Eligibility Carryover for Schools and Local Education Agencies Using Special Assistance Provisions 2 and 3

Reference: U.S. Department of Agriculture (USDA) SP Policy Memo 06-02 February 2, 2006; USDA SP Policy Memo 05-26 September 13, 2005; USDA's Implementation Memo - SP 17 August 30, 2005; Child Nutrition and WIC Reauthorization Act of 2004 Section 9(b)(9)(C).

This Management Bulletin (MB) provides information regarding the Thirty-day Eligibility Carryover for Schools and LEAs (Local Educational Authorities) using Special Assistance Provisions 2 and 3.

USDA's Policy Memo SP-05-26 (September 13, 2005) explains how the Child Nutrition and WIC Reauthorization Act established a mandatory thirty-day carryover for eligibility determination for LEAs. This MB will clarify how the mandatory thirty-day carryover affects LEAs that use special assistance Provisions 2 and 3.

LEAs that use Provisions 2 and 3 to calculate claims make eligibility determinations and take meal counts during a base year, then use the eligibility category data from the base year to calculate reimbursement during the next three years. The base year and the following three years together are called a "provision cycle." When the provision cycle is over, the LEA must establish a new base year, receive approval from the state agency for an extension based on socioeconomic data, or return to regular counting and claiming procedures.

Unless the California Department of Education grants the LEA a provision extension, the LEA must use standard counting and claiming starting on the first operating day after the end of the final school year of the provision cycle. Since schools that use Provision 2 or Provision 3 do not make household eligibility determinations in the last year of a provision cycle, there will often be no eligibility data to carryover into the first thirty days of the following school year. In such a circumstance, LEAs must make eligibility determinations based on new applications, direct certification, and information from migrant/homeless/runaway coordinators. The LEA may claim meals at free or reduced-price rates (free/reduced price) only for those students whose eligibility it has established in the current year. Generally, until the LEA makes an eligibility determination for a particular household or student, it must claim meals at the paid rate.

The above notwithstanding, there may be cases where a school's provision cycle has ended, but the LEA does have eligibility information for some of the school's children. For example, an LEA may have made an eligibility determination for a household whose children attended both the provision school and standard counting and claiming schools. In this case, if administratively feasible, the LEA could carryover the eligibility determination it made in the previous year to the household members who attend the school whose provision cycle just ended. There may be other complex circumstances where an LEA would have determined in the previous year the eligibility of a household whose members attend a school that has just ended its base year.

If a school is no longer participating in Provision 2 or 3, the school reverts back to the normal requirements for annual determinations of eligibility for free and reduced-price school meals and daily meal counts by type (free, reduced-price and paid) at the point of service. Should a school decide to return to standard meal counting and claiming procedures, there are time-sensitive notification requirements that must be met.

If you have any questions regarding this bulletin, please contact your Field Services Unit Child Nutrition Consultant at 916-445-0850 or 800-952-5609, or you may contact your School Nutrition Programs county specialist at 916-322-1450.

Please share this bulletin with your district management and business personnel as appropriate.

Questions:   Nutrition Services Division | 800-952-5609
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