AASC Form Requirements

This Management Bulletin (MB) supersedes MB CNP-06-2014, issued in June 2014, regarding the Annual Audit Status Certification (AASC) form. Private schools, residential child care institutions, private agencies, community colleges, camps/recreation programs, and Indian Tribal Councils participating in the federal child nutrition programs, administered by the California Department of Education (CDE), are required to annually report to the CDE the total amount of state and federal financial assistance expended during the agency’s preceding fiscal year. This reporting process is facilitated by submitting a completed AASC form through the Child Nutrition Information and Payment System (CNIPS). Public institutions—including school districts, charter schools, state schools, and county offices of education—are currently exempt from the AASC reporting requirement.

To identify and track all of the required annual audits in accordance with Title 2, Code of Federal Regulations (2 CFR), Part 200, Subpart F, the CDE’s Audits and Investigations (A&I) Division notifies agencies by e-mail during the month of August each year, outlining the AASC form submission requirements. A&I requests that applicable agencies annually access the CNIPS and submit the AASC form to the CDE by September 15. The announcement letter is addressed to the directors of organizations that received funding for participation in the following nutrition programs administered by the CDE during the previous fiscal year:

• National School Lunch Program (NSLP)
• School Breakfast Program (SBP)
• Afterschool Meal Supplements (AMS)
• Special Milk Program (SMP)
• Summer Food Service Program (SFSP)
• Commodity Supplemental Food Program
• Food Distribution Program

Even if an agency’s participation in the federal nutrition program was self-cancelled or terminated by the CDE, the agency’s authorized representatives must still complete and return the AASC form if the agency received any federal financial assistance during the applicable fiscal year. Failure to submit the completed AASC form jeopardizes an agency’s continued participation in, and reimbursement for, any program administered by the CDE.

An individual who has knowledge of all of an organization’s financial contracts and programs should complete and submit the AASC form. Inaccurate information reported on the AASC form may indicate that the agency will be required to conduct an audit for the applicable fiscal year. Audit reports not submitted in accordance with the CDE’s audit filing deadlines may jeopardize the agency’s participation in the nutrition programs.

For agencies participating in the SFSP, if the agency fails to submit an AASC form to the CDE by September 15, the CDE will declare the agency seriously deficient in the management of the program(s) in which the agency participates. Ultimately, the agency’s nutrition program agreement with the CDE may be terminated. In addition to being terminated from program participation, Agencies and responsible principals may also be placed on the U.S. Department of Agriculture’s National Disqualified List (NDL). Placement on the NDL will prevent the agency from participating in the SFSP, NSLP, and SBP as an institution or facility and its responsible principals will not be able to serve as a responsible principal in any institution or facility.

If agencies participating in the NSLP, SBP, AMS, and/or SMP, do not submit an AASC form to the CDE by September 15, the CDE may withhold meal reimbursements, which could ultimately lead to termination of the agency’s nutrition program agreement.

Accessing the AASC Form

Go to the CNIPS Web site at https://www.cnips.ca.gov and follow these steps:

1. In the Log On box, enter your User ID and Password
   
2. Select Year on the blue menu bar at the top of your screen; the Year Select screen will display
3. Select the applicable audit period (e.g., 2015–16)
4. Select Application at the top left of the screen
5. Select Annual Audit Status Certification
6. Complete all applicable sections
7. Select Save to submit the AASC form to the CDE

Fiscal Year

A fiscal year means a 12-month period (e.g., July 1 through June 30; April 1 through March 31; or January 1 through December 31, etc.). Agencies are required to report to the CDE the starting and ending dates of the agency’s fiscal year, as well as the amount of total federal financial assistance expended during that time period.

Total Federal Financial Assistance

Total federal financial assistance means any federal assistance that agencies receive or administer in the form of grants, loans, loan guarantees, property (including donated surplus property), cooperative agreements, interest subsidies, insurance, food commodities, meal reimbursements, direct appropriations, and any other federal financial assistance received from outside of the CDE. It does not include amounts received as reimbursement for services rendered to individuals such as child care subsidies, Medi-Cal fees, or Medicaid service fees.

Audit Report Requirements

Per 2 CFR, Section 200.501(a), if an agency has expended $750,000 or more in total federal financial assistance during the previous fiscal year, the agency is required to submit an annual organization-wide contract audit report or program specific audit report. Section 200.512 of 2 CFR provides the reporting requirements for these audits which must be submitted to the CDE and to the Federal Audit Clearinghouse (FAC) within 30 calendar days of receiving the auditor’s report(s), or nine months after the end of the agency’s fiscal year, whichever is sooner.

The reporting package submitted to the FAC must include all elements described in 2 CFR, Section 200.512(c). Indian tribes and tribal organizations may opt out of one of these required elements, specifically tribes and tribal organizations may choose not to authorize the FAC to make the audit reporting package publicly available on the FAC Web site. If the auditee chooses to exercise this exception, the auditee is responsible for making copies of the reporting package available for public inspection (2 CFR, Section 200.512[b][2]).

Additional audit information and instructions are available on the Contracting Agencies Audit Guidelines Web page at http://www.cde.ca.gov/fg/au/pm/.

Contact Information

If you have any questions about the AASC form, please contact Robert Hoyer, Associate Governmental Program Analyst, A&I Division, by phone at 916-445-6776 or by e-mail at rhoyer@cde.ca.gov.