Thirty-Day Eligibility Carryover

This management bulletin 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 management bulletin 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 must use a household meal application to determine categorical eligibility for any students not directly certified. 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.

Contact Information

If you have any questions regarding this subject, please contact your county’s School Nutrition Programs (SNP) Specialist. A list of SNP Specialists is available on the California Department of Education's SNP Directory web page at https://www.cde.ca.gov/ls/nu/sn/snpcontacts.asp. A list is also located in the Download Forms section of the Child Nutrition Information and Payment System, Form ID Caseload.

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