School Nutrition Programs Compliance Handbook
Chapter 6 – Counting and Claiming
School Food Authorities (SFA) must have an accurate counting and claiming system demonstrating integrity of program funds, which benefits all children participating in the school nutrition programs. SFAs can only claim reimbursement for meals that meet program requirements. SFAs must ensure that meals claimed:
1) Meet the required meal pattern requirements.
2) Are only served to eligible children.
3) Are tracked by the eligibility category; and
4) They are served at the point of service.
The number of meals claimed for reimbursement must have adequate documentation on file to support the claim. When an SFA applies to participate in the School Nutrition Programs, the Meal Counting and Collection Procedures form is completed. This form identifies the procedures used for counting and claiming by the SFA.
Child Participation
Children enrolled in a participating site can participate in the National School Lunch Program (NSLP), School Breakfast Program (SBP), Afterschool Snack Program, or the Special Milk Program (SMP). This applies to both children in regular and special education. Children 21 years of age or younger residing in a participating private nonprofit Residential Child Care Institution (RCCI) are eligible to receive meals offered by School Nutrition Programs. Counting and claiming meals is based on each child’s eligibility. Eligible children consist of the following:
- Children approved for free meals through:
- Household applications
- Are categorically eligible
- Directly Certified
- Children approved for reduced-priced meals through household application.
- Children who are eligible for free and reduced priced meals are eligible for paid student meals.
Counting and Collection Procedures
School Food Authorities (SFA) must develop counting and collection procedures for each of their sites. When SFAs apply for the School Nutrition Programs, a Meal Counting and Collection Procedures form is completed and submitted to OKDHS School Nutrition Programs (SNP). The Meal Counting and Collection Procedures form identifies meal payment collection procedures, the number of food items served to each student receiving a reimbursable meal, the person(s) responsible for counting and claiming, and the point of service procedures. These procedures are approved as part of the SFA agreement with OKDHS SNP. If procedures change, the SFA is responsible for notifying OKDHS SNP of the changes.
SFAs can use various methods to collect meal payments. SFAs can collect payments daily, monthly or as part of the tuition payment. Each SFA may also use various mediums of exchange such as tickets, tokens, scan cards, rosters, and so forth. Regardless of the exchange method used, the SFA must prevent overt identification (See section below on Overt Identification) of students receiving reduced price and free meals.
Point of Service Meal Counts
Prior to filing a reimbursement claim, School Food Authorities (SFA) are required to count meals daily at the point of service for each site [as required by federal regulation 7 CFR Part 210.7 (c) (1) (iii)]. Point of service meal counts increases accuracy and consistency. The point of service is the point in the food service operation where it can be determined whether the meal served to an eligible child is compliant with the meal pattern requirements. This usually occurs at the end of the service line when staff can ensure that the meal taken by the child contains the required components and serving sizes and the meal is then counted. Staff should refer to the Counting and Collection Procedures to determine the SFAs policy. This is part of the SFAs permanent file for school food service on file with OKDHS School Nutrition Programs (SNP).
To ensure a point of service count, the school must have a consistent meal counting system, and staff trained to identify reimbursable meals. Table 1.1 provides the requirements for point of service meal counts.
Table 1.1: Requirements for Point of Service Meal Counts |
To count a reimbursable meal at the point of service, the procedures must ensure that meals: 1. Compliant with the required meal pattern. 2. Reflect only free, reduced price and paid price eligible students. 3. Are counted daily by category. 4. Are claimed one meal per eligible child. 5. Served to adults and meals served as seconds are counted but not claimed for reimbursement. |
To make a system reliable, all persons responsible for recording the meal counts must be able to identify a reimbursable meal. Teachers, house parents, and other staff responsible for taking meal counts must receive training to identify reimbursable meals to record meal counts correctly. When a meal is not reimbursable, school food service programs must have procedures that allow staff to return the meal for a reimbursable one (for example, requesting the child return to the serving line to get what is lacking from the meal to make it eligible to be claimed) or record the meal as non-reimbursable.
Alternate Point of Service
An alternative point of service is used when schools cannot count meals at the time of service. School Food Authorities (SFA) may use alternate point of service counts only with prior approval by OKDHS SNP. Alternate point of service meal counts must be accurate and reliable. The point of service counts is listed on the Meal Counting and Collection Procedure form (part of every SFA’s permanent documents). Any changes to these procedures must be submitted to OKDHS SNP in writing and in detail. The state agency (OKDHS SNP) will review the detailed description of the alternative point of service to determine accuracy and reliability as part of the process to decide on providing approval or denial of an alternate point of service. SFAs must use the point of service listed in the SFA’s meal counting and collecting procedures form on file with OKDHS SNP until a determination on the alternate point of service is provided by OKDHS SNP.
Table 1.1 provides examples of point of service meal counts.
Table 1.1: Examples of Point of Service Meal Counts |
Examples of Point of Service Counts:
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Unallowable Meal Counts
At times, schools will implement a counting system that is not accurate or reliable. Listed in table 2 are examples of unreliable meal counts and cannot be counted as reimbursable. If a SFA’s counting system is not reliable, schools must take immediate steps to find the issue(s) and take immediate corrective action. The corrective actions taken must increase the accuracy of the SFA’s counting and claiming system.
Table 2: Examples of Unallowable Meal Counts |
Examples of unallowable meal counts:
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Visiting Students
Schools providing meals to students visiting from another school may claim those meals at the paid reimbursement rate. Meals served to visiting students eligible for free or reduced priced meals may be claimed as free or reduced if the school complies with program regulations. Schools claiming visiting students must:
1) Receive documentation of the student’s eligibility to receive paid, free meals, or reduced priced meals.
2) Serve meals for visiting students that comply with meal pattern requirements for reimbursable meals.
3) Ensure that the visiting school is not claiming the same meals for the day of the visit.
Second Meals
One meal compliant with meal patterns may be claimed for reimbursement for each eligible student. Second meals served to students may not be claimed for reimbursement. Schools should document second servings separately from the reimbursable meals.
Preschool and Day Care Programs
Preschool programs located on a school campus and operated by the school are eligible to participate in the National School Lunch Program (NSLP) and School Breakfast Program (SBP). Children attending the preschool program must be provided with a household application or should be included on a sibling’s application. Meals served to children in nonpricing programs such as day care or RCCI must be claimed in the appropriate category (free, reduced price or paid) even if there is no charge to the children.
Preschool programs located on school campuses that are not operated by the school may not participate in the NSLP and the SBP. The sponsoring school may enter into a catering contract with the non-participating school to supply meals at a cost. The sponsoring school food service program must receive all income for the meals catered to another school. There are special requirements for the procurement of catering (vended meal) contracts, see chapter 7 on procurement for more information.
If a preschool program chooses to participate in the Child and Adult Care Program (CACFP) rather than the NSLP, the school may provide meals, but reimbursement would be claimed by the organization sponsoring the CACFP. For CACFP, apply with Oklahoma State Department of Education.
Non-school Days
When an on-site day care program is open and the school is closed, meals are not reimbursable under the School Nutrition Programs. This includes private schools that have a day care program during the holidays, breaks (fall, winter, and spring), and summer.
Claiming days for Residential Child Care Institutions (RCCI)
Residential Child Care Institutions (RCCI) are allowed to claim lunch and breakfast during the weekends, holidays, and school vacations if the criteria in table 3 are met:
Table 3: Criteria for RCCIs to Claim Meals When School is Not in Session |
1. Breakfast and lunch are served on Saturday and Sunday as documented by: a. Meal Counts b. Menus c. Production Records 2. Breakfast and lunch meet the minimum requirements for the meal patterns for the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) [as required by federal regulations 7 CFR Part 210.10 (c) and 7 CFR Part 220.8 (c)] as documented by: a. Menus b. Production Records 3. Snacks cannot be claimed for the Afterschool Snack Program when school is not in session [per federal regulation 7 CFR Part 210.2]. For more on the Afterschool Snack Program see chapter 13. |
Daily Reporting
Accuracy in the counting system helps to ensure an accurate reimbursement claim. During the compliance reviews (Administrative Reviews), OKDHS School Nutrition Programs (SNP) assess the accuracy of each SFA’s counting and claiming system, School Food Authorities (SFA) using the procedures listed in table 4 have more accurate counting and claiming systems.
Table 4: Procedures to Increase the Reliability in Counting and Claiming Systems |
1. Record meals daily by the name of each student. This should be done at the point of service either in an electronic meal counting system, or on a paper meal roster. a. Ensure overt identification is prevented when recording meals [as required by federal regulation 7 CFR Part 245.6 (b) (10) and USDA Memo SP 45 – 2012]. The eligibility category (free meals, reduced price meals, and paid meals) must not be visible where the meals are being recorded. i. Students, volunteer parents, and non-authorized staff should not be able to identify the students eligible for free meals and reduced priced meals. *OKDHS School Nutrition Programs has meal rosters that do not identify student’s eligibility category available by emailing AFS.School.Nutrition.Programs@OKDHS.org. 2. If a child charges their meal, the meal is recorded by category on the day the meal is served, not on the day the meal is paid for. A charged meal is NOT counted as a served meal. 3. Where schools receive meals from a vendor (catered meals) or a central kitchen, count for reimbursement the meals (compliant with meal patterns) served to children eligible to participate in school nutrition programs. 4. Adult meals and second meals served to children are NOT reimbursable and should never be claimed. Adult meals and second meals should be recorded for income purposes, as well as to document the integrity of the program. a. If food service personnel eat free, or a reduced price, School Food Authorities (SFA) should record the meals served to food service personnel and non-program staff separately. b. Adult meals may be recorded on the child meal roster or on a separate meal roster. 5. Conduct daily edit checks [as required by federal regulations 7 CFR Part 210.8 (a) (3) and 7 CFR Part 220.11 (d)]. SFAs are required to conduct daily checks at each site to ensure only the number eligible for free meals, reduced priced meals, and paid meals are claimed. a. Edit checks allows the SFA to compare the number of meals claimed to the number of allowable meals (number of children present by eligibility category at the time of the meal service). *Edit check spreadsheets for RCCIs and schools are available upon request by emailing AFS.School.Nutrition.Programs@okdhs.org. 6. Record separately on the reimbursement claim the number of paid, reduced priced, and free meals served during the month the claim is for. Submit the claim following each report month to OKDHS School Nutrition Programs. a. Meal counts should be taken for the edit checks after the meals are compared to the attendance factor rate. |
Overt Identification
School Food Authorities (SFA) must avoid any policy or practice that has the effect of overtly identifying Children’s eligible categories [as required by federal regulation 7 CFR Part 245.6 (b) (10) and USDA Memo SP 45 – 2012]. Where necessary, SFAs should promptly update their policy statements, implementation procedures, and operations to comply with this guidance. State agencies [OKDHS School Nutrition Programs (SNP)] must assure that SFAs’ practices address ways to prevent overt identification. This includes reviewing policy statements and point of service systems for new SFAs submitting applications for participation in the school meals programs. Further, state agencies (such as OKDHS SNP) are required to review the policy statement and the medium of exchange used as part of the general areas when conducting administrative reviews.
Defining Overt Identification
Overt identification is any action that may result in a child being recognized as potentially eligible to receive or certified for free meals or reduced-priced meals. School Food Authorities (SFA) must assure that a child’s eligibility category is not disclosed at any point in the process of providing free meals or reduced-priced meals, including notification of the availability of free meals or reduced-priced meal benefits; certification and notification of eligibility; provision of meals in the cafeteria; and the point of service.
Preventing Overt Identification of Directly Certified Children
School Food Authorities (SFA) are not required to provide applications to parents when children are eligible for free meals through direct certification but must ensure that these children are not overtly identified through the method used to distribute applications. If a SFA distributes applications to individual households, such as by mail (including e-mail), or in individual student packets; or online availability, applications do not have to be provided to households in which all children are determined eligible through direct certification. If the distribution method is not individualized, all households must be provided with applications. [See federal regulation 7 CFR 245.6(b)(10)]. Table five contains actions prohibited by federal law and regulation regarding overt identification.
Table 5: Prohibited Actions |
The following actions are prevented by law and federal regulation: · Publicizing or announcing eligible households or children’s names [per federal regulation 7 CFR Part 245.6 and USDA Memo SP 45 – 2012]. · Using different mediums of exchange (see the “Different Mediums of Exchange” section below for additional discussion) [per USDA Memo SP 45 – 2012]. · Having separate dining areas, service times, or serving lines [per USDA Memo SP 45 – 2012]. · Limiting choices of reimbursable meals [per USDA Memo SP 45 – 2012]. · Requiring children to work for their meals [per USDA Memo SP 45 – 2012]. |
Food Service Area Considerations
School Food Authorities (SFA) are prohibited from having separate dining areas, service times or serving lines or limiting the choices of reimbursable meals based on a student’s eligibility status. In addition, SFAs choosing to sell competitive foods during the meal service are encouraged to ensure the operation of the sale of competitive foods does not inadvertently result in eligible children being identified. Table 6 contains ways to limit overt identification related to the sale of competitive foods.
Table 6: Methods to Limit Overt Identification Related to the Sale of Competitive Foods |
The methods to limit overt identification related to the sale of competitive foods include: · Limit competitive foods to those also offered as part of reimbursable meals on the reimbursable lunch lines. · Offer competitive foods on the same lines as reimbursable meals are offered; or · Only allow competitive foods to be purchased with a pre-paid card or other type of pre-paid system. |
Medium of Exchange
Schools must prevent overt identification at the point of service [as required by USDA Memo SP 45 – 2012]. Meal cards, tickets, tokens, ID numbers, or other methods to obtain reimbursable meals cannot be coded or colored in a manner that would overtly identify free and reduced-priced eligible children. In addition, School Food Authorities (SFA) must take steps to assure that rosters, computer screens or other equipment used at the point of service cannot be viewed by anyone not needing the information, especially children. Further, the information on the rosters or screens should be masked or coded to avoid other children discerning any child’s eligibility status [as required by USDA Memo SP 45 – 2012].
Whichever medium of exchange is adopted in the meal count/collection system, the system must be complex enough to prevent other children from identifying the students receiving free and reduced-priced meals. Children can easily recognize single-symbol and coding to identify free and reduced-priced students. SFAs should never use single-symbol code such as A, B, C; X, Y, Z; or 1, 2, 3. Additionally, color-coding by category and single-symbol coding using obvious identifiers such as F, R, and P cannot be used.
Another system to prevent overt identification is prepayments. SFAs should allow parents and children to make payments online or prior to the lunch service.
Reducing a cash system reduces the identification of eligible children. However, SFAs cannot eliminate the cash basis altogether. Households must have a way to pay for their meals daily.
When recording meal counts, staff should use a consistent coding system to identify the various types of meals. If the counting system requires number or letter codes for children who are absent children, for second meals, adult meals, and reimbursable meals, the coding must be consistent. Example: if the letter N is used to notate a non-reimbursable meal and the letter X is used for mark a reimbursable meal, all staff responsible for recording counts, must be trained to use the same codes.
Edit Checks
All schools are required to conduct an edit check process [as required by federal regulations 7 CFR Part 210.8 (a) (3) and 7 CFR Part 220.11 (d)]. The edit check process compares daily meals counts to the School Food Authority’s (SFA) assigned attendance factor. The attendance factor is assigned by the state agency [OKDHS School Nutrition Programs (SNP)] using the school’s averaged enrollment and average daily attendance for the month of October. Private Schools use the Excel spreadsheet edit check for schools, or the edit check report generated by their electronic counting system. The Excel spreadsheet edit check for schools can be requested by emailing AFS.School.Nutrition.Programs@okdhs.org.
Residential Child Care Institutions (RCCI) complete a different form for the edit check Process. Because of the unpredictable numbers used to determine enrollment and attendance rates, the state agency does not use October data to determine RCCIs’ attendance factor. RCCIs are required to conduct an edit check to ensure that the meal counts do not exceed the enrollment numbers each day. To prevent over claiming, staff will need to review daily census records. OKDHS SNP has an Excel spreadsheet edit checks for RCCIs available upon request by emailing AFS.School.Nutrition.Programs@okdhs.org.
Attendance Factor
OKDS School Nutrition Programs (SNP) will establish attendance rates for each School Food Authority (SFA). Each year, no later than November 30, SFAs will submit the attendance factor rate, calculated by the school, to OKDHS SNP. OKDHS SNP will review the attendance factor rate for each SFA and keep the attendance factors on file. The attendance factor is used during the edit check process prevents the over claiming of meals. To get the attendance factor, SFAs must first calculate the average daily enrollment and the average daily attendance. To request the attendance factor worksheet email AFS.School.Nutrition.Programs@okdhs.org.
To get the average daily enrollment: List the daily enrollment for each operating day in October (or alternate month) on the enrollment calculation column. Do not list weekends or days school is not in session. At the end of the month, total enrollment for each day, then divide that number by the total number of operating days in the month. This is your average daily enrollment.
To get the average daily attendance: List the daily attendance for each operating day in October (or alternate month) on the daily attendance calculation column. Do not list weekends, or days when school is not in session. At the end of the month, total attendance for each day, then divide that number by the total number of operating days in the month. This is your average daily attendance.
If the meal count is higher than the attendance factor, SFAs should check the following:
1. The accuracy of the monthly meal counts.
2. The accuracy of the number of approved students for reduced or free.
3. Check to see if there was high attendance or participation during the month.
Table 7.1: Calculating the Attendance factor |
To calculate the attendance factor: Divide the average daily attendance by the average daily enrollment. Multiply the result by 100 to get the percentage
Attendance Factor = (Average Daily Attendance) (______) = ______ X 100 =______% (Average Daily Enrollment) ( ) |
Table 7.2: Example Attendance Factor Calculation |
Example: · Gather enrollment and attendance: · October Enrollment (total of each day): 5434 · October Attendance (total of each day: 5290 · Number of Operating Days in October: 22 Average Daily Attendance: 5290 (sum of each day’s total attendance for October) = 240 22 (number of operating days in October) Average Daily Enrollment: 5434 (sum of each day’s enrollment for October) = 247 22 (number of operating days in October) Attendance Factor = Average Daily Attendance = 240 = .972 X 100 = 97.2 % Average Daily Enrollment 247 |
To request an attendance factor calculation sheet email AFS.School.Nutrition.Programs@okdhs.org.
State Edit Check Using Attendance Factor
OKDHS School Nutrition Program (SNP) calculates the reimbursement payments for each meal claimed. The calculation is based on the number of free, reduced price and paid meals claimed and additional assistance provided to schools with a high percentage of low-income students. The OKDHS School Nutrition Programs staff will compare meals counts to the attendance factor assigned to the School Food Authority (SFA). If OKDHS SNP determines that meal counts exceed the attendance factor, a justification for the claim may be requested.
Accountability Requirements
Accountability Procedures
School Food Authorities (SFA) should maintain on file written procedures for the meal count system. If more than one system is in place at different sites, written procedures should be maintained for each site. Procedures should state how, when and where a duty is to be performed and which personnel position is responsible. It should also identify procedures and personnel for the eligibility determination, verification, edit checks, and the claiming process. Written procedures should be specific enough to allow substitute staff to implement an accurate counting and claiming system.
Staff Training
Personnel responsible for counting, claiming, and serving reimbursable meals should receive training. It is the staff’s responsibility to ensure only reimbursable meals are counted during the point of service. Staff members should also receive orientation on their duties and responsibilities. Training should cover the topics listed in table 8.
Table 8: Counting and Claiming Recommended Training Topics |
Counting and claiming training should cover the following topics:
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Training should be documented, including title of the training, dates, topics covered, training provider, and attendees. See chapter 8 Professional Standards for more on documentation of training.
On-Site Review for Multiple Sites
School Food Authorities (SFA) having more than one site participating in the National School Lunch Program (NSLP) must conduct a site review at each site prior to February 1 of each year. SFA must complete the review no later than February 1 and submit the summary form to OKDHS School Nutrition Programs (SNP) by February 15 (to request the Multiple Site Summary Report forms, email AFS.School.Nutrition.Programs@okdhs.org). The purpose of the site review is to ensure that meal counting procedures comply with federal requirements and agency procedures.
The SFA must assign a reviewing official to conduct the on-site review for each school or site to ensure that counting and claiming systems meet program requirements. If the reviewing official identifies problems with their meal counting or claiming procedures, the SFA must take steps listed in table 9 to correct the problems.
Table 9: Steps to Take to Correct Problems Identified on a Multi Site Review |
1. Assist the food service site in developing and implementing a corrective action plan. 2. Conduct a follow-up on-site review within 45 calendar days of the first review to ensure the corrective action corrected the problem identified in the initial site review. |
Reimbursement Claims
OKDHS School Nutrition Program (SNP) requires School Food Authorities (SFA) to submit their claim through the online claiming system, unless approved to submit the reimbursement claim form (OKDHS form 23CD006E) to OKDHS SNP. The information for completing the claim by either the online claiming system or the reimbursement claim form is found on the edit check spreadsheet or edit check report from an electronic counting system. SFAs must thoroughly complete the online claiming screen or the claim form prior to submission. Incomplete reimbursement claims or claim forms containing the incorrect address, agreement number and federal identification number cannot be processed. OKDHS SNP will review the information to identify discrepancies in the claiming process. For questions regarding the online claiming system, or for assistance contact OKDHS School Nutrition Programs.
Due Date
OKDHS School Nutrition Programs (SNP) requests that School Food Authorities (SFA) submit all claims by the tenth (10th) of the month following the claim month. If the 10th day is on a Saturday, Sunday, or a state holiday, SFAs can submit the claim on the following working day. Federal regulations [7 CFR Part 210.8 (b) and 7 CFR Part 220.11 (b)] allow the state agency to pay a claim if filed within 60 days after the claim month. In some cases, Federal regulations may prevent the state agency (OKDHS SNP) from paying a late claim. Claims submitted after 60 calendar days may be granted a one-time exception for payment if corrective action is taken to prevent future late claims. This exception is allowed only once for thirty-six (36) months. No other exceptions may be granted within the thirty-six (36) month period.
On-line Claiming
School Food Authorities (SFA) must file an online claim file by the SFA’s authorized representative using a user id and password. OKDHS SNP may direct SFAs (on a case-by-case basis) to file a paper claim signed by the authorized representative. Filing an online claim increases payment timeliness. Built in edits checks will identify claiming errors such as an overclaim or data entry error. Rejected claims will be returned to the SFA with a notice for the rejection. Only one person from each SFA is allowed to file a claim on-line. For assistance with on-line claiming, contact OKDHS School Nutrition Programs.
Authorized representative
The authorized representative is the person who is authorized to sign the reimbursement claim and other documents required for school nutrition programs. In many cases, the director, principal or financial officer is the authorized representative. In other cases, the director or principal will authorize other personnel, such as the food service manager to complete and sign the reimbursement claim. Authorized representatives must be approved by OKDHS School Nutrition Programs.
To become an authorized representative, personnel must complete the School Nutrition Programs Change of Personnel Form. For online claiming the documentation in table 10 must be completed.
Table 10: Documentation Required for Online Claiming |
The authorized representative must complete to file reimbursement claims online:
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Contact the OKDHS School Nutrition Programs to request these forms.
Under no circumstances do authorized representatives share their user ID and password with anyone, staff, or non-staff. The password and user ID is unique to the person authorized to claim online. If non-authorized personnel are caught trying to log onto the online claim system, the SFA may lose the privilege of online claiming.
Late Claim Exception Options
If your claim is received after the final deadline date, the following two options are available:
Within Your Control Exception: This option is used if the lateness of the claim or amendment submission is due to circumstances within your control. OKDHS School Nutrition Programs (SNP) has the authority to approve and process the payment of one late claim or amendment within a 36-month period. That approval is dependent upon receiving a corrective action plan (CAP) including the items in table 11.1.
Table 11.1: Late Claim Corrective Action Plan Requirements |
1 . Actions taken to avoid repetition of the situation linked to the late reimbursement claim submission. 2 . Actions to be taken to avoid any future late reimbursement claim submissions for the same or other causes. 3 . A statement the School Food Authority (SFA) understands that an exception can be granted only once every 36 months for a late reimbursement claim submission that is under the SFA’s control. Future late claims will not be paid unless the SFA has not been granted an exception during the previous 36-month period or the lateness can be attributed to conditions outside the SFA’s control. 4 . The signature of the SFA official listed on the contract agreement with OKDHS SNP for the school meals program. |
The SFA shall forward its corrective action plan and the late claim to the School Board, Superintendent, or other appropriate local senior level official for approval prior to forwarding it to OKDHS SNP.
OKDHS SNP shall review the corrective action plan and approve, at its discretion, only those which in its opinion warrant approval.
Outside the School Food Authority’s (SFA) Control Exception: The second option is available if the lateness of the claim or amendment was beyond the School Food Authority’s (SFA) control and the SFA wants to request an exception to the regulations. The SFA will need to submit the items in table 11.2.
Table 11.2: Items to Submit for Reimbursement Claims Outside of the SFA’s Control |
1 . A written request for an outside of the SFA’s control exception. 2 . A detailed description of the events and circumstances that prevented the reimbursement claim or amended reimbursement claim from being submitted on time. |
The information you submit will be reviewed by the state agency [OKDHS School Nutrition Programs (SNP)] and forwarded to the United States Department of Agriculture (USDA) for review and approval. USDA is responsible for approving late claim exceptions for circumstances that are beyond the SFA’s control. OKDHS SNP does not have the authority to process this type of payment. That authority rests with the USDA regional office.
Other Late Claim Submissions
Downward Claim Adjustments: The 90-day time limit does not apply to downward adjustments. Federal regulations [7 CFR Pat 210.8 (b) (4) and 7 CFR Part 220.11 (b)] require that downward adjustments shall be made regardless of when it is determined that adjustments are necessary.
Review or Audit Findings: OKDHS School Nutrition Programs (SNP) may grant an exception for late upward adjustments that result from a review or audit. To request this type of exception, the School Food Authority (SFA) must submit information to OKDHS SNP as described in table 12.3 Required Actions for late claims adjustments.
Appeals - A SFA may submit a written appeal to OKDHS SNP regarding a claim or adjustment that has been denied due to 60 or 90-day submission deadlines.
Table 12.3 contains the required actions for School Food Authorities (SFA) to take for late reimbursement claims and reimbursement claim adjustments.
Table 12.3: Required Actions for Late Reimbursement Claims and Reimbursement Claim Adjustments |
· To submit a downward adjustment: Send revised claims to OKDHS SNP any time. · To submit an original claim after 60 calendar days, or upward adjustment after 90 days, that is late due to circumstances outside the SFA’s control: o Request an exception from OKDHS SNP by submitting a written description of the outside events and circumstances that prevented the claims from being submitted on time. o If the USDA denies the exception request, the SFA will be ruled out of compliance and the claim will not be paid. |
OKDHS School Nutrition Programs (SNP) may take administrative actions. Table 12.4 contains one or more of the administrative actions OKDHS SNP might have to require to bring the SFA into compliance with federal regulations.
Table 12.4: Administrative Actions to Bring SFA’s into Compliance with Requirements for Timely Submission of Reimbursement Claims and Reimbursement Claim Adjustments |
· Require the School Food Authority (SFA) to develop and carry out a plan for ensuring future compliance with time frames for reimbursement claim submissions/reimbursement claim adjustments. · Place the SFA in noncompliance on conditional status. · OKDHS School Nutrition Programs (SNP) conducted on-site reviews of the SFAs that are chronically in noncompliance. · To submit one original claim after 60 days, or one upward adjustment after 90 days, that is late due to circumstances within the sponsor's control (this exception available only if sponsor has not already used this type of exception, for the program/s claimed, within the previous 36 months): o Request an exception from OKDHS SNP by submitting signed documentation, including an outline of the procedures/actions taken by the SFA to avoid repetition of the situation that caused the error in claiming. o Before requesting this exception, the SFA should evaluate whether the late reimbursement claim or reimbursement claim adjustment is large enough, in relation to SFA's usual total reimbursement claim, to justify "using up" the exception for the affected program or programs for the next 36 months, or whether the exception should be "saved" for possible use during the following 36 months. · To submit late adjustments resulting from OKDHS SNP review findings or from audit findings: o If the adjustment resulted from an OKDHS SNP review, the OKDHS SNP staff will initiate the required claim adjustments. o If the adjustment resulted from an audit, submit: § Letter from auditor, or copy of the audit finding, specifying the necessary adjustment(s) § Signed documentation of the procedures/actions taken by the SFA to avoid repetition of the situation that caused the error. |
Procedures Applicable to Requests for All Types of Exceptions:
· To submit requests for all types for exceptions, scan the revised claim, the Corrective Action Plan (CAP), and other supporting documentation and submit by email to:
Oklahoma Department of Human Services
School Nutrition Programs
AFS.School.Nurition.Programs@okdhs.org
· Ensure the claim is complete with authorized signature.
· Review documents to ensure that Corrective Action Plan (CAP) contains sufficient details to enable OKDHS School Nutrition Programs (SNP) and USDA to make a fair decision, provide a written description of the events and circumstances that prevented timely submittal of the claim. The statement must provide a complete written description of the circumstances and justification for not meeting the deadline, including documentation, if available.
· OKDHS SNP will review the submitted information. If the exception is approved, claim(s) will be entered into the claim system by OKDHS SNP staff for payment processing. If the exception is denied, formal correspondence will be sent to the sponsoring authority.
Reimbursement Rates
Each year, USDA Child Nutrition Programs (CNP) will post the reimbursement rates for the National School Lunch Program (NSLP), School Breakfast Program (SBP), Afterschool Snacks and the Special Milk Program (SMP). These reimbursement rates are in effect from July 1 through June 30 of each year. Some School Food Authorities (SFA) will receive additional assistance for their meal program, dependant on the number of children eligible to receive reduced-priced meals and free meals. Contact OKDHS School Nutrition Programs after July 30 for the current reimbursement rates.
National School Lunch Program (NSLP) Reimbursement Rates
There are two different reimbursement rates for the National School Lunch Program (NSLP). School Food Authorities (SFA) claiming less than 60% of the lunches as free meals or reduced-priced meals in the second preceding year will receive reimbursement at the regular rate. SFAs that claimed 60% or more lunches in the free meal or reduced-priced meal category in the second preceding year are eligible for an extra 2 cents per meal. OKDHS School Nutrition Programs (SNP) will identify which schools will receive the higher rate.
Severe Need Breakfast Reimbursement Rates
School Food Authorities (SFA) that serve 40% or more free lunches and reduced-price lunches in the second preceding year are eligible for the Severe Need Breakfast Program and can receive a higher rate of reimbursement for free meals and reduced-priced meals. OKDHS SNP will determine which schools are eligible for severe need.
After School Snack Program
School Food Authorities (SFA) that administer afterschool care programs can receive reimbursement for serving snacks. SFAs who do not have more than 50% of the children eligible for free lunches and reduced-priced lunches will receive the regular reimbursement rates for snacks claimed at the free, reduced-priced, and paid price. Sites located in areas served by a school in which at least 50 percent of the enrolled children are eligible for free meals and reduced-priced meals are eligible to receive reimbursement at the free rate for snacks served to all children, regardless of each child’s eligibility for free or reduced-price meals.
Only SFAs participating in the National School Lunch Program (NSLP) can receive reimbursement for snacks. Under no circumstances may snacks be reimbursed in programs operated before or during the child’s school day. Schools are not eligible to receive reimbursement under this provision for snacks served on weekends or holidays, including vacation periods. For more information on the Afterschool Snack Program consult chapter 13 – Afterschool Snack Program.
Chapter Six Resource List
The resources listed in table 13.1 are available upon request to Oklahoma Human Services School Nutrition Programs by email at AFS.School.Nutrition.Programs@okdhs.org.
Table 13.1: Chapter Six Resources |
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OKDHS School Nutrition Programs prototype edit checks for schools |
OKDHS School Nutrition Programs prototype edit check for RCCIs |
Attendance factor worksheet |
Attendance factor calculation sheet |
Muti-site self-review forms |
Reimbursement rates for the current school year. |
OKDHS School Nutrition Programs online claiming instructions |
Afterschool Snack Program Self-Monitoring Checklist |
The resources listed below in table 11.2 are available online.
Table 13.2: Chapter Six Online Resources |
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USDA webpage for reimbursement rate webpages: |
OKDHS School Nutrition Programs webpage: |
