CACFP Late Claims

There are two types of adjusted claims that can be submitted after the claim submission deadline:

• Changes to meal data that result in no increase in reimbursement
• Downward adjusted claims that must be submitted to correct an error that resulted in the program operator being overpaid

Adjusted claims that are submitted after the claim submission deadline and result in an increase in reimbursement cannot be processed. Upward adjusted claims submitted after the deadline will automatically be rejected for payment in the Child Nutrition Information and Payment System (CNIPS) and will not be processed unless the reasons for a late submission meet one or more of the criteria described below.

A late claim may be considered for payment in the following three instances:

I. Administrative Review or Independent Audit
The state agency (SA) may adjust claims to correct errors discovered on an earlier claim by an administrative review (AR) or an independent audit. The California Department of Social Services (CDSS) processes AR reports for fiscal action and may adjust claims after operators sign and acknowledge the report findings. In order to determine the fiscal action for independent audits, the operator’s authorized agent or representative must submit a copy of the audit to the CDSS for processing and potential claim adjustments. If the resulting fiscal action from an AR report or independent audit generates an upward adjusted claim, the CDSS will reimburse agencies without requiring them to utilize their one-time only exception option for late claims. The claiming error must be identified in the AR report or the independent audit as a finding with required corrective action or additional payment will not be approved.

II. One-time Only Exception
The SA may grant a one-time only (OTO) exception for reimbursing a valid late monthly claim once every 36 months to a Child and Adult Care Food Program (CACFP) operator. OTO exception payment is at the SA's discretion. To receive an OTO exception, an operator must submit an acceptable Corrective Action Plan (CAP) to the SA. The CAP must include the following items:

• A detailed explanation of the problems contributing to the late claim submission
• Description of actions being taken to avoid future late claim submissions
• A statement that the program operator understands that the one-time exception is only available once in a 36 month period for circumstances within the operator’s control with approval from the Child and Adult Care Food Program Branch (CACFPB)
• The signatures of the claim preparer and the operator’s authorized representative, who must be an employee of the program operator

Once the CDSS approves the OTO request, the program operator must certify and submit the OTO reimbursement claim in the CNIPS no more than 15 days after receiving approval from the CACFPB. 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, operators must proceed to the certification screen for the applicable month in the CNIPS claim entry module to finish submission.

The CDSS limits the use of the OTO to the federal fiscal year (October 1–September 30) in which the claim is late. Sponsors must submit their request for an OTO, including a complete and acceptable corrective action plan (CAP) form, to the CDSS CACFPB no later than December 15 of the following fiscal year.

III. Late claims approvable only by the U.S. Department of Agriculture (USDA)
The SA may forward program operator exception requests to the USDA if the operator demonstrates to the SA’s satisfaction that the circumstances resulting in the missed claim deadline were beyond the operator’s control. Circumstances beyond an operator’s control include, but are not limited to:

• Major breakdowns in mechanical processing accompanied by an inability to manually process the data; for example, a major data processing failure
• Natural catastrophes coupled with the operator's inability to manually process the data; for example, floods or earthquakes that destroy records, equipment, or facilities
• Unusual postal delays that are verified by a postal receipt or other specific verification from the postal service.
• Death or severe illness of key staff members in situations where it is not possible to assume the operator could have used backup staff members

Missed claim deadlines that are the result of staffing changes are not typically considered to be outside the operator’s control, as part of the operator’s agreement to participate states that operators will provide adequate supervisory and operational personnel for the effective management of the program.

The request for a USDA exception must include a letter that identifies which claim month(s) you are requesting and justifies that the reason for missing the claim submission deadline was clearly beyond the claim preparer’s control. The letter must explain in detail the extenuating circumstances that made it impossible to meet the deadline and that the deadline was not missed because of staffing issues, negligence, oversight, or workload backlog. The CACFPB will forward requests that meet the required criteria to the USDA for approval.

Please submit all requests for late claim exceptions to lateclaimsrequest@dss.ca.gov.