U.S. Department of Agriculture memorandum MW S&CNP: SA 09, April 18, 2002
FY 02 School and Community Nutrition Programs Policy Memorandum #02-23
This is to clarify the rules on the electronic file storage of scanned free and reduced-price meal applications. As you know, many school districts have become interested in retaining electronic copies of applications to lessen the burden of filing and retrieving paper copies and to reduce the number of file cabinets needed. Therefore, the number of school districts that are scanning completed free and reduced-price meal applications has been increasing.
Current regulations specify that the school food authority must properly document its claims for reimbursements, including retaining free and reduced-price meal applications for a minimum of three fiscal years after the submission of the last claim for reimbursement and as long as necessary to resolve any audits. For schools operating under Provision 2 or 3, base year applications and direct certification documentation must be retained during the period the Provision is in effect, including all extensions, plus three fiscal years after the submission of the last claim for reimbursement which employed the base year data and as long as necessary to resolve any audits. Additionally, the school food authority must have a system to update children’s eligibility status. The regulations do not specify that the documentation must be in paper form.
Generally, there is no need to retain the paper copies of the applications once they are scanned because they are “photo” copies of the original. However, we believe that as a precautionary measure, school food authorities must retain the paper copies until they have a secure and confidential backup system for their electronic files. A backup system includes any system that allows immediate access to the applications in the event of loss of the scanned copies or a system failure that prevents access to the scanned applications. The backup system may include, for example, having the scanned copies on microfiche or on a second independent computer system.
Lastly, the state agency has the authority to require that school food authorities retain paper copies.