Meal Benefit Eligibility and Verification for Certifying Students’ Eligibility for Meal Benefits Benefit Issuance Verification

Meal Benefit Eligibility and Verification for Today, we will explain: How to determine eligibility and document same; Steps to take to ensure students receive the benefits you determine; and, How to conduct Verification and report the results

Meal Benefit Eligibility and Verification for USDA issued: Eligibility Manual for School Meals August 2014 edition Determining and Verifying Eligibility

Meal Benefit Eligibility Some Absolute Truths: Applications go out to all households Must provide guidance and application in any language necessary (Civil Rights) Use prototypes; many other languages available at fns.usda.gov

Meal Benefit Eligibility Some Absolute Truths: Eligibility carryover for up to 30 operating days Include new students from households with children approved previous year New determination in effect immediately

Meal Benefit Eligibility Some Absolute Truths: New apps processed within 10 operating days

Meal Benefit Eligibility Establishing Eligibility: Automated Data Matching – eDC Direct Certification – letter method Meal Benefit Application: 1. Categorical Eligibility 2. Household Size and Income

Meal Benefit Eligibility eDC: Supersedes all Established through matching of school’s student database with children living in SNAP households Eligibility extended to other household members (who may not be on list)

Meal Benefit Eligibility Direct Certification – letter method: When school-aged children’s names on SNAP list don’t match school enrollment, letter generated by DHS that household can submit in lieu of completing application Not included with eDC numbers

Meal Benefit Eligibility Meal Benefit Application: Categorical Eligibility: Case number from assistance program (SNAP, RI Works) needed for any member of household – Part 2 of application; case number in RI is 9 digits

Meal Benefit Eligibility Other Categorical Eligibility: Foster Homeless

Meal Benefit Eligibility Foster Child(ren): A foster child is categorically eligible for free meals A foster child’s application is included in the Verification pool

Meal Benefit Eligibility Foster Child(ren): The foster child and his/her personal income can be included in the household size and income when determining the eligibility of other household children

Meal Benefit Eligibility Homeless children are categorically eligible for free meals; further, such students should be certified as such by school’s homeless liaison. If so certified, homeless students’ eligibility is not subject to Verification

Meal Benefit Eligibility Income-based applications: Only convert income to annual if multiple intervals if income reported If so, use X 52 for weekly; X 26 for bi- weekly; 24 if semi-monthly; and 12 if monthly No decimal places for converting

Meal Benefit Eligibility “0” Income reported: Get written explanation for circumstances, i.e., how living with no income? If questionable ( any app, actually), verify for cause No temporary approvals

Meal Benefit Eligibility Notification of Determination: Households must be notified of status Notification of approval for free/reduced-price meals can be verbal Denial of benefits must be in writing (prototype letter) including appeal process

Meal Benefit Eligibility Effective Date of Determinations NEW – LEAs can choose to use the date of the submitted application as effective date Also applies to direct certification (eDC) LEAs must notify RIDE if choosing this flexibility and do so in all schools

Benefit Issuance Benefit Issuance refers to the process of making sure eligible students receive the appropriate benefits and not ineligible students How do the people serving and recording meals know the eligibility of each student?

Benefit Issuance A computer roster identifies students at the point-of-service Paper rosters are only manageable in the smallest of schools Must be discrete and used in a confidential manner – No F,R,Ps on paper roster Update real time

Verification What is Verification? Important dates- October 1 October 31 November 15 December 15

Verification Verification is confirmation of eligibility for free and reduced price meals. Verification is only required when eligibility is determined through the application process

Definitions Error Prone – means applications within $1200 per year of the applicable Income Eligibility Guidelines] Random Sampling – means each application has an equal chance of being selected; LEAs must determine a selection interval by dividing the number of applications by the required sample size

Definitions (cont’d) Sample Pool – means the total # of new applications on file as of October 1 Sample Size – means the number of applications subject to verification; the minimum and maximum sample size is three percent total (rounded up!)

Direct Certification e Direct Certification – through data match with DHS via eRIDE Direct Certification – letter from DHS taken in lieu of completed application – letters only generated when name doesn’t match eDC Students approved for free meals by Direct Certification are not included in the Verification Process

VERIFICATION DATES Verification sample is based on # applications on file as of October 1 st Verification must be completed by November 15 th

VERIFICATION SELECTION 3% of all approved applications –not students - on file as of 10/1 May omit applications for afternoon kindergarten Special Milk Program participants must be selected from error-prone apps

ERROR-PRONE APPLICATION Those that indicate monthly income is within $100 of the monthly income eligibility limits or within $1200 of the annual income guidelines

How is Verification conducted?  Mail “We must check your application” letter and verification paperwork to every household selected for verification  Make at least one “follow-up contact” with households who do not respond/submit documents (keep record of follow-up contact)

VERIFICATION FOLLOW-UP LEAs must provide a toll-free number households can call for assistance LEA is required to make at least 1 add’l attempt to obtain information

VERIFICATION: INCOME DOCUMENTATION Income documentation may be from any point in time between the month prior to application and the time the household is required to provide documentation

How is Verification conducted?  Receive documents from household to verify information on application  Examine documents submitted by households  Confirm or change household’s eligibility status based on documents they submit  Mail “We have Checked Your Application” letter to family with results of verification

How is Verification conducted? Once an application is randomly selected, you must follow through to a final result

VERIFICATION: CONFIRMATION REVIEWS Prior to verification of a selected application: LEAs must have the initial determination reviewed for accuracy by someone other than the original approving official Exception: “accurate” technology-based determinations

CONFIRMATION REVIEWS (cont.) If the original determination is incorrect, the LEA must: 1. Correct the household’s eligibility status; 2. Notify the household and explain the change 3. Allow the household to reapply and provide documentation

CONFIRMATION REVIEWS (cont.) If a confirmation review indicates that a household is eligible, the LEA must proceed to verify the application.

Completing Verification Verification is complete when household eligibility for the level of benefits is: Confirmed at the same eligibility level Changed to a higher eligibility level Benefits denied or reduced because household does not qualify

Completing Verification Results of Verification: Letter of adverse action (We have Checked Your Application) is sent informing the household that benefits will remain the same or be reduced Letter of adverse action is sent informing the households that benefits will be terminated (changed to paid status)

Time Periods for Changing Eligibility Status Reduction or Termination of benefits – household has 10 calendar days from date on written notice to file for Appeal Increase in benefits – effective immediately and must be implemented no later than 3 operating days after decision

Completing Verification Verification is complete the day you send out notices to households Do not forget to change student(s)’ status at the appropriate time (immediate for increase; on the 11 th day after notice is given if benefits are reduced)

Common Review Findings Not completed on time (11/15) Too many or two few applications selected Documents submitted by households not evaluated correctly Changes not made to eligibility rosters/POS

Verification for Cause Obligation to verify “for cause” any questionable applications Zero or unreasonably low incomes School district employee applications that don’t correspond to known income Separate from annual Verification

Verification for Cause (cont’d) Send request for Verification with or at the same time as approval letter For zero income applications, request an explanation for how living expenses are met Collateral contacts # of applications verified for cause reported separately on new FNS-742

Reporting Results – FNS 742 Verification results are an important part of national evaluation of student eligibility statistics Numbers reported support school eligibility percentages which in turn support funding formula, e-rate, Title 1 All LEAs must complete the FNS 742