Determining Eligibility for School Meals

Determining Eligibility for School Meals
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Determining Eligibility for School Meals
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Topic 1 | Determination Methods
Participants will: Describe how students may be determined to be eligible for free or reduced price meals (i.e. through Direct Certification, categorical eligibility or completion of a Household Application for Free and Reduced Price Meals). Background All schools participating in the School Nutrition Programs (SNP) (National School Lunch Program, School Breakfast Program, Afterschool Snack Program, and Special Milk Program) must make meals available to all students. Local Educational Agencies (LEAs) that claim reimbursement for free, reduced price, and paid meals under the United States Department of Agriculture (USDA) programs, administered through the Pennsylvania Department of Education (PDE), Division of Food and Nutrition (DFN), must ensure they have adequate documentation on file to support this claim(s). The eligibility determination process determines whether or not students are eligible for free or reduced price meals. The eligibility determination process must be done at the beginning of each school year. In addition, households may apply for meal benefits at any time throughout the school year. Continued on next slide.

Background (Continued) Students are determined to be eligible for free or reduced price meals through any of the following methods: Direct Certification A student is automatically eligible for free meals based on documentation obtained directly from the appropriate State or local agencies, or other authorized individuals. The students listed on the Direct Certification list are students who receive Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or Medical Assistance (MA) (with qualifying income). All LEAs that distribute and process applications are required to run Direct Certification at least three times during the school year (July 1 through September 30, October 1 through October 31, and November 1 through January 31). Sponsors participating in the Community Eligibility Provision (CEP) must perform Direct Certification at least once during the school year, prior to April 1. All LEAs must obtain their Direct Certification list from the Pennsylvania-Student Eligibility System (PA-SES) powered by PrimeroEdge. LEAs using the full PA-SES must send the Notice of Direct Certification letter to the file address listed in PA-SES. Continued on next slide.

Background (Continued) Students are determined to be eligible for free or reduced price meals through any of the following methods: Direct Certification (Continued) DC only LEAs must send the Notice of Direct Certification letter to the person listed under the Payee Name and Address1 column on the Direct Certification list. The Notice of Direct Certification letter is available through the Pennsylvania Electronic Application and Reimbursement System (PEARS) website. The Notice of Direct Certification letter must indicate the children are automatically eligible for free meals and the household does not have to submit a Household Application for Free and Reduced Price Meals. Eligibility determined through inclusion on the Direct Certification list must be extended to all other students living in the household (does not have to be a relative) even if their name(s) do(es) not appear on the Direct Certification list. Continued on next slide.

Background (Continued) Students are determined to be eligible for free or reduced price meals through any of the following methods: Categorical Eligibility - A categorically eligible child is automatically eligible for free benefits based on one of the following criteria: The child is validated as being in foster care as defined by the state in that the child has been adjudicated dependent and formally placed by a court or a State child welfare agency. The child is a member of a household receiving SNAP or TANF and a valid SNAP or TANF case number is indicated on the Household Application for Free and Reduced Price Meals. The child is homeless as determined by the LEA's homeless liaison or by the director of a homeless shelter. The child is migrant as determined by the State or local Migrant Education Program coordinator. The child is a runaway who is receiving assistance from a program under the Runaway and Homeless Youth Act and is identified by the LEA's liaison. The child is enrolled in Head Start. The child is enrolled in an eligible pre-kindergarten class. Continued on next slide.

Background (Continued) Students are determined to be eligible for free or reduced price meals through any of the following methods: Household Application for Free and Reduced Price Meals The Household Application for Free and Reduced Price Meals is completed by the household, and the student(s) is/are approved based on income or a SNAP/TANF case number. SNAP/TANF Case Number The Household Application for Free and Reduced Price Meals indicating a SNAP/TANF case number is taken at face value as long as the application is complete, and should not be validated. The SNAP/TANF case number should only be validated if verifying the application "for cause" because something is questionable and during the Verification process. Income-Based The household size and income levels indicated on the application are compared to the Income Eligibility Guidelines (IEGs) issued annually by the USDA. The guidelines to qualify for free meals are incomes at or below 130 percent of the Federal Poverty Guidelines. The reduced price guidelines are between 130 and 185 percent of the Federal Poverty Guidelines.

Topic 2 | Packet Requirements
Participants will: Describe the requirements for the application packet, including the contents of the packet, where to find Pennsylvania Department of Education (PDE), Division of Food and Nutrition (DFN), recommended forms/letters, how and when to distribute the packets, and appropriate procedures for collection of applications. Letter to Households Each school year the Letter to Households must be distributed to all households of children attending the school except for households whose children are on the Direct Certification list. The letter should inform the households that School Nutrition Programs are available and meals may be available free or at a reduced price. Sending the applications as early as possible in the school year ensures that eligibility determinations can be made as soon as possible. If the application is not included with the Letter to Household, the application must be available to households at all times. PDE recommends that LEAs send out the letters no earlier than four calendar weeks prior to the start of school. Letters can be sent by U.S. Mail, , or through information packets. An application may be included with the letter or notice. LEAs cannot send letters home at the end of the school year for the next school year. Applications cannot be accepted or processed prior to July 1st of each school year. Households that enroll students in an LEA after the start of the school year must be provided a letter and application when they enroll. Continued on next slide.

Letter to Households A PDE prototype letter and application can be found on the PEARS website. These items are available in 25 different languages on the USDA website. If you choose to modify the letter or application, it must be pre- approved by PDE. The required components of the letter are described in the Eligibility Manual for School Meals. In this letter households can also be encouraged to use the available online application tools within the Commonwealth of Pennsylvania’s Access to Social Services (COMPASS) website at to apply for free or reduced price meals, if the sponsor did not opt into PA-SES. If the sponsor opted into PA- SES, the households would apply online at for free or reduced price meals.

Household Application for Free and Reduced Price Meals A PDE prototype application can be found on the PEARS website. Prior approval from PDE is required if the LEA chooses to use their own application. LEAs cannot require one application for each child in a household. The required components of the application are described in the Eligibility Manual for School Meals. Families may also apply through COMPASS or PA-SES.

Distribution of Application For LEAs who uses only paper processes, a household application with instructions must be distributed with the Letter to Household at the beginning of each school year to households of all children in attendance at school. In accordance with the Child Nutrition and WIC Reauthorization Act of 2004, FNS encourages LEAs to make electronic applications available and accept applications electronically. LEAs may also scan paper applications. If the LEA uses electronic system for one of their processes, the letter to households must inform the household how to access the system in order to apply for benefits. The letter must also explain the household still has the option to submit a paper application, and must indicate how the household may obtain and submit a paper application from the school. The Household Application for Free and Reduced Price Meals may be sent in the mail, or distributed to students. For example, the school could include the application in a packet of school- related information addressed to the household but carried home to the household by the student at the beginning of the school year. Applications must be distributed in some manner. A public announcement that applications are available and that interested parties may pick one up is not sufficient. LEAs cannot pick out families that they think are eligible and only distribute applications to them. Applications must be available throughout the school year. Applications may not be distributed at the end of the school year for households to return at the beginning of the next school year. Directly certified students do not need applications, but LEAs must be discreet.

Collection of Completed Applications The collection of completed applications should be done in a discreet manner, preferably through a central office. Do not accept completed applications in the cafeteria during the meal service on the serving line.

Topic 3 | Prior Year Eligibility and Process Timeline
Participants will: Describe how to determine if free or reduced price meal benefits should be offered to students prior to processing applications and the timeframe for processing applications. Benefits Prior to Processing of Applications Prior to processing of applications for the new school year, students' eligibility from the prior school year must be carried over for the first 30 operating days of the new school year or until a new eligibility determination is made (whichever comes first). Applications from the prior year are only valid for the first 30 operating days of the new school year. Carryover of eligibility within an LEA is mandatory, whether a child is continuing in the same school or will attend a different school within the same LEA. The LEA must carryover a child’s eligibility status for no less than 30 operating days, unless a new eligibility determination is made prior to the end of the 30-day carryover period. When a student moves to a new school within an LEA, the LEA must carryover eligibility for free or reduced price benefits for: Children with approved applications on file from the previous year; Continued on next slide.

Benefits Prior to Processing of Applications (Continued) Children who are newly enrolled in the LEA, but who reside in a household where another child (i.e. a sibling) has an approved application on file from the previous year; Children directly certified for free meal benefits in the previous school year; Children who are newly enrolled in the LEA, but who reside in a household where another child (e.g., a sibling) was approved through direct certification with an Assistance Program in the previous year; Children determined Other Source Categorically Eligible for free benefits in the previous school year; and Children in kindergarten who were enrolled in Head Start under the jurisdiction of the same LEA during the previous school year. Continued on next slide.

Benefits Prior to Processing of Applications (Continued) When children move to a new LEA, either at the beginning of the new school year or during the summer months, the new LEA is encouraged to use the former LEA’s eligibility determination from the previous school year and carryover the child’s eligibility status. As stated in 7 CFR 245.6(a)(4), the receiving school may accept the former school’s eligibility determination without incurring liability for the accuracy of the determination. LEAs opting to do this can use the former LEA’s eligibility determination for up to 30 operating days, or until a new eligibility determination is made, whichever comes first. FNS strongly encourages carryover between LEAs to ensure students do not experience a gap in school meal access. Continued on next slide.

Application Processing Timeframe Household Application for Free and Reduced Price Meals must be reviewed and an eligibility determination made within ten (10) working days of the receipt of the application. Whenever possible, applications should be processed immediately, particularly for new students who do not have approved applications on file from the previous school year. If a student transfers from another LEA and an application is sent as part of his/her file, review the application to determine if it was approved correctly. If so, you may use this application as documentation of eligibility status. If it was not sent, you may contact the LEA to request a copy of the application. Note: USDA and FNS do not currently evaluate, recommend, approve, or endorse any software used for certification or verification purposes. LEAs are responsible for assuring that any automated certification and verification processes meet all regulatory requirements and policies, including the calculation of household income when multiple frequencies are reported.

Topic 4 | Complete Applications and Categorical v. Income Eligibility
Participants will: Describe the components of a complete Household Application for Free and Reduced Price Meals and will be able to explain the difference between categorical and income eligibility. Eligibility Criteria For a child to be eligible for free or reduced price meals, one of the following conditions must exist: The child is directly certified. This eligibility is extended to all students in the household. A list of directly certified students must be obtained from PA-SES. The child is determined to be categorically eligible based on certification of his or her status as homeless, migrant, runaway or Head Start, or foster. The homeless liaison at the school can provide a list of homeless and runaway students. A list of students certified as migrant must be obtained from PA-SES. The Head Start coordinator can provide the list of students in the federally funded Head Start and any State-funded pre- kindergarten program that use eligibility criteria that is identical or more stringent than Federal Head Start. Continued on next slide.

Eligibility Criteria For a child to be eligible for free or reduced price meals, one of the following conditions must exist: (continued) Documentation from the county court or state foster care system can provide confirmation of those children that are formally placed by the State welfare agency or court. Informal arrangements, those existing outside of or as a result of State or court systems, do not apply. The household submitted a complete application and is determined to be income eligible. The sum of the reported incomes for the household is at or below the Income Eligibility for the corresponding household size. The household submitted a complete application and the child is determined to be categorically eligible based on inclusion of a valid SNAP or TANF case number. This eligibility is extended to all students listed in the household. The household indicated on the application that the child is a foster child or the child has been directly certified eligible through documents obtained or provided by the courts or State or local foster agencies.

Complete Application for Categorical Eligibility If a SNAP or TANF case number is only provided, categorical eligibility must be extended to all students in the household If the application contains a SNAP or TANF case number and income, disregard the income. Children may also be categorically eligible due to their migrant, homeless, or runaway, or head start status. However, their eligibility cannot be determined based on self-declaration of this status on the application. These children must be certified through the LEA's homeless liaison (for homeless and runaway) or through PA-SES (migrant). If there is an indication on the application that the child may be categorically eligible based on homeless, migrant, runaway or Head Start status, the LEA must confirm the child's status. Foster children are categorically eligible if a Household Application for Free and Reduced Price Meals has indicated that a child is foster or the child has been directly certified eligible through documents obtained or provided by the courts or State or local foster agencies. Next slide displays an example of a complete application for determining categorical eligibility based on receipt of SNAP or TANF.

Complete Household Application for Free and Reduced Price Meals for Income Eligibility Next slide displays an example of a complete application for determining income eligibility.

Complete Application for Foster Child A foster child is a child who is living with a household but remains the legal responsibility of the welfare agency or court. For the purposes of eligibility determination: When foster parents apply for benefits for their own children, they may include foster children as members of their household. The foster child(ren) remain(s) categorically eligible, even if the other children in the household do not qualify. When a foster child is indicated on a household application, it is taken at face value. If a foster child is indicated with other children in the household, the foster child(ren)’s personal income must be reported as part of the household income. The foster child's income includes funds provided by the welfare agency that are identified for the child's personal use such as for clothing, school fees, and allowances. Welfare funds paid to the foster parents for shelter and care and those identified as special needs funds, such as those for medical and therapeutic needs are not considered income. Welfare funds that cannot be identified by category are considered income. Other funds received by the child (i.e. any income the child earns through employment and money provided by the child's family for personal use) are considered income. Continued on next slide.

Complete Application for Foster Child An adopted child for whom a household has accepted legal responsibility is considered to be a member of that household. If the adoption is a “subsidized” adoption, which may include children with special needs, the subsidy is included in the total household income. Other adoption assistance payments are also included as income. Because some adopted children may first be placed in families as foster children, parents may not be aware once a child is adopted, the child is no longer categorically eligible for free meals as a foster child. Due to year-long eligibility, the free eligibility status of a foster child would not change within the school year, including up to 30 operating days into the subsequent school year, if the child is adopted. However, for the subsequent school years, an adopted child must be determined eligible based on the economic unit. All income available to that household, including any adoption assistance, is counted in establishing eligibility. Please remember that the household size and income does not affect the free eligibility of the foster child.

Topic 5 | Income Computation and Eligibility Determination
Participants will: Describe how to compute income listed on applications and will compare income computed from applications to "Income Eligibility Guidelines" to determine eligibility. Computation of Income The income amount must be the most recent information available, which may be: Households can provide income for the current month, or Households can submit projected income for the first month the household completes the Household Application for Free and Reduced Price Meals, or Households can submit current income received for up to one month prior to completing the Household Application for Free and Reduced Price Meals LEAs must compute household's current income and compare it to the current Income Eligibility Guidelines (IEGs) IEGs are updated yearly (July) and can be found on the PEARS website Income must be identified with the individual who received it, the source of the income including the frequency of which the income is paid. It is the responsibility of the determining official to compute the household's total income and compare the total amount to the current Income Eligibility Guidelines.

Income Frequencies One or more incomes may be reported on an application. Income frequencies reported may be weekly, bi-weekly (every two weeks), semi-monthly (twice a month), monthly, or annually. Note: Annual income is acceptable. Review the Eligibility Manual for detailed guidance. Use the flowchart on the right to determine how to compute total income. Instructions for Determining Eligibility for School Meals with Same/Different Income Frequencies are on the next slide.

Determining Eligibility for School Meals with Same/Different Income Frequencies.

Topic 6 | Approval, Acquiring Missing Information, Recordkeeping, and Confidentiality
Participants will: Describe procedures for approving applications, steps to take to obtain required information if applications are not complete, and recordkeeping as well as confidentiality requirements. Application Approval or Denial Households that submit a complete application with a valid SNAP or TANF case number must be approved for free meals for all students in the household. Households that submit a complete application indicating total income at or below income limits for free or reduced price meals must be approved for free or reduced price meals, as appropriate. When a household reports zero or temporary reduction in income, income eligibility is determined based on the present rate of income. Temporary approval of an application is not permitted since the duration of eligibility is for the entire school year and 30 operating (school) days in the subsequent school year. Continued on next slide.

Application Approval or Denial Incomplete applications If any required information is missing, the information must be obtained before an eligibility determination can be made. Applications missing the signature of an adult household member must be returned for signature. Every reasonable effort should be made to obtain the missing information prior to denying the application. To get the required information, the school may return the application to the household or contact the household either by phone or in writing. The determining official should document the details of the contact, then date and initial the entry. If there are inconsistencies or questions concerning the required eligibility information provided, the household’s application must be denied unless the inconsistencies or questions are resolved. The official may contact the household prior to denial, document the details of the contact, then date and initial the entry. Determination of eligibility must not be delayed due to missing non-required information.

Recordkeeping Requirements Household Applications for Free and Reduced Price Meals, including denied and inactive applications, must be retained for three years plus the current school year. Files must be kept longer if they are required for audit purposes. These files must be retained until audit findings have been resolved.

Disclosure of children’s eligibility information is a sensitive and complicated issue. LEAs may choose to disclose eligibility information to programs, activities, and individuals that are specially authorized access under the National School Lunch Act. The agency responsible for making the eligibility determination (i.e. the LEA or school administration) makes the decision about whether or not to disclose this information. The LEA may disclose aggregate information to any program or individual when children cannot be identified through release of the data or through deduction. An example of aggregate data is the number of children eligible for free and reduced price meals in a school district. Release of this type of data does not identify individual children. Therefore, parental consent is not required. LEAs are cautioned about release of aggregate data when children’s eligibility status may be deduced, such as release of eligibility information about a specific classroom when the number of eligible children may be very small. The Eligibility Manual for School Meals includes a chart outlining circumstances and requirements involved in disclosing eligibility information.

Topic 7 | Notification and Changed Circumstances
Participants will: Describe proper procedures for notifying households of their eligibility status and the expectations of households when/if circumstances change throughout the school year. Notification of Eligibility Determination All households must be notified of their eligibility status by letter, via , telephone, or by using an automated notification system. Households denied benefits must be given written notification of the denial through the postal service or an to the parent or guardian. The notification must advise the household of: The reason for denial The right to appeal Instructions on how to appeal A statement that households may re-apply at any time during the school year Continued on next slide.

Prototype of Notice of Approval/Denial (PDE017a.pdf)

Topic 7 | Notification and Changed Circumstances
Changes in Household Circumstances Eligibility for free and reduced price meals remains valid for the entire school year except when verification indicates a reduction or termination of benefits. However, households may voluntarily report changes. If a household reports a change that will increase benefits (paid to free, reduced to free, etc.), the LEA must put that change into effect immediately. If the change will decrease (free to reduced) or terminate benefits, the LEA must explain to the household that the change does not have to go into effect but that the household may request that the lower benefits go into effect. If this is the case, the household should be sent a notice of adverse action (We Have Checked letter). Refusal of Free or Reduced Price Meals If a household refuses free or reduced price meals, the LEA must discontinue benefits immediately and must document the refusal. Administration Submitting Application If a household does not submit a Household Application for Free and Reduced Price Meals, the administration (i.e.superintendent, principal, etc.) may submit an application for the household. However, the administration must have real knowledge of a household’s income. For example, if the household was applying for a grant and had to submit their household income with the grant application, the administration may use that income information to complete an application.

Topic 8 | Eligibility Manual for School Meals
Participants will: Sponsors will become familiar with the “Eligibility Manual for School Meals. Sources of Information about Eligibility Manual for School Meals The Eligibility Manual for School Meals Manual contains information on determining eligibility for free and reduced price meals. All information from this module is in this manual. You can download a copy of this manual using this link. Child Nutrition Program Electronic Application and Reimbursement System (CN PEARS) website PDE, DFN, PEARS website includes notices about workshops, changes in procedures, and reminders about deadlines for financial reports. Check the PEARS website at least weekly. You can access CN PEARS by using this link.

Determining Eligibility for School Meals

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