1. Verification Kentucky Department of Education September 2012

2. What is Verification? Verification is the confirmation of eligibility for free and reduced price meals under the NSLP and SBP. Verification is only required when eligibility is determined through the application process. Verification must include either confirmation of income eligibility or confirmation that the child or any member of the household is receiving assistance under SNAP (formally food stamps) or TANF (formally welfare) or that a child is Other Source Categorically Eligible. Verification may include confirmation of any other information required on the application such as household size.

3. Verification vs. Verification for Cause

4. Verification For Cause Verification for cause is when an application is verified outside of the required verification procedures reported to the State Agency. Verification for cause is when an application is verified outside of the required verification procedures reported to the State Agency.

5. Eligibility Guidance for School Meals August 2012 August 2012 Reflects changes from: Reflects changes from: –Reauthorization of 2010, –Final and interim regulations, –Policy clarifications. www.fns.usda.gov/cnd www.fns.usda.gov/cnd www.fns.usda.gov/cnd

6. Verification Not Required Children who have been directly certified through the monthly electronic downloads for Foster Children, SNAP/KTAP and Medicaid recipients. Children who have been directly certified through the monthly electronic downloads for Foster Children, SNAP/KTAP and Medicaid recipients. Children appropriately documented by the District as eligible migrant, homeless or in a federally funded Headstart or Even start slot in a District operated program (not a State funded Slot). Children appropriately documented by the District as eligible migrant, homeless or in a federally funded Headstart or Even start slot in a District operated program (not a State funded Slot). Residential children in a RCCI (non residential students are included in verification). Residential children in a RCCI (non residential students are included in verification). Non base year applications for Provision 2 or 3. Non base year applications for Provision 2 or 3.

7. Verification Process I. Determine type of verification II. Select Applications for Verification III. Conduct Confirmation Review (Replacement Applications) IV. Household Notification V. Conduct Verification VII. Verification Report to SA (742) VI. Verification Results

8. Timeline of Verification Activities October 1st – Day that establishes the sample pool. October 1st – Day that establishes the sample pool. November 15 th – All verification activities must be complete or SFA must have an approved extension with SCN. November 15 th – All verification activities must be complete or SFA must have an approved extension with SCN. *February 15 th – Verification Reporting in Colyer *February 15 th – Verification Reporting in Colyer * More information to come

9. Determine Type of Verification Standard Sample Size – Calculation for # of error prone applications to verify. Standard Sample Size – Calculation for # of error prone applications to verify. Alternate One Sample Size –Calculation for the # of random applications to verify. Alternate Two Sample Size – 2 step calculation that provides a combination of error prone applications and applications approved based on a case number on their application. I.

10. Prior Approval Required All SFA’s must use the Standard Sample Size Verification type unless approval is obtained from SCN to use Alt 1 or Alt 2 prior to Verification activities on October 1 st. All SFA’s must use the Standard Sample Size Verification type unless approval is obtained from SCN to use Alt 1 or Alt 2 prior to Verification activities on October 1 st. Approvals this year are conducted by emailing your approving consultant. If an approval is given, keep on file with verification records. Approvals this year are conducted by emailing your approving consultant. If an approval is given, keep on file with verification records.

11. Alternate Approval Eligibility The LEA’s non response rate was less than 20% for the previous year. The LEA’s non response rate was less than 20% for the previous year. If the LEA has more than 20,000 children approved for free or reduced benefits by application and show a 10% decrease in their non response rate from the previous year. If the LEA has more than 20,000 children approved for free or reduced benefits by application and show a 10% decrease in their non response rate from the previous year. The above is based on the assumption that the verification sample sizes were correctly calculated and the correct number and types of applications were verified. Approval will not be granted if the verification process if found invalid during a CRE in the previous school year or through Verification reporting to the SA in the previous year.

12. Sample Pool The sample pool for all types of verification is based on the number of free and reduced applications on file as of October 1 st. August 2012 Eligibility Manual

13. Sample Size Calculations All fractions or decimals are rounded up to the nearest whole number. Example – 6.1 would be 7 applications. All fractions or decimals are rounded up to the nearest whole number. Example – 6.1 would be 7 applications. LEA’s may not verify more or less than the calculated sample size. For the example above, only 7 applications can be verified. Not 6 or less and not 8 or more. LEA’s may not verify more or less than the calculated sample size. For the example above, only 7 applications can be verified. Not 6 or less and not 8 or more. August 2012 Eligibility Manual

14. Standard Verification The number of applications in the sample pool X 3% (.03) = The number of applications to verify, selected from error prone applications. *The maximum number of applications to verify is 3,000 applications.

15. Standard Sample Size 900 total applications: 900 total applications: –600 income applications –300 SNAP/TANF Case number applications 900 X.03 = 27 900 X.03 = 27 27 “error prone” applications to Verify 27 “error prone” applications to Verify August 2012 Eligibility Manual

16. Alternate One (Alt 1) The number of applications in the sample pool X 3% (.03) = The number of applications to verify, selected randomly. *The maximum number of applications to verify is 3,000 applications.

17. Alternate 1 Sample Size 900 total applications: 900 total applications: –600 income applications –300 SNAP/TANF Case number applications 900 X.03 = 27 900 X.03 = 27 27 randomly selected applications to Verify 27 randomly selected applications to Verify August 2012 Eligibility Manual

18. Alternate 2 (Alt 2) Two part calculation Part 1: The number of applications in the sample pool X 1% (.01) = the number of applications to verify selected from error prone applications. *Maximum of 1,000

19. Alternate 2 Sample Size Part 2: One-half (1/2) of one percent (1%) or.005 X the number of applications approved based on a case number for SNAP/KTAP = the number of applications to verify approved categorically eligible. *Maximum of 500

20. Alternate 2 Sample Size Part 1 (error prone apps) + Part 2 (Case number apps) = Total number of applications to verify

21. Alternate 2 Sample Size 900 total applications: 900 total applications: - 600 income applications - 300 SNAP/TANF applications 900 X.01 = 9 (Part 1) 900 X.01 = 9 (Part 1) 300 X.005 = 1.5, round up to 2 (Part 2) 300 X.005 = 1.5, round up to 2 (Part 2) 9 error prone applications + 2 SNAP/TANF Case number applications = 11 total applications to verify. 9 error prone applications + 2 SNAP/TANF Case number applications = 11 total applications to verify. August 2012 Eligibility Manual

22. Selecting Applications Error Prone Error Prone Categorical Eligible (Case #) Categorical Eligible (Case #) Random Random II

23. Selecting Applications Error Prone Applications Type of application to pull when conducting Standard and Alternate 2 Verification. Type of application to pull when conducting Standard and Alternate 2 Verification. Definition: Applications that are within $100 per month ($1200 annually) of the applicable Income Eligibility Guideline.

24. Selecting Applications Categorical Eligible (Case #) Application approved based on a valid case number for SNAP/KTAP on an application. Type of application to pull in Alternate 2 Verification.

25. Selecting Applications Random Can be any application type. Error Prone, Non Error Prone or Case Number. Use for Alternate 1 Verification.

26. Conduct Confirmation Review Required to be conducted on all applications pulled for verification PRIOR TO notifying the households of their selection for verification or conducting Direct Verification activities. Required to be conducted on all applications pulled for verification PRIOR TO notifying the households of their selection for verification or conducting Direct Verification activities. An LEA official, other than the official who made the initial eligibility determination must review each approved application selected to ensure the initial determination was correct. An LEA official, other than the official who made the initial eligibility determination must review each approved application selected to ensure the initial determination was correct. III August 2012 Eligibility Manual

27. Confirmation Review Steps 1. Ensure that household members are not on the Direct Certification list. Apps should not be included if the household members can be identified as direct cert. 2. Identify how the determining official approved the application, income vs. case number. If a valid case number was provided, ensure that application is marked as being approved based upon a case number and not by income.

28. Confirmation Review Steps 3. Once it has been established how the application was determined (income vs. case number), review the eligibility manual to ensure that the application was approved correctly. (Part 4 of Eligibility Manual for income applications and Part 5 for categorical Eligibility. If the application does not have all required items, it is considered incomplete.

29. Confirmation Review Steps 4. Depending upon the outcome of each confirmation review, the LEA takes one of the following actions: No change in status No change in status –If initial eligibility status was correct, the LEA verifies the application. August 2012 Eligibility Manual

30. Confirmation Review Status change from reduced price to free: Status change from reduced price to free: –Make the increased benefits available immediately; Notify the household of the change in benefits; Verify the application. August 2012 Eligibility Manual

31. Confirmation Review Status change from Free to Reduced: Status change from Free to Reduced: –Do not change the child’s status; Verify the application August 2012 Eligibility Manual

32. Confirmation Review Status change from Free or Reduced to Paid: Status change from Free or Reduced to Paid: –Immediately send the household a notice of adverse action; Do not verify the application; Select a similar application for verification; follow confirmation review procedures for the newly selected application. August 2012 Eligibility Manual

33. Replacing Applications. Used when the status changed to Paid during the confirmation review or if the LEA believes the household would be unable to satisfactorily respond to the verification request. Used when the status changed to Paid during the confirmation review or if the LEA believes the household would be unable to satisfactorily respond to the verification request. Replace with a like application. (Example, Error prone for error prone) Replace with a like application. (Example, Error prone for error prone) Can replace up to 5% of applications Can replace up to 5% of applications August 2012 Eligibility Manual

34. Household Notification Letter Requirements Household was selected for verification Household was selected for verification Use of information statement Use of information statement The types of acceptable information The types of acceptable information May provide proof that a child or other household member receives SNAP/KTAP benefits May provide proof that a child or other household member receives SNAP/KTAP benefits IV August 2012 Eligibility Manual

35. Household Notification Documentation of income or receipt of assistance may be provided at any point in time between the month prior to application and the time the household is required to provide income documentation Documentation of income or receipt of assistance may be provided at any point in time between the month prior to application and the time the household is required to provide income documentation Information must be provided by due date or benefits will be lost Information must be provided by due date or benefits will be lost August 2012 Eligibility Manual

36. Household Notification Provide a name of an LEA official who can answer questions and provide assistance Provide a name of an LEA official who can answer questions and provide assistance A toll free number households can use to contact the LEA or instructions on how to call collect A toll free number households can use to contact the LEA or instructions on how to call collect *May have to rent a toll free line during the verification time period. August 2012 Eligibility Manual

37. Conducting Verification For income applications, households must submit documentation for each income type reported for each household member. For income applications, households must submit documentation for each income type reported for each household member. For Case number applications, households must submit an official letter, notice or list from the appropriate State agency. For Case number applications, households must submit an official letter, notice or list from the appropriate State agency. For all other types of categorical eligibility documentation requirements – refer to the Eligibility Manual. For all other types of categorical eligibility documentation requirements – refer to the Eligibility Manual. August 2012 Eligibility Manual V

38. Conducting Verification Timeframe Timeframe Documentation can be from 1 month prior to the date of the application until the time when the documentation is due.

39. Conducting Verification Direct Verification Conducted prior to notifying the household Conducted prior to notifying the household Must use SCN direct verification form to send to appropriate agency with the names of the school children listed on the app. Names of other household members and non school age children should not be included. *DIRECT VERIFICATION CANNOT BE CONDUCTED VIA A PHONE CALL TO THE AGENCY! Must use SCN direct verification form to send to appropriate agency with the names of the school children listed on the app. Names of other household members and non school age children should not be included. *DIRECT VERIFICATION CANNOT BE CONDUCTED VIA A PHONE CALL TO THE AGENCY! If unable to verify eligibility, the LEA must proceed with regular verification activities If unable to verify eligibility, the LEA must proceed with regular verification activities August 2012 Eligibility Manual

40. When Verification is Considered Complete The household submits either adequate written evidence or provides collateral contact corroboration of all income or categorical eligibility The household submits either adequate written evidence or provides collateral contact corroboration of all income or categorical eligibility –Verification is considered complete for this household.

41. When Verification is Considered Complete The household submits adequate written evidence or collateral contact corroboration of income that indicates that the household should receive a greater or lesser benefit level. The household submits adequate written evidence or collateral contact corroboration of income that indicates that the household should receive a greater or lesser benefit level. –Complete when the notice of adverse action is sent to the household or notification of an increase in benefits.

42. When Verification is Considered Complete The household indicates *verbally or in writing that it no longer wishes to receive benefits. The household indicates *verbally or in writing that it no longer wishes to receive benefits. –Complete when the notice of adverse action sent

43. When Verification is Considered Complete The application was approved based on a case number and it is determined that no household member is receiving benefits from an assistance program The application was approved based on a case number and it is determined that no household member is receiving benefits from an assistance program –Complete when the notice of adverse action is sent August 2012 Eligibility Manual

44. Conducting Verification Follow Up The LEA must make at least one follow-up attempt to contact the household when the household does not adequately respond to the request for verification. Follow up may be in writing or phone with documentation that a contact was attempted (initial statement, date and time) August 2012 Eligibility Manual

45. Conducting Verification Follow up cont… Must inform the household that failure to provide adequate written evidence or to designate an adequate collateral contact will result in termination of benefits. Must inform the household that failure to provide adequate written evidence or to designate an adequate collateral contact will result in termination of benefits. Attempt to obtain the missing written evidence or obtain collateral contact information Attempt to obtain the missing written evidence or obtain collateral contact information August 2012 Eligibility Manual

46. Conducting Verification The deadline to complete verification activities is November 15 th. The deadline to complete verification activities is November 15 th. Extension requests must be made in writing to SCN. State agencies may approve an extension up to December 15 th. Beyond December 15 th must be approved by USDA. Extension requests must be made in writing to SCN. State agencies may approve an extension up to December 15 th. Beyond December 15 th must be approved by USDA.

47. Verification Results If benefits increased, the change is effective immediately, implemented within 3 working days and the household notified. If benefits increased, the change is effective immediately, implemented within 3 working days and the household notified. If benefits decreased, a notice of adverse action must be sent. If benefits decreased, a notice of adverse action must be sent. VI August 2012 Eligibility Manual

48. Verification Results Adverse action letter requirements Change in benefits Change in benefits Reason for change Reason for change Appeal must be filed within 10 calendar days and benefits will not change while awaiting a hearing and decision. Appeal must be filed within 10 calendar days and benefits will not change while awaiting a hearing and decision. Instructions on how to appeal Instructions on how to appeal May re-apply for benefits at any time during the school year May re-apply for benefits at any time during the school year If terminated because no member was receiving benefits from SNAP/KTAP, may apply and provide income information. If terminated because no member was receiving benefits from SNAP/KTAP, may apply and provide income information. August 2012 Eligibility Manual

49. Verification Results Households whose benefits were reduced or terminated may re-apply at any time during the school year. If benefits were terminated, the household is required to submit income documentation or proof of participation in SNAP/KTAP program. August 2012 Eligibility Manual

50. Verification Results Record Keeping Description of verification efforts including a summary of the selection process; the total number of applications on file on October 1 st and the number of apps that are/will be verified by Nov 15 th. Description of verification efforts including a summary of the selection process; the total number of applications on file on October 1 st and the number of apps that are/will be verified by Nov 15 th. Compliance with the confirmation review Compliance with the confirmation review Provision of a no-cost telephone number for assistance in the verification process Provision of a no-cost telephone number for assistance in the verification process August 2012 Eligibility Manual

51. Verification Results Recordkeeping cont… For each application: source documentation used to verify the application; correspondence; written records documented by the LEA when a written records was not otherwise available; any other information necessary to show the efforts by the LEA meet verification requirements; criteria used to replace applications. For each application: source documentation used to verify the application; correspondence; written records documented by the LEA when a written records was not otherwise available; any other information necessary to show the efforts by the LEA meet verification requirements; criteria used to replace applications. August 2012 Eligibility Manual

52. Verification Reporting Form FNS – 742 Form FNS – 742 New this year! Verification reporting will be conducted in the Colyer system. New this year! Verification reporting will be conducted in the Colyer system. VII

53. Verification for Cause Not included in the annual verification process or reported to the SA. Not included in the annual verification process or reported to the SA. LEA’s must verify all questionable applications. LEA’s must verify all questionable applications. If application is complete with all required information it must be process and an eligibility status awarded. If application is complete with all required information it must be process and an eligibility status awarded. Once Eligibility status determined, then a letter for verification can be sent to the household. This letter can go out at the same time that notifies them of their benefits. Once Eligibility status determined, then a letter for verification can be sent to the household. This letter can go out at the same time that notifies them of their benefits.

54. Verification for Cause School District Employees Cannot automatically verify households of school district employees because salary information is available. Cannot automatically verify households of school district employees because salary information is available. Can be used if the LEA finds the application questionable and is therefor subject to verification for cause otherwise. Can be used if the LEA finds the application questionable and is therefor subject to verification for cause otherwise. It is recommended to consult with legal counsel in establishing the parameters of verification for cause when it involves a school district employee It is recommended to consult with legal counsel in establishing the parameters of verification for cause when it involves a school district employee August 2012 Eligibility Manual

55. To ensure that all verification requirements are met. It is a best practice to have documentation second partied to ensure the records are complete in order to avoid findings in an administrative review. If you utilize a system to conduct verification, double check all system provided information. The LEA is responsible for the information even if the system did not provide it properly.

56. Verification Questions?