2. 2 The U.S Department of Agriculture prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or all or part of an individual ’ s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.) If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.USDA Program Discrimination Complaint Formttp://www.ascr.usda.gov/complaint_filing_cust.htmlprogram.intake@usda.gov Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish). USDA is an equal opportunity provider and employer. 6/2013

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4. Federal Policy for determining and verifying eligibility http://fns.dpi.wi.gov/fns_fincou1#manual Eligibility Manual for School Meals, August 2013, Part 8 is Verification  Terms related to the Free and Reduced-price eligibility process (helpful to understand parts of verification) are included in Eligibility Manual (EM) Part 1: B  Definitions related to Verification EM Part 8: A 4

5. LEA (L ocal Educational Agency) to identify the entity responsible for application, certification, and verification activities for National School Lunch (NSLP) and School Breakfast (SB) programs EM Part 1: A 5 SFA (School Food Authority) for agencies administering the school meals programs

6. WI Child Nutrition Programs Website http://fns.dpi.wi.gov/fns Click on “INDEX” button: select “topic” listed in alphabetical order Verification information is located at: http://fns.dpi.wi.gov/fns_topics#V Annually download letters/forms/mailings! This guarantees the current Civil Rights statement is included! 6

7. USDA’s Food and Nutrition Service USDA Guidance Memos for Schools explain changes, updates or clarifications. USDA’s Food and Nutrition Service is linked to DPI website at: http://fns.dpi.wi.gov/fns_topics#U http://www.fns.usda.gov/cnd/Governance/policy.htm 7

8. USDA Guidance Memos Memos pertinent to Verification: SP38-2013 Verification Report SP13-2012 Verification for Cause SP02-2012 Verification & Reporting of Foster Children 8

9. Let’s Do a Quick Review of the Application Approval Process 1. Application materials must be distributed to all households each year. Click “Free & Reduced Meal applications” on Child Nutrition Programs website for current application(s). 2. Determining Official receives applications, contacts household if application is incomplete; approves or denies eligibility; documents eligibility decision on application, creates Benefit Issuance list and/or enters into computer system. 3. Complete “Benefit Issuance” list of F/R students: specific date approved, denied, benefit changed, Direct Cert, foster child, benefits extended per sibling, withdrawn from school, etc. 4. Household is notified of decision. Written notice including appeal procedure is required - if benefits are denied. 9

10. Who is involved in the eligibility approval process? 4 officials named on the school/district’s on-line DPI contract for school year (SY):  Determining Official  Verifying Official  Confirming Official  Hearing Official 10

11. Determining Official  Reviews each application for completeness, correct case number or computes income, initial/date, approve/deny application. Runs Direct Certification  Compiles “Benefit Issuance” list for each school. Lists each student’s Free or Reduced-price status & precise date of any change. (Can’t backdate)  Documents up to 30 operating days carry-over of eligibility from previous school year or until a new application is approved, whichever occurs first Eligibility Manual for School Meals, August 2013 and Direct Cert: http://fns.dpi.wi.gov/fns_directcerthttp://fns.dpi.wi.gov/fns_directcert 11

12. Verifying Official  Notifies households selected for verification  Verifies information on each application: reviews documentation submitted for completeness; checks for each income & does math, FoodShare/W-2 Cash/FDPIR documentation from ACCESS, foster care documentation from State or foster care agency  Signs/dates; informs household in writing of results: change or no change in eligibility status  Maintains the records of verification in a separate file  May be the Determining Official EM Part 8 and Part 9 12

13. Confirming Official  Only required to double-check household applications selected for Verification  Assures that initial determination was correct. If not correct: update application with correct eligibility, benefit issuance list & inform household (before verification notices are mailed to households); then verify per this correct determination  Exclude household from Verification if no longer eligible for benefits or withdrawn from school  Confirming Official can not be Determining Official EM Part 8: G 13

14. Hearing Official  Conducts a Hearing, when requested, for appeals to the determination or verification decision  Can not be involved in the original determination or the verification processes  Hearing Official is generally a superior of the Determining Official and Verifying Official  May be the Confirming Official EM Part 8: M 14

15. Determining Eligibility Direct Certification (DC): S, T, O, E = “free” eligible Categorical Eligibility: automatic “free” based on eligibility as: 1. Foster Child (court placed/WI/agency documents) or marked “foster child” box on application Part 1. All Household Members 2. FoodShare/SNAP: 10 digit case number 3. W- 2 cash assistance (Wisconsin’s name for Temporary Aid to Needy Families (TANF) - 10 digit case number 4. Food Distrib. Program on Indian Reservations (FDPIR) 5. Other Source Categorically Eligible: homeless, runaway, migrant, Head Start, Even Start Income-based applications: can be free, reduced or denied EM Part 3, 4, 5 Direct Cert: http://fns.dpi.wi.gov/fns_directcerthttp://fns.dpi.wi.gov/fns_directcert 15

16.  Required 3 times per school year by each LEA participating in NSLP & SBP – run after July 1  1) before or about the beginning of school  2) 90 days after first run (about 3 month)  3) 180 days after first run (about 6 months)  Eligible students identified/coded S, T, O, E on each Direct Cert “run” are not subject to Verification!  If using computer software, be sure system has been updated for the new Direct Cert code letters Direct Certification: http://fns.dpi.wi.gov/fns_directcerthttp://fns.dpi.wi.gov/fns_directcert 16 Direct Certification

17.  Keep each DC list. Each list documents students as “free eligible” based as of that specific date  May run DC as often as useful  Direct Cert takes precedence over an application  Keep application of student(s) who are eligible by DC on-file. Application helps identify other children in household to whom benefits are extended. These children are also considered DC. EM Part 1:B; Part 3: A, C; Part 5: A; Part 6: A http://fns.dpi.wi.gov/fns_directcert http://fns.dpi.wi.gov/fns_directcert 17 Direct Certification

18. Other Source Categ Eligible Defined as: Homeless, Runaway or Migrant Head Start, Even Start enrollment An individual child’s “Other Source Categorically Eligible” does not convey to other children in the household. Foster child status does not convey to other children in a household. EM Part 1: B; Part 3: C, F; Part 5: B, D 18

19. What is Verification?  Verifies eligibility for a sample number of applications received/approved in the current school year for free and reduced-price meal benefits under the National School Lunch Program (NSLP) and School Breakfast Program (SBP)  Required by USDA for all school agencies and any Residential Child Care Institutions (RCCI) with day students who are participating in federal meal programs such as National School Lunch Program (NSLP) & School Breakfast Program (SBP) who have any approved applications 19

20. Excluded from Verification Free Eligible s tudents with no application; but based on documentation:  Direct Certification (DC)  Homeless, Runaway, Migrant status (only with documentation/email from Homeless Liaison in public schools, or Migrant Education Program Coordinator)  Foster Child based on DC or court/agency documents  Resident in RCCI (not day students)  Head Start/Even Start participants (Federal & WI programs) EM Part 5, 6, 8 and USDA Memo SP 40-2013, SP02-2012 20

21. Mark your calendar!  Sept 30 - consider a Direct Certification run  Oct 1: from the number of current school year applications approved on/by Oct 1. Verifying Official will calculate the correct sample size  Last operating day in Oct: # of enrolled students  November 15 - complete verification process  Nov 1 to Feb 1 - submit Verification Report to DPI at http://fns.dpi.wi.gov/fns_onlinehttp://fns.dpi.wi.gov/fns_online EM Part 6: A, B; Part 8: C, O; Verif Report Instructions 21

22. How is Verification conducted?  Required sampling method is determined (applications may need to be sorted into groups)  As of Oct. 1, count the total number of approved applications submitted for current school year  Carryover apps of previous SY are NOT included  Select required percentage based on sampling method - but not more (do not verify 100% of paper applications) 22

23. How is Verification conducted?  Confirming Official checks only applications selected for verification and if necessary, corrects eligibility status and notifies household of correction before verification paperwork is mailed to the household  Must mail/give “We must check your application” letter and verification paperwork to each household selected to be verified. Consider phoning each household to explain process/what they need to sent in. Verifying Official decides “due-date” 23

24. How is Verification conducted?  Receive documents from household to verify information on application  Examine documents submitted by households (keep documents or photo copies)  Validate eligibility or change household’s eligibility status based on documents received. Calculate income based on documents submitted.  Mail/send “We have Checked Your Application” letter to household with results of verification 24

25. How is Verification conducted? Must make at least one “follow-up attempt to contact” any household who do not respond to submit documents. Must ensure that adequate language assistance is provided. Follow-up may be in writing (including by email) or by telephone. Document that a contact was attempted. Please keep good records of each follow-up contact/s. If household indicates, verbally or in writing, that it no longer wishes free or reduced; verif is complete when “we have checked” letter is sent. EM Part 8: J 25

26. Verification Terms  Sampling Methods: EM Part 8: E  Verification For Cause: Part 8: D and the USDA Memo SP13-2012 http://www.fns.usda.gov/cnd/Govern ance/policy.htm  Direct Verification (optional) EM Part 1: B and Part 9 26

27. Verification “For Cause”  School agencies have an obligation to verify “questionable” applications. Can’t delay the approval of applications  Verification “for cause” is done any time during school year as soon as possible after the application is received EM Part 3: F; Part 8: D USDA Memo SP 13-2012 27

28. Verification “For Cause”  Any paper application verified “for cause” is in addition to the sample size required for the “official” verification process  Any application(s) verified “for cause” is reported on Verification Report (FNS-742) in 2 places: Section 5, 5-8 boxes and line VC-1 Verification Report Instructions 28

29. 3 Sampling Methods Standard: lesser of 3% or 3000 apps from error-prone paper applications Alternate 1: lesser of 3% or 3000 apps selected randomly Alternate 2: lesser of 1% or 1000 apps selected first from error-prone apps; PLUS.5% of apps with case # EM Part 8: E 29

30. Computer System with Verification Feature Check the computer system to ensure that:  it selects appropriate sample size  it selects error prone applications for the Standard and Alternate #2 sample sizes  all letters to households generated by the computer system contain the required current school year Privacy Act and Non-Discrimination Statement EM Part 2: C, E, F, G; Part 8: E, F, G, H, K, P and SNT Mailing April 25, 2013 Web-based Direct Certification 30

31. Which Sampling Method to Use? Choice is based on last school year’s verification results  “Standard” sampling must be used if your preceding school year non-response rate was equal to or greater than 20%. Pull your file & calculate non-response %  Large LEA’s (more than 20,000 students approved by October 1 for free or reduced by application) with greater than 20% non-response but showed at least a 10% improvement in non-response rate may select any of the 3 sampling methods  LEA’s with less than 20% non-response rate may select any of the 3 sampling methods EM Part 8: B, C, E, F 31

32. Mailings-School Nutrition Programs Late September: watch for Verification mailing Posted under letter “M”, “Mailings-School Nutrition Programs” http://fns.dpi.wi.gov/fns_sntmailhttp://fns.dpi.wi.gov/fns_sntmail If your Local Educational Agency receives specific notice that LEA is obligated to use Standard Sample Size of error-prone income applications {this letter is not posted on website} Your LEA had ≥ 20% non- response rate in the previous school year 32

33. After the Initial Selection: Confirmation Review  Confirming Official checks only the application(s) selected for verification (her/his initials/date it)  Checks accuracy of the original determination (i.e. does math manually, if F/R income app)  Corrects the eligibility, if needed, before verification notification is sent to household. Notify household. Never verify a “paid” app. Randomly replace app with another app of same type: error-prone income, income, Foster child or Case # EM Part 8: G 33

34. Replacing Applications After Confirmation Review, LEA may decline up to 5% (.05) of applications selected for verification Must replace application on the same basis as the one declined: error-prone, income, case number, etc. EM Part 8: G, P 34

35. Possible Reasons to Replace an Application May choose to replace an application because: household had been selected for verification last year household has language barriers, or literacy issues, or is embroiled in a custody battle which may impact compliance household with on-going or unresolved issues with school agency which may impact compliance 35

36. Replacing Applications Examples: 1. Verifying 100 applications (100 x.05 = 5), can replace up to 5 of those applications with others 2. Verifying 20 applications (20 x.05 = 1.00) can replace 1 application with another application 3. Verifying 2 applications (2 x.05 =.10) can replace 1 application with another Minimum of one application may always be replaced even if the result is less than 1 EM Part 8: G 36

37. Meeting Minimum Sample Size Randomly select a similarly approved replacement application if:  Confirming Official finds an error in the initial determination and household is no longer eligible for free or reduced- price meal benefits  Student/students listed on selected application have left the school/district LEA may not choose more than sample size LEA may not verify all approved applications EM Part 8: C, D, E, F, G, H, P 37

38. Zero Income Household Selected for Verification  LEA must request an explanation of how living expenses are met  LEA may request additional written documentation or collateral contacts information from whom assistance is being received  Cash withdrawn from savings is reportable income EM Part 3: E, P Part 4: B, C Part 8: I, P 38

39. Before written notification is mailed, Direct Verification is an option  LEA may obtain documentation of Food Share, W-2 cash benefits & FDPIR application directly from local agency that administers each program (communicate by FAX or scanned copy) http://fns.dpi.wi.gov/fns_fincou1#verification use Verification Forms: fax pages 12 & 13 to agency http://fns.dpi.wi.gov/fns_fincou1#verification  Not necessary to notify household if eligibility remains the same. Verification is completed  If results in change in eligibility: mail household written notification of verification, “We Must Check” EM Part 1: B Part 9 39

40. Direct Verification (optional) Fax or scan pages 12 & 13 of Verification Forms to your county’s Income Maintenance (IM) agency. All Wisconsin county & Tribal agencies are posted: http://www.dhs.wisconsin.gov/ http://www.dhs.wisconsin.gov/ Click on “Topics: A to Z”; click on letter “I”; then Income Maintenance (IM) Agency Directory Or http://www.dhs.wisconsin.gov/forwardhealth/imagen cy/index.htm http://www.dhs.wisconsin.gov/forwardhealth/imagen cy/index.htm 40

41. Written Notification to Household Selected for Verification Includes: 1. Deadline for submitting written evidence is set by LEA 2. Name of LEA contact and phone number that can be reached without charge (for local call, toll free, or collect) to answer verification questions 3. “We must check your application” letter lists acceptable documentation of FoodShare/SNAP; W-2 cash benefits/TANF; FDPIR; foster child or income. 4. Recommend use of Verification Forms (16 pages) posted: http://fns.dpi.wi.gov/fns_fincou1#verification http://fns.dpi.wi.gov/fns_fincou1#verification EM Part 8: H, I, J, K, L 41

42. Documentation to Support Eligibility 1.Written evidence received directly from the household (pay stubs, child support, SSI, etc.) 2.Collateral contact identified by household that school can request information from directly: Employer Social service agency Migrant workers’ agency Religious or civic organization EM Part 8: I, J 42

43. Income Documentation  Must receive documentation for all sources of income reported on application (Be sure to keep copies on file)  Income may be for any time from one month prior to date of application up to time of verification  Frequency of income(s) should be identifiable (e.g., weekly, biweekly, monthly, 2 times per month). Ask household if frequency is not clear. Date/initial the response  Gross income must be used; except for self- employment and farming income or seasonal/fluctuating income Free and Reduced Price School Meals Family Application 43

44. Documentation for FoodShare/SNAP, W-2 cash benefits/TANF and FDPIR  Documentation that shows eligibility for programs from any point in time between the month prior to date of application and up to time of verification  Documentation of a child (or any household member on the application) is receiving benefits under FoodShare, W-2 cash benefits or FDPIR  Quest card (electronic benefits) can’t be used. It has no expiration date. EM Part 3: A, C; Part 8: H, I 44

45. Foster Child(ren) A. Foster child only application: Social worker, agency, court/State confirms child’s “foster status” and personal income, if any, in writing or over the phone (record documentation received verbally onto application and initial date) B. Foster child appearing on household application: foster child is categorically eligible. Foster does not convey “free” benefits to household’s own children. Household children determined by income or sources of household categorical eligibility EM Part 1: B; Part 3: C; Part 4: B; Part 5: B, D; Part 6: G USDA memo SP02-2012 and SP17-2011 45

46. Kinship Care Ask: in cases where no specific welfare agency or court is legally responsible for the child or child is living with relatives, or friends of the family, the child is considered to be a member of the household with whom s/he resides. Household must submit an application. App could be selected for verification. Child(ren) placed with relatives through formal arrangement by courts or State is considered Foster “Determining Eligibility for Meal/Milk Benefits: Foster Care, Kinship Care & Adoption Assistance Fact Sheet” 8/19/11 posted at: http://fns.dpi.wi.gov/fns_fincou1 46

47. Adoption Children are part of household when there is legal adoption. They must be listed on application. Any adoption subsidy is considered reportable income. Application could be selected for verification. Due to year-long duration of eligibility, free eligible status on a foster child doesn’t change if foster child was adopted during the same school year. EM Part 4: B, D Part 5: C, D 47

48. After Household Responds- Verifying Official:  Must receive documentation on all sources of income listed on original application; compares documentation with information listed on the application; computes total income from documentation for income applications Overtime: Contact household and ask if overtime is one- time or sporadic source of income. If only sporadic, income should be calculated based on regular monthly income without overtime Records to whom you spoke; person’s answer/initial and date - that the conversation occurred EM Part 8: H, I, J, N, P 48

49. After Household Responds- Verifying Official:  Informs household that eligibility remains the same or changes (be sure to use the most current “We have checked your application” letter from DPI website)  Written notice is required to include “Appeal Procedures” for change in benefit level and/or for termination of benefits  Updates Benefit Issuance List or computer system database to correct benefit level of each student/siblings 49

50. Insufficient Evidence or No Response  Verifying Official must make at least one documented attempt (written, email or verbal) to contact the household and inform them that failure to comply with verification will result in termination of benefits (document contact(s)  Terminate benefits and change to “paid” status if household does not respond by deadline set, but no later than November 15. Letter must give 10 calendar days written advance notice from date the notice is sent. EM Part 8: J, K, L 50

51. When household indicates, verbally or in writing, that it no longer wishes to receive free or reduced-price benefits Household eligibility for the level of benefits is:  Validated at current eligibility level  Changed to a higher/lower eligibility level Household eligibility is changed to “paid” due to non-response to request for documentation EM Part 8: J, K 51 Verification is complete

52.  Letter (We have Checked Your Application) is sent informing household of results and that benefits will remain the same or be reduced  Letter/notice of adverse action is sent informing households that benefits will be terminated (changed to “paid” status). Include the Fair Hearing paragraph and Hearing Official’s contact information EM Part 8: J, K, L 52

53. Time Periods for Changing Eligibility Status  Any household that fails to respond or submits incomplete verification documentation by due date receives notice that household will be changed to “paid”  Reduction or Termination of benefits – household has 10 calendar days from date on written notice to file for Appeal. (Benefits remain the same until end of appeal)  Increase in benefits – effective immediately and must be implemented no later than 3 operating days after decision EM Part 8: J, K, L 53

54. “We have checked” Notification Letter – Results of Verification  Specifies change in benefits (if any) and reason  Includes Fair Hearing paragraph and time frame for submitting appeal (within 10 calendar days from date on notice) to continue benefits.  When household doesn’t appeal, or Hearing Official rules that benefits must be reduced, the actual reduction or termination of benefits must take place no later than 10 operating days after the 10 calendar day advance notice period, or 10 operating days after the decision by the Hearing Official. EM Part 8: K, L 54

55. Households that reapply “in same school year” for program benefits  Household is required to submit income documentation or proof of participation in Assistance Program(s) at the time of reapplication prior to approval  Not considered a new application EM Part 8: N 55

56. Appeal Rights  Household is allowed 10 calendar days from date on notice to request a Hearing to appeal decision  If a household appeals by the end of the ten calendar day period, LEA continues to provide benefits as originally issued to the child until hearing is held and a final decision is made  If no appeal is made, actual reduction or termination of benefits must take place no later than 10 operating days after the 10 calendar day advance notice period EM Part 8: L, M, N 56

57. Fair Hearing Procedure  Household may request a school conference to review information prior to a formal hearing  Refer to procedures in Permanent Agreement Policy statement and Verification Forms. The last page contains the Fair Hearing Procedure. Verification Forms (16 pg.) posted: http://fns.dpi.wi.gov/fns_fincou1#verification EM Part 8: K, L, M 57

58. 58

59. QUESTIONS About Verification? Contact any School Nutrition Program Consultant Directory posted at: http://fns.dpi.wi.gov/fns_sntdirectory 59

60. New to your role; or seek a refresher? Use INDEX button; A-Z; Training offers ‘upcoming’, ‘recurring’ and ‘resources’ at: http://fns.dpi.wi.gov/fns_snt_training http://fns.dpi.wi.gov/fns_snt_training ‘School Nutrition Team Webcasts’ are updated - as USDA regulations change http://fns.dpi.wi.gov/fns_sntwebcasts 60