1. NH Department of Education Division of Program Support Bureau of Nutrition Programs and Services Verification Module for National School Lunch Program 9/27/12

2. Agenda 9/27/12 Introduction/Definition Direct Certification Requirements Methods of Sampling Household Notification Methods of Verification Completion of Verification Record Keeping Questions and Answers

3. Introduction/Definition Verification of Eligibility for School Meals What does verification mean? Confirmation of eligibility for free and reduced price meals (please see handout)

4. Verification vs Direct Certification Verification vs Direct Certification Verification efforts are not required for children who have been directly certified. What is Direct Certification? Documentation received from the State or local agency responsible for the administration of the Food Stamp Program (SNAP)/FDPIR or TANF Program indicating those children as eligible for direct certification.

5. Direct Certification When is Direct Certification not Direct Certification? What is not direct certification: If a household fills out a free and reduced Income Eligibility Application (application) for meal benefits and provides a food stamp number AND if that household does not appear on a direct certification list, that household cannot be considered directly certified and remains in the verification pool.

6. Activity ACTIVITY 1 GROUP PARTICIPATION PRESENTER KATHY HODGES

7. Requirements SAU must: Select a sample of applications that were on file and approved by October1st. The sample is based on the number of applications, not the number of children represented. Cont’d

8. Requirements During the verification process for 2012-2013, the SAU must use the standard sample size error prone based on the sample pool. SAU’s may not verify more than required minimum sample. Cannot discriminate. All questionable applications are verified. Complete verification by November 15 th of each year, unless a waiver was granted by the State Agency which would shift the deadline to December 15 th.

9. Verification Timeline SAU’s will do the following: October 1 st – Compile all approved applications. October 15 th – Select from the applications for verification based on the sampling method and send the following documents to the household: Notification of selection and verification of information form Letter to the employer Letter to Social Security Office If applicable, fax the food stamp number direct verification form to the food stamp office. Cont’d

10. Verification Timeline October 29 th – Submit the Verification Effort Plan of Action form to the Bureau of Nutrition Programs and Services including the request for waiver, if needed. November 15 th – Complete the verification effort on applications unless there is an approved waiver. Then send the Notice to Households of Approval/Denial of Benefits and lastly, place all completed verification documents on file. December 15 – Approved waiver received, complete the verification effort on applications. Then send Notice of Households of Approval/Denial of Benefits and lastly, place all the completed verification documents on file. December 31 st – Send completed School Food Authority (SFA) Verification Summary Report (one per SFA) to Bureau of Nutrition Programs and Services.

11. Methods of Sampling There are specific formulas for selecting the required number of applications for verification using the standard sample size. o Standard Sample Size o Alternate Sample Size Alternate One Alternate Two Remember: fractions or decimals must be rounded upward to the next whole number.

12. Standard Error Prone Applications are selected by the error prone method. Select the sample pool that indicates total household income within $100 monthly or $1200 yearly of the income eligibility guidelines. See handbook

13. Standard Size Sampling Any method giving each application an equal chance of being selected, including both categorical and applications. Randomly verify a minimum of lesser of 3% or 3000 of the total number of approved applications on file from the SAU as of October 1 st. At least one application must be verified.

14. Verification for Cause Application must be processed and approved for the correct meal benefit. Only after the determination of eligibility has been made can the LEA begin the verification for cause process. The LEA has an obligation to verify all questionable applications. (verification for cause) Must send the household a letter explaining that it must submit verification of eligibility information with the application for continued services.

15. Verification for Cause Any household that fails to submit the requested information or submits information that does not support the initial determination of eligibility, a notice of adverse action must be sent. (by mail or by email) Once households have been requested to provide documentation for cause, the LEA must complete the verification process for these households. Any application verified for cause is above and beyond what is verified during the verification process.

16. No Income If a household is selected for regular verification or verification for cause and the application indicates zero income, the LEA must request an explanation of how living expenses are met and may request additional written documentation or collateral contacts. To continue the verification process subsequent to household notification, the LEA must either determine: o If the household has submitted adequate information to complete its individual verification activity; or o If follow-up with the household is needed.

17. Household Notification All households that have been selected as part of the verification process must be notified that they are required to provided information. Refer to the Eligibility Guidance for School Meals Manual (Aug. 2012)(pg. 75) that outlines what must be included in the household notification letter. The SAU must complete the verification process for all households that have been notified of their selection for verification.

18. Methods of Verification There are 3 methods of verifying: 1.Written Evidence 2.Collateral Contacts 3.Agency Records

19. Methods of Verification 1.Written evidence regarding income: Acceptable written evidence contains: name of the household member; amount of income received; frequency received; and the date the income was received. Cont’d

20. Methods of Verification 1.Written evidence regarding categorical: Acceptable written evidence contains: A written statement from the Food Stamp (SNAP), TANF, or FDPIR agency that specifies that the child is a member of a household currently receiving benefits. Cont’d

21. Methods of Verification 2.Collateral Contact Collateral Contact is a person who is outside of the household but is: Knowledgeable about the household; and Can confirm household’s income or Food Stamp(SNAP)/FDPIR or TANF status. All collateral contacts may be written or oral and must be documented, dated, and initialed. Cont’d

22. Methods of Verification 3.Agency Records Provide a Food Stamp (SNAP)/FDPIR or TANF case number on the application and submit this to the local Food Stamp or welfare office for confirmation of receipt of benefits from agency records. Request information as early as possible so as to ensure that there is sufficient time to acquire the documents from the agency in order to comply with the required information to be verified.

23. Activity ACTIVITY 2 GROUP PARTICIPATION PRESENTER Judy Gosselin

24. Completion of Verification Verification is completed when household’s eligibility for the level of benefits for which it was approved is: Confirmed. When verification results in a higher level of benefits, the change is effective immediately, but must be made within 3 days. Cont’d

25. Completion of Verification When verification results in the benefits being reduced or terminated: A letter of adverse action is sent giving 10 calendar days advance written notice. First day of the period is the day the notice was sent. Letter must include: Description of change; Reason for change; and How and when to appeal or reapply. Cont’d

26. Completion of Verification Household appeals within the 10 day period: SAU must continue to provide benefits until the hearing is held and determination is made. Household does not appeal: Reduction or termination of meal benefits must take place immediately after the 10 day period.

27. Reapplying for Benefits Households that are affected by a reduction or termination of benefits due to a non-response to the verification request, may reapply at any time during the school year. These are not considered new applications but must submit income eligibility documentation or proof of participating in the Food Stamp (SNAP) or TANF programs as originally requested during the verification process. This will start the verification process with the submitted documentation.

28. Record Keeping SAUs must keep and maintain: all verification documentation to demonstrate compliance in case of an applicant’s appeal. Documents include: summary of the verification efforts; selection process; total number of applications on file on 10/1; and percentage/number of applications that are or will be verified by 11/15. The verification documents are reviewed by the State Agency as part of an administrative review. Cont’d

29. Record Keeping For each application, the following source of information from the household must be kept as verification: Food stamp (SNAP) office information Wage/pay stubs Collateral contacts All documents must be kept on file for 3 years plus the current year. Question: Are EBT cards an acceptable form of documentation? copies of EBT cards are not an acceptable form of documentation. Cont’d

30. Record Keeping Copies of Information that must be documented: All relevant correspondence between households selected for verification and SAU. Verification of documents submitted by the household. Any changes in meal benefit eligibility, reasons and date of change. LEA must keep: Verified applications readily retrievable by school; and a copy of the verified application at the SAU.

31. Activity ACTIVITY 3 GROUP PARTICIPATION PRESENTER Tami Drake

32. Verification Module This verification module has been brought to you by the NH Bureau of Nutrition Programs and Services. Bureau Staff and information can be found at our website: http://education.nh.gov/program/nutrition/index.htm The information regarding verification can be found in the Eligibility Manual for School Meals, Verification from pages 67 through 83.

33. Bureau of Nutrition Programs and Services Questions and Comments

34. Bureau of Nutrition Programs and Services Thank you for your attention today as we discussed Verification of Eligibility for School Meals. We are all working together to create a more accurate verification system through understanding of the regulations. When we ensure all schools receive the reimbursements and that all students receive the nutritious meals they need, we ALL benefit. Thank you for attending this training. Travel safely.