WHO’S ELIGIBLE FOR WHAT: THE FREE AND REDUCED PRICE PROCESS

Administrative Review (AR): Critical Areas of Review  Certification and benefit issuance  Accuracy of meal counting and claiming  Whether meals claimed for reimbursement meet meal pattern and nutritional quality requirements 2 Performance Standard 1 Performance Standard 2

Administrative Review (AR): Off-site Review Procedures To prepare for the review, your reviewer will examine:  SFA Agreement  Free and reduced price policy statement  Renewal applications  Claims for reimbursement  Other miscellaneous reports (e.g. Verification Collection Report)  Review findings from prior years, corrective action plans, and documented corrective action  Other audits

Administrative Review (AR): On-site Review Procedures To ensure program compliance, includes an examination of:  Free and reduced price certification and benefit issuance process  The meal service  General areas

Free and Reduced Price Process: Off-Site Review Procedures  Questions to address SFA’s procedures regarding:  Household applications  Direct certification  Benefit issuance  Benefit issuance document  Applications  Direct certification lists  Other categorical eligibility documentation Off-site Assessment ToolSupporting Documentation

Benefit Issuance Document 6 Student name School name Eligibility status (free or reduced price) Date of certification Method of certification Total number of eligible students in the SFA Notes (e.g. withdrawal/transfer date) List of all students in the SFA eligible for free or reduced price meals REMINDERS: No duplicate names Not grouped by eligibility status

Sample Benefit Issuance List 7

Benefit Issuance: Other reminders 8  Must be updated anytime changes occur in eligibility, as well as when a student transfers or withdraws  Share student eligibility only with the school or program personnel who “need to know”

Selecting Certifications for Review State agency may elect to review either:  All free and reduced price students on the benefit issuance document  A statistically valid sample of free and reduced price students on the benefit issuance document  Only an option if the SFA has greater than 100 students certified for free or reduced price benefits

Obtaining Certifications for Review For each selected student, the state agency must obtain:  The certification document (e.g. application or direct certification list)  Any verification materials

Application Processing: What are we looking for?  Were applications processed correctly?  Was carryover of the previous year’s eligibility done properly?  Were applications approved and households notified of eligibility status in the required timeframes?  Did the SFA follow all requirements for the independent review of applications (if applicable)?

Denied Applications: What are we looking for?  Was the denied household notified of:  Reason for denial  Right to appeal  Instructions on how to appeal  Statement that the household may reapply at any time during the school year

Common Review Finding: Applications FINDING: Data entry error results in incorrect eligibility status...  Incorrect household size or failure to include all household members;  Incorrect income amount and/or frequency of pay period;  Incorrect eligibility guidelines used in determining eligibility, including in the eligibility software.  Application is incomplete or missing key data

Common Review Finding: Applications … FINDING: Free/reduced applications are not processed within 10 days of receipt…  Applications should be reviewed and an eligibility determination made IMMEDIATELY, but no later than 10 days from receipt.

Direct Certification: What are we looking for?  Did the Direct Certification list contain all required information?  Did the SFA perform Direct Certification the required number of times?  Are students that have free eligibility based on Direct Certification found on a list as a match?  Was extension of benefits done correctly?

Direct Certification: New For  SFAs will now be required to run direct certification to show eligibility by school within the SFA  Wisconsin School Directory online: Last NameFirst Name Middle Initial Date of Birth School UseSchool Number

Benefit Issuance: What are we looking for?  Was each student’s eligibility status properly transferred from the certification document to the benefit issuance document?  Does the benefit issuance document contain all required pieces of information?  Was the benefit issuance document updated as needed?  Are benefits provided in a manner that prevents overt identification?

Common Review Finding: Benefit Issuance FINDING: Student eligibility status is not updated in Point Of Sale (POS) or roster…  Eligibility must be current and correct at POS and on eligibility rosters at all times, including at the end of the 30 operating day carry-over period and at the end of the Verification process.  REMEMBER…change in status must occur no later than 3 days for an increase in benefits and 10 calendar days for decrease in benefits.

Common Review Finding: Benefit Issuance FINDING: One student is receiving free benefits due to Direct Certification, but his sibling is reduced or full pay.  REMEMBER…Free eligibility may be extended to other school-aged children living in the SAME household, based on another household member’s receipt of FoodShare or W-2 benefits or FDIPR.

Common Review Finding: Benefit Issuance FINDING: Reimbursement claimed for student meals when there is not an approved application on file…  Except during the *carry-over period, meals may not be claimed under the free or reduced price meal category unless:  an approved application is on file;  student is directly certified or extended benefits;  student is certified to be foster child, homeless, runaway, migrant or Even Start/Head Start

Independent Review of Applications  Second review of applications before eligibility determinations are made by someone other than the original Determining Official  Required if certification and benefit issuance errors is greater than 10%  Would occur during the subsequent school year

Technical Assistance/Corrective Action  Technical assistance will be provided and corrective action will be required for all certification and benefit issuance errors identified  Corrective action must be applied system-wide, including at non-reviewed schools

Fiscal Action  Taken for errors resulting from the following:  Applications with missing information  Miscategorized certifications (eligibility)  Benefit issuance errors  Failure to update a change in eligibility status resulting from Verification

Administrative Review (AR): General Areas of Review  Nonprofit school foodservice account  Paid lunch equity  Revenue from non- program foods  Indirect costs  USDA Foods  Civil rights  SFA On-site monitoring  Local school wellness policy  Smart Snacks  School meal environment  Water availability  Food safety  Reporting and recordkeeping  SBP/SFSP outreach efforts Resource ManagementGeneral Program Compliance

Verification A process used by SFAs to confirm selected students’ eligibility for free and reduced price meals in the National School Lunch Program and School Breakfast Program.  Only required for a sample of students  Students certified for free meal benefits through Direct Certification or other documented sources of categorical eligibility (e.g. homeless, migrant, runaway) are not subject to Verification

Verification Process: Off-site Review Procedures  Questions to explore whether SFA has met all Verification requirements:  Participation in Verification training  Conducted process appropriately  Properly changed eligibility status (if required)  Submission of Verification Collection Report (FNS-742)  Compliant electronic system (if applicable)  N/A Off-site Assessment ToolSupporting Documentation

Verification Process: On-site Review Procedures  Validate any information provided on the Off-site Assessment Tool  Determine compliance with Verification Requirements  Select sample of verified applications for additional evaluation

Verification: What are we looking for?  Were applications selected correctly?  Was the confirmation review appropriately conducted?  Do notification letters contain all required information?  Was follow-up conducted for unresponsive households?  Were changes in eligibility made within the required timeframes?  Was the process completed by November 15?

Common Review Finding: Verification FINDING: Confirmation review requirements not understood…  Confirming Official must review each application selected for Verification  Eligibility may need to be changed and the application may need to be replaced based on outcome of confirmation review

Common Review Finding: Verification FINDING: Application in Verification sample pool not replaced when household withdraws from district during Verification process…  If the Verification process was not completed before the household withdraws, a “similar” application must be selected in its place.

Common Review Finding: Verification FINDING: The follow up requirements were not met for the Verification process…  SFA must make at least one follow up attempt to obtain documentation when household does not adequately respond  SFA must maintain records of follow up attempts

Technical Assistance/Corrective Action  Technical assistance will be provided and corrective action will be required for all Verification errors

Fiscal Action  Fiscal action is not required for General Areas of Review  Fiscal action is applied for students reviewed in cases of Verification-related certification or eligibility change errors

August 2014 revisions to USDA’s Eligibility Manual for School Meals Eligibility Manual Clarifications

Eligibility Manual Clarification  Other Source Categorically Eligible status must be confirmed prior to certification for free and reduced price meals

Eligibility Manual Clarification  Eligibility Manual states (pgs 29, 31, 33, 55):  “LEAs should validate case numbers/other identifiers listed on the application by reviewing direct certification data or contacting local assistance program officials. Validation means a confirmation of an active case number.”  Per USDA, nothing has changed with the process.  Only required to validate format (i.e. is the FoodShare or W-2 cash benefits case number 10 digits long)  Not required to check against Direct Certification list or contact program officials

Eligibility Manual Clarification Is a child considered a foster child if placed in a relative’s home?  Whether placed by the state welfare agency or a court, in order for a child to be considered categorically eligible for free meals, the State must retain legal custody of the child

Eligibility Manual Clarification Effective Date of Eligibility Determinations  Can establish the date of submission of an application as the effective date, rather than the date the Determining Official approved it  LEAs must notify State Agency if they decide to implement this flexibility  For further information, see USDA memo SP

Eligibility Manual Clarification Effective Date of Eligibility Determinations  Can use the date the student is first identified as eligible for free meals via Direct Certification, rather than the date the LEA processes the Direct Certification file into their POS system For Other Source Categorically Eligible students:  Can use the date the household or agency official submitted the letter, list, or other form of documentation to the LEA, rather than the date the eligibility is confirmed *Must notify State Agency before implementing this flexibility. See USDA memo SP

Eligibility Manual Clarification  Transferring eligibility within the same LEA  Eligibility must be transferred  P2 to non-P2: new application or DC may be required  CEP to non-CEP: new application or DC may be required  Transferring eligibility to another school district/LEA  Not required to share eligibility  May accept eligibility from former LEA, but must double check

Eligibility Manual Clarification “Questionable application” under Verification for Cause:  Inability to confirm household’s participation in Assistance Programs  Ineligibility for other benefits based on data included on the household application  Variance in household size

Resources  USDA’s Eligibility Manual for School Meals (updated August 2014)  Direct Certification materials  Verification materials  USDA Guidance Memos

Remember…  The AR process is not intended to “get” schools who don’t comply  It is intended to provide schools with the tools and guidance they need to operate a successful nutrition program  Working together we can meet that goal!

Feeding children matters… Thank You for all that you do!

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