A P RIMER ON V ERIFICATION P ROCEDURES - F REE AND R EDUCED P RICE F AMILY M EALS A PPLICATION ARTs Training August 13, 2014 Concord High School Concord, NH Tami Drake, Accountant Cheri White, Administrator

D EFINITION What is verification? Verification is the confirmation of the eligibility status for free and reduced price meals served to children in your SAU under the National School Lunch Program. Note: The Verification Effort is not determined on school or individual district applications but on the SAU as a whole. 2

V ERIFICATION VS. D IRECT C ERTIFICATION Verification efforts are not required for: Children who have been directly certified*; Children who designated categorically eligible: Foster Migrant Homeless Runaway Head Start Schools electing Community Eligibility Provision (CEP) * Documentation received from the State or local agency responsible for the administration of the Food Stamp Program (SNAP/TANF) indicating those children as eligible for direct certification. 3

D IRECT C ERTIFICATION Direct certification means determining a child’s eligibility for free meals or free milk, as applicable, based on documentation obtained directly from the appropriate State or local agency or individuals authorized to certify that the child is a member of a household receiving assistance under SNAP/TANF. Directly certified students are not part of the SAU verification pool. When is Direct Certification not Direct Certification? If a household fills out a free and reduced price family meals 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. 4

D IRECT V ERIFICATION Direct verification is the process of determining the authenticity of a SNAP/TANF free and reduced price family meals application without contacting the household. Example: The household submits a family meals application with a case number: SAUs use the information provided on the family meals application to contact the Food Stamp (FS) Program office. Contact of the FS office is made after the selection of the SAU verification pool. SAUs may only submit the names of students listed on approved household applications being verified. 5

I NITIAL V ERIFICATION The SAU must: Select a sample pool of all free and reduced price family meals applications, from the entire SAU, that were on file and approved as of October 1st. The verification sample pool is based on the number of applications, not the number of children represented. 6

R EQUIREMENTS During the verification process for , the SAU must use the standard sample size (error prone*) based on the sample pool. SAUs may not verify more or less than the required minimum sample. SAUs cannot discriminate in the selection of applications to be verified. All questionable applications are verified – verification for cause Complete verification by November 15 th of each year, unless a waiver was requested by the SAU and granted by the State Agency which would shift the deadline to December 15 th. *Error prone means total household income within $100 per month or $1,200 per year (up or down) of the applicable Income Eligibility Guidelines (IEG). 7

V ERIFICATION T IMELINE October 1 st – Compile all approved applications. October 10 th – Submit the Verification Effort Plan of Action form to the Bureau of Nutrition Programs and Services to a request waiver of the November 15 th deadline date, if needed. Must be signed by the Superintendent of Schools or the facility Director if an RCCI. October 15 th – Select from the applications for verification based on the error prone sampling method and send the following documents to the household: Notification of selection and verification of information form; Letter to the employer; and Letter to Social Security Office If applicable, fax the food stamp number direct verification form to the food stamp office. 8

V ERIFICATION T IMELINE ( CONT.) November 15 th – Complete the verification effort on applications unless there is an approved State Agency waiver. Send the Notice to Households of Approval/Denial of Benefits. Place all completed verification documents on file. December 15 – Approved waiver granted, complete the verification effort on applications. Send Notice of Households of Approval/Denial of Benefits. Place all the completed verification documents on file. December 31 st – Complete the SAU on-line FNS-742 SFA Verification Summary Report into the Bureau of Nutrition Programs and Services computer system. 9

M ETHOD OF S AMPLING : S TANDARD S AMPLE S IZE ( E RROR P RONE ) The Standard Sample Size (Error Prone) is to be used in NH for choosing family meals applications that are to be verified. Remember: fractions or decimals must be rounded upward to the next whole number. Example 1: 3% of SAU error prone applications is 5.7. SAU must verify 6 applications. The SAU sample size may increase due to applications verified for cause. Verification for cause applications are not included in the initial sample size count. Example 2: 3% of SAU error prone applications is 5.7. Verification for cause is 3. SAU verifies a total of 9 applications; 6 error prone (required) and 3 verification for cause. 10

S TANDARD S IZE S AMPLING * Any method giving each application an equal chance of being selected, including both SNAP/TANF applications and income applications. Randomly verify a minimum of the lesser of 3% or 3,000 of the total number of SAU approved error prone applications on file as of October 1 st. At least one application must be verified. Note: There may not be enough applications that meet the error prone criterion. When this happens, the SAU must select, at random, additional approved applications from the sample pool to complete the required sample size. In other situations, the number of error prone applications may exceed the required sample size. When this happens, the SAU must randomly select the required number of applications from all error prone applications. 11

V ERIFICATION FOR C AUSE Applications must be processed and approved for the correct meal benefit. Only after the determination of eligibility has been made can the SAU begin the verification for cause process. The SAU has an obligation to verify all questionable applications. (verification for cause) SAUs must send the household a letter explaining that it must submit verification of eligibility information with the application for continued services. 12

V ERIFICATION FOR C AUSE ( CONT.) 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 ) Once households have been requested to provide documentation for cause, the SAU must complete the verification process for these households. Any application verified for cause is above and beyond what is verified during the verification process. 13

H OUSEHOLD N OTIFICATION 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. 2014; Pg. 89) 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. 14

M ETHODS OF V ERIFICATION There are 3 methods of verifying: 1. Written Evidence 2. Collateral Contacts 3. Agency Records 15

M ETHODS OF V ERIFICATION ( CONT.) 1. WRITTEN EVIDENCE 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. Written evidence regarding categorical determination: Acceptable written evidence contains: A written statement from the Food Stamp (SNAP) or TANF agency that specifies that the child is a member of a household currently receiving benefits. 16

M ETHODS OF V ERIFICATION (CONT.) 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/TANF) status. All collateral contacts may be written or oral and must be documented, dated, and initialed. Question: Are EBT cards an acceptable form of documentation? Answer: No, copies of EBT cards are not an acceptable form of documentation. 17

M ETHODS OF V ERIFICATION ( CONT.) 3. Agency Records Provide the Food Stamp (SNAP/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. 18

N O I NCOME If a household is selected for regular verification or verification for cause and the application indicates zero income, the SAU 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 SAU must either determine: If the household has submitted adequate information to complete its individual verification activity; or If follow-up with the household is needed. 19

C OMPLETION OF V ERIFICATION 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. 20

C OMPLETION OF V ERIFICATION ( CONT.) When verification results in the benefits being reduced or terminated: A letter of adverse action is sent giving 10 calendar days advance written notice – (grace period). First day of the grace 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. 21

C OMPLETION OF V ERIFICATION ( CONT.) If household appeals within the 10 day grace period: the SAU must continue to provide benefits until the hearing is held and determination is made. If household does not appeal: reduction or termination of meal benefits must take place immediately after the 10 day grace period. 22

H OUSEHOLDS F AILING TO S UBMIT R EQUIRED D OCUMENTATION SAUs must make at least one follow-up attempt to contact households who have not adequately responded to the request for verification. Attempt may be in writing via regular mail, or by telephone. SAUs must document that a contact was attempted. SAUs must inform the households that failure to supply the necessary information will result in termination of benefits. 23

R EAPPLYING FOR B ENEFITS 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. Households must submit income eligibility documentation or proof of participating in the Food Stamp SNAP/TANF programs as originally requested during the verification process. This will start the re-verification process with the submitted documentation. 24

R ECORD K EEPING 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. 25

R ECORD K EEPING ( CONT.) For each application, the following source of information from the household must be kept as verification: Food stamp (SNAP/TANF) office information Wage/pay stubs Collateral contacts All documents must be kept on file for 3 years plus the current year. 26

R ECORD K EEPING ( CONT.) 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. SAU must keep: Verified applications readily retrievable by school; and a copy of the verified application at the SAU. 27

F OOD AND N UTRITION S ERVICES Questions or Comments Contacts: Cheri White; Tami Drake; Judy Gosselin; Kathy Hodges; 28

Verification Activity 29