NSLP/SNAP - Direct Certification and State Performance: The new process, data requirements, and responsibilities beginning School Year 2013-2014 Webinar.

NSLP/SNAP - Direct Certification and State Performance: The new process, data requirements, and responsibilities beginning School Year Webinar – Tuesday, August 20, 2013 – 2:00-3:30 pm Patricia B. Von Reyn – Senior Management Analyst USDA/FNS/Special Nutrition programs/Child nutrition Division

What is Direct Certification with SNAP?
Children living in households receiving assistance under the Special Nutrition Assistance Program (SNAP) must be directly certified to receive free school meals under the National School Lunch Program (NSLP) and/or School Breakfast Program (SBP).

How is Direct Certification with SNAP Conducted?
Source Data School Enrollment Data SNAP Participation Data Match Process Use Match Results to directly certify at local level SNAP DC Match Results 3

Some Different Ways States Match with SNAP
DC A DC C DC B DC D SA/Central Level SFA/LEA/Local Level

Goals of Direct Certification
Improve access for low-income children Reduce paperwork for households and program administrators Improve integrity of the free and reduced-price meal certification process

History of Direct Certification with SNAP
2004 All NSLP LEAs must perform direct certification with SNAP by SY (May conduct direct certification with other programs, but are not required to do so) P.L Child Nutrition and WIC Reauthorization Act of 2004 2008 Assess effectiveness of direct certification and publish results in Report to Congress (starting with SY ) P.L Food Conservation, and Energy Act of 2008 (2008 Farm Bill) 2010 Performance benchmarks are set at 95% for SY and beyond (lower benchmarks for the two previous school years) SNAP Letter Method no longer DC (phased out by regulation by SY ) P.L Healthy, Hunger-Free Kids Act of 2010 P.L – Omnibus Budget Reconciliation Act of 1981 P.L – Child Nutrition and WIC Reauthorization Act of 1989 P.L – Child Nutrition and WIC Reauthorization Act of 2004 P.L – Food, Conservation, and Energy Act of 2008 (2008 Farm Bill) 2013 New formula and ways to collect/report data elements to compute State direct certification performance rates with SNAP Final Rule NSLP: Direct Certification Continuous Improvement Plans Required by the Healthy, Hunger-Free Kids Act of 2010

Benchmarks - Direct Certification with SNAP
SY and beyond – 95% Second year - SY % First year – SY – 80%

Will my State be at 95%?

This Webinar describes the New Methodology for Assessing Performance, which:
Is straightforward Promotes transparency Is more accurate Provides States with tools to measure their own performance in a timely manner

Direct Certification with SNAP and a Formula Approach to Improvement

Understand how the pieces of the puzzle fit together
Formula Data Element #1 Data Element # 2 Data Element # 3 (2008 Farm Bill)

Direct Certification Performance Rate
#1 # 3 Direct Certification Performance Rate # 2

DATA ELEMENT #1

#1 DATA ELEMENT . #1 The # of children living in households receiving SNAP benefits who are directly certified for free school meals as of the last operating day in October

DATA ELEMENT . Who collects it?
#1 #1 DATA ELEMENT Who collects it? The School Food Authority tracks, records, and reports the number of SNAP Direct Certifications that occur by the last operating day in October

DATA ELEMENT . Reporting
#1 DATA ELEMENT Reporting #1 TANF FDPIR Other SNAP DC on old FNS-742, line 4-1 to State agency by March 1st to FNS by April 15th on revised FNS-742, line 3-2 to State agency by February 1st to FNS by March 15th

Need to be able to separate out SNAP DC for Section 3 of the FNS-742 – Free, not subject to verification SNAP Letter Method is no longer Direct Certification SNAP Direct Certification Non-SNAP Direct Certification Other TANF SNAP DC FDPIR Homeless Migrant Runaway Foster Head Start, etc TANF Other FDPIR SNAP DC Line 3-2 Line 3-3 Line 3-4

The count on Line 3-2 of the FNS-742 is Data Element #1
SNAP DC TANF Other FDPIR

#1 “Grow” DATA ELEMENT #1 SNAP DC

How to Grow DATA ELEMENT #1
SNAP DC #1 How to Grow DATA ELEMENT #1 Know what is considered to be a SNAP Direct Certification Certifications Based On: Matching SNAP database to Student-Enrollment Database Adjudication of the unmatched or partial SNAP match list SNAP-combo matches, SNAP trumps! Extended SNAP-DC Eligibility Converting to SNAP DC by the last operating day in October

SNAP DC #1 How to Grow DATA ELEMENT #1 Improve the System Perform a State Self-Assessment

SNAP DC #1 How to Grow DATA ELEMENT #1 Improve the System Perform a State Self-Assessment Determine where your State’s strengths and weaknesses lie Work with counterparts to develop a plan of action Look to FNS grants for financial support

SNAP DC #1 How to Grow DATA ELEMENT #1 Key tasks for this year Match more frequently if possible – if only 3x/yr, make sure 2nd is before the last operating day in October Make sure the SFA can capture (code), retain, and select for the method for the direct certification so the FNS- 742 counts will be accurate Monitor the progress step-by-step

Expectation is that line 3-2 of the FNS-742 will be only SNAP DCs, even this first year, SY Separate SNAP from non-SNAP: Work with SNAP State agency to be sure SNAP matches carry some kind of coding designating “SNAP” so the local level will know the source of the match when they directly certify a child for free school meals. Work with IT at all levels to be sure that the coding is retained at the local level so the SFA can retrieve the direct certifications based on SNAP for the FNS-742. Work in retrospect, if needed – see Q-and-As, SP If by February 1, 2014, the NSLP State agency is not able to affirm that line 3-2 is only SNAP DCs, SA must inform FNS of the inaccuracy of the data.

DATA ELEMENT #2

The “School-aged SNAP UNIVERSE”
Data Element #2 The “School-aged SNAP UNIVERSE” The # of school-aged children in SNAP households during the months of July, August, and September

USDA uses ages 5-17 years old for “school aged”
in the count for Data Element #2

But, even though USDA uses ages 5-17 years old for “school aged” in the count for Data Element #2 States are to use as broad an age range for the match as will include ALL students in their NSLP schools

#2 Estimate by FNS using a variety of data sources
How and by whom would this count be determined? Estimate by FNS using a variety of data sources Actual counts from the SNAP State agency SNAP Administrative data (for July, Aug, Sept average monthly SNAP participation data) SNAP QC data and Admin data (to narrow down the age range) SIPP data (to help remove duplicates) SNAP State agency queries the SNAP database to get the actual, unduplicated count of children age 5-17 at any time during the months of July, Aug, Sept.

SNAP State agency sends to FNS and the NSLP State agency by
#2 How and when would NSLP State agencies find out? FNS-834 SNAP State agency sends to FNS and the NSLP State agency by Published in the REPORT TO CONGRESS Fall of the next school year Dec 1st of the same school year

SNAP State Agency Responsibilities for Data Element #2
Look at the SNAP rolls for the months of: July, August, and September beginning with July-August-September of 2013 On SNAP at any time during these three months?

Count all children on the SNAP rolls during these same three months who were ages 5-17 at any time during these months. Use the prescribed birth date range for the query

#2 SNAP State Agency – Prescribed Birth Date Range to Query for 5-17 year olds for Data Element #2 School Year First part of SY (from which to subtract the 18 or 5) Children on SNAP at anytime during: Beginning Birth Date Ending Birth Date Birth Date Range for SNAP State Agency’s Query for Children Ages 5-17 Date FNS-834 due Beginning Birth Date Ending Birth Date RULE or July, Aug, Sept of that school year July 1, ( “FP” - 18) 30, Sept. (“FP” - 5) Children born July 1, ( “FP” - 18) through Sept. 30, ( 5) Dec. 1, “FP” “FP” * Any SY EXAMPLE July 1, ( ) so, July 1, 1995 Sept. 30, ( ) So, Sept. 30, 2008 SY July, Aug, or Sept 2013 Children born July 1, 1995 through Sept. 30, 2008 Dec. 1, 2013 2013 *FP = Calendar year when the school year begins

Ensure that the counts are unduplicated Whether a child is on SNAP for all 3 months, or for only 1 day during that 3-month period, count the child only once.

After getting the unduplicated count of children who are on SNAP at any time during July, August, or September 2013, and who were born July 1, 1995 through September 30, 2008 Report the count for the entire State on the new form FNS-834 by December 1, 2013.

Fill Out Fill Out Optional #2 SNAP State Agency – Data Element #2
For the December 2013 submission, this form will be ed in to but in future years, after it is incorporated into FPRS, much of this section will be pre-populated. Fill Out Specific examples for setting the query are included in the Q-and-As: SP , dated August 16, 2013. #2 Optional OPTIONAL

SNAP State Agency’s Submittal of the FNS-834
By December 1st each year to FNS NSLP SA to THIS YEAR to sda.gov by Dec 1, 2013. FPRS in 2014? Provide to the NSLP State agency in a manner agreed upon by both the NSLP State agency and the SNAP State agency each year, starting Dec 1, 2013.

SNAP DC #1 #3 “THE UNIVERSE” #2 #2

So, how do you “Shrink” DATA ELEMENT #2?

How to Shrink DATA ELEMENT #2
The NSLP State agency does not have much control over this, but it can: Ensure the Accuracy of the Count Review the count from the SNAP State agency after they send it over to you by December 1st on the FNS-834 Work with the SNAP State agency if the count does not seem reasonable Develop a way to quantify the actual number of SNAP children not in NSLP schools

DATA ELEMENT #3

Data Element #3 The “SPECIAL PROVISION” Adjustment
The # of children in SNAP households attending special provision schools operating in a non-base year

ON LINE 3-2 NOT ON LINE 3-2 SNAP DC #1 #3 “THE UNIVERSE” #2

#3 Estimate by FNS using a variety of data sources
How and by whom would this count be determined? #3 Estimate by FNS using a variety of data sources Actual counts from the NSLP State agency Line 4-4 of the old FNS-742 (to get the # free eligibles). Adjusted (applying generalized adjustment factors to approximate the narrower SNAP subset). Limitations - particularly when the number of SNAP-participant children had changed from the most- recent base year or as schools moved in or out of non- base year status. NSLP State agency ensures that a “Special Provision Match” with SNAP is run for each special provision school operating in a non-base year. NSLP State agency totals the unduplicated count of matches and reports on the FNS- 834 by December 1st .

#3 Fall of the next school year Dec 1st of the same school year
How and when would NSLP State agencies find out? #3 NSLP State agency ensures that the match is run (or is running the match itself), so it would know earlier than when the report is due, namely by: Published in the REPORT TO CONGRESS Fall of the next school year Dec 1st of the same school year

DATA ELEMENT . NSLP State Agency Responsibilities
#3 #3 DATA ELEMENT NSLP State Agency Responsibilities The NSLP State agency ensures that a “Special Provision Match” with SNAP is run with special provision schools not operating in a base year, totals the number of matches, and reports the total on the FNS-834.

DATA ELEMENT . About the “Special Provision Match” with SNAP:
#3 #3 Timing – it is to be run in or near October—but no later than the last operating day in October Pertains to which schools - all special provision schools not operating in a base year What to count – all matches made using the “Special Provision Match” Alternative phase-in procedures - allowed only for SY Certain Community Eligibility data options available each year

DATA ELEMENT . With which schools must the match be run?
#3 DATA ELEMENT With which schools must the match be run? #3 Provision 2/3 schools when operating in non-base year. Community Eligibility schools, each year they operate under community eligibility. Other schools operating in a non-base year under the special provisions of 7 CFR 245.9–that is, those schools that would not be reporting SNAP-DCs on line 3-2 of the FNS-742.

DATA ELEMENT . Must the State itself run the match?
#3 #3 DATA ELEMENT Must the State itself run the match? Regardless of the method of matching (central or local or combo) for the regular SNAP matched: The NSLP State agency may run the “Special Provision Match” with SNAP; or The SFAs may run the “Special Provision Match” with SNAP and report the counts to the NSLP State agency; or States may decide to use a combination of approaches. NOTE: States with no special provision schools (or with only those operating in a base year) need not run a “Special Provision Match.” Simply report “0” on the FNS-834.

#3 #3 DATA ELEMENT What does it mean to “Count all the matches” found in the “Special Provision Match”? Match Results School Enrollment Data SNAP Participation Data Use for Data Element #3 To FNS-742 for Data Element #1 Use Match Results to directly certify at local level SNAP DC Not for Data Element #3

#3 #3 DATA ELEMENT What are the Alternative Phase-in Procedures for SY ? For SY only, the NSLP State agency may allow the use of the “Base Year Percentage Option” for any school for which the match cannot be run.

DATA ELEMENT . “Base Year Percentage Option”
#3 DATA ELEMENT “Base Year Percentage Option” #3 For SY only . . . School Base Year # Directly Certified as FREE Total # certified as FREE Percentage Factor SY # reported as FREE Apply Percentage Factor Total “Special Provision Match” Total count from the 10 non-base-year special provision schools where the “Special Provision Match” was able to be performed 129 9, 475 38 9, 475 102 271 102 271 343 x A 102 271 343 129 38 B 32 57 68 102 271 68 x Did not conduct direct certification in base year, or no access to data C TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834 9, 642

DATA ELEMENT . Community Eligibility Data Options
#3 #3 DATA ELEMENT Community Eligibility Data Options OPTION 1 - “SPECIAL PROVISION MATCH” – the same match done with other special provision schools OPTION 2 - CLAIMING PERCENTAGE COUNT- Use the count of identified students matched with SNAP used in determining the claiming percentage for that school year OPTION 3 - CALENDAR YEAR APRIL COUNT – Use the count of the identified students matched with SNAP conducted by the April 1st preceding the school year, whether or not the school elected to update its claiming percentages

Community Eligibility Data Options - Example
Scenario The school year is SY The first year of the claiming cycle was SY The school ran a match with SNAP by April 1, 2015, but elected not to update its claiming percentages for SY Data Options OPTION 1 – Conduct and use the results of an “October” “SPECIAL PROVISION MATCH” OPTION 2 – CLAIMING PERCENTAGE COUNT - Use the count of SNAP matches from the “April” 2012 match OPTION 3 – CALENDAR YEAR APRIL COUNT – Use the count of SNAP matches from the “April” match

#3 DATA ELEMENT . #3 Example from future, SY 2015-2016 CE 2 CE 3 n/a
Example of Totals with Community Eligibility Data Options Example from future, SY Can only use “Special Provision Match” or CE Data Options, since Alternative Phase-in Procedures are not available after SY Total “Special Provision Match” Total count from all SNAP matches from the “Special Provision Match” performed “in/near October 2015,” including many Community Eligibility schools 12,321 CE 2 Total count from those Community Eligibility schools electing CE DATA OPTION 2 choosing to use the actual count from the identified students matched with SNAP by the April 1st used to establish the SY claiming percentages 416 CE 3 Total count from those Community Eligibility schools electing CE DATA OPTION 3 choosing to use the actual count from the identified students matched with SNAP by April 1st, 2015 237 n/a If not in the “Special Provision Match” and not using a “Community Eligibility Data Option,” cannot count any students for Data Element #3 . Enter “0.” TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834 12, 974

Much guidance on the “Special Provision Match” is included in the
NSLP State Agency – Data Element #3 Fill Out For the December 2013 submission, this form will be ed in to but in future years, after it is incorporated into FPRS, much of this section will be pre-populated. Fill Out Much guidance on the “Special Provision Match” is included in the Q-and-As: SP , dated August 16, 2013. #3 Optional OPTIONAL

NSLP State Agency’s Submittal of the FNS-834
By December 1st each year to FNS THIS YEAR to sda.gov by Dec 1, 2013. FPRS in 2014?

SPECIAL PROVISION ADJUSTMENT SPECIAL PROVISION ADJUSTMENT
#3 SNAP DC #1 or SPECIAL PROVISION ADJUSTMENT #3 “THE UNIVERSE” #2

Reach all special provision schools Know the special provision schools in your State Keep track of when they are operating in a non-base year Find out which schools already have their students in a statewide student enrollment database Determine which SFAs/schools are not geared up for the match this year Develop relationships with these schools for this match to be successful Work to remove obstacles that would keep schools from being included

Match well, even this first year Design a business practice for the Special Provision Match in your State Be flexible – run the match at the State level or run the match at the local level or use some combination of the two; maybe upload student enrollment info via Excel or even run the match for a school Run the match in or close to October, if possible, but no later than the last operating day in October to maximize the number of matches Automate as much as possible

SPECIAL PROVISION ADJUSTMENT
SNAP DC #1 SPECIAL PROVISION ADJUSTMENT #3 Direct Certification Performance Rate SFA on LINE 3-2 of FNS-742 NSLP State agency on FNS-834 “THE UNIVERSE” #2 SNAP State agency on FNS-834

DATA ELEMENTS #1 #2 #3 Data Element WHAT IS IT? WHO REPORTS?
HOW REPORT WHEN REPORT #1 # SNAP CHILDREN DIRECTLY CERTIFIED FOR FREE SCHOOL MEALS SFA FNS-742 Feb 1 (Mar 15) #2 # SCHOOL-AGED SNAP CHILDREN IN THE STATE IN JULY, AUG, SEPT SNAP STATE AGENCY FNS-834 Dec 1 #3 #SNAP CHILDREN IN NON-BASE YEAR SPECIAL PROVISION SCHOOLS NSLP STATE AGENCY

What can the NSLP State Agency Do to Monitor its Rate?
DATA ELEMENT #1 - Watch the 742 data as it is coming in from the SFAs, be sure that all schools are reporting, compare this year’s data to last year’s data. If it is very different, is there a reason for that? Be sure that the SFA has reported in line 3-2 SNAP direct certifications ONLY . DATA ELEMENT #2 – Be in contact with the SNAP State agency to determine the best way to receive the FNS-834 data. Check the count to see if it is reasonable for your State. How does it compare to the lists that you have been receiving? The count should be an unduplicated count, so if a child is on SNAP for July, August AND September, the child should still be listed only once. DATA ELEMENT #3 – Do you have data in from each special provision school? Is it properly combined for you to report for the FNS-834? FORMULA - Plug the data into the formula as you get it. Is your rate what you expect? If it has dropped significantly, check to be sure there are no errors in the individual data elements.

What can the SFAs do to increase the rate?
Know what constitutes a SNAP Direct Certification Make sure the POS system properly records the type of certification and can select/sort/count by type Keep school enrollment data as current and up-to-date as possible Check new students as they enroll Send SNAP DC status to transferring student’s school Adjudicate the non-matches—try to find every child Go back and code a student as a SNAP DC if the student shows up on the SNAP DC list, even if the student has already been certified in another way, so long as it is done before the last operating day in October Get/arrange for additional assistance during heavy certification times, if possible

What can the SFAs do to increase the rate?
Get proper training, ask questions if anything is not well understood, train back-ups for your role in the process Look to see where the automated systems could be revised to make things easier for you—if you are doing a series of steps over and over, they could probably easily be automated Understand the policies and rules governing direct certification Match frequently –if only running 3 matches, make sure the 2nd one is before the last operating day in October Properly complete the FNS-742, Verification Collection Report Check your submission last year to see if it is close to this year’s—if it is not close, is the difference warranted? If not, search for errors

Direct Certification Improvement Grants Opportunities
The RFA was extended in July to provide 4 more grant opportunities: OCTOBER 1, 2013 JANUARY 2, 2014 APRIL 1, 2014 JULY 1, 2014 MAXIMUM AWARD SCOPE APPLICATION PROCESS TIER 1 $150,000 Limited scope Simplified TIER 2 $ 1 million Full scope – for major initiatives Usual

Helpful Resources Final Rule, National School Lunch Program: Direct Certification Continuous Improvement Plans required by the Healthy, Hunger-Free Kids Act of (February 22, 2013) CIP Development Guide, with State Self-Assessment Tool (December 2012 and March 2013) SP , Release of the new State Agency (NSLP/SNAP) Direct Certification Rate Data Element Report (Form FNS-834) (July 1, 2013) Q-and-As - Direct Certification Process – SP (August 16, 2013) SP , Release of the new School Food Authority (SFA) Verification Collection Report (April ) Webinars: CIP Webinar (January 2013) FNS-742 Webinar (July 2013) New Direct Certification Process Webinar (August 20, 2013)

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NSLP/SNAP - Direct Certification and State Performance: The new process, data requirements, and responsibilities beginning School Year 2013-2014 Webinar.

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NSLP/SNAP - Direct Certification and State Performance: The new process, data requirements, and responsibilities beginning School Year 2013-2014 Webinar.

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