ab Verification Webinar Office of School Nutrition (OSN)

ab Verification Webinar Office of School Nutrition (OSN)
This webinar will start at 2PM. All participants are in listen-only mode. The audio is through your computer speakers. Rachael Burnham, BA Program Specialist CDE, Office of School Nutrition September 28th, 2017 Good afternoon! Welcome to the Verification Webinar for school year ! Thank you so much for being here today! For those of you who don’t know me, I’m Rachael Burnham. I am the program specialist for benefit issuance areas for the Office of School Nutrition, so that includes free and reduced price meals, verification and direct certification. I wanted to provide a webinar to refresh everyone on the Verification process as this starts next week! We cover this topic during regional training and a lot of you have taken the online training, however, I wanted to give everyone another quick opportunity to understand verification and the numerous steps involved as well as learn of several new updates. Attending this webinar will count for one hour of continuing education in Administration - Free and Reduced Price Meal Benefits. The certificate of completion will be provided in an later this afternoon.

Together We Can Colorado Department of Education Vision
All students in Colorado will become educated and productive citizens capable of succeeding in society, the workforce, and life. CDE Office of School Nutrition Mission The Office of School Nutrition is committed to ensuring all school- aged children have equal access to healthy meals by supporting, training, and connecting Colorado’s child nutrition community. Please take a few minutes to read through our mission. Our mission is to ensure we offer you all the support needed to provide access to healthy meals for all CO children.

Virtual Housekeeping Sign-In! Enter your name and district into the chat box Use the chat box to ask questions File share in the top right corner This PowerPoint Eligibility Manual Verification Tracker How to Calculate Self-Employment and Farming Income Verification Process Overview Verification Notification Templates (English and Spanish) Questions or concerns? Contact Rachael Burnham: Verification Webpage: Let’s first take care of a couple of virtual housekeeping items. Please start by everyone entering their name and district into the chat box so I can see who all is online with me today. You will use the chat box to ask questions. We will be providing time at the end of the webinar for Q&A, so please try to hold your questions until the end. We have provided helpful resources that you can refer to throughout this webinar, one of those being this presentation. Specifically please open the copy of the verification process overview. This will be very useful to have as a reference so please have this available. The documents in the file share can also be found on our Verification webpage, the link to this webpage is at the bottom of this slide. We are recording this presentation today, and we will be posting the slide show with notes and the recording on the verification webpage. If you have future questions or concerns please see the lines of communications listed.

Participant Outcomes Understand the annual verification process
9/18/2018 Participant Outcomes Understand the annual verification process Learn required contents for household notifications How can we improve household response rates? Identify acceptable income and/or assistance program documentation Learn how to organize household responses and properly document verification activities Briefly cover the Verification Collection Report This training will guide you through the verification processes. We want participants to leave this training with confidence to accurately process applications, conduct verification and have know how to locate resources.

9/18/2018 Overview Verification is the confirmation of eligibility for free and reduced price school meals based on applications. Required annually SFAs must select a random sample of applications for accuracy and request written documentation from the household Results are reported in the Verification Collection Report (VCR) Provisional districts follow different verification procedures Verification is the confirmation of eligibility for free or reduced price meals determined through applications. It’s an annual USDA requirement and involves selecting a 3% sample from all current year approved applications. Households in the sample size are notified that further income or assistance program documentation is required to confirm the information provided on the application. The entire process must be documented carefully and all results must be entered timely and accurately in the Verification Collection Report

Definitions Adverse Action Error Prone Sample Pool
9/18/2018 Definitions Adverse Action All currently certified households for whom benefits are decreased or terminated must be given 10 calendar days’ written notice prior to the date of status change. Error Prone Applications within $100 per month of applicable income eligibility guidelines. Sample Pool Total number of approved applications as of October 1. Standard Sample Size Number of applications subject to verification. Standard sample size is 3% of the sample pool selected from error prone first. Verification for Cause Questionable applications that are verified outside of the annual verification process. Summarize definitions.

Verification for Cause
9/18/2018 Verification for Cause Must verify any questionable application: Outside knowledge of the SFA A report of fraud Multiple applications submitted with conflicting information Inability to confirm household’s participation in SNAP or TANF Applications must be approved at face value and then verified for cause Must not be used to automatically verify the households of all school district employees Same process is used as the annual required process May be conducted at any time during the school year Results and total applications verified for cause are reported on the VCR As mentioned at the beginning of this training, in addition to verification being required as part of the annual process, it is also required to be conducted for any application that is questionable. The SFA has the obligation to uphold the integrity of the F&R program and should verify any questionable application. When an application is submitted and is questionable, it still must be taken at face value and processed. However, the SFA can then go about verifying the application for cause. However, from among the list of children approved for free or reduced meals, the SFA could identify children of school district employees and use available district salary information available to them to identify questionable applications and then conduct verifications for cause on those questionable applications. USDA recommends that SFAs consult with legal counsel in establishing parameters of verification for cause for school district employees. SFAs should also consult with their state agency prior to undertaking verification for cause where concerns with employee misrepresentation of information on an income eligibility application have been raised. For more information, please see the USDA memo SP , which is posted on the OSN’s website. To verify for cause, the SFA will follow the same procedure as the annual process. The LEA will need to: Establish a due date for the documentation Send a notification letter to the household Verify the documentation that is submitted Send the results letter to the household Update the student status, if needed Verification for cause may be conducted any time during the school year. Keep in mind that verification for cause is conducted separately and in addition to the annual process. Therefore, any applications verified for cause cannot be included as part of the annual sample size.

Key dates and Verification Activities
9/18/2018 f Verification Timeline Key dates and Verification Activities October 1: Count all current year approved applications on file as of Oct. 1; Select sample size October 31 or Last Operating Day in October Count total number of students, by respective categories November 15: Complete verification activities November 16 - February 1: Complete and submit the Verification Collection Report, FNS - 742 Here are the key dates to the verification timeline. October 1 is an important date as this is the day you count all current year applications in order to determine the size of your sample pool. This year October 1 is on a Sunday, so you will be counting your applications at the start of the day on October 2nd. We will go over which applications to count in depth later. October 31st or the last operating day in October is important as well. This date you must count the total number of students by specific eligibility. Again, we will cover this in depth later. November 15th is the closing date of verification. All households need to respond by this date, and all those that have not responded will be sent adverse action letters. The VCR records the count of applications you conduct on October 1, the count of students you conduct on October 31 and the results of verification. This must be completed by February 1st.

9/18/2018 Verification Process Count all approved free and reduced applications as of October 1st and determine sample pool Can choose to conduct rolling verification Conduct confirmation reviews Replacement of applications (if applicable) Notify households Follow-up attempts (if applicable) Review submitted documentation Send results to households and update student statuses Count students as of October 31st Submit VCR by February 1st *Document all verification activities on the verification tracker The first part of this presentation focuses on the requirement of the annual Verification process. There are main steps required to completing this process correctly. These are all covered in depth in the slides to follow. The verification tracker will be your best friend! Please open this from your resources box. This is very helpful to document each step of the verification process. You can attach it to each application selected for verification and record every date documents were sent, record income calculations and cite when results were sent, when you made follow up attempts etc.

s Document Confirmation Review
Record Date Verification Notice was Sent Document Follow-Up Attempts Record Submitted Documentation Calculations Document Verification Results and Date Results Letter was Sent Here is the verification tracker. This resource will be a huge help during verification season to stay organized. It’s in your resources section and is also posted on the verification webpage. Use this as a cover page for each application that you have selected for verification and you can track your process, income calculations, communication with households and any pertinent notes needing to be documented. Conducting verification this way will also help for review season. If you document everything on your tracker for each application, you can keep each year in a binder and you will have all required documentation needed for an administrative review!

s Examples of organizing verification documentation in a binder and using the tracker.

9/18/2018 Count of Applications Count the total number of approved applications on file as of October 1. Keep record of: # of free categorical applications # of free income applications # of reduced applications # of error prone applications Review a complete list of applications not to include in sample pool in the Eligibility Manual Rolling verification: SFAs may start verification activities once they begin the application approval process for the current school year Conducting verification on a rolling basis (e.g. weekly or monthly) See Memo SP Cover complete list on pages The first step of the annual verification process is the count of applications. This count must be accurate as of the close of business on October 1, and it is to entail the counting of all approved free and reduced price applications for the current year. This year October 1 is a Sunday, so your count should be done at the start of the day on October 2. Remember that the sample pool is the total number of applications approved as of October 1. Counting applications the start of the day on October 2 will give an accurate number of approved applications as of the 1st. The count does not include paid applications, and if the SFA is still in the carryover period, it does not include applications from the previous year. This count is conducted primarily so that SFAs will know how many applications must be verified. Further, the data from this count will later be reported on the VCR. The SFA’s count must break out the following information: number of free categorical applications, number of free income applications, number of reduced applications, and the number of error prone applications Beginning Verification before Oct. 1 – USDA release Memo SP called Beginning Verification before October 1: Guidance to Local Educational Agencies. SFAs can begin verification once they start collecting current year applications and have approved applications on file. You will need to choose how often you would like to conduct the rolling verification. If you choose bi-weekly, you still count approved applications from that timeframe and select a 3% or approved 1.5% sample size and select error-prone first. On October 1 the SFA must still count all approved applications on file to determine an aggregate annual sample size. If the sample size has not been met from the rolling verification, fill the remainder of the sample.

FAQs What if a student is directly certified and on an application?
9/18/2018 FAQs What if a student is directly certified and on an application? Do not count the application What if a student is on an application, but his sibling is directly certified? This student should be extended eligible; do not count the application What if a student is on a foster only application? Unless this student is on a foster list from the county, this application must be counted What if the application has some student’s approved based on income and other student’s are OSCE? Count the application The CDE OSN frequently receives questions on which applications should be counted and which should not. If a student is on an application and on Direct Certification, Direct Cert takes precedence, and so the application is not counted. If a student is on an application along with another student who has been directly certified, this status should extend to him; as such, he is also considered directly certified, and the application is not counted. If a student is on a foster application, the application is counted. The only exception to this would be if the SFA also receives foster lists from the county, and the student is also on that list. In that case, the application would not be counted. What if the application has some student’s approved based on income and other student’s are OSCE? Count the application.

Establishing the Sample Pool
9/18/2018 Establishing the Sample Pool Three types of sample sizes Standard Sample 3% of counted applications must be verified Must be selected first from error prone applications Must be approved by CDE OSN to use Alternate 1 or 2 Alternate Sample 1 Must be selected at random – includes error prone, non-error prone, & categorical applications Alternate Sample 2 1% of counted applications must be verified, selected first from error prone, PLUS .5% of all SNAP/TANF/FDPIR applications The next step in the process is to determine the sample pool from which a certain number of applications will be chosen for verification. The standard sample, a sample that randomly chooses, 3% of the approved applications that have been counted as of October 1. These applications are selected first from error prone applications, which will be covered in the next slide. SFAs can qualify to use two different sample sizes which help them verify less applications. To qualify, a SFA must have had a non-response rate of less than 20% for applications verified in the preceding year. Qualifying SFAs are being notified by CDE OSN and may elect either alternate sample – or stay with the standard sample. If SFA chooses an alternate sample, an assurance must be completed, as well as an Alternate Sample Size Calculation Worksheet, to the OSN. Regardless of which sample size is chosen, SFAs are reminded to check their electronic systems for accuracy, if using a system to pull the sample. Most SFAs with errors in sample size have had these errors because of mistakes in their systems.

9/18/2018 Standard Sample Standard Sample = 3% of all approved applications as of October 1, selected first from error prone Determine total number of applications Multiply by 3% Always round the answer up Begin selecting from error prone applications If there are no more error prone, complete the sample size by drawing from the non-error prone To determine the number of applications to verify using the standard sample, the SFA will need to: Determine the number of applications that were counted as of October 1 Multiply this number by 3% Round the answer up to the nearest whole number Begin selecting applications to verify from the error prone applications If needed, complete the sample size by choosing the remaining needed applications from the non-error prone applications. SFA has 5,280 approved applications on file that were counted. Of these, 111 are error prone, and 5,169 are non-error prone. Multiply 5,280 by 3%, which is This number must be rounded up, so it becomes 159. The SFA will first need to select from the error prone applications. So, the LEA will need to include all 111 error prone applications, and to complete the sample size of 159, the SFA will need to choose an additional 48 non-error prone applications.

9/18/2018 Error Prone Error prone application: any income application that is close to the thresholds of the income eligibility guidelines (IEGs) Non-error prone: all other applications, including income and categorical Frequency Threshold for Error Prone Yearly EP = Apps with income within $1,200 of the yearly IEGs Monthly EP = Apps with income within $100 of the monthly IEGs Twice per Month EP = Apps with income within $50 of the twice per month IEGs Every 2 Weeks EP = Apps with income within $46.15 of the every 2 weeks IEGs Weekly EP = Apps with income within $23.07 of the weekly IEGs Please reference your error prone chart. Before we look at the different sample sizes in more detail, we must first have an understanding of what error prone and non-error prone applications are. Error prone applications are simply those applications that fall, depending on frequency, within $1200 of the yearly Income Eligibility Guidelines (IEGs) $100 of the monthly IEGs, $50 of the twice per month IEGs $46.15 of the every two weeks IEGs OR $23.07 of the weekly IEGs. A non-error prone application is any other application, including income or categorical applications. Most electronic free and reduced software systems do flag applications if they are error prone. However, as with anything with an electronic system, the LEA should always spot check the system for accuracy.

Error Prone Chart 9/18/2018 Please reference your error prone chart.
Before we look at the different sample sizes in more detail, we must first have an understanding of what error prone and non-error prone applications are. Error prone applications are simply those applications that fall, depending on frequency, within $1200 of the yearly Income Eligibility Guidelines (IEGs) $100 of the monthly IEGs, $50 of the twice per month IEGs $46.15 of the every two weeks IEGs OR $23.07 of the weekly IEGs. A non-error prone application is any other application, including income or categorical applications. Most electronic free and reduced software systems do flag applications if they are error prone. However, as with anything with an electronic system, the LEA should always spot check the system for accuracy.

POLL Poll 2: Household of 3; monthly income of $2,200
Is this Error-Prone? YES

Standard Sample Example:
9/18/2018 Standard Sample Example: 1,214 approved applications on file as of October 1 Of these, 35 are error prone, and 1,179 are non-error prone Multiply 1,214 by 3% = 36.42 ALWAYS ROUND UP = 37 applications will be selected for verification Select first from error prone to meet the sample size = Select ALL 35 error-prone applications Select the remaining 2 applications from non-error prone to complete the sample size To determine the number of applications to verify using the standard sample, the SFA will need to: Determine the number of applications that were counted as of October 1 Multiply this number by 3% Round the answer up to the nearest whole number Begin selecting applications to verify from the error prone applications If needed, complete the sample size by choosing the remaining needed applications from the non-error prone applications. SFA has 5,280 approved applications on file that were counted. Of these, 111 are error prone, and 5,169 are non-error prone. Multiply 5,280 by 3%, which is This number must be rounded up, so it becomes 159. The SFA will first need to select from the error prone applications. So, the LEA will need to include all 111 error prone applications, and to complete the sample size of 159, the SFA will need to choose an additional 48 non-error prone applications.

POLL Poll: What processes are required to use an alternate sample size? Choose any sample size I want Count applications on October 1st and select 3% Start rolling verification on July 1st. An improved response rate of 20% from the prior year and an approved assurance

9/18/2018 Confirmation Reviews Prior to notifying households, selected applications must be reviewed for accuracy by an individual other than the individual who made the initial determination If the review indicates a change in the initial determination: Review the table, SFA responsibility following a status change in the Eligibility Manual Confirmation reviews must be documented; Use the verification tracker If a highly accurate benefit issuance software is used, a confirmation review waiver can be submitted to CDE OSN Review page 103 in the eligibility manual. Highlight the review must be conducted by an individual other than the individual that made the initial determination. Cover the table on page 104. Once the SFA has determined which applications are to be verified, they must conduct confirmation reviews on the applications that were selected for verification. A confirmation review means that an individual, other than the individual making the initial eligibility determination, checks the application to ensure that it was approved correctly. It is critical that the confirmation review must be documented – i.e., the confirming official must sign off – and date – that the review took place. The best place to document this is on the Verification Tracker. If the review indicates that the household is not eligible for free or reduced, the eligibility status must be corrected and the household sent a letter of adverse action. This application will be removed from the sample pool, and another must be selected in its place. If the review indicates that the household continues to be eligible for free or reduced, the application must be verified. However, if the application was reduced and should have been free, the status must also be changed right away and the household notified. If the status was free but should have been reduced, the status is not changed until after the application is verified. This is to prevent having the family go to a lesser benefit temporarily if verification ends up changing the application back to free anyway.

Replacement of Applications
9/18/2018 Replacement of Applications Up to 5% of applications may be replaced Applies when the household would be unable to respond satisfactorily Does not apply to Limited English Proficient (LEP) households Must be replaced with applications selected on the same basis, if possible Must occur if it is found households cannot respond, even if it is after verification notices have been sent out Applications do not need to be replaced if it is found that a household has been directly certified Would be advantageous to conduct a direct certification upload of students’ selected for verification prior to sending notices One lesser known provision of verification is that applications selected to be verified can be replaced, on a case-by-case basis. So, the fourth step is to look through the applications about to be verified and determine whether any of these households would not be able to respond satisfactorily. For example, is the parent in the hospital, is he in jail, or is he out of the country? These could be legitimate reasons not to verify the family – but just be certain to document the reason that any application was replaced. Please note that an application cannot be replaced just because the household does not have a ready grasp of written English. If this is the case, language services must be made available to the household so that the Verification process can be completed. If an SFA replaces an application with another, the replacement application must be selected on the same basis. For example, if the original application was error prone, the replacement application must also be error prone (assuming there are still enough error prone applications remaining in the pool). Often, it is found that students have left the district or moved. If this is known, you must replace the application. If it is found that the household has become directly certified you do not have to replace the application. You can send the direct certification notification and the verification for that household is considered complete.

Notification to Households
9/18/2018 Notification to Households Contact households at beginning of October, or as soon as possible Recommend sending in English and Spanish if appropriate The notification of selection for verification must contain: Use CDE OSN template A statement that the household was selected for verification Modified Use of Information Statement & Non-discrimination Statement Types of acceptable information that may be provided to confirm current income Household members form Information must be provided by a certain date & that failure to do so will result in termination of benefits Statement of earnings by employer form Name of SFA contact & a no-cost telephone number Social Security or Supplemental Securing Income form Mark page 106. Summarize requirements. Highlight bullet points. Use CDE OSN template, it is attached in the resources section. Once the households have been selected, the SFA must send out the notification they have been selected for verification. This letter should be sent out in early October and must contain the following information: That the household was selected for Verification The types of acceptable information that may be provided to confirm current income Paystubs, benefit award letters, support payment decrees from courts Information on the receipt of benefits under SNAP, FDPIR, or TANF Proof that a child is homeless/migrant/runaway/foster/Head Start That current income means any time between the month prior to application and the time the household is being verified The household members form That information must be provided by a certain date & that failure to do so will result in termination of benefits Name of LEA contact & no-cost telephone number Modified Use of Information Statement & Non-discrimination Statement

9/18/2018 Follow-up Attempts Before November 15, at least one additional attempt to obtain the necessary verification information is required Follow-up if a household does not respond or submits insufficient written evidence Ensure LEP households are provided adequate assistance May be via phone, mail, or Recommended follow-up is conducted by phone Must be documented on the verification tracker Once households have been notified that they must submit documentation for verification, the SFA will need to track of households that are not responding. The SFA must make a follow-up attempt before the verification deadline of November 15. It is recommended initially giving households one month to submit documentation – and providing the follow-up notice two weeks before that deadline. This still gives the households adequate time to respond before their documents are due. A follow-up must also be given if the household has responded but has not given sufficient written evidence. For example, maybe a household sent in proof of one income but not another, or perhaps the frequency was missing on the paystub. If this is the case, the LEA must follow up. Follow-ups must especially be sent to Limited English Proficient households, to ensure they have the resources needed to complete the request. Follow-ups may be conducted via phone, mail, or , but they must always be documented – preferably on the Verification Tracker.

Submitted Documentation
9/18/2018 Submitted Documentation Ensure all required documents have been submitted Household Members form Proof of income or enrollment in SNAP/TANF/FDPIR or OSCE programs Ensure information is current Month prior to the submission of the application and up until the time of verification Documentation must include name of household member Review page 107. Households will start submitting documentation in October. When the SFA receives this information, they must ensure that all required documents have, in fact, been submitted. This includes the household members form and proof either of income or of enrollment in Assistance Programs (like SNAP or TANF) or in OSCE programs (like homeless, migrant or foster). Once it has been determined that all of the paperwork has been submitted, the next question is, “Is the information current?” For purposes of verification, current refers to the month prior to the time of application, the month in which the application was submitted, or any month after that, up until the time the application is being verified. Highlight page 111. Next, the SFA will need to ensure that the documentation includes the name of the person for whom it was submitted. For example, does the paystub have the name of the employee who lives in the household, or does the SNAP letter have the name of someone in the household who is receiving the benefits?

POLL Poll 3: An additional follow-up attempt is required to obtain necessary verification information from families that have not yet responded to the verification request.

Employment Households may send pay stubs or letter from employer
9/18/2018 Employment Households may send pay stubs or letter from employer Must include name, date, frequency, gross amount and pay date If letter from employer, frequency must be in writing from the employer If a weekly pay stub is representative of typical income, one pay stub is sufficient If multiple pay stubs are given, SFA should average the total based on frequency of pay Determine eligibility status as if processing an application Compare household income and size to the IEGs Document calculations on the verification tracker and any changes in status Let’s now look through the different types of documentation that must be submitted, depending on the household’s circumstances – and at how the SFA will need to process it. If a household receives income from employment, they must send in a pay stub or signed letter from the employer. Again, the documentation must include the person’s name and the date, frequency, and amount. The frequency must be indicated by the employer on the paystub or in the letter; the household cannot self-indicate this. If income documentation is submitted, it must also have the frequency and the amount, for one month’s worth of income. (If a weekly pay stub, for example, is representative of what the household normally receives each week, though, one pay stub is sufficient). The SFA will need to calculate the total income the same as if they were processing an application. If there is just one income, or if all income is received at the same frequency, the income must be determined at that specific frequency. If income is received at different frequencies, it must be annualized. Once the SFA knows the total amount of the income, the SFA will compare it to the IEG chart, determine the eligibility status, and document all calculations on the Verification Tracker.

Name of Household Member
9/18/2018 Frequency of Pay d Current Information Gross Wages Is this an example of acceptable income documentation? Yes, includes: name, gross wages and the frequency. With this stub, I would request one month’s worth. It is difficult to determine if they are paid bi-weekly or bi-monthly.

Self-Employment Households may send in:
9/18/2018 Self-Employment Households may send in: Last year’s income (1040 tax form) to project income for this year Quarterly tax estimates or ledgers to show current income Cannot send personal taxes or statements of work For Verification, income is calculated based on net income Business loss should be listed as zero income Reference the 1040 examples to calculate self- employment and/or farming income Income for those self-employed is determined and verified differently. Sometimes questions arise as to whether someone is actually self-employed. According to the IRS website, if someone can answer yes to any of these questions, he would be considered self-employed: Do you carry the business as a sole proprietor or independent contractor? Are you a member of a partnership that carries on a trade or business? You are in business for yourself, including part-time? If a household is self-employed, they may send in last year’s income (if it is still a good representation of current income). Acceptable documentation is a 1040 tax form. Households may also submit quarterly tax estimates or ledgers to show income. Personal taxes or statements of work are not allowable. Remember that income for the self-employed is calculated based on net, not gross income. To determine this, the household must subtract business expenses from the gross, before deductions. If there is a business loss, this loss is simply listed as $0.

s The family is reporting different income frequencies. We must annualize the income. 2 Incomes provided Different frequencies = Annualize Income Jane Doe = $1,200 bi-weekly $1,200 x 26 = $31,200 John Doe = $900 2x/month $900 x 24 = $21,600 $31,200 + $21,600 = $52,800 Use IEG for household of 6 Family qualifies for reduced The family was originally free and now qualifies for reduced. What next steps must be taken? You must send the family notification that their status is changing and provide the family 10 days of adverse action. Make sure your notification contains the lunch prices and prices for reduced rates.

Agency Records Benefit programs: Assistance Programs (SNAP/TANF/FDPIR)
9/18/2018 Agency Records Benefit programs: Social Security retirement benefit letter Pension award notice Unemployment Letter from Worker’s Comp Welfare Payments Assistance Programs (SNAP/TANF/FDPIR) Certification notice showing the beginning and ending dates Foster Documentation verifying the child is under the legal custody of the agency, state or court Other OSCE (Homeless/Migrant/Runaway/Head Start) District liaisons must provide documentation Documentation must be current During Verification, many SFAs come across households receiving benefits. This includes benefits from Social Security, pensions, retirement, unemployment, disability, worker’s comp, and welfare payments. Appropriate documentation that the households may submit includes notices of eligibility, benefit letters, statements of benefits received, or check stubs. The SFA will need to ensure that a household member’s name is listed on this documentation, and that it is current. If the household does not have current documentation, they will need to contact the appropriate agency to obtain a letter for the amount (and frequency) they are receiving. Another main type of documentation that may be submitted is proof of enrollment in Assistance Programs or in OSCE. If a SFA chooses one the of the alternate sample sizes, this increases the chances that one of these types of applications will be verified. If an application being verified was determined eligible based on SNAP, TANF or FDPIR benefits, the household must submit either a certification notice or a letter showing that benefits are being received by someone in the household. It must also show that the benefits are current. If an application being verified was determined based on foster status, the household will need to submit either written documentation or the name and contact information of a person at the agency or court. The documentation or this person must be able to verify that the child is in the custody of the county – during the current timeframe. Finally, if a household is being verified and has a student who may qualify based on OSCE, such as homeless, migrant, runaway, or Head Start, households should be encouraged to contact the district. Then the appropriate liaison can provide food services with the information (e.g., a homeless list) needed to show that the child has been identified under these programs. This documentation will serve as proof of the student’s status and is sufficient for satisfying the requirements of verification. It is important to note that just because a household applies based on an Assistance Program or OSCE, that does not mean that they cannot provide documentation for verification showing that they also qualify for free based on income. Income documentation should still be provided with a new income application.

Other Forms of Income Seasonal workers Zero income Child support
9/18/2018 Other Forms of Income Seasonal workers Annual income may be used, including prior year, if still current Zero income Signed written note stating how the individual is providing food, clothing, and housing – and when he/she expects to receive income Child support Court decree, child support registry, copies of checks received, bank statements As with determining income during the F&R application process, the verification process also includes a number of special circumstances. These include income for seasonal workers, those who have no income, child support, and military housing. A seasonal worker’s current income may distort his actual income circumstances. Accordingly, the Eligibility Manual allows for annual income to be used for seasonal workers, including prior year, if it is still current. Therefore, 1040 tax forms would be an allowable form of documentation. Sometimes, households may not currently be receiving any income at all. If this is the case, they must submit a signed, written notice stating how basic needs, such as food, clothing, and shelter, are being met. There should also be an indication of when the individual expects to start receiving income again. Such a letter is considered sufficient evidence for verification. Child support can be very tricky, in that the amounts stipulated to be paid are not always received – or are not always received consistently. The best documentation for child support includes a court degree, child support registry, or copies of checks received.

9/18/2018 Collateral Contacts Collateral contact is a person outside of the household who is knowledgeable about the household’s circumstances Can confirm household’s income or participation in other programs Examples Employer Social service agencies Migrant workers’ agencies Religious or civic organizations May be used only when there is no adequate written evidence Must be designated and/or approved by the household May be written or oral Must be documented, dated, and initialed One final method of documenting eligibility for free or reduced benefits is for the household to designate a collateral contact. A collateral contact is a person outside of the household who is knowledgeable about the household’s circumstances, including household size and income information. Examples include employers, social services, migrant workers’ agencies, and religious or civic organizations. A collateral contact may be used only when there is no adequate written evidence that may be submitted by the household. This person may not be contacted by the LEA unless the household has provided prior consent. The information received from the collateral contact may be written or oral, but if oral, the conversation must also be documented, including the date and the initials of the verifying official.

Household Members Form
9/18/2018 Household Members Form To be submitted with each application verified Helps provide a clear picture of current household composition Acceptable if household composition is different than what was on initial application Will need to clarify with household and document all communication A written letter from household or employer documentation of loss of employment can be requested The last piece of information to note, which must be submitted as part of the household’s documentation, is the Household Members Form, which was briefly mentioned previously. This form gives the SFA a clear picture of who lives in the household – and whether they have income. This form can be particularly helpful if, for example, both Mom and Dad had income listed when the application was submitted, but now Mom has lost her job, and only Dad sends in proof of income. By Mom marking the no income box on the Household Members form, the SFA will know that it was not just an oversight; Mom really did not have any income documentation to submit. Also, it could be helpful if the household has chosen to report on their current circumstances, which have changed since the time of the app. If Aunt Sally and Uncle George have since moved in, the household can simply note them on the Household Members form, and the SFA will not need to wonder why the household suddenly has two extra people living there.

Sending Results to Households
9/18/2018 Sending Results to Households SFA must send a results letter to the household Results (no change or change to a different status) Effective date of change (if any) Cost of meals (if change in status) Letters of adverse action must be sent to households that did not properly respond, had a reduction in benefits or did not respond at all by November 15 Adverse action notice must provide 10 calendar days’ written notice that benefits are decreasing Notice must state: Change in benefits Reason for the change Appeal must be filed within the 10 calendar day period Instructions on how to appeal Household can reapply at any time during the school year Use CDE OSN template Review rules on page 57. Highlight appeal must be filed within 10 days of adverse action. Use the CDE OSN template, it is attached in the resources section. Once the SFA has verified all of the documentation that has been submitted – and has made a determination on all of the applications, the SFA will need to send results to the households. The Results Letter should include the following information: The results of Verification (i.e., no change in status, or a change to a different status) The effective date of the change (if any) The cost of meals (if change in status).

POLL Poll 4: What date do families need to provide verification documentation by? November 15 December 15 February 1 October 31

When Verification is Considered Complete
9/18/2018 When Verification is Considered Complete Submitted documentation supports, or increases eligibility, and SFA sends results letter Household becomes directly certified Submitted documentation does not support the level of original eligibility, and SFA sends results letter/adverse action Household indicates verbally, or in writing, that they no longer wish to receive benefits, and SFA sends letter of adverse action Household does not respond by November 15, and SFA sends results letter/adverse action Questions often come up on when verification is considered complete. Verification is considered complete when the SFA sends the results letter. This may be once: The household submits documentation that supports or increases the benefit level, and the SFA sends the results letter The household documentation does not support the level of benefits, and the SFA sends the results letter/adverse action The household indicates verbally or in writing that they no longer wish to receive benefits, and the SFA sends the results letter/adverse action The household does not respond by the November 15 deadline, and the SFA sends the results letter/adverse action Households can reapply at any time during year, but must provide income documentation.

Update of Benefits Changes to a higher benefit Decrease in benefits
9/18/2018 Update of Benefits Changes to a higher benefit Must be implemented within 3 operating days Decrease in benefits Must be implemented after 10 calendar days The first day of the 10 calendar days is the day the notice of adverse actions is sent Changes must be reflected in the benefit issuance system/on application and the point of sale Once determinations have been made and letters have been sent, the SFA will need to update the benefits of any student whose application changed status. If the student is moving from reduced to free, this change must be implemented within 3 operating days, but preferably as soon as possible. If the student is moving from free to reduced or paid - or from reduced to paid, this change must be made within 10 calendar days from the date the letter of adverse action is sent. During the 10 days, the household does have the right to appeal. If this is the case, the SFA’s hearing procedure must be followed, and the household’s benefits must stay the same during the time of the appeal. If a household has been changed to reduced or denied, they may re-apply at any time. Households that had changed to reduced must submit documentation and update their application, in order to re-apply. Households that had changed to denied must submit documentation but also must submit a new application. Documentation must always be submitted by these households because they are considered to be in Verification for the whole year.

Count of Students Occurs on the last operating day of October
9/18/2018 Count of Students Occurs on the last operating day of October Count number of: Enrolled students Directly certified SNAP & extended eligible SNAP students Students directly certified TANF, extended eligible TANF, homeless, migrant, runaway, Head Start, or foster on a list from the county Students on categorical applications Students on free income applications Students on reduced applications May not correlate with # of applications counted on October 1 Number will be reported on the VCR SFA will need to conduct a count of students as of close of business on the last operating day of October, which is usually the 30th or 31st. The SFA will need to count all students in all of the following groups: Number of enrolled students at participating schools All directly certified and extended eligible students Students certified as homeless, migrant, runaway, Head Start, or foster on a list from the county Students on categorical (SNAP/FDPIR/TANF) applications Students on free income applications Students on reduced applications It is possible that the numbers reported on the last operating day of October may not correlate with the number of applications counted on October 1, and this is okay. For example, a smaller district may have had 3 SNAP applications (with 3 students total) on October 1, and then maybe two of these students changed to Direct Cert part-way through October. Therefore, this LEA would have reported 3 SNAP applications but just 1 SNAP student on the last operating day of October. There would normally be more students than applications, but since the count days are different, it makes sense that the numbers will not necessarily correlate. The numbers of students counted on the last operating day of October will need to be jotted down, as they will need to be reported on the VCR. It is good that this count is taken at the end of October, as this gives SFAs time to complete Direct Cert uploads through October and match more students, who will, in turn, be reported to the USDA and be factored into Colorado’s match rate.

Record Retention Documentation for each verified application:
9/18/2018 Record Retention Documentation for each verified application: Confirmation review Follow-up attempts Copies of correspondence Documents submitted by the household (or copies) Changes in eligibility, reason for the change, date the household was notified, the effective date, follow-up attempts Title and signature of the verifying official Criteria for replacing applications for verification Keep for five years after certification or until audited The last step in the verification process is record retention. SFAs must maintain on file a description of their verification efforts. The description must include a summary of the verification efforts including the selection process, the total number of applications on file on October 1, and the percentage or number of applications that are/will be verified by November 15. SFAs must also record and maintain documentation for each verified application. This is to include the following: Confirmation review – date and signature of confirming official Copies of correspondence with the household Documents submitted by the household (or copies) Changes in eligibility, the reason for the change, the date the household was notified, the effective date, & follow-up attempts Title and signature of the verifying official The best place to maintain all of this is on the Verification Tracker. If the SFA replaced any applications, they must also document the criteria used for replacing the applications. Keep in mind that per state statute, verification records must be kept for five years after the certification due date or until audited. (Federal requirements are for three years plus current.)

Verification Collection Report (VCR)
9/18/2018 Verification Collection Report (VCR) Will be completed in the CO Child Nutrition Hub Username/password needed Contains all of the data from the application count, student count and verification results Due February 1 Any corrections must be completed by this date Detailed instructions will be provided The VCR must be completed in some aspect by all SFAs in some aspect whether they conducted verification or not. The VCR captures verification activities and directly certified students. The report is due annually by February 1. The VCR must be submitted and completed (meaning all errors have been corrected) no later than February 1. Please note the following critical information about the VCR: Detailed instructions will be provided with the VCR. Following these will answer most questions and will help ensure that the form is filled out correctly. Errors on the VCR do lead to a finding on the Administrative Review

Enter questions and comments into the chat box
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