1. FREE AND REDUCED PRICE ELIGIBILITY “Making the Pieces Fit” Common Errors and Findings…

2. FREE & REDUCED PRICE MEAL AVAILABILITY Schools participating in the NSLP, SBP, and/or ASSP MUST offer free and reduced priced benefits to eligible children...

3. FREE & REDUCED PRICE MEAL AVAILABILITY Free/Reduced Price meal APPLICATIONS & LETTERS must be made available to each enrolled student yearly. REMEMBER…Only ONE application per household is required…

4. COMMON FINDINGS Distribution & Receipt of Applications

5. FINDING: The F/R application is sent home with students at the end of the school year for the next year… Eligibility applications and letters may NOT be distributed earlier than four calendar weeks prior to the time students start back to school…

6. FINDING: The LEA requires all students to submit applications for free/reduced price meals… Households CANNOT be required to submit free/ reduced applications if they do not wish to apply. page 15, EMFSM

7. Finding: US Citizenship is used as a basis for determining eligibility. US citizenship is NOT a criteria for determining eligibility. You should not ask nor use citizenship as a means for students receiving free or reduced priced meals.

8. FINDING: The correct USDA non-discrimination statement is not included on eligibility application and/or letter(s). ALL ALL published materials and resources, including Web sites and menus, used by the Child Nutrition program that tells the public about FNS programs must contain a nondiscrimination statement, per FNS-113.

9. NON-DISCRIMINATION STATEMENT In accordance with Federal law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on the basis of race, color, national origin, gender (male or female), age or disability. To file a complaint of discrimination, write USDA, Director, Office of Adjudication, 1400 Independence Avenue SW, Washington, DC 20250-9410 or call toll-free (866) 632-9992 (voice). Individuals who are hearing impaired or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish). USDA is an equal opportunity provider and employer. *ENSURE YOU USE THE CORRECT STATEMENT!!!

10. NON-DISCRIMINATION STATEMENT Abbreviated Version: If the material is too small to permit the full statement to be included, the material will at a minimum include the statement, in print size no smaller than the text that: “This institution is an equal opportunity provider and employer.”

11. Finding: The USDA non- discrimination poster is not clearly displayed in the cafeteria. This poster must be prominently displayed in a location clearly visible to your customers.

12. COMMON FINDINGS Application Processing

13. 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

14. What is the *CARRY-OVER Period? A student who received free/reduced benefits during the previous school year, may receive the same benefit for the first 30 operating days of the current school year OR until a new application is processed. REMEMBER…Eligibility may also be extended to the student’s siblings for the first 30 operating days.

15. … 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. REMEMBER…Eligibility becomes effective when the student submits the application for free/reduced priced meals.

16. FINDING: Student is approved as Categorically Eligible, but case number is not listed on the application… Categorical Eligibility based on receipt of Public Assistance requires that a FS, TANF or FDPIR case number be listed on the application (EBT # not acceptable). Names of children for whom the application is made for, as well as the adult signature are also required to be a complete application.

17. FINDING: Homeless Student approved as Categorically Eligible based on “self- declaration” on application… Homeless, migrant and run- away students must be certified by the LEA’s Homeless liaison or MEPC in order to qualify as Categorically Eligible under this criteria.

18. FINDING: Foster child NOT processed as Categorically Eligible… Foster children are now considered Categorically Eligible when formally placed by a State Child Welfare agency or court system. Remember…you must obtain and maintain confirming documentation from the placement agency…

19. FINDING: Application processed as an income application but required information is missing Income applications must contain the following to be considered complete: Names of ALL household members Income (and frequency of receipt) for ALL household members OR indication of “No Income” Signature of Adult head of household Last 4 digits of the Social Security Number of person signing application OR indication of “no” Social Security Number

20. FINDING: Application is processed as an Income Application, but incorrect income is used to determine eligibility… Current gross income is used to determine eligibility, unless special circumstances exist, i.e. self-employed, deployed family member, combat pay, etc. –Current income is: Income received in month of application Income received in prior month of application Anticipated/projected income (if not received yet)

21. 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.

22. FINDING: Application completed as “Emergency” application by school official, but no documentation to confirm nature of emergency… Applications must contain sufficient documentation to support student’s eligibility. Minimum documentation includes: –Nature of emergency –Knowledge (and source of information) to support that student is eligible for benefits based on income and household size –Signature of person completing application. * REMEMBER – family must be notified of eligibility

23. COMMON FINDINGS Application Maintenance

24. FINDING: Student is approved for free/reduced benefits, but family is not notified of eligibility. All households MUST be notified of eligibility, including DC status. Households DENIED benefits MUST be given written notification which must advise : –-reason for denial –-right to appeal –-households may reapply at any time during the school year

25. FINDING: Sponsor fails to follow- up on Temporary Free application at end of “temporary” eligibility period. Suggested time period for Temporary Free status is no longer than 45 days. SFA must follow-up with family prior to the end of this timeframe to determine if household circumstances have changed.

26. FINDING: Family reports change in household circumstances resulting in eligibility status moving to lesser benefit. Unless given temporary approval, student eligibility is in effect from the date of application through the first 30 days of the next school year, except in situations where the status changes as a result of Verification or the initial eligibility determination was incorrect…

27. FINDING: Sponsor did not use Direct Certification for students who receive FS and TANF. By law, all sponsors must Directly Certify children from household receiving food stamps. Although not required, sponsors are encouraged to use Direct Certification for students from TANF households. Remember…Eligibility is extended to all students living in the same household.

28. FINDING: Students categorized as Direct Certification (DC), but names are not on the DC listing. Direct Certification confirmation should be maintained by the sponsor as proof of eligibility …3 years plus current school year. Remember…maintain documentation to support sibling’s extended eligibility as well…

29. 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 Foods Stamps (SNAP/FNS Benefits) or TANF.

30. FINDING: Student is receiving extended benefits, but there is no documentation to support eligibility. When extending eligibility benefits to family members living in the same household as a Direct Cert., always maintain documentation to support the extended eligibility, i.e. name of student for whom benefits are extended, name of student who is receiving DC benefits, and source of matching data and/or person contacted, date of eligibility.

31. FINDING: Confidential eligibility information is released for unauthorized purposes or without prior consent. Release of free/reduced eligibility information is very limited and for specific Federal programs on a NEED TO KNOW basis in order to provide a service or carry out an authorized activity… REMEMBER…Prior to releasing any F/R eligibility information, a Memorandum of Agreement (MOA) or parental waiver must be in place.

32. Memorandum of Agreement Current Memorandum of Agreement that are signed by the State Agency include: –Testing/Accountability –Title I/Reading First –Career and Technical Education (CTE) –National Assessment of Education Progress (NAEP)

33. FINDING: Student eligibility status is not updated in POS or roster at end of 30-day carry-over period. Eligibility must be current and correct at POS and on eligibility roster at all times, including at the end of the 30-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 days for decrease in benefits.

34. FINDING: Students receiving free/reduced price benefits are required to state name or use PIN at POS, while paying students are not. Overt identification of meal eligibility is in direct violation of the Richard B. Russell National School Lunch Act, PL 109-97. All students must be issued and must use a personal identification number at the point of sale to prevent overt identification of meal eligibility.

35. REFERENCES FOR ELIGIBILITY DETERMINATION: Current Eligibility GuidelinesCurrent Eligibility Guidelines Eligibility Guidance for School Meals Manual, January 2008Eligibility Guidance for School Meals Manual, January 2008 Statutory Authority:Statutory Authority: 7 CFR 245, Determining Eligibility for Free and Reduced Price Meals 7 CFR 245, Determining Eligibility for Free and Reduced Price Meals http://www.fns.usda.gov/cnd/governance/notices/iegs/EligibilityManual.pdf

36. QUESTIONS?