1. INDEPENDENT REVIEW OF APPLICATIONS KENTUCKY DEPARTMENT OF EDUCATION SCHOOL AND COMMUNITY NUTRITION DEBORAH THOMPSON

2. WHO DOES AN INDEPENDENT REVIEW? Only those districts that collect applications can be required to conduct a Second Review.

3. WHO DOES AN INDEPENDENT REVIEW?  Beginning SY 2014 -2015, LEAs that demonstrate a high risk for administrative error or high levels of error associated with certification and benefit issuance are required to conduct a Second Review of Applications otherwise known as an Independent Review.  SCN utilizes FNS specified criteria when selecting LEAs who must conduct an Independent Review. (Criteria 1 or Criteria 2)

4. WHO DOES A SECOND REVIEW? CRITERIA 1 Any LEA found to have 10% or more certifi- cation/benefit issuance errors during an Administrative Review. CRITERIA 2 Any LEA that KDE considers “at risk” for certification error, but were not selected according to Criteria 1.

5. WHY AN INDEPENDENT REVIEW? The Healthy, Hunger Free Kids Act (HHFKA) included several provisions to help increase effectiveness and integrity in Child Nutrition Programs. In an effort to decrease certification error during the eligibility determination process, the HHFKA requires that certain LEAs to conduct a Second Review of Applications.

6. WHAT IS AN INDEPENDENT REVIEW? A Second Review (Independent Review) requires a re-evaluation of the eligibility determination made by the original determining official, based on the information provided by the household, on the application. This is done by a second party.

7. WHAT OCCURS IN AN INDEPENDENT REVIEW? The Second Review must determine whether the application is complete. To be considered complete, the following information should be included in the application:  the signature of an adult household member,  the last four digits of a social security number (or an indication of “none”),  the names of all household members including the student for whom the application is made,

8. WHAT OCCURS IN AN INDEPENDENT REVIEW? (CONT.)  the income amount (received by each household member) identified by the individual who receives it,  the income source,  the income frequency or categorical information, if applicable,  the signature of the Determining Official,  the signature of the 2 nd Reviewer (Best Practice- signature done in different color ink).

9. WHAT ARE THE REPORTING REQUIREMENTS ? Submit to KDE an annual report (FNS 742a), detailing the number of free and reduced price applications subject to a Second Review, the number and percentage of reviewed applications for which the eligibility determination was changed, and a summary of the type of changes that were made.

10. WHAT ARE THE REPORTING REQUIREMENTS ? LEAs will only need to report on applications for the current school year that have been reviewed on or before October 31 st. Reporting is due to KDE by November 16 th.

11. WHEN MUST THE INDEPENDENT REVIEW BE CONDUCTED?  BEFORE the household is notified of eligibility and should NOT result in the delay of an eligibility determination  Notify households of the child’s eligibility determination within 10 operating days of receiving the application.

12. Reporting Form FNS 742a

13. REPORT FORM (FNS 742A) : DATA ELEMENTS Requires that ALL applications be reviewed, including applications initially determined to be ineligible for free and reduced price benefits (i.e. denied by the initial reviewer). Section 1-3: all applications, including applications that were initially determined to be eligible or ineligible for free and reduced price benefits Section 1-4: changes in eligibility determinations for applications that were initially determined eligible for free and reduced price benefits, as well as those initially determined ineligible but were changed to free or reduced price as a result of the Independent Review

14. REPORT FORM (FNS 742A) DATA ELEMENTS Section 1-5: information pertaining to changes in eligibility determinations and the type of error that contributed to the incorrect initial eligibility determination, if applicable

15. WHO DOES THE INDEPENDENT REVIEW?  an individual or entity that did NOT make the original eligibility determination  an individual or entity is not required to be an employee of the LEA,but must be trained on how to make an application determination.

16. WHEN IS THE INDEPENDENT REVIEW COMPLETE?  When KDE determines that the LEA provided documentation or, data obtained during an Administrative Review demonstrates that no more that 5% of reviewed applications required a change in eligibility determinations.

17. FOR FURTHER QUESTIONS: Deborah Thompson Child Nutrition Program Consultant School and Community Nutrition Kentucky Department of Education Ph. 502-564-5625 Ext. 4928 deborah.thompson@education.ky.gov

18. The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers, employees, and applicants for employment on the bases of race, color, national origin, age, disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs, marital status, familial or parental status, sexual orientation, or if all or part of an individual’s income is derived from any public assistance program, or protected genetic information in employment or in any program or activity conducted or funded by the Department. (Not all prohibited bases will apply to all programs and/or employment activities.) If you wish to file a Civil Rights program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, found online at http://www.ascr.usda.gov/compliant _filing_cust.html, or any USDA office, or call (866) 632-9992 to request the form. You may also write a letter containing all of the information requested in the form. Send your completed complaint form or letter to us by mail at U.S. Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W., Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.http://www.ascr.usda.gov/compliant _filing_cust.htmlprogram.intake@usda.gov Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (in Spanish). USDA is an equal opportunity provider and employer.