1. How to Conduct the Verification Process for NSLP SY 15-16 Division of School and Community Nutrition Kentucky Department of Education

2. Quick Note- Verification does not apply to SFAs that do not process applications. If your district is FULL CEP or you are a RCCI without applications, verification ACTIVITIES do not apply to you. You are however, NOT EXEMPT, from Verification Reporting which will be the topic of the October DISH.

3. Objectives for Today’s Session: By the end of this presentation, you will understand the purpose and necessity of the verification process. By the end of this presentation, you will understand how to conduct the verification process including the selection process. By the end of this presentation, you will understand documentation and record keeping requirements for the verification process.

4. Authority Verification is required for all SFAs that collect and process household applications per the following: National School Lunch Act, Section 9 7 CFR 245.6a “Verification Requirements” 7 CFR 210.15 “Reporting and Recordkeeping” Eligibility Manual for Schools (August 2015)

5. Verification: What is it? Verification is the confirmation of eligibility for free and reduced price meals under NSLP and SBP.

6. Key Verification Dates October 1 st - SFAs determine the total number of approved applications on file for the current school year as of October 1 October 31 st - SFAs determine the total number of students enrolled for the current SY as of this date- FROM POS November 15 th - SFAs must complete verification activities

7. A Look at the Verification Process Create your Sample Pool and determine verification method Process information via CNIPS Know Your Verification Method Standard, Alternate One or Alternate Two Method for Sample Size Select Applications for Verification Based on Method LEA confirming official reviews selected applications LEA chooses to replace applications or proceed with verification process Conduct Confirmation Review/Replacement Applications Send notification to household regarding verification selection Collect acceptable written evidence Notify Households for Verification Verify evidence submitted by household Follow-up with household if adequate evidence is not provided Conduct Verification Check to see if change in benefit level occurred Notify households of results and appeals procedure if necessary Determine Verification Results Report information in CNIPS Report Verification to SCN

8. Documentation: Let’s Get Started on the Worksheet

9. Establish the Sample Size Know Your Verification Method Establish the Sample Size LEAs may begin verification activity once the application process is underway and approved applications are on file. LEAs may project number of applications to verify based on previous year, HOWEVER the actual sample size must be determined based on actual applications on file as of October 1 of the current school year. Number 26 on your CNIPS Sponsor Application Will show you your approved Verification Method The total number of approved applications on file as of October 1 of the current school year is your SAMPLE POOL.

10. Establish the Sample Size Know Your Verification Method Establish the Sample Size Calculate the sample size- or the number of applications that must be verified. Always round upward to the nearest whole number. At least one application must be verified. You may not verify more or less than required. Verification “for cause” is done in addition to what is required. Print the Total Number of Approved Applications on October 1 st from your POS. KEEP THAT DOCUMENT!

11. Methods of Verification Select Application for Verification Based on Method Methods of Verification Standard Verification Select the lesser of: -3% of all applications approved by the LEA as of October 1 of the current school year selected from error prone applications. -3,000 error prone applications approved by LEA as of October 1 of the current school year. There are three methods for verification. Each SFA is required to use the STANDARD method unless otherwise approved. Check CNIPS for your approved method.

12. Select Application for Verification Based on Method How to Qualify for an Alternate Sample Size: Two Ways 2. Improved Non-Response Rate An LEA with more than 20,000 children approved by application as eligible for free or reduced meals as of October 1 of the school year may use an alternate sample size when it’s non-response rate for the preceding year is at least ten percent below the non-response rate for the second preceding school year. 1. Lowered Non-Response Rate Any LEA may use an alternate sample size for any school year when its non-response rate for the preceding school year is less than 20%. You must have prior state approval annually via CNIPS to use an alternate sample size.

13. Methods of Verification Select Application for Verification Based on Method Methods of Verification Alternate Two The sample size equals the lesser of the sum of: 1,000 of all applications approved by the LEA as of October 1 of the current school year selected from error prone applications OR 1% of all applications approved by the LEA as of October 1 of the current school year, selected from error prone applications PLUS THE LESSER OF: 500 applications approved by the LEA as of October 1 of the current school year that provide a case number in lieu of income information OR ½ of 1% of applications approved by the LEA as of October 1 of the current school year that provides a case number in lieu of income information Alternate One Select the lesser of: 3,000 of all applications selected at random from applications approved by the LEA as of Oct. 1 of the current school year or 3% of all applications selected at random from applications approved by the LEA as of October 1 of the current school year

14. Let’s Take a Look at a Report

15. Did you get it right? 510 + 82= 592*.03= 17.76= 18

16. Verification for Cause Select Application for Verification Based on Method Verification for Cause LEA’s have an obligation to verify all questionable applications. Complete applications that indicate a student is eligible to receive free or reduced price benefits must be approved. Verification begins after the approval. To verify an application for cause, the LEA must send a letter informing the household that it must submit eligibility information for continued benefits. Any household that fails to submit information or if the information does not support the initial determination, the LEA must sent a notice of adverse action.

17. Post Selection Procedures Conduct Confirmation Reviews/Replacement Applications Post Selection Procedures Prior to contacting the household for verification, the LEA will: 1. Conduct a Confirmation Review An LEA official, other than the official which made the original determination, must review each application selected for verification to ensure that the initial determination is accurate. This official must SIGN and DATE the application after confirming. StatusLEA Action No Change in status, initial eligibility status was correct Verify application Status Change- Reduced to Free statusIncrease benefit level immediately, notify household of change, verify application Status Change- Free to Reduced statusDo not change status, verify application Status Change- Free/Reduced to Paid statusImmediately send household notice of adverse action, do not verify application, select a similar application (maybe error prone) and follow confirmation review procedures for new application Ensure you have a Confirmation Signature on all Applications selected for Verification. Suggestion- Sign in a Different color ink!

18. Replacing Applications Conduct Confirmation Reviews/Replacement Applications Replacing Applications After confirmation reviews, the LEA may replace up to 5% of applications selected. Applications must be replaced with another approved application selected on the same basis. Newly chosen applications must go through the confirmation review process. When 5% of LEA applications is less than 1, 1 application may be replaced. All result calculations should be rounded up to the next whole number. LEA’s may want to replace selected applications if it believes that the household would be unable to satisfactorily respond to the verification request.

19. Contact Household and Acceptable Documentation Notify Household for Verification Contact Household and Acceptable Documentation Written evidence: pay stubs, award letters from welfare department Written evidence must contain the name of the household member, amount received, frequency received, and date income was received. EBT cards cannot confirm eligibility in SNAP. Collateral Contact- can provide information regarding household income, but should only be requested when written evidence is insufficient. Agency Records: may be used when the LEA has legal access. Print each letter to households and attached to application. Ensure a date is on there! KEEP THAT DOCUMENT!

20. Now Verify the Information Conduct Verification Now Verify the Information At this point it is time to actually verify the information as submitted by the household to ensure that the LEA’s determination of the student’s status is accurate. Also, determine if a follow-up is needed with the household to gain more information. Acceptable documentation of income or receipt of assistance may be provided for any point in time between the month prior to the application and the time the household is required to provide income documentation.

21. No Income Reported Notify Household for Verification No Income Reported If a household indicates zero income, the LEA must request an explanation of how living expenses are met. (Eligibility Manual, pg. 75) The LEA may request additional written documentation or collateral contacts.

22. Follow-Up Contact Conduct Verification Follow-Up Contact The LEA must make at least one follow-up attempt to contact the household when the household does not adequately respond to the LEA’s request. Follow-up may be in writing or via telephone. LEA’s must ensure households are provided adequate language assistance and understand the need to respond to verification request. Always keep documentation. LEA’s must make a follow-up attempt when the household: does not respond, submits insufficient written evidence, does not designate collateral contacts and collateral contacts are unable or unwilling to provide requested evidence. Ensure that you have documentation of follow-ups. Who made the contact, when and what was the response. KEEP THAT DOCUMENT!

23. Verification Completion Determine Verification Results Verification Completion Demonstration of CompletionFollow-Up Action if Required The household submits adequate evidence of income or categorical eligibility. Verification is considered complete. The household submits adequate evidence of income which indicates that the child(ren) should receive a greater or lesser level of benefits. Verification is considered complete when the notice of adverse action is sent or the household is notified that its benefits will be increased or decreased. The household indicates that it no longer wishes to receive free or reduced priced items. Verification is considered complete when the notice of adverse action is complete. The application provides case numbers and it is determined that no household member is receiving benefits from an Assistance Program. Verification is considered complete when the notice of adverse action is sent.

24. Verification Result and Household Notification Determine Verification Results Verification Result and Household Notification The LEA must notify the household once the verification process is complete. A prototype is available on the SCN website. Ensure that you print the notification letter and ensure that the date is on it. KEEP THAT DOCUMENT!

25. A Change in Benefit Status? Determine Verification Results A Change in Benefit Status? Verification Result = Higher Benefits If verification results in higher benefits, the change is effective immediately and must be implemented no later than three operating days. Parents should be notified through whatever channels the LEA uses to notify the household of approval of benefits. Notice of Adverse Action All households for whom benefits are to be reduced or terminated must be given 10 calendar days’ written advance notice of the change. Print documentation from your POS if a benefit status change occurred. The date must show that you followed the proper timeframes. KEEP THAT DOCUMENT!

26. Appeal and Hearing Procedure Determine Verification Results Appeal and Hearing Procedure Appeals during the 10 calendar day notice period, the LEA must continue to provide benefits for which the child was originally approved until a final determination is made. Appeals after the 10 calendar day notice period, a reduction or termination of benefits must take place no later than 10 operating days after the 10 day calendar notice period or hearing official’s decision. Households affected by a reduction or termination of benefits may reapply for benefits at any time during the school year.

27. Direct Verification Direct Verification occurs when the SFA DOES NOT CONTACT THE HOUSEHOLD. Instead, the SFA uses a direct source to confirm eligibility for the benefit status. The SFA must use the Direct Verification and directly contact the assistance agency. Also, a student may show up on the DC list and that would be considered direct verification. A Direct Verification Form is available on the SCN website. FNS Verification Collection Report 20130923

28. Record Keeping Report Verification to SCN Record Keeping Documentation must be kept to demonstrate compliance with the verification requirements. The LEA must also be able to demonstrate compliance with the confirmation review requirements. For each application, the LEA must keep records of the source of information used to verify the application. For example: Copies of relevant correspondence between households and LEA can be documents submitted by household or reproductions of documents.

29. Record Keeping Report Verification to SCN Record Keeping LEA’s should also record any change in eligibility as a result of verification procedures, the reason for the change and the date the household was notified. Finally, LEA’s should also record: Any additional information necessary to show the effort made by the LEA to meet verification requirements Title and signature of the verifying official Criteria for replacing applications for verification LEA’s will be asked to provide this information for each school selected for an Administrative Review.

30. CNIPS Report Verification to SCN CNIPS All verification reporting to SCN with be conducted via CNIPS and the FNS 742 form. Training is available on this process.

31. Resources Available to You! FNS Verification Collection Report 20130923

32. In Conclusion For further information regarding verification refer to: Eligibility Manual for School Meals: Determining and Verifying Eligibility, August 2015.

33. SCN 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/complaint_filing_cust.html, or at 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. 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.