Verification Reporting

FNS Verification Collection Report 20130923

Verification Reporting

FNS 742: School Food Authority (SFA) Verification Collection Report


Objectives• At the completion of this presentation you will be

able to:o Define verification and its purposeo State when there are exceptions to the requiremento Be able to correctly identify your sample pool and sample sizeo Use verification for cause when appropriateo Complete post selection procedureso Identify acceptable sources for verificationo Complete verification and follow proper record-keeping procedureso Complete an appeal and hearing process/procedure


Verification: What is it?

Guidance• National School Lunch Act,

Section 9• 7 CFR 245.6a “Verification

Requirements”• 7 CFR 210.15 “Reporting

and Recordkeeping”• Eligibility Manual for Schools

(August 2013)

What is it?• Verification is confirmation

of eligibility for free and reduced price meals under NSLP and SBP.


Exceptions:When is Verification Not

Required• Residential RCCI students• Schools participating only in

the Special Milk Program• Provision (includes CEO)

schools do not complete all verification requirements.

• Students who have been directly certified through the monthly electronic downloads for foster children, SNAP/KTAP and Medicaid recipients.

• Students appropriately documented by the district as eligible migrant, homeless or in a federally funded Head Start or Even Start Program.


Key Verification DatesDistrict Level State Level

• October 1st- SFAs determine the total number of applications on file for the current school year as of October 1

• October 31st- SFAs determine the total number of students enrolled for the current SY as of this date

• November 15th- SFAs complete verification activities

• February 1st- SFAs report verification results to the SA

• March 15th- SAs submit compiled SFA results to FNS

• March-June- FNS reviews data and follows up with SA


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 providedConduct 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 CNIPSReport Verification to SCN



Starting off: Determine Sample Pool

• LEA may begin verification activity once the application process is underway and approved applications are on file.

• LEA 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.

• The total number of applications on file as of October 1 of the current school year is your SAMPLE POOL.



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.


Select Application for Verification Based on Method

Methods of VerificationStandard VerificationSelect 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.



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.



Methods of VerificationAlternate 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

OR½ 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 OneSelect 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

or3% of all applications selected at random from applications approved by the LEA as of October 1 of the current school year



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.


Conduct Confirmation Reviews/Replacement Applications

Post Selection Procedures• Prior to contacting the household for verification, the LEA

will:o 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. Status LEA Action

No Change in status, initial eligibility status was correct

Verify application

Status Change- Reduced to Free status Increase benefit level immediately, notify household of change, verify application

Status Change- Free to Reduced status Do not change status, verify application

Status Change- Free/Reduced to Paid status Immediately 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


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.o Newly chosen applications must go through the confirmation review

process.• When 5% of LEA applications is less than 1, 1

application may be replaced. o 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.


Notify Household for Verification

It’s now time to notify the household

• The LEA is required to send a letter informing them of their selection for verification and the types of information acceptable to the LEA.

• Prototype is listed on the SCN website along with all required information.

WE MUST CHECK YOUR APPLICATION

You must send the information we need, or contact [name] by [date], or your child/children will stop getting free or reduced price meals. School: _______________________________________________________________ Date: ___________________________________________ Dear __________________________________________________________________: We are checking your Free and Reduced Price School Meals Application. Federal rules require that we do this to make sure only eligible children get free or reduced price meals. You must send us information to prove that [name(s) of child/children][is/are] eligible. If possible, send copies, not original papers. If you do send originals, they will be sent back to you only if you ask. 1. IF YOU WERE RECEIVING BENEFITS FROM [State SNAP], [State TANF] OR [FDPIR]WHEN YOU APPLIED FOR FREE OR REDUCED PRICE MEALS, OR AT ANY TIME SINCE THEN, SEND US A COPY OF ONE OF THESE:

[State SNAP] or [State TANF] or [FDPIR] Certification Notice that shows dates of certification. Letter from [State SNAP] or [State TANF] or [FDPIR] office that shows dates of certification. Do not send your EBT card.

2. IF YOU GET THIS LETTER FOR A HOMELESS, MIGRANT, OR RUNAWAY CHILD, PLEASE CONTACT [school, homeless liaison, or migrant coordinator] FOR HELP. 3. IF THE CHILD IS A FOSTER CHILD: Provide written documentation that verifies the child is the legal responsibility of the agency or court or provide the name and contact information for a person at the agency or court who can verify that the child is a foster child.

4. IF NO ONE IN YOUR HOUSEHOLD RECEIVES [State SNAP] or [State TANF] or [FDPIR] benefits: Send this page along with papers that show the amount of money your household gets from each source of income. The papers you send must show the name of the person who received the income, the date it was received, how much was received, and how often it was received. Send information to: [address]

Acceptable papers include:

JOBS: Paycheck stub or pay envelope that shows the amount and how often pay is received; letter from employer stating gross wages and how often you are paid; or, if you work for yourself, business or farming papers, such as ledger or tax books.

SOCIAL SECURITY, PENSIONS, OR RETIREMENT: Social Security retirement benefit letter, statement of benefits received, or pension award notice.



Acceptable Source Documentation• Written evidence: pay stubs, award letters from

welfare departmento 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. 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.



No Income Reported• If a household indicates zero income, the LEA

must request an explanation of how living expenses are met.

• The LEA may request additional written documentation or collateral contacts.


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.


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.



Verification CompletionDemonstration of Completion Follow-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.



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.

WE HAVE CHECKED YOUR APPLICATION

School: __________________________________________________________________ Date: _________________________________________ Dear _____________________________________________________________________: We checked the information you sent us to prove that [name(s) of child/children] are eligible for free or reduced price meals and have decided that: Your child/children’s eligibility has not changed. Starting [date], your child/children’s eligibility for meals will be changed from reduced price to free

because your income is within the free meal eligibility limits. Your child/children will receive meals at no cost.

Starting [date], your child/children’s eligibility for meals will be changed from free to reduced price because your income is over the limit. Reduced price meals cost [$] for lunch and [$] for breakfast.

Starting [date], your child/children is/are no longer eligible for free or reduced price meals for the following reason(s): _____ Records show that no one in your household received [State SNAP] or [State TANF] benefits. _____ Records show that the child/children is/are not homeless, runaway, or migrant _____ Your income is over the limit for free or reduced price meals _____ You did not provide ______________________________________________________________________________________ _____ You did not respond to our request

Meals cost [$] for lunch and [$] for breakfast. If your household income goes down or your household size goes up, you may apply again. If you were previously denied benefits because no one in the household received [State SNAP], [State TANF] or [FDPIR] benefits, you may reapply based on income eligibility. If you did not provide proof of current eligibility, you will be asked to do so if you reapply. If you disagree with this decision, you may discuss it with [name] at [phone]. You also have the right to a fair hearing. If you request a hearing by [date], your child/children will continue to receive free or reduced price meals until the decision of the hearing official is made. You may request a hearing by calling or writing to: [name], [address], [phone number], or [e-mail]. Sincerely, [signature]

Non-Discrimination Statement: This explains what to do if you believe you have been treated unfairly. “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, sex, age, or disability. To file a complaint of discrimination, write USDA, Director, Office of Adjudication, 1400 Independe nce Avenue, SW, Washington, D.C. 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.”



A Change in Benefit Status?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.

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.



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.


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:o Copies of relevant correspondence between households and LEA can

be documents submitted by household or reproductions of documents.



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:o Any additional information necessary to show the effort made by the

LEA to meet verification requirementso Title and signature of the verifying officialo Criteria for replacing applications for verification

LEA’s will be asked to provide this information for each school selected for an Administrative

Review.



CNIPS• All verification reporting to SCN with be

conducted via CNIPS and the FNS 742 form.• Training is available on this process.


In Conclusion• For further information

regarding verification refer to:

Eligibility Manual for School Meals:

Determining and Verifying Eligibility,

August 2013.


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 [email protected].

• 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.

Documents

Verification Reporting