Verification: The Process

Verification WebinarSeptember 2014

Karla WheelerSenior Compliance Specialist,

SN Services

USDA is an equal opportunity provider and employer.

Outline of the Presentation

What is Verification Definitions

Exceptions to Verification Requirements Important 2014-2015 Verification Dates Initial Verification

Establishing the Sample Pool Establishing the Sample Size

Verification for Cause General Verification for Cause for School District Employees

Application Selection Procedures Standard Alternate 1 Alternate 2 Completing the Sample Size

Outline of the Presentation

Qualifying to Use an Alternate Sample Size Lowered Non-Response Rate Improved Non-Response Rate Notification of Use of Alternative Sample Size

Post Selection Proceduresconfirmation reviews;outcome of confirmation replacing application

Household Notification of Selection Contacting the household

Sourced For Verification of Written Evidence Collateral Contacts Agency Records When a Household Indicates No Income

Outline of the Presentation

Continuing the Verification Process When is Verification Considered Complete Follow-Up

Notice of Adverse Action Benefits During an Appeal Hearing Procedure Households that Re-apply for Program Benefits Recordkeeping

Individual Applications Common Mis-Understandings The Online Verification Report

WHAT IS VERIFICATION?

What is Verification ?

VERIFICATION is the confirmation of eligibility for Free and

Reduced price meals under the NSLP and SBP.

For complete instructions refer to the Eligibility Manual for School Meals, September 2014 Chapter 9, pages 81-97.

•

Verification is only required when eligibility is determined through the application process, not through direct certification conducted with an Assistance Program or officials or agencies that documented Other Source Categorical Eligibility.

Verification Is….

include either confirmation of income eligibility or confirmation that the child or any member of the household is receiving assistance under FNS, FDPIR, or TANF or that a child is Other Source Categorically Eligible.

Verification Must…

Include confirmation of any other information on the application such as household size.

Verification May…

Verification Definitions

Direct VerificationError ProneRandom SamplingSample PoolSample Size

Verification Definitions

Direct Verification – is using records from public agencies to verify income and/or program participation.

(Part 10 of the Eligibility Manual for School Meals and the State Agency offers https://ncdcv.org )

Verification Definitions

Error Prone – means applications within $100 per month of the applicable Income Eligibility Guideline.

(Error prone replaces the old term “Focused Sample”)

Verification Definitions

Random Sampling– means each application has an equal chance of being selected.

(A statistically valid random sample is not required, the SFA must determine a selection interval by dividing the number of applications by the required sample size)

Verification Definitions

Sample Pool – means the total number of free and reduced applications approved as of October 1.

Verification Definitions

Sample Size – means the number of applications subject to verification; the minimum and maximum sample size is three (3) percent total.

Exceptions to Verification RequirementsFor children who have been certified under

direct certification, including children documented as eligible migrant, homeless, foster and children participating in the federally funded Head Start/Even Start

Children in an RCCI (except for applications for any non-residential students attending the RCCI)

FNS approved special cash assistance (not in NC)

Schools participating only in SMPProvisions 1, 2 and 3 or CEP schools except

in the base year in which applications are taken for students in attendance.

Important

2014-15

Dates

When does Verification Begin?

Each SFA must verify a sample that is selected from all approved free and reduced applications as of October 1 (unless October 1 falls on a weekend)in the current school year.

Verification Process Ends

Verification of the selected applications must be completed by November 15 ( unless this date falls on a weekend , then the process will end on the next working day , November 17, 2014 )

If the SFA knows in advance the deadline cannot be met, a request for an extension must be made to the SA. If the deadline passes without asking for an extension then a Corrective Action Plan will be required.

On Line Survey and Opening of Verification Report (SNTS)

Each SFA must report to the State Agency that verification activities have been completed via an online survey on the day after the process is complete. (November 18, 2014)

Tuesday, November 18,2014 is also the opening date of the online verification report in the School Nutrition Technology System (SNTS).

Online Verification Report Closes

December 19, 2014 the online Verification Report closes in the

School Nutrition Technology System.

Survey for the Verification Households that Reapply

Data must be collected from November 15, through February 15 (2014-2015 dates will be November 17 through February 16) for the households that did not respond to verification.

The data must be reported on a Survey to be distributed on line on February 17, 2015.

October 1 verification beginsNovember 17 verification ends November 18 (verification on line survey

report and verification report open in School Nutrition Technology System {SNTS})

December 19 (Deadline to submit the online verification report in the SNTS)

February 16 (collection of data {applications and students} for the non-response households that Reapplied or were Reapproved between November 17 and February 16)

February 17 online survey to report the above

Recap of Verification Dates 2014-15

Initial Verification

Process

Establishing the Sample Pool

The sample pool uses the total number of approved applications on file as of October 1 of the current school year. LEAs may choose not to count applications for students in split- session kindergarten programs participating in the SMP when determining the verification sample pool.

The sample pool depends on the number of applications (paper or electronic) and is not based on the number of children eligible for free and reduced priced meals.

Establishing the Sample Size

Once the sample pool is determined, the SFA calculates the

sample size—ALWAYS ROUND UP (example 2.02 would be

3 applications). At least one application must be verified.

With the exception of “verification for cause” the SFA MUST

VERIFY the EXACT NUMBER REQUIRED…NOT more than or

less than the standard sample size or the alternate sample size.

NEVER verify 100% of the applications!

Verification “for cause” is done in addition to the required

sample size. An SFA may do verification for cause at any

point in time during the school year (now reported)

What is verification for cause?

The SFA has an obligation to verify all questionable applications (verification for cause). This process cannot delay the approval of the application (if the application is complete), once the determination is made, the SFA may begin verification.

To verify an approved application for cause a letter must be sent to the household and this may be done at the same time the notification letter is sent.

If the household does not respond, an adverse letter must be sent.

Once the verification information is requested the verification process must be completed.

Reporting Verification for Cause

“Verification for cause” must be recorded on the Verification Report in the SNTS.

*Remember the number of applications recorded as verification for cause is NOT added to the number in the verification sample size.

Verification for Cause for School District Employees

Verification for cause must not be used to automatically verify the households of all school district employees whose children are certified for free or reduced price meals.

However the SFA may use SFA salary information available to them to identify questionable applications for school district employees.

USDA recommends consultation with the SFA’s legal counsel to address integrity concerns.

Verification Sample Sizes

Standard

Alternate One

Alternate Two

Informing the SFAs and SA

The State Agency (SA) will inform each SFA of the verification sample size (either standard or the choice to choose an alternate method). The SFA will then go to the online application and complete the SFA question #46 appropriately.

Standard Sample Size

Verify the lesser of:3% of all applications approved as of October

1 selected from error prone for the school year

or 3,000 error prone approved applications as of October 1 for the school year.

Once sample size is determined, error prone applications are the first selected ~ error prone are those with income within $100 monthly or $1200 annually

If not enough error prone applications on file, the remainder of the applications verified are selected randomly from all applications subject to verification (including income and case number).

Example #1 for Standard

199 approved free and reduced applications on file (excludes all DC, homeless, migrant, runaway, headstart and foster children)

3% of 199 would be 5.97 Number to verify = 6 50 applications make up the Error Prone

Sample because they fall within $100 of the monthly guidelines or $1200 annually

You would select 6 applications randomly from the 50 error prone applications.

135 approved free and reduced applications on file

3% of 135 would be 4.05 Number to verify = 5 3 applications make up the Error Prone

Sample because they fall within $100 of the monthly guidelines or $1200 annually

You would select all 3 error prone and randomly select 2 applications from the other 132 applications on file.

Example # 2 for Standard

Alternate One Sample

Verify the lesser of: 3,000 applications selected at random

from all the applications approved as of October 1 of the school year.

or 3% of all approved applications selected at random as of October 1 of the school year.

Once the sample size is determined, all applications are selected at random.

Example of Alternate One2001 approved free

and reduced applications on file

3% of 2001 would be 60.03

Number to verify = 61

Select all 61 applications randomly from the approved free and reduced applications.

3%

Alternate TwoVerify the lesser of the sum of:1000 of all applications approved as October 1

of the school year, selected from error prone applications

or 1% of all applications approved as of October 1 selected from error prone applications

PLUSThe lesser of 500 or .5% of all applications

approved as of October 1 that provided a case number in lieu of income information.

Example of Alternate Two

(Remember for the 1% it is of all approved applications which includes case numbers.)

2001 approved free and reduced applications on file (includes the case number apps)

1% of 2001 would be 20.01 Number to verify = 21 Select 21 applications from

the error prone applications unless the error prone applications are not enough to complete the sample and then select the rest randomly.

102 applications are approved using a case number.

.5% of 102 = .51Select 1 application

randomly from the approved case number applications.

Completing the Sample Size

If the sample size is based on error prone applications, and there is not enough applications to meet this criteria, the SFA must select applications at random from all approved applications including income and case numbers.

If the number of error prone applications exceed the amount required, then from the error prone applications the sample size would be selected randomly.

Qualifying to use an Alternate Sample Size

To be able to use the Alternate Sample Size the SFA must have:(1) Lowered non-response rate--a Non-

Response Rate from preceding SY of less than 20%. ( 10 apps 8 responded 20% non-response rate)

(2) 10% Improved non-response rate for SFAs with >20,000 children approved by application (excluding DC) by 10/1 in the second proceeding SY.Non-Response Rate from preceding year is less than

10% below the verification non-response rate for the second preceding SY (Example: 11-12, 180 households, 45 non-response 25 % must improve by 10% which is 2.5%; 12-13, 180 households, 40 non-response 22.2%, now 25%-2.5%=22.5% since 22.2% is less than 22.5% then the SFA may use an alternate method in 13-14.

QUALIFYING for an alternate sample size is on an annual basis.

Post Selection ProceduresPrior to contacting the households the SFA must do these two procedures:

#1 Required Confirmation Reviews (no waivers allowed in NC)

# 2 Optional Replacement of certain applications

* It is optional to conduct DV

Required Confirmation Reviews

Prior to verification of any selected applicationa person (known as the confirming official) otherthan the determining official of the applicationmust confirm that the eligibility status ofapplication selected for verification wasapproved correctly.

This person must initial or sign the selectedapplication(s) prior to the SFA mailing the

selection letter to the household(s).

Outcome of Confirmation Reviews

If the application was confirmed to be correct

proceed with the verification process.

If the application changes from Reduced Price to Free:

* increase the benefits immediately

*notify the household of the change

*verify the application

And Next….

Status change Free to Reduced* Do not change the child’s status* Verify the application

Status change Free or Reduced to Paid* Immediately send an adverse action

letter* Do not verify the application* Select a similar application

(error prone, select another error prone)

* Follow the same confirmation review process

Replacing Applications

Upon the confirmation review, the SFA may on a case by case basis replace up to 5% of the applications selected. (Example 60 applications approved, replace up to 5%= 3)

Again replace applications with like applications and the confirmation process must take place on the replaced application.

Rounding may be used in the SFAs where the total of 5% is less than one. One application may be replaced.

Household Notification of Selection

The SFA must send a letter informing the household of selection and of the types of information acceptable to the SFA.

(Retain a copy of these letters in the verification file)

Requirements of the Selection Letter

The letter must include the following:

That the household was selected for verification;

Use of Information Statement (Please note that the Social Security Number (SSN) for all household members is no longer required for verification.);

The types of acceptable information that may be provided to confirm current income, including pay stubs, award letters from assistance agencies for benefits such as social security or supplemental security income, and support payment decrees from courts;

More Requirements of the Selection Letter

That the household may provide proof that a child or any household member is receiving benefits under the Assistance Programs instead of providing income information or that a child is Other Source Categorically Eligible; that documentation of income or receipt of assistance may be provided for any point in time between the month prior to application and the time the household is required to provide income documentation;

That information must be provided by a date as specified by the SFA and that failure to do so will result in termination of benefits;

Name of an SFA official who can answer questions and provide assistance; and

A no-cost to the household telephone number.

If the SFA is using the DV system to verify eligibility, then a letter of notification is not necessary.

Using Direct Verification(DV)

Written Evidence

Primary Source of Verification (most often pay stubs, award letters from welfare departments or governmental agencies

Written evidence must have: Name of Household Member Amount of Income received Frequency Date Received

Acceptable written documentation for Assistance Programs and Other Source Categorical is an official letter.

Collateral ContactsPerson outside of the household who

is knowledgeable about the household’s circumstances.

Should only be contacted if the household does not provide adequate written evidence.

Household must be notified before contact is made with the collateral contact.

Collateral contact may be written or oral, must be documented, dated and initialed.

If Collateral contact is unwilling, then the SFA must contact the household to complete the verification process.

Agency RecordsA household’s eligibility may be confirmed

through the use of information maintained by other government agencies to which the State agency, SFA, or school has legal access.

Such records are State records, and the release of information maintained by State employment offices is governed by State law.

Acceptable timeframeAcceptable

documentation of income or receipt of assistance from any of the above sources may be provided for any point in time between the month prior to application and the time the household is required to provide income documentation.

When a household indicates no income

If a household is selected for regular verification or verification for cause and the application indicates zero income, the SFA must request an explanation of how living expenses are met and may request additional written documentation or collateral contacts.

Continuing the verification process

To continue the verification process subsequent to household notification, the LEA must either determine:

If the household has submitted adequate information to complete its individual verification activity; or If follow-up with the household is

needed.

When is Verification considered complete?

The household submits either adequate written evidence or collateral contact confirms income or categorical eligibility: Verification is considered complete for this household;

When is Verification considered complete?

The household submits either adequate written evidence or collateral contact confirms of income which indicates that the child(ren) should receive either a greater or lesser level of benefits and the notice of adverse action is sent or household is notified that its benefits will be increased or decreased; Verification is considered complete;

When is Verification considered complete?

The Household indicates, verbally or in writing, that it no longer wishes to received free or reduced price benefits and the notice of adverse action is sent: Verification is considered complete;

When is Verification considered complete?

The application provides case numbers and it is determined that no household member is receiving benefits from an Assistance Program and the notice of adverse action is sent:

Verification is considered complete for this household;

Effective Time of the Change

HIGHER BENEFITS (status is moved from reduced to free, paid/denied to free, paid/denied to reduced)Immediately and implemented no later than 3

operating days and household is notified.

LOWER BENEFITS (status from free to reduced or paid/denied, or reduced to paid/denied), 10 calendar day adverse action notice (may be sent via postal service or email address of a parent/guardian…NOT by phone).

Follow Up Required

The SFA must make at least one follow up attempt to contact the household that does not adequately respond to the verification request.

Helpful Hints: Documentation for the second attempt must

be maintained (written or oral)

The SFA may deem it necessary to make additional attempts to lower the non-response rate)

Follow Up

The SFA must make a follow-up attempt when the household:

Does not respond to the request for

verification;

Submits insufficient or obsolete written

evidence; Does not designate collateral contacts; and

Collateral contacts are unable or unwilling to

provide the requested evidence

If after at least one Follow Up Attempt

The household responds and provides all needed evidence, verification is considered complete for this household:

* If there is no change in benefits;

* When household is notified that its benefits

will be increased;

* When notice of adverse action is sent.

The household does not respond, verification is considered complete for this household:

* When notice of adverse action is sent.

The SFA is unable to continue its verification activities because the household fails to provide adequate written evidence or knowledgeable collateral contacts, verification is considered complete for this household:

* When the notice of adverse action is sent.

Benefits During the Appeal

When the household appeals within the 10 calendar day advance

notice period, the benefits must continue

until a final determination is made.

Notice of Adverse Action The first day of the advance notice period is the day the notice

is sent. The notice must advise the household of the following:

Change in benefits;

Reasons for the change;

That an appeal must be filed within the 10 calendar days

advance notice period to ensure continued benefits

while waiting a hearing and decision;

Instructions on how to appeal;

That the household may reapply for benefits at any time

during the school year; and

Households that were terminated because no member was receiving benefits from an Assistance Program may

submit an application containing household names and

income information and provide written evidence of

current household income.

Benefits During an AppealAppeals during the 10 day calendar notice, SFA continues the benefits originally approved until a final determination is made.

After the decision is made and it is to reduce the benefits the household receives 10 operating days after the final decision.

Hearing Procedure

REMEMBER ~ The Hearing Official must be an individual who was not connected with the approval or verification process.

Households that Reapply for Program Benefits

Households with a reduction or termination in benefits may reapply during the school year. If the benefits were terminated, and the household reapplies during the same school year, the household is required to submit current income documentation or proof of participation in FNS, TANF or FDPIR at the time of reapplication.

(NOTICE: These are not considered new applications…but the original application not verified by November 15 is null. Current income documentation must be submitted with the re-application process. )

Verification Process RecordkeepingThe SFA should maintain:

* The Approved Verification Selection Method

* The Verification Sample Pool (October 1)* The Verification Sample Size (# of

applications)* Documentation of Replaced files (if

applicable, not to exceed 5%)

* The Confirmation signatures on the applications

(copies of the applications are preferred)* The Selection Letters* The Second attempt (whether written or

verbal)* The Verification Results letter.* The On line Verification Report

Individual ApplicationsFor each application verified the SFA must retain

either: Copies of all relevant correspondence between the

households selected for verification and the SFA;

* One of the following for all documentation used to verify eligibility:

All documents submitted by the household or reproductions of those documents;

or In cases where the actual documents or photocopies cannot be kept, the verifying official must make a written record of the documents submitted by the household including the type of document, e.g., wage stubs or a letter from an employer, income shown on the document, time period of the income, and the date of the document and any changes in eligibility as a result of verification procedures, the reasons for the changes, and the date the change was made.

Individual Applications Recordkeeping

• Any change in eligibility as a result of verification procedures, the reason for the change and the date the household was notified, if necessary, and the date it became effective; and

• If applicable, Records of follow-up attempts and results. LEAs should also record:

• Any additional information necessary to show the efforts made by the LEA to meet the verification requirements;

• Title and signature of the verifying official; and

• Criteria for replacing applications for verification. .

Extended Benefits

Refer to USDA Policy Memo SP25-2010, Questions and Answers on Extending Categorical Eligibility to Additional Children in a Household, questions 24 and 25.

Remember that extending benefits has to be documented by the SFA.

CommonMisunderstandings

Common Misunderstandings

The verification process did not begin on October 1 (unless it falls on the weekend).

The verification process did not end by November 15 (unless it falls on the weekend).

Common Misunderstandings

SFA uses the incorrect verification method as determined by the State Agency.

SFA does not understand the Sample size, or finds that the verification software language is not consistent with USDA and the incorrect method is selected.

The software did not select the correct number of applications for the sample size. (The system did not round up)…or the manual mathematical calculation was incorrect.

It is the responsibility of the SFA authority to ensure that verification software is compliant.

Common Misunderstandings

Common MisunderstandingsThe sample size was not round up therefore there are not enough applications verified…remember USDA requires that the exact number selected be verified…not more, not less!

Common Misunderstandings

It is a requirement that all applications selected for verification be confirmed as correct before sending letters to the selected households.

Most verification fiscal action errors found would not have happened if truly confirmation had taken place.

The confirmation process did not take place and errors were on the applications pulled for verification.

An application was pulled for DC student.

If you have an application for a DC student, please place the application in an inactive file.

DC students are exempt from verification.

COMMON MISUNDERSTANDINGS

Common Misunderstandings

Only one attempt made to collect the verification information.

Documentation was not maintained for the second attempt.

A student withdraws during the verification process the process cannot be completed and another similar application should be selected in its place.

Common MisunderstandingsHouseholds that reapply must provide

another application with current income or proof of FNS. This is for all households that were denied or were selected for verification but did not respond by the November 15 deadline.

Common Misunderstandings

Proper and accurate record keeping is not available, i.e. selection Letters are not in the verification file. These letters must be present in the files with the actual date it was sent to the parent/guardian.

THE ONLINE VERIFICATION REPORT

Verification Summary Report: General Information

Verification Summary Report: Instructions and Section I. Total Schools, RCCIs and Enrolled Students

Verification Summary Report: Section 2. SFAs with Schools Operating

Alternate Provisions

Verification Summary Report: Section 3 Students approved as FREE eligible

NOT subject to verification

Verification Summary Report: Section 4 Students approved as fREE or

REDUCED PRICE eligible through a household application

Verification Summary Report: Section 5

Verification Summary Report: Section 5

Verification Summary Report: Document Attachments (only upon State

Agency Request)

Thank you for attending the Verification Webinar.

Please Email all Questions to:

karla.wheeler@dpi.nc.govor call

919-807-3518

(Remember your consultant should be the first line of contact)

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 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.