How to Conduct the Verification Process for

NSLPSY 15-16

Division of School and Community NutritionKentucky Department of Education

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.

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.

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)

Verification: What is it?

Verification is the confirmation of eligibility for free and reduced price meals under NSLP

and SBP.

Key Verification Dates

• October 1st- SFAs determine the total number of approved 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- FROM POS

• November 15th- SFAs must complete verification activities

A Look at the Verification Process

•Create your Sample Pool and determine verification method•Process information via CNIPSKnow Your Verification Method

•Standard, Alternate One or Alternate Two Method for Sample SizeSelect 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 necessaryDetermine Verification Results

•Report information in CNIPSReport Verification to SCN

Documentation: Let’s Get Started on the Worksheet

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 ApplicationWill 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.

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 1st from your POS.KEEP THAT DOCUMENT!

Select Application for Verification Based on Method

Methods of Verification

Standard 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.

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.

Select Application for Verification Based on Method

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

Let’s Take a Look at a Report

Did you get it right?

510 + 82= 592*.03= 17.76= 18

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.

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.

Status LEA ActionNo 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

Ensure you have a Confirmation Signature on all Applications selected for Verification. Suggestion- Sign in a Different color ink!

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.

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!

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.

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.

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!

Determine Verification Results

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.

Determine Verification ResultsVerification Result and Household Notification

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.”

• 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!

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!

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.

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

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.

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.

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.

Resources Available to You!

FNS Verification Collection Report 20130923

In Conclusion• For further information

regarding verification refer to:

Eligibility Manual for School Meals: Determining and Verifying

Eligibility, August 2015.

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.