NSLP/SNAP - Direct Certification and State Performance: The new process, data requirements, and responsibilities beginning School Year 2013-2014WEBINAR – TUESDAY, AUGUST 20, 2013 – 2:00-3:30 PM

PATRICIA B. VON REYN – SENIOR MANAGEMENT ANALYSTUSDA/F NS /SPE C IAL NUTR IT ION PROGRAMS/CH ILD NUTR IT I ON D I V IS ION

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What isDirect Certification with SNAP?Children l iving in households receiving assistance under the Special Nutrition Assistance Program (SNAP) must be directly certified to receive free school meals under the National School Lunch Program (NSLP) and/or School Breakfast Program (SBP).

Match Results

Source Data

Match Process

Use Match

Results to

directly

certify at

local level

School Enrollment Data

3

How is Direct Certification with SNAP Conducted?

SNAP DC

SNAP Participation Data

Some Different Ways States Match with SNAP

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SA/Central Level

SFA/LEA/Local Level

DC

A

DC

B

DC

C

DC

D

5

Goals of Direct Certification

Improve access for low-income childrenReduce paperwork for households and program administratorsImprove integrity of the free and reduced-price meal certification process

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History of Direct Certification with SNAP

2004

All NSLP LEAs must perform direct certification with SNAP by SY 2008-09

(May conduct direct certification with other programs, but are not required to do so)

P.L. 108-265Child Nutrition and WIC

Reauthorization Act of 2004

2008Assess effectiveness of direct certification and

publish results in Report to Congress(starting with SY 2007-2008)

P.L. 110-246Food Conservation, and

Energy Act of 2008 (2008 Farm Bill)

2010Performance benchmarks are set at 95%

for SY 2013-2014 and beyond(lower benchmarks for the two previous school years)

SNAP Letter Method no longer DC (phased out by regulation by SY 2012-2013)

P.L. 111-296Healthy, Hunger-Free Kids Act of

2010

2013 New formula and ways to collect/report data elements to compute State direct certification performance rates with SNAP

Final RuleNSLP: Direct Certification

Continuous Improvement Plans Required by the Healthy,

Hunger-Free Kids Act of 2010

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SY 2013-2014 and beyond – 95%

Benchmarks - Direct Certification with SNAP

Second year - SY 2012-2013 - 90% First year – SY 2011-2012 – 80%

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Will my State be at 95%?

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This Webinar describes the New Methodology for Assessing Performance, which:

• Is straightforward• Promotes transparency• Is more accurate• Provides States with tools to measure their own

performance in a timely manner

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Direct Certification with SNAPand a Formula Approach to Improvement

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Understand how the pieces of the puzzle fit together

Formula• Data Element #1• Data Element #

2• Data Element #

3

(2008 Farm Bill)

12

Direct Certificati

on Performan

ce Rate

#1 # 3

# 2

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DATA ELEMENT #1

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DATA ELEMENT .

The # of children living in households receiving SNAP benefits who are directly certified for free

school meals as of the last operating day in October

#1#1

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DATA ELEMENT . Who collects it?

The School Food Authority tracks, records, and reports the number of SNAP Direct

Certifications that occur by the last operating day in October

#1#1

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SNAP DC SNAP DC

TANF FDPIR

Other

on old FNS-742, line 4-1to State agency by

March 1st to FNS by April 15th

on revised FNS-742, line 3-2to State agency by February 1st

to FNS by March 15th

#1 DATA ELEMENT . Reporting

#1

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Need to be able to separate out SNAP DC for Section 3 of the FNS-742 – Free, not subject to verification

SNAP DC

TANF OtherFDPIR

TANF

Other

FDPIR

SNAP DC

SNAP Letter Method is no longer Direct

CertificationNon-SNAP Direct

CertificationSNAP Direct Certification

Head

Sta

rt,

etcFoste

r

Runa

way

Migr

ant

Hom

eless

Line 3-2 Line 3-3 Line 3-4

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The count on Line 3-2 of the FNS-742

is Data Element #1

TANF

Other

FDPIR

SNAP DC

#1

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SNAP DC

“Grow” DATA ELEMENT #1#1

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How to GrowDATA ELEMENT #1

Certifications Based On:• Matching SNAP database to Student-Enrollment Database• Adjudication of the unmatched or partial SNAP match list• SNAP-combo matches, SNAP trumps!• Extended SNAP-DC Eligibility• Converting to SNAP DC by the last operating day in October

SNAP DC

#1

Know what is considered to be a SNAP Direct

Certification

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How to GrowDATA ELEMENT #1

• Perform a State Self-Assessment

SNAP DC

#1

Improve the System

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How to GrowDATA ELEMENT #1

• Perform a State Self-Assessment• Determine where your State’s strengths and weaknesses lie

• Work with counterparts to develop a plan of action

• Look to FNS grants for financial support

SNAP DC

#1

Improve the System

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How to GrowDATA ELEMENT #1

• Match more frequently if possible – if only 3x/yr, make sure 2nd is before the last operating day in October

• Make sure the SFA can capture (code), retain, and select for the method for the direct certification so the FNS-742 counts will be accurate

• Monitor the progress step-by-step

SNAP DC

#1

Key tasks for this year

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Expectation is that line 3-2 of the FNS-742 will be only SNAP DCs, even this first year, SY 2013-2014.

Separate SNAP from non-SNAP: • Work with SNAP State agency to be sure SNAP matches carry some kind of coding

designating “SNAP” so the local level will know the source of the match when they directly certify a child for free school meals.

• Work with IT at all levels to be sure that the coding is retained at the local level so the SFA can retrieve the direct certifications based on SNAP for the FNS-742.

• Work in retrospect, if needed – see Q-and-As, SP 54-2013.

• If by February 1, 2014, the NSLP State agency is not able to affirm that line 3-2 is only SNAP DCs, SA must inform FNS of the inaccuracy of the data.

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DATA ELEMENT #2

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Data Element #2 The # of school-aged children in SNAP households during the months of July, August, and September

The “School-aged SNAP UNIVERSE”

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USDA uses ages 5-17 years old for “school aged” in the count for Data Element #2

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States are to use as broad an age range for the match as will include ALL students in their NSLP schools

But, even thoughUSDA uses ages 5-17 years old for “school aged”

in the count for Data Element #2

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SNAP Administrative data (for July, Aug, Sept average monthly SNAP participation data)

SNAP QC data and Admin data (to narrow down the age range)

SIPP data (to help remove duplicates)

Actual counts from the SNAP State

agency

How and by whom would this count be determined?

Estimate by FNS using a variety of

data sourcesSNAP State agency queries the SNAP database to get the actual, unduplicated count of children age 5-17 at any time during the months of July, Aug, Sept.

#2

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FNS-834SNAP State agency sends to FNS

and the NSLP State agency by

Published in the REPORT TO CONGRESS

How and when would NSLP State agencies find out?

#2

Fall of the next school year

Dec 1st of the same school year

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• Look at the SNAP rolls for the months of: July, August, and September

beginning with July-August-September of 2013

On SNAP at any time during these three months?

#2SNAP State Agency Responsibilities for Data Element #2

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SNAP State Agency Responsibilities for Data Element #2

•Count all children on the SNAP rolls during these same three months who were ages 5-17 at any time during these months.

• Use the prescribed birth date range for the query

#2

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SNAP State Agency – Prescribed Birth Date Rangeto Query for 5-17 year olds

for Data Element #2

School Year

First part of SY (from which to subtract

the 18 or 5)

Children on SNAP at anytime during:

Beginning Birth Date

Ending Birth Date

Birth Date Range for SNAP State Agency’s Queryfor Children Ages 5-17

Date FNS-834

due

*FP = Calendar year when the school year begins

Any SYorJuly, Aug,

Sept of that school year

“FP” * July 1, (“FP” -18)

30, Sept.(“FP” -5)

Children born July 1, (“FP”-18)through Sept. 30, (“FP”-5)

Dec. 1, “FP”

2013July, Aug, or Sept 2013

SY 2013-2014.

Sept. 30, (2013 -5)

So, Sept. 30,

2008

July 1, (2013 -18)

so, July 1, 1995

Children born July 1, 1995through Sept. 30, 2008

Dec. 1, 2013

Beginning Birth Date

Ending Birth Date

#2

EXAMPLE

RULE

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SNAP State Agency Responsibilities for Data Element #2• Ensure that the counts are unduplicated

• Whether a child is on SNAP for all 3 months, or for only 1 day during that 3-month period, count the child only once.

#2

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SNAP State Agency Responsibilities for Data Element #2

After getting the unduplicated count of children who are on SNAP at any time during July, August, or September 2013, and who were born

July 1, 1995 through September 30, 2008

Report the count for the entire State on the new form FNS-834 by December 1, 2013.

#2

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SNAP State Agency – Data Element #2

Fill Out

Optional

#2

OPTIONAL

Specific examples for setting the query are included in the

Q-and-As: SP 54-2013, dated August 16, 2013.

Fill Out

For the December 2013 submission, this form will be emailed in to

CNStatesytems@fns.usda.gov, but in future years, after it is incorporated

into FPRS, much of this section will be pre-populated.

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SNAP State Agency’s Submittal of the FNS-834

• THIS YEAR email to CNStatesystems@fns.usda.gov by Dec 1, 2013.

• FPRS in 2014?

By December 1st each year

to FN

S to NSLP SA

• Provide to the NSLP State agency in a manner agreed upon by both the NSLP State agency and the SNAP State agency each year, starting Dec 1, 2013.

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SNAP DC

#1

#3

#2“THE UNIVERSE”

#2

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So, how do you “Shrink” DATA ELEMENT #2?

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How to ShrinkDATA ELEMENT #2

The NSLP State agency does not have much control over this, but it can:• Ensure the Accuracy of the Count

• Review the count from the SNAP State agency after they send it over to you by December 1st on the FNS-834

• Work with the SNAP State agency if the count does not seem reasonable

• Develop a way to quantify the actual number of SNAP children not in NSLP schools

#2

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DATA ELEMENT #3

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Data Element #3 The # of children in SNAP households

attending special provision schools operating in a non-base year

The “SPECIAL PROVISION” Adjustment

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SNAP DC

#1

“THE UNIVERSE”

#2

#3

ON LINE 3-2

NOT ON LINE 3-2

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Line 4-4 of the old FNS-742 (to get the # free eligibles).

Adjusted (applying generalized adjustment factors to approximate the narrower SNAP subset).

Limitations - particularly when the number of SNAP-participant children had changed from the most-recent base year or as schools moved in or out of non-base year status.

Actual counts from the NSLP State

agency

How and by whom would this count be determined?

Estimate by FNS using a variety of

data sourcesNSLP State agency ensures that a “Special Provision Match” with SNAP is run for each special provision school operating in a non-base year.

NSLP State agency totals the unduplicated count of matches and reports on the FNS-834 by December 1st .

#3

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Dec 1st of the same school year

Fall of the next school year

How and when would NSLP State agencies find out? #3

Published in the REPORT TO CONGRESS

NSLP State agency ensures that the match is run (or is

running the match itself), so it would know earlier than when the report is due, namely by:

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DATA ELEMENT . NSLP State Agency Responsibilities

The NSLP State agency ensures that a “Special Provision Match” with SNAP is run with special provision schools not operating in a base year, totals the number of matches, and reports the total on the FNS-834.

#3 #3

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DATA ELEMENT . About the “Special Provision Match” with SNAP:

• Timing – it is to be run in or near October—but no later than the last operating day in October

• Pertains to which schools - all special provision schools not operating in a base year

• What to count – all matches made using the “Special Provision Match”

• Alternative phase-in procedures - allowed only for SY 2013-2014

• Certain Community Eligibility data options available each year

#3 #3

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DATA ELEMENT . With which schools must the match be run?

• Provision 2/3 schools when operating in non-base year.• Community Eligibility schools, each year they operate

under community eligibility.• Other schools operating in a non-base year under the

special provisions of 7 CFR 245.9–that is, those schools that would not be reporting SNAP-DCs on line 3-2 of the FNS-742.

#3 #3

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DATA ELEMENT . Must the State itself run the match?

Regardless of the method of matching (central or local or combo) for the regular SNAP matched:• The NSLP State agency may run the “Special Provision Match” with

SNAP; or

• The SFAs may run the “Special Provision Match” with SNAP and report the counts to the NSLP State agency; or

• States may decide to use a combination of approaches.

NOTE: States with no special provision schools (or with only those operating in a base year) need not run a “Special Provision Match.” Simply report “0” on the FNS-834.

#3 #3

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DATA ELEMENT . What does it mean to

“Count all the matches” found in the “Special Provision Match”?

#3 #3

Use Match

Results to

directly

certify at

local level

SNAP DC

Match Results

School Enrollment Data

SNAP Participation Data

To FNS-742 for Data Element #1

Not for Data Element #3

Use for Data

Element #3

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DATA ELEMENT . What are the Alternative Phase-in

Procedures for SY 2013-2014?

• For SY 2013-2014 only, the NSLP State agency may allow the use of the “Base Year Percentage Option” for any school for which the match cannot be run.

#3 #3

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School

Base Year# Directly Certified as FREE

Base YearTotal #

certified as FREE

Percentage Factor

SY 2013-2014 # reported as

FREE

Apply Percentage

Factor Total

0

129

9, 475

DATA ELEMENT . “Base Year Percentage Option”

For SY 2013-2014 only . . .

#3 #3

A 102 271 102271

343102271343 x

C Did not conduct direct certification in base year, or no access to data

“Special Provision Match”

Total count from the 10 non-base-year special provision schools where the “Special Provision Match” was able to be performed

TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834 9, 642

38B 32 57 32 57

6810227168 x

0

129

9, 475

38

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DATA ELEMENT . Community Eligibility Data Options

• OPTION 1 - “SPECIAL PROVISION MATCH” – the same match done with other special provision schools

• OPTION 2 - CLAIMING PERCENTAGE COUNT- Use the count of identified students matched with SNAP used in determining the claiming percentage for that school year

• OPTION 3 - CALENDAR YEAR APRIL COUNT – Use the count of the identified students matched with SNAP conducted by the April 1st preceding the school year, whether or not the school elected to update its claiming percentages

#3 #3

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Community Eligibility Data Options - Example

Scenario The school year is SY 2015-2016. The first year of the claiming cycle was SY 2012-2013. The school ran a match with SNAP by April 1, 2015, but elected not to update its claiming percentages for SY 2015-2016.

Data Options• OPTION 1 – Conduct and use the

results of an “October” 2015 “SPECIAL PROVISION MATCH”

• OPTION 2 – CLAIMING PERCENTAGE COUNT - Use the count of SNAP matches from the “April” 2012 match

• OPTION 3 – CALENDAR YEAR APRIL COUNT – Use the count of SNAP matches from the “April” 2015 match

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Example from future, SY 2015-2016Can only use “Special Provision Match” or CE Data Options,

since Alternative Phase-in Procedures are not available after SY 2013-2014 Total

12,321

DATA ELEMENT . Example of Totals with Community Eligibility Data Options

#3 #3

“Special Provision Match”

Total count from all SNAP matches from the “Special Provision Match” performed “in/near October 2015,” including many Community Eligibility schools

TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834 12, 974

CE 2Total count from those Community Eligibility schools electing CE DATA OPTION 2

choosing to use the actual count from the identified students matched with SNAP by the April 1st used to establish the SY 2015-2016 claiming percentages

CE 3 Total count from those Community Eligibility schools electing CE DATA OPTION 3 choosing to use the actual count from the identified students matched with SNAP by April 1st, 2015

n/a If not in the “Special Provision Match” and not using a “Community Eligibility Data Option,” cannot count any students for Data Element #3 . Enter “0.”

416

237

0

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NSLP State Agency – Data Element #3

Fill Out

Optional

#3

OPTIONAL

Much guidance on the “Special Provision Match”

is included in the Q-and-As: SP 54-2013, dated August 16, 2013.

Fill Out

For the December 2013 submission, this form will be emailed in to

CNStatesytems@fns.usda.gov, but in future years, after it is incorporated

into FPRS, much of this section will be pre-populated.

57

NSLP State Agency’s Submittal of the FNS-834

• THIS YEAR email to CNStatesystems@fns.usda.gov by Dec 1, 2013.

• FPRS in 2014?

By December 1st each year

to

FNS

58

SNAP DC

#1

“THE UNIVERSE”

#2or

SPECIAL PROVISION

ADJUSTMENT

#3

SPECIAL PROVISION

ADJUSTMENT

#3

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How to GrowDATA ELEMENT #3

• Know the special provision schools in your State• Keep track of when they are operating in a non-base year• Find out which schools already have their students in a statewide

student enrollment database• Determine which SFAs/schools are not geared up for the match this year• Develop relationships with these schools for this match to be successful• Work to remove obstacles that would keep schools from being included

Reach all special provision schools

#3

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How to GrowDATA ELEMENT #3

• Design a business practice for the Special Provision Match in your State

• Be flexible – run the match at the State level or run the match at the local level or use some combination of the two; maybe upload student enrollment info via Excel or even run the match for a school

• Run the match in or close to October, if possible, but no later than the last operating day in October to maximize the number of matches

• Automate as much as possible

Match well, even this first year

#3

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Direct Certificati

on Performan

ce Rate

SNAP DC

#1

SFA on LINE 3-2 of FNS-742

SNAP State agency on FNS-834

SPECIAL PROVISION

ADJUSTMENT

#3

NSLP State agency on FNS-834

“THE UNIVERSE”

#2

62

DATA ELEMENTSData Element

WHAT IS IT?

WHO REPORTS

?

HOW REPORT

WHEN REPORT

#1# SNAP CHILDREN

DIRECTLY CERTIFIED FOR

FREE SCHOOL MEALS

SFA FNS-742 Feb 1(Mar 15)

#2# SCHOOL-AGED

SNAP CHILDREN IN THE STATE IN

JULY, AUG, SEPT

SNAP STATE

AGENCYFNS-834 Dec 1

#3#SNAP CHILDREN

IN NON-BASE YEAR SPECIAL

PROVISION SCHOOLS

NSLP STATE

AGENCYFNS-834 Dec 1

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What can the NSLP State Agency Do to Monitor its Rate? • DATA ELEMENT #1 - Watch the 742 data as it is coming in from the SFAs, be sure

that all schools are reporting, compare this year’s data to last year’s data. If it is very different, is there a reason for that? Be sure that the SFA has reported in line 3-2 SNAP direct certifications ONLY .

• DATA ELEMENT #2 – Be in contact with the SNAP State agency to determine the best way to receive the FNS-834 data. Check the count to see if it is reasonable for your State. How does it compare to the lists that you have been receiving? The count should be an unduplicated count, so if a child is on SNAP for July, August AND September, the child should still be listed only once.

• DATA ELEMENT #3 – Do you have data in from each special provision school? Is it properly combined for you to report for the FNS-834?

• FORMULA - Plug the data into the formula as you get it. Is your rate what you expect? If it has dropped significantly, check to be sure there are no errors in the individual data elements.

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What can the SFAs do to increase the rate?• Know what constitutes a SNAP Direct Certification• Make sure the POS system properly records the type of certification and

can select/sort/count by type• Keep school enrollment data as current and up-to-date as possible• Check new students as they enroll• Send SNAP DC status to transferring student’s school• Adjudicate the non-matches—try to find every child• Go back and code a student as a SNAP DC if the student shows up on the

SNAP DC list, even if the student has already been certified in another way, so long as it is done before the last operating day in October

• Get/arrange for additional assistance during heavy certification times, if possible

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What can the SFAs do to increase the rate?

• Get proper training, ask questions if anything is not well understood, train back-ups for your role in the process

• Look to see where the automated systems could be revised to make things easier for you—if you are doing a series of steps over and over, they could probably easily be automated

• Understand the policies and rules governing direct certification• Match frequently –if only running 3 matches, make sure the 2nd one is before the last operating day in October

• Properly complete the FNS-742, Verification Collection Report• Check your submission last year to see if it is close to this year’s—if it is not close, is the difference warranted? If not, search for errors

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Direct Certification Improvement Grants OpportunitiesThe RFA was extended in July to provide 4 more grant

opportunities:

OCTOBER 1, 2013JANUARY 2, 2014APRIL 1, 2014JULY 1, 2014MAXIMUM

AWARD SCOPE APPLICATION PROCESS

TIER 1 $150,000 Limited scope Simplified

TIER 2 $ 1 million Full scope – for major initiatives Usual

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Helpful Resources• Final Rule, National School Lunch Program: Direct Certification Continuous Improvement

Plans required by the Healthy, Hunger-Free Kids Act of 2010 (February 22, 2013)

• CIP Development Guide, with State Self-Assessment Tool (December 2012 and March 2013)

• SP 50-2013, Release of the new State Agency (NSLP/SNAP) Direct Certification Rate Data Element Report (Form FNS-834) (July 1, 2013)

• Q-and-As - Direct Certification Process – SP 54-2013 (August 16, 2013)

• SP 38-2013, Release of the new School Food Authority (SFA) Verification Collection Report (April 29. 2013)

• Webinars: • CIP Webinar (January 2013)

• FNS-742 Webinar (July 2013)

• New Direct Certification Process Webinar (August 20, 2013)

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QUESTIONS?