WHO’S ELIGIBLE FOR WHAT: THE FREE AND REDUCED PRICE PROCESS.

WHO’S ELIGIBLE FOR WHAT: THE FREE AND REDUCED PRICE PROCESS

Administrative Review (AR):Critical Areas of Review

Certification and benefit issuance

Accuracy of meal counting and claiming

Whether meals claimed for reimbursement meet meal pattern and nutritional quality requirements

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Performance Standard 1 Performance Standard 2

Administrative Review (AR):Off-site Review Procedures

To prepare for the review, your reviewer will examine:

SFA Agreement Free and reduced price policy statement Renewal applications Claims for reimbursement Other miscellaneous reports (e.g. Verification

Collection Report) Review findings from prior years, corrective

action plans, and documented corrective action Other audits

Administrative Review (AR):On-site Review Procedures

To ensure program compliance, includes an examination of:

Free and reduced price certification and benefit issuance process

The meal service General areas

Free and Reduced Price Process:Off-Site Review Procedures

Questions to address SFA’s procedures regarding: Household

applications Direct certification Benefit issuance

Benefit issuance document

Applications Direct certification

lists Other categorical

eligibility documentation

Off-site Assessment Tool Supporting Documentation

Benefit Issuance Document6

• Student name• School name• Eligibility status (free or reduced price)• Date of certification• Method of certification• Total number of eligible students in the

SFA• Notes (e.g. withdrawal/transfer date)

List of all students in the SFA eligible for free or reduced price meals

REMINDERS: No duplicate names Not grouped by eligibility status

Sample Benefit Issuance List7

Benefit Issuance: Other reminders8

Must be updated anytime changes occur in eligibility, as well as when a student transfers or withdraws

Share student eligibility only with the school or program personnel who “need to know”

Selecting Certifications for Review

State agency may elect to review either: All free and reduced price students on

the benefit issuance document A statistically valid sample of free and

reduced price students on the benefit issuance document Only an option if the SFA has greater than

100 students certified for free or reduced price benefits

Obtaining Certifications for Review

For each selected student, the state agency must obtain:

The certification document (e.g. application or direct certification list)

Any verification materials

Application Processing:What are we looking for?

Were applications processed correctly? Was carryover of the previous year’s

eligibility done properly? Were applications approved and

households notified of eligibility status in the required timeframes?

Did the SFA follow all requirements for the independent review of applications (if applicable)?

Denied Applications:What are we looking for?

Was the denied household notified of: Reason for denial Right to appeal Instructions on how to appeal Statement that the household may reapply

at any time during the school year

Common Review Finding:Applications

FINDING: Data entry error results in incorrect eligibility status...

Incorrect household size or failure to include all household members;

Incorrect income amount and/or frequency of pay period;

Incorrect eligibility guidelines used in determining eligibility, including in the eligibility software.

Application is incomplete or missing key data

Common Review Finding:Applications

FINDING: Free/reduced applications are not processed within 10 days of receipt…

Applications should be reviewed and an eligibility determination made IMMEDIATELY, but no later than 10 days from receipt.

Direct Certification:What are we looking for?

Did the Direct Certification list contain all required information?

Did the SFA perform Direct Certification the required number of times?

Are students that have free eligibility based on Direct Certification found on a list as a match?

Was extension of benefits done correctly?

Direct Certification:New For 2014-2015

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SFAs will now be required to run direct certification to show eligibility by school within the SFA

Wisconsin School Directory online:http://dpi.wi.gov/directories

Last Name

First Name

Middle Initial

Date of Birth

School Use

School Number

Benefit Issuance:What are we looking for?

Was each student’s eligibility status properly transferred from the certification document to the benefit issuance document?

Does the benefit issuance document contain all required pieces of information?

Was the benefit issuance document updated as needed?

Are benefits provided in a manner that prevents overt identification?

Common Review Finding:Benefit Issuance

FINDING: Student eligibility status is not updated in Point Of Sale (POS) or roster…

Eligibility must be current and correct at POS and on eligibility rosters at all times, including at the end of the 30 operating day carry-over period and at the end of the Verification process.

REMEMBER…change in status must occur no later than 3 days for an increase in benefits and 10 calendar days for decrease in benefits.

Common Review Finding:Benefit Issuance

FINDING: One student is receiving free benefits due to Direct Certification, but his sibling is reduced or full pay.

REMEMBER…Free eligibility may be extended to other school-aged children living in the SAME household , based on another household member’s receipt of FoodShare or W-2 benefits or FDIPR.

Common Review Finding:Benefit Issuance

FINDING: Reimbursement claimed for student meals when there is not an approved application on file…

Except during the *carry-over period, meals may not be claimed under the free or reduced price meal category unless: an approved application is on file; student is directly certified or extended benefits; student is certified to be foster child, homeless,

runaway, migrant or Even Start/Head Start

Independent Review of Applications

Second review of applications before eligibility determinations are made by someone other than the original Determining Official

Required if certification and benefit issuance errors is greater than 10%

Would occur during the subsequent school year

Technical Assistance/Corrective Action

Technical assistance will be provided and corrective action will be required for all certification and benefit issuance errors identified

Corrective action must be applied system-wide, including at non-reviewed schools

Fiscal Action

Taken for errors resulting from the following: Applications with missing information Miscategorized certifications (eligibility) Benefit issuance errors Failure to update a change in eligibility

status resulting from Verification

Administrative Review (AR):General Areas of Review

Nonprofit school foodservice account

Paid lunch equity Revenue from

non-program foods

Indirect costs USDA Foods

Civil rights SFA On-site monitoring Local school wellness

policy Smart Snacks School meal environment Water availability Food safety Reporting and

recordkeeping SBP/SFSP outreach efforts

Resource Management General Program Compliance

Verification

A process used by SFAs to confirm selected students’ eligibility for free and reduced price meals in the National School Lunch Program and School Breakfast Program. Only required for a sample of students Students certified for free meal benefits

through Direct Certification or other documented sources of categorical eligibility (e.g. homeless, migrant, runaway) are not subject to Verification

Verification Process:Off-site Review Procedures

Questions to explore whether SFA has met all Verification requirements: Participation in Verification

training Conducted process

appropriately Properly changed eligibility

status (if required) Submission of Verification

Collection Report (FNS-742) Compliant electronic

system (if applicable)

N/A

Off-site Assessment Tool Supporting Documentation

Verification Process:On-site Review Procedures

Validate any information provided on the Off-site Assessment Tool

Determine compliance with Verification Requirements

Select sample of verified applications for additional evaluation

Verification:What are we looking for?

Were applications selected correctly? Was the confirmation review

appropriately conducted? Do notification letters contain all required

information? Was follow-up conducted for

unresponsive households? Were changes in eligibility made within

the required timeframes? Was the process completed by November

15?

Common Review Finding:Verification

FINDING: Confirmation review requirements not understood…

Confirming Official must review each application selected for Verification

Eligibility may need to be changed and the application may need to be replaced based on outcome of confirmation review

Common Review Finding:Verification

FINDING: Application in Verification sample pool not replaced when household withdraws from district during Verification process…

If the Verification process was not completed before the household withdraws, a “similar” application must be selected in its place.

Common Review Finding:Verification

FINDING: The follow up requirements were not met for the Verification process…

SFA must make at least one follow up attempt to obtain documentation when household does not adequately respond

SFA must maintain records of follow up attempts

Technical Assistance/Corrective Action

Technical assistance will be provided and corrective action will be required for all Verification errors

Fiscal Action

Fiscal action is not required for General Areas of Review

Fiscal action is applied for students reviewed in cases of Verification-related certification or eligibility change errors

August 2014 revisions to USDA’s Eligibility Manual for School Meals

Eligibility Manual Clarifications

Eligibility Manual Clarification Other Source Categorically Eligible

status must be confirmed prior to certification for free and reduced price meals

Eligibility Manual Clarification Eligibility Manual states (pgs 29, 31, 33, 55):

“LEAs should validate case numbers/other identifiers listed on the application by reviewing direct certification data or contacting local assistance program officials. Validation means a confirmation of an active case number.”

Per USDA, nothing has changed with the process. Only required to validate format (i.e. is the

FoodShare or W-2 cash benefits case number 10 digits long)

Not required to check against Direct Certification list or contact program officials

Eligibility Manual ClarificationIs a child considered a foster child if

placed in a relative’s home? Whether placed by the state welfare

agency or a court, in order for a child to be considered categorically eligible for free meals, the State must retain legal custody of the child

Eligibility Manual ClarificationEffective Date of Eligibility Determinations Can establish the date of submission of

an application as the effective date, rather than the date the Determining Official approved it

LEAs must notify State Agency if they decide to implement this flexibility

For further information, see USDA memo SP 11-2014

Eligibility Manual Clarification

Effective Date of Eligibility Determinations Can use the date the student is first identified as

eligible for free meals via Direct Certification, rather than the date the LEA processes the Direct Certification file into their POS system

For Other Source Categorically Eligible students: Can use the date the household or agency official

submitted the letter, list, or other form of documentation to the LEA, rather than the date the eligibility is confirmed

*Must notify State Agency before implementing this flexibility. See USDA memo SP 51-2014

Eligibility Manual Clarification Transferring eligibility within the same LEA

Eligibility must be transferred P2 to non-P2: new application or DC may be

required CEP to non-CEP: new application or DC may be

required Transferring eligibility to another school

district/LEA Not required to share eligibility May accept eligibility from former LEA, but must

double check

Eligibility Manual Clarification“Questionable application” under

Verification for Cause: Inability to confirm household’s

participation in Assistance Programs Ineligibility for other benefits based on

data included on the household application

Variance in household size

Resources

USDA’s Eligibility Manual for School Meals (updated August 2014)http://fns.dpi.wi.gov/fns_fincou1#manual

Direct Certification materialshttp://fns.dpi.wi.gov/fns_directcert

Verification materialshttp://fns.dpi.wi.gov/fns_fincou1#verification USDA Guidance Memoshttp://www.fns.usda.gov/school-meals/policy

Remember…

The AR process is not intended to “get” schools who don’t comply

It is intended to provide schools with the tools and guidance they need to operate a successful nutrition program

Working together we can meet that goal!

Feeding children matters… Thank

You for all that you

do!

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