Direct Certification and Direct Verification in Indiana July 24, 2008

1. Direct Certification and Direct Verification in Indiana July 24, 2008 John Todd, Assistant Director Office of School & Community Nutrition Indiana Department of Education (317) 232-0865 jtodd@doe.in.gov

2. Direct Certification

3. Direct Certification is a technique that allows a school district to identify those students who receive either Food Stamps or TANF cash benefits. Any student identified can be “Directly Certified” for a Free Meal benefit. They do not have to complete and submit the standard “paper application” for free meals. Schools can typically expect to identify about 50% of their free eligible students in this way. Some districts find many more. Indianapolis Public Schools has processed their matches for the upcoming school year and downloaded 16,189 student names. Their most recent May 2008 reimbursement claim showed a total of 26,200 total Free Eligible Students. This is almost 62%. Gary Community Schools typically can identify 64% or more. This time saving technique is an accurate method of determining eligibility, that is convenient for parents, and efficient for school administrators. While it’s most important contribution is its efficiency, it also undoubtedly identifies some students who otherwise would not receive the nutritional assistance they need and are entitled to. Direct Certification is one method of determining eligibility. Other students may be determined to be eligible based on their household size and household income or other factors. (All students not directly certified must receive a copy of the “paper” application.) Since Food Stamp and TANF eligibility criterion are similar to the Free Lunch eligibility guidelines (130 percent of poverty), all directly certified students are Free eligible. There is no direct certification for Reduced Price Students (185 percent of poverty).

4. Direct Certification has been available in Indiana since 1990. We were a very early adopter of the technology. From the very beginning we have enjoyed strong support from the Indiana Family and Social Services Administration (FSSA). FSSA administers, Food Stamps, TANF, Medicaid, SCHIP, and many other assistance programs. We would like to thank them at this time for their cooperation.

5. During the first years, the process was very “manual” with schools submitting student enrollment information by mailing disks of data which would be processed. Results were placed on disks and mailed (snail mail) back. Very labor intensive. In the early years only the 15-25 largest school corporations participated. (These few largest school corporations did of course account for an overwhelmingly large percentage of Free Eligible students.)

6. We have evolved the process into a web based application that is almost totally self-service, with results made available for download almost instantaneously. With the 2008-2009 School Year, USDA has for the first time made the use of Direct Certification manditory for all schools participating in the National School Lunch Program. Indiana has almost 300 Public School Districts, and more than 250 other non public/parochial and other sponsors of the program.

7. We offer a variety of techniques and tools appropriate for a variety of situations and school districts of various sizes and levels of experience. While many schools will only conduct the Direct Certification process at the beginning of the school year (and in doing so meet the mandate), We offer a variety of enhancements to encourage schools to update their list of students directly certified throughout the year.

8. All Direct Certification activities are hosted on the Indiana Department of Education’s “Application Center.” The Application Center is a very secure environment used by schools to submit a variety of record types to the state. Since sensitive information is being transferred (in both directions), the department takes it’s obligation to safeguard the information very seriously.

9. https://ac.doe.state.in.us

12. We offer two basic methods for schools with varying levels of experience. Results can be downloaded in a variety of formats to accommodate a wide variety of computing platforms. Enhancements allow convenient retrieval of updated results throughout the year

14. We utilize algorithms that allow for matching of names that are not spelled consistently in School Enrollment lists and Food Stamp and TANF rolls • Example: • Laquisha • La Quisha • L’Quisha • These names are not “exact” matches, but would meet the test of “similar”. We use a common computer procedure called the Soundex Algorithm.

15. Matches are made based on: • First Name identical or similar • Last Name identical • Date of Birth • County of Residence and County Issuing Food Stamps • While Food Stamps/TANF records have SSN numbers, schools usually do not collect this information.

16. Once the list is retrieved, Parents must be notified and offered the opportunity to reject the benefit if they wish. It is assumed however, that they desire the benefit unless the parent notifies to the contrary. (Opt OUT) This is the opposite of the paper application (Opt IN).

18. In addition to the basic “Batch Processes” of downloading whole lists of eligible students, we have developed other tools that are appropriate for solving individual problems as they are identified. • These addition tools allow school officials to search for an individual record based on a variety of different methods • Look up based on: • Case Number • Student Information • Parent/Guardian Information • These techniques allow schools to fine tune the results and handle difficult cases.

25. Direct Verification

26. Unlike Direct Certification that takes the place of and eliminates the need for the traditional paper application for free and reduced-price meals, Direct Verification is a technique that is available to validate/verify the information submitted by the parent when they complete a traditional paper application. USDA Regulations require the verification of three percent (3%) of the applications submitted. This verification activity takes place from October 1, through November 15 of each school year. Traditionally, this verification was accomplished by mailing a request for information to the selected parents/households. Parents were requested to submit written records (proof) to substantiate the information they put on the application. If parents do not comply after repeated requests for information, the student looses the benefit. Process is difficult and time consuming.

27. Recent regulatory changes by USDA allow for the Direct Verification of some selected applications without the need to contact the household. To accomplish this, USDA authorized the use of Medicaid and SCHIP data in addition to the Food Stamp and TANF program data used by Direct Certification. Medicaid and SCHIP program information can in some cases validate household income levels matching those for Free (<= 130 % of Poverty) and Reduced-Price (185%).

28. For the last two years, we have received monthly Medicaid and SCHIP data from Indiana Family and Social Services Administration, in addition to the Food Stamp and TANF information that we have received for almost twenty years. The Medicaid data also is used by the Department of Education to assist in calculating Medicaid Administrative Claiming by School Districts. Unlike Direct Certification which is now mandatory, Direct Verification is optional.

29. Direct Certification and Direct Verification used together improve the efficiency of eligibility determinations in the USDA School Nutrition Programs. Direct Certification, as previously mentioned, can reduce the number of applications by one-half or more. By reducing the number of applications, the number of applications that need to be verified is reduced, since schools must verify 3% of the applications, not 3% of the students eligible for free meals. Direct Verification can often then assist in verifying somewhere between 25 and 30 percent of the selected verification sample.

30. A school such as Indianapolis Public Schools might have to verify 300 applications. Many smaller districts may verify only 10-30 applications. While Direct Verification is in its infancy, it is proving to be a useful technique. Where a selected application cannot be Directly Verified, the household is then contacted for a tradition request for information.

31. Indiana was one of just a few states selected to participate in a Pilot Project of Direct Verification with Medicaid Data, over the last two years. The results of the study have not been released yet. Most schools use the “look-up” methods shown below to individually attempt to verify each application. The individual look-ups work very similarly to the Direct Certification look-ups described earlier. We have also developed a batch method that is appropriate for the very largest schools that is more efficient. It will not be covered today in this presentation since it is of limited use.

37. The existence and usefulness of these techniques is based on maintaining a delicate balance between acknowledging the limitations imposed by HIPPA1, FERPA2, and USDA Confidentially Requirements on the one-hand, and the desirability of utilizing “cross-program” information in reasonable ways to deliver needed services to needy families and children. One would hope that these concepts will evolve in useful ways in future years allowing better delivery of services. 1Family Educational Rights and Privacy Act 2Health Insurance Portability and Accountability Act

38. Additional Information: John Todd, Assistant Director Office of School and Community Nutrition Programs Indiana Department of Education jtodd@doe.in.gov (317) 232-0865 Three complete manuals are available on our Website: http://doe.in.gov/food/schoolnutrition Direct Certification (rev. 4/2008) Direct Certification-STN Method-Quickstart Guide (rev. 4/2008) This manual is a subset of the Direct Certification manual. Direct Verification (rev. 9/2007) The Center on Budget and Policy Priorities published a study in August 2006 titled “Implementing Direct Certification: States and School Districts can Help Low-Income Children Get the Free School Meals for Which They Are Eligible”, by Zöe Neuberger. It can be found at http://www.cbpp.org/8-11-06fa.pdf