Free and Reduced Price Meal Eligibility

1. Free and Reduced Price Meal Eligibility Distance Learning August 13, 2009 Karen Franklin, SNS Arkansas Department of Education

2. Changes to Application2009-10 School Year • Food Stamp program is now called Supplemental Nutrition Assistance Program (SNAP) • Racial Identity check boxes – “Other” category was removed • Change in instructions and Privacy Act Statement (due to SNAP name change)

3. Application Processing Timeframe • Applications MUST be processed, determination made, and households notified within 10 working days from receipt of application. See page 26 of Eligibility Manual

4. Student Names on Applications • ADE/CNU Application Prototype • Student names MUST be listed in both Part 1 and Part 3 of the application • Cannot draw arrows from names in Part 1 to Part 3 • Student name must be listed in Part 3 due to USDA requirement that student income MUST be listed on application

5. Student Names on Applications • Districts not using the ADE/CNU prototype application MUST have applications approved by ADE/CNU PRIORto distribution to households • District applications MUST have section for student income to be listed

6. Master Roster • The LEA MUST have a master roster that contains: • Name of student (other identifier) • School • Grade • Eligibility Status • Date of Eligibility Status determination • Date of withdrawal or re-enrollment

7. Master Roster • The LEA MUST be able to show the source documents to verify the number of free and reduced price eligibles for any given day during the claim month. • If the master roster is on a computer then it must be printed each month as a source document for the claim form.

8. Master Roster • Must be able to show, for any given day, the students that were free, reduced and paid on that date. • Records must be kept for 5 years after the date of the last claim filed based on those documents, so must be able to show free and reduced for any day in last five years.

9. Computer Systems • All Child Nutrition computer systems MUST be backed up • If there is a computer failure or power failure the LEA MUST be able to show all students eligibility and eligibility determination dates • If you do not feel comfortable that the district has your system backed up then you MUST contact the appropriate district personnel and make sure this is happening

10. Computer Systems • Remember: Even if your district has a computer system that scans applications – the paper application is the SOURCE DOCUMENT and must be maintained. The paper application is the legal document allowing the students to receive meal benefits, not the computerized record.

11. Master Roster, 30 Day, APSCN • All students should be coded PAID in APSCN at the beginning of the school year • APSCN is NOT the Child Nutrition Master Roster • As new eligibility determinations are made the Child Nutrition Master Roster AND APSCN should be updated

12. Master Roster & 30 Day Carryover • At the beginning of the school year use last years master roster for 30 day carryover of meal eligibility benefits • Update this roster with new application determinations and new categorical lists as received • May need to print this list daily at beginning of the school year to reflect accurate eligibility status of students

13. 30 Day Carryover • LEAs MUST carryover the eligibility status from the previous school year for all students for 30 OPERATING DAYS or until new application is processed or new list is submitted • An operating day is any day that meals are served to students

14. 30 Day Carryover The 30th operating day for districts that will begin school on August 19th and will take September 7th off for Labor Day will beWednesday, September 30th

15. 30 Day Carryover • Carryover is discontinued only by the following: • New application submitted, eligibility determined and household notified • New categorical list received and household notified • At end of 30 operating day carryover if no new application has been submitted and student’s name is not on a categorical list, then the student is moved to paid status

16. 30 Day Carryover • School Districts DO NOT HAVE THE OPTION to discontinue the carryover of previous years eligibility status prior to the 30th operating day • The district MAY ask for applications to be returned earlier than 30 days, however • The district MAY NOT change the carryover status of students that do not have new determination prior to the 30th operating day

17. 30 Day Carryover • In short, the new eligibility determination supersedes the 30 day carryover, however the district must allow the FULL 30 day carryover time frame for any student that has not had new determination (by new application or new categorical list) See page 25 of manual for more information

18. Income Eligibility • Economic Unit – group of related or unrelated individuals living together sharing income and expenses. If two families are sharing the same residence but each pays their own bills and has their own income, then they are treated as two households. See page 46 of manual.

19. Income • Income is ANY money received on a regular recurring basis; occasional babysitting and lawn mowing jobs would not be reported as income • Must report GROSS income (before deductions for taxes, insurance, etc.) on the application

20. Determining Household Income There are four categories of income on the Free and Reduced Price Meal Application • Earnings from work (gross earnings) • Welfare / child support / alimony • Retirement / disability benefits • Any other income

21. Current Income Current income means income received by the household for the current month, the amount projected for the first month the application is made or the month prior to the month the application was completed. See Special Situations on Page 48 of Guidance for guidelines.

22. Income Conversions • Income all received at same frequency: • For example, all income listed is received on a weekly basis • Add all income together and look at the Income Eligibility Guidelines • Make determination based on household size and weekly income

23. Income Conversions • Income all received at different frequencies: • For example: some income received weekly and some received monthly • Must convert all income to YEARLY income • Look at IEGs for household size and yearly income to make determination

24. Income Conversions • Only convert income to YEARLY income when all reported income is not received at the same frequency • Cannot convert all income to monthly (cannot use 4.33 or 2.15 anymore) • USDA requires that if a conversion is needed that all income be converted to YEARLY income

25. Income Conversions • See page 31 of manual for more information on income conversion • See Appendix I, Application #4 for example of application without income conversion • See Appendix I, Application #5 for example of application with income conversion

26. Special Situations • Joint Custody – If: • Child changes residences based on joint custody • Both households apply for meal benefits • Different eligibility statuses result THEN: • Child receives the greatest benefit level regardless of which home he is living in at the time of the meal service See page 47 of manual

27. Special Situations • Foreign Exchange Student – does not get special treatment in our program. Must be on application of the household in which they reside. See page 47. • Foster Child – each foster child goes on an application by themselves as a household of one (Part 2 of application) see page 47.

28. Special Situations • Foster Child – the income that is designated for the foster child as personal income is reported in Part 2 of the application • Foster Child Household – the foster child IS NOT included in the household in which they reside (considered a household of one) • Foster Child Household Income – the income a household receives for the care of a foster child IS NOT reported as income on the application (page 50 of Guidance)

29. Special Income Situations • Seasonal workers – when income fluctuates from one month to another the household may project its annual rate of income and report this amount as current income; prior year information may be used if it is accurate for the current year.

30. Adopted Children • Adopted Child – does not get special treatment in the Child Nutrition program. Treated as any member of the household (must be on application or be on a categorically eligible list). Adoption assistance is included as income on applications.

31. Income Exclusions • Please see Page 50 Income Exclusions, for a list of income sources that are excluded from consideration in our program. For example: • Payments for care of foster children • Student financial assistance, grants, scholarships • Loans that must be repaid • In kind compensation • Occasional earnings received on an irregular basis

32. Income Exclusions For a list of federal program income sources that are excluded from consideration see Question 2 on Page 51 and its answer on Page 52 of the Guidance Regularly check the website listed at the top of Page 53 for changes to this excluded income list http://www.ssa.gov/OP_Home/cfr20/416/416-ap01.htm

33. Special Income Situations • Self Employed – credited with net income and not gross income • Net income determined by subtracting business expenses from gross receipts (see page 49 of Guidance for details) • May use last year’s income unless current net income provides more accurate information • A negative number is reported as Zero income (not temporary in this circumstance) If household receives income from wages AND self employment –both must be listed separately on the application

34. Military Personnel • Any benefits received in cash, such as housing, food or clothing allowances, are considered income. • In-kind benefits where no cash is provided to the household are excluded from income (i.e. Family Subsistence Supplemental Allowance – FSSA). • Deployed Service Members – Only the income that is available for the households use is listed as income on the application. Deployed Service Members may be counted as a member of the household on the application.

35. Public Assistance Payments • General Assistance payments • General Relief payments • Welfare benefits • SNAP (Food Stamp) benefits are not counted as income to the household and should not be listed on the application See page 48

36. Retirement / Disability Benefits • Pensions or veteran’s benefits • Social Security benefits • Supplemental Security Income (must be blind, disabled or over 65 to receive) • Disability benefits (permanent disability benefits – not worker’s compensation) See page 48

37. Examples of Other Income • Rental income (net) • Interest • Cash withdrawn from savings • Regular contributions from persons not living with household (i.e. money from parents or grandparents, etc) • Estates, trusts, investments • Any money that is available to pay for children’s meals See page 48

38. Garnished Wages The gross income BEFORE the garnishment is considered income for the household on the free and reduced price meal application. The fact that the income is designated for a particular purpose (the garnishment) is not relevant in determining eligibility for free and reduced price meal benefits. See page 50

39. Child Support and Alimony • Child support and alimony included on the application should reflect the amount the household actually receives regularly • Child Support and Alimony are counted as income for the receiving household, but are not excluded from the income for the household that is paying the benefits See page 50

40. SNAP (Food Stamp) Households • The names of children on an application with a nine digit SNAP (Food Stamp) case number should be checked against the Direct Certification list sent to the LEA in August of the current school year. If all students on the application are on the Direct Certification list then the application should be put into a “Duplicate Applications” file and the application should be disregarded. See page 56

41. SNAP (Food Stamp) Applications • Any application with a SNAP (Food Stamp) case number must have the box checked next to each student’s name that is considered part of the SNAP (Food Stamp) household. Any name that does not have the box checked cannot be considered part of the SNAP (Food Stamp) household without further contact with the family. See page 56

42. SNAP (Food Stamp) Applications • If a SNAP (Food Stamp) case number application does not have the box checked for each student on the application, then the determining official MUST contact the household to determine if the household receives SNAP (food stamps) for that child. • If the household does receive SNAP (food stamps) for that child, then the contact should be documented, the box should be checked and the student allowed free meals. • If the household does not receive SNAP (food stamps) for that child, then the contact should be documented and the household must supply income information in order for the LEA to determine the eligibility status based on income of the student(s) that does not receive SNAP (food stamp) benefits. See page 56

43. Dual Eligibility Applications • It is possible to have two different eligibility determinations on the same application. See pages 28-29 of manual • If one student is on SNAP (food stamps), and another student in the household is not on SNAP, then need income information for the student not on SNAP

44. Dual Eligibility Applications • Income information is used to determine the eligibility status of the student that is not on SNAP (food stamps): • Free, based on income • Reduced, based on income • Denied or paid, based on income See Appendix I, Application #2 of manual for example of dual eligibility application

45. Dual Eligibility Applications The verification of these dual eligibility applications will be discussed in the September 3rd Distance Learning On the roster – may want to give this application two application numbers, or an application number with a letter designation – for example the FS application may be #102 and the Income application may be #102a. This helps you realize this is dual eligibility determination

46. Dual Eligibility Applications • Households must be allowed to complete only ONE application for the entire household. We cannot ask households to put the two different types of eligibility on two different applications. We will have only one piece of paper, but it may be treated as two applications for verification purposes. • The only exception to one application per household is that Foster children will have their own application.

47. Categorical Eligibility • Member of SNAP (Food Stamp) household • Enrolled in Federally-funded Head Start program • Enrolled in a pre-kindergarten Even Start program • Enrolled in a Migrant Education Program • Identified as a Runaway child • Identified as a Homeless child

48. Categorical Eligibility Categorical Eligibility is determined on an individual basis. A child’s receipt of benefits, such as SNAP (Food Stamps), or participation in a program, such as Migrant Education, cannot be used to certify other children in the same household who are not considered members of that program’s assistance unit or who are not participants in that program. See Part 5 on pages 55 – 62 of the manual

49. Duration of Categorical Eligibility • Due to year long eligibility, households are not required to report changes in categorical eligibility status during the school year • If a household voluntarily reports changes the LEA must inform the household that the students are eligible to continue to receive meal benefits for the remainder of the school year • This categorical eligibility would be subject to the 30 day carryover at the beginning of the school year. See page 60

50. Notice to Household of Categorical Eligibility • The Forms and Letters Packet of the Policy Statement Renewal for 2009-10 has included a letter for Notice to Households of students that are categorically eligible based on being on a list (Migrant, homeless, etc.) in addition to the Direct Certification Notice to Households. This Notice to Households MUST be sent to all households with students on categorically eligible lists.