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Verification Process: What is Involved?

Verification Process: What is Involved?.

flynn-mclaughlin
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Verification Process: What is Involved?

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  1. Verification Process:What is Involved?

  2. The U.S Department of Agriculture 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 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 (Spanish). USDA is an equal opportunity provider and employer. 6/2013

  3. Federal Policy for determining and verifying eligibility http://fns.dpi.wi.gov/fns_fincou1#manual Eligibility Manual for School Meals, August 2013, Part 8 is Verification • Terms related to the Free and Reduced-price eligibility process (helpful to understand parts of verification) are included in Eligibility Manual (EM) Part 1: B • Definitions related to Verification EM Part 8: A

  4. SFA(School Food Authority) LEA(Local Educational Agency) to identify the entity responsible for application, certification, and verification activities for National School Lunch (NSLP) and School Breakfast (SB) programs EM Part 1: A for agencies administering the school meals programs

  5. WI Child Nutrition Programs Website http://fns.dpi.wi.gov/fns Click on “INDEX” button: select “topic” listed in alphabetical order Verification information is located at: http://fns.dpi.wi.gov/fns_topics#V Annually download letters/forms/mailings! This guarantees the current Civil Rights statement is included!

  6. USDA’s Food and Nutrition Service USDA Guidance Memos for Schools explain changes, updates or clarifications. USDA’s Food and Nutrition Service is linked to DPI website at: http://fns.dpi.wi.gov/fns_topics#U http://www.fns.usda.gov/cnd/Governance/policy.htm

  7. USDA Guidance Memos Memos pertinent to Verification: SP38-2013 Verification Report SP13-2012 Verification for Cause SP02-2012 Verification & Reporting of Foster Children

  8. Let’s Do a Quick Review of theApplication Approval Process • Application materials must be distributed to all households each year. Click “Free & Reduced Meal applications” on Child Nutrition Programs website for current application(s). • Determining Official receives applications, contacts household if application is incomplete; approves or denies eligibility; documents eligibility decision on application, creates Benefit Issuance list and/or enters into computer system. • Complete “Benefit Issuance” list of F/R students: specific date approved, denied, benefit changed, Direct Cert, foster child, benefits extended per sibling, withdrawn from school, etc. • Household is notified of decision. Written notice including appeal procedure is required - if benefits are denied.

  9. Who is involved in the eligibility approval process? 4 officials named on the school/district’s on-line DPI contract for school year (SY): • Determining Official • Verifying Official • Confirming Official • Hearing Official

  10. Determining Official • Reviews each application for completeness, correct case number or computes income, initial/date, approve/deny application. Runs Direct Certification • Compiles “Benefit Issuance” list for each school. Lists each student’s Free or Reduced-price status & precise date of any change. (Can’t backdate) • Documents up to 30 operating dayscarry-over of eligibility from previous school year or until a new application is approved, whichever occurs first Eligibility Manual for School Meals, August 2013 and Direct Cert: http://fns.dpi.wi.gov/fns_directcert

  11. Verifying Official • Notifies households selected for verification • Verifies information on each application: reviews documentation submitted for completeness; checks for each income & does math, FoodShare/W-2 Cash/FDPIR documentation from ACCESS, foster care documentation from State or foster care agency • Signs/dates; informs household in writing of results: change or no change in eligibility status • Maintains the records of verification in a separate file • May be the Determining Official EM Part 8 and Part 9

  12. Confirming Official • Only required to double-check household applications selected for Verification • Assures that initial determination was correct. If not correct: update application with correct eligibility, benefit issuance list & inform household (before verification notices are mailed to households); then verify per this correct determination • Exclude household from Verification if no longer eligible for benefits or withdrawn from school • Confirming Official can not be Determining Official EM Part 8: G

  13. Hearing Official • Conducts a Hearing, when requested, for appeals to the determination or verification decision • Can not be involved in the original determination or the verification processes • Hearing Official is generally a superior of the Determining Official and Verifying Official • May be the Confirming Official EM Part 8: M

  14. Determining Eligibility • Direct Certification (DC): S, T, O, E = “free” eligible • Categorical Eligibility: automatic “free” based on eligibility as: • Foster Child (court placed/WI/agency documents) or marked “foster child” box on application Part 1. All Household Members • FoodShare/SNAP: 10 digit case number • W- 2 cash assistance (Wisconsin’s name for Temporary Aid to Needy Families (TANF) - 10 digit case number • Food Distrib. Program on Indian Reservations (FDPIR) • Other Source Categorically Eligible: homeless, runaway, migrant, Head Start, Even Start • Income-based applications: can be free, reduced or denied EM Part 3, 4, 5 Direct Cert: http://fns.dpi.wi.gov/fns_directcert

  15. Direct Certification • Required 3 times per school year by each LEA participating in NSLP & SBP – run after July 1 • 1) before or about the beginning of school • 2) 90 days after first run (about 3 month) • 3) 180 days after first run (about 6 months) • Eligible students identified/coded S, T, O, E on each Direct Cert “run” are not subject to Verification! • If using computer software, be sure system has been updated for the new Direct Cert code letters Direct Certification: http://fns.dpi.wi.gov/fns_directcert

  16. Direct Certification • Keep each DC list. Each list documents students as “free eligible” based as of that specific date • May run DC as often as useful • Direct Cert takes precedence over an application • Keep application of student(s) who are eligible by DC on-file. Application helps identify other children in household to whom benefits are extended. These children are also considered DC. EM Part 1:B; Part 3: A, C; Part 5: A; Part 6: A http://fns.dpi.wi.gov/fns_directcert

  17. Other Source Categ Eligible Defined as: • Homeless, Runaway or Migrant • Head Start, Even Start enrollment An individual child’s “Other Source Categorically Eligible” does notconvey to other children in the household. Foster child status does not convey to other children in a household. EM Part 1: B; Part 3: C, F; Part 5: B, D

  18. What is Verification? • Verifies eligibility for a sample number of applications received/approved in the current school year for free and reduced-price meal benefits under the National School Lunch Program (NSLP) and School Breakfast Program (SBP) • Required by USDA for all school agencies and any Residential Child Care Institutions (RCCI) with day students who are participating in federal meal programs such as National School Lunch Program (NSLP) & School Breakfast Program (SBP) who have any approved applications

  19. Excluded from Verification Free Eligible students with no application; but based on documentation: • Direct Certification (DC) • Homeless, Runaway, Migrant status (only with documentation/email from Homeless Liaison in public schools, or Migrant Education Program Coordinator) • Foster Child based on DC or court/agency documents • Resident in RCCI (not day students) • Head Start/Even Start participants (Federal & WI programs) EM Part 5, 6, 8 and USDA Memo SP 40-2013, SP02-2012

  20. Mark your calendar! • Sept 30 - consider a Direct Certification run • Oct 1: from the number of current school year applications approved on/by Oct 1. Verifying Official will calculate the correct sample size • Last operating day in Oct: # of enrolled students • November 15 - complete verification process • Nov 1 to Feb 1 - submit Verification Reportto DPI at http://fns.dpi.wi.gov/fns_online EM Part 6: A, B; Part 8: C, O; Verif Report Instructions

  21. How is Verification conducted? • Required sampling method is determined (applications may need to be sorted into groups) • As of Oct. 1, count the total number of approved applications submitted for current school year • Carryover apps of previous SY are NOT included • Select required percentage based on sampling method - but not more (do not verify 100% of paper applications)

  22. How is Verification conducted? • Confirming Official checks only applications selected for verification and if necessary, corrects eligibility status and notifies household of correction before verification paperwork is mailed to the household • Must mail/give “We must check your application” letter and verification paperwork to each household selected to be verified. Consider phoning each household to explain process/what they need to sent in. Verifying Official decides “due-date”

  23. How is Verification conducted? • Receive documents from household to verify information on application • Examine documents submitted by households (keep documents or photo copies) • Validate eligibility or change household’s eligibility status based on documents received. Calculate income based on documents submitted. • Mail/send “We have Checked Your Application” letter to household with results of verification

  24. How is Verification conducted? • Must make at least one “follow-up attempt to contact” any household who do not respond to submit documents. Must ensure that adequate language assistance is provided. Follow-up may be in writing (including by email) or by telephone. • Document that a contact was attempted. Please keep good records of each follow-up contact/s. • If household indicates, verbally or in writing, that it no longer wishes free or reduced; verif is complete when “we have checked” letter is sent. EM Part 8: J

  25. Verification Terms • Sampling Methods: EM Part 8: E • Verification For Cause: Part 8: D and the USDA Memo SP13-2012 http://www.fns.usda.gov/cnd/Governance/policy.htm • Direct Verification (optional) EM Part 1: B and Part 9

  26. Verification “For Cause” • School agencies have an obligation to verify “questionable” applications. Can’t delay the approval of applications • Verification “for cause” is done any time during school year as soon as possible after the application is received EM Part 3: F; Part 8: D USDA Memo SP 13-2012

  27. Verification “For Cause” • Any paper application verified “for cause” is in addition to the sample size required for the “official” verification process • Any application(s) verified “for cause” is reported on Verification Report (FNS-742) in 2 places: Section 5, 5-8 boxes and line VC-1 Verification Report Instructions

  28. 3 Sampling Methods Standard: lesser of 3% or 3000 apps from error-prone paper applications Alternate 1: lesser of 3% or 3000 apps selected randomly Alternate 2: lesser of 1% or 1000 apps selected first from error-prone apps; PLUS .5% of apps with case # EM Part 8: E

  29. Computer System with Verification Feature Check the computer system to ensure that: • it selects appropriate sample size • it selects error prone applications for the Standard and Alternate #2 sample sizes • all letters to households generated by the computer system contain the required current school year Privacy Act and Non-Discrimination Statement EM Part 2: C, E, F, G; Part 8: E, F, G, H, K, P and SNT Mailing April 25, 2013 Web-based Direct Certification

  30. Which Sampling Method to Use? Choice is based on last school year’s verification results • “Standard” sampling must be used if your preceding school year non-response rate was equal to or greater than 20%. Pull your file & calculate non-response % • Large LEA’s (more than 20,000 students approved by October 1 for free or reduced by application) with greater than 20% non-response but showed at least a 10% improvement in non-response rate may select any of the 3 sampling methods • LEA’s with less than 20% non-response rate may select any of the 3 sampling methods EM Part 8: B, C, E, F

  31. Mailings-School Nutrition Programs • Late September: watch for Verification mailing • Posted under letter “M”, “Mailings-School Nutrition Programs” http://fns.dpi.wi.gov/fns_sntmail • If your Local Educational Agency receives specific notice that LEA is obligated to use Standard Sample Size of error-prone income applications {this letter is not posted on website} Your LEA had ≥ 20% non-response rate in the previous school year

  32. After the Initial Selection: Confirmation Review • Confirming Official checks only the application(s) selected for verification (her/his initials/date it) • Checks accuracy of the original determination (i.e. does math manually, if F/R income app) • Corrects the eligibility, if needed, before verification notification is sent to household. Notify household. Never verify a “paid” app. Randomly replace app with another app of same type: error-prone income, income, Foster child or Case # EM Part 8: G

  33. Replacing Applications • After Confirmation Review, LEA may decline up to 5% (.05) of applications selected for verification • Must replace application on the same basis as the one declined: error-prone, income, case number, etc. EM Part 8: G, P

  34. Possible Reasons to Replace an Application May choose to replace an application because: • household had been selected for verification last year • household has language barriers, or literacy issues, or is embroiled in a custody battle which may impact compliance • household with on-going or unresolved issues with school agency which may impact compliance

  35. Replacing Applications Examples: • Verifying 100 applications (100 x .05 = 5), can replace up to 5 of those applications with others • Verifying 20 applications (20 x .05 = 1.00) can replace 1 application with another application • Verifying 2 applications (2 x .05 = .10) can replace 1 application with another Minimum of one application may always be replaced even if the result is less than 1 EM Part 8: G

  36. Meeting Minimum Sample Size Randomly select a similarly approved replacement application if: • Confirming Official finds an error in the initial determination and household is no longer eligible for free or reduced- price meal benefits • Student/students listed on selected application have left the school/district LEA may notchoose more than sample size LEA may notverify all approved applications EM Part 8: C, D, E, F, G, H, P

  37. Zero Income HouseholdSelected for Verification • LEA must request an explanation of how living expenses are met • LEA may request additional written documentation or collateral contacts information from whom assistance is being received • Cash withdrawn from savings is reportable income EM Part 3: E, P Part 4: B, C Part 8: I, P

  38. Before written notification is mailed, Direct Verificationis an option • LEA may obtain documentation of Food Share, W-2 cash benefits & FDPIR application directly from local agency that administers each program (communicate by FAX or scanned copy) • http://fns.dpi.wi.gov/fns_fincou1#verification use Verification Forms: fax pages 12 & 13 to agency • Not necessary to notify household if eligibility remains the same. Verification is completed • If results in change in eligibility: mail household written notification of verification, “We Must Check” EM Part 1: B Part 9

  39. Direct Verification (optional) Fax or scan pages 12 & 13 of Verification Forms to your county’s Income Maintenance (IM) agency. All Wisconsin county & Tribal agencies are posted: http://www.dhs.wisconsin.gov/ Click on “Topics: A to Z”; click on letter “I”; then Income Maintenance (IM)Agency Directory Or http://www.dhs.wisconsin.gov/forwardhealth/imagency/index.htm

  40. Written Notification to Household Selected for Verification Includes: 1. Deadline for submitting written evidence is set by LEA • Name of LEA contact and phone number that can be reached without charge (for local call, toll free, or collect) to answer verification questions • “We must check your application” letter lists acceptable documentation of FoodShare/SNAP; W-2 cash benefits/TANF; FDPIR; foster child or income. • Recommend use of Verification Forms (16 pages) posted: http://fns.dpi.wi.gov/fns_fincou1#verification EM Part 8: H, I, J, K, L

  41. Documentation to Support Eligibility • Written evidence received directly from the household (pay stubs, child support, SSI, etc.) • Collateral contact identified by household that school can request information from directly: • Employer • Social service agency • Migrant workers’ agency • Religious or civic organization EM Part 8: I, J

  42. Income Documentation • Must receive documentation for all sources of income reported on application (Be sure to keep copies on file) • Income may be for any time from one month prior to date of application up to time of verification • Frequency of income(s) should be identifiable (e.g., weekly, biweekly, monthly, 2 times per month). Ask household if frequency is not clear. Date/initial the response • Gross income must be used; except for self-employment and farming income or seasonal/fluctuating income Free and Reduced Price School Meals Family Application

  43. Documentation for FoodShare/SNAP, W-2 cash benefits/TANF and FDPIR • Documentation that shows eligibility for programs from any point in time between the month prior to date of application and up to time of verification • Documentation of a child (or any household member on the application) is receiving benefits under FoodShare, W-2 cash benefits or FDPIR • Quest card (electronic benefits) can’t be used. It has no expiration date.EM Part 3: A, C; Part 8: H, I

  44. Foster Child(ren) • Foster childonly application: Social worker, agency, court/State confirms child’s “foster status” andpersonal income, if any, in writing or over the phone (record documentation received verbally onto application and initial date) • Foster child appearing on household application: foster child is categorically eligible. Foster does not convey “free” benefits to household’s own children. Household children determined by income or sources of household categorical eligibility EM Part 1: B; Part 3: C; Part 4: B; Part 5: B, D; Part 6: G USDA memo SP02-2012 and SP17-2011

  45. Kinship Care • Ask: in cases where no specific welfare agency or court is legally responsible for the child or child is living with relatives, or friends of the family, the child is considered to be a member of the household with whom s/he resides. Household must submit an application. App could be selected for verification. • Child(ren) placed with relatives through formal arrangement by courts or State is considered Foster “Determining Eligibility for Meal/Milk Benefits: Foster Care, Kinship Care & Adoption Assistance Fact Sheet” 8/19/11 posted at: http://fns.dpi.wi.gov/fns_fincou1

  46. Adoption • Children are part of household when there is legal adoption. They must be listed on application. Any adoption subsidy is considered reportable income. Application could be selected for verification. • Due to year-long duration of eligibility, free eligible status on a foster child doesn’t change if foster child was adopted during the same school year. EM Part 4: B, D Part 5: C, D

  47. After Household Responds-Verifying Official: • Must receive documentation on all sources of income listed on original application; compares documentation with information listed on the application; computes total income from documentation for income applications • Overtime: Contact household and ask if overtime is one-time or sporadic source of income. If only sporadic, income should be calculated based on regular monthly income without overtime • Records to whom you spoke; person’s answer/initial and date - that the conversation occurred EM Part 8: H, I, J, N, P

  48. After Household Responds-Verifying Official: • Informs household that eligibility remains the same or changes (be sure to use the most current “We have checked your application” letter from DPI website) • Written notice is required to include “Appeal Procedures” for change in benefit level and/or for termination of benefits • Updates Benefit Issuance List or computer system database to correct benefit level of each student/siblings

  49. Insufficient Evidence or No Response • Verifying Official must make at least one documented attempt (written, email or verbal) to contact the household and inform them that failure to comply with verification will result in termination of benefits (document contact(s) • Terminate benefits and change to “paid” status if household does not respond by deadline set, but no later than November 15. Letter must give 10 calendar days written advance notice from date the notice is sent. EM Part 8: J, K, L

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