Free & Reduced Process Updates and Reminders

1. Free and Reduced Process 2019-20 Updates and Reminders @EducateIN

2. Agenda Preparing for End of 2019 and Beginning of 2020 Direct Certification Free/Reduced Application Processing Notification/Appeals Transferring Eligibility Verification for Cause/Verification Disclosure Record Retention/Reviews

3. End of 2018-2019 Reminders

4. End of Year Reminders Make sure your 2018-2019 files are organized. Create a list of non-responding households from the 2018-2019 Verification Process. Determine what type of verification process you must use in 2019-2020.

5. First Steps in PY 2020

6. Prepare Your Applications Download the 2019-2020 F/R Application, Parent Letter/Instructions, and Notification Letters Review updated paperwork Edit templates with school’s information Do not distribute applications until July 1!

7. Online Applications

8. Direct Certification

9. Direct Certification Tips • Users must have a log in and password – obtain this from your school’s STN administrator • Conduct Direct Certification: • Before applications are distributed • Every month • If you are not the one that conducts DC, make sure the person who is knows they must download multiple matches a year! • Once matched, approved for the rest of the year

10. Reminder! DC based on Medicaid • DC students based on: • SNAP • TANF • Foster • Medicaid • DC for Free or Reduced – system will let you know how student is approved • Only applies to students matched through STN Center • If not found in the STN Center, households must provide income information on an application. • Do not accept a written Medicaid number at face value!

11. Additional Medicaid DC info • With Medicaid status: • Extend free or reduced eligibility to all in household • Once DC, free or reduced the entire year • DC status sticks with student • Identify eligibility on column U (line 21): • SNAP - F • TANF - A • Foster - W • Medicaid Free - M • Medicaid Reduced - R

12. Additional Medicaid DC info If approved for reduced, allow households to submit an application to see if they qualify for free based on other information Report Medicaid Reduced separately on VSR Cannot DC a Medicaid case number on an application Cannot DC a letter from FSSA that states they currently have Medicaid Software must accurately categorize students for DC because of SNAP, TANF, Foster, or Medicaid Free or Reduced.

13. Effective Date DC Approval Direct Certification approval process: Run DC match list or conduct DC look up Extend eligibility to other students Benefit begins date student(s) originally matched

14. Effective Date DC Approval Implemented the same for all students. Any money paid by or on behalf of the child for reimbursable meals during the 10 day processing period must be refunded. Any debt accrued during the 10 day processing period must be forgiven. Retain documentation that shows the original date of eligibility. Eligibility must still be extended to all others in household if identified due to SNAP, TANF, or Medicaid (Free or Reduced). Must receive waiver before beginning to implement this process. Must implement for DC and applications.

15. Common DC Questions • The student is DC because of his mom but we know he doesn’t live with his mom, can the student still be DC? • As long as a school can validate that the student found in DC is the correct student, he or she can be considered DC even if they don’t live with the guardian listed on the DC match.

16. Common DC Questions • A student that was identified through DC moves into a new household, does he get to keep his eligibility? • Yes, the DC eligibility sticks with the student. The free or reduced eligibility will also extend to any other student he is now living with if identified as Food Stamp, TANF, or Medicaid. Foster status does not extend to the rest of the household.

17. Common DC Questions • A DC student has siblings in the household who were not on the list, what do I do with them? • If the student was DC because of Food Stamps, TANF, or Medicaid (Free or Reduced) then that eligibility can extend to everyone else in the household. Make sure to keep notes on file indicating that they live in the same household.

18. Common DC Questions • If a household brings in a letter showing the receive Medicaid, can that letter be used to Direct Certify them for benefits? • No, a school can only approve a household for Medicaid Free or Medicaid Reduced when found in the STN Application Center (DC Database).

19. Common DC Questions • A household submits an application with a ten digit case number beginning with a 10. In DC Look-Up, it is a Medicaid Reduced case number. What are the steps to process this application? • Send home a letter notifying the household that they were DC for reduced meals. If the household questions why they weren’t approved for free benefits, explain that the State system indicated that the case number was tied to a Medicaid number that was eligible for reduced meals. • If they insist that the number is a Food Stamp or TANF case number, they will need to provide a letter from the state agency that shows they are currently receiving Food Stamps or TANF. • The household could also submit an income application if they believe they qualify for free benefits.

20. Common DC Questions • A household has free benefits carrying over from the previous school year (for the first 30 operating days), but were found in Direct Certification as reduced because of Medicaid. What are the next steps? • As soon as the household is identified in Direct Certification, make that change immediately and send home a notification letter. The household could always submit an income application if they feel they still should qualify for free meals.

21. Need Additional Help? • Check out our Free and Reduced Fact Sheets on the DC Process: • Direct Certification Fact Sheet • Medicaid Fact Sheet • SNAP/TANF Fact Sheet • Foster Approval Fact Sheet • Homeless and Migrant Fact Sheet • https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training

22. Free and Reduced Applications

23. State Board Of Accounts Reminder ISBOA requires schools to have procedures in place to double check (randomly) the work of all their employees, including those who approve applications. NO one person should have complete control over benefit assignments. Make sure there is a segregation of duties. Check out our sample Internal Control Policy for Approving Free and Reduced Applications: https://www.doe.in.gov/nutrition/indiana-state-board-accounts

24. Annual Frequency Reminder • Schools may now process income applications with annual frequency reported. • IDOE Free/Reduced application template will not display the annual frequency option. • This does not change how to verify application. • Only households that own their own business may use a tax return.

25. Processing Applications • Cross check apps with your direct certification list • Process applications within 10 operating days • Effective Date Waiver • 30 Day Carryover ends when new application is processed • If benefit decreases, send letter but implement eligibility change immediately

26. Effective Date App Approval Effective Date App Approval Application approval process: Free and reduced application for meals submitted Application immediately date stamped Maximum 10 operating days to process Once approved, benefits can be applied beginning when application was first submitted

27. Effective Date App Approval Implemented the same for all students. A date stamp is required. Any money paid by or on behalf of the child for reimbursable meals during the 10 day processing period must be refunded. Any debt accrued during the 10 day processing period must be forgiven. Must receive waiver before beginning to implement this process. Must implement for both DC and applications.

28. Categorical Application • Food Stamp/TANF • 10 digits, beginning with a 10 • If not, is this an out of state case number? Is it an EBT card number? Find out more information. • If they indicate this is anything other than Food Stamp/TANF, ask for income information • Check with DC List • Conduct DC Lookup • If cannot find through DC, approve based on face value and flag to verify for cause

29. Categorical Application • Foster • Conduct DC Lookup • If no match can be made call the household to see if the child actually is a foster child • If cannot determine foster status, advise household to complete income section of application • If the household indicates the student is a ward of the State, then approve the application based on face value – this can still be verified • Due to ESSA - School districts now have a foster point of contact

30. Direct Certification Look-Up STN Database – Direct Certification - Lookup Enter the least amount of information

31. Direct Certification Look-Up • Direct Certification Results • Identify the student and click Print to the left of his or her name. • No need to click on the plus sign.

33. Categorical Application • Migrant, Runaway, Homeless • Eligibility must be validated before approved: • Letter from Homeless/Migrant Agency • Letter from school’s Homeless/Migrant Liaison. • Letter must include child’s name, the date determined homeless, runaway, or migrant, and the liaison’s signature • Maintain on file • This should be updated every year • School’s homeless liaison - https://www.doe.in.gov/elme/mckinney-vento-liaison • School’s regional migrant contacts - https://www.doe.in.gov/sites/default/files/elme/migrant-regional-center-contact-information-dec-2018.pdf

34. Income Application • If an application has a case number and income recorded, process using the case number. • Check that the application is complete • Must include Social Security # or checked no SSN box • Signature in the correct box • Identifying a Complete Application Fact Sheet: https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training • Textbook Signature – should not delay approval • Only convert to annual income if multiple pay frequencies. • Flag error prone applications*

35. No Income Application The free/reduced application allows households to leave any fields blank to indicate they have no income to report. If a household leaves all income fields blank – approve based on face value and verify for cause. Ask how are they meeting their bills? Where are they living? Ask for household to provide Collateral Contact No Income Fact Sheet available here: https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training.

36. School Employee Application If the application appears to be complete, approve based on face value. If the salary information shows a misrepresentation of income on the application, verify for cause. Always talk with your school legal counsel to determine the best way to handle questionable school employee applications. SP 13-2012 Verification for Cause in the School Meals Program School Employee Fact Sheet: https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training.

37. Notification/Appeals

38. Direct Certification Notification • DC Notification Letter must include: • List of children eligible for free or reduced benefits • An explanation of extended eligibility and how to notify LEA of any additional children in the household not listed on the notification • No further application is necessary • Reduced DC Notification must include: • Information about submitting an application if they believe they qualify for free benefits. • Allow households to opt out! • Full non-discrimination statement

39. Application Notification • Approval Notification for Applications • Households must be notified, either in writing (letter, email, text) or verbally, of their eligibility status. • Denial Notification for Applications • Households must be notified in writing of the denial (letter or email) • The notification page of an online system does not meet this requirement • Notification must advise the household of: • Reason for denial of benefits • Right to appeal • Instructions on how to appeal • Ability to reapply for benefits at any time during year

40. Notification Clarification • If a household was denied and reapplies for benefits – process the application. • If approved for benefits - flag the application and verify for cause. • If a household reapplies after not responding to a verification request the same school year - request verification documentation before processing the application. • If a household reapplies the following year after not responding to a verification request the year before – process the application. Then verify for cause. • Check out the Notification of Free and Reduced Eligibility Fact Sheet: https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training

41. Appeal Process • Appeal Fact Sheet - https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training • Households can: • Appeal their f/r price eligibility determination • Make an oral or written request for a hearing • Be assisted or represented by an attorney, advocate, or other person • Examine the documents and records supporting the decision being appealed before the hearing • Request a school conference prior to a formal hearing

42. Transferring Eligibility Transferring Eligibility Fact Sheet: https://www.doe.in.gov/nutrition/free-and-reduced-fact-sheets-and-training

43. Transferring During 30 day Carryover • Students transferring from another school can continue to receive their eligibility benefit from the prior school year for the first 30 operating days of the new school year (or until their new application has been processed). • Documentation can include: • The notification letter from the previous school year; or • An email from the original school stating the student was approved for free or reduced benefits the pervious school year; or • A copy of the processed application from the original school (school must review to make sure it was approved correctly).

44. Transferring Mid-Year within a LEA • Non-Provision to Non-Provision • Required to immediately accept the eligibility determination from the student’s former school. • Provision to Non-Provision • Required to give the children free reimbursable meals for up to 30 operating days, or until a new eligibility determination is made (whichever comes first). • Non-Provision to Provision • Required to immediately apply free benefits due to the school’s Provision (1, 2, 3, or CEP) status.

45. Transferring Mid-Year Between LEAs • Non-Provision to Non-Provision • Required to immediately accept the eligibility determination from the student’s former school. • Provision to Non-Provision • Maygive the children free reimbursable meals for up to 30 operating days, or until a new eligibility determination is made (whichever comes first). • Effective July 1, 2019 – required to provide free reimbursable meals for up to 30 operating days or until a new eligibility determination has been made, whichever comes first. • Non-Provision to Provision • Required to immediately apply free benefits due to the school’s Provision (1, 2, 3, or CEP) status.

46. Verification for Cause

47. Flagging Suspicious Apps Last year’s non responders reapplying Food Stamp/TANF number not identified in DC No income indicated on the application Questionable school employee application Verification for Cause Fact Sheet - https://www.doe.in.gov/nutrition/snp-verification

48. Verification for Cause Can be conducted any point during the school year Follow normal verification process Send home a letter requesting verification documentation Keep track for Verification Summary Report Verification for Cause Fact Sheet: https://www.doe.in.gov/nutrition/snp-verification

49. Verification Process

50. Issue 1:Not pulling the right # of applications If using a software or manually counting the applications- be sure the system is counting the total number of approved applications on file as of October 1st. Always round up!