A Primer on Verification Procedures

1. A Primer on Verification Procedures August 14, 2018 Laconia Middle School Laconia, NH Nancy Bradford-Sisson Patty Carignan Marty Davis NH Department of Education Office of Nutrition Programs and Services

2. Eligibility Manual for School Meals, July 2017 In the Eligibility Manual for School Meals, July 2017, Section 6: Verification, you will find information on: • The initial steps for verification; • Application selection procedures (Including available sample sizes) • When to review questionable applications; • Required procedures for notification and follow up; • Allowable sources for verification; and • How to determine if verification is complete

3. Terms to Know Verification Effort Direct Certification Direct Verification Verification for Cause

4. What is verification? Verification is the confirmation of the eligibility status for free and reduced price meals served to children in your SAU/RA under the National School Lunch Program. • Verification is only required when eligibility is determined through the application process, not through direct certification conducted with an Assistance Program or with agencies or officials who documented Other Source Categorical Eligibility. • Please note: Copies of household applications are to be counted only once for verification purposes.

5. When is verification? Verification is required to be completed every year by the SAU/RA by November 15 or by December 15 with an approved State Agency waiver. Note: The Verification Effort is not determined on school or individual district applications but on the SAU/RA as awhole.

6. What is Direct Certification? Direct certificationmeans: • Determining a child’s eligibility for free benefits based on documentation obtained directly from appropriate State or local agencies or other authorized individuals. • Direct certification of a child’s eligibility status should not involve the household. The communication exchange should be between an appropriate agency and the State agency, SAU or school. • Directly certified students are not part of the SAU/RA verification pool.

7. When is Direct Certification not Direct Certification? • If a household fills out a free and reduced price school meals application for meal benefits and provides a food stamp number AND • if that household does not appear on a direct certification list, that household cannot be considered directly certified and remains in the verification pool.

8. The Verification Effort andDirect Certification Verification efforts are not required for: • Directly Certified* children • Categorically Eligible children who are designated: • Foster • Migrant • Homeless • Runaway • Head Start • Schools electing Community Eligibility Provision (CEP) if all schools within the SAU participate in CEP. • Mixed CEP SAUs/RAs are still required to complete the Verification Summary for School Food Authority – FNS 742 *Documentation received from the State or local agency responsible for the administration of the Food Stamp Program (SNAP/TANF) indicating those children as eligible for direct certification. Foster, Migrant & Homeless children are now also included on the monthly direct certification list in New Hampshire.

9. What is Direct Verification ? Direct verificationis the use of records from public agencies to verify children’s eligibility for free or reduced price meal benefits. • If information provided by the public agency through direct verification of an application indicates a child listed on the application is participating in one of the assistance programs, no additional verification is required. The eligibility status of the application is considered verified. • If information provided by the public agency does not verify eligibility of the household application, the SAU/RA must proceed with regular verification effort activities.

10. The Verification Effort and Direct Verification • The Verification Effort is required. • Direct Verification is not required. However, State Agencies and LEAs are encouraged to expand the use of Direct Verification. • Direct Verification can be an activity of the Verification Effort. • Direct Verification must be conducted prior to contacting the household for documentation.

11. What is Verification for Cause? Verification for cause are applications that are questionable. • Done on a case-by-case basis. • Applications must be processed and approved for the correct meal benefit. • Only after the determination of eligibility has been made can the SAU/RA begin the verification for cause process. • The SAU/RA has an obligation to verify all questionable applications. (verification for cause) • SAUs/RAs must send the household a letter explaining that it must submit verification of eligibility information with the application for continued services.

12. Verification for Cause • Any household that fails to submit the requested information or submits information that does not support the initial determination of eligibility, must be sent a notice of adverse action by mail or by email. • Once households have been requested to provide documentation for cause, the SAU/RA must complete the verification process for these households.

13. Confirmation Reviews Prior to any other verification activity, a confirmation official, must review each approved application selected for verification to ensure that the initial determination was accurate. This individual cannot be the one who made the initial eligibility determination. This requirement is waived if: • the SAU/RA uses a technology-based system that demonstrates a high level of accuracy in processing an initial eligibility determination. • The SAU/RA must contact the State Agency to determine if its system qualifies for a waiver. • the SAU/RA conducts a confirmation review of all applications at the time of initial eligibility determination.

14. Depending on the outcome of each confirmation review, the SAU/RA takes one of the following actions:

15. Replacing Applications • After completing the confirmation reviews, the SAU/RA may, on a case-by-case basis, replace up to five percent of applications selected. • In the SAUs/RAs where five percent of total applications result in less than one, one application may still be replaced. All results of the five percent calculation are rounded up to the next whole number. • Any application removed from the original selected pool must be replaced with another approved application selected on the same basis, that is, an error prone application must be substituted for a withdrawn error prone application. • The newly selected application must then have a confirmation review and signature.

16. Verification Effort Procedure

17. Verification Effort Procedure The SAU/RA must: • Select a sample pool of all free and reduced price school meals applications, from the entire SAU/RA, that were on file and approved as of October 1st. • Multi district SAUs/RAs must complete the Verification Effort by SAU/RA – (not by district). • The verification sample pool is based on the number of applications, not the number of children represented. • Confirmation Reviewer determines the accuracy of the original eligibility determination for the meal benefit of the selected applications before the Notification of Selection letters are sent home to the families.

18. Requirements For Application Selection During the verification process for 2018-2019, the SAU/RA must use the standard sample size (error prone*) basedon the sample pool. • *Error prone means total household income within $100 per month or $1,200 per year (up or down) of the applicable Income Eligibility Guidelines (IEG). • SAUs/RAs may not verify more or less than the required minimum sample. • If 3% of error prone applications selected results in fractions or decimals, application selection must be roundedupwardto the next whole number. • SAUs/RAs cannot discriminate in the selection of applications to be verified. • All questionable applications are verified – verification for cause • Complete verification by November 15th of each year, unless a waiver was requested by the SAU/RA and granted by the State Agency, which would shift the deadline to December 15th.

19. Verification Effort Timeline October 1st– Compile all approved applications. October 10th– Submit the Verification Effort Plan of Action form to the Office of Nutrition Programs and Services to request waiver of the November 15th deadline date, if needed. Must be signed by the Superintendent of Schools or the Facility Director of an RCCI. October 15th– Select from the applications for verification based on the error prone sampling method and send the following applicable documents to the household: (This can happen on October 1st) • Notification of selection and verification of information form; • Letter to the employer; and • Letter to Social Security Office • If applicable, fax the food stamp number direct verification form to the food stamp office.

20. Verification Effort Timeline November 15th– Complete the verification effort on applications unless there is an approved State Agency waiver. Send the Notice to Households of Results of Benefits. Place all completed verification documents on file. December 15 – If State Agency approved waiver granted, complete the verification effort on applications. Send Notice to Households of Results of Benefits. Place all the completed verification documents on file. December 31st– Complete the SAU/RA on-line FNS-742 SFA “Verification Summary Collection Report” into the DOE Single Sign-On System.

21. Method of Sampling:Standard Sample Size (Error Prone) The Standard Sample Size (Error Prone) is to be used in NH for choosing 2018-2019 Free & Reduced Price School Meals Applications that are to be verified. Remember: fractions or decimals must be roundedupto the next whole number. Example 1: 3% of SAU/RA error prone applications is 5.1. SAU/RA must verify 6 applications.The SAU/RA sample size may increase due to applications verified for cause. Verification for cause applications are included in the initial sample size count. They are not to be in the pool used to pull random selected applications form

22. Standard Sample Size • Use any method giving each application an equal chance of being selected, including both SNAP/TANF applications and income applications. (Reminder: do not select any Directly Certified students). • Randomly verify a minimum of the lesser of 3% or 3,000 of the total number of SAU/RA approved error prone applications on file as of October 1st. • At least one application must be verified. Note: There may not be enough applications that meet the error prone criteria. When this happens, the SAU/RA must select, at random, additional approved applications from the sample pool to complete the required sample size. In other situations, the number of error prone applications may exceed the required sample size. When this happens, the SAU/RA must randomly select the required number of applications from the availableerror prone applications.

23. Household Notification • All households that have been selected as part of the verification process must be notified that they are required to provide information. • Refer to the Eligibility Guidance for School Meals Manual (July 2017; pg. 106) that outlines what must be included in the household notification letter. (A sample letter is on the ONPS website.) • The SAU/RA must complete the verification process for all households that have been notified of their selection for verification.

24. Methods of Verification There are 3 methods of verifying: 1. Written Evidence 2. Collateral Contacts 3. Agency Records

25. Methods of Verification 1. WRITTEN EVIDENCE • Written evidence regarding income: Acceptable written evidence contains: • name of the household member; • amount of income received; • frequency received; and • the date the income was received. • Written evidence regarding categorical determination: Acceptable written evidence contains: • A written statement from the Food Stamp (SNAP) or TANF agency that specifies that the child is a member of a household currently receiving benefits.

26. Methods of Verification 2. Collateral Contact Collateral Contact is a person who is outside of the household but is: • Knowledgeable about the household; and • Can confirm household’s income or Food stamp (SNAP/TANF) status. All collateral contacts may be written or oral (example: taken over the phone) and must be documented, dated, and initialed by the determining official. Question: Are EBT cards an acceptable form of documentation? Answer: No, copies of EBT cards are not an acceptable form of documentation.

27. Methods of Verification 3. Agency Records – Similar to Direct Verification Household eligibility may be confirmed through the use of information maintained by other government agencies to which the State agency, SAU/RA or school has legal access. Contacting the local Food Stamp or welfare office is only done as a last resort. • Work with the household as much as possible to verify the information provided on the school meals application. If a household does not respond, Direct Verification does not have to be completed. • The eligibility status of the household would then become changed due to non-response.

28. Household Application Chosen for Verification with “Zero” Income If a household is selected for regular verification or verification for cause and the application indicates zero income, the SAU/RA must request an explanation of how living expenses are met and may request additional written documentation or collateral contacts. For example: • The collateral contact may be asked to document the duration and type of assistance that is provided to the household. Currently, any income field left blank is a positive indication of no income and certifies that there is no income to report. When no income is provided for any household member, the application is still considered complete.

29. Completion of Verification Effort The Verification Effort is completed when household’s application eligibility for the level of benefits for which it was approved shows: • the household submitted adequate written evidence or collateral contact corroboration of income or categorical eligibility • the household indicates, verbally or in writing, that it no longer wishes to receive free or reduced price benefits • the application provided case number has been validated by the public agency When verification effort results in a higher level of benefits, the change is effective immediately, but must be made within 3 days. • Master roster and point-of-service (POS) must be updated with new eligibility status.

30. Completion of Verification Effort When verification effort results in the benefits being reduced or terminated, a letter of adverse action is sent to households giving 10 calendar daysadvance written notice (grace period). First day of the grace period is the day the notice was sent. A notice of adverse action must advise the household of the following: • Change in benefit; • Reason for the change; • An appeal must be filed within the 10 calendar days advance notice period to ensure continued benefits while awaiting a hearing and decision; • Instructions on how to appeal; • The household may reapply for benefits at any time during the school year; and • Households that were terminated because no member was receiving benefits from an Assistance Program may submit an application containing household names and income information and provide written evidence of current household income.

31. Completion of Verification Effort If a household appeals the determination decision within the 10 calendar day grace period: • the SAU/RA must continue to provide benefits to the household until the hearing is held and determination is made. • The SAU/RA may continue to claim reimbursement at that level during this period. If a household does not appeal within the 10 calendar day grace period: • reduction or termination of meal benefits must take place immediately after the 10 calendar day grace period.

32. If the hearing official rules that the benefits must be reduced, the actual reduction or termination of benefits must take place no later than 10 calendar days after the hearing official’s decision. • Master roster and point-of-service (POS) must be updated with new eligibility status. • Households affected by a reduction or termination of benefits may reapply for benefits at any time during the school year.

33. Households Failing to Submit Required Documentation SAUs/RAs must make at least one follow-up attempt to contact households who have not adequately responded to the request for verification effort. • Attempt may be in writing via regular mail, email, by telephone or text. SAUs/RAs must document that a contact was attempted. • SAUs/RAs must inform the households that failure to supply the necessary information will result in termination of benefits. • Verification is complete when notification of adverse action (change of benefit) is sent.

34. Reapplying for Benefits • Households that are affected by a reduction or termination of benefits due to a non-response to the verification request, may reapply at any time during the school year; however, • These are not considered new applications. Households must submit income eligibility documentation or proof of participating in the Food Stamp SNAP/TANF programs as originally requested during the verification effort process. • This will start the re-verification effort process with the submitted documentation.

35. Record Keeping To demonstrate compliance with the verification requirements when SAUs/RAs are reviewed by State or Federal officials, SAUs/RAs must keep and maintain all verification effort documentation to demonstrate compliance in case of an applicant’s appeal. Documents include: • summary of the verification efforts; • selection process; • total number of applications on file on October 1; and • percentage/number of applications that are or will be verified by November 15. The SAU/RA must also demonstrate compliance with the confirmation review requirements and provision of a no-cost telephone number for assistance in the verification process.

36. Record Keeping For each application, the following source of information submitted from the household for the verification effort must be kept such as: • Food stamp (SNAP/TANF) office information • Wage/pay stubs • Collateral contacts All documents must be kept on file for 3 years plus the current yearunless the SAU/RA is under an on-going audit.

37. Record Keeping Copies of information that must be documented: • All relevant correspondence between households selected for verification and SAU/RA. • Verification of documents submitted by the household. • Any changes in meal benefit eligibility status, reasons and date of change. SAU/RA must keep: • Verified applications readily retrievable by school; and a copy of the verified application at the SAU/RA.

38. Office of Nutrition Programs and Services Questions or Comments NSLP Contacts: Cheri White: Cheri.White@doe.nh.gov 271-3860 Kathryn Hodges: Kathryn.Hodges@doe.nh.gov271-3861 Nancy Bradford-Sisson: Nancy.Bradford-Sisson@doe.nh.gov 271-3864 Patty Carignan: Patricia.Carignan@doe.nh.gov 271-3862 Marty Davis: Marty.Davis@doe.nh.gov 271-3647