Verification Reporting

Verification Reporting FNS 742: School Food Authority (SFA) Verification Collection Report FNS Verification Collection Report 20130923

Objectives • At the completion of this presentation you will be able to: • Define verification and its purpose • State when there are exceptions to the requirement • Be able to correctly identify your sample pool and sample size • Use verification for cause when appropriate • Complete post selection procedures • Identify acceptable sources for verification • Complete verification and follow proper record-keeping procedures • Complete an appeal and hearing process/procedure FNS Verification Collection Report 20130923

Verification: What is it? What is it? • Verification is confirmation of eligibility for free and reduced price meals under NSLP and SBP. Guidance • National School Lunch Act, Section 9 • 7 CFR 245.6a “Verification Requirements” • 7 CFR 210.15 “Reporting and Recordkeeping” • Eligibility Manual for Schools (August 2013) FNS Verification Collection Report 20130923

Exceptions:When is Verification Not Required • Students who have been directly certified through the monthly electronic downloads for foster children, SNAP/KTAP and Medicaid recipients. • Students appropriately documented by the district as eligible migrant, homeless or in a federally funded Head Start or Even Start Program. • Residential RCCI students • Schools participating only in the Special Milk Program • Provision (includes CEO) schools do not complete all verification requirements. FNS Verification Collection Report 20130923

Key Verification Dates District Level State Level October 1st- SFAs determine the total number of applications on file for the current school year as of October 1 October 31st- SFAs determine the total number of students enrolled for the current SY as of this date November 15th- SFAs complete verification activities February 1st- SFAs report verification results to the SA March 15th- SAs submit compiled SFA results to FNS March-June- FNS reviews data and follows up with SA FNS Verification Collection Report 20130923

A Look at the Verification Process FNS Verification Collection Report 20130923

Know Your Verification MethodStarting off: Determine Sample Pool • LEA may begin verification activity once the application process is underway and approved applications are on file. • LEA may project number of applications to verify based on previous year, HOWEVER the actual sample size must be determined based on actual applications on file as of October 1 of the current school year. • The total number of applications on file as of October 1 of the current school year is your SAMPLE POOL. FNS Verification Collection Report 20130923

Know Your Verification MethodEstablish the Sample Size • Calculate the sample size- or the number of applications that must be verified. • Always round upward to the nearest whole number. • At least one application must be verified. • You may not verify more or less than required. • Verification “for cause” is done in addition to what is required. FNS Verification Collection Report 20130923

Select Application for Verification Based on MethodMethods of Verification • There are three methods for verification. • Each SFA is required to use the STANDARD method unless otherwise approved. • Check CNIPS for your approved method. Standard Verification Select the lesser of: • 3% of all applications approved by the LEA as of October 1 of the current school year selected from error prone applications. • 3,000 error prone applications approved by LEA as of October 1 of the current school year. FNS Verification Collection Report 20130923

Select Application for Verification Based on MethodHow to Qualify for an Alternate Sample Size:Two Ways 1. Lowered Non-Response Rate • Any LEA may use an alternate sample size for any school year when its non-response rate for the preceding school year is less than 20%. 2. Improved Non-Response Rate • An LEA with more than 20,000 children approved by application as eligible for free or reduced meals as of October 1 of the school year may use an alternate sample size when it’s non-response rate for the preceding year is at least ten percent below the non-response rate for the second preceding school year. You must have prior state approval annually via CNIPS to use an alternate sample size. FNS Verification Collection Report 20130923

Select Application for Verification Based on MethodMethods of Verification Alternate One Select the lesser of: 3,000 of all applications selected at random from applications approved by the LEA as of Oct. 1 of the current school year or 3% of all applications selected at random from applications approved by the LEA as of October 1 of the current school year Alternate Two The sample size equals the lesser of the sum of: 1,000 of all applications approved by the LEA as of October 1 of the current school year selected from error prone applications OR 1% of all applications approved by the LEA as of October 1 of the current school year, selected from error prone applications PLUS THE LESSER OF: 500 applications approved by the LEA as of October 1 of the current school year that provide a case number in lieu of income information OR ½ of 1% of applications approved by the LEA as of October 1 of the current school year that provides a case number in lieu of income information FNS Verification Collection Report 20130923

Select Application for Verification Based on MethodVerification for Cause • LEA’s have an obligation to verify all questionable applications. • Complete applications that indicate a student is eligible to receive free or reduced price benefits must be approved. Verification begins after the approval. • To verify an application for cause, the LEA must send a letter informing the household that it must submit eligibility information for continued benefits. • Any household that fails to submit information or if the information does not support the initial determination, the LEA must sent a notice of adverse action. FNS Verification Collection Report 20130923

Conduct Confirmation Reviews/Replacement ApplicationsPost Selection Procedures • Prior to contacting the household for verification, the LEA will: • 1. Conduct a Confirmation Review • An LEA official, other than the official which made the original determination, must review each application selected for verification to ensure that the initial determination is accurate. This official must SIGN and DATE the application after confirming. FNS Verification Collection Report 20130923

Conduct Confirmation Reviews/Replacement ApplicationsReplacing Applications • After confirmation reviews, the LEA may replace up to 5% of applications selected. • Applications must be replaced with another approved application selected on the same basis. • Newly chosen applications must go through the confirmation review process. • When 5% of LEA applications is less than 1, 1 application may be replaced. • All result calculations should be rounded up to the next whole number. LEA’s may want to replace selected applications if it believes that the household would be unable to satisfactorily respond to the verification request. FNS Verification Collection Report 20130923

Notify Household for VerificationIt’s now time to notify the household • The LEA is required to send a letter informing them of their selection for verification and the types of information acceptable to the LEA. • Prototype is listed on the SCN website along with all required information. FNS Verification Collection Report 20130923

Notify Household for VerificationAcceptable Source Documentation • Written evidence: pay stubs, award letters from welfare department • Written evidence must contain the name of the household member, amount received, frequency received, and date income was received. • EBT cards cannot confirm eligibility in SNAP. • Collateral Contact- can provide information regarding household income, but should only be requested when written evidence is insufficient. • Agency Records: may be used when the LEA has legal access. Acceptable documentation of income or receipt of assistance may be provided for any point in time between the month prior to the application and the time the household is required to provide income documentation. FNS Verification Collection Report 20130923

Notify Household for VerificationNo Income Reported • If a household indicates zero income, the LEA must request an explanation of how living expenses are met. • The LEA may request additional written documentation or collateral contacts. FNS Verification Collection Report 20130923

Conduct VerificationNow Verify the Information • At this point it is time to actually verify the information as submitted by the household to ensure that the LEA’s determination of the student’s status is accurate. • Also, determine if a follow-up is needed with the household to gain more information. FNS Verification Collection Report 20130923

Conduct VerificationFollow-Up Contact • The LEA must make at least one follow-up attempt to contact the household when the household does not adequately respond to the LEA’s request. • Follow-up may be in writing or via telephone. • LEA’s must ensure households are provided adequate language assistance and understand the need to respond to verification request. • Always keep documentation. • LEA’s must make a follow-up attempt when the household: does not respond, submits insufficient written evidence, does not designate collateral contacts and collateral contacts are unable or unwilling to provide requested evidence. FNS Verification Collection Report 20130923

Determine Verification ResultsVerification Completion FNS Verification Collection Report 20130923

Determine Verification ResultsVerification Result and Household Notification • The LEA must notify the household once the verification process is complete. • A prototype is available on the SCN website. FNS Verification Collection Report 20130923

Determine Verification ResultsA Change in Benefit Status? Notice of Adverse Action • All households for whom benefits are to be reduced or terminated must be given 10 calendar days’ written advance notice of the change. Verification Result = Higher Benefits • If verification results in higher benefits, the change is effective immediately and must be implemented no later than three operating days. • Parents should be notified through whatever channels the LEA uses to notify the household of approval of benefits. FNS Verification Collection Report 20130923

Determine Verification ResultsAppeal and Hearing Procedure • Appeals during the 10 calendar day notice period, the LEA must continue to provide benefits for which the child was originally approved until a final determination is made. • Appeals after the 10 calendar day notice period, a reduction or termination of benefits must take place no later than 10 operating days after the 10 day calendar notice period or hearing official’s decision. Households affected by a reduction or termination of benefits may reapply for benefits at any time during the school year. FNS Verification Collection Report 20130923

Report Verification to SCNRecord Keeping • Documentation must be kept to demonstrate compliance with the verification requirements. • The LEA must also be able to demonstrate compliance with the confirmation review requirements. • For each application, the LEA must keep records of the source of information used to verify the application. For example: • Copies of relevant correspondence between households and LEA can be documents submitted by household or reproductions of documents. FNS Verification Collection Report 20130923

Report Verification to SCNRecord Keeping • LEA’s should also record any change in eligibility as a result of verification procedures, the reason for the change and the date the household was notified. • Finally, LEA’s should also record: • Any additional information necessary to show the effort made by the LEA to meet verification requirements • Title and signature of the verifying official • Criteria for replacing applications for verification LEA’s will be asked to provide this information for each school selected for an Administrative Review. FNS Verification Collection Report 20130923

Report Verification to SCNCNIPS • All verification reporting to SCN with be conducted via CNIPS and the FNS 742 form. • Training is available on this process. FNS Verification Collection Report 20130923

In Conclusion • For further information regarding verification refer to: Eligibility Manual for School Meals: Determining and Verifying Eligibility, August 2013. FNS Verification Collection Report 20130923

SCN • The U.S. Department of Agriculture (USDA) 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 if 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 (in Spanish). • USDA is an equal opportunity provider and employer. FNS Verification Collection Report 20130923

Verification Reporting