THE VERIFICATION PROCESS
Ver if i cat io n Over view At or around the beginning of the program year: The school collects student eligibility by direct certification matches and also by collecting household applications. The school processes application information at face value and approves the child for meal benefits. Oct. 1 Complete verification activities You have this long to COMPLETE verification! Oct. 1- Nov. 15 Starting Oct. 1, count all of the applications (certified at face value) that did not match on Direct Certification. Use this total to calculate how many applications you will need to verify. You have until Nov. 15 to verify these applications. Nov. 15 Submit report Jan. 10 Verification report is due! You have this long to REPORT verification! January 10 Verification report must be submitted electronically through CNP Verification Summary form. 2
What is Verification? The process of confirming the eligibility for free and reduced-price meals under the National School Lunch Program MUST include either confirmation of income eligibility or confirmation that the child is eligible to receive benefits from assistance programs Verification is performed on a percentage of applications, NOT all the applications on file 3
Which SFAs are Required to Co mpl ete the Verification Process? 1. All schools participating in school meal programs who utilize the free and reduced application process 2. Residential Child Care Institutions (RCCIs) that have day students (verification completed for day students only) CEP or RCCIs without day students MUST complete the online Verification Summary Form (FNS 742) but do not have to perform the verification process. 4
Who is I nvolved in the Verification Pro ce ss? Collection Officials Determining Official: Check to make sure the application is complete; following up on applications with missing information; calculate and/or evaluate the application for eligibility; assign and record f/r/p status on EACH application or batch sheet Confirming Official (Pre-Verifying): Responsible for confirming the accuracy of the original f/r status determination made on applications that have been selected for verification. This individual can NOT be the same person as the Determining Official; can list the software system as the confirming official but a person should check behind the computer. 5
Who is I nvolved in the Verification Pro ce ss? Collection Officials (cont.) Verifying Official: Responsible for the annually-required verification process, and any follow-up which must be done to complete the process. This may be the same person as the Determining OR Pre-Verifying Official. Hearing Official: A business manager, superintendent or child welfare manager to serve as a separate, unbiased hearing official. This official is responsible for hearing any appeals resulting from the verification process. It is important that this individual is not involved in any way with the approval or verification of the Meal Benefits Applications. Only applications selected for verification require a signature from the Pre-Verifying (Confirming) Official and the Verifying Official. 6
St e p s t o Ve r i f i c a t i o n Step 1: Select the sample pool (as of October 1) Step 2: Establish sample size Step 3: Conduct confirmation review Step 4: Begin verifying the selected, confirmed applications IN WRITING Step 5: Submit results on verification summary report (Due January 10) 7
St e p 1 : Se l e c t t h e Sa m p l e Po o l SFAs are required to verify approved applications on file as of October 1 (If October 1 falls on a weekend, use the next operating day to establish the sample pool) Count all of the applications (certified at face value) that did NOT match on Direct Certification Students approved for free without an application are NOT subject to verification Any applications pulled for verification for cause would also NOT be counted in the sample pool 8
Who i s Subject to Verification? Those Households with a free or reduced-priced APPROVED application on file as of October 1 are subject to verification, including: 1. Income applications: Free Income Reduced-Priced Income 2. SNAP applications ***Denied/paid applications are not included*** 3. Foster child applications If the child is categorically eligible under DC, foster, homeless, migrant or runaway by agency records and the parent submitted an application, the application is NOT subject to verification---categorical free eligibility supersedes the application. 9
Students NOT Included in Verification In some cases, students are determined Free based on agency documents, not a f/r application, and therefore are not subject to verification: 1.Children who have been certified under Direct Certification (and their siblings) at any point in the current SY 2.Children in RCCIs except for day students 3.Foster Children that are directly certified (documentation was provided from DCFS to school/central office with no HH involvement) 4.Children deemed homeless, migrant or runaway by the appropriate official 5.Children enrolled in a Head Start or Even Start program 10
St e p 2: E st a b l i sh i n g t h e Sa m p l e Si z e Most SFAs will use the standard (basic) method If qualified, one of two alternate samples, random or focused, may be used 11
The St a n d a r d (Basic) Method Multiply the total free and reduced-priced applications on file as of October 1 by 0.03 to get a 3% Sample Size Round up to get a whole number of applications to pull for Verification Select the 3% of free/reduced-priced applications from error prone applications Error-prone applications are those applications with an income listed within $100/month ($1,200/year) above or below the free eligibility limit or $100/month ($1,200/year) below reduced-price eligibility limit. * You may want to flag all error prone apps during the approval process (Determining Official) *In cases where there are not enough error-prone applications to comply with the required sample options, SFAs must randomly select additional applications to fulfill the 3% requirement. 12
Ba si c Met ho d Exam pl e You have 210 approved applications as of Oct 1 You need to verify seven applications by Nov 15 210 x.03 = 6.3 or 7 applications These seven applications must be selected from error-prone applications If you have only six error prone apps, the seventh is selected randomly from the rest of the applications If you have eight error prone apps, you randomly select and verify seven of them 13
Alternate One ( R a n d o m ) Me t h o d If qualified to use this alternate sample, an SFA may select 3% at RANDOM from approved applications on file as of October 1 (regardless of error-prone) With the Random Method, error prone applications are not identified for verification selection as done in the Basic/Standard Method Example: For 210 approved applications as of October 1, random selection would be to used to get the seven required for verification. 210 x 0.03 = 6.3 or 7 applications 14
Alternate Two ( F o c u s e d ) Me t h o d The sample size is completed in two parts: 1. All approved applications 2. SNAP applications The sample size for all approved apps is determined by: Taking 1% of all approved apps on file as of October 1 Select these from error prone income applications The sample size for SNAP apps is determined by: Taking 0.5% of all approved SNAP apps on file as of October 1 (case numbers) Example: 245 apps on file as of October 1 with 60 of the 245 being SNAP apps 245 x 0.01 = 2.45 or 3 applications (selected at random from error-prone apps) 60 x 0.005 = 0.3 or 1 application (selected from the 60 available SNAP apps) 15
Which Met ho d Can Yo u Use? Systems with: < 20% non-response rate can use any method for verification > 20% non-response rate must use the Basic/Standard Method MEMO SFS-17-42 16
What i s a No n - Respo nse Rate? Any SFA with a non-response rate for the preceding school year of less than 20% qualifies for using the random or focused methods. The non-response rate is the percentage of approved household applications with no response to the request for verification information. 17
Ver if ication f or Cause SFAs have an obligation to verify questionable applications (for cause) For cause may include, but is not limited to, situations where school officials have knowledge of household circumstances that would lead them to question the information on the application 18
Repl acing Appl icatio ns An SFA may replace up to 5 percent of applications in the selected sample SFAs should consider factors such as household stability and communication difficulties when declining applications Any application removed from the sample must be replaced with another approved application First from error prone, and if not enough error prone, then select randomly from all approved applications 19
Step 3: Conduct Confirmation Review Once the sample has been selected: Applications must undergo a confirmation review by someone other than the determining official (pre-verifying or confirming official) The confirming official reviews ONLY the applications selected for verification to ensure the accuracy of the initial determination This is done prior to contacting households The confirming official must do a confirmation review of each application selected for verification; then sign the application or sign a cover letter to attach to the reviewed applications 20
Respo n si bi l i t i es Fo l l o w i n g a St at u s Cha nge If the initial determination of the application is incorrect and status is changed to paid, the SFA must: 1. Immediately send the household a notice of adverse action 2. NOT verify the application 3. Select a similar application for confirmation and verification 4. Follow the confirmation review procedures for the newly selected application If the initial determination of the application is incorrect, yet the status is changed from free to reduced, the SFA must: 1. NOT correct the household s eligibility status 2. Proceed with verification of this application If the initial determination of the application is incorrect, yet the status is changed from reduced to free, the SFA must: 1. Correct the household s eligibility status 2. Notify the household of the change in benefits 3. Proceed with verification of this application If the initial determination of the application is correct, the SFA proceeds with verification 21
St e p 4 : Beg i n Ve r i f y i n g t h e Se l e c t e d Applicatio ns Inform Selected Households: A letter must be sent to the households informing them of their selection for verification and of the types of eligibility documentation to be submitted. IN WRITING Households are allowed to submit proof of income for any point in time between one month prior to application and the time the verification notice is received. SFAs are encouraged to use the prototype verification forms on the CNP website under forms 22
Directly Verified Applications If households are selected for verification and later found on an October DC match: The application is directly verified and no additional verification is required The directly verified applications will be reported on the online summary form * Directly verified applications do NOT need to be replaced 23
Fo l l o w- Up Requirement SFA sets the deadline for households to reply to the verification process (cannot be after November 15) SFA must follow-up (in writing, by phone, or email) with households who do not (or do not sufficiently) respond by the deadline; households are typically given a small extension with this contact Documentation of each contact must be maintained by the SFA 24
Acceptable Wr itten Evi d ence Income Eligible Categorically Eligible: Assistance Program Categorically Eligible: Other Source Acceptable Written Evidence Contains: The name of the household member Amount of income received Frequency received The date the income was received For example, a pay stub with no dates would be insufficient An official letter or notice indicating that the child or any household member is receiving benefits from that program, such as a notice of eligibility A document from an Assistance Program that does not specify the certification period does not meet the documentation for verification. For example, the identification cards for SNAP or TANF would be insufficient because they usually do not have an expiration date An official letter, notice, or list from the appropriate State agency, social service agency, program office or coordinator, or court 25
When is Ver if i cat io n Co m pl ete? 1. The household submits adequate written evidence that results in no change in status: considered complete for this household. 2. The household submits adequate written evidence which indicates that the children should receive either a greater or lesser level of benefits: considered complete for this household when the notice of adverse action is sent OR household is notified that its benefits will be increased or decreased. 3. The household indicates, verbally or in writing, that it no longer wishes to receive free or reduced price benefits: considered complete when the notice of adverse action is sent. 4. The application provided case numbers and it is determined that no household member is receiving benefits from an Assistance Program: considered complete when the notice of adverse action is sent. 26
Verification Results If verification results in increased benefits, this change is effective immediately and must be implemented no later than 3 operating days from the time of the new determination. If verification results in decreased or terminated benefits, the household must be given 10 calendar days written advance notice of the change. The first day of the 10 calendar day advance notice is the day the notice is sent. If the household does not request a hearing during the 10 calendar days, the reduction or termination of benefits must take place no later than 10 operating days after the 10 calendar day advance notice. If the household requests a hearing during the 10 calendar days, the SFA must continue to provide benefits for which the child was originally approved until a hearing is held and a final determination made. If the hearing official rules that benefits must be reduced, this must take place within 10 operating days after the hearing official renders the decision. If the hearing official rules that benefits must be increased, this must take place within 3 operating days after the hearing official renders the decision. 27
Notice of Ad verse Action The notice shall advise the household of: 1. The change 2. The reasons for the change 3. Notification of the right to appeal and when the appeal must be filed to ensure continued benefits while awaiting a hearing and decision 4. Instructions on how to appeal 5. The right to reapply at any time during the school year 28
Step 5: Submit Results on the Verification Summary Report The Verification report has 5 separate sections All SFAs (including RCCIs) participating in the NSLP must complete Section 1 of the report SFAs using CEP must also complete the applicable sections of the form This section is prepopulated for SFAs by the State Agency 29
Section 1: Total Schools and Enrolled Students Report all School, RCCI, and Student Counts as of October 31. Public, Charter, Private, and Parochial Systems report information for question 1-1 only Residential Child Care Institutions (RCCIs) report information for question 1-2 only, and must also complete the parts a and b of 1-2, as applicable. 30
Se c t i o n 2: SFAs Utilizing Alternate Pro visio ns If your school system will not use CEP in SY 17-18 at any school site, you may skip this section of the Verification Summary Form. COMMON ERROR: SFAs operating partial or system-wide CEP must complete question 2-3 to reflect CEP school data. 31
Section 3: Free Eligible Students Not Subject to Verification If the SFA is implementing CEP system-wide (at all sites) or RCCIs without any day students in SY 17-18, you may check 3-1 and proceed to the next section. Otherwise, this section must be completed (3-2 to 3-3). COMMON ERROR: Many software programs reverse the information in 3-2 and 3-3. Generally, 3-2 should be larger than 3-3. 32
Section 4 : Students Eligible for Free/ Red uced - Applicatio n As of October 31 If after an application is processed, one or more of the students is found on the DC list during verification, the application is not reported here. Instead the children will be reported under Question 3-2. As of October 1 33
Se c t i o n 4 To t a l s T-1 = Total FREE eligible students reported T-2 = Total REDUCED PRICE eligible students reported AUTO-POPULATED FOR SFAs 34
Sect i o n 5: Resu l t s o f Ver if i cat i o n COMMON ERROR: If all schools in the SFA are exempt from verification (such as an RCCI without any day students or if all schools in the SFA are on CEP), the box next to 5-1 should be checked. If 5-1 is checked, no other reporting if necessary and the Verification Summary Form is complete. Otherwise, the SFA must complete questions 5-2 through 5-8. 35
Sect i o n 5: Resu l t s o f Ver if i cat i o n Box 5-6 should be checked if none of the applications selected for verification were directly verified (students on applications for verification were not found on the October DC match). If the check box in 5-6 is checked, skip 5-7. Otherwise, question 5-7 must be completed with the number of applications and number of students directly verified. 36
Sect i o n 5: Resu l t s o f Ver if i cat i o n Results of verification are reported in 5-8. 37
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : Tr a d i t i o n a l SF A Must report information for question 1-1 only Skip section 2. Section 3 must be completed (3-2 and 3-3). Generally, 3-2 should be larger than 3-3. Number of applications as of October 1 and students as of October 31 38
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : Traditional SFA (cont.) The SFA must complete questions 5-2 through 5-8. The number of applications selected (5-5) plus verified for cause (VC-1) must equal the results in 5-8 plus any applications that were directly verified (5-7). 39
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : Pa r t i a l C E P SF A Section 2: Report only the number of schools and the number of students operating CEP in 2-3. Section 1: Public, Charter, Private, and Parochial Systems report information for question 1-1. This is the total number of schools and the total number of students. The remaining sections of the form will be completed the same as the traditional SFAs for the NON-CEP schools ONLY. 40
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : RCCIs WI TH Day Stud ents Number of Schools and Number of students should be reported in 1-2a for the DAY students only. Residential Child Care Institutions (RCCIs) with Day students report information for question 1-2, and must also complete the part a section of 1-2 as well. The remaining sections of the form will be completed the same as the traditional SFAs for DAY students ONLY. 41
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : RCCIs without Day Students RCCIs without any day students should check 3-1. Residential Child Care Institutions (RCCIs) with NO day students report information for question 1-2 only, and must also complete the part b section of 1-2. Box 5-1 should also be checked and the Verification Summary Form is then complete. 42
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : Sy s t e m - Wi d e C E P Section 2: Report the same number of schools and the number of students in 2-3 since all schools are operating CEP. Section 1: Public, Charter, Private, and Parochial Systems report information for question 1-1. This is the total number of schools and the total number of students. 43
Sa m p l e Ve r i f i c a t i o n Su m m a r y R e p o r t : Sy st e m - Wi d e CEP (co n t.) Check 3-1 and proceed to the next section. Since all schools in the SFA are exempt from verification, the box next to 5-1 should be checked. No other reporting if necessary and the Verification Summary form is complete. 44
Submission of Verification Summary Report Why do I need to submit a Verification Summary Report if I do not collect applications/or do verification? SFAs are required to report enrollment information on the verification report Even if the SFA is not required to conduct verification, the summary form is due January 10 45
When is t he ear l iest yo u ca n subm it m y verification report? You can submit the verification report once you have all of the information needed You do not have to wait until January 10 to submit the report SFAs should have all data required to submit the report by November 16 All non-responders as of November 15 will be reported as did not respond and their eligibility status will be changed to paid If you were not required to conduct verification, you are able to submit your verification report as soon as the current year s report is open online This typically occurs around November 15 46
As a Rem i n d er... The Online Verification Summary must be completed by ALL SFAs no later than January 10 The December claim may not be submitted until the Summary is complete The amount of data reported is dependent on whether the SFA is: a RCCI with or without day students a system that fully implements CEP (all sites, breakfast and lunch) a system that collects meal applications or partially implements CEP 47
Ver if i cat io n Over view At or around the beginning of the program year: The school collects student eligibility by direct certification matches and also by collecting household applications. The school processes application information at face value and approves the child for meal benefits. Oct. 1 Complete verification activities You have this long to COMPLETE verification! Oct. 1- Nov. 15 Starting Oct. 1, count all of the applications (certified at face value) that did not match on Direct Certification. Use this total to calculate how many applications you will need to verify. You have until Nov. 15 to verify these applications Nov. 15 Submit report Jan. 10 Verification report is due! You have this long to REPORT verification! January 10 Verification report must be submitted electronically through CNP Verification Summary form 48
This concludes the LDOE Training on Verification. Are there any Additional Questions? You may contact LDOE with any future questions that you may have at (225) 342-9661. 49