Eligibility Guidance Parts 46

1
Eligibility GuidanceParts 4-6

• Directors Conference 2008
• Karen Franklin, SNS
• Arkansas Department of Education

2
Part 4 Income Eligibility

• Economic Unit group of related or unrelated
  individuals living together sharing income and
  expenses.
  
• If two families are sharing the same residence
  but each pays their own bills and has their own
  income, then they are treated as two households.

3
Special Situations

• Adopted Child does not get special treatment in
  the Child Nutrition program. Treated as any
  member of the household (must be on application
  or be on a categorically eligible list).
  Adoption assistance is included as income on
  application.

4
Special Situations

• Joint Custody If
• Child changes residences based on joint custody
• Both households apply for meal benefits
• Different eligibility statuses result
• THEN
• Child receives the greatest benefit level
  regardless of which home he is living in at the
  time of the meal service

5
Special Situations

• Foreign Exchange Student does not get special
  treatment in our program. Must be on application
  of the household in which they reside.
  
• Foster Child each foster child goes on an
  application by themselves as a household of one
  (Part 2 of application)

6
Special Situations

• Foster Child the income that is designated for
  the foster child as personal income is reported
  in Part 2 of the application
  
• Foster Childs Household the foster child IS NOT
  included in the household in which they reside
  (considered a household of one)
  
• Foster Childs Household Income the income a
  household receives for the care of a foster child
  IS NOT reported as income on the application
  (page 50 of Guidance)

7
Determining Household Income

• There are four categories of income on
• the Free and Reduced Price Meal
• Application
• Earnings from work (gross earnings)
• Welfare / child support / alimony
• Retirement / disability benefits
• Any other income

8
Income

• Income is ANY money received on a regular
  recurring basis occasional babysitting and lawn
  mowing jobs would not be reported as income
  
• Must report GROSS income (before deductions for
  taxes, insurance, etc.) on the application

9
Current Income

• Current income means income received by the
  household for the current month, the amount
  projected for the first month the application is
  made or the month prior to the month the
  application was completed. See Special Situations
  on Page 48 of Guidance for guidelines.

10
Special Income Situations

• Seasonal workers when income fluctuates from
  one month to another the household may project
  its annual rate of income and report this amount
  as current income prior year information may be
  used if it is accurate for the current year

11
Special Income Situations

• Self Employed credited with net income and not
  gross income
  
• Net income determined by subtracting business
  expenses from gross receipts (see page 49 of
  Guidance for details)
  
• May use last years income unless current net
  income provides more accurate information
  
• A negative number is reported as Zero income (not
  temporary in this circumstance)
  
• If household receives income from wages AND self
  employment both must be listed separately on
  the application

12
Military Personnel

• Any benefits received in cash, such as housing,
  food or clothing allowances, are considered
  income
  
• In-kind benefits where no cash is provided to the
  household are excluded from income (i.e. Family
  Subsistence Supplemental Allowance FSSA)
  
• Deployed Service Members Only the income that
  is available for the households use is listed as
  income on the application. Deployed Service
  Members may be counted as a member of the
  household on the application.

13
Garnished Wages

• The gross income BEFORE the garnishment is
  considered income for the household on the free
  and reduced price meal application. The fact
  that the income is designated for a particular
  purpose (the garnishment) is not relevant in
  determining eligibility for free and reduced
  price meal benefits.

14
Child Support and Alimony

• Child support and alimony included on the
  application should reflect the amount the
  household actually receives regularly.
  
• Child Support and Alimony are counted as income
  for the receiving household, but are not excluded
  from the income for the household that is paying
  the benefits

15
Public Assistance Payments

• General Assistance payments
• General Relief payments
• Welfare benefits
• Food Stamp benefits are not counted as income to
  the household and should not be listed on the
  application
  

16
Retirement / Disability Benefits

• Pensions or veterans benefits
• Social Security benefits
• Supplemental security income (must be blind,
  disabled or over 65 to receive)
  
• Disability benefits (permanent disability
  benefits not workers compensation)

17
Examples of Other Income

• Rental income (net)
• Interest
• Cash withdrawn from savings
• Regular contributions from persons not living
  with household (i.e. money from parents or
  grandparents, etc)
  
• Estates, trusts, investments
• Any money that is available to pay for childrens
  meals

18
Other Income

• If the household has put a notation on the
  application stating the income received is
  unemployment or workers compensation then the
  application is treated as a Temporary application.

19
Income Exclusions

• Please see Page 50 Income Exclusions, for a list
  of income sources that are excluded from
  consideration in our program. For example
  
• Payments for care of foster children
• Student financial assistance, grants,
  scholarships
  
• Loans that must be repaid
• In kind compensation
• Occasional earnings received on an irregular
  basis
  

20
Income Exclusions

• For a list of federal program income sources that
  are excluded from consideration see Question 2 on
  Page 51 and its answer on Page 52 of the
  Guidance.
• Regularly check the website listed at the top of
  Page 53 for changes to this excluded income list
  
• http//www.ssa.gov/OP_Home/cfr20/416/416-ap01.htm
  

21
Lottery Winnings

• Lump sum payments or large cash settlements are
  not counted as income since they are not received
  on a regular basis.
  
• However, when lump sum payments are put into a
  savings account and the household regularly draws
  from the account for living expenses, the amount
  withdrawn is counted as income.

22
Part 5 Categorical Eligibility

• Member of Food Stamp household
• Enrolled in Federally-funded Head Start program
• Enrolled in a pre-kindergarten Even Start
  program
  
• Enrolled in a Migrant Education Program
• Identified as a Runaway child
• Identified as a Homeless child

23
Categorical Eligibility

• Categorical Eligibility is determined on an
  individual basis. A childs receipt of benefits,
  such as Food Stamps, or participation in a
  program, such as Migrant Education, cannot be
  used to certify other children in the same
  household who are not considered as members of
  that programs assistance unit or who are not
  participants in that program.

24
Food Stamp Households

• The names of children on an application with a
  nine digit Food Stamp case number should be
  checked against the Direct Certification list
  sent to the LEA in August of the current school
  year. If all students on the application are on
  the Direct Certification list then the
  application should be put into a Duplicate
  Applications file and the application should be
  disregarded. This will be discussed further in
  the next part (Part 6) of this presentation.

25
Food Stamp Applications

• Any application with a Food Stamp case number
  must have the boxes checked next to each
  students name that is considered part of the
  Food Stamp household. Any name that does not
  have the box checked cannot be considered part of
  the Food Stamp household without further contact
  with the family.

26
Food Stamp Applications

• If a Food Stamp case number application does not
  have the box checked for each student on the
  application, then the verifying official MUST
  contact the household to determine if the
  household receives food stamps for that child.
• If the household does receive food stamps for
  that child, then the contact should be
  documented, the box should be checked and the
  student allowed free meals.
• If the household does not receive food stamps for
  that child, then the contact should be documented
  and the household must supply income information
  in order for the LEA to determine the eligibility
  status based on income of the student(s) that
  does not receive food stamp benefits.

27
Head Start Programs

• NEW RULE Children enrolled in federally funded
  Head Start programs are categorically eligible
  for free meals.
  
• The Director of the Head Start Program can
  furnish a list of enrolled students to the
  verifying official. The list must have
  
• The names of the students enrolled,
• The effective date of the list, and
• The signature of the program director. (See
  Appendix H of the Guidance)

28
Even Start Programs

• NEW RULE Children enrolled in federally funded
  Even Start programs are categorically eligible
  for free meals.
  
• The Director of the Even Start Program can
  furnish a list of enrolled students to the
  verifying official. The list must have
  
• the names of the students enrolled,
• the effective date of the list,
• a statement that the program is a
  Pre-kindergarten, and
  
• the signature of the program director (See
  Appendix H of the Guidance)

29
Policy Statement reporting of Child Nutrition
Contacts

• The LEA reports to CNU, ADE the LEAs designated
  Migrant Program Coordinator and Homeless /
  Runaway Liaison each year as part of the Policy
  Statement. Please make sure the person reported
  on the 2008-09 CN Contact Information Page of the
  Renewal of Policy Statement is the same person
  that is completing the appropriate categorically
  eligible lists.

30
2008-2009Child Nutrition Contact Information
Page(Must be attached to Renewal of Policy
Statement)

• School District
• LEA Number
• Superintendent
• Child Nutrition Director

• District Homeless / Runaway LiaisonName of
  person that is the Homeless Liaison for the
  school district ____________________________Migr
  ant CoordinatorName of person that is the
  Migrant Coordinator ________________________
  Phone number _______________

31
Migrant Education Program

• Students listed by the Migrant Education Program
  coordinator are considered categorically eligible
  for free meals.
  
• The list must have
• the names of the students enrolled,
• the effective date of the list, and
• the signature of the Migrant Education Program
  coordinator (see Appendix H of the Guidance).

32
Runaway Students

• A child who is identified as a runaway receiving
  assistance through a program under the Runaway
  and Homeless Youth Act (RHYA) by the LEAs
  homeless / runaway liaison is categorically
  eligible for free meals
• The LEAs homeless / runaway liaison may furnish
  a list with
  
• the eligible runaway students names,
• effective date of the list, and
• the signature of the runaway liaison (see
  Appendix H of the Guidance).

33
Homeless Students

• A child who is identified as homeless by the
  LEAs homeless liaison is categorically eligible
  for free meals. See Page 59 of the Guidance for
  definitions of homeless.
• The LEAs homeless liaison may furnish a list
  with
  
• the eligible homeless students names,
• effective date of the list, and
• the signature of the homeless liaison (see
  Appendix H of the Guidance)

34
Homeless Residing with Another Household

• Homeless child is on Homeless List and is
  categorically eligible for free meals
  
• Host family applies by application
• May include homeless family as members of the
  household if host family provides financial
  support to the homeless family
  
• but MUST include any income received by homeless
  family
  
• Determine eligibility for host family in
  traditional manner

35
Duration of Categorical Eligibility

• Due to year long eligibility, households are not
  required to report changes in categorical
  eligibility status.
  
• If a household voluntarily reports changes the
  LEA must inform the household that the students
  are eligible to continue to receive meal benefits
  for the remainder of the school year.
• If the household wants to decrease their benefits
  please refer to Part 3, Section L. Changes in
  Household Circumstances.

36
Transferring Categorically Eligible Benefits
between LEAs

• Categorical determination can be transferred by
  letter from the transferring LEA to the receiving
  LEA.
  
• The letter must be on school district letterhead,
  
  
• Must state the method of categorical
  determination (i.e. Migrant, homeless, etc.), and
  
  
• be signed and dated by an official of the
  transferring LEA.

37
Notice to Household of Categorical Eligibility

• The Forms and Letters Packet of the Policy
  Statement Renewal for 2008-09 has included a NEW
  form for Notice to Households of students that
  are categorically eligible based on being on a
  list (Migrant, homeless, etc.) in addition to the
  Direct Certification Notice to Households. This
  Notice to Households MUST be sent to all
  households with students on categorically
  eligible lists.

38
Part 6 Direct Certification with Food Stamp
Program

• All school districts in Arkansas are required to
  participate in the Mandatory Direct Certification
  process.
  
• CNU, ADE has an agreement with the Department of
  Human Services that matches student information
  with Food Stamp records.
  
• CNU, ADE provides a printed Direct Certification
  list by school to the LEAs in August of each
  school year.

39
Direct Certification

• In addition to the Mandatory State Direct
  Certification the LEA may choose to use
  ADDITIONAL Optional Direct Certification by an
  agreement between the LEA and the Food Stamp
  Program office.
• See Page 66 of the Guidance for information on
  what is required for this optional local level
  direct certification agreement.

40
Direct Certification Notice to Households

• Each year the Forms and Letters Packet of the
  Policy Statement or Renewal will have the
  correctly updated letters for Notice to Household
  of eligibility for free meals based on the
  student being listed on the Direct Certification
  List.
• http//cnn.k12.ar.us On the ADE Memos page, look
  for the current school year Agreement or Renewal
  of Agreement. The Forms and Letters packet will
  be an attachment to this memo.

41
Direct Certification

• Direct Certification DOES NOT extend to any
  student not listed on the Direct Certification
  list. Other students in the household, including
  Pre-K or kindergarten students are not
  automatically eligible based on a sibling being
  on the Direct Certification list.
• Verification is not required for students listed
  on the Direct Certification list.

42
Recordkeeping

• As with all documentation in this program, USDA
  requires records be kept for the current year
  plus 3 preceding years, however Arkansas
  Legislative Audit requires all documentation be
  kept for a minimum of 5 years after submission of
  the final claim relating to the documentation.
• Documentation must be kept longer if required by
  an audit or for resolution of issues raised by an
  audit.

43
Recordkeeping

• Documentation must be readily retrievable by
  school.
  
• LEAs must ensure that all changes and transfers
  are accurately and promptly reflected on the
  appropriate categorically eligible lists and on
  each schools eligibility list (master roster).

44
Recordkeeping

• Copies of all correspondence with households
  regarding free and reduced price eligibility and
  verification activities MUST be kept by the LEA.
  This correspondence must be readily retrievable
  by school and made available for review purposes.