Revised Eligibility Manual

1
Revised Eligibility Manual

• Parts 7, 8, 9
• Director's Conference 2008
• Robert Ginder

2
Part 7 Confidentiality / Disclosure of
Eligibility Information

• Disclosure is an option, not a requirement.
• Aggregate Information can be disclosed, when
  specific children cannot be identified
• Disclosure Chart
• When in doubt call CNU, ADE and do not release
  the information!

3
Part 7 Confidentiality / Disclosure

• Need to Know
• National Assessment of Education Progress (NAEP)
  and No Child Left Behind (NCLB)
• Federal
• Need to Know Directly Connected
• May Disclose the Information
• Memorandum of Understanding

4
Part 7 Confidentiality / Disclosure

• Parental Notification for Disclosure
• Must inform households
• Can be specific or general
• Given opportunity to decline disclosure
• Memoranda of Understanding
• Not required for Federal, State reviewers
• Outlines data released and acceptable uses of
  information, penalties for improper disclosure

5
Part 7 Confidentiality / Disclosure

• Parents and Guardians may disclose any and all
  information to any program they choose (Parents
  Rights)
• Consent Statement Requirements
• Must be in writing, identify information to be
  shared and how it will be used
• Must be signed and dated by both parties
• Statement that consent does not affect
  eligibility
• Enable Parent/Guardian to limit consent to
  selected programs (not all or none)

6
Part 7 Confidentiality / Disclosure

• Penalties
• A fine up to 1000
• Imprisonment for up to 1 Year
• Overview
• It is a choice that may help your children
• Inform the parents prior to disclosure
• When in doubt, call CNU prior to release

7
Part 8 Verification of Eligibility for School
Meals

• Verification is the confirmation of eligibility
  of Free or Reduced Price meals under the NSLP.
• Verification is only required for Income Eligible
  or Food Stamp Case number applications.

8
Part 8 Verification of Eligibility

• CHANGES for 2008-2009
• Error Prone Verification is now Standard
  Sample Size
• Random Verification is now Alternate 1
• Focused Verification is now Alternate 2

9
Part 8 Verification of Eligibility

• Verification Not Required for
• Direct Certification
• Documented Migrant, Homeless, or Runaway Children
• Documented Head Start and Even Start Students
• Children attending Provision 2 Schools in a
  non-base year

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Part 8 Verification of Eligibility

• Must verify a sample EACH year
• May begin once approved applications are on file
• Sample pool depends on Applications on file as of
  October 1
• Verification must be completed by November 15

11
Part 8 Verification of Eligibility

• Once a household has been notified, verification
  must be completed
• An Application Tracker Must be completed for each
  verified application
• Application must be checked prior to the start of
  Verification Confirmation Review

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Part 8 Verification of Eligibility

• Sample Pool
• Standard Pool 3 of all approved apps pulled
  from Error Prone apps
• Alternate 1 3 of all approved apps
• Alternate 2 1 of all approved apps pulled from
  Error Prone apps PLUS ½ of all Food Stamp
  approved apps
• ALWAYS ROUND UP!!!!!!!!

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Part 8 Verification of Eligibility

• Verification for CAUSE
• Required to Verify all questionable
  applications
• Do not include in Sample Pool or Verification
  Summary Report
• Follow all standard procedures notice, time
  frames, adverse action, follow-up

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Part 8 Verification of Eligibility

• Error Prone Application
• Annual income within 1200 of IEGs
• Monthly income within 100 of IEGs
• Twice Monthly income within 50 of IEGs
• Every two weeks income within 46.51 of IEGs
• Weekly income within 23.09 of IEGs

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Part 8 Verification of Eligibility

• ALL DISTRICTS are required to use Standard
  Sampling unless they qualify for use of alternate
  1 or 2
• To qualify for an alternate, have a non-response
  rate of less than 20
• AND
• No errors in Verification during the previous
  year

16
Part 8 Verification of Eligibility

• Random Selection
• Each and Every application has the same chance of
  being selected for verification
• Darts
• Having a principal select applications
  blindfolded
• Pulling every ____ application from the file
  (number is picked at random)
• Any reasonable approach

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Part 8 Verification of Eligibility

• Confirmation Reviews
• No Change Verify application
• Change from Reduced to Free
• Change childs status immediately
• Notify family and verify application
• Change from Free to reduced price
• Do not change childs status
• Verify application
• Change to Paid
• Send notice of adverse action
• Do not verify, replace application

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Part 8 Verification of Eligibility

• Household Notification
• Use Form letters in Application packet
• Keep copies, dates of distribution, and be
  pleasant
• Response rates all start with you
• No-Cost Phone number

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Part 8 Verification of Eligibility

• Verification documentation must contain
• Name of Household Member
• Amount of income received
• Frequency received
• Date the income was received
• Names and SSs for all adults
• May document any period from a month
• prior to application till time of verification.

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Part 8 Verification of Eligibility

• Income to consider for Verification
• Regular Gross salary or wages
• Holiday Pay
• Sick Leave, Personal Leave, Annual Leave
• Regularly scheduled Overtime
• Do not include random or occasional
• payments or income.

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Part 8 Verification of Eligibility

• When Verification is complete when
• Household submits documentation to fully support
  application and eligibility for benefits
• Notice of adverse action is sent includes
  change in household income, household request to
  no longer participate, non-response or missing
  information

22
Part 8 Verification of Eligibility

• Follow-up Attempt Requirement
• LEA MUST make one additional attempt to complete
  verification
• Additional attempts MUST be documented by
  verifying official
• May be in writing or by phone
• Notify household of the consequences for not
  completing verification

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Part 8 Verification of Eligibility

• Verification MUST result in
• No change in benefit level OR
• Reduction in benefit level OR
• Free to Reduced, Free to Paid, Reduced to Paid
• Increase in benefit level OR
• Reduced to Free
• Termination of benefits (household did not
  respond)

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Part 8 Verification of Eligibility

• Changes to meal status
• Increase in benefits must be made within three
  operating days and extended to all children in
  the household
• Decrease in benefits must be extended to all
  children in the household 10 days after the
  Notice of Adverse Action was sent

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Part 8 Verification of Eligibility

• Households that reapply
• If a household reapplies for program benefits
  after a verification related reduction or
  termination of benefits. The household must
  supply documentation to support the new
  application at the time of reapplication.

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Part 8 Verification of Eligibility

• Record Keeping
• LEAs MUST maintain a description of their
  verification efforts. The description must
  include a summary of the verification efforts
  including the selection process the total number
  of applications on file on Oct 1 and the
  percentage or number of applications that
  are/will be verified by November 15.

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Part 8 Verification of Eligibility

• Record Keeping
• Must be able to document all aspects of
  verification No-Cost Phone Number, Confirmation
  Reviews, sources of documentation for
  applications, correspondence between the
  household and the district

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Part 8 Verification of Eligibility

• Common Qs and As
• Household moves during Verification
• Select a new application and continue
• Q. Overtime included
• Only if it is normal or regular
• Q. Application with Dual Eligibility
• A. Should be treated as two applications

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Part 9 Direct Verification

• Direct Verification is using records from public
  agencies to verify income and/or program
  participation.
• Direct Verification is NOT required.
• MUST contact State Agency for assistance.

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Part 9 Direct Verification

• Agency Records to Utilize
• Food Stamp Program
• State Medicaid Program
• State Childrens Health Insurance Program (ARKids
  1st)
• The LEA Must only submit the names of children on
  the application to be verified. NO EXCEPTION

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Part 9 Direct Verification

• For Arkansas
• Food Stamps confirms participation, no further
  verification needed. Child Eligible for Free
  Meals
• ARKids A confirms participation, no further
  verification needed. Child Eligible for Free
  Meals.

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Part 9 Direct Verification

• Cont
• ARKids B confirms participation, the child may be
  eligible for reduced meals, but further inquiry
  is needed. ARKids would need to supply the LEA
  with HS size and income or percentage of poverty
  level. If percentage is between 134 and 185,
  child is eligible for Reduced price meals.

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Part 9 Direct Verification

• Benefits
• Eligibility for Free or Reduced Price meals can
  be verified with minimal impact on the household
• Multiple households could be verified at one time

34
Part 9 Direct Verification

• Incomplete or Inconsistent Information from
  Direct Verification
• If information provided by the public agency does
  not verify eligibility, the LEA MUST proceed with
  regular verification activities and timelines.

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Distance Learning

• September 3 4, 2008 1-4 pm
• Two training sessions on approval of
  Applications, Master Roster, Eligibility
  determinations, and new Eligibility Guidance
• SAME TRAINING both days, pick one and attend
• A MUST for all determining officials, confirming
  officials, and verifying officials

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Final Thoughts

• We are working to update the Child Nutrition
  Website.
• All of these changes will be incorporated into
  the Verification Timelines under the red
  verification tab.
• October 2, 2008 Distance Learning on Submitting
  the Verification Summary Report

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Final Thoughts - cont

• Look for the new Purple Button on the Child
  Nutrition Website Eligibility Guidance
• Write your questions down and turn them into a
  CNU staff member so they can be answered in
  tomorrows presentation