Eligibility Guidance for School Meals

1
Eligibility Guidance for School Meals

• Parts 1-3 of Guidance Manual

2
Local Education Agency (LEA)

• In 2004, the Reauthorization Act added the term
  LEA
• Responsible for meal application, certification
  and verification activities
• Definition on page 2

3
School Food Authority (SFA)

• Governing body or administrative agency
• In Colorado, the SFA and LEA are usually one and
  the same

4
Policy Statement

• Required for participation
• Permanent document on file with CDE
• Amended with significant changes in free and
  reduced policy
• Appendix A (page 86)

5
Public Release

• Near the beginning of the SY
• Eligibility criteria for free and reduced
• SMP displays free guidelines only
• Provide to local news media, employment office,
  and any major employers who are contemplating
  large layoffs in the attendance area of the
  school.
• page 3

6
Public Release updated on web

• Supplemental Nutrition Assistance Program (SNAP)
  households will be notified of eligibility and
  that their children will be provided free
  benefits unless the household notifies the school
  that it chooses to decline benefits.
• Must say that households receiving SNAP should
  only submit an application unless notified by
  specified date determined by SFA.

7
Public Release

• Must contain the same information as the letter
  to households, except that the public release
  must contain both the free and reduced income
  eligibility guidelines (IEGs)
• SMP public release should not contain reduced
  price IEGs

8
New Section

• Terms Used in this Manual
• Pages 4-5
• Supplemental Nutrition Assistance Program (SNAP)
  replaces Food Stamps this year
• Note Colorado TANF recipients are not
  categorically eligible for free meals.

9
Part 2 Application Materials

• Clear and simple design
• Foreign language translations USDA prototype at
  www.fns.usda.gov/cnd
• LEAs encouraged to provide assistance in
  completing using personnel proficient in foreign
  language(s) predominant in school
• Page 7

10
Application Materials

• Cannot send earlier than four calendar weeks
  prior to the time students start school.
• Year-round schools usually follow the July 1-June
  30 school year, distribute in June

11
APPLICATION

• Applications may only be distributed to schools
  participating in the Child Nutrition Programs
  (CNPs).
• An alternate form, the Family Economic Data
  Survey, must be used for those schools not
  participating in CNPs. (Same IEGs).
• Food service funds cannot be used for processing
  these alternate forms.

12
Computer or web-based application processing

• Letter must inform household how to access the
  system in order to apply.
• Must explain how to obtain and submit paper
  application.
• page 8

13
Changes for 2009-2010 SYLetter to Parents

• A statement that WIC recipients may be eligible
  for free or reduced price meals
• There is no charge for reduced price breakfast
  (Start Smart)
• There is no charge for PK-2 for reduced price
  lunch
• (updated version on web)

14
Application Changes

• Space for SNAP number next to each student
• Frequency of income received
• Attesting statement directly above the signature
  block

15
Household Applications

• Cannot require separate applications when some
  children are eligible based on SNAP and some
  based on income.
• LEAs cannot require one application for each
  child in a household unless
• Foster child (or a list from the court or
  responsible agency for placement) page 9
• Residents of RCCI (or eligibility documentation
  sheet for all children in residence) page 10

16
Electronic applications/Scanning applications

• LEA may accept electronically and may provide for
  electronic signatures. Must be approved by CDE.
• Scanning process must meet regulatory
  requirements (example must be able to recognize
  and accept less than whole dollar amounts)

17
Application Contents

• Except for the information in the attesting
  statement, the required information on the
  application form may be separate from the
  signature block.
• Example Privacy Act statement may be referred to
  in the signature block but may be on the reverse
  side of the application
• page 11

18
Part 3 Processing Applications -Benefits Prior
to Processing

• LEAs must carryover the eligibility status from
  the previous year for any child
• From households with approved apps from the
  previous year
• Who is a new student from a household with
  children approved the previous year, unless
  categorically eligible
• Previously approved and transfers to another
  school within the same district
• page 15

19
Carryover of Previous Years Eligibility

• LEAs must carryover eligibility
• Carryover is for first 30 operating days
• Applies to migrant, homeless, runaway, direct
  certificaton, SNAP applications and income
  applications

20
Application Processing Timeline

• Expedite eligibility determinations for children
  who do not have approved apps on file from
  previous school year
• An eligibility determination must be made and
  implemented within 10 working days of receipt of
  application
• page 16

21
Complete SNAP Application

• Student name(s)
• SNAP number for each child
• Signature of adult household member
• page 16

22
Complete Income Application

• Names of all household members
• Amount and source of current income by each
  member
• Signature of adult household member
• Complete social security number of the adult
  signing application or an indication that they do
  not have one
• page 17

23
Application Indicating Different Types of
Eligibility

• Children who are part of SNAP household can be on
  the same application with children who are
  not/applying with income
• The LEA must have a method to process different
  eligibility statuses that may result from these
  applications
• Application may be reproduced - cannot ask family
  for two applications

24
Complete Foster Child Application

• Name of the child
• Childs personal use income
• Signature of an adult household member (may be an
  official of a court or other agency with
  responsibility for the child)
• page 18

25
Incomplete Applications

• Any application that is missing required
  information, that contains inconsistent
  information, or is unclear is considered an
  incomplete application and cannot be processed
• LEAs should make reasonable efforts to contact
  the household in order to obtain or clarify
  required information
• page 18

26
Complete Applications

• LEA must not delay approval of applications if
  household fails to provide any information that
  is not required.
• Examples missing address, phone number, date
  next to adult signature

27
Citizenship/Legal Status

• US citizenship or immigration status is NOT a
  condition of eligibility for free and reduced
  price benefits.
• LEAs must apply the same eligibility criteria for
  citizens and non-citizens

28
Current Income Definition

• Current month
• Amount projected for the first month application
  is made or
• Month prior to application

29
Income Received at Different Intervals

• If there are multiple income sources with more
  than one frequency, the LEA must annualize all
  income by multiplying
• Weekly income by 52
• Bi-weekly (every 2 weeks) by 26
• Bi-monthly (twice per month) by 24
• Monthly by 12
• Add all un-rounded converted values and compare
  to IEGs for annual income for household size
• page 19

30
Income Received in Same Frequency

• No conversion required
• Total all sources and compare to the appropriate
  IEGweekly, monthly, annually, twice per month or
  every two weeks

31
Household Members without Income

• Each household member who does not have income
  must indicate by
• checking a no income box
• Writing zero or no income or inserting 0

32
Determining Eligibility

• Categorical using SNAP case numbers
• Alpha numeric 7 total
• Currently in Colorado, all begin with 1B
• The EBT card number cannot be used
• page 20

33
Determining Eligibility

• Based on Income
• Required information that is missing must be
  obtained before approval
• All missing required information may be obtained
  by contacting the household by phone or in
  writing - document details of the contact, date
  and initial the entry
• Applications missing signatures must be returned.
• Every reasonable effort should be made to obtain
  missing information prior to denying the
  application

34
Duration of Eligibility

• A childs eligibility is in effect from the date
  of eligibility for the current school year and
  for up to 30 operating days in the subsequent
  school year
• This does not apply when initial eligibility
  determination was incorrect or when verification
  does not support the benefits approved

35
Temporary Approval

• LEAs are encouraged to approve households on a
  temporary basis when their need for assistance
  appears to be short-term
• Zero income applications
• Temporary reduction in income (temporary layoffs,
  strikes, temporary disability)
• pages 21-22

36
Zero Income Applications

• Suggested time period is 45 days
• Before the end of the 45 days, contact the
  household to determine if the situation has
  changed
• If unchanged
• Continue on a temporary basis and reevaluate at
  second 45 day interval
• Make the approval valid for the duration of the
  current school year allowing for carry-over of
  that status into the next school year.

37
Zero Income Applications

• If contact is made before the end of the 45 day
  period - update application to reflect any
  changes, sign and date.
• If the application expires, the family must file
  a new application or come in and update the
  information on the existing application and
  initial.
• pages 21-22

38
Unapproved Applications

• If there are any inconsistencies or questions
  concerning the required eligibility information
  provided, the households application must be
  denied until resolved.
• Example if it is unclear whether the household
  provided weekly or monthly income, this issue
  must be resolved. Contact the household prior to
  denial, document the details, date and initial
  the entry.

39
Households That Fail to Apply

• Local school officials may complete an
  application for a child known to be eligible if
  the household fails to apply.
• The source of the information must be noted on
  the application.
• These applications are excluded from
  verification.
• The household must be notified of the benefits.
• LIMITED USE ONLY!

40
Notification of Eligibility Determination

• Households who are approved for free or reduced
  benefits may be informed in writing or orally.
• Households denied benefits must be given written
  notice
• page 23

41
Notification of Denial of Benefits

• Must include
• Reason for the denial of benefits
• The right to appeal
• Instructions on how to appeal
• A statement that the family may re-apply at any
  time during the school year

42
Changes in Household Circumstances

• Families may voluntarily report changes
• Increases in benefits take effect immediately
• When there is a decrease or termination, the LEA
  must explain that the change does not have to go
  into effect unless the household requests it. If
  so, the LEA must provide a notice of adverse
  action.

43
Appeals

• Households may appeal denial or level of benefits
  approved
• Hearing procedures outlined in the LEAs free and
  reduced policy statement must be followed
• Contact CDE
• page 24

44
Recordkeeping

• For approved applications record
• approval date
• level of benefit approved
• Signature or initial on each application/batch
  (electronic systems)
• For denied applications record
• denial date
• Reason for denial
• Date denial notice sent
• Signature or initial application/batch

45
Updating Records for Changes

• LEA must
• Note the change
• Write the date of the change on the application
  (notes/comment section electronic systems)
• Implement the change by updating point of sale
  system (roster, computer, etc.)
• When a student transfers to another school, the
  date of the transfer must be noted on application
  or in computer system.
• When a student leaves the district, the date
  withdrawn must be recorded.

46
Record Retention

• All approved and denied applications must be kept
  on file for 3 years the current school year.
• Files must be kept longer if required by an audit
  and until audit issues are resolved.
• Applications do not need to be filed by school.
  CDE will request applications for reviewed
  schools during a CRE review (once every five
  years).

47
Transferring Eligibility between LEAs

• The new LEA may accept the eligibility
  determination from the former LEA without
  incurring liability for the accuracy of the
  initial determination.
• The new LEA should review for accuracy.
• page 25

48
Answer these Questions Using the Q A, pages
25-29

• Is a social security number required on an
  emancipated childs application?
• What should you do if you know an income source
  is missing from an application?

49
One More Question

• A child is receiving free meals during the first
  30 operating days of the new school year due to
  last years application. A new application is
  received on the 15th day and is approved for
  reduced. Can you give the 10 days notice of
  adverse action?