Verification Process: What is Involved?

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Verification ProcessWhat is Involved?
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The U.S Department of Agriculture 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 all or part of an individuals
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.htm
l, or at any USDA office, or call [phone]
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 [phone] or email at
program.intake_at_usda.gov. Individuals who are
deaf, hard of hearing or have speech disabilities
may contact USDA through the Federal Relay
Service at [phone] or [phone]
(Spanish).   USDA is an equal opportunity
provider and employer.
6/2013
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(No Transcript)
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Federal Policy for determining and verifying
eligibility

• http//fns.dpi.wi.gov/fns_fincou1manual
• Eligibility Manual for School Meals,
• August 2013, Part 8 is Verification
• Terms related to the Free and Reduced-price
  eligibility process (helpful to understand parts
  of verification) are included in Eligibility
  Manual (EM) Part 1 B
• Definitions related to Verification EM Part 8
  A

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SFA (School Food Authority)
for agencies administering the school meals
programs

• LEA (Local Educational Agency)
• to identify the entity responsible for
  application,
• certification, and verification activities
  for
• National School Lunch (NSLP) and School
  Breakfast
• (SB) programs
• EM Part 1 A

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WI Child Nutrition Programs Website

• http//fns.dpi.wi.gov/fns
• Click on INDEX button select topic listed in
  alphabetical order
• Verification information is located at
• http//fns.dpi.wi.gov/fns_topicsV
• Annually download letters/forms/mailings!
• This guarantees the current Civil Rights
  statement is included!

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USDAs Food and Nutrition Service

• USDA Guidance Memos for Schools explain changes,
  updates or clarifications. USDAs Food and
  Nutrition Service is linked to DPI website at
• http//fns.dpi.wi.gov/fns_topicsU
• http//www.fns.usda.gov/cnd/Governance/policy.htm

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USDA Guidance Memos

• Memos pertinent to Verification
• SP38-2013 Verification Report
• SP13-2012 Verification for Cause
• SP02-2012 Verification Reporting of Foster
  Children

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Lets Do a Quick Review of theApplication
Approval Process

• Application materials must be distributed to all
  households each year. Click Free Reduced Meal
  applications on Child Nutrition Programs website
  for current application(s).
• Determining Official receives applications,
  contacts household if application is incomplete
  approves or denies eligibility documents
  eligibility decision on application, creates
  Benefit Issuance list and/or enters into computer
  system.
• Complete Benefit Issuance list of F/R students
  specific date approved, denied, benefit changed,
  Direct Cert, foster child, benefits extended per
  sibling, withdrawn from school, etc.
• Household is notified of decision. Written notice
  including appeal procedure is required - if
  benefits are denied.

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Who is involved in the eligibility approval
process?

• 4 officials named on the school/districts
  on-line DPI contract for school year (SY)
• Determining Official
• Verifying Official
• Confirming Official
• Hearing Official

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Determining Official

• Reviews each application for completeness,
  correct case number or computes income,
  initial/date, approve/deny application. Runs
  Direct Certification
• Compiles Benefit Issuance list for each school.
  Lists each students Free or Reduced-price status
  precise date of any change. (Cant backdate)
• Documents up to 30 operating days carry-over of
  eligibility from previous school year or until a
  new application is approved, whichever occurs
  first
• Eligibility Manual for School Meals, August 2013
• and Direct Cert http//fns.dpi.wi.gov/fns_dire
  ctcert

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Verifying Official

• Notifies households selected for verification
• Verifies information on each application reviews
  documentation submitted for completeness checks
  for each income does math, FoodShare/W-2
  Cash/FDPIR documentation from ACCESS, foster care
  documentation from State or foster care agency
• Signs/dates informs household in writing of
  results
• change or no change in eligibility status
• Maintains the records of verification in a
  separate file
• May be the Determining Official
• EM Part 8 and Part 9

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Confirming Official

• Only required to double-check household
  applications selected for Verification
• Assures that initial determination was correct.
  If not correct update application with
  correct eligibility, benefit issuance list
  inform household (before verification notices are
  mailed to households) then verify per this
  correct determination
• Exclude household from Verification if no longer
  eligible for benefits or withdrawn from school
• Confirming Official can not be Determining
  Official
• EM Part 8 G

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Hearing Official

• Conducts a Hearing, when requested, for appeals
  to the determination or verification decision
• Can not be involved in the original determination
  or the verification processes
• Hearing Official is generally a superior of the
  Determining Official and Verifying Official
• May be the Confirming Official
• EM Part 8 M

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Determining Eligibility

• Direct Certification (DC) S, T, O, E free
  eligible
• Categorical Eligibility automatic free based
  on eligibility as
• Foster Child (court placed/WI/agency documents)
  or marked foster child box on application Part
  1. All Household Members
• FoodShare/SNAP 10 digit case number
• W- 2 cash assistance (Wisconsins name for
  Temporary Aid to Needy Families (TANF) - 10 digit
  case number
• Food Distrib. Program on Indian Reservations
  (FDPIR)
• Other Source Categorically Eligible homeless,
  runaway, migrant, Head Start, Even Start
• Income-based applications can be free, reduced
  or denied
• EM Part 3, 4, 5 Direct Cert http//fns.dpi.wi.g
  ov/fns_directcert

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Direct Certification

• Required 3 times per school year by each LEA
  participating in NSLP SBP run after July 1
• 1) before or about the beginning of school
• 2) 90 days after first run (about 3 month)
• 3) 180 days after first run (about 6 months)
• Eligible students identified/coded S, T, O, E on
  each Direct Cert run are not subject to
  Verification!
• If using computer software, be sure system has
  been updated for the new Direct Cert code letters
• Direct Certification http//fns.dpi.wi.gov/fns_di
  rectcert

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Direct Certification

• Keep each DC list. Each list documents students
  as free eligible based as of that specific date
• May run DC as often as useful
• Direct Cert takes precedence over an application
• Keep application of student(s) who are eligible
  by DC on-file. Application helps identify other
  children in household to whom benefits are
  extended. These children are also considered DC.
• EM Part 1B Part 3 A, C Part 5 A Part 6 A
  http//fns.dpi.wi.gov/fns_directcert

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Other Source Categ Eligible

• Defined as
• Homeless, Runaway or Migrant
• Head Start, Even Start enrollment
• An individual childs Other Source Categorically
  Eligible does not convey to other children in
  the household.
• Foster child status does not convey to other
  children in a household.
• EM Part 1 B Part 3 C, F Part 5 B, D

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What is Verification?

• Verifies eligibility for a sample number of
  applications received/approved in the current
  school year for free and reduced-price meal
  benefits under the National School Lunch Program
  (NSLP) and School Breakfast Program (SBP)
• Required by USDA for all school agencies and any
  Residential Child Care Institutions (RCCI)
  with day students who are participating in
  federal meal programs such as National School
  Lunch Program (NSLP) School Breakfast Program
  (SBP) who have any approved applications

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Excluded from Verification

• Free Eligible students with no application
  but based on documentation
• Direct Certification (DC)
• Homeless, Runaway, Migrant status (only with
  documentation/email from Homeless Liaison in
  public schools, or Migrant Education Program
  Coordinator)
• Foster Child based on DC or court/agency
  documents
• Resident in RCCI (not day students)
• Head Start/Even Start participants (Federal WI
  programs)
• EM Part 5, 6, 8 and USDA Memo SP 40-2013,
  SP02-2012

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Mark your calendar!

• Sept 30 - consider a Direct Certification run
• Oct 1 from the number of current school year
  applications approved on/by Oct 1. Verifying
  Official will calculate the correct sample size
• Last operating day in Oct of enrolled
  students
• November 15 - complete verification process
• Nov 1 to Feb 1 - submit Verification Report to
  DPI
• at http//fns.dpi.wi.gov/fns_online
• EM Part 6 A, B Part 8 C, O Verif Report
  Instructions

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How is Verification conducted?

• Required sampling method is determined
  (applications may need to be sorted into groups)
• As of Oct. 1, count the total number of approved
  applications submitted for current school year
• Carryover apps of previous SY are NOT included
• Select required percentage based on sampling
  method - but not more (do not verify 100 of
  paper applications)

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How is Verification conducted?

• Confirming Official checks only applications
  selected for verification and if necessary,
  corrects eligibility status and notifies
  household of correction before verification
  paperwork is mailed to the household
• Must mail/give We must check your application
  letter and verification paperwork to each
  household selected to be verified. Consider
  phoning each household to explain process/what
  they need to sent in. Verifying Official decides
  due-date

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How is Verification conducted?

• Receive documents from household to verify
  information on application
• Examine documents submitted by households (keep
  documents or photo copies)
• Validate eligibility or change households
  eligibility status based on documents received.
  Calculate income based on documents submitted.
• Mail/send We have Checked Your Application
  letter to household with results of verification

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How is Verification conducted?

• Must make at least one follow-up attempt to
  contact any household who do not respond to
  submit documents. Must ensure that adequate
  language assistance is provided. Follow-up may be
  in writing (including by email) or by telephone.
• Document that a contact was attempted. Please
  keep good records of each follow-up contact/s.
• If household indicates, verbally or in writing,
  that it no longer wishes free or reduced verif
  is complete when we have checked letter is
  sent. EM Part 8 J

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Verification Terms

• Sampling Methods EM Part 8 E
• Verification For Cause Part 8 D and the USDA
  Memo SP13-2012
• http//www.fns.usda.gov/cnd/Governance/policy.htm
  
• Direct Verification (optional)
• EM Part 1 B and Part 9

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Verification For Cause

• School agencies have an obligation to verify
  questionable applications. Cant delay the
  approval of applications
• Verification for cause is done any time during
  school year as soon as possible after the
  application is received
• EM Part 3 F Part 8 D USDA Memo SP 13-2012

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Verification For Cause

• Any paper application verified for cause is in
  addition to the sample size required for the
  official verification process
• Any application(s) verified for cause is
  reported on Verification Report (FNS-742) in 2
  places Section 5, 5-8 boxes and line VC-1
• Verification Report Instructions

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3 Sampling Methods

• Standard lesser of 3 or 3000 apps from
  error-prone paper applications
• Alternate 1 lesser of 3 or 3000 apps selected
  randomly
• Alternate 2 lesser of 1 or 1000 apps
  selected first from error-prone apps
• PLUS .5 of apps with case
• EM Part 8 E

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Computer System with Verification Feature

• Check the computer system to ensure that
• it selects appropriate sample size
• it selects error prone applications for the
• Standard and Alternate 2 sample sizes
• all letters to households generated by the
  computer system contain the required current
  school year Privacy Act and Non-Discrimination
  Statement
• EM Part 2 C, E, F, G Part 8 E, F, G, H, K, P
  and SNT Mailing April 25, 2013 Web-based Direct
  Certification

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Which Sampling Method to Use?

• Choice is based on last school years
  verification results
• Standard sampling must be used if your
  preceding school year non-response rate was equal
  to or greater than 20. Pull your file
  calculate non-response
• Large LEAs (more than 20,000 students approved
  by October 1 for free or reduced by application)
  with greater than 20 non-response but showed at
  least a 10 improvement in non-response rate may
  select any of the 3 sampling methods
• LEAs with less than 20 non-response rate may
  select any of the 3 sampling methods
• EM Part 8 B, C, E, F

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Mailings-School Nutrition Programs

• Late September watch for Verification mailing
• Posted under letter M, Mailings-School
  Nutrition Programs http//fns.dpi.wi.gov/fns_sntm
  ail
• If your Local Educational Agency receives
  specific notice that LEA is obligated to use
  Standard Sample Size of error-prone income
  applications this letter is not posted on
  website Your LEA had 20 non-response rate in
  the previous school year

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After the Initial Selection

• Confirmation Review
• Confirming Official checks only the
  application(s) selected for verification (her/his
  initials/date it)
• Checks accuracy of the original determination
  (i.e. does math manually, if F/R income app)
• Corrects the eligibility, if needed, before
  verification notification is sent to household.
  Notify household. Never verify a paid app.
  Randomly replace app with another app of same
  type error-prone income, income, Foster child or
  Case EM Part 8 G

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Replacing Applications

• After Confirmation Review, LEA may decline up to
  5 (.05) of applications selected for
  verification
• Must replace application on the same basis as the
  one declined error-prone, income, case number,
  etc.
• EM Part 8 G, P

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Possible Reasons to Replace an Application

• May choose to replace an application because
• household had been selected for verification last
  year
• household has language barriers, or literacy
  issues, or is embroiled in a custody battle which
  may impact compliance
• household with on-going or unresolved issues with
  school agency which may impact compliance

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Replacing Applications

• Examples
• Verifying 100 applications (100 x .05 5), can
  replace up to 5 of those applications with others
• Verifying 20 applications (20 x .05 1.00) can
  replace 1 application with another application
• Verifying 2 applications (2 x .05 .10) can
  replace 1 application with another
• Minimum of one application may always be
  replaced even if the result is less than 1
• EM Part 8 G

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Meeting Minimum Sample Size

• Randomly select a similarly approved replacement
  application if
• Confirming Official finds an error in the
  initial
• determination and household is no longer
• eligible for free or reduced- price meal
  benefits
• Student/students listed on selected application
• have left the school/district
• LEA may not choose more than sample size
• LEA may not verify all approved applications
• EM Part 8 C, D, E, F, G, H, P

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Zero Income HouseholdSelected for Verification

• LEA must request an explanation of how living
  expenses are met
• LEA may request additional written documentation
  or collateral contacts information from whom
  assistance is being received
• Cash withdrawn from savings is reportable income
  
• EM Part 3 E, P Part 4 B, C Part 8 I, P

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Before written notification is mailed, Direct
Verification is an option

• LEA may obtain documentation of Food Share, W-2
  cash benefits FDPIR application directly from
  local agency that administers each program
  (communicate by FAX or scanned copy)
• http//fns.dpi.wi.gov/fns_fincou1verification
  use Verification Forms fax pages 12 13 to
  agency
• Not necessary to notify household if eligibility
  remains the same. Verification is completed
• If results in change in eligibility mail
  household written notification of verification,
  We Must Check
• EM Part 1 B Part 9

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Direct Verification (optional)

• Fax or scan pages 12 13 of Verification Forms
  to your countys Income Maintenance (IM) agency.
• All Wisconsin county Tribal agencies are
  posted http//www.dhs.wisconsin.gov/  
• Click on Topics A to Z click on letter I
  then Income Maintenance (IM) Agency Directory
• Or http//www.dhs.wisconsin.gov/forwardhealth/imag
  ency/index.htm

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Written Notification to Household Selected for
Verification Includes

• 1. Deadline for submitting written evidence is
  set by LEA
• Name of LEA contact and phone number that can be
  reached without charge (for local call, toll
  free, or collect) to answer verification
  questions
• We must check your application letter lists
  acceptable documentation of FoodShare/SNAP W-2
  cash benefits/TANF FDPIR foster child or
  income.
• Recommend use of Verification Forms (16 pages)
  posted http//fns.dpi.wi.gov/fns_fincou1verific
  ation
• EM Part 8 H, I, J, K, L

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Documentation to Support Eligibility

• Written evidence received directly from the
  household (pay stubs, child support, SSI, etc.)
• Collateral contact identified by household that
  school can request information from directly
• Employer
• Social service agency
• Migrant workers agency
• Religious or civic organization
• EM Part 8 I, J

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Income Documentation

• Must receive documentation for all sources of
  income reported on application (Be sure to keep
  copies on file)
• Income may be for any time from one month prior
  to date of application up to time of verification
• Frequency of income(s) should be identifiable
  (e.g., weekly, biweekly, monthly, 2 times per
  month). Ask household if frequency is not clear.
  Date/initial the response
• Gross income must be used except for
  self-employment and farming income or
  seasonal/fluctuating income
• Free and Reduced Price School Meals Family
  Application

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Documentation for FoodShare/SNAP, W-2 cash
benefits/TANF and FDPIR

• Documentation that shows eligibility for programs
  from any point in time between the month prior to
  date of application and up to time of
  verification
• Documentation of a child (or any household member
  on the application) is receiving benefits under
  FoodShare, W-2 cash benefits or FDPIR
• Quest card (electronic benefits) cant be used.
  It has no expiration date.EM Part 3 A, C Part
  8 H, I

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Foster Child(ren)

• Foster child only application Social worker,
  agency, court/State confirms childs foster
  status and personal income, if any, in writing
  or over the phone (record documentation received
  verbally onto application and initial date)
• Foster child appearing on household application
  foster child is categorically eligible. Foster
  does not convey free benefits to households
  own children. Household children determined by
  income or sources of household categorical
  eligibility
• EM Part 1 B Part 3 C Part 4 B Part 5 B, D
  Part 6 G
• USDA memo SP02-2012 and SP17-2011

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Kinship Care

• Ask in cases where no specific welfare agency or
  court is legally responsible for the child or
  child is living with relatives, or friends of the
  family, the child is considered to be a member of
  the household with whom s/he resides. Household
  must submit an application. App could be selected
  for verification.
• Child(ren) placed with relatives through formal
  arrangement by courts or State is considered
  Foster
• Determining Eligibility for Meal/Milk
  Benefits Foster Care, Kinship Care Adoption
  Assistance Fact Sheet 8/19/11 posted at
  http//fns.dpi.wi.gov/fns_fincou1

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Adoption

• Children are part of household when there is
  legal adoption. They must be listed on
  application. Any adoption subsidy is considered
  reportable income. Application could be selected
  for verification.
• Due to year-long duration of eligibility, free
  eligible status on a foster child doesnt change
  if foster child was adopted during the same
  school year.
• EM Part 4 B, D Part 5 C, D

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After Household Responds-Verifying Official

• Must receive documentation on all sources of
  income listed on original application compares
  documentation with information listed on the
  application computes total income from
  documentation for income applications
• Overtime Contact household and ask if overtime
  is one-time or sporadic source of income. If only
  sporadic, income should be calculated based on
  regular monthly income without overtime
• Records to whom you spoke persons
  answer/initial and date - that the conversation
  occurred
  EM Part 8 H, I, J, N, P

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After Household Responds-Verifying Official

• Informs household that eligibility remains the
  same or changes (be sure to use the most
  current We have checked your application
  letter from DPI website)
• Written notice is required to include Appeal
  Procedures for change in benefit level and/or
  for termination of benefits
• Updates Benefit Issuance List or computer system
  database to correct benefit level of each
  student/siblings

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Insufficient Evidence or No Response

• Verifying Official must make at least one
  documented attempt (written, email or verbal) to
  contact the household and inform them that
  failure to comply with verification will result
  in termination of benefits (document contact(s)
• Terminate benefits and change to paid status if
  household does not respond by deadline set, but
  no later than November 15. Letter must give 10
  calendar days written advance notice from date
  the notice is sent.
• EM Part 8 J, K, L

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Verification is complete

• When household indicates, verbally or in writing,
  that it no longer wishes to receive free or
  reduced-price benefits
• Household eligibility for the level of benefits
  is
• Validated at current eligibility level
• Changed to a higher/lower eligibility level
• Household eligibility is changed to paid due to
  non-response to request for documentation
• EM Part 8 J, K

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Verification is complete

• Letter (We have Checked Your Application) is sent
  informing household of results and that benefits
  will remain the same or be reduced
• Letter/notice of adverse action is sent informing
  households that benefits will be terminated
  (changed to paid status). Include the Fair
  Hearing paragraph and Hearing Officials contact
  information
• EM Part 8 J, K, L

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Time Periods for Changing Eligibility Status

• Any household that fails to respond or submits
  incomplete verification documentation by due date
  receives notice that household will be changed
  to paid
• Reduction or Termination of benefits household
  has 10 calendar days from date on written
  notice to file for Appeal. (Benefits remain the
  same until end of appeal)
• Increase in benefits effective immediately and
  must be implemented no later than 3 operating
  days after decision
• EM Part 8 J, K, L

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We have checked Notification Letter Results
of Verification

• Specifies change in benefits (if any) and reason
• Includes Fair Hearing paragraph and time frame
  for submitting appeal (within 10 calendar days
  from date on notice) to continue benefits.
• When household doesnt appeal, or Hearing
  Official rules that benefits must be reduced, the
  actual reduction or termination of benefits must
  take place no later than 10 operating days
  after the 10 calendar day advance notice period,
  or 10 operating days after the decision by the
  Hearing Official.
• EM Part 8 K, L

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Households that reapply in same school year for
program benefits

• Household is required to submit income
  documentation or proof of participation in
  Assistance Program(s) at the time of
  reapplication prior to approval
• Not considered a new application
• EM Part 8 N

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Appeal Rights

• Household is allowed 10 calendar days from date
  on notice to request a Hearing to appeal decision
• If a household appeals by the end of the ten
  calendar day period, LEA continues to provide
  benefits as originally issued to the child until
  hearing is held and a final decision is made
• If no appeal is made, actual reduction or
  termination of benefits must take place no later
  than 10 operating days after the 10 calendar day
  advance notice period
• EM Part 8 L, M, N

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Fair Hearing Procedure

• Household may request a school conference to
  review information prior to a formal hearing
• Refer to procedures in Permanent Agreement Policy
  statement and Verification Forms. The last page
  contains the Fair Hearing Procedure.
• Verification Forms (16 pg.) posted
• http//fns.dpi.wi.gov/fns_fincou1verification
• EM Part 8 K, L, M

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(No Transcript)
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• QUESTIONS
• About
• Verification?
• Contact any
• School Nutrition Program Consultant
• Directory posted at
• http//fns.dpi.wi.gov/fns_sntdirectory

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New to your role or seek a refresher?

• Use INDEX button A-Z Training offers
  upcoming, recurring and resources at
  http//fns.dpi.wi.gov/fns_snt_training
• School Nutrition Team Webcasts are updated -
• as USDA regulations change
• http//fns.dpi.wi.gov/fns_sntwebcasts