FREE AND REDUCED PRICE ELIGIBILITY

1
FREE AND REDUCED PRICE ELIGIBILITY

• Making the Pieces Fit
• Common Errors and Findings

2
FREE REDUCED PRICE MEAL AVAILABILITY

• Schools participating in the NSLP, SBP, and/or
  ASSP MUST offer free and reduced priced benefits
  to eligible children...

3
FREE REDUCED PRICE MEAL AVAILABILITY

• Free/Reduced Price meal APPLICATIONS
  LETTERS must be made available to each enrolled
  student yearly.
• REMEMBEROnly ONE application per household is
  required

4
COMMON FINDINGS Distribution Receipt of
Applications
5
FINDING The F/R application is sent home with
students at the end of the school year for the
next year

• Eligibility applications and letters may NOT be
  distributed earlier than four calendar weeks
  prior to the time students start back to school

6
FINDING The LEA requires all students to
submit applications for free/reduced price
meals

• Households CANNOT be required to submit free/
  reduced applications if they do not wish to
  apply.
• page 15, EMFSM

7
Finding US Citizenship is used as a basis for
determining eligibility.

• US citizenship is NOT a criteria for determining
  eligibility. You should not ask nor use
  citizenship as a means for students receiving
  free or reduced priced meals.

8
FINDING The correct USDA non-discrimination
statement is not included on eligibility applicat
ion and/or letter(s).

• ALL published materials and resources, including
  Web sites and menus, used by the Child Nutrition
  program that tells the public about FNS programs
  must contain a nondiscrimination statement, per
  FNS-113.

9
NON-DISCRIMINATION STATEMENT

• In accordance with Federal law and U.S.
  Department of Agriculture policy, this
  institution is prohibited from discriminating on
  the basis of race, color, national origin, gender
  (male or female), age or disability.To file a
  complaint of discrimination, write USDA,
  Director, Office of Adjudication, 1400
  Independence Avenue SW, Washington, DC 20250-9410
  or call toll-free [phone] (voice). 
  Individuals who are hearing impaired 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.
• ENSURE YOU USE THE CORRECT STATEMENT!!!

10
NON-DISCRIMINATION STATEMENT

• Abbreviated Version
• If the material is too small to permit the full
  statement to be included, the material will at a
  minimum include the statement, in print size no
  smaller than the text that
• This institution is an equal opportunity
  provider and employer.

11
Finding The USDA non-discrimination poster is
not clearly displayed in the cafeteria.

• This poster must be
• prominently displayed
• in a location clearly
• visible to your
• customers.

12
COMMON FINDINGS Application Processing
13
FINDING Reimbursement claimed for student
meals when there is not an approved application
on file

• Except during the carry-over period, meals may
  not be claimed under the free or reduced price
  meal category unless
• an approved application is on file
• student is directly certified or extended
  benefits
• student is certified to be foster child,
  homeless, runaway, migrant or Even Start/Head
  Start

14
What is the CARRY-OVER Period?

• A student who received free/reduced benefits
  during the previous school year, may receive the
  same benefit for the first 30 operating days of
  the current school year OR until a new
  application is processed.
• REMEMBEREligibility may also be extended to the
  students siblings for the first 30 operating
  days.

15
FINDING Free/reduced applications are not
processed within 10 days of receipt

• Applications should be reviewed and an
  eligibility determination made IMMEDIATELY, but
  no later than 10 days from receipt.
• REMEMBEREligibility becomes effective when the
  student submits the application for free/reduced
  priced meals.

16
FINDING Student is approved as Categorically
Eligible, but case number is not listed on the
application

• Categorical Eligibility based on receipt of
  Public Assistance requires that a FS, TANF or
  FDPIR case number be listed on the application
  (EBT not acceptable).
• Names of children for whom the application is
  made for, as well as the adult signature are also
  required to be a complete application.

17
FINDING Homeless Student approved as
Categorically Eligible based on
self- declaration on application

• Homeless, migrant and run-away students must be
  certified by the LEAs Homeless liaison or MEPC
  in order to qualify as Categorically Eligible
  under this criteria.

18
FINDING Foster child NOT processed as
Categorically Eligible

• Foster children are now considered
  Categorically Eligible when formally placed by a
  State Child Welfare agency or court system.
• Rememberyou must obtain and maintain confirming
  documentation from the placement agency

19
FINDING Application processed as an income
application but required information is missing

• Income applications must contain the following to
  be considered complete
• Names of ALL household members
• Income (and frequency of receipt) for ALL
  household members OR indication of No Income
• Signature of Adult head of household
• Last 4 digits of the Social Security Number of
  person signing application OR indication of no
  Social Security Number

20
FINDING Application is processed as an Income
Application, but incorrect income is used to
determine eligibility

• Current gross income is used to determine
  eligibility, unless special circumstances exist,
  i.e. self-employed, deployed family member,
  combat pay, etc.
• Current income is
• Income received in month of application
• Income received in prior month of application
• Anticipated/projected income (if not received
  yet)

21
FINDING Data entry error results in incorrect
eligibility status...

• Incorrect household size or failure to include
  all household members
• Incorrect income amount and/or frequency of pay
  period
• Incorrect eligibility guidelines used in
  determining eligibility, including in the
  eligibility software.

22
FINDING Application completed as Emergency
application by school official, but no
documentation to confirm nature of emergency

• Applications must contain sufficient
  documentation to support students eligibility.
  Minimum documentation includes
• Nature of emergency
• Knowledge (and source of information) to support
  that student is eligible for benefits based on
  income and household size
• Signature of person completing application.
• REMEMBER family must be notified of eligibility

23
COMMON FINDINGSApplication Maintenance
24
FINDING Student is approved for free/reduced
benefits, but family is not notified of
eligibility.

• All households MUST be notified of eligibility,
  including DC status.
• Households DENIED benefits MUST be given written
  notification which must advise
  
• -reason for denial
  
• -right to appeal
• -households may reapply at any time during the
  school year

25
FINDING Sponsor fails to follow- up on
Temporary Free application at end of
temporary eligibility period.

• Suggested time period for Temporary Free
  status is no longer than 45 days. SFA must
  follow-up with family prior to the end of this
  timeframe to determine if household circumstances
  have changed.

26
FINDING Family reports change in household
circumstances resulting in eligibility status
moving to lesser benefit.

• Unless given temporary approval, student
  eligibility is in effect from the date of
  application through the first 30 days of the next
  school year, except in situations where the
  status changes as a result of Verification or the
  initial eligibility determination was incorrect

27
FINDING Sponsor did not use Direct
Certification for students who receive FS and
TANF.

• By law, all sponsors must Directly Certify
  children from household receiving food stamps.
• Although not required, sponsors are encouraged to
  use Direct Certification for students from TANF
  households.
• RememberEligibility is extended to all students
  living in the same household.

28
FINDING Students categorized as Direct
Certification (DC), but names are not on the DC
listing.

• Direct Certification confirmation should be
  maintained by the sponsor as proof of eligibility
  3 years plus current school year.
• Remembermaintain documentation to support
  siblings extended eligibility as well

29
FINDING One student is receiving free benefits
due to Direct Certification, but his sibling is
reduced or full pay.

• REMEMBERFree eligibility may be extended to
  other school-aged children living in the SAME
  household , based on another household members
  receipt of Foods Stamps (SNAP/FNS Benefits) or
  TANF.

30
FINDING Student is receiving extended benefits,
but there is no documentation to support
eligibility.

• When extending eligibility benefits to family
  members living in the same household as a
  Direct Cert., always maintain documentation to
  support the extended eligibility, i.e. name of
  student for whom benefits are extended, name of
  student who is receiving DC benefits, and source
  of matching data and/or person contacted, date
  of eligibility.

31
FINDING Confidential eligibility information
is released for unauthorized purposes or
without prior consent.

• Release of free/reduced eligibility information
  is very limited and for specific Federal programs
  on a NEED TO KNOW basis in order to provide a
  service or carry out an authorized activity
• REMEMBERPrior to releasing any F/R eligibility
  information, a Memorandum of Agreement (MOA) or
  parental waiver must be in place.

32
Memorandum of Agreement

• Current Memorandum of Agreement that are signed
  by the State Agency include
• Testing/Accountability
• Title I/Reading First
• Career and Technical Education (CTE)
• National Assessment of Education Progress (NAEP)

33
FINDING Student eligibility status is not
updated in POS or roster at end of 30-day
carry-over period.

• Eligibility must be current and correct at POS
  and on eligibility roster at all times, including
  at the end of the 30-day carry-over period and at
  the end of the Verification process.
• Rememberchange in status must occur no later
  than 3 days for an increase in benefits and 10
  days for decrease in benefits.

34
FINDING Students receiving free/reduced price
benefits are required to state name or use PIN at
POS, while paying students are not.

• Overt identification of meal eligibility is in
  direct violation of the Richard B. Russell
  National School Lunch Act, PL 109-97. All
  students must be issued and must use a personal
  identification number at the point of sale to
  prevent overt identification of meal eligibility.
  

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REFERENCES FOR ELIGIBILITY DETERMINATION

• Current Eligibility Guidelines
• Eligibility Guidance for School Meals Manual,
  January 2008
• Statutory Authority
• 7 CFR 245, Determining Eligibility for Free and
  Reduced Price Meals

http//www.fns.usda.gov/cnd/governance/notices/ieg
s/EligibilityManual.pdf
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QUESTIONS?
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The U.S Department of Agriculture (USDA)
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 if all or part of
an individual's 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 at
http//www.ascr.usda.gov/complaint_filing_cust.htm
l or at any USDA office, or call 866.632.9992 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] (in
Spanish). USDA is an equal opportunity provider
and employer.