Arkansas Department of Education Eligibility Effective Date for Directly Certified Students

Memo Information

Memo Number
Memo Date
Memo Type
Fiscal & Administrative Services
Regulatory Authority
§7 CFR 245.2; USDA Memos SP 51-2014, SP 11-2014; Commissioner’s Memo FIN-15-020
Response Required
Co-op Directors; Elementary Principals; Middle School Principals; High School Principals; Superintendents; Child Nutrition Directors, Bookkeepers, Determining Officials

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Memo Text

The purpose of this memo is to provide clarification regarding flexibility for determining the effective date of eligibility under all methods used to directly certify students for free meal benefits. Methods of direct certification include automated data matching, the letter method, and lists or other forms of documentation provided to the school or local educational agency (LEA) directly from the appropriate State or local agency administering the direct certification program. Direct certification means determining a child is eligible for free meals based on documentation obtained directly from the appropriate State or local agency or individuals authorized to certify that the child is:a member of a household receiving assistance under the Supplemental Nutrition Assistance Program (SNAP) a foster child, homeless child, migrant child, Head Start or Even Start or runaway child Methods of direct certification:Automated Data Matching Method– LEAs may consider the effective date of eligibility for free school meal benefits to be the date of the automated date match.  To be used for this purpose, the data file must have been generated and received by the LEA in thecurrent school year.  AUTOMATED DATA MATCHING IS THE ONLY METHOD OF DIRECT CERTIFICATION FOR SNAP. Letter Method and Lists or Other Forms of Documentation – may be used to directly certify students as members of households that receive benefits or other categorically eligible programs such as foster, homeless, migrant, Head Start, Even Start or runaway.  Although, THE LETTER METHOD IS NOT A FORM OF DIRECT CERTIFICATION FOR SNAP, a letter from the appropriate SNAP agency can be used in lieu of a meal application to establish a child’s categorical eligibility.  Therefore, the flexibility in determining the effective date of eligibility also applies to the letter method of documentation from SNAP.  Implementation: If the LEA elects to exercise the flexibility described above for direct certification, the LEA must: Do so consistently for all direct certification methods;Apply direct certification eligibility effective date flexibility consistently to all students directly certified across all participating schools and school meal programs within the LEA;Document the effective date used, such as a date stamp for documentation from other agencies or the traceable run date of automated match files;Extend eligibility to all members of a SNAP household;Refund any money paid by or on behalf of the student for reimbursable meals during the period from the free meal eligibility effective date through the date the direct certification is actually implemented at the local school, including forgiving accrued debt, for any meals adjusted to free due to the change in effective date.  The LEA can only claim those meals at the free reimbursement rate if the student is given a refund or the debt is discharged;Notify Arkansas Department of Education/Child Nutrition Unit (ADE/CNU) in writing of intent to use date flexibility and to ensure proper implementation of the flexibility and the accuracy of the LEA’s adjusted claims, as applicable.  Refer to Commissioner’s Memo FIN-15-020 for Effective Date of Eligibility Determination Form. For questions regarding direct certification, contact Patricia Winders, Assistant Director of Program Administration, ADE/CNU 501-324-9502.  


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