Arkansas Department of Education Division of Elementary and Secondary Education USDA Eligibility Manual for School Meals, Revised July 2015

Memo Information

Memo Number
CNU-16-001
Memo Date
7/23/2015
Memo Type
Regulatory
Unit
Child Nutrition
Regulatory Authority
§PL 108-265, 7CFR Part 245, Healthy Hunger Free Kids Act 2010, USDA Policy Memo SP 40-2015
Response Required
NO
Attention
Charter Directors; Co-op Directors; Superintendents; Child Nutrition Directors, Determining Officials, Verifying Officials

Primary Contact Information

Memo Reference

No references available.

Memo Text

The United States Department of Agriculture (USDA) Eligibility Manual for School Meals was revised in July, 2015. The Eligibility Manual reflects immediate changes in determining student eligibility for free or reduced-price meals. These revised procedures will be used in making eligibility determinations for meal benefits for the 2015-16 school year. This revised guidance must be used in place of the USDA Eligibility Manual for School Meals published August 2014 for the 2014-15 school year. Please retain a copy of the 2014 manual for supporting documentation of eligibility determination for the 2014-15 school years.

This manual contains information on Federal requirements regarding the determination and verification of eligibility for free and reduced-price meals in the National School Lunch Program and the School Breakfast Program.

ASSISTANCE PROGRAMS:

USDA’s manual indicates that “assistance programs” are categorically eligible for free meals, and defines the “assistance programs”:
“ASSISTANCE PROGRAMS - Receipt of benefits by any household member from certain programs conveys categorical (automatic) eligibility for free school meals to all children in the household. The determination is made through an application with appropriate case numbers or through “direct certification for assistance programs.” The Assistance Programs are: Supplemental Nutrition Assistance Program (SNAP); Food Distribution Program on Indian Reservations (FDPIR); and Temporary Assistance for Needy Families (TANF is a Federal designation).”

In the state of Arkansas, the only Assistance Program that qualifies a student to be categorically eligible for free meals is SNAP. Arkansas does not have any FDPIR and the income guidelines in Arkansas for TANF does not correlate with the Child Nutrition Income Eligibility Guidelines. Therefore, when the USDA Eligibility Manual refers to “assistance programs” categorical eligibility, the only program that meets the criteria in Arkansas is Supplemental Nutrition Assistance Program (SNAP).

Three new areas added to this year’s manual are in Chapter 1, “The Application: Indication of “No Income”, in Chapter 2, “Determining Eligibility: In-Kind Benefits”, and in Chapter 6 “Record Retention: “Special Provision Certification Documents.”

FREE AND REDUCED PRICE MEAL APPLICATION, USDA PROTOTYPE: USDA has revised the Free and Reduced Price Meal Application prototype that is now being used by child nutrition programs in Arkansas public schools. Please see USDA Policy Memo SP 33-2015 for more information regarding the revised prototype. Arkansas has eliminated the references to FDPIR and TANF in the application materials.

The application materials have significant changes from previous meal applications. It is very important that all district personnel with eligibility determination responsibilities attend the August 6, 2015, Distance Learning opportunity for updated information. Please see Commissioner’s Memo FIN-15-123: August DL: Free & Reduced Meals: Eligibility and Application Process for 2015-16 for more information regarding this training.

DIRECT CERTIFICATION: The manual reinforces the importance of validating an active case number or migrant, homeless, or runaway status prior to certification. The validation process is an important tool that can reduce the household application burden, improve direct certification rates, and increase program integrity. Validation is referenced in Chapter 2 “Determining Eligibility”, Chapter 4 “Verification”, and Chapter 5 “Record Retention.”

The procedure for School Food Authorities (SFAs) to validate SNAP eligibility will be through the statewide direct certification match or the “instant match” feature on the direct certification portal. SFAs receiving Free or Reduced Price Meal applications should first check to determine if any of the students listed on the application are listed on the direct certification list. If any student on the application is also on the direct certification list then all students on the application will receive free meal benefits based on direct certification. If no students on the meal application are on the direct certification list then the names from the application should be entered into the instant match feature of the direct certification portal. If any student on the application matches through the instant match then all students on the application will receive free meal benefits based on direct certification (no longer considered free based on SNAP application). Any student matches made through the instant match feature of the direct certification portal will also be considered to have been directly verified and are not subject to verification activities (see page 45 of the Eligibility Manual).

EFFECTIVE DATE OF DIRECT CERTIFICATION ELIGIBILITY: LEAs may consider the effective date of eligibility for free school meal or milk benefits to be the date of the automated data matching file (or benefit recipient file from another agency) which first identifies the student as eligible for direct certification, rather than the date the LEA accesses and processes the automated data matching file into their local point of service (POS) system. To be used for this purpose, the data file must have been generated and received by the LEA in the current school year. Please see Commissioner’s Memo FIN-15-055: Eligibility Effective Date for Directly Certified Students for more information.

EFFECTIVE DATE OF ELIGIBILITY DETERMINATION from Free and Reduced Price Meal Applications: USDA Memo SP11-2014 “Effective Date of Free or Reduced Price Meal Eligibility Determinations” allows SFAs the flexibility to use the date the meal application is received by the Child Nutrition department as the eligibility determination date. SFAs choosing to use this flexibility must advise the State Agency by completing “School Food Authority Election to Use Date Flexibility in Free and Reduced Price Meal Eligibility Determination” and returning to the SFA’s area specialist. The fax number is 501-324-9505.


In using this flexibility the SFA will ensure that all Free and Reduced Price Meal Applications are processed and determined within ten (10) operating days of receipt of the application, as required by federal regulation. For SFAs using this flexibility the date of determination of the new eligibility status will be the date the application was submitted to the SFA Child Nutrition Department.

The SFA must have a procedure in place to document the date of submission of household Free and Reduced Price Meal Applications, such as a date stamp, and the SFA agrees to refund any money paid by or on behalf of the child for a reimbursable meal prior to the meal eligibility determination, including forgiving debt accrued after the date of submission of application. The SFA must have supporting documentation for Claims for Reimbursement through revised Daily Records and Monthly Reports to show that student meals were claimed in the newly determined category based on the eligibility determination date.

For example, if a child had paid for full price meals and was subsequently determined eligible for reduced price meals, the LEA could adjust the claim to have the previously-served meals reimbursed as reduced price, rather than paid. In turn, the LEA must refund the difference to the student’s account between the total amount paid for the full price meals and the total amount that would have been paid for reduced price meals from the date the application was submitted to the LEA to the date the eligibility determination was made. Similarly, the same amount must be removed from any debt accrued by the child for meals served without payment.

For example, the school has a policy that allows a child to receive a meal even if s/he does not have money to pay for a reduced price or paid meal. Under this policy, a child received five lunches after submitting an application, but prior to being determined to be eligible to receive reduced price meals. If this child was in debt for the full price ($3.00) for each of the five lunches ($15.00) and the LEA charges $0.40 for a reduced price lunch, the LEA may claim the five lunches as reduced price if it adjusts the debt to reflect only the cost of five reduced price lunches ($2.00). If this child had spent $15.00 instead of accruing a debt, the LEA must refund the difference between the cost of five paid lunches and five reduced price lunches or $13.00. The LEA can only claim those meals at the higher reimbursement rate if the child is given a refund or their debt is discharged.

This flexibility would assist low income children by allowing them to access free or reduced price school meals during the eligibility determination period. It could also assist LEAs that are experiencing challenges with unpaid debt.

RECORD RETENTION:
The USDA Eligibility Manual indicates that SFAs are required to retain records for three (3) years after the last claim was filed based on those records however the state of Arkansas requires five (5) year record retention.


Additional information can be found in chapter 5: “Record Retention.”

Local educational agencies, school food authorities, and other program operators should direct any questions concerning this guidance to the school district area specialist at 501-324-9502.


Attachments:
Eligibility Manual for School Meals Revised July 2015

School Food Authority Election to Use Date Flexibility in Free and Reduced Price Meal Eligibility Determination

SP 13-2012: Verification for Cause in School Meals Program

SP 45-2012: Preventing Overt Identification
SP 11-2014: Effective Date of Free or Reduced Price Meal Eligibility Determinations
SP 51-2014: Eligibility Effective Date for Directly Certified Student

SP 33-2015: Revised Prototype Free and Reduced Price Application Materials: Policy Changes and Design Overview

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