United States Department of Agriculture (USDA) Eligibility Manual for School Meals was revised July 2016. The Eligibility Manual reflects immediate
changes in determining student eligibility for free or reduced price
meals. The revised procedures will be
used in making the eligibility determinations for meal benefits for the
2016-2017 school year. Please retain a
copy of the July 2015 manual for supporting documentation of eligibility
determination for the 2015-2016 school year.
manual contains information on Federal requirements regarding the determination
and verification of eligibility for free and reduced price meals in the
National School Lunch and School Breakfast Program.
The Eligibility Manual
indicates on page 12 that Receipt
of benefits by any household member from certain Assistance Programs conveys
categorical (automatic) eligibility for free school meals to all children in
the household. The determination is made through direct certification for
Assistance Programs or through an application with appropriate case numbers.
The Assistance Programs that convey categorical eligibility to all children in
the household are: Supplemental Nutrition Assistance Program (SNAP), Food
Distribution Program on Indian Reservations (FDPIR), and Temporary Assistance
for Needy Families (TANF).
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 areas of land that
are managed by Native American tribes under the US Bureau of Indian Affairs and
the income guidelines in Arkansas for TANF do not correlate with the Child
Nutrition Income Eligibility Guidelines.
Notable changes from the 2015-16 Eligibility Manual are
highlighted throughout the manual. The
most significant changes are in Section 3:
Establishing eligibility, and Section 4:
The School Meal Application.
Section 3 incorporates the changes codified in the final rule,
National School Lunch Program and Breakfast Program: Eliminating applications through Community
Eligibility as required by the Healthy Hunger Free Kids Act of 2010, published
in the Federal Register on July 29, 2016, 81 FR 50194. The revision includes changes to the
requirements regarding carryover and transfer of eligibility for children
transitioning from schools participating in a special Provision, including
Community Eligibility Provision (CEP) to schools in a student pricing
Section 4 provides an overview of requirements for the
Application for Free and Reduced Price School Meals effective for SY 2016-2017. This section also expands the overview of
longstanding State agency and LEA responsibilities for ensuring meaningful
access for individuals with Limited English Proficiency throughout the
application process. For more
information regarding SFA/LEA responsibilities for LEP households please see
Commissioner’s Memo CNU-17-001.
Other changes to the 2016 edition include:
Clarification of how the notice of denial and
notice of adverse action apply when a household’s benefits expire after the
carryover period ends.
An updated Nondiscrimination Statement that was
new as of November 2015; and
A revised definition of Determining Official
Food Service Management Company, and
Supplemental Nutrition Assistance Program, Appendix and Glossary of Acronyms
FREE AND REDUCED PRICE MEAL APPLICATION:
The manual reinforces the importance of validating that a student meets
the criteria migrant, homeless, or runaway status prior to certification. The Child Nutrition Director should request
the list of validated students from the migrant, homeless, and runaway liaison
or coordinator for the district. This
can reduce the household application burden, improve direct certification
rates, and increase program integrity. See Section 3; Direct Certification
The procedures for Local Education Authority (LEA) 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 students
listed on the meal application are listed on the direct certification list, the
application does not need to be processed and all students listed on the
application are eligible to receive free meal benefits based on direct
certification. If no students listed
on the application are on the direct certification portal the names should be
entered through the “Instant Match” feature.
If any name on the meal application is found through this feature, all
students listed on the meal application will receive free meal benefits based
on direct certification. These students
will be considered to have been directly verified.
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
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
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.
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. See Eligibility Manual, Section 6, Record
Retention for more information.
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.
Eligibility Manual for School Meals, Determining and Verifying
Eligibility School Year 2016-2017
SP 45 2012
School Food Authority Election to Use Date Flexibility in Free
and Reduced Price Meal Eligibility Determination