Arkansas Department of Education Eligibility Manual for School Meals, Revised July 2016

Memo Information

Memo Number
CNU-17-004
Memo Date
8/9/2016
Memo Type
Regulatory
Section
Child Nutrition
Regulatory Authority
§PL 108-265, 7 CFR Part 245, Healthy Hunger Free Kids Act, USDA Policy Memo SP 50-2016; CACFP 19-2016; SFSP 17-2016
Response Required
NO
Attention
Federal Programs; Superintendents; Principals; General Business Manager

Contact Information

Memo Text

The 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.

 

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 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 situation.

 

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:

 

DIRECT CERTIFICATION:  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 Process.

 

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 Department.

 

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.  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.

 

Attachments:

Eligibility Manual for School Meals, Determining and Verifying Eligibility School Year 2016-2017

SP 51-2014

SP 45 2012

SP13-2012

SP 11-2014

FIN 15-055

CNU 17-001

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


 

Attachments