ATTENTION: CO-OP DIRECTORS, CHILD NUTRITION DIRECTORS, DETERMINING, VERIFYING OFFICIALS, CHILD NUTRITION MANAGERS
The United States Department of Agriculture (USDA) Eligibility Manual for School Meals was revised for 2017-2018 school year. 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 2017-2018 school year. Please retain a copy of the July 2016 manual for supporting documentation of eligibility determination for the 2016-2017 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 Programs.
Notable changes from the 2016-2017 Eligibility Manual are highlighted throughout the 2017-2018 manual. In addition, USDA has added Questions and Answers at the end of each section of the manual.
The USDA Manual indicates on page 9 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. Therefore, the only program in Arkansas that meets the criteria for “assistance programs” categorical eligibility is the Supplemental Nutrition Assistance Program (SNAP)
The USDA Eligibility Manual indicates that School Food Authorities (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.
FREE AND REDUCED PRICE MEAL APPLICATION:
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. See Section 3; Direct Certification Process.
The procedures for 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.
SFA/LEAs should direct any questions concerning this guidance to the school district area specialist at 501-324-9502.