DEPARTMENT OF EDUCATION
P.O.
SUPTS. MEMO NO. 6
September 29, 2006
REGULATORY
|
TO: |
Division
Superintendents |
|
FROM: |
Billy K.
Cannaday, Jr. Superintendent
of Public Instruction |
|
SUBJECT: |
Verification
of Household’s Eligibility for Free or Reduced Price Meals in the School
Nutrition Programs |
Public Law 108-265, the Child Nutrition and Special Supplemental Nutrition Program
for Women, Infants, and Children (WIC) Reauthorization Act of
2004, amended requirements for verification of household’s eligibility for free
or reduced price meals in schools participating in the National School Lunch
Program and/or School Breakfast Program. The amended provisions were effective
July 1, 2005. This memo provides information required for the annual
verification process.
The number of approved applications on file on
October 1 will be the number used to calculate the required sample size. The deadline for completion of verification
activities is November 15. The deadline
for reporting the results of verification to the Virginia Department of
Education (VDOE) is January 15.
The basic sample size for verification is 3 percent
of all approved applications, or 3,000 applications, whichever is less. The law requires school divisions to draw the
sample from error-prone applications.
Error-prone applications are those that report total household income
within $100 monthly, or $1200 annually, of the income eligibility guidelines
for free or reduced price meals for the applicable household size.
In lieu of the basic sample size, school divisions
may be eligible to use an alternate sample size if they meet the following
conditions:
1.
The division’s non-response rate for
verification in the preceding year was less than 20 percent; or
2.
For school divisions with more than 20,000
students approved by application (excluding direct certification) as of October
1:
a.
The verification non-response rate for the
preceding school year was at least 10 percent below the non-response rate for
the second preceding year.
The alternate sample sizes set forth in the law are
the same options that were in effect prior to the July 1, 2005, changes. If interested, school divisions should
contact the VDOE School Nutrition Programs (SNP) office to determine if they
meet the conditions established for alternate sample size.
Prior to conducting verification, school divisions are required to
conduct a confirmation review of all applications selected for
verification. The purpose of the review
is to check the accuracy of the initial free or reduced price eligibility
determination. An individual other than
the one who made the initial eligibility determination must do the confirmation
review.
If the initial determination is found to be incorrect, the school
division must correct the household eligibility status and notify the household
of the change in eligibility using the notice of adverse action letter. A sample notice of adverse action letter is
included in the prototype verification forms available on the School Nutrition
Programs Web system (SNPWeb). If the
correction results in the application no longer being eligible for verification
it must be replaced by another eligible application (i.e., a correctly approved
application within $100 of the monthly eligibility limit). Upon completing the confirmation review, the
division should proceed with verification of applications with confirmed
eligibility and those with corrected eligibility that remain eligible for
benefits.
The law permits school divisions to decline to verify 5 percent,
or less, of the selected applications in the sample. Any application that is removed from the
sample pursuant to this provision must be replaced with a similar application
(i.e., a correctly approved application within $100 of the monthly eligibility
limit). School divisions may consider
factors such as communication difficulties and household stability when
declining to verify selected applications.
Households selected for verification must be provided with a
telephone number that they may call for assistance. This phone number must be provided to the
household in the “notice of selection” letter.
A sample notice of selection letter is included in the prototype
verification forms on SNPWeb. The number
must permit the call to be free for all households in the division. The division may provide different phone
numbers for each local calling area within the school division or they may
establish a toll-free number for households outside of the local calling area.
The “notice of selection” letter must include the name of a school
official(s) who can serve as a point of contact for the household to either
directly assist them or to refer the caller to a specific person for help.
There is a formal follow-up requirement for households that fail to respond to the initial request for verification information. At least one attempt, through mail, by telephone, or personal contact must be made. Written documentation of all follow-up attempts and the results must be kept. If the household’s eligibility status cannot be verified after the follow-up attempt(s), the household’s benefits must be terminated through a “notice of adverse action” letter.
Questions regarding verification may be directed to
the school nutrition program specialist assigned to the division, or Lynne Fellin, acting director, at (804) 225-2074.
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