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WHO’S ELIGIBLE FOR WHAT: THE FREE AND REDUCED PRICE PROCESS
Administrative Review (AR):Critical Areas of Review
Certification and benefit issuance
Accuracy of meal counting and claiming
Whether meals claimed for reimbursement meet meal pattern and nutritional quality requirements
2
Performance Standard 1 Performance Standard 2
Administrative Review (AR):Off-site Review Procedures
To prepare for the review, your reviewer will examine:
SFA Agreement Free and reduced price policy statement Renewal applications Claims for reimbursement Other miscellaneous reports (e.g. Verification
Collection Report) Review findings from prior years, corrective
action plans, and documented corrective action Other audits
Administrative Review (AR):On-site Review Procedures
To ensure program compliance, includes an examination of:
Free and reduced price certification and benefit issuance process
The meal service General areas
Free and Reduced Price Process:Off-Site Review Procedures
Questions to address SFA’s procedures regarding: Household
applications Direct certification Benefit issuance
Benefit issuance document
Applications Direct certification
lists Other categorical
eligibility documentation
Off-site Assessment Tool Supporting Documentation
Benefit Issuance Document6
• Student name• School name• Eligibility status (free or reduced price)• Date of certification• Method of certification• Total number of eligible students in the
SFA• Notes (e.g. withdrawal/transfer date)
List of all students in the SFA eligible for free or reduced price meals
REMINDERS: No duplicate names Not grouped by eligibility status
Sample Benefit Issuance List7
Benefit Issuance: Other reminders8
Must be updated anytime changes occur in eligibility, as well as when a student transfers or withdraws
Share student eligibility only with the school or program personnel who “need to know”
Selecting Certifications for Review
State agency may elect to review either: All free and reduced price students on
the benefit issuance document A statistically valid sample of free and
reduced price students on the benefit issuance document Only an option if the SFA has greater than
100 students certified for free or reduced price benefits
Obtaining Certifications for Review
For each selected student, the state agency must obtain:
The certification document (e.g. application or direct certification list)
Any verification materials
Application Processing:What are we looking for?
Were applications processed correctly? Was carryover of the previous year’s
eligibility done properly? Were applications approved and
households notified of eligibility status in the required timeframes?
Did the SFA follow all requirements for the independent review of applications (if applicable)?
Denied Applications:What are we looking for?
Was the denied household notified of: Reason for denial Right to appeal Instructions on how to appeal Statement that the household may reapply
at any time during the school year
Common Review Finding:Applications
FINDING: Data entry error results in incorrect eligibility status...
Incorrect household size or failure to include all household members;
Incorrect income amount and/or frequency of pay period;
Incorrect eligibility guidelines used in determining eligibility, including in the eligibility software.
Application is incomplete or missing key data
Common Review Finding:Applications
FINDING: Free/reduced applications are not processed within 10 days of receipt…
Applications should be reviewed and an eligibility determination made IMMEDIATELY, but no later than 10 days from receipt.
Direct Certification:What are we looking for?
Did the Direct Certification list contain all required information?
Did the SFA perform Direct Certification the required number of times?
Are students that have free eligibility based on Direct Certification found on a list as a match?
Was extension of benefits done correctly?
Direct Certification:New For 2014-2015
16
SFAs will now be required to run direct certification to show eligibility by school within the SFA
Wisconsin School Directory online:http://dpi.wi.gov/directories
Last Name
First Name
Middle Initial
Date of Birth
School Use
School Number
Benefit Issuance:What are we looking for?
Was each student’s eligibility status properly transferred from the certification document to the benefit issuance document?
Does the benefit issuance document contain all required pieces of information?
Was the benefit issuance document updated as needed?
Are benefits provided in a manner that prevents overt identification?
Common Review Finding:Benefit Issuance
FINDING: Student eligibility status is not updated in Point Of Sale (POS) or roster…
Eligibility must be current and correct at POS and on eligibility rosters at all times, including at the end of the 30 operating day carry-over period and at the end of the Verification process.
REMEMBER…change in status must occur no later than 3 days for an increase in benefits and 10 calendar days for decrease in benefits.
Common Review Finding:Benefit Issuance
FINDING: One student is receiving free benefits due to Direct Certification, but his sibling is reduced or full pay.
REMEMBER…Free eligibility may be extended to other school-aged children living in the SAME household , based on another household member’s receipt of FoodShare or W-2 benefits or FDIPR.
Common Review Finding:Benefit Issuance
FINDING: Reimbursement claimed for student meals when there is not an approved application on file…
Except during the *carry-over period, meals may not be claimed under the free or reduced price meal category unless: an approved application is on file; student is directly certified or extended benefits; student is certified to be foster child, homeless,
runaway, migrant or Even Start/Head Start
Independent Review of Applications
Second review of applications before eligibility determinations are made by someone other than the original Determining Official
Required if certification and benefit issuance errors is greater than 10%
Would occur during the subsequent school year
Technical Assistance/Corrective Action
Technical assistance will be provided and corrective action will be required for all certification and benefit issuance errors identified
Corrective action must be applied system-wide, including at non-reviewed schools
Fiscal Action
Taken for errors resulting from the following: Applications with missing information Miscategorized certifications (eligibility) Benefit issuance errors Failure to update a change in eligibility
status resulting from Verification
Administrative Review (AR):General Areas of Review
Nonprofit school foodservice account
Paid lunch equity Revenue from
non-program foods
Indirect costs USDA Foods
Civil rights SFA On-site monitoring Local school wellness
policy Smart Snacks School meal environment Water availability Food safety Reporting and
recordkeeping SBP/SFSP outreach efforts
Resource Management General Program Compliance
Verification
A process used by SFAs to confirm selected students’ eligibility for free and reduced price meals in the National School Lunch Program and School Breakfast Program. Only required for a sample of students Students certified for free meal benefits
through Direct Certification or other documented sources of categorical eligibility (e.g. homeless, migrant, runaway) are not subject to Verification
Verification Process:Off-site Review Procedures
Questions to explore whether SFA has met all Verification requirements: Participation in Verification
training Conducted process
appropriately Properly changed eligibility
status (if required) Submission of Verification
Collection Report (FNS-742) Compliant electronic
system (if applicable)
N/A
Off-site Assessment Tool Supporting Documentation
Verification Process:On-site Review Procedures
Validate any information provided on the Off-site Assessment Tool
Determine compliance with Verification Requirements
Select sample of verified applications for additional evaluation
Verification:What are we looking for?
Were applications selected correctly? Was the confirmation review
appropriately conducted? Do notification letters contain all required
information? Was follow-up conducted for
unresponsive households? Were changes in eligibility made within
the required timeframes? Was the process completed by November
15?
Common Review Finding:Verification
FINDING: Confirmation review requirements not understood…
Confirming Official must review each application selected for Verification
Eligibility may need to be changed and the application may need to be replaced based on outcome of confirmation review
Common Review Finding:Verification
FINDING: Application in Verification sample pool not replaced when household withdraws from district during Verification process…
If the Verification process was not completed before the household withdraws, a “similar” application must be selected in its place.
Common Review Finding:Verification
FINDING: The follow up requirements were not met for the Verification process…
SFA must make at least one follow up attempt to obtain documentation when household does not adequately respond
SFA must maintain records of follow up attempts
Technical Assistance/Corrective Action
Technical assistance will be provided and corrective action will be required for all Verification errors
Fiscal Action
Fiscal action is not required for General Areas of Review
Fiscal action is applied for students reviewed in cases of Verification-related certification or eligibility change errors
August 2014 revisions to USDA’s Eligibility Manual for School Meals
Eligibility Manual Clarifications
Eligibility Manual Clarification Other Source Categorically Eligible
status must be confirmed prior to certification for free and reduced price meals
Eligibility Manual Clarification Eligibility Manual states (pgs 29, 31, 33, 55):
“LEAs should validate case numbers/other identifiers listed on the application by reviewing direct certification data or contacting local assistance program officials. Validation means a confirmation of an active case number.”
Per USDA, nothing has changed with the process. Only required to validate format (i.e. is the
FoodShare or W-2 cash benefits case number 10 digits long)
Not required to check against Direct Certification list or contact program officials
Eligibility Manual ClarificationIs a child considered a foster child if
placed in a relative’s home? Whether placed by the state welfare
agency or a court, in order for a child to be considered categorically eligible for free meals, the State must retain legal custody of the child
Eligibility Manual ClarificationEffective Date of Eligibility Determinations Can establish the date of submission of
an application as the effective date, rather than the date the Determining Official approved it
LEAs must notify State Agency if they decide to implement this flexibility
For further information, see USDA memo SP 11-2014
Eligibility Manual Clarification
Effective Date of Eligibility Determinations Can use the date the student is first identified as
eligible for free meals via Direct Certification, rather than the date the LEA processes the Direct Certification file into their POS system
For Other Source Categorically Eligible students: Can use the date the household or agency official
submitted the letter, list, or other form of documentation to the LEA, rather than the date the eligibility is confirmed
*Must notify State Agency before implementing this flexibility. See USDA memo SP 51-2014
Eligibility Manual Clarification Transferring eligibility within the same LEA
Eligibility must be transferred P2 to non-P2: new application or DC may be
required CEP to non-CEP: new application or DC may be
required Transferring eligibility to another school
district/LEA Not required to share eligibility May accept eligibility from former LEA, but must
double check
Eligibility Manual Clarification“Questionable application” under
Verification for Cause: Inability to confirm household’s
participation in Assistance Programs Ineligibility for other benefits based on
data included on the household application
Variance in household size
Resources
USDA’s Eligibility Manual for School Meals (updated August 2014)http://fns.dpi.wi.gov/fns_fincou1#manual
Direct Certification materialshttp://fns.dpi.wi.gov/fns_directcert
Verification materialshttp://fns.dpi.wi.gov/fns_fincou1#verification USDA Guidance Memoshttp://www.fns.usda.gov/school-meals/policy
Remember…
The AR process is not intended to “get” schools who don’t comply
It is intended to provide schools with the tools and guidance they need to operate a successful nutrition program
Working together we can meet that goal!
Feeding children matters… Thank
You for all that you
do!
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