USDA Eligibility Manual for School Meals, July 2017 Pages 99 -100
https://fns-prod.azureedge.net/sites/default/files/cn/SP36-2017_CACFP15-2017_SFSP11-2017a1.pdf
Verification for Cause:
· Sponsors are required to verify all questionable applications.
· If an application is complete and indicates that the child is eligible for free or reduced price benefits, the application must be approved while the sponsor begins ‘Verification for Cause.’
· ‘Verification for Cause:’
o Cannot delay the approval of applications
o Is separate from the verification sample required yearly.
o May be conducted at any time during the school year.
o Used when school employees may have misrepresented their incomes on their applications.
· The process used for Verification for Cause is the same as yearly verification.
‘Verification for Cause’ is outlined in the following steps:
1. Conduct a confirm review of questionable applications selected for ‘Verification for Cause:’
Required for manual eligibility systems (determine eligibility by hand) A confirmation review of selected applications must be completed by a different person than who approved them.
Waived if:
· Technology-based system is used with a high level of accuracy (Sponsors must contact the state agency to determine if their system qualifies them for this waiver.)
· All applications are reviewed at the time of certification.
Sponsor Responsibilities Following a Status Change
/No Change in Status / The Sponsor verifies the application
Status Change from
Reduced Price to
Free / The Sponsor:
· Makes the increased benefits available immediately;
· Notifies the household of the change in benefits; and
· Verifies the application.
Status Change from
Free to Reduced
Price / The Sponsor:
· Does not change the child’s status;
· Verifies the application;
· Notifies the household of the correct eligibility status after verification is completed and, if required, sends the household a notice of adverse action.
Status Change from
Free or Reduced
Price to Paid / The Sponsor:
· Immediately sends the household a notice of adverse action;
· Does not verify the application;
· Selects a similar application, such as another error prone application for verification; and
· Follows the confirmation review procedures for the selected application.
2. Notify Households of selection by sending written notification with deadline.
Sponsors must send the household a Notice of Verification Selection Letter.
(This is the same letter used for yearly verification) informing them of their responsibility to:
· Submit documentation and the deadline for submission
· Include a toll free phone number for parent/guardian needing assistance
· Notice of Verification Selection letter may be sent at the same time as the Household Eligibility Notification letter.
3. Verify household submitted information
· Review the submitted written information from each household to determine the level of benefits
· File and retain this information provided by households
The documentation must include:
o confirmation that the child or any household member is receiving SNAP, TANF or FDPIR
OR
o confirmation of income eligibility
Use the most current income data. Current income is that amount of money for one of the following:
o Current month
o Month for which the application was filled out (may be projected)
o Month prior to application
Calculating Monthly Income for all household members must be documented. Income means any money regularly received from work, child support, alimony, pensions, retirements, social security or any other source.
Exclude student/school loans and one-time or sporadic Over-Time pay.
If a household has multiple income sources and income sources are received with varying frequency, the sponsor MUST annualize (Math calculations for all income to convert to annual) by:
· Weekly: Multiply total earnings and wages for one pay period, before deductions, by 52.
· Bi-weekly (paid every 2 weeks): Multiply total earnings and wages for one pay period, before deductions, by 26.
· Semi-monthly (paid twice a month): Multiply total earnings and wages for one pay period, before deductions, by 24.
· Monthly income multiple total earnings and wages by 12.
Household members who are seasonal workers or work less than 12 months: Calculate the annual rate of income from the documentation provided.
Note: Money received from a business or farm owned by you should be reported as "net income." Net Income is defined as the total income left after business and farm operating expenses are subtracted from gross receipts. This may be documented from a prior year’s taxes.
No Income: When a household indicates no income, they need to provide a written explanation how living expenses are met. Sponsors may request additional written documentation and/or collateral contacts.
· The verifying official should request collateral contact when the household has not been able to provide adequate written evidence.
· Collateral contact is a person outside the household who is knowledgeable about the household’s circumstances and can confirm income or Assistance Programs or Other Source Categorical Eligibility.
· Collateral contacts include employers, social service or migrant agencies, religious or civic organizations.
4. Notify households of results
· If verification results in higher benefits or no change in benefits, the household can be notified in person, by telephone or in writing.
· If verification results in reduced or terminated benefits due to response, written notification is required. Send the ODE CNP Verification Results Letter.
· If verification results in terminated benefits due to non-response, written notification is required. Send the ODE CNP Verification Results- Non-Responding Letter.
· Households must be given 10 calendar days to appeal reduced price or terminated benefits.
5. ‘Verification for Cause’ is complete:
· Household responds by submitting either adequate written evidence or collateral contact corroboration of income or categorical eligibility – Benefit status:
o Confirmed
o Changed to a higher level (F è R)
o Reduced or terminated send the Notification of Meal Change Benefits letter no later than November 15. (The 10 day appeal period may delay the change in meal benefits an additional 10 calendar days.)
Household may indicate verbally or in writing, it no longer wishes to receive free or reduced benefits send the Notification of Meal Change Benefits letter no later than November 15.
· Household do not respond and benefits are being terminated send the Verification Results– Non Responding Letter no later than November 15. (The 10 day appeal period may delay the change in meal benefits an additional 10 calendar days.)
· Verification status changes are made at the Point of Service (for each student on the application.)
Note concerning sponsor employees:
It is recommended that sponsors consult with legal counsel in establishing the parameters of “Verification for Cause” for school district employees.
It must not be used to automatically verify households of all school district employees whose children are certified for free or reduced price meals. However, from among the list of children approved, a sponsor could identify children of school district employees and use sponsor salary information available to identify questionable applications and then conduct verification as needed.
Results from Verification for Cause are now included on the FNS 742a Verification Collection Report in CNPweb on the Claims tab as shown below.
If households reapply after Verification:
If benefits were reduced or terminated because of the failure to complete Verification or “Verification for Cause” and household reapplies in the same school year, the household is required to submit income documentation or SNAP, TANF or FDPIR proof. These applications are not considered new applications. Page 59
Retain completed for three years plus the current year:
· All relevant correspondence including documents submitted by the household and letters of reduction of benefits or termination of benefits sent to the households
Verification Resources are located at:
http://www.oregon.gov/ode/students-and-family/childnutrition/SNP/Pages/Verification.aspx
· Verification Sample Processes and Instructions
· FNS 742 Verification Collection Report (Sample Only) actual report is in CNPweb on the claim tab.
· Letters to Households:
o Notice of Verification Selection
o Notification Changing Meal Benefits (Use for Administrative Review, Second Review of Applications, and Verification)
o Verification Results Non-Response Letter – Notice of Adverse Action
· Tracking form (optional)
Schools Verification Quick Reference (Rev 8/17) Page 1 of 4