Verification

School Nutrition Programs

Verification of Applications for Educational Benefits – SY 2013-14

Local education agencies (LEAs) that participate in School Nutrition Programs (SNPs) are required to verify a percentage of approved Applications for Educational Benefits by contacting households for confirming information at the beginning of each school year.

− LEAs must complete verification activities for school year 2013-14 no later than November 15, 2013. This document provides procedures for conducting verification with households.
LEAs must report verification results to the Minnesota Department of Education (MDE) between November 1 and 15, 2013. Instructions for reporting verification data to MDE will be provided by November 1, 2013.
− Program reimbursements may be delayed if verification activities are not completed and reported to MDE by November 15.

Exemptions

Only the following types of LEAs, which do not collect any Applications for Educational Benefits for school meal purposes, are exempt from conducting verification:

− Residential child care institutions, with no day school students.
− LEAs with all sites participating in Provision 2 or 3 (in non-base year).

(These LEAs are required to complete a verification report to MDE to report the LEA’s current number of enrolled students.)

New Verification Data Elements

While conducting verification activities for 2013-14, be aware that requirements for verification reporting have changed significantly for school year 2013-14, including new data elements that LEAs will be required to report. View the Verification Reporting User Guide.

Additional Resource

For additional information about verification requirements, refer to Part 8 – Verification in the U.S. Department of Agriculture (USDA) Eligibility Manual for School Meals. View USDA Eligibility Manual for School Meals.

Verification Procedures

Applications Subject to Verification

Applications for Educational Benefits submitted for the current school year are subject to verification. The LEA must select a sample of applications to verify, as described below.

Not subject to verification:

− Carry-over applications from the prior school year. Carry-over applications are not counted when determining the number of applications to verify, and may not be selected for verification.
− Direct certifications, and other certifications such as for homeless students and Head Start students.

Number of Applications to Verify

To determine the number of Applications for Educational Benefits that must be verified:

1. Determine the total number of applications that the LEA has approved for the current school year as of October 1. Do not include applications carried over from the previous school year, or any other certifications for school meal benefits for example direct certifications.

An LEA may begin its verification process prior to October 1, based on the number of expected applications. If the verification process is started before October 1, the LEA must check on October 1 whether a sufficient number of applications were selected for verification and if necessary select additional applications.

2. Determine the sampling method that the LEA will use to select applications for verification from the three sampling methods listed below. Check whether your LEA is on the list of school food authorities required to use the three percent error-prone sampling method: View - List of School Food Authorities Required to Use Three Percent Error-Prone Sampling Method. If your LEA is not on the list, any one of the three sampling methods may be used.

Authorized Sampling Methods:

Note on rounding: For any of the three sampling methods listed below, round up (not standard rounding) to the next whole number when determining the number of applications to verify. For example, an LEA verifying three percent of 105 approved applications must select four applications to verify (105 X 3% = 3.15, rounded up to 4).

LEAs may not verify 100 percent of applications (unless there was only one approved application) and may not choose to verify “extra” applications as part of the required verification sample. LEAs may verify any questionable application “for cause,” in addition to the required verification sample.

An LEA may decline to verify, and replace with another application, up to five percent (5%) of the total number of applications selected for verification. Any LEA may decline and replace one application, regardless of the total number of applications being verified. Consider factors such as household stability and communication difficulties when declining and replacing an application. Once the verification process has begun by notification to the household, an application may not be declined and replaced for verification.

Sampling Method 1 - “Three Percent Error-Prone”

This sampling method must be used by LEAs that are on this list: View - List of School Food Authorities Required to Use Three Percent Error-Prone Sampling Method.

The LEA verifies three percent (3%) of the number of current-year applications approved as of October 1, rounded up (not standard rounding) to the next whole number. Select the required number of applications from error-prone income applications, that is, those applications that are within $100 of monthly income eligibility guidelines. If error-prone applications are insufficient, randomly select additional applications from other (non-error-prone) applications.

LEAs that are required to conduct three percent error-prone verification are also required to verify, for cause, any applications submitted by households that failed to respond to verification in the previous school year. See the section below on “Additional Verification Requirement for LEAs over 20 Percent Non-Response.”

Sampling Method 2 - “Three Percent Random”

The LEA verifies three percent (3%) of the number of current-year applications approved as of October 1, rounded up (not standard rounding) to the next whole number. Randomly select the required number of applications from all approved applications.

LEAs that are on the list of School Food Authorities Required to Use Three Percent Error-Prone Sampling Method (see link above) may not use this sampling method.

Sampling Method 3 - “One Percent Plus”

Note: This sampling method usually results in verifying fewer applications than the “three percent” methods, except for LEAs with a small number of applications to verify.

1. The LEA verifies one percent (1%) of the total number of current-year applications (income and case number applications) that were approved as of October 1, rounded up (not standard rounding) to the next whole number. Select the applications from error-prone income applications, that is, applications that are within $100 of monthly income eligibility guidelines. If error-prone applications are insufficient, randomly select additional applications from other (non-error-prone) applications.
2. In addition, the LEA verifies one-half percent (0.5%) of case number applications that were approved as of October 1, rounded up to the next whole number.

LEAs that are on the list of School Food Authorities Required to Use Three Percent Error-Prone Sampling Method (see link above) may not use this sampling method.

Additional Verification Requirement for LEAs over 20 Percent Non-Response

LEAs that are on the list of School Food Authorities Required to Use Three Percent Error-Prone Sampling Method (see link above) are required to conduct “for cause” verification on any current-year applications submitted by those households that did not respond to verification requests in the previous school year.

Confirmation Review of Original Approved Status or Waiver

Before proceeding with verification, the approved eligibility status of all applications selected for verification must be double-checked by a person other than the person who made the original eligibility determination, unless MDE has waived this requirement for an LEA that uses a reliable computerized system for application approval. If your LEA uses a computerized system but has not applied for the waiver, download the Application for Waiver form from the SNP – Student Meal Applications – Verification page of the MDE website.

If the confirmation review of an application shows that the application should have been denied at the original time of application, notify the household of termination of benefits and select a different application for verification. If the confirmation review of an application shows that the application was correctly approved, or that the household should have been approved for a different benefit (reduced-price instead of free, or vice versa), then proceed with verification.

Notification to Households

Template letters to notify households about verification are available on the MDE website.

Notice of Selection for Verification Letter (“We Must Check Your Application”) If any households being verified are outside of the local calling area, the LEA must either provide a toll-free number or instruct the household to reverse the phone charges.

View Template Letter – Selection for Verification.

Notice of Verification Result Letter (“We Have Checked Your Application”) Households whose meal benefits are being changed or terminated must be notified. The LEA may notify households that have no change in meal benefits.

View Template Letter – Notice of Verification Results.

Translated versions of USDA prototype verification letters are available on the USDA website. View translations of USDA prototype application-verification forms.

− Select the prototype application packet in the desired language (also review the English version for reference).
− The verification letters are toward the end of the packet.
− References to “TANF” on the verification letters should be changed to “MFIP” to make the letters specific to Minnesota. View translations of USDA prototype application-verification forms.

Non-Responding Households

Required Follow-Up

Before terminating benefits of a household that has not responded to verification, the LEA must make at least one follow-up attempt to contact the household, for example, by phone. Follow-up efforts and results must be documented.

Reporting Non-Response

A household that provides a partial or phone response is considered to have responded to verification. For example, it is counted as a response if a household informs the LEA that it will not be providing verification information and that it should returned to paid status. However, once meal benefits have been terminated due to non-response, an application must be counted as “non-response” when reporting verification results to MDE, even if the household later submits verifying information.

Reporting Verification Results

Verification results for school year 2013-14 must be reported to MDE by November 15, 2013. MDE will provide revised instructions for reporting by November 1, 2013.