Verification Kentucky Department of Education September 2012

VerificationVerification

Kentucky Department of Kentucky Department of EducationEducation

September 2012

What is Verification?What is Verification?

Verification is the confirmation of eligibility for free and reduced price meals under the NSLP and SBP.

Verification is only required when eligibility is determined through the application process.

Verification must include either confirmation of income eligibility or confirmation that the child or any

member of the household is receiving assistance under SNAP (formally food stamps) or TANF (formally welfare) or that a child is Other Source Categorically

Eligible. Verification may include confirmation of any other information required on the application such as

household size.


vs. vs.

Verification for Verification for CauseCause

Verification For CauseVerification For Cause

Verification for cause is when an Verification for cause is when an application is verified outside of application is verified outside of the required verification the required verification procedures reported to the State procedures reported to the State Agency. Agency.

Eligibility Guidance for School MealsEligibility Guidance for School Meals

August 2012August 2012 Reflects changes from:Reflects changes from:

– Reauthorization of 2010,Reauthorization of 2010,– Final and interim regulations,Final and interim regulations,– Policy clarifications.Policy clarifications. www.fns.usda.gov/cnd

Verification Not Verification Not RequiredRequired Children who have been directly certified through Children who have been directly certified through

the monthly electronic downloads for Foster the monthly electronic downloads for Foster Children, SNAP/KTAP and Medicaid recipients.Children, SNAP/KTAP and Medicaid recipients.

Children appropriately documented by the District Children appropriately documented by the District as eligible migrant, homeless or in a federally as eligible migrant, homeless or in a federally funded Headstart or Even start slot in a District funded Headstart or Even start slot in a District operated program (not a State funded Slot).operated program (not a State funded Slot).

Residential children in a RCCI (non residential Residential children in a RCCI (non residential students are included in verification).students are included in verification).

Non base year applications for Provision 2 or 3.Non base year applications for Provision 2 or 3.

Verification ProcessVerification Process

I. Determine type of verification

II. Select Applications for Verification

III. Conduct Confirmation Review (Replacement Applications)

IV. Household Notification

V. Conduct Verification

VII. Verification Report to SA (742)

VI. Verification Results

Timeline of Verification Timeline of Verification ActivitiesActivities October 1st – Day that October 1st – Day that

establishes the sample pool.establishes the sample pool. November 15November 15thth – All verification – All verification

activities must be complete or activities must be complete or SFA must have an approved SFA must have an approved extension with SCN.extension with SCN.

*February 15*February 15thth – Verification – Verification Reporting in ColyerReporting in Colyer

* More information to come* More information to come

Determine Type of Determine Type of VerificationVerification

Standard Sample Size – Calculation for # Standard Sample Size – Calculation for # of error prone applications to verify.of error prone applications to verify.

Alternate One Sample Size –Calculation for the # of random applications to verify.

Alternate Two Sample Size – 2 step calculation that provides a combination of error prone applications and applications approved based on a case number on their application.

I.I.

Prior Approval Prior Approval RequiredRequired

All SFA’s must use the All SFA’s must use the Standard Standard Sample SizeSample Size Verification type Verification type unless approval is obtained from unless approval is obtained from SCN to use Alt 1 or Alt 2 prior to SCN to use Alt 1 or Alt 2 prior to Verification activities on October 1Verification activities on October 1stst. .

Approvals this year are conducted Approvals this year are conducted by emailing your approving by emailing your approving consultant. If an approval is given, consultant. If an approval is given, keep on file with verification records.keep on file with verification records.

Alternate Approval Alternate Approval EligibilityEligibility The LEA’s non response rate was The LEA’s non response rate was

less than 20% for the previous less than 20% for the previous year.year.

If the LEA has more than 20,000 If the LEA has more than 20,000 children approved for free or children approved for free or reduced benefits by application reduced benefits by application and show a 10% decrease in their and show a 10% decrease in their non response rate from the non response rate from the previous year.previous year.

The above is based on the assumption that the verification sample sizes were correctly calculated and the correct number and types of applications were verified. Approval will not be granted if the verification process if found invalid during a CRE in the previous school year or through Verification reporting to the SA in the previous year.

Sample PoolSample Pool

The sample pool for all types of The sample pool for all types of verification is based on the verification is based on the number of free and reduced number of free and reduced applications on file as of applications on file as of October 1October 1stst..

August 2012 Eligibility Manual

Sample Size Sample Size CalculationsCalculations All fractions or decimals are All fractions or decimals are

rounded up to the nearest whole rounded up to the nearest whole number. number. Example – 6.1 would be 7 Example – 6.1 would be 7 applications.applications.

LEA’s may not verify more or less than LEA’s may not verify more or less than the calculated sample size. For the the calculated sample size. For the example above, only 7 applications example above, only 7 applications can be verified. Not 6 or less and not can be verified. Not 6 or less and not 8 or more.8 or more.


Standard VerificationStandard Verification

The number of applications in the The number of applications in the

sample pool sample pool XX 3% (.03) = The number 3% (.03) = The number of applications to verify, selected from of applications to verify, selected from error prone applications.error prone applications.

*The maximum number of *The maximum number of applications to verify is 3,000 applications to verify is 3,000 applications.applications.

Standard Sample SizeStandard Sample Size

900 total applications:900 total applications:– 600 income applications600 income applications– 300 SNAP/TANF Case number applications300 SNAP/TANF Case number applications

900 X .03 = 27900 X .03 = 27 27 “error prone” applications to Verify27 “error prone” applications to Verify


Alternate One (Alt 1)Alternate One (Alt 1)

The number of applications in the The number of applications in the

sample pool sample pool XX 3% (.03) = The 3% (.03) = The number of applications to verify, number of applications to verify, selected randomly.selected randomly.

*The maximum number of *The maximum number of applications to verify is 3,000 applications to verify is 3,000 applications.applications.

Alternate 1 Sample Alternate 1 Sample SizeSize 900 total applications:900 total applications:

– 600 income applications600 income applications– 300 SNAP/TANF Case number applications300 SNAP/TANF Case number applications

900 X .03 = 27900 X .03 = 27 27 randomly selected applications to Verify27 randomly selected applications to Verify


Alternate 2 (Alt 2)Alternate 2 (Alt 2)

Two part calculationTwo part calculationPart 1:Part 1:

The number of applications in the The number of applications in the sample pool sample pool X X 1% (.01) = the 1% (.01) = the number of applications to verify number of applications to verify selected from error prone selected from error prone applications.applications.

*Maximum of 1,000*Maximum of 1,000

Alternate 2 Sample Alternate 2 Sample Size Size Part 2:Part 2:

One-half (1/2) of one percent (1%) One-half (1/2) of one percent (1%)

or .005 or .005 X X the number of the number of applications approved based on a applications approved based on a case number for SNAP/KTAP = the case number for SNAP/KTAP = the number of applications to verify number of applications to verify approved categorically eligible.approved categorically eligible.

*Maximum of 500*Maximum of 500

Alternate 2 Sample Alternate 2 Sample SizeSize

Part 1 (error prone apps)Part 1 (error prone apps)

+ Part 2 (Case number apps)+ Part 2 (Case number apps)

= Total number of applications to = Total number of applications to verifyverify

Alternate 2 Sample Alternate 2 Sample SizeSize 900 total applications:900 total applications:

- 600 income applications- 600 income applications

- 300 SNAP/TANF applications- 300 SNAP/TANF applications 900 X .01 = 9 (Part 1)900 X .01 = 9 (Part 1) 300 X .005 = 1.5, round up to 2 (Part 2)300 X .005 = 1.5, round up to 2 (Part 2) 9 error prone applications + 2 SNAP/TANF 9 error prone applications + 2 SNAP/TANF

Case number applications = 11 total Case number applications = 11 total applications to verify.applications to verify.


Selecting ApplicationsSelecting Applications

Error ProneError Prone

Categorical Eligible (Case #)Categorical Eligible (Case #)

RandomRandom

IIII


Error Prone ApplicationsError Prone ApplicationsType of application to pull when Type of application to pull when conducting Standard and Alternate 2 conducting Standard and Alternate 2 Verification.Verification.DefinitionDefinition::

Applications that are within $100 per Applications that are within $100 per month ($1200 annually) of the month ($1200 annually) of the applicable Income Eligibility Guideline.applicable Income Eligibility Guideline.


Categorical Eligible (Case #)Categorical Eligible (Case #)Application approved based on a valid case number for SNAP/KTAP on an application.

Type of application to pull in Alternate 2 Verification.


RandomRandomCan be any application type. Error Prone, Non Error Prone or Case Number.Use for Alternate 1 Verification.

Conduct Confirmation Conduct Confirmation ReviewReview

Required to be conducted on all Required to be conducted on all applications pulled for verification applications pulled for verification PRIORPRIOR TOTO notifying the households of notifying the households of their selection for verification or their selection for verification or conducting Direct Verification activities.conducting Direct Verification activities.

An LEA official, other than the official An LEA official, other than the official who made the initial eligibility who made the initial eligibility determination must review each determination must review each approved application selected to approved application selected to ensure the initial determination was ensure the initial determination was correct.correct.

IIIIII


Confirmation Review Confirmation Review StepsSteps

1.1. Ensure that household members are not on Ensure that household members are not on the Direct Certification list. Apps should not the Direct Certification list. Apps should not be included if the household members can be be included if the household members can be identified as direct cert.identified as direct cert.

2.2. Identify how the determining official approved Identify how the determining official approved the application, income vs. case number. If a the application, income vs. case number. If a valid case number was provided, ensure that valid case number was provided, ensure that application is marked as being approved application is marked as being approved based upon a case number and not by based upon a case number and not by income.income.


3.3. Once it has been established how the Once it has been established how the application was determined (income application was determined (income vs. case number), review the vs. case number), review the eligibility manual to ensure that the eligibility manual to ensure that the application was approved correctly. application was approved correctly. (Part 4 of Eligibility Manual for income (Part 4 of Eligibility Manual for income applications and Part 5 for categorical applications and Part 5 for categorical Eligibility. If the application does not Eligibility. If the application does not have all required items, it is have all required items, it is considered incomplete.considered incomplete.


4.4. Depending upon the outcome of Depending upon the outcome of each confirmation review, the LEA each confirmation review, the LEA takes one of the following actions:takes one of the following actions:

No change in statusNo change in status– If initial eligibility status was correct, If initial eligibility status was correct,

the LEA verifies the application. the LEA verifies the application.


Confirmation ReviewConfirmation Review

Status change from reduced price Status change from reduced price to free:to free:

– Make the increased benefits Make the increased benefits available immediately; Notify the available immediately; Notify the household of the change in benefits; household of the change in benefits; Verify the application.Verify the application.



Status change from Free to Status change from Free to Reduced:Reduced:– Do not change the child’s status; Do not change the child’s status;

Verify the applicationVerify the application



Status change from Free or Status change from Free or Reduced to Paid:Reduced to Paid:– Immediately send the household a Immediately send the household a

notice of adverse action; Do not notice of adverse action; Do not verify the application; Select a verify the application; Select a similar application for verification; similar application for verification; follow confirmation review follow confirmation review procedures for the newly selected procedures for the newly selected application.application.


Replacing Replacing Applications.Applications.

Used when the status changed to Used when the status changed to Paid during the confirmation review Paid during the confirmation review or if the LEA believes the household or if the LEA believes the household would be unable to satisfactorily would be unable to satisfactorily respond to the verification request.respond to the verification request.

Replace with a like application. Replace with a like application. (Example, Error prone for error (Example, Error prone for error prone)prone)

Can replace up to 5% of applicationsCan replace up to 5% of applications


Household NotificationHousehold Notification

Letter RequirementsLetter RequirementsHousehold was selected for Household was selected for verificationverificationUse of information statementUse of information statementThe types of acceptable informationThe types of acceptable informationMay provide proof that a child or May provide proof that a child or other household member receives other household member receives SNAP/KTAP benefitsSNAP/KTAP benefits

IVIV



Documentation of income or receipt Documentation of income or receipt of assistance may be provided at of assistance may be provided at any point in time between the any point in time between the month prior to application and the month prior to application and the time the household is required to time the household is required to provide income documentationprovide income documentation

Information must be provided by Information must be provided by due date or benefits will be lostdue date or benefits will be lost



Provide a name of an LEA official Provide a name of an LEA official who can answer questions and who can answer questions and provide assistanceprovide assistance

A toll free number households can A toll free number households can use to contact the LEA or use to contact the LEA or instructions on how to call collectinstructions on how to call collect

*May have to rent a toll free line *May have to rent a toll free line during the verification time period. during the verification time period.


Conducting Conducting VerificationVerification

For income applications, households must For income applications, households must submit documentation for each income submit documentation for each income type reported for each household member.type reported for each household member.

For Case number applications, households For Case number applications, households must submit an official letter, notice or list must submit an official letter, notice or list from the appropriate State agency.from the appropriate State agency.

For all other types of categorical eligibility For all other types of categorical eligibility documentation requirements – refer to the documentation requirements – refer to the Eligibility Manual.Eligibility Manual.


VV

Conducting Conducting VerificationVerification TimeframeTimeframe

Documentation can be from 1 Documentation can be from 1 month prior to the date of the month prior to the date of the application until the time when application until the time when the documentation is due.the documentation is due.


Direct VerificationDirect VerificationConducted prior to notifying the householdConducted prior to notifying the householdMust use SCN direct verification form to send to Must use SCN direct verification form to send to appropriate agency with the names of the school appropriate agency with the names of the school children listed on the app. Names of other children listed on the app. Names of other household members and non school age children household members and non school age children should not be included. should not be included. *DIRECT *DIRECT VERIFICATION CANNOT BE CONDUCTED VIA VERIFICATION CANNOT BE CONDUCTED VIA A PHONE CALL TO THE AGENCY!A PHONE CALL TO THE AGENCY!If unable to verify eligibility, the LEA must If unable to verify eligibility, the LEA must proceed with regular verification activitiesproceed with regular verification activities


When Verification is When Verification is Considered CompleteConsidered Complete

The household submits either adequate The household submits either adequate written evidence or provides collateral written evidence or provides collateral contact corroboration of all income or contact corroboration of all income or categorical eligibilitycategorical eligibility

– Verification is considered complete Verification is considered complete for this household.for this household.

When Verification is When Verification is Considered CompleteConsidered Complete The household submits adequate The household submits adequate

written evidence or collateral contact written evidence or collateral contact corroboration of income that indicates corroboration of income that indicates that the household should receive a that the household should receive a greater or lesser benefit level.greater or lesser benefit level.– Complete when the notice of Complete when the notice of

adverse action is sent to the adverse action is sent to the household or notification of an household or notification of an increase in benefits.increase in benefits.

When Verification is When Verification is Considered CompleteConsidered Complete The household indicates *verbally or in The household indicates *verbally or in

writing that it no longer wishes to writing that it no longer wishes to receive benefits.receive benefits.– Complete when the notice of Complete when the notice of

adverse action sentadverse action sent

When Verification is When Verification is Considered CompleteConsidered Complete The application was approved based The application was approved based

on a case number and it is determined on a case number and it is determined that no household member is receiving that no household member is receiving benefits from an assistance programbenefits from an assistance program– Complete when the notice of Complete when the notice of

adverse action is sentadverse action is sent



Follow UpFollow Up

The LEA must make at least one follow-The LEA must make at least one follow-up attempt to contact the household up attempt to contact the household when the household does not when the household does not adequately respond to the request for adequately respond to the request for verification. verification.

Follow up may be in writing or phone Follow up may be in writing or phone with documentation that a contact was with documentation that a contact was attempted (initial statement, date and attempted (initial statement, date and time)time)



Follow up cont…Follow up cont…Must inform the household that failure Must inform the household that failure to provide adequate written evidence or to provide adequate written evidence or to designate an adequate collateral to designate an adequate collateral contact will result in termination of contact will result in termination of benefits.benefits.Attempt to obtain the missing written Attempt to obtain the missing written evidence or obtain collateral contact evidence or obtain collateral contact informationinformation


Conducting Conducting VerificationVerification The deadline to complete The deadline to complete

verification activities is November verification activities is November 1515thth..

Extension requests must be made Extension requests must be made in writing in writing to SCN. State agencies to SCN. State agencies may approve an extension up to may approve an extension up to December 15December 15thth. Beyond December . Beyond December 1515thth must be approved by USDA. must be approved by USDA.

Verification ResultsVerification Results

If benefits increased, the change If benefits increased, the change is effective immediately, is effective immediately, implemented within 3 working implemented within 3 working days and the household notified.days and the household notified.

If benefits decreased, a notice of If benefits decreased, a notice of adverse action must be sent.adverse action must be sent.

VIVI


Verification ResultsVerification ResultsAdverse action letter requirementsAdverse action letter requirements

Change in benefitsChange in benefitsReason for changeReason for changeAppeal must be filed within 10 calendar days Appeal must be filed within 10 calendar days and benefits will not change while awaiting a and benefits will not change while awaiting a hearing and decision.hearing and decision.Instructions on how to appealInstructions on how to appealMay re-apply for benefits at any time during May re-apply for benefits at any time during the school year the school year If terminated because no member was If terminated because no member was receiving benefits from SNAP/KTAP, may apply receiving benefits from SNAP/KTAP, may apply and provide income information.and provide income information.August 2012 Eligibility Manual


Households whose benefits were Households whose benefits were reduced or terminated may re-reduced or terminated may re-apply at any time during the school apply at any time during the school year. If benefits were terminated, year. If benefits were terminated, the household is required to submit the household is required to submit income documentation or proof of income documentation or proof of participation in SNAP/KTAP participation in SNAP/KTAP program.program.



Record KeepingRecord KeepingDescription of verification efforts Description of verification efforts including a summary of the selection including a summary of the selection process; the total number of applications process; the total number of applications on file on October 1on file on October 1stst and the number of and the number of apps that are/will be verified by Nov 15apps that are/will be verified by Nov 15thth..Compliance with the confirmation reviewCompliance with the confirmation reviewProvision of a no-cost telephone number Provision of a no-cost telephone number for assistance in the verification processfor assistance in the verification process



Recordkeeping cont…Recordkeeping cont…For each application: source For each application: source documentation used to verify the documentation used to verify the application; correspondence; written application; correspondence; written records documented by the LEA when a records documented by the LEA when a written records was not otherwise written records was not otherwise available; any other information available; any other information necessary to show the efforts by the LEA necessary to show the efforts by the LEA meet verification requirements; criteria meet verification requirements; criteria used to replace applications.used to replace applications.


Verification ReportingVerification Reporting

Form FNS – 742Form FNS – 742 New this year! New this year! Verification Verification

reporting will be conducted in the reporting will be conducted in the Colyer system.Colyer system.

VIIVII

Verification for CauseVerification for Cause

Not included in the annual verification process or Not included in the annual verification process or reported to the SA.reported to the SA.

LEA’s must verify all questionable applications.LEA’s must verify all questionable applications. If application is complete with all required If application is complete with all required

information it must be process and an eligibility information it must be process and an eligibility status awarded.status awarded.

Once Eligibility status determined, then a letter Once Eligibility status determined, then a letter for verification can be sent to the household. for verification can be sent to the household. This letter can go out at the same time that This letter can go out at the same time that notifies them of their benefits.notifies them of their benefits.

Verification for Cause Verification for Cause School District School District EmployeesEmployees Cannot automatically verify households of Cannot automatically verify households of

school district employees because salary school district employees because salary information is available.information is available.

Can be used if the LEA finds the application Can be used if the LEA finds the application questionable and is therefor subject to questionable and is therefor subject to verification for cause otherwise.verification for cause otherwise.

It is recommended to consult with legal It is recommended to consult with legal counsel in establishing the parameters of counsel in establishing the parameters of verification for cause when it involves a verification for cause when it involves a school district employeeschool district employee


To ensure that all verification To ensure that all verification requirements are met. It is a best requirements are met. It is a best practice to have documentation practice to have documentation second partied to ensure the records second partied to ensure the records are complete in order to avoid are complete in order to avoid findings in an administrative review.findings in an administrative review.

If you utilize a system to conduct If you utilize a system to conduct verification, double check all system verification, double check all system provided information. The LEA is provided information. The LEA is responsible for the information even responsible for the information even if the system did not provide it if the system did not provide it properly.properly.


Questions?

Documents

Verification Kentucky Department of Education September 2012