Verification Process: What is Involved in Doing Verification ?

1. Verification Process:What is Involved in Doing Verification ? School Year 2010 – 2011 In accordance with Federal law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on the basis of race, color, national origin, sex, age, or disability. To file a complaint of discrimination, write USDA, Director, Office of Civil Rights (Office of Adjudication), 1400 Independence Avenue, SW, Washington, D.C. 20250-9410 or call toll free (866) 632-9992 (Voice).  TDD users can contact USDA through local relay or the Federal Relay at (800) 877-8339 (TDD) or (866) 377-8642 (relay voice users). USDA is an equal opportunity provider and employer.

2. Verification Process Resource The Verification Process is explained in the Eligibility Manual for School Meals, January 2008 edition, Parts 8 – 9, pages 62 - 84. This includes most federal updates to date. • Terms related to the Free and Reduced Price eligibility process (may be helpful to understand parts of verification) are included on pages 4 – 5. • Terms used in understanding the Verification Process are included EM page 65

3. Save These DPI Webpages: DPI Child Nutrition Website is located at: http://fns.dpi.wi.gov/fns_index (click on “Verification” in green left margin) Verification information is located at: fns.dpi.wi.gov/fns_fincou1 Be sure to check each school year for the most current forms/information

4. Hot Topics - new information Quick Links to frequently used topics Verification Forms link to section with forms and related documents

5. Verification Resources Verification Forms packet Contains the information and forms that include: Worksheets for the three sampling methods Household notification letter (We Must Check Your Application) Household results of verification letter (We have checked your application) Verification Tracker (use 1 for each application)  Other information and forms for verification

6. Verification documents related to Verification process Verification Forms information and forms to use in verification including letters and the “tracker” Verification Summary Report Link will be live starting November 1 to submit the report

7. Verification Tracker Use one for each application Notes the steps to be sure they are documented Section on results helps get ready for the Verification Summary Report

8. What the Verifying Official Needs to Know What is Verification and How is it Conducted

9. What is Verification? • Confirming eligibility for a sample number of applications received/approved in the current school year for free and reduced-price meal benefits under the NSLP and SBP • Required by USDA for all school agencies & any Residential Child Care Institution (RCCI) with day students who are participating in federal meal programs such as National School Lunch Program (NSLP) & School Breakfast Program (SBP) who have any approved applications

10. How is Verification conducted? • As of Oct. 1, the total number of approved applications submitted for the current school year are counted • Sampling method to select applications is determined • Select required percentage based on sample method but no more (cannot verify 100% of applications) • Select any applications to be verified “for cause”

11. How is Verification Conducted? • Confirming Official checks only the applications selectedfor verification and corrects the eligibility status (if necessary) beforepaperwork is mailed to the household • Mail “We must check your application” letter and verification paperwork to every household selected for verification • Must make at least one “follow-up contact” with households who do not respond to submit all documents (keep record of follow-up contact)

12. How is Verification conducted? • Receive documents from household to verify information on original application • Examine documents submitted by household • Confirm or change household’s eligibility status based on documents they submit • Mail “We have Checked Your Application” letter to family with results of verification

13. Who is involved in the eligibility approval and verification process? Four “Officials” are named on the school/district’s on-line contract with DPI: • Determining Official • Confirming Official • Verifying Official • Hearing Official

14. Determining Official • Reviews each application for completeness, correct case number or computes income, signs/dates, approves/denies application • Compiles Benefit Issuance List for each school. This list documents each student’s Free or Reduced-price status & precise date of any change • Documents 30 operating days carry-over of eligibility from previous year or until a new application is approved, whichever occurs first EM pages 15-16, 20 – 21

15. Confirming Official • Reviews only the applications selected for Verification • Confirming Official can not be the same person as the Determining Official • Assures that the initial determination was correct. • If it was not correct: correct the application determination, benefit issuance list & inform household of correct eligibility (before the verification notices are mailed to households) • Household is excluded from Verification if no longer eligible for benefits EM page 70

16. Verifying Official • Can be the same person as Determining Official • Determines the number of applications to verify and selects the applications to be verified • Notifies household of selection for verification • Reviews information received for each application (income documents or household approved for Food Share, W-2 cash benefits, or FDPIR) selected for verification • Notifies household of results of verification • Maintains the records of verification

17. Hearing Official • Conducts a Hearing, when requested, for appeals to the determination or verification decision • Can not be involved in the original determination or the verification processes • Hearing Official is generally in a superior position to Determining and Verifying Officials EM page 77

18. Appeal Rights • Notify household of results of verification • Household has 10 calendar days to appeal decision and request a Hearing (child receives original benefits in this period) • If a household appeals during 10 calendar day period, LEA continues to provide original benefits to the child until hearing is held and a final determination made • If no appeal is made, change benefits at end of the 10 calendar days notice EM pages 76 – 77

19. Hearing Procedures • Household may request a school conference to review information before requesting a formal hearing • Refer to procedures in policy statement and the verification materials for formal hearing procedures EM page 77

20. Meeting Minimum Sample Size LEA may not choose to verify more than the required sample size LEA may not verify all applications EM pages 66 - 67

21. Sampling Method Selected Three Sampling Methods for selecting applications for Verification are: • Standard (formerly Basic) • Alternate 1 (formerly Random) • Alternate 2 (formerly Focused) Method is determined by previous year verification results For more information view the webcast: Verification Process 2010 – 2011: Basic Sampling Methods to Select Applications for Verification at: fns.dpi.wi.gov/fns_training

22. Computer Systems with Verification Feature Check the computer system to ensure that: • it selects appropriate sample size • it selects the error prone applications for the Standard and Alternate #2 sample methods • all letters to households generated by the computer system must contain: • the required current school year Privacy Act and Non-Discrimination Statement • Language indicating document submission timeframe and no cost telephone contact information EM page 10, 95 - 106

23. It Is Possible to Decline an Application • After the Confirmation Review, the LEA may decline up to 5% (.05) of applications selected for verification • Must choose a replacement application approved/selected on the same basis as the one declined (error-prone, income, case number, etc.). EM page 71

24. Some Possible Reasons to Decline an Application LEA may choose to decline an application because: • household had been selected for verification last year • household has language barriers, literacy issues, health care issues or is embroiled in a custody battle which may impact their compliance • household with on-going or unresolved issues with school agency which may impact their compliance EM page 71

25. Examples: verifying 100 approved applications (100 x .05 = 5), LEA can replace up to 5 of those applications verifying 45 approved applications (45 X .05 =2.25=3) LEA can replace up to 3 of those applications verifying 16 applications (16 x .05=.8=1) can replace 1 application with another application A minimum of one application may always be replaced. EM page 71 Declining Applications

26. Replacing an Application Applications may need to be replaced after Confirmation Review or if an application is declined. Randomly select a similarly approved replacement application if: • Confirming Official finds an error in the initial determination and household is no longer eligible for free or reduced- price meals • Student/students listed on selected application have left the school/district EM pages 66 - 67

27. What the Verifying Official Needs to Know Other Situations

28. Verification “For Cause” • School agencies have an obligation to verify all questionable applications “for cause” as soon as possible (not necessarily at time of regular verification) • “Questionable application” is one that appears correct and approvable but may have other reasons to question • Approve first, then verify for cause • Any verification conducted “for cause” is in addition to the sample size required for the “official” verification process and is not included on the Verification Summary Report EM pages 21, 26, 66 – 67

29. Zero Income Household • Applications may be selected for verification • Household must provide written documentation describing the household’s circumstances when no income is indicated on the application (how they are meeting living expenses) • LEA may request additional written documentation or collateral contacts EM pages 19, 21-22, 74

30. Foster Child/Kinship Care • Foster Child – Application is subject to verification. If selected,social worker must confirms child’s “foster child” status and any personal income either in writing or over the phone (write down documentation received orally on application). Should be separate application for each “foster child”. • Kinship Care child should have been reported on a “household application”. If based on income, should include all household members and all sources of income. EM pages 18, 32, 34,74, 79

31. Irregular Income • Overtime – Not included if only a sporadic source of income; • Overtime –Included if overtime is frequent and therefore a regular source of income; • Irregular earnings (odd jobs on an irregular schedule) not included EM page 35

32. What the Verifying Official Needs to Know Documenting Eligibility

33. Documentation to Support Eligibility Written evidence received directly from the household for income or categorical eligibility Refer to Verification Forms posted at:http://fns.dpi.wi.gov/fns_fincou1

34. Documentation to Support Eligibility Collateral contact identified by household that school can request information from directly: • Employers • Social service agencies • Migrant workers’ agencies • Religious, civic organizations Refer to Verification Forms posted at:http://fns.dpi.wi.gov/fns_fincou1

35. Income Documentation • Shows income for any time from one month prior to application up to the time of verification • Must specify frequency of income source (e.g., weekly, biweekly, monthly) check with household if frequency is not clear • Must receive documentation for all sources of income reported on an application • Must use gross income, except for self-employment income (business, farming) and seasonal earnings EM pages 34, 72-74

36. Food Share, W-2 Cash, FDPIR Eligibility Documentation • Documentation that shows eligibility at any time from one month prior to application up to the time of verification • Documentation must include name of children on application to prove they were eligible EM pages 72-74

37. After Household Responds, Verifying Official: • Compares documentation with information listed on the application • Computes total income from documentation for income applications • Confirms or changes eligibility status

38. After Household Responds, Verifying Official: • Updates benefit issuance list or computer system database to correct benefit level • Informs household that eligibility remains the same or changes (be sure to use the most current “We have checked your application” letter from DPI website) • Written notice required to include “Appeal Procedures” for change in benefit leveland/or for termination of benefits EM pages 76 - 77

39. Insufficient Evidence or No Response • School agency mustmake at least one documented attempt (written or verbal) to contact the household and inform them that failure to comply with verification will result in termination of benefits • Terminate benefits and change to paid eligibility status if households do not respond by deadline set, but no later than November 15 EM pages 75 - 76

40. What the Verifying Official Needs to Know Verification is Complete

41. Verification Is Complete When: Household eligibility for the level of benefits is: • Confirmed at the same eligibility level • Confirmed at a greater eligibility level • Determined to be ineligible (denied benefits) EM page 76

42. Verification is complete when: Household is notified and eligibility for benefits is: • Changed to a higher eligibility level • Letter of adverse action (We have Checked Your Application) is sent informing the household that benefits will be reduced • Letter of adverse action is sent informing the households that benefits will be terminated (changed to paid status) EM page 76

43. Notification Letter with Results of Verification • Specify change in benefits and reason • Include appeal procedures and time frame for submitting appeal (within 10 calendar- days from date on notice) to continue benefits • Inform household they may reapply during the same school year, but documentation is required to verify information on application prior to approval Refer to Verification Forms posted at: http://fns.dpi.wi.gov/fns_fincou1

44. Time Periods for Changing Eligibility Status Any household that fails to respond or does not submit verification documentation for all information on application must receive notice that they will be changed to paid status • Reduction or Termination of benefits – household has 10 calendar days from date on written notice to file for Appeal • Increase in benefits – effective immediately and must be implemented no later than 3 operating days after decision EM pages 76 - 77

45. Reporting the Results of Verification • USDA requires that results of verification be reported to the State Agency • Results are submitted to DPI on-line in the Verification Summary Report • Verification Summary Report must be submitted to DPI between November 1 and November 15 each year

46. Reporting the Results of Verification • Schools who do not submit the Verification Summary Report by November 15 will be put in withholding • These schools will not be able to submit claims on-line or receive reimbursement payments until the report is submitted.

47. QUESTIONS On Verification? Contact DPI School Nutrition Team Personnel Directory is posted at: http://fns.dpi.wi.gov/fns_directory

48. More Training Opportunities Go to “Training Opportunities” to review webcast sessions and other DPI training opportunities: fns.dpi.wi.gov/fns_training Watch for a mailing in late September on verification

49. Thank you for participating and for your support of Wisconsin students every day !!!