Summer Institute Deciphering the Verification Process Again. Presented by: Doreen Iovanna, LDN, DT August 11, 2014

Transcription

1 Summer Institute 2014 Deciphering the Verification Process Again. Presented by: Doreen Iovanna, LDN, DT August 11, 2014

2 General Definitions Verification: Confirmation of eligibility for free and reduced price meals under the NSLP and SBP. The LEA may begin verification activity once the application approval process for the current school year is underway Direct Verification: Using records from public agencies to verify income and/or program participation (EM) Error prone: Applications within a certain income variance of the applicable Income Eligibility Guidelines (IEG). Error prone replaces the term Focused Sample. (Please refer to the Verification Checklist) 2

3 General Definitions Random sampling: Each application has an equal chance of being selected. The LEA must determine a selection interval by dividing the number of applications by the required sample size Sample pool: The total number of applications determined and confirmed as of October 1 Sample size: The number of applications subject to verification; the minimum and maximum sample size is three (3%) For example: 100 free and reduced price applications x 3%= 3 applications need to be selected 3

4 Verification Official s Checklist 4

5 Exemptions from Verification Children who have been directly certified Homeless, Runaway and Migrant Children Foster children (unless included on a F/R app.) Children in RCCI s except for day students Children participating in Head Start/Even Start Schools that participate in Provision 2, except in the base year Schools participating in Community Eligibility Provision (CEP) 5

6 Exemptions for Verification In schools where all children are served with no separate charge for food service and no special cash assistance is claimed (i.e. nonpricing programs claiming only the paid rate of reimbursement) In schools only participating in Special Milk Program (SMP) Denied applications 6

7 Meal Benefit Application Selection Cycle Sample Pool Determined and Confirmed Meal Benefit Forms Received by October 1st Error Prone 1st 3% of the Total Pool 7

8 All of the following are examples of exemptions to the Verification Process except one: A. All Foster Children B. Schools that participate in Provision 2, except in the base year C. Schools participating in the Community Eligibility Process (CEP) D. Children participating in Head Start/Even Start Answer is A 8

9 7 Steps to Verification Success Step 1: Beginning October 1st a) Select the Verification Sample Pool b) Select the Verification Sample Size Step 2: Conduct Verification a)direct Verification Process and b)paper Verification (if needed) Step 3: Household Contact for: a) Direct Verification Exact Match b) Paper Verified Households *Select a Household Response Deadline *Household Follow-up must be initiated (Second Request, if needed) with Deadline For Households To Respond 9

10 Steps to Success: Step 4: Eligibility Changes when required Step 5: LEA Completes Verification Process Activity Step 6: November 15 Of Each School Year Verification Activities Must Be Completed Step 7: January 9, 2015 Verification Collection Report submitted to ESE through the security portal 10

11 Step 1a: Select the Verification Sample Pool Beginning October 1st 1)Establish the Sample Pool The number of applications (not the number of children eligible for meal benefits) determined and confirmed as of October 1 of the current school year 2)Establish the Standard Sample Size Three percent (3%) of the total approved free and reduced price applications on file as of October 1 (fractions/decimals are rounded up). Districts may qualify for one of the alternate sample sizes at the discretion of DESE. (Please refer to the Eligibility Manual (EM)) 11

12 Step 1b: Select the Verification Sample Size Beginning October 1st Random Selection: Any method which gives each application an equal chance of being selected as long as the selection does not involve discrimination If you have an.. a) Excessive Amount Of Error Prone Applications: Randomly select from the error prone applications identified If you have an b) Insufficient Amount Of Error Prone Applications: Select all error prone applications then randomly select from the remaining applications to meet the required sample size 12

13 When establishing the verification sample size, I initially select the applications from A. All the applications I have on my desk B. The sample pool of determined and confirmed meal benefit applications C. The determined and confirmed error prone applications Answer is B 13

14 Step 2: Conduct Verification Direct Verification: Located under the Direct Verification tab in the Virtual Gateway Paper Verification: Households that were not a Direct Verification match need household contact 14

15 Step 2a: Directly Verified Households In Massachusetts, eligibility from SNAP, TAFDC and Medicaid is verified through the Virtual Gateway Conducted prior to contacting the household for documentation Documentation to household must be retained (Please refer to the Verification Tracker) 15

16 Why Conduct Direct Verification First? Reduces workload and hassle for school district staff Reduces burden and intrusion on families selected for verification Reduces number of non-respondents and rate of benefit termination for non-response Improves program integrity by checking eligibility with programs that document income information Reference: Abt. Associates, Nov

17 Direct Verification Requiring Action *** Direct Verification Outcomes (Medicaid Match) # SNP Status in the Input Household FPL Possible Outcomes 1 F Exact Match - Verified - Free 2 F Partial Match - MFILC - Verified - Free 3 F < = 133% Partial Match - MFLPD - Verified - Free 4 F Partial Match - MFPLC - Verified - Free 5 F Exact Match - Verified - Free to Reduced 6 F 133% < x < = 7 F 185% Partial Match - MFLPD - Verified - Free to Reduced 8 F Partial Match - MFPLC - Verified - Free to Reduced 9 F 10 F > 185% Exact Match - Verified - Free to Paid Partial Match - MFILC - Verified - Free to Paid 11 F Partial Match - MFLPD - Verified - Free to Paid 12 F Partial Match - MFPLC - Verified - Free to Paid 13 R Exact Match - Verified - Reduced to Free 14 R Partial Match - MFILC - Verified - Reduced to Free 15 R < = 133% Partial Match - MFLPD - Verified - Reduced to Free 16 R Partial Match - MFPLC - Verified - Reduced to Free 17 R Exact Match - Verified - Reduced 18 R Partial Match - MFILC - Verified - Reduced 133% < x < = 185% 19 R Partial Match - MFLPD - Verified - Reduced 20 R Partial Match - MFPLC - Verified - Reduced 21 R Exact Match - Verified - Reduced to Paid 22 R > 185% Partial Match - MFILC - Verified - Reduced to Paid 23 R Partial Match - MFLPD - Verified - Reduced to Paid 24 R Partial Match - MFPLC - Verified - Reduced to Paid 25 F Any FPL No Match - Manual Verification Required 26 R Any FPL No Match - Manual Verification Required 27 F Any FPL Duplicate Match - Not Verified 28 R Any FPL Duplicate Match - Not Verified 17

18 Virtual Gateway Direct Verification: Match History Results 18 Refer to Key to Understanding Direct Certification and Direct Verification Match History Results Reference Guide for more information on Match Types.

19 Directly Verified Households Request for Paper Verification We Have Verified Your Eligibility Letter indicates to the household that.. If you do not agree with the Virtual Gateway eligibility determination, please contact (responsible school official) at (phone number) to request a paper verification package, which will allow you to submit current income information. 19

20 Step 2b: Paper Verified Households Must be sent a dated: We Must Check Your Application letter Verification documentation for each application verified must be available (Verification Tracker) LEA must provide a telephone number that is available at no cost to the household 20

21 Determining Sources of Verification Written evidence for income eligible households and categorically eligible households must indicate: Name of person(s) receiving the income Amount, frequency, and the date the income was received Collateral contacts Agency records (Please refer to the EM ) 21

22 Step 3: Household Contact The LEA must complete the verification process for all households that have been notified If all students withdraw from a selected household another application must be selected and verified 22

23 Step 3a: Direct Verification Exact Match The We Have Verified Your Eligibility letter is sent to the household whose applications have been verified through the Virtual Gateway (VG) 23

24 After sending the letter to the household requesting documentation of income I then.. A. Send the free and reduced application with the letter to the household B. File the applications back in the drawer C. Begin a record of documentation for each application selected for verification Answer is C 24

25 Step 3b: Paper Verification *Select a Household Response Deadline Households must respond to the request for information within a specified period of time set by the LEA. This does not have to be 10 calendar or operational days. The response deadline cannot be November 15 th Why????? All correspondence for the Verification Process must be completed by November 15th 25

26 Step 3b: Paper Verification *Household Follow-up Must Be Initiated (Second Request) The LEA must follow-up if the household Does not respond to the request for verification Submits insufficient or obsolete written evidence The collateral contact is not able to provide requested information Failure to provide adequate written evidence may result in termination of benefits Follow-up in writing (including s) or telephone call with documentation of the attempted contact to obtain missing written evidence Don t forget to document. 26

27 Depending on the household circumstances, a household can respond to the written evidence request by sending in.. A. A copy of their EBT card B. A letter from the Department of Transitional Assistance (DTA) C. A pay stub with no dates Answer is B 27

28 Step 4: Eligibility Changes When Required Reduction in benefits in 10 calendar days (the actual reduction is effective on the 11 th calendar day from the date of the letter) Increase in benefits are immediate or within 3 days of the verification check 28

29 Step 5: LEA Completes Verification Process Activity After One Follow Up To The Household.. 1. The household provides all information Verification is considered complete if: a) There are no change in benefits b) Benefits will be increased or decreased OR 2. The household does not respond and a notice of adverse action is sent OR 3. Inadequate written evidence is given to the LEA and a notice of adverse action is sent The household must receive a result letter from LEA 29

30 Households That Are Denied Benefits May appeal the denial or reduction in benefits within the 10 calendar day advance notice period Continue receiving the approved benefits and the district can continue to claim that benefit May reapply for benefits at any time during the same school year, but must always submit income documentation or categorical proof that is indicated on the application These are not considered new applications 30

31 The Deadline For All Communication To Be Sent From The Household To The LEA Is November 15th True False Answer is False 31

32 Step 6: Completing the Meal Benefit Application PART 6. CHILDREN S ETHNIC AND RACIAL IDENTITIES (OPTIONAL) Choose one ethnicity: Choose one or more (regardless of ethnicity): Hispanic/Latino Not Hispanic/Latino Asian American Indian or Alaska Native Black or African American White Native Hawaiian or other Pacific Islander DO NOT FILL OUT THIS PART. THIS IS FOR SCHOOL USE ONLY. Annual Income Conversion: Weekly x 52, Every 2 Weeks x 26, Twice A Month x 24, Monthly x 12 Only annualize income if there are multiple pay frequencies Total Income: Per: Week, Every 2 Weeks, Twice A Month, Month, Year Household size: Dual Eligibility: Foster child(ren) Free Non-foster child(ren) Free Reduced Denied Categorical Eligibility: Date Withdrawn: Eligibility: Free Reduced Denied Reason: Check if this is an error prone application utilize for verification standard sample size see Eligibility Manual for instructions. Determining Official s Signature: Date: Confirming Official s Signature: Date: Verifying Official s Signature: Date: 32

33 Verification for Cause Questionable applications in addition to the sample size chosen for verification Follow the same procedures as explained in the verification process (EM) Can be conducted through the year SP Verification for Cause and School District Employees 33

34 Verification for Cause We Have Verified Your Eligibility letter is sent when any household when: Fails to submit requested verification information by the date specified by the LEA OR Submits information that does not support the reported income information 34

35 Household Reports No Income If zero income is listed on regular verification or verification for cause.. LEA must request an explanation of how living expenses are met and may request additional written documentation or collateral contacts 35

36 Step 7: Verification Collection Report (FNS-742) Deadline: January 9,

37 Important Verification Facts to Remember No more or no less than 3% of the total applications are to be verified 100% verification is not permissible Verification cannot be requested at the time of the application At least one application must always be verified Deadline for completion of all verification activity is November 15 (Verification cycle is Oct. 1 Nov. 15) Verification Summary Report must be submitted to ESE via Security Portal no later than early January each year (This year the deadline is: January 9, 2015) Remember to DOCUMENT.. DOCUMENT..DOCUMENT 37

38 Recordkeeping Compliance Copy of the free and reduced price application Source of information used to verify the application (i.e. wage stubs) Copies of correspondence between household and LEA Change in eligibility as a result of the outcome of the verification process Records of follow-up attempts and results (Please reference the Verification Tracker) 38

39 Verification Resources Available Eligibility Manual for School Meals (revision coming soon) [ screen shot of new verification section] 39

40 Questions!! 40