Eligibility Effective Date For Directly Certified

Nutrition Services Division Management Bulletin

Purpose: Policy, Beneficial Information

Date: March 2015

Number: SNP-17-2015

To: School Nutrition Program Sponsors

Attention: Food Service Directors

Reference: U.S. Department of Agriculture (USDA) Policy Memorandum SP 51-2014: Eligibility Effective Date for Directly Certified Students; the Richard B. Russell National School Lunch Act, Section 9(b)(9)(B) (Title 42, U.S. Code, Section 1758[b][9][A]); and USDA Eligibility Manual for School Meals

Subject: Eligibility Effective Date For Directly Certified Students

---

This Management Bulletin (MB) provides School Nutrition Program (SNP) sponsors with information regarding the flexibility available to local educational agencies (LEA) for establishing the effective date of household eligibility for directly certified children participating in the National School Lunch Program, School Breakfast Program, and Special Milk Program.

Background

Direct certification is a process through which a child who is a member of a household receiving assistance under CalFresh (formerly Food Stamps), California Work Opportunity and Responsibility to Kids (CalWORKs), or the Food Distribution Program on Indian Reservations (FDPIR) is certified for free school meals or free milk, without further application, based on documentation obtained directly from the appropriate state or local agency. Additionally, a child categorized as foster, homeless, migrant, runaway, or participating in Head Start or Even Start is also qualified for free school meals or free milk through the direct certification process.

Methods of direct certification include automated data matching, the letter method, and lists or other forms of documentation provided to LEAs directly from the appropriate state or local agency.

Automated Data Matching

Automated data matching is the only method of direct certification acceptable for identifying CalFresh recipients who automatically qualify for free school meals. It is also the most common method to directly certify students who are recipients of CalWORKs or FDPIR benefits, or in foster care. There are two common automated data matching processes:

1. Local/LEA-level data matching is a direct certification process through the local county welfare department that matches CalFresh, CalWORKs, FDPIR, and foster benefit data with student enrollment records.
2. State/Central-level data matching is a direct certification process through the California Longitudinal Pupil Achievement Data System (CALPADS) that matches data from the student information stored in the CALPADS with benefit data from a statewide CalFresh and CalWORKs recipient data system.

While processing these automated matches, LEAs now have some flexibility in choosing the effective date of eligibility for free school meal or milk benefits, which can be the date of the automated data matching file (or benefit recipient file from another agency) that first identifies the student as eligible for direct certification, rather than the date the LEA accesses and imports the automated data matching file into their local point of service (POS) system. This flexibility applies even to students who are not immediately identified (e.g., students whose records are not matched until later, due to a data entry error in school records, after the LEA conducts the initial matching process).

Data Matching Through Letter Method and List

The letter method, lists, or other forms of documentation may be used to directly certify students as recipients of CalWORKs and FDPIR, as well as Other Source Categorically Eligible Programs (foster child, homeless, migrant, Head Start or Even Start, and runaway children). LEAs may consider the effective date of eligibility for free school meal or milk benefits to be the date the household or appropriate state or local agency submitted the letter, list, or other form of documentation to the LEA, rather than the date the school official approves the documentation.

LEAs that implement the eligibility effective date flexibility must:

1. Notify the California Department of Education (CDE) that they are using the eligibility effective date option by submitting Form ID SNP-48, which is available in the Child Nutrition Information and Payment System (CNIPS) Download Forms section.
2. Use this option consistently for all of the direct certification methods such as, automated data matching, letter method, and lists or other forms of documentation.
3. Record the effective date of eligibility by using a date stamp (or other date documentation method) to document the date lists or letters from other agencies were received, or the documented and traceable run date of automated match files or recipient benefit files from another appropriate agency.
4. Apply this to extended eligibility based on CalFresh, CalWORKs, and FDPIR participation to other children in the household.
5. Refund any money paid by or on behalf of a child for a reimbursable meal or milk prior to the eligibility determination—this includes adjusting accrued debt towards meal payments.
6. Submit the current monthly reimbursement claims and adjust claims after initial submission to reflect changes in meal eligibility.
7. Notify their SNP specialist in writing before canceling this option.

For any claim adjustment-related errors or issues, LEAs can contact the appropriate CDE Nutrition Fiscal Analyst. The Nutrition Fiscal Analyst Directory is available on the CDE Nutrition Services Allocations and Apportionments Web page at http://www.cde.ca.gov/fg/aa/nt/. 

LEAs can access the referenced Policy Memos on the USDA School Meals Policy Web page at http://www.fns.usda.gov/school-meals/policy.

If you have any questions regarding this MB, please contact your assigned SNP Specialist. The SNP county specialist list is available in the CNIPS Download Forms section, Form ID Caseload. You can also contact the SNP Office Technician by phone at 916-322-1450, 916-322-3005, or 800-952-5609, Option 2 to be directed to your SNP County Specialist.