Changes to Free and Reduced Price School Meals Eligibility, Applications and Verifications

On June 30, 2004, the Child Nutrition and WIC Reauthorization Act of 2004 ("the Act") was signed into law. The Act makes many changes to eligibility, application and verification processes for free and reduced price school meals:

1. Extended student eligibility for free and reduced price school meals

• Automatic eligibility for free meals for homeless, runaway and migrant students
• Expanded eligibility for some military families
• Full school year certifications for all eligible students
  
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2. Streamlined application processes for school meals

• Phased-in mandatory direct certification of food stamp households for free school meals
• Lists of names in lieu of applications for homeless, runaway and migrant students
• Household and electronic applications
• Language access for Limited English Proficiency families


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3. Focused selection of households for verification of eligibility

• Most schools to select households for verification from the pool of applications that list income within $100 per month of the free or reduced price eligibility guidelines


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4. Easing the process of verifying families' eligibility

• Preliminary reviews of eligibility
• Direct verification via other income-tested programs
• Toll-free numbers, language access and community follow-up
• Individual case reviews
• Income documentation from any time period


» more...

Full Description of the Changes

1. Extended student eligibility for free and reduced price school meals

Automatic eligibility for free school meals for migrant, homeless and runaway children

• Homeless children. The Act establishes in law that all children who are defined as homeless, according to the McKinney-Vento Homeless Assistance Act, are automatically eligible for free school meals.
• Runaway and migrant children. The Act also confers automatic eligibility for free school meals on migrant children served through the Migrant Education Program (MEP) and runaway children and youth served through the three grant programs established under the Runaway and Homeless Youth Act (RHYA): Basic Center Program, Transitional Living Program for Older Homeless Youth, and Street Outreach Program.
• Lists of names in lieu of applications. Homeless, runaway and migrant students may be identified by certain State or school officials, who may submit lists of these students’ names in lieu of school meal applications usually submitted by children’s parents or guardians (see below).
• Read more about homeless, runaway and migrant students and school meals.

Full School Year Certifications

• For all eligible students. The Act extends eligibility for free and reduced price school meals through full school year. Schools are allowed to continue a student’s eligibility for up to 30 operating days into the next school year, or until a new eligibility determination is made, whichever occurs first.
• For automatically eligible students. When a student has been certified as eligible for free meals, based on designation as homeless, runaway or migrant by a local educational agency liaison, homeless or domestic violence shelter director, RHYA service provider or MEP coordinator (see below), the eligibility remains effective for the remainder of the school year and up to 30 days into the next school year. This policy holds even if children or youth move into permanent housing and are no longer homeless, migrant, or served by RHYA programs.
• View Memo SP 3 about this provision on the U.S. Department of Agriculture website.

Exclusion of Military Housing Allowances

• The Act allows more children from military households to receive free and reduced price school meals by excluding privatized housing vouchers from being counted as income when determining school meal eligibility. With less income counted, more military families fall within the eligibility ranges for free or reduced price meals.
• This exclusion applies only to households living in housing covered by the Military Housing Privatization Initiative. Through this initiative, private contractors operate military-owned housing on some military installations, and housing allowances appear on service members’ earnings statements.
• Military households that live off-base in regular commercial or private housing are NOT eligible for this exclusion of income.
• Read more about this exclusion of military housing allowances.

2. Streamlined Application Procedures

Simplified Application Process for Homeless, Runaway and Migrant Students

• Homeless and runaway students. The McKinney-Vento Act requires every school district to designate a local educational agency liaison for homeless children and youth. The liaisons ensure that children receive the educational and other services for which they are eligible, including free school meals. School food service directors or other officials who determine school meal eligibility must accept lists of children who are homeless or runaway (see below) from local educational agency liaisons, homeless or domestic violence shelter directors and RHYA service providers.
• Migrant students. Most school districts that have migrant children attending school have an MEP coordinator who identifies children from migrant families. If a school district does not have an MEP coordinator, every state has a State MEP Director (who generally works for the State Education Agency) who can facilitate the identification of migrant children. School food service directors or other officials who determine school meal eligibility must accept lists of children who are migrant (see below) from the MEP coordinators and State MEP Directors.
• Lists of names in lieu of applications. The documentation of a child as homeless, runaway or migrant is a dated list of each child’s name and the signature of the local educational agency liaison, homeless or domestic violence shelter director, MEP coordinator, State MEP Director or RHYA service provider. This list is acceptable in lieu of a school meal application usually submitted by the child's parent or guardian and is sufficient for school officials to approve the child’s eligibility for free school meals.
• Read more about homeless, runaway and migrant students and school meals.

For All Eligible Students

• Household applications. Starting in the 2005-06 school year, household – or multi-child – applications will be mandatory, so that a school or district may not request a separate application for each child in the household. This eases the process for low-income families who do submit school meal applications, by allowing them to fill out only one application for all the children in the household who attend schools in the same school district.
• Language and electronic access. Application forms and descriptive materials are required to be in a language that parents can understand, to the extent practicable. In addition, the Act allows households to submit applications electronically via the Internet, when possible.

Direct Certification

• Streamlining school meal certifications. Direct certification simplifies the school meal application process for families that receive food stamps, Temporary Assistance for Needy Families (TANF), or the Food Distribution Program on Indian Reservations (FDPIR). Such families are directly certified when schools, districts or state agencies communicate directly with food stamp, TANF or FDPIR offices in order to confirm the students’ eligibility for free school meals. These directly certified households are not required to fill out any paperwork before receiving free school meals.
• Optional direct certification. Schools are allowed to directly certify students who live in TANF and food stamp households. Starting in the 2006-07 school year, some school districts will be required to directly certify food stamp students for free school meals (see below).
• Phased-in mandatory direct certification. The Act phases in mandatory direct certification of food stamp households for free school meals. Starting in the 2006-07 school year, school districts with enrollments of over 25,000 students will be required to directly certify food stamp students for free school meals. In the 2007-08 school year, districts with over 10,000 students will fall under this requirement, and starting with the 2008-09 school year, all school districts nationwide will be required to directly certify food stamp students for free school meals.
• View Memo SP 8 about direct certification of food stamp households on the U.S. Department of Agriculture website.
  

3. Focused Selection of Households for Verification of Eligibility

• Current 3% random sample. Currently, schools are allowed two different methods to select a sample of school meal applications in order to verify students’ eligibility for free or reduced price school meals. The first method is random: schools randomly select 3% of approved school meal applications. The second method is focused: schools select 1% of approved applications from the pool of applications that list income within $100 per month of the free or reduced price eligibility guidelines and ½% of applications that list TANF, FDPIR or food stamp case numbers in lieu of income on the application forms.
• Future 3% focused. Starting in the 2005-06 school year, most schools will be required to select 3% of approved applications from the pool of applications that list income within $100 per month of the free or reduced price eligibility guidelines.
• Alternatives for certain districts. Low non-response rate school districts will be allowed to use the current 3% random sampling method instead of the 3% focused sampling method. (A non-response is counted when a household fails to reply to a request for documentation of their eligibility for free or reduced price school meals.) There are two definitions of low non-response rate districts: school districts that had less than 20% non-response rates in the prior year, and large school districts (those with over 20,000 approved applications) that in the prior year had non-response rates that were 10% lower than those of the second preceding year. (In addition, for just the 2005-06 school year, large districts may avoid any sampling of applications if they instead directly verify [see below] students’ eligibility through at least two programs.)
• Categorically eligible students shielded from income verification. Students who receive free school meal eligibility through food stamp, TANF or FDPIR direct certification, or identification as homeless, runaway or migrant on lists submitted by certain officials in lieu of school meal applications (see above), are NOT included in the verification samples . These students’ households are not required to provide documentation of their eligibility for free school meals at any time during the school year.
• View Memos SP 5, SP 9, SP 13, SP 18 about verification requirements on the U.S. Department of Agriculture website.
  

4. Easing the Verification Process

• Preliminary reviews. Before requesting documentation of their eligibility for free or reduced price meals from households that have been selected for verification, schools or districts are required to review their original school meal applications to confirm that the students were initially placed in the correct meal categories. If the preliminary review finds a discrepancy, the school or district must correct the household's eligibility status, notify them of such changes, and if the households loses their benefits as a result, inform them that they may reapply for school meals with income documentation. If the preliminary review confirms the family’s meal category, then the school or district will proceed to verify their eligibility for free or reduced price meals.
• Direct verification via other income-tested programs. Schools and districts have the option to directly verify households’ eligibility for free or reduced price meals by using income and program participation information from other income-tested programs, such as from food stamps, TANF, FDPIR and Medicaid. If a household’s eligibility for meal benefits is confirmed through direct verification, then the household does not need to be contacted by the school or district. As a result, direct verification should streamline the process and reduce paperwork for schools, districts and families by decreasing the number of applications that have to be verified through requests for income documentation from households.
• View Memo SP 8 on direct verification on the U.S. Department of Agriculture website.
• Toll-free numbers and language access. All communication regarding verification is required to be in a language that parents can understand, to the extent practicable. In addition, any requests that are sent to families for documentation of their eligibility are required to include toll-free telephone numbers for families to use to obtain assistance.
• Community follow-up. If a family does not respond to a request for documentation of eligibility for free or reduced price meals, the school or district is required to make at least one follow-up attempt to contact the family before terminating their meal benefits. The Act permits schools and districts to contract with community-based organizations to do this follow-up.
• Individual case reviews. A school or district may decline to verify up to 5% of the verification sample and replace them with other applications, based upon individual case reviews of special household circumstances.
• Income documentation from any time period. Since eligibility for free or reduced price school meals are valid for the full school year, families may provide income documentation for any time period from the month before their meal application was submitted to month that they received the request for documentation of their meal eligibility

Updated May 2006

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