Reminders on Child Nutrition Eligibility Determinations

by Cynthia Rojo, CPA, Senior Associate

Posted on June 13, 2018

The eligibility determination performed as part of the Child Nutrition program affects various other school district programs, but also affects the students who receive benefits that make an important contribution to their overall nutrition.

A free or reduced price eligibility determination can be reached by a few different processes. One manner includes a submitted income application. A determination is made by the school district, based on the “face value” of the application, and comparing the information provided on the application to the Income Eligibility Guidelines published by the United States Department of Agriculture (USDA), on a yearly basis. Additionally, applications must be complete in order to be considered for eligibility; the completeness of an application consists of the following:

  • the names of all household members;
  • the income amounts, sources, and frequencies for each household member;
  • the signature of an adult household member; and
  • the last four digits of the Social Security Number of the household’s primary wage earner or another adult household member, or an indication that no adult household member has a Social Security Number

Another method includes a submitted application for categorical eligibility. With categorical eligibility applications, individuals or households are eligible for meals based on determining factors other than income. Unlike income applications, eligibility is determined by participation in Assistance Programs (ex. SNAP, TANF, FDPIR) or other programs (ex. migrant, runaway, homeless, foster). Additionally, applications must be complete in order to be considered for eligibility; the completeness of an application consists of the following:

  • the names of the children for whom the application is made;
  • the case number or identifier for the children or any household member listed on the application; and
  • the signature of the adult household member completing the application.

A third method involves the school district completing the direct certification process. Direct certification is the process under which school districts certify children as eligible for meals by participation in Assistance Programs (ex. SNAP, TANF, FDPIR) or other programs (ex. migrant, runaway, homeless, foster child) based on information provided by the State or local agencies administering those programs.  There is no submission of an application for this method.

It is important that school districts develop policies and procedures to ensure the eligibility determination process is completed properly and administered in accordance with the guidelines as recommended by the Eligibility Manual for School Meals Determining and Verifying Eligibility published by the USDA. Policies and procedures may address the following areas:

  • Process for distributing applications to households; including timeline, manner and frequency
  • Process for determining eligibility status for returning students during the first 30 operating days or until an income application is received (the eligibility status from the prior year can be carried over for 30 operating days or until an application is received or a household is directly certified; if an application is not received or direct certification status is not valid after the carry over period, children must pay full price for school meals)
  • Timeline, manner and frequency in which the direct certification process will be completed (school districts must conduct a direct certification for SNAP at least three times during the school year: at or around the beginning of the school year; three months after the beginning of the school year; and, six months after the beginning of the school year)
  • Process for receiving and reviewing of applications
  • Process for determining and reviewing eligibility (inputting and reviewing application data entered into computerized systems, if applicable)
  • Process for notifying households of the eligibility determination

Due to the various programs and students affected by eligibility determinations, it is important that school districts make accurate and informed determinations, while also following the USDA Eligibility Manual for School Meals Determining and Verifying Eligibility and any other school district policies and procedures.