NSLP/SNAP - Direct
Certification and State
Performance:
The new process, data requirements,
and responsibilities beginning School
Year 2013-2014
WEB I NA R – T U E SDAY, AUG UST 20 , 20 13 – 2:0 0 - 3:3 0 PM
PAT R ICIA B . VO N R E Y N – S E N I O R M A N AG E ME NT A N A LY S T
USDA/FNS/SPECIAL NUTRITION PROGRAMS/CHILD NUTRITION DIVISION
What is
Direct Certification with SNAP?
Children living in households receiving assistance under the Special
Nutrition Assistance Program (SNAP) must be directly certified to receive
free school meals under the National School Lunch Program (NSLP) and/or
School Breakfast Program (SBP).
2
How is Direct Certification with SNAP Conducted?
Source Data
School Enrollment Data
SNAP Participation Data
Match Process
SNAP DC
Match Results
3
Some Different Ways States Match with SNAP
SA/Central
Level
SFA/LEA/Local
Level
D C
D C
D C
D C
4
Goals of Direct Certification
Improve access for low-income children
Reduce paperwork for households and
program administrators
Improve integrity of the free and
reduced-price meal certification process
5
History of Direct Certification with SNAP
2004
All NSLP LEAs must perform direct certification
with SNAP by SY 2008-09
(May conduct direct certification with other programs, but are not required to do so)
2008
Assess effectiveness of direct certification and
publish results in Report to Congress
(starting with SY 2007-2008)
P.L. 108-265
Child Nutrition and WIC
Reauthorization Act of 2004
P.L. 110-246
Food Conservation, and
Energy Act of 2008
(2008 Farm Bill)
Performance benchmarks are set at 95%
2010
for SY 2013-2014 and beyond
(lower benchmarks for the two previous school years)
SNAP Letter Method no longer DC
P.L. 111-296
Healthy, Hunger-Free Kids Act of
2010
(phased out by regulation by SY 2012-2013)
Final Rule
2013
New formula and ways to collect/report data elements
to compute State direct certification performance rates with SNAP
NSLP: Direct Certification
Continuous Improvement Plans
Required by the Healthy,
Hunger-Free Kids Act of 2010
6
Benchmarks - Direct Certification with SNAP
SY 2013-2014 and beyond – 95%
Second year - SY 2012-2013 - 90%
First year – SY 2011-2012 – 80%
7
Will my
State be
at 95%?
8
This Webinar describes the New Methodology
for Assessing Performance, which:
• Is straightforward
• Promotes transparency
• Is more accurate
• Provides States with tools to measure their own
performance in a timely manner
9
Direct Certification with SNAP
and a Formula Approach to Improvement
10
Understand
how the pieces
of the puzzle fit
together
Formula
• Data Element #1
• Data Element # 2
• Data Element # 3
(2008 Farm Bill)
11
12
DATA ELEMENT
#1
13
DATA ELEMENT
.
The # of children living in households
receiving SNAP benefits who are
directly certified for free school meals
as of the last operating day in October
14
DATA ELEMENT
.
Who collects it?
The School Food Authority tracks, records,
and reports the number of SNAP Direct
Certifications that occur by the last
operating day in October
15
DATA ELEMENT
.
Reporting
SNAP DC
on old FNS-742, line 4-1
to State agency by March 1st
to FNS by April 15th
SNAP DC
on revised FNS-742, line 3-2
to State agency by February 1st
to FNS by March 15th
16
Need to be able to separate out SNAP DC for Section 3 of the
FNS-742 – Free, not subject to verification
SNAP Direct Certification
Non-SNAP Direct
Certification
SNAP Letter Method is no
longer Direct Certification
SNAP
DC
SNAP
DC
Line 3-2
Line 3-3
Line 3-4
17
The count on Line 3-2 of the FNS-742
is Data Element #1
SNAP
DC
18
“Grow” DATA ELEMENT #1
SNAP DC
19
How to Grow
#
DATA ELEMENT 1
SNAP
DC
Know what is considered to be a
SNAP Direct Certification
Certifications Based On:
• Matching SNAP database to Student-Enrollment Database
• Adjudication of the unmatched or partial SNAP match list
• SNAP-combo matches, SNAP trumps!
• Extended SNAP-DC Eligibility
• Converting to SNAP DC by the last operating day in October
20
How to Grow
DATA ELEMENT #1
Improve the System
SNAP
DC
• Perform a State Self-Assessment
21
How to Grow
#
DATA ELEMENT 1
Improve the System
SNAP
DC
• Perform a State Self-Assessment
• Determine where your State’s strengths and
weaknesses lie
• Work with counterparts to develop a plan of action
• Look to FNS grants for financial support
22
How to Grow
#
DATA ELEMENT 1
Key tasks for this year
SNAP
DC
• Match more frequently if possible – if only 3x/yr, make
sure 2nd is before the last operating day in October
• Make sure the SFA can capture (code), retain, and select
for the method for the direct certification so the FNS742 counts will be accurate
• Monitor the progress step-by-step
23
Expectation is that line 3-2 of the FNS-742 will be
only SNAP DCs, even this first year, SY 2013-2014.
Separate SNAP from non-SNAP:
• Work with SNAP State agency to be sure SNAP matches carry some kind of coding
designating “SNAP” so the local level will know the source of the match when they
directly certify a child for free school meals.
• Work with IT at all levels to be sure that the coding is retained at the local level so
the SFA can retrieve the direct certifications based on SNAP for the FNS-742.
• Work in retrospect, if needed – see Q-and-As, SP 54-2013.
• If by February 1, 2014, the NSLP State agency is not able to affirm that line 3-2 is
only SNAP DCs, SA must inform FNS of the inaccuracy of the data.
24
DATA ELEMENT
#2
25
#
Data Element 2
The “School-aged SNAP UNIVERSE”
The # of school-aged children in SNAP households during the
months of July, August, and September
26
USDA uses ages 5-17 years old for “school aged”
in the count for Data Element #2
27
But, even though
USDA uses ages 5-17 years old for “school aged”
in the count for Data Element #2
States are to use as broad an age range for the match
as will include ALL students in their NSLP schools
28
How and by whom would this count be determined?
Estimate by FNS using
a variety of data sources
SNAP Administrative data
(for July, Aug, Sept average monthly SNAP
participation data)
SNAP QC data and Admin data
Actual
counts from the
SNAP State agency
SNAP State agency queries the SNAP
database to get the actual, unduplicated count of
children age 5-17 at any time during the months of
July, Aug, Sept.
(to narrow down the age range)
SIPP data (to help remove duplicates)
29
How and when would NSLP State agencies find out?
30
SNAP State Agency Responsibilities for
Data Element #2
• Look at the SNAP rolls for the months of:
July, August, and September
On SNAP
at any
time
during
these
three
months?
beginning with July-August-September of 2013
31
SNAP State Agency Responsibilities for
Data Element #2
• Count all children on the SNAP rolls during these same
three months who were ages 5-17 at any time during these
months.
• Use the prescribed birth date range for the query
32
SNAP State Agency – Prescribed Birth Date Range
to Query for 5-17 year olds
for Data Element #2
School
Year
R
U
L
E
E
X
A
M
P
L
E
Any SY
SY
20132014.
First part of SY
(from which to subtract
the 18 or 5)
“FP” *
2013
Children on
SNAP at
anytime
during:
Beginning
Birth
Date
July, Aug, or
Sept of that
school year
July 1,
Sept. 30, Children born July 1, (“FP”-18)
(“FP” -18) (“FP”-5)
through Sept. 30, (“FP”-5)
Dec. 1,
“FP”
July, Aug, or
Sept 2013
Sept. 30,
July 1,
(2013 -18) (2013 -5)
So,
so,
Sept. 30,
July 1,
2008
1995
Dec. 1,
2013
Ending
Ending
Birth
Birth
Date
Date
Birth Date Range for SNAP
State Agency’s Query
for Children Ages 5-17
Date
FNS-834
due
Children born July 1, 1995
through Sept. 30, 2008
*FP = Calendar year when the school year begins
33
SNAP State Agency Responsibilities for
Data Element #2
• Ensure that the counts are unduplicated
• Whether a child is on SNAP for all 3 months, or for only 1 day
during that 3-month period, count the child only once.
34
SNAP State Agency Responsibilities for
Data Element #2
After getting the unduplicated count of children who are on SNAP at
any time during July, August, or September 2013, and who were born
July 1, 1995 through September 30, 2008
Report the count for the entire State on the new form FNS-834 by
December 1, 2013.
35
SNAP State Agency – Data Element #2
For the December 2013
submission, this form will be
emailed in to
CNStatesytems@fns.usda.gov, but
in future years, after it is
incorporated into FPRS, much of
this section will be pre-populated.
#2
Optional
Specific examples
for setting the query
are included in the
Q-and-As: SP 54-2013,
dated August 16, 2013.
OPTIONAL
36
SNAP State Agency’s Submittal of the FNS-834
By December 1st each year
• THIS YEAR email to
CNStatesystems@fns.u
sda.gov by Dec 1, 2013.
• FPRS in 2014?
• Provide to the NSLP State
agency in a manner agreed
upon by both the NSLP State
agency and the SNAP State
agency each year, starting
Dec 1, 2013.
37
SNAP
DC
“THE UNIVERSE”
38
So, how do you “Shrink” DATA ELEMENT #2?
39
How to Shrink
#
DATA ELEMENT 2
The NSLP State agency does not have much control over this, but
it can:
• Ensure the Accuracy of the Count
• Review the count from the SNAP State agency after they send it
over to you by December 1st on the FNS-834
• Work with the SNAP State agency if the count does not seem
reasonable
• Develop a way to quantify the actual number of SNAP children
not in NSLP schools
40
DATA ELEMENT
#3
41
#
Data Element 3
The “SPECIAL PROVISION” Adjustment
The # of children in SNAP households
attending special provision schools
operating in a non-base year
42
ON LINE 3-2
NOT ON
LINE 3-2
SNAP
DC
“THE UNIVERSE”
43
How and by whom would this count be determined?
Estimate by FNS using
a variety of data sources
Actual
counts from the
NSLP State agency
Line 4-4 of the old FNS-742 (to get
NSLP State agency ensures that a “Special
the # free eligibles).
Provision Match” with SNAP is run for each special
provision school operating in a non-base year.
Adjusted (applying generalized adjustment
factors to approximate the narrower SNAP subset).
Limitations - particularly when the number of
SNAP-participant children had changed from the mostrecent base year or as schools moved in or out of nonbase year status.
NSLP State agency totals the
unduplicated count of matches and reports on the FNS834 by December 1st .
44
How and when would NSLP State agencies find out?
45
DATA ELEMENT
.
NSLP State Agency Responsibilities
The NSLP State agency ensures that a “Special
Provision Match” with SNAP is run with special
provision schools not operating in a base year,
totals the number of matches, and reports the
total on the FNS-834.
46
DATA ELEMENT
.
About the “Special Provision Match” with SNAP:
• Timing – it is to be run in or near October—but no later than the
last operating day in October
• Pertains to which schools - all special provision schools not
operating in a base year
• What to count – all matches made using the “Special Provision
Match”
• Alternative phase-in procedures - allowed only for SY 2013-2014
• Certain Community Eligibility data options available each year
47
DATA ELEMENT
.
With which schools must the match be run?
• Provision 2/3 schools when operating in non-base
year.
• Community Eligibility schools, each year they operate
under community eligibility.
• Other schools operating in a non-base year under the
special provisions of 7 CFR 245.9–that is, those
schools that would not be reporting SNAP-DCs on line
3-2 of the FNS-742.
48
DATA ELEMENT
.
Must the State itself run the match?
Regardless of the method of matching (central or local or
combo) for the regular SNAP matched:
• The NSLP State agency may run the “Special Provision Match” with
SNAP; or
• The SFAs may run the “Special Provision Match” with SNAP and report
the counts to the NSLP State agency; or
• States may decide to use a combination of approaches.
NOTE: States with no special provision schools (or with only those operating in a base year)
need not run a “Special Provision Match.” Simply report “0” on the FNS-834.
49
DATA ELEMENT
.
What does it mean to
“Count all the matches” found in the
“Special Provision Match”?
School Enrollment Data
SNAP Participation Data
Use for
Data
Element
#3
To FNS-742 for
Data Element #1
SNAP
DC
Not for Data
Element #3
Match
Results
50
DATA ELEMENT
.
What are the Alternative Phase-in
Procedures for SY 2013-2014?
• For SY 2013-2014 only, the NSLP State agency
may allow the use of the “Base Year Percentage
Option” for any school for which the match
cannot be run.
51
DATA ELEMENT
.
“Base Year Percentage Option”
For SY 2013-2014 only . . .
School
“Special
Provision
Match”
Base Year
# Directly
Certified
as FREE
Base Year
Total #
certified as
FREE
Percentage
Factor
SY 2013-2014 #
reported as
FREE
Total
Total count from the 10 non-base-year special provision schools where
the “Special Provision Match” was able to be performed
9, 475
102
343 x 271
129
A
102
271
102
271
343
B
32
57
32
57
68
C
Apply
Percentage
Factor
102
68 x 271
38
Did not conduct direct certification in base year, or no access to data
0
TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834
9, 642
52
DATA ELEMENT
.
Community Eligibility Data Options
• OPTION 1 - “SPECIAL PROVISION MATCH” – the same match
done with other special provision schools
• OPTION 2 - CLAIMING PERCENTAGE COUNT- Use the count of
identified students matched with SNAP used in determining the
claiming percentage for that school year
• OPTION 3 - CALENDAR YEAR APRIL COUNT – Use the count of
the identified students matched with SNAP conducted by the
April 1st preceding the school year, whether or not the school
elected to update its claiming percentages
53
Community Eligibility Data Options - Example
Scenario
Data Options
The school year is SY 2015-2016.
The first year of the claiming
cycle was SY 2012-2013. The
school ran a match with SNAP by
April 1, 2015, but elected not to
update its claiming percentages
for SY 2015-2016.
• OPTION 1 – Conduct and use the
results of an “October” 2015
“SPECIAL PROVISION MATCH”
• OPTION 2 – CLAIMING
PERCENTAGE COUNT - Use the
count of SNAP matches from the
“April” 2012 match
• OPTION 3 – CALENDAR YEAR APRIL
COUNT – Use the count of SNAP
matches from the “April” 2015
match
54
DATA ELEMENT
.
Example of Totals with Community Eligibility Data Options
Example from future, SY 2015-2016
Can only use “Special Provision Match” or CE Data Options,
since Alternative Phase-in Procedures are not available after SY 2013-2014
Total
“Special
Provision
Match”
Total count from all SNAP matches from the “Special Provision Match” performed
“in/near October 2015,” including many Community Eligibility schools
12,321
CE 2
Total count from those Community Eligibility schools electing CE DATA OPTION 2
choosing to use the actual count from the identified students matched with SNAP
by the April 1st used to establish the SY 2015-2016 claiming percentages
416
CE 3
Total count from those Community Eligibility schools electing CE DATA OPTION 3 choosing to use
the actual count from the identified students matched with SNAP by April 1st, 2015
n/a
If not in the “Special Provision Match” and not using a “Community Eligibility Data Option,”
cannot count any students for Data Element #3 . Enter “0.”
TOTAL TO REPORT FOR DATA ELEMENT #3 ON THE FNS-834
237
0
12, 974
55
NSLP State Agency – Data Element #3
For the December 2013
submission, this form will be
emailed in to
CNStatesytems@fns.usda.gov, but
in future years, after it is
incorporated into FPRS, much of
this section will be pre-populated.
#3
Optional
Much guidance on the
“Special Provision Match”
is included in the
Q-and-As: SP 54-2013,
dated August 16, 2013.
OPTIONAL
56
NSLP State Agency’s Submittal of the FNS-834
By December 1st each year
to
FNS
• THIS YEAR email to
CNStatesystems@fns.u
sda.gov by Dec 1, 2013.
• FPRS in 2014?
57
SNAP
DC
SPECIAL
PROVISION
ADJUSTMENT
or
“THE UNIVERSE”
SPECIAL
PROVISION
ADJUSTMENT
58
How to Grow
#
DATA ELEMENT 3
Reach all special provision schools
• Know the special provision schools in your State
• Keep track of when they are operating in a non-base year
• Find out which schools already have their students in a statewide student
enrollment database
• Determine which SFAs/schools are not geared up for the match this year
• Develop relationships with these schools for this match to be successful
• Work to remove obstacles that would keep schools from being included
59
How to Grow
#
DATA ELEMENT 3
Match well, even this first year
• Design a business practice for the Special Provision Match in your
State
• Be flexible – run the match at the State level or run the match at
the local level or use some combination of the two; maybe upload
student enrollment info via Excel or even run the match for a school
• Run the match in or close to October, if possible, but no later than
the last operating day in October to maximize the number of
matches
• Automate as much as possible
60
SPECIAL
PROVISION
ADJUSTMENT
SNAP
DC
SFA on LINE 3-2 of FNS-742
NSLP State agency on FNS-834
“THE UNIVERSE”
SNAP State agency on FNS-834
61
DATA ELEMENTS
WHAT
IS IT?
WHO
REPORTS?
HOW
REPORT
WHEN
REPORT
#1
# SNAP CHILDREN
DIRECTLY
CERTIFIED FOR
FREE
SCHOOL MEALS
SFA
FNS-742
Feb 1
(Mar 15)
#2
# SCHOOL-AGED
SNAP CHILDREN IN
THE STATE IN
JULY, AUG, SEPT
SNAP
STATE
AGENCY
FNS-834
Dec 1
#3
#SNAP CHILDREN
IN NON-BASE
YEAR SPECIAL
PROVISION
SCHOOLS
NSLP
STATE
AGENCY
FNS-834
Dec 1
Data Element
62
What can the NSLP State Agency Do to Monitor its Rate?
• DATA ELEMENT #1 - Watch the 742 data as it is coming in from the SFAs, be sure
that all schools are reporting, compare this year’s data to last year’s data. If it is
very different, is there a reason for that? Be sure that the SFA has reported in line
3-2 SNAP direct certifications ONLY .
• DATA ELEMENT #2 – Be in contact with the SNAP State agency to determine the
best way to receive the FNS-834 data. Check the count to see if it is reasonable for
your State. How does it compare to the lists that you have been receiving? The
count should be an unduplicated count, so if a child is on SNAP for July, August AND
September, the child should still be listed only once.
• DATA ELEMENT #3 – Do you have data in from each special provision school? Is it
properly combined for you to report for the FNS-834?
• FORMULA - Plug the data into the formula as you get it. Is your rate what you
expect? If it has dropped significantly, check to be sure there are no errors in the
individual data elements.
63
What can the SFAs do to increase the rate?
• Know what constitutes a SNAP Direct Certification
• Make sure the POS system properly records the type of certification and
can select/sort/count by type
• Keep school enrollment data as current and up-to-date as possible
• Check new students as they enroll
• Send SNAP DC status to transferring student’s school
• Adjudicate the non-matches—try to find every child
• Go back and code a student as a SNAP DC if the student shows up on the
SNAP DC list, even if the student has already been certified in another way,
so long as it is done before the last operating day in October
• Get/arrange for additional assistance during heavy certification times, if
possible
64
What can the SFAs do to increase the rate?
• Get proper training, ask questions if anything is not well understood,
train back-ups for your role in the process
• Look to see where the automated systems could be revised to make
things easier for you—if you are doing a series of steps over and over,
they could probably easily be automated
• Understand the policies and rules governing direct certification
• Match frequently –if only running 3 matches, make sure the 2nd one is
before the last operating day in October
• Properly complete the FNS-742, Verification Collection Report
• Check your submission last year to see if it is close to this year’s—if it is
not close, is the difference warranted? If not, search for errors
65
Direct Certification Improvement Grants Opportunities
The RFA was extended in July to provide 4 more grant opportunities:
OCTOBER 1, 2013
JANUARY 2, 2014
APRIL 1, 2014
JULY 1, 2014
MAXIMUM
AWARD
SCOPE
APPLICATION
PROCESS
TIER 1
$150,000
Limited scope
Simplified
TIER 2
$ 1 million
Full scope – for
major initiatives
Usual
66
Helpful Resources
• Final Rule, National School Lunch Program: Direct Certification Continuous Improvement
Plans required by the Healthy, Hunger-Free Kids Act of 2010 (February 22, 2013)
• CIP Development Guide, with State Self-Assessment Tool (December 2012 and March
2013)
• SP 50-2013, Release of the new State Agency (NSLP/SNAP) Direct Certification Rate
Data Element Report (Form FNS-834) (July 1, 2013)
• Q-and-As - Direct Certification Process – SP 54-2013 (August 16, 2013)
• SP 38-2013, Release of the new School Food Authority (SFA) Verification Collection
Report (April 29. 2013)
• Webinars:
• CIP Webinar (January 2013)
• FNS-742 Webinar (July 2013)
• New Direct Certification Process Webinar (August 20, 2013)
67
QUESTIONS?
68