To SY14-15 Verification and Civil Rights Webinar

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Verification
School Year
2014-2015
Alabama
Department of Education
Child Nutrition Programs
What is Verification?
The confirmation of a students’
eligibility for Free and Reduced-Priced
meals under the National School Lunch
Program or School Breakfast Program.
Required annually by the USDA
Reauthorization Act of 2004
School Year 2014-15
Verification Deadlines
• As of October 1
• Count Total Number of Approved Applications
• November 15
• Verification Process Completed
• February 1
- Track households that were terminated due to verification and
reapplied and were reapproved
• Summary Submission to State Department
Selecting Applications for
Verification
• First establish the Sample Pool
•
The total number of applications approved as of
October 1st
• Then calculate the Sample Size
•
This is number of applications subject to verification; the
minimum and maximum sample size is 3% total
•
The Sample Size does not include Direct Certification,
Homeless, Runaway, Migrant, or Head Start
Selecting Applications for
Verification
Calculate number of applications to be
verified using one of the following
methods:
• Standard Sample Size
• Alternate Sample Sizes
•
•
Alternate One
Alternate Two
Verification Information is
Available:
Eligibility Manual for School Meals (yellow book)
Determining and Verifying Eligibility
August 2014
Part 9, Pages 81-100
Online Verification Tutorial
SEPTEMBER 23, 2014
ALABAMA STATE DEPARTMENT OF EDUCATION
CHILD NUTRITION PROGRAMS
Authority Levels for Online Verification
Authority levels must be set for Sponsor Users prior to accessing the online Verification
Summary
 To set authority levels:
 Log on to the CNP Online Application
 Click User Account
 Click Edit User
 Click the Edit button next to the Sponsor User that is being edited
 Select the authority level appointed to the Sponsor User
 Click Update User
 There are 3 levels of authority for verification:
1.
Editor
2.
Submitter
3.
Viewer
Accessing the Online Verification Summary
1.
2.
3.
4.
5.
Log onto the CNP Online Application
Click NSLP
Click Forms
Select Verification Summary
The LEA’s verification summary page opens
Accessing the Online Verification Summary
 Sponsor’s agency name, LEA-ID, LEA name, address, and
type of LEA are all pre-populated from the system
interface.
 Use the drop down box to select the school year.
Entering Information Into the Online
Verification Summary
 After selecting the program year, the verification
summary page will load.
 Only the cells applicable to the Sponsor are editable.
Editable Cells
Disabled Cells
I. Enrollment, Application, and
Pre-Verification Counts
I. Enrollment, Application, and
Pre-Verification Counts
Complete before starting the verification process to identify
the correct number of applications to pull for verification.
I. Enrollment, Application, and
Pre-Verification Counts
Section 1:
Total School, Residential Child Care Institutions, and Enrolled Students
The numbers entered in this section should be the
enrollment numbers as of October 1st.
I. Enrollment, Application, and
Pre-Verification Counts
Section 2:
SFAs with Schools Operating Alternate Provisions
Only SFAs operating under Provision 2, 3, or Community Eligibility
Provision (CEP) report under Section 2.
I. Enrollment, Application, and
Pre-Verification Counts
Section 3:
Students Approved as FREE Eligible NOT Subject to
Verification. (Direct Certification)
I. Enrollment, Application, and
Pre-Verification Counts
Section 4:
Students Approved as FREE or REDUCED PRICE Eligible
Through a Household Application
I. Enrollment, Application, and PreVerification Counts
These cells will populate automatically.
I. Enrollment, Application, and PreVerification Counts
The following cells will be visible only to schools
required to conduct Independent Review.
Saving Information Entered
To save the information that has been entered, scroll to the bottom of the
form and click the Save button located on the bottom left corner.
Saving Information Entered
Once the information entered has been saved, a red circle with a white
exclamation point will appear beside any cell where an error was found
or if no information was entered into the cell.
Correct the errors and save the
verification summary again.
II. Results of Verification
II. Results of Verification
Section 5:
All SFAs must report Section 5 (except for No Verification required).
“For Cause” Applications
 The LEA has an obligation to verify all questionable applications as
“for cause.”
 Any verification that is conducted “for cause” is in addition to the
sample size required.
II. Results of Verification
Entering Data From Verified Applications
Click the “Add New Application” button to add applications.
This button must be clicked every time that a new application is
entered.
II. Results of Verification
Enter the File # for Household Application. This is the method the LEA uses to identify the
application.

For example:

Numerical

Last Name
II. Results of Verification
Enter the number of approved students on the application.
II. Results of Verification
Select the benefit type prior to the verification process using the drop
down box to select:
•
•
•
FREE-CATEGORICAL
FREE INCOME
REDUCED PRICE
II. Results of Verification
Select the result of verification by using the drop down box:

Responded, no change

Responded, changed to free

Responded, changed to reduced price

Responded, changed to paid

Non Response, incomplete documentation provided by household

Non Response, household never responded to SFA
II. Results of Verification
This step may not be able to complete before February 15th.
Check the box next to Reapplied & Reapproved by Feb. 15 if the
application was resubmitted and reapproved on or before Feb. 15th.
II. Results of Verification
Click the update button located at the bottom right to show the application as
entered on the verification summary.
II. Results of Verification
Once updated, the application information is listed below
the search fields.
Search
field
Application
Information
Changes may be made to an application that has already been entered by clicking the Edit
link beside the application information. The entire application may be deleted by
clicking the Delete link.
II. Results of Verification
Click on “Add New Application” to enter all verified
applications” until the correct number of
applications have been entered (See 5-5).
Checking for Errors
Verification entries may be sorted in the following ways to check for errors:
 Application ID
 Number Of Students Approved On Application
 Original Benefit Type



Free – Categorical
Free – Income
Reduced Price
 Results of Verification






Responded, no change
Responded, changed to free
Responded, changed to reduced price
Responded, changed to paid
Non Response, incomplete documentation provided by household
Non Response, household never responded to SFA
 Reapplied and Reapproved
Methods for Finding Application Information
Information may be found in two ways:
1.
METHOD ONE: To sort alphabetically or numerically, click the column name
in the Application Data Header.
2.
METHOD TWO: To search for applications with a specific value in any column,
enter the desired value in the search fields under the Application Data Header.
Methods for Finding Application Information
Method One
Application
Data Header
Method Two
Search Fields
II. Results of Verification
Verification totals will be calculated for you based on the
information entered.
Submitting the Verification Summary
 Be sure that you have “Saved” information that you
have entered.
 Once all information has been entered, checked for
errors and saved, click the “Submit” button on the
bottom left of the screen.
Submitting the Verification Summary
A message from webpage will appear. Click OK to finalize submission of the
Verification Summary.
Submitting the Verification Summary
After clicking OK, the Verification Summary will appear with a message
below that is highlighted yellow.
The message indicates read only mode with the user name, date, and time
of the successful submission.
Submitting the Verification Summary
If there are errors when the Verification Summary is submitted, an error
message will appear that is highlighted in red.
The submission was not successful.
Submitting the Verification Summary
Errors will be identified on the Verification Summary by a red circle with
an exclamation point inside.
Correct the errors and click the Submit button again.
After Submitting the Verification Summary
Report
The Verification Summary Report can be printed by clicking on “File”,
then “Print” on the upper left corner of your screen.
After Submitting the Verification Summary
Report
The Verification Summary Report may be edited after it has been
submitted until March 1st.
Click the Undo Submit button located in the top left corner of the
Verification Summary Report below the year selection to undo the
submission.
Civil Rights Compliance In
Child Nutrition Programs
State of Alabama
Department of Education
Child Nutrition
Sponsors Receiving USDA Funds Must Follow Civil Rights
Regulations And Policy:
• Food and Nutrition Service (FNS) 7CFR 15, 210-252.7
Federal Regulations cover the following Child Nutrition
Programs:
•
•
•
•
National School Lunch, Breakfast and Special Milk Programs
Summer Food Program
Food Distribution Program
Child and Adult Care Food Programs
What Is Discrimination?
Discrimination is defined as different
treatment which makes a distinction of one
person or a group of persons from others;
either intentionally, by neglect, or by the
actions or lack of actions based on six
protected classes: race, color, national
origin, sex, age, or disability.
Discrimination = 4 D’s
…an individual or group is:
• Denied benefits or services that others receive.
• Delayed receiving benefits or services that others
receive.
• Treated Differently than others to their
disdvantage.
• Given Disparate treatment something which does
not seem discriminatory, but has a discriminatory
impact in practice
Examples Of Discrimination
•
•
•
•
•
•
Refuse a child’s enrollment based on disability.
Failure to provide reasonable accommodations to disabled individuals.
Serving meals at a time, place, or manner that is discriminatory.
Selectively distributing applications.
Failure to provide the same eligibility criteria to all participants.
Failure to provide foreign language materials regarding Child Nutrition
Programs.
Goals Of Civil Rights
• Equal treatment for all applicants and beneficiaries.
• Knowledge of rights and responsibilities.
• Elimination of illegal barriers that prevent or deter people from
receiving benefits.
• Dignity and respect for all.
Public Notification System
• All sponsors in Child Nutrition Programs must
display the non-discrimination poster in a
prominent area where participants and potential
participants have access.
“And Justice For All”
Non-Discrimination Statement
“The U.S. Department of Agriculture (USDA) prohibits discrimination against its customers,
employees, and applicants for employment on the bases of race, color, national origin, age,
disability, sex, gender identity, religion, reprisal, and where applicable, political beliefs,
marital status, familial or parental status, sexual orientation, or if all or part of an individual's
income is derived from any public assistance program, or protected genetic information in
employment or in any program or activity conducted or funded by the Department. (Not all
prohibited bases will apply to all programs and/or employment activities.)
If you wish to file a Civil Rights program complaint of discrimination, complete the USDA
Program Discrimination Complaint Form, found online at
http://www.ascr.usda.gov/complaint_filing_cust.html, or at any USDA office, or call (866)
632-9992 to request the form. You may also write a letter containing all of the information
requested in the form. Send your completed complaint form or letter to us by mail at U.S.
Department of Agriculture, Director, Office of Adjudication, 1400 Independence Avenue, S.W.,
Washington, D.C. 20250-9410, by fax (202) 690-7442 or email at program.intake@usda.gov.
Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA
through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (in Spanish).
USDA is an equal opportunity provider and employer.”
When A Non-Discrimination Statement Is
Needed:
•Employee Handbooks
Informational
Materials that
require the
Nondiscrimination
Statement include:
•Enrollment Forms
•Menus
•Newsletters
•Brochures
•Parent Handbooks
•Flyers
•Print or broadcast advertisements
•Photos and other graphics used to provide program or
program related information
•Websites
Public Notification
• If material is too small to permit the full civil rights statement
then use:
• “The USDA is an equal opportunity provider and employer”
Public Notification System
• Include the required nondiscrimination statement on all
appropriate FNS and agency publications, web sites,
posters, and informational materials.
• Convey the message of equal opportunity in all photos and
other graphics that are used to provide program or program
related information.
Complaints Investigation
To file a complaint of discrimination, write USDA, Director,
Office of Adjudication, 1400 Independence Avenue, SW,
Washington, D.C. 20250-9410 or call toll free (866) 6329992 (Voice). Individuals who are hearing impaired or have
speech disabilities may contact USDA through the Federal
Relay Service at (800) 877-8339; or (800) 845-6136
(Spanish).
Communicating With Others:
• Acknowledge people’s views even when you cannot agree
with them.
• Try to identify issues and emotions in the beginning.
• Try to establish rapport.
• Try to remain calm and open.
Communicating With Others Cont’d:
• Be careful with words you use.
• There are no right or wrong answers, just differences in
perspectives.
• One of the reasons parents from different cultural,
economic, and religious backgrounds are not involved in
their children’s schools is they feel there is a lack of
understanding about their culture by others.
Communicating With Others Cont’d:
• LEAs have a responsibility to be aware of the language
needs of Limited English Proficient (LEP) families and ensure
these households have access to the same information other
parents have in a manner they can easily understand.
• Once an LEA becomes aware of a household’s
communication needs, the LEA must provide meaningful
access to information that is furnished to non-LEP
households.
Food For Thought
In order to reduce the risk of a civil rights discrimination
complaint, ask yourself the following questions each
time an applicant and/or participant comes to your
program.
• Am I treating this person in the same manner I treat
others?
• Have I given this person the opportunity to clarify all
relevant factors or inconsistencies?
• Have I told this person exactly what information I need
to make a determination on the application?
• Have I provided the person with the information he or
she needs to make necessary decisions?
PLATINUM RULE:
“Treat others the way you want to be treated”
Cultural Knowledge Test
Laughter is a universal symbol of humor.
False.
Laughter, for many people, is a sign of embarrassment symbolizing that
they do not know what is being discussed or the answer to an inquiry.
Cultural Knowledge Test
For most Native Americans, when a child is being reprimanded by an adult,
eye contact with the adult is a sign of honesty and respect.
False.
In some Native cultures, a child is being defiant if she looks an adult or
authority figure in the eye while being reprimanded or corrected.
Is This A Civil Rights Complaint??
•Remember that:
•They may be valid and important, but
some are not covered by the rules for
Civil Rights complaints.
67
Is This A Civil Rights Complaint??
o A complaint is received from a site that someone who
came to conduct a review was rude and disrespectful. The
complaint states that the reviewer’s tone was demeaning
and generally unpleasant.
o Is this a civil rights complaint and should it be reported?
o Depends, needs to be investigated to see if rude behavior was
because of a protected class. People can discriminate
someone of their own race.
o When in doubt of whether it is a civil rights violation, always
provide complaint information.
Is This A Civil Rights Complaint??
o To meet the annual training requirement for site
supervisors, the sponsor develops a computer based
training program that everyone will be required to
complete.
o Is this a civil rights violation and should it be reported?
o No
Is This A Civil Rights Complaint??
o A community group approaches a SFSP sponsor and asks for a list of
Hispanic children so it can provide holiday presents to them.
o Is this a civil rights violation and should it be reported?
o Yes, This is a confidential list and raises issues of national origin.
o You can give the name of the organization to providers or have providers
sign a waiver. Example: Free/reduced meal benefits. You may receive
information that your household might be interested.
Is This A Civil Rights Complaint??
o A parent of a child alleges program discrimination by a site
and wants to file a complaint. You know that the site does
not discriminate.
o Is this a civil rights complaint and should it be reported?
o Yes, if discrimination is alleged, you must provide the complaint
information.
Is This A Civil Rights Complaint??
o A sponsor is very angry that someone filed a frivolous
discrimination complaint and took up a lot of her time and
made her look bad. She tells her site supervisor to watch
out for this “troublemaker.” The next time the person
visits, he encounters “attitude” from the co-provider.
o Is this a civil rights violation and should it be reported?
o Yes, this is reprisal and retaliation. There is also a
confidentiality issue.
Is This A Civil Rights Complaint??
o A parent complains about the choices provided during
breakfast and demands that gluten-free products be
provided for her child.
o Is this a civil rights complaint and should it be reported?
o Yes, This relates to civil rights if it is a disability defined by a
physician special rule that provides accommodating food when
there is a disability.
Is This A Civil Rights Complaint??
• An autistic middle school student forgets her lunch
money for the fourth time. The teacher tells the
cashier to give the child two packages of saltine
crackers and tells the child that “This will teach you
not have your lunch money again”. The child’s
mother writes a letter to the Secretary of Agriculture
alleging discrimination based on the child’s autism.
Is this a civil rights complaint and should it be
reported?
• Yes. It should be considered a complaint even if it appears
to be a program related issue.
• The results of the investigation determined that it was a
program complaint. Improper application of the SFA
charge policy and a potential violation of the FNS
Instruction 791.1 Prohibition Against Denying Meals and
Milk to Children as a Disciplinary Act
Is This A Civil Rights Complaint??
o A parent contacts the School Food Service Director
and says their child is being denied their religious
right to be able to eat only vegetarian meals.
o Is this a civil rights complaint and should it be reported?
o No. Religion is not a protected class in Child Nutrition
Programs under FNS Instruction 113-1 Civil Rights
Compliance and Enforcement – Nutrition Programs and
Activities .
o It would be suggested that the SFA try to work with the
complainant and try to accommodate there religious
needs.
Is This A Civil Rights Complaint??
o A minority high school football player approaches
the cafeteria manager and says he isn’t getting
enough food when he selects a reimbursable meal
and would like larger servings.
o Is this a civil rights complaint and should it be reported?
o No. Just because the student is a minority student does not mean
he automatically is considered to be alleging discrimination. He
did not state that he was not getting adequate servings because of
his minority status. He only wants a larger serving.
o If he had said that he was not getting a large enough serving
because of his racial/ethnic background, then, Yes, it would be a
complaint and you would need to report it.
Questions?
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