Finding Text
7 CFR Part 245.6(c)(4) requires that the local educational agency must use the income information provided by the household on the application to calculate the household's total current income for determination if the household was eligible for free or reduced-price benefits. When a household submits an application containing complete documentation, as defined in 7 CFR Part 245.2, and the household's total current income is at or below the eligibility limits specified in the Income Eligibility Guidelines as defined in 7 CFR Part 245.2, the children in that household must be approved for free or reduced-price benefits, as applicable.
Errors in the eligibility determination were noted with 2 out of 60 individual students tested. Two students selected were receiving free benefits, however, there was no supporting documentation (i.e. application or direct certification) available to support this determination. We noted these students received free benefits in the prior school year. According to 7 CFR 245.6(c)(2), an individual student’s eligibility from the previous school year (before July 1) carries over for up to 30 operating days into the new school year, or until a new eligibility determination is made, whichever comes first. Therefore, these students’ eligibility would have been appropriately free for the first 30 days of the school year, however, should have been changed to denied when an application was not received, and the students were not directly certified. Therefore, the students’ eligibility was incorrectly determined to be free, and this error would have led to the School District receiving less program income from providing meals as well as being over reimbursed for claimed meals relating to these students’ actual benefits usage.
The School District should ensure eligibility calculations on submitted applications are properly performed, which could include a secondary review. Additionally, a review of all free/reduced students should be performed to ensure they have an approved application on file or are directly certified. This will help to ensure that the School District properly complies with Federal regulations, properly receives all program income due to the school and is not over reimbursed with federal funding for unallowable claimed free or reduced-price meals.