Finding: Improvements were needed in the District’s process for verifying free and reduced-price meal applications.
Criteria: Title 7, Section 245.6, Code of Federal Regulations (CFR), provides application and other documentation requirements for a child to qualify for meals served free or at a reduced price under the School Breakfast and National School Lunch programs. Children qualify for free or reduced-price meals based on household income and categorical eligible children are automatically eligible for free meal benefits because they, or any household member, receive benefits from, or are eligible for, certain other assistance programs. Also, Title 7, Section 245.6a, CFR, provides, in part, that the District must verify the household income of the lesser of 3,000 or 3 percent of the free and reduced-price meal applications approved as of October 1. The sample must be selected from error-prone applications defined as applications that indicate monthly income within $100, or annual income within $1,200, of the applicable income eligibility limit for free or reduced-price meals.
Title 7, Section 245.6a(a)(7), CFR, provides that the sources of verification may include written evidence as the primary source of verification and includes written confirmation of a household’s circumstances, such as wage stubs, award letters, and letters from employers. Whenever written evidence is insufficient to confirm income information on the application or current eligibility, the District may require verbal confirmations of a household’s circumstances by a person outside of the household.
Title 7, Section 245.6a(f)(2), CFR, also provides that the documentation of income must indicate the source, amount, and frequency of all income and can be for any point in time between the month prior to application for school meal benefits and the time the household is requested to provide income documentation. The USDA, Eligibility Manual for School Meals: Determining and Verifying Eligibility, July 18, 2017 (Manual) requires that reportable income to be included on the free and reduced-price meal application include earnings from work, public assistance, and any other income regularly received. In addition, Title 7, Section 245.6a(f)(7), CFR, requires the District, based on the verification activities, to make appropriate modifications to the eligibility determinations made initially and notify the household of any change.
Condition: For the 2022-23 fiscal year, the District had a total of 655 free and reduced-price meal applications and District personnel input household information for students into food service software to help determine the student’s meal-price status. In an effort to comply with Federal requirements, District personnel selected for verification 20 (3 percent) of the applications. However, our examination of District records supporting the 20 applications disclosed that, contrary to Federal verification requirements, the household income listed on 4 applications was not properly supported and the District did not change the meal-price status of the students listed on the 4 applications. Specifically, based on District records, the listed household income was incorrect on:
• 2 applications and the food service software was not updated based on the income of the households’ most recent earnings statements.
• Another application because it reflected earnings from a prior year earnings statement and District personnel did not request the most recent earnings statement.
• A fourth application because the application excluded housing and subsistence allowances.
Cause: District personnel indicated that, due to personnel turnover, those responsible for verifying free and reduced-price meal applications did not fully understand the Federal verification requirements. In addition, those responsible for review of the verifications were not fully aware of the input requirements within the food service software and did not detect the errors.
Effect: The price of the meals for each of the students listed on the 4 applications should have been, but was not, increased to reduced price or paid (i.e., full price). Without following the Federally mandated verification procedures, the District did not comply with those requirements and may be using Federal funds to serve students who do not qualify for free or reduced-price meals.
Recommendation: The District should enhance procedures to ensure that free and reduced-price meal application verifications are performed in accordance with Federal requirements. Such enhancements should include appropriate training for personnel to understand the Federal verification requirements and food service software input requirements.
District Response: The District acknowledges the finding and has corrected the errors. Accordingly, a corrective action plan (CAP) has been developed and provided separately.