Reducing Paperwork and Connecting Low-Income Children with School Meals
Opportunities under the New Child Nutrition Reauthorization Law
In enacting the Child Nutrition and WIC Reauthorization Act of 2004, Congress made several changes in the eligibility determination process for free and reduced-price school meals. (The eligibility determination process has two parts: “certification,” in which children are approved to receive meal benefits, and “verification,” in which school districts obtain documentation of eligibility for a small sample of certified children.) The changes in the legislation were aimed at improving the accuracy of eligibility determinations without hindering access to meals or overly complicating program administration.
As a result of these changes, school districts face new requirements this year and in coming years.  Recognizing the increased administrative burden school districts and state agencies would face, Congress also provided tools to reduce the workload associated with these new requirements; these tools offer the further benefit of simplifying the eligibility determination process for poor families.
This paper describes a few of the key changes to the eligibility determination process — those that provide the greatest opportunity to improve low-income children’s access to free or reduced-price meals — and explains how they can be implemented in ways that reduce the administrative burden on states and school districts.
Why Did Congress Make Changes in the Eligibility Determination Process?
Recent research by the U.S. Department of Agriculture on the school meals programs identified several areas of concern that shaped the reauthorization legislation.
- Ineligible children sometimes receive free or reduced-price school meals. A portion of children approved for free or reduced-price meals were found not to be eligible for program benefits in the school districts included in one recent study. These inaccuracies arose for a variety of reasons including: 1) the household reported information accurately on its school meals application but the school district mistakenly placed the child in the wrong meal category; 2) the household reported information accurately and was certified correctly at the start of the school year, but later in the school year the household’s income rose above the free or reduced-price income limit; or 3) the household reported information incorrectly on the meals application and was certified on the basis of this erroneous information.
- Eligible children are losing school meals benefits. Each year schools must verify the information provided on a sample of school meal applications. Eligible children enrolled in the free or reduced-price meal program lose meal benefits if their parents do not respond to the request for documentation of eligibility. This can happen because the parents did not receive the request, did not understand it, do not speak English, or did not have the necessary paperwork to provide to the school.
A USDA study found that under current verification procedures, children in more than one of every three families selected for verification in metropolitan areas lost their free or reduced-price meal benefits despite being eligible for such meals.  Based on this and other USDA studies, we estimate that approximately 77,000 eligible low-income children nationwide lose free or reduced-price meals each year as a result of their parents’ failure to respond to verification requests.
- Many eligible children are not enrolled in the school meals programs. One recent study found that in the areas examined, nearly one-third (31 percent) of the children who were eligible for free meals were not certified for them, and three-fourths of the children eligible for free meals were not certified even to receive reduced-price meals. 
Guided by these findings, the authors of the reauthorization legislation sought to meet three main goals:
- improve program integrity by increasing the accuracy of the certification and verification processes;
- improve program access for low-income children by simplifying the eligibility determination process and by making sure that children who are approved for free and reduced-price meals continue to receive them throughout the school year; and
- simplify program administration so that state agencies and school districts can focus their efforts on improving program integrity and access.
These goals can sometimes be at odds with each other. For example, while increasing the sample of applications for which school districts must obtain eligibility documentation might improve program integrity, doing so has been shown to create significant barriers to program participation and to impose administrative burdens on school districts. Congress was particularly concerned about the impact of program changes on vulnerable children who need food assistance but whose parents may not successfully navigate the application or verification processes.
What Changes Were Enacted?
The provisions of the new law that relate to program integrity and access were intended to balance the three goals of strengthening program integrity, improving program access, and simplifying program administration. Although anti-hunger advocates and schools would have liked to achieve broader improvements to program access and greater administrative simplification, the changes to the certification and verification processes garnered widespread support from low-income children’s advocates, school administrators, and meal program directors. The legislation creates several opportunities for state agencies and school districts to reduce their own workload while improving program access.
Increasing Verification Response Rates
The legislation gives states and school districts new tools to increase their verification response rates (and thereby reduce the number of eligible children who lose meal benefits because their parents failed to respond to a verification request) and offers significant rewards for doing so.
School districts that use these tools or other means to achieve a high or improved verification response rate can qualify for relief from some of the new verification requirements the legislation imposes.
One of the new tools is known as “direct verification.” Beginning in July 2005, state child nutrition agencies and school districts will have the option of conducting “direct verification” — that is, using income or participation data maintained by other programs or agencies to verify eligibility for free or reduced-price meals without having to contact the household. By relying on data that has already been verified by another program, school districts can eliminate duplicative work for themselves and keep more low-income children connected to the school meals programs.
In addition, beginning in July 2005, each school district may decline to verify up to five percent of applications selected for verification and replace them with other applications to be verified. School districts may not use this discretion to reduce the overall number of applications they verify, but they may use it to continue providing free or reduced-price meals to vulnerable children whose parents are unlikely to respond to the verification request.
Reducing the Number of Applications Processed and Verified
The legislation includes new provisions that allow school districts to reduce the number of applications they must process and verify while improving program access. The law strengthens an important tool known as “direct certification,” which states and school districts can use to reduce paperwork. Children who are directly certified are approved for free meals based on information provided by another program or agency; they do not have to submit an application, are not subject to verification, and are not considered when determining the size of a school district’s verification sample.
One way the legislation strengthens direct certification is by adding new categories of children who can be directly certified. Effective July 2004, all homeless, runaway, and migrant children are designated “categorically eligible” for free meals once identified by a homeless education liaison, shelter director, migrant education coordinator, or other appropriate official. This designation enables the school district to directly certify these children, meaning they will not have to submit an application to receive free meals at the start of the school year or when they change schools. While this provision will not substantially increase the number of children who are directly certified, it will reduce paperwork for very poor families experiencing significant hardship and reduce the number of applications a school district must process.
The legislation further strengthens direct certification by requiring all school districts to directly certify children in households receiving food stamps by 2008. School districts and state child nutrition agencies already have the option of directly certifying children in households receiving cash assistance under the Temporary Assistance for Needy Families Program (TANF) or benefits under the Food Distribution Program on Indian Reservations (FDPIR), and they will continue to have this option under the new legislation.
Simplifying Program Administration
Another provision of the legislation will simplify program administration. Effective July 2004, a child who is determined eligible for free or reduced-price meals will remain eligible for the entire school year, unless a redetermination is made through the verification process. School districts will no longer be required to track when someone moves in to or out of a household or when a family’s income fluctuates.
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In sum, the reauthorization legislation offers important new opportunities to strengthen the school meals programs while helping more low-income children benefit from them. School districts will need to make up-front investments to develop procedures that take advantage of these opportunities, but these investments will pay off in the form of reduced paperwork and increased federal reimbursements.
 P.L. 108-265. The RichardB. Russell National School Lunch Act (42 U.S.C. § 1751 et seq.) and the Child Nutrition Act of 1966 (42 U.S.C. § 1771 et seq.) as amended by P.L. 108-265 are available at http://www.fns.usda.gov/cnd/Governance/nslp-legislation.htm.
 Until June 30, 2004, School Food Authorities (SFAs) were responsible for the certification and verification of eligibility for free or reduced-price school meals. The Child Nutrition and WIC Reauthorization Act of 2004 (P.L. 108-265) amended the Richard B. Russell National School Lunch Act (42 U.S.C. § 1751 et seq.) so that Local Educational Agencies (LEAs), as defined in Section 9101 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. § 7801), are now responsible for the certification and verification of eligibility for free or reduced-price school meals. This paper uses the term “school districts” to refer to SFAs or LEAs.
 For a summary of other changes to the certification and verification processes, see https://www.cbpp.org/sites/default/files/atoms/files/8-18-04fa.pdf , Zoë Neuberger, Center on Budget and Policy Priorities, August 18, 2004.
 For a more detailed discussion of research findings related to ineligible children receiving free or reduced-price meals, see https://www.cbpp.org/sites/default/files/atoms/files/11-11-03fa.pdf, Zoë Neuberger and Robert Greenstein, Center on Budget and Policy Priorities, November 13, 2003.
 See Case Study of National School Lunch Program Verification Outcomes in Large Metropolitan School Districts, prepared by Mathematica Policy Research, Inc. under a research contract with the Food and Nutrition Service, USDA, Report CN-04-AV3, April 2004, available at http://www.fns.usda.gov/oane/MENU/Published/CNP/CNP.HTM and What Have We Learned from FNS’ New Research Findings about Overcertification in the School Meals Programs?.
 See What Have We Learned from FNS’ New Research Findings about Overcertification in the School Meals Programs?.
 See Evaluation of the National School Lunch Program Application/Verification Pilot Projects — Volume I: Impacts on Deterrence, Barriers, and Accuracy , prepared by Mathematica Policy Research, Inc. under a research contract with the Food and Nutrition Service, USDA, Report No. CN-04-AV1, February 2004, Tables IV.3 and IV:11, available at http://www.fns.usda.gov/oane/MENU/Published/CNP/FILES/NSLPPilotVol1.pdf.