Eating a healthy breakfast and lunch is an important aspect of a child’s nutrition, and studies have shown that students who eat healthy diets perform better in school than children with unhealthy diets. The National Education Association (NEA) has published facts about child nutrition, and noted that a child’s development and achievement is impaired when students miss meals and experience hunger. In addition, many studies have indicated that eating breakfast at school helps children perform better academically, have better attendance records, are less likely to be late, and exhibit fewer behavioral and psychological problems.
School Districts can participate in Child Nutrition Programs administered by the United States Department of Agriculture (USDA). Schools that participate in the National School Lunch or Breakfast Program, must make free and reduced price meals available to all eligible children. Depending on a family’s income level and household size, families may be eligible to qualify for this program. According to the USDA, families currently receiving Supplemental Nutrition Assistance Program benefits (SNAP) or Temporary Assistance for Needy Families (TANF) are automatically eligible to participate in the program.
Close to the beginning of the school year, the school district must notify residents in the district that free and reduced price meals are available. The notice must include the eligibility criteria and it must be provided to the local news media (usually the local paper of the district), the unemployment office, and any major employers in the district who are contemplating large layoffs. Many schools also maintain copies of the application form at each of the buildings as a household can apply for benefits at any time of the school year.
Schools are required to review and process an application for free and reduced meals within 10 days after receiving the form. A good practice is to date stamp when the form is received by the district. Only one application is required for all children in the household, and those students that are directly certified do not need to complete an application. Eligible families must fill out information such as names of the children attending the school district, family’s annual income of each individual member, whether or not they receive SNAP or TANF benefits, and contact information. The form requests only the last four digits of the household’s primary wage earner’s social security number; however, the applicant can indicate “none” for no social security number. Students who received benefits in the prior school year are considered to be in the same status for the first 30 days starting the first day of school.
Determining if a family is eligible is based on whether the family meets the income requirements for benefits by comparing household size and total household income. The household size is based on related or unrelated individuals who are living at one residence, share housing, and the majority of the income and expenses. The income is based on the reportable income for the household, meaning that income is any money received on a recurring basis such as earnings and child support (unless specifically excluded by law for the nutrition program, such as financial assistance benefits and loans). The income reported must be gross income before deductions, and the income must be in whole dollars. The frequency of the income should be indicated on the form (e.g. weekly, bi-weekly, monthly, etc.); however, if it is not, the district can utilize the frequency as “weekly” when computing the total annual salary. If the household has no income, the household must be asked to report their status as “zero income” on the form. The school must not delay approval of an application if the form is missing information that is not required to determine eligibility such as address or birth dates. All determinations based on the results of the review of the application, whether the application is approved for free or reduced, denied, or if benefits are lessened (e.g. from free to reduced), must be communicated to the applicant. Along with the determination, the school must record on the application the date of determination, and the form must be signed or initialed by the reviewer.
If the application is incomplete, where it is missing information to determine eligibility, then the application must be denied, and the school must provide written notification to the household of the denial. The notification must include the reason for the denial, the applicant’s right to appeal, instructions for appealing the decision, and the applicant’s ability to reapply at another time during the school year. The school must keep a copy of the letter sent.
Schools are obligated to verify “for cause” when an application may be questionable. If the application in question contains all required information to assess eligibility, then the application must be approved. Schools should reach out to the household to first clarify any unclear information, before proceeding with verification for cause. The school must send the household a Notice of Selection letter, and must make at least one attempt to contact the household when there has not been adequate response to the verification.
While the application process is relatively short, there can still be instances in which confusion arises for the individuals attempting to apply for the program. This has led to efforts being made to improve the application process and facilitate the process for eligible families to apply. For example, schools are attempting to pre-populate some of the information fields, alter the technical language of the application to make it easier to read, clearly outline the automatic eligibility (if receiving SNAP, TANF, foster care, etc.), and mail applications to the family’s home throughout the school year instead of only once. This will allow schools to focus in on growing the cafeteria programs and food offerings while making eligible families feel more comfortable in applying for the program.
The more students successfully benefiting from the free or reduced lunch program, the more the school will directly benefit. This is due to a federal reimbursement the school receives for each free or reduced meal that the school provided to its students. Additionally, by encouraging more participation in the program, it will help reduce unpaid meal charges for those students who are eligible yet not certified in the program. Many students will attend school without breakfast or lunch simply because they were not enrolled in the program. This shows how imperative it is for schools to ensure its students are provided the opportunity to apply for this program and do not go hungry at school due to financial hardships.
Matthew Hecker, MS
Matthew is a member of Cerini & Associates’ audit staff where he works with our nonprofit and school district clients. Matthew has experience in internal claims auditing and external auditing, including financial statement audits and pension plan audits. Matthew’s knowledge and experience allow him to provide specific services including systems testing and analysis, internal and external audit functions, and claims audit functions.