School food service compliance document

              CHILD NUTRITION PROGRAMS
SCHOOL FOOD SERVICE
COMPLIANCE DOCUMENT
School Year 2011-2012
July 2011
Nondiscrimination Statement: This explains what to do if you believe you have been treated unfairly. ��In accordance
with federal law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on the basis
of race, color, national origin, sex, age, or disability. 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) 632-9992 (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). USDA is an equal opportunity provider and employer.”
This publication, printed by the Oklahoma State Department of Education Printing Services, is issued by the Oklahoma
State Department of Education as authorized by 70 O.S. §3-104. Thirteen hundred copies have been prepared using
Child Nutrition Programs federal funds at a cost of $15,314.00. Copies have been deposited with the Publications
Clearinghouse of the Oklahoma Department of Libraries. JULY 2011.
Oklahoma State Department of Education
Child Nutrition Programs Section
2500 North Lincoln Boulevard, Room 310
Oklahoma City, Oklahoma 73105-4599
(405) 521-3327
Fax: (405) 521-2239
Consultant Territories .................................................................................................................... 1
Reimbursement Rates ................................................................................................................... 2
Reporting Dates Checklist ............................................................................................................. 3
List of Child Nutrition and Related Acronyms ................................................................................ 4
I. After-School Snack Program (ASSP) ......................................................................... 5
II. Charter School Procedures for Child Nutrition Programs ........................................... 15
III. Civil Rights ............................................................................................................... 17
IV. Eligibility Documentation for Meal Application and Verification ................................... 25
V. Financial Management ............................................................................................107
VI. Food Service Management Companies (FSMC) ..................................................... 137
VII. Fresh Fruit and Vegetable Program (FFVP) ............................................................ 151
VIII. Meal-Counting and Meal-Claiming Procedures ....................................................... 153
IX. Menu Planning and Food Production ....................................................................... 181
X. Nutrition Education and Training (NET) Program ..................................................... 213
XI. Procurement Procedures and Practices ................................................................... 229
XII. School Meals Initiative/Meal Responsibilities ........................................................... 269
XIII. Special Milk ........................................................................................................... 319
XIV. Staffing Standards ................................................................................................... 321
XV. Student Issues ........................................................................................................ 325
XVI. Summer Meal Availability ........................................................................................ 337
XVII. USDA-Donated Foods (Formerly Commodities) .................................................... 343
XVIII. Index ...................................................................................................................... 367
Residential Child Care Institutions Additional Requirements: Pages 353-365
TABLE OF CONTENTS
CHILD NUTRITION PROGRAMS
SCHOOL FOOD SERVICE COMPLIANCE DOCUMENT
SCHOOL YEAR 2010-2011
Foreword
The School Food Service Compliance Document was developed by the Oklahoma State Department of Education
(SDE) Child Nutrition Programs (CNP) Section (hereinafter referred to as the State Agency) with the intent to assist
school personnel in understanding the policies and procedures of CNP. All items discussed in the Compliance Document
specifically deal with the requirements of the National School Lunch Program (NSLP) and the School Breakfast Program
(SBP) and how implementation of these requirements may be accomplished.
National School Lunch Program
The National School Lunch Act (NSLA), passed in 1946, established school lunch programs across the nation. The
purpose of the program is to safeguard the health and well-being of the nation’s children and to encourage the consumption
of agricultural abundance. The objectives of the NSLP are to make available to all students a lunch that is nutritionally
adequate and acceptable, to provide assistance to participants to ensure that minimum meal requirements are met, and
to ensure that all programs are accountable.
School Breakfast Program
Established by federal legislation in 1966, the SBP received permanent authorization by Public Law 94-105, enacted
October 7, 1975. The purpose of this program is to make breakfast available for students who, for various reasons,
come to school without an adequate breakfast.
Other programs administered by the State Agency in which schools can participate are as follows:
• Special Milk Program (SMP) (refer to page 319)
• After-School Snack Program (ASSP) (refer to page 5)
• Summer Food Service Program (SFSP) (refer to page 337)
• Nutrition Education and Training (NET) Program (refer to page 213)
• Fresh Fruit and Vegetable Program (FFVP) (refer to page 151)
The Compliance Document is updated annually, incorporating the latest changes, and is available to all program
participants at the CNP Web site listed below. If you have questions concerning any part of the Compliance Document,
please contact the State Agency at (405) 521-3327.
The following Web sites are provided for your information:
• SDE Web site address is: www.sde.state.ok.us
• Code of Federal Regulations Web site address is: http://www.gpoaccess.gov/ecfr
• Food and Nutrition Service (FNS) Web site address is: www.fns.usda.gov/cnd
• Commodities Distribution Web site address is: www.okdhs.org
• National Food Service Management Institute (NFSMI) Web site address is: http://www.nfsmi.org/
information/schoolrecipeindexalpha.html
1 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
NANCY McCULLOUGH Cleveland
(405) 779-0130 Grady
South Central McClain
Nancy_McCullough@sde.state.ok.us Pontotoc
Stephens
KRISTEN MILLER Alfalfa
(405) 880-2323 Beaver
Northwest Cimarron
Kristen_Miller@sde.state.ok.us Custer
Dewey
Ellis
Garfield
Grant
Harper
Major
Roger Mills
Texas
Woods
Woodward
JENNIFER WEBER Blaine
(405) 255-5059 Canadian
West Central Oklahoma
Jennifer_Weber@sde.state.ok.us (West of Santa Fe)
FONDI WESEVICH Craig
(918) 876-0539 Kay
North Noble
Fondi_Wesevich@sde.state.ok.us Nowata
Osage
Ottawa
Pawnee
Washington
VACANT Coal
Hughes
East Central Lincoln
@sde.state.ok.us Pittsburg
Pottawatomie
Seminole
VACANT Rogers
Tulsa
East
@sde.state.ok.us
PATRICIA BEUTLER Kingfisher
(405) 433-2868 Logan
North Central Oklahoma
Patricia_Beutler@sde.state.ok.us (East of Santa Fe)
Payne
DARREN BLANCHARD Creek
(918) 321-3231 McIntosh
Mideast Muskogee
Darren_Blanchard@sde.state.ok.us Okfuskee
Okmulgee
JERI BUCHANAN Beckham
(580) 393-4461 Caddo
Southwest Comanche
Jeri_Buchanan@sde.state.ok.us Greer
Harmon
Jackson
Kiowa
Washita
PAT GOWER Adair
(918) 456-4263 Cherokee
Northeast Delaware
Pat_Gower@sde.state.ok.us Mayes
Sequoyah
Wagoner
KAREN JOHN Bryan
(580) 775-3515 Carter
South Cotton
Karen_John@sde.state.ok.us Garvin
Jefferson
Johnston
Love
Marshall
Murray
Tillman
CARRIE LOCKHART Atoka
(918) 232-6278 Choctaw
Southeast Haskell
Carrie_Lockhart@sde.state.ok.us Latimer
LeFlore
McCurtain
Pushmataha
CONSULTANT TERRITORIES
Area consultants are available to provide technical assistance to school food authorities (SFAs). Following is a list
of the area consultants, assigned counties, and telephone numbers where the consultants may be reached.
State Agency Telephone Number: (405) 521-3327
State Agency Fax Number: (405) 521-2239
2 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
REIMBURSEMENT RATES
SCHOOL BREAKFAST PROGRAM (SBP),
NATIONAL SCHOOL LUNCH PROGRAM (NSLP),
SPECIAL MILK PROGRAM (SMP), AND
AFTER-SCHOOL SNACK PROGRAM (ASSP)
The United States Department of Agriculture (USDA) has announced the Child Nutrition Programs’ (CNP) reimbursement
rates. Reimbursement rates are revised annually to account for changes in the Consumer Price Index (CPI). The
following rates are effective July 1, 2011.
Reimbursable Lunches Served to Students SFAs that served 60 percent or more of their
lunches free or at a reduced price in second
preceding school year (2009-2010)
Free Lunches $ $
Reduced-Price Lunches
Full-Price Lunches
Reimbursable Breakfasts Served to Students
Free Breakfasts $
Reduced-Price Breakfasts
Full-Price Breakfasts
Commodities Per Student Lunch $
Severe Need Breakfasts1
Free Breakfasts $
Reduced-Price Breakfasts
Full-Price Breakfasts
Special Milk Program2
Nonpricing Program $ per half-pint served
Option 1 Pricing Program per full-price half-pint served and average
cost of free half-pint served
Option 2 Pricing Program per half-pint served
After-School Snack Program
Free Snack $
Reduced-Price Snack
Full-Price Not Eligible Snack
School sites within a district that served 40 percent or
more of their lunches free or at a reduced price in the
second preceding year (2009-2010)
REIMBURSEMENT
RATES WILL BE
ENTERED INTO
THE CNP
eCLAIMS
SYSTEM AND
POSTED ON THE
WEB SITE
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 3
The following reports must be completed and maintained in SFA files.
October 31 Civil Rights Compliance Checklist: page 19
February 1 of Each Year On-Site Review (Only for sites with more
than one eating site; a review must be
completed for each site): page 173
Twice Annually On-Site Review for After-School Snacks
(Only for sites participating): page 13
REPORTING DATES CHECKLIST
Date Due Report Date Submitted
Zip Code Direct Certification Request Due
July 10 of Each Year Year-End Expenditure Report for previous school year (NSLP,
SBP, SMP, ASSP)—eClaims: page 129
Prior to Submitting Renewal Application, Agreement, Policy Statement,
First Claim for Year and Changes to the Permanent Policy Statement—eClaims
Tenth of Each Month Monthly Claim for Reimbursement—eClaims
Fifteenth of Each Month Monthly Claim for Reimbursement—Fresh Fruit and Vegetable
Program
August 1 Each Year Provision 1, 2, or 3 Application (Only for sites participating)
(Call 405-521-3327 for a copy)
Before September Food Safety Inspection Report—eClaims: page 207
Claim May Be Submitted
October 1 Verification Process to Begin: page 59
After October Claim Has Low-Income Student Count Report (Must be completed prior
to submission of November claim)—eClaims: page 127
November 15 Verification Process to Be Completed
Before December Claim Direct Certification Request Due
May Be Submitted
January Workshop Registration Form Due for Summer Food Service
Program
Before January Claim Verification Summary Report—eClaims: page 101
May Be Submitted
Before March Claim Direct Certification Request Due
May Be Submitted
April 15 Application for Fresh Fruit and Vegetable Program—eClaims
May 15 Seamless Summer Option Application Due
After July 1, Until
September 10
The following reports are to be submitted electronically to the State Department of Education, hereinafter referred to as
the State Agency, on or before the denoted date of each year. Log onto the CNP Web site to locate the appropriate
report form(s).
(If Applicable)
Been Processed, No Later
Than November 18
Forms needed for eligibility at a glance (also available through eClaims):
Income-Eligibility Guidelines for Free and Reduced-Price Meals—page 69
Letter to Household NSLP/SBP—page 61
Application for Free and Reduced-Price Meals—pages 65
Notice to Households of Approval/Denial of Benefits—page 71
Direct Certification Notice—page 81
Notification of Selection for Verification of Eligibility—pages 93
Letter of Verification Results and Adverse Action—page 97
4 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
LIST OF CHILD NUTRITION AND RELATED ACRONYMS
ADA Average Daily Attendance
ADM Average Daily Membership
AF Attendance Factor
ANSMP Assisted Nutrient Standard Menu Planning
ASSP After-School Snack Program
CACFP Child and Adult Care Food Program
CN Child Nutrition
CNA Child Nutrition Act
CNP Child Nutrition Programs
CPI Consumer Price Index
CRE Coordinated Review Effort
DHS Department of Human Services
EC Early Childhood
EPA Environmental Protection Agency
FDA Food and Drug Administration
FDPIR Food Distribution Program on Indian Reservations
FFVP Fresh Fruit and Vegetable Program
FMNV Foods of Minimal Nutritional Value
FNS Food and Nutrition Service (USDA)
FSIS Food Safety and Inspection Service (USDA)
FSMC Food Service Management Company
FY Fiscal Year
HACCP Hazard Analysis of Critical Control Points (USDA)
HUSSC HealthierUS School Challenge
IEG Income-Eligibility Guidelines
IEP Individual Educational Plan
ITB Invitation to Bid
LEA Local Education Agency
NCLB No Child Left Behind
NET Nutrition Education and Training
NFSMI National Food Service Management Institute
NSLA National School Lunch Act
NSLP National School Lunch Program
NSMP Nutrient Standard Menu Planning
OCAS Oklahoma Cost Accounting System
OMB Office of Management and Budget
RCCI Residential Child Care Institution
RDA Recommended Dietary Allowance
RFP Request for Proposal
SA State Agency (also known as the State Department of Education)
SBP School Breakfast Program
SDE State Department of Education (also known as the State Agency)
SFA School Food Authority
SFSA School Food Service Account
SFSP Summer Food Service Program for Children
SMI School Meals Initiative
SMP Special Milk Program
SNAP Supplemental Nutrition Assistance Program (formerly Food Stamp)
SNB Severe Need Breakfast
SOP Standard Operating Procedures
TANF Temporary Assistance to Needy Families
USDA United States Department of Agriculture
WIC Special Supplemental Nutrition Program for Women, Infants, and Children
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 5
I. AFTER-SCHOOL SNACK PROGRAM (ASSP)
Sections 107 and 108 of Public Law 105-336 (the Child Nutrition Reauthorization Act of 1998) authorizes
reimbursement for snacks served to children through the age of 18 (and to individuals, regardless of age, who
are determined by the State Department of Education [the State Agency] to be mentally or physically disabled)
who participate in programs organized to provide after-school care. The intent is to assist sites in operating
organized programs of care which include education or enrichment activities known to help reduce or prevent
children’s involvement in juvenile crime or other high-risk behavior. (Reference 2000-CN-04.)
A. Eligible Programs
To be eligible to qualify for reimbursement under the National School Lunch Program (NSLP), after-school
care programs must meet the following criteria:
1. They must be run by a site that is participating in the NSLP.
2. The purpose of these programs must be to provide care in after-school settings. This does not mean
that the programs must offer formal child care as recognized by a licensing authority. There is no
federal requirement for after-school care sites operating under this provision to have either federal,
state, or local licensing or approval as a condition of eligibility. However, to qualify under this
provision, these programs must be organized to provide children with regularly scheduled activities
in a setting that is structured and supervised. By regularly scheduled, it is not meant that the program
must occur daily. Moreover, while eligible programs would not need to establish formal enrollment
procedures, they must have a means of determining that children are present on a given day, such as
a roster or sign-in sheet.
3. Eligible programs must include education or enrichment activities in organized, structured, and
supervised environments. It must be stressed that any extracurricular activities such as the school
choir, debate team, or drama society CAN qualify to participate under this provision only if their
basic purpose is to provide after-school care as defined above.
It must be emphasized that under no circumstances can organized athletic programs engaged in
interscholastic sports be approved as after-school care programs under this provision. In the
Conference Report that accompanied Public Law 105-336, the Conference Committee declared its
intent that support under this provision would not be provided to members of athletic teams. However,
while athletic teams participating in interscholastic sports programs may not be approved, programs
which include supervised athletic activity along with education or enrichment activities may
participate. The key would be that they are open to all and do not limit membership for reasons
other than space or security considerations or, where applicable, licensing requirements.
B. Oversite
Any site that is operating the NSLP may be reimbursed for snacks served to eligible children in eligible
after-school care programs. While the After-School Snack Program (ASSP) must be sponsored or operated
by a school food authority (SFA), this does not mean that the SFA must carry out the day-to-day management
of the program. For example, the Parent-Teacher Association (PTA) or Young Men Christian’s Association
(YMCA) could operate the program under an arrangement with the site. However, the SFA must retain final
administrative and management responsibility for the snack service. Furthermore, the SFA for the school
must be the party that enters into the agreement with the State Agency and must assume full responsibility
for meeting all program requirements.
6 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
C. Reimbursement
Under this provision, sites may claim reimbursement for one snack, per child, per day. Children are
eligible to participate through the age of 18, and if a student’s nineteenth birthday occurs during the
school year, reimbursement may be claimed for snacks served to that student during the remainder of the
school year. Reimbursement may also be claimed for individuals, regardless of age, who are determined
by the State Agency to be mentally or physically disabled.
After-school programs operated by a school at a site in which at least 50 percent of the enrolled children
(based on the previous October site data) are certified eligible for free or reduced-price meals or are located
in the attendance area of a school site which has at least 50 percent of its enrollment eligible for free or
reduced-price meals must serve snacks free to all children at the site. The school then receives reimbursement
at the free rate. Sites which are not in areas served by a site in which at least 50 percent of the enrolled
children are certified eligible for free or reduced-price meals must count meals and claim reimbursement by
type (free, reduced-price, and full-price) and must have documentation of eligibility for all meals served
free or at a reduced price. Under no circumstances may a site charge children for snacks claimed at the free
reimbursement rate. Charges for reduced-price snacks may not exceed 15 cents, as stipulated in
7 CFR § 210.9(c)(4). The eClaims system will automatically display the ASSP claim for reimbursement for
any SFA approved.
D. Times of Operation
This change in the law applies ONLY to programs that provide care for children after their school day has
ended. Under no circumstances may snacks be reimbursed in programs operated before or during the
child’s school day except when a school site is implementing an expanded learning time program.* (Reference
USDA Policy Memo SP-04-2011.) Sites MUST be in session during the day for an after-school snack to be
served. If a school participates in the NSLP during the school year, the site does not necessarily need to
be participating in the NSLP during summer school or fall, spring, or winter breaks to be able to claim
snacks served in an ASSP. Sites are not eligible to receive reimbursement under this provision for snacks
on weekends or holidays, including vacation periods, with one exception: if school, which is an integral
part of the curriculum or an extension of the local educational program, is in session, snacks may be served
at the end of the school day; i.e., Saturday school is in session to make up for days missed because of
inclement weather. Refer to USDA Policy Memo 2000-CN-04.
However, a child’s eligibility is based on when his or her scheduled school day ends and not on whether
or not the site continues in session. For example, if a kindergarten program ends at noon but the children
remain in school under a care program, snacks served to these children may be reimbursed under this
provision. The same would be true for older children enrolled in sites that have split sessions. If children
enrolled in the early session remain on campus to participate in an approved after-school care program,
they may receive reimbursable snacks even though the site continues to operate a later academic session.
* The ASSP was established to support afternoon programs with educational and enrichment activities
for children in the late afternoon or evening when they might otherwise be unsupervised and engage
in risky behaviors. USDA regulations define after-school care programs as those providing organized
care to enrolled school-age children after school hours for the purpose of care and supervision of
children (7 CFR 210.2 and 226.17A[b]). Recently, educational programs aimed at serving at-risk
children have evolved to include schools operating expanded learning times longer than the traditional
school day. Expanded learning time is a common term used in the educational area to describe
schools or school districts that add significantly more school time for academic and enrichment
opportunities to improve student achievement.
Therefore, a school operating longer than the traditional school day may be eligible for after-school
snack reimbursement through NSLP, provided that it operates a school day that is at least one hour
longer than the minimum number of school day hours required for the comparable grade levels by the
local educational agency in which the school is located.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 7
E. Content of Snacks
Snacks served under this provision must meet the meal pattern for snacks set forth in 7 CFR § 210.10(a)(ii)
and § 210.10(n). Both snack components in the quantities required must be served to each student.
Snacks cannot be taken off-site for consumption. (Reference 7 CFR §210.7[d].) Portions for children
aged 13 through 18 shall be not less than the portions stipulated for children aged 6 through 12. In fact, it
is recommended that sites offer larger portions for older children (aged 13 through 18), based on their
greater food energy requirements. This means that Offer versus Serve is not an allowable option.
These components and quantities are required even if a site has implemented the Nutrient Standard Menu
Planning (NSMP) or Assisted Nutrient Standard Menu Planning (ANSMP) options. Minimum meal pattern
requirements can be found on page 8.
F. Record Keeping
It is the intention of the law to keep any record-keeping burden to the minimum necessary to ensure that
federal reimbursement is properly paid. At a minimum, SFAs participating under this provision must
maintain the following records for the time periods required in 7 CFR §210.23(c):
1. Documentation that the site is located in an area served by a site in which at least 50 percent of the
enrolled students are certified eligible for free or reduced-price meals (if all snacks are claimed free).
2. Documentation of free and reduced-price eligibility for all children for whom free and reduced-price
snacks are claimed (for all other sites).
3. Documentation of an individual child’s attendance/participation on a daily basis.
a. For school sites that must claim categorical counts (sites that are less than 50 percent free and
reduced-price):
(1) The snack attendance/meal count record must show each child in attendance and whether a
meal was served. Refer to page 9 for a copy of the form.
(2) Each child in attendance that was served a meal must then be placed in the proper category.
Refer to page 10 for a copy of the form.
b. For school sites that are not required to claim categorical counts (sites that are more than 50 percent
free and reduced-price): The record must indicate when a child in attendance received a meal.
Refer to page 9 for a copy of the form.
4. Food production records indicating components and quantities of food prepared. Refer to page 11
for a copy of the form.
5. On-Site Reviews: Each after-school site must be reviewed for compliance with counting and claiming
procedures and the snack meal pattern by the SFA. The SFA must review each NEW site two times per
year, with the first review conducted during the first four weeks of snack service. After the first year
of operation, the SFA must review each site twice annually. A form has been provided on page 13 for
SFAs to use for this purpose. (Reference 7 CFR §210.9[c][7].)
8 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
SNACK (Choose two of the following components)
Milk1
Milk, fluid 1/2 cup 1/2 cup 1 cup
Vegetables and Fruits2
Vegetable(s), fruit(s), full-strength juice9 1/2 cup 1/2 cup 3/4 cup
Bread and Bread Alternates3
Enriched or whole-grain bread 1/2 serving 1/2 serving 1 serving
Cereal (cold, dry) 1/4 cup or 1/3 oz4 1/3 cup or 1/2 oz4 3/4 cup or 1 oz4
Cooked pasta or noodle products 1/4 cup 1/4 cup 1/2 cup
Cooked cereal or cereal grains 1/4 cup 1/4 cup 1/2 cup
Nonsweet snack products11 1/2 serving 1/2 serving 1 serving
Meat and Meat Alternates5
Lean meat, poultry, or fish6 1/2 oz 1/2 oz 1 oz
Cheese 1/2 oz 1/2 oz 1 oz
Eggs 1/2 egg 1/2 egg 1/2 egg
Cooked dry beans or peas7 1/8 cup 1/8 cup 1/4 cup
Peanut butter, soynut butter, or other nut or seed butters 1 Tbsp 1 Tbsp 2 Tbsp
Peanuts, soynuts, or tree nuts or seeds8 1/2 oz 1/2 oz 1 oz
Yogurt, plain or flavored, unsweetened or sweetened10 2 oz or 1/4 cup 2 oz or 1/4 cup 4 oz or 1/2 cup
Children
Aged 1 Through
2 Years
Children
Aged 3 Through
5 Years
Children
Aged 6 Through
18 Years
1 Must offer pasteurized milk in at least two choices of fat content from the following: fat-free milk, unflavored or
flavored; lowfat (1%) milk, unflavored; fat-free or lowfat lactose-reduced milk; fat-free or lowfat lactose-free milk;
fat-free or lowfat buttermilk; and fat-free or lowfat acidified milk. Such products must be pasteurized fluid milk that
meets state and local standards.
2 Or an equivalent quantity of any combination of vegetable(s), fruit(s), and juice.
3 Or an equivalent quantity of any combination of bread/bread alternate.
4 Either volume (cup) or weight (ounce), whichever is less.
5 Or an equivalent quantity of any combination of meat/meat alternate.
6 Cooked lean meat without bone.
7 May be used as the meat alternate or as part of the vegetable/fruit component, but not as both components in the
same meal.
8 Tree nuts and seeds that may be used as meat alternates are listed in program guidance.
9 Juice may not be served when milk is served as the only other component.
10 Applies to commercially prepared yogurt, lowfat yogurt, and nonfat yogurt. It does not apply to nonstandardized
yogurt products such as frozen yogurt, yogurt-flavored products, yogurt bars, or yogurt-covered fruit or nuts.
Commercial flavorings may be added, such as fruit, fruit juice, nuts, seeds, or granola, but they shall not be
credited toward meeting the second food component requirement in the supplement.
11 Includes such products as hard pretzels or chips made of whole-grain or enriched meal or flour.
MINIMUM MEAL REQUIREMENTS FOR SNACKS
UNDER THE NATIONAL SCHOOL LUNCH PROGRAM (NSLP)
When the meal pattern is properly used, the meals will include foods which supply needed nutrients and energy. The
nutritional goal for meals and snacks is to furnish high-quality meals to all students in accordance with the
Recommended Daily Dietary Allowance of the National Research Council/National Academy of Sciences.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 9
INSTRUCTIONS
1. Record the name of the After-School Snack Program site.
2. Record the month and year.
3. List each child’s first and last names.
4. Daily, check each child who is in attendance.
5. As a reimbursable snack is served to each child, circle the check mark indicated for attendance. At the end of the month, obtain the point-of-service count by counting all
checks that are circled.
Name 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
SNACK ATTENDANCE/MEAL COUNT RECORD
Name of After-School Snack Site: Month: Year:
10 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
AFTER-SCHOOL SNACK PROGRAM
MEAL COUNT WORKSHEET
Name of After-School Snack Site:
Month: Year:
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
TOTALS
DATE
FREE REDUCED-PRICE
FULL-PRICE TOTAL
50%
ELIGIBLE
SITES ONLY
CATEGORICAL COUNT SITES ONLY
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 11
AFTER-SCHOOL SNACK
FOOD PRODUCTION RECORD
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
Qty. Served:
Meat/Meat
Alternate
Snack Menu Qty. Served:
Bread/Cereal
Qty. Served:
Fruit/Veg./Juice
Qty. Served:
Milk
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
12 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
AFTER-SCHOOL SNACK
FOOD PRODUCTION RECORD
INSTRUCTIONS
1. The snack menus are recorded on the menu-planning pages under the Menu column.
2. Each meal component being credited must be recorded in the proper component box.
3. Total quantities of food served from each meal component must be recorded. Remember to indicate package size,
poundage, ounces, fresh, frozen, etc.
4. Remember to always record the following daily:
a. Date, including year
b. Total number of children served
c. Number of children served in each age group
d. Number of adults served
e. Number of contract snacks served
5. The menu-planning pages must be kept on site at all times.
6. Maintain the menu-planning pages on a fiscal year basis beginning July 1 and ending on June 30 of each fiscal year.
7. Keep the menu-planning pages on file with all other CNP records at the close of the fiscal year.
Example:
Qty. Served:
Meat/Meat
Alternate
Snack Menu Qty. Served:
Bread/Cereal
Qty. Served:
Fruit/Veg./Juice
Qty. Served:
Milk
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
DATE:
Total children served:
Number of children served:
1-2:
3-5:
6-18:
Adults:
Contract:
Fresh strawberries
& bananas
Milk
Assorted cold cereals
Milk
44 1-oz boxes of
assorted cereals
8—1/2# of
strawberries
8—1/2# of bananas
2/16/12
41
41
00
2/17/12
44
44
00
39 1/2-pints of
fat-free chocolate
milk
2 1/2-pints of 1%
white milk
43 1/2-pints of
1% white milk
1 1/2-pint of fat-free
chocolate milk
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 13
AFTER-SCHOOL SNACK PROGRAM (ASSP)
ON-SITE REVIEW
SITE: YES NO N/A*
A. ATTENDANCE
1. Is an attendance list used in the meal count system?
2. Is attendance list updated as needed (at least daily)?
3. Is there an educational or enrichment component offered?
E. MEAL COUNT SYSTEM
1. Does the meal count system produce an accurate count of reimbursable snacks
(free, reduced-price, full-price) served to eligible children?
a. If students are charged for snacks, do the collection procedures in use
match the approved collection procedures in the Policy Statement?
b. If the meal count is not taken at the time the snack is served, does the
school have a system to account for reimbursable snacks?
2. Does the meal count system prevent overt identification?
a. Is the medium of exchange made available to all students at the same
location?
b. Does the medium of exchange used prohibit codes for identifying students
as free, reduced-price, or full-price?
FOR SITES NOT MEETING 50 PERCENT ELIGIBILITY ONLY
D. APPLICATION APPROVAL
1. Are applications approved at the school?
Responsible party:
2. Are applications on file correctly approved?
3. Do names on the attendance list match approved applications on file?
4. Are snacks made available free or at a reduced price to all students who are
determined by the school food authority (SFA) to be eligible for such benefits?
YES NO N/A*
Comments (List any problems that need corrective action):
Signature of Reviewer: Date:
*Not Applicable
B. MEAL COUNT RECORDING AND EDIT CHECKS
1. Are snacks served after the students’ school day has ended?
2. Are all snacks consumed in their entirety on-site?
3. Does the site use proper procedures for counting and recording snacks?
4. For any day during the review month, does the number of snacks claimed
exceed the daily attendance?
5. Does the site have proper procedures to manage and safeguard cash
(reconciliation, extra item sales, adult meals, etc.)?
C. MINIMUM MEAL PATTERN REQUIREMENTS
1. Do all snacks served include the required components (two of the four)?
2. Do all snacks served meet the quantity requirements for the age groups served?
3. Do all students receive both the required components in the correct quantities
before the snacks are claimed?
4. Are adequate food production records being maintained?
5. Are at least two choices of fat content in the pasteurized milk offered from the
following?
• Unflavored or flavored fat-free • Cultured buttermilk lowfat (1%) or fat-free
• Unflavored lowfat (1%) • Acidified milk lowfat (1%) or fat-free
• Lactose-reduced lowfat (1%) or • Lactose-free lowfat (1%) or fat-free
fat-free
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Oklahoma State Department of Education School Food Service Compliance Document, July 2011 15
II. CHARTER SCHOOL PROCEDURES FOR CHILD NUTRITION PROGRAMS
A. A charter school is treated as its own local education agency (LEA) or school district for all Federal
Programs, including Child Nutrition.
1. The charter school is assigned a county/district code. The charter school completes its own
application/agreement/policy statement with the CNP Section of the State Agency.
2. The charter school is responsible for the distribution and collection of the free/reduced-price
applications, the approval of these applications, Direct Certification activity, and any issuance of
benefits for the charter school students.
3. The charter school is responsible for its own meals (self-operating) or can contract for its
meal services:
a. Every meal claimed for reimbursement must meet minimum meal pattern requirements.
b. A charter school may contract its meals with a school district participating in the National School
Lunch Program (NSLP)/School Breakfast Program (SBP) that is not under a food service
management company (FSMC) contract—in this case, a simple contract (National School Lunch/
School Breakfast Programs Agreement to Furnish Food Service) (see page 177) can be used.
The charter school is not obligated to bid this service competitively as long as the service is
provided by a school district that is self-operating.
c. A charter school is not allowed to contract its meals/food services with a school district that is
NOT participating in the NSLP/SBP unless these services are bid competitively. Further, a charter
school is not allowed to contract its meals/food services with a school district that IS participating
in the NSLP/SBP that IS under an FSMC contract. This would cause a substantive change to the
FSMC contract that would require the school district to have to rebid its FSMC contract.
d. A charter school may contract its food service operations with an FSMC—in this case, the Food
Service Management Company (FSMC) Request for Proposal (RFP)/Contract prototype must
be used.
e. A charter school may contract for food delivery only (not preparation) with an outside entity—in
this case, the National School Lunch/School Breakfast Programs Agreements to Furnish Food
Service may be used. This service must be procured under federal procurement regulations.
4. The charter school will collect all of its own meal counts and eligible counts each month to report on
its own claim for reimbursement. The money from its claim will be deposited into whatever bank
account the charter school has set up with the State Department of Education.
a. Charters sponsored by a school district will have its money deposited in the charter school
account.
b. Charters sponsored by a university will have its money deposited into the university account.
5. The charter school is responsible for establishing and implementing the following policies and plans:
a. Wellness Policy
b. Hazard Analysis Critical Control Point (HACCP) Plan
c. Procurement Plan
6. The charter school is responsible for the submission all CNP reports:
a. Claim for reimbursement
b. Food safety inspection report
c. Low-income report
d. Verification report
7. Economically disadvantaged data for the charter school LEA is collected on the claim for reimbursement
and the Low-Income Report. This data is used in the calculation of State Aid, Title I, e-Rate, and grant
formulas.
16 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
B. Additional Two-Cent Reimbursement
An LEA, in the second preceding year, that served 60 percent of its lunches to students who qualified for
free or reduced-price meals will automatically receive an additional $.02 for each lunch claimed. This
means that a new charter LEA must be in its third year of participation before the additional reimbursement
is paid.
C. Severe Need Breakfast (SNB)
Each site under a charter LEA MAY receive additional reimbursement for breakfast. A site, in the second
preceding year, that served 40 percent of its lunches to students who qualified for free or reduced-price
meals will receive additional funding for each breakfast claimed. This means a new charter school site
must be in its third year of participation before it would qualify for the additional breakfast funding.
D. USDA-Donated Foods
Once a charter school LEA has been approved to participate in CNP for a full school year, the meal counts
from that LEA will be sent to the Department of Human Services to determine the USDA-Donated Foods
allocation for the FOLLOWING school year. This means that the charter LEA will participate in CNP for
one year before USDA-Donated Foods are received. Once the charter school begins to receive USDA-Donated
Foods, if it is contracting its meals with another school district, the charter school should allow
the district to have the USDA-Donated Foods and the rate per LUNCH that the charter school is paying
the district should be reduced by the USDA-Donated Foods rate. (The USDA-Donated Foods rate for the
2012 school year is $. per lunch.)
E. Procurement
Because CNP funds are federal, charter schools must follow Federal Procurement Regulations when
purchasing anything acquired with CNP funds.
F. About the CNP Section of the SDE
1. CNP staff
(a) State is divided into 12 territories.
(b) Each territory has assigned to it a CNP consultant.
(c) CNP consultants are available for technical assistance at any time requested.
2. Review cycle—CNP staff conducts two separate reviews of each LEA
(a) Coordinated Review Effort (CRE) focuses on application approval, benefit issuance, verification,
meal counting and -claiming (ABVM), and meal pattern requirements.
(b) School Meals Initiative (SMI) focuses on the Nutrient Standards of the meals served.
(c) Five-year review cycle (current cycle ends June 30, 2013).
G. Record Maintenance
1. All records pertaining to CNP must be maintained for a period of three years after the fiscal year has
ended.
2. Records for School Year 2012 must be maintained until June 30, 2015.
3. Records involved in a state or federal review or audit must be maintained until the review/audit issues
are resolved.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 17
III. CIVIL RIGHTS
United States Department of Agriculture (USDA)/Food and Nutrition Service (FNS) Instruction 113-1 (dated
11/8/05) delineates the civil rights requirements for participants in Child Nutrition Programs (CNP). The
following is required at the local school food authority (SFA) level.
A. Public Information Responsibilities
1. Ensure that all forms of communication and printed program information that are disseminated
include the following nondiscrimination statement.
In accordance with federal law and United States Department of Agriculture (USDA)
policy, this institution is prohibited from discriminating on the basis of race, color, national
origin, sex, age, or disability.
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)
632-9992 (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). USDA is an equal opportunity provider and employer.
If material is too small to permit the full statement, this institution is an equal opportunity
provider and employer will be included at a minimum in print size no smaller than the text.
2. Inform parents or guardians of students in sites participating in the CNP, as well as local minority
and grassroots organizations, of the availability of program benefits and services, the nondiscrimination
policy, and all significant changes in existing requirements that pertain to program eligibility and
benefits.
3. Display in a prominent place, where meals are served, the nondiscrimination poster developed by
USDA. The poster is required to measure 11 inches x 17 inches.
4. Make available to the public, and to participants and potential participants upon request, information
about program requirements and the procedures for filing a complaint in English and/or in the
appropriate translation to non-English-speaking persons.
B. Data Collection
1. Develop a method for collection of data. Methods include determination of the information by a
school official through observation, personal knowledge, or voluntary self-identification by an
applicant on the Application for Free and Reduced-Price Meals or the Application for Free Milk
forms.
2. Maintain information on file for three years.
3. Establish procedures to ensure that the information is made available only to authorized state and
federal personnel during reviews or as a part of federal- or state-approved surveys.
a. The nondiscrimination statement must be included on all of the forms that sites send to parents.
The public release will satisfy the provisions of Item A2 (above).
b. A Civil Rights Compliance Checklist is included on page 19. This checklist, which is to be
completed by each school site by October 31 of each year and maintained by each SFA, furnishes
an overview of the requirements.
18 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
C. Civil Rights Complaints
1. All written or verbal complaints alleging discrimination on the basis of race, color, national origin,
sex, age, or disability shall be processed within 90 days upon receipt in the manner prescribed by this
instruction.
2. The Office of Minority Affairs (OMA) has been delegated the authority to determine the manner in
which all civil rights complaints, investigations, preliminary inquiries, and compliance reviews are
to be handled. Regardless of the administrative or operational level of the CNP where a civil rights
complaint is filed, it must be forwarded in accordance with Item D2 (below) to the Director, Civil
Rights (CR) Division, for submission to the OMA. The OMA will prepare and issue letters of
acknowledgment to the complainant(s).
3. A preliminary inquiry or an investigation will be conducted on all valid complaints to substantiate or
refute the allegations.
D. Procedure for Filing Complaints of Discrimination
1. Right to File a Complaint: Any person alleging discrimination based on race, color, national origin,
sex, age, or disability has a right to file a complaint within 180 days of the alleged discriminatory
action. Under special circumstances, this time limit may be extended by OMA.
2. Acceptance: All complaints must be in writing and signed by the complainant. All complaints shall be
accepted by the SFA, Oklahoma State Department of Education (the State Agency), or Food and
Nutrition Service Regional Office (FNSRO). The complaints will be forwarded to the FNSRO (as
applicable), and then forwarded at once to the CR Division. It is necessary that the information be
sufficient to determine the identity of the agency or individual toward which the complaint is directed
and to indicate the possibility of a violation. Please see a Civil Rights Complaint Form on page 21. The
person who has allegedly been discriminated against must complete and sign a Complainant Consent/
Release Form found on page 23, this form must accompany the Civil Rights Complaint Form.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 19
1. Does the letter to households include:
a. The required nondiscrimination statement?
b. Where a complaint may be filed?
2. Is a USDA/Food and Nutrition Service (FNS)-approved poster displayed in a
prominent place and visible to recipients?
3. Is the correct nondiscrimination statement included on appropriate program
materials?
4. Has the school food authority (SFA) sent out a public release to community/
grassroots organizations?
5. Are foreign language translations available when a significant number of persons
speaking only a foreign language are in the population?
6. Are procedures established to receive complaints alleging discrimination?
a. Have there been any written or verbal complaints alleging discrimination?
b. If YES, have these complaints been reported to the State Department of
Education (the State Agency)?
7. Do admission procedures used restrict enrollment by minority persons?
8. Are incorrectly denied Applications for Free and Reduced-Price Meals
disproportionately composed of minority applications?
9. Are disabled students provided program benefits as prescribed by regulations
(including special dietary needs), as appropriate?
*Not Applicable
CIVIL RIGHTS COMPLIANCE CHECKLIST
SCHOOL YEAR ____________
United States Department of Agriculture (USDA) regulations outline each site’s responsibility with regard to civil
rights compliance in the Child Nutrition Programs (CNP). The following checklist furnishes a quick overview of
requirements.
YES NO N/A*
This form should be duplicated and completed each year by each site within the SFA. The completed form will be
reviewed during the CRE.
Please complete by October 31 of each year, and retain in your CNP files.
Enrollment
Number
Approved
for Free and
Reduced-Price
Meals/Free Milk
Number
Denied
• Hispanic or Latino
Ethnicity:
• Not Hispanic or Latino
• Native Hawaiian or Other Pacific Islander
• Asian
• Black or African American
• White
TOTAL STUDENTS BY RACE
• American Indian or Alaska Native
Race:
TOTAL STUDENTS BY ETHNICITY
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Oklahoma State Department of Education School Food Service Compliance Document, July 2011 21
Civil Rights Complaint Form
Name:
Address:
Street City State Zip Code
Telephone Number: Home: ( ) Work: ( )
Name:
Address:
Street City State Zip Code
Telephone Number: Home: ( ) Work: ( )
Name:
Any individual if known:
Address:
Street City State Zip Code
Telephone Number: Home: ( ) Work: ( )
4. Nonemployment: Does your complaint concern discrimination in the delivery of services or in other
discriminatory actions in the United States Department of Agriculture, State Agency, or the School
Food Authority in its treatment of you or others? If so, please indicate below the base(s) on which you
believe these discriminatory actions were taken (e.g., “Race: African American” or “Sex: Female”).
_________ Race/Color:
_________ National Origin:
_________ Sex:
_________ Religion:
_________ Age:
_________ Disability:
Employment: Does your complaint concern discrimination in employment by the United States
Department of Agriculture, State Agency, or School Food Authority? If so, please indicate the base(s)
1. State your name and address:
2. Person(s) discriminated against, if different from above:
3. Agency and department or program that discriminated:
22 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
on which you believe these discriminatory actions were taken (e.g., “Race: African American” or “Sex:
Female”).
_________ Race/Color:
_________ National Origin:
_________ Sex:
_________ Religion:
_________ Age:
_________ Disability:
5. To your best recollection, on what date(s) did the alleged discrimination take place?
Earliest date of discrimination:
Most recent date of discriination:
6. Please explain as clearly as possible what happened, why you believe it happened, and how you were
discriminated against. Indicate who was involved. Be sure to include how other persons were treated
differently from you. (Please use additional sheets if necessary and attach a copy of written materials
pertaining to your case.)
______________________________________________________________________________
____________________________________________________________________________________________________________________________________________________________
_______________________________________________________________________________________
__________________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
7. Your complaint cannot be accepted if it has not been signed. Please sign and date this complaint form
below.
___________________________________________ ____________________
Signature Date
Please feel free to add additional sheets to explain the present situation to us.
Your consent is needed to disclose your name, if necessary, in the course of any investigation. Therefore,
please sign the Consent Form. (If you are filing this complaint for a person whom you allege has been
discriminated against, the signed Consent Form needs to be from that person.) Please mail the completed,
signed Discrimination Complaint Form and the signed Consent Form (please make one copy of each for
your records) to:
United States Department of Agriculture
Food & Nutrition Service
Civil Rights Division
3101 Park Center Drive, Room 942
Alexandria, VA 22302
(703) 305-2195
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 23
CIVIL RIGHTS
COMPLAINANT CONSENT/RELEASE FORM
Your Name: ____________________________________________________________________
Address: ______________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
Please read the information below, initial the appropriate space, and sign and date this form on the lines at the
bottom of this form.
I have read the Notice of Investigatory Uses of Personal Information by the USDA, Food and Nutrition
Service (FNS). As a complainant, I understand that in the course of a preliminary inquiry or investigation it
may become necessary for FNS to reveal my identity to persons at the organization or institution under
investigation. I am also aware of the obligations of FNS to honor requests under the Freedom of Information
Act. I understand that it might be necessary for FNS to disclose information, including personally identifying
details, which it has gathered as a part of its preliminary inquiry or investigation of my complaint. In addition,
I understand that as a complainant I am protected by Federal regulations from intimidation or retaliation for
having taken action or participated in action to secure rights protected by nondiscrimination statutes enforced
by the Federal government.
CONSENT GRANTED—I have read and understand the above
information and authorize FNS to reveal my identity to persons at the
organization or institution under investigation and to other Federal agencies
that provide Federal financial assistance to the organization or institution or
also have civil rights compliance oversight responsibilities that cover that
organization or institution. I hereby authorize FNS to received material and
information about me pertinent to the investigation of my complaint. This
release includes, but is not limited to, applications, case files, personal records,
and medical records. I understand that the material and information will be
used for authorized civil rights compliance and enforcement activities. I
further understand that I am not required to authorize this release, and I do
so voluntarily.
CONSENT DENIED—I have read and understand the information and do
not want FNS to reveal my identity to the organization or institution under
investigation, or to review, receive copies of, or discuss material and consent
information about me, pertinent to the investigation of my complaint. I
understand that this is likely to make the investigation of my complaint and
getting all the facts more difficult and, in some cases, impossible, and may
result in the investigation being closed.
CONSENT/RELEASE
_________________
Initial on the line above
if you give consent.
_________________
Initial on the line above
if you deny consent
______________________________________ ___________________
Signature Date
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Oklahoma State Department of Education School Food Service Compliance Document, July 2011 25
IV. ELIGIBILITY DOCUMENTATION FOR MEAL APPLICATION AND
VERIFICATION (NOTE: This section does not pertain to RCCIs with ONLY
residential students.)
A. Submission of Applications for Free and Reduced-Price Meals by All Households
1. The National School Lunch Act (NSLA), which includes snacks, the School Breakfast Program (SBP),
and the Special Milk Program (SMP), requires that school food authorities (SFAs) inform households
of the availability of the program(s) and how a household may apply for free or reduced-price benefits
(7 CFR § 245.5). However, neither the NSLA, the Child Nutrition Act, nor the regulations and guidance
material governing these programs has a requirement that would mandate submission of an Application
for Free and Reduced-Price Meals. While school officials must make families aware of the availability
of free and reduced-price meals and may even request that households apply, school officials may not
require that a household submit an Application for Free and Reduced-Price Meals. A site or SFA
wishing to require income information from all households with enrolled children for purposes other
than child nutrition must secure information through means other than the household’s Application
for Free and Reduced-Price Meals. SFAs that provide households with multiuse applications (i.e.,
those which include both meal program benefits as well as nonfood benefits) must ensure that the
process does not violate the requirements specified herein. A copy of the Letter to Household and
Application for Free and Reduced-Price Meals can be found on pages 61 through 67.
2. It is the household’s responsibility to complete the application. The local education agency (LEA)
may send households an application with the child’s name and the household’s name and address
preprinted on it. No other information required for an eligibility determination may be preprinted.
(Reference Eligibility Manual for School Meals, January 2008, page 12.)
B. Household Applications
Section 105 of the Child Nutrition and WIC Reauthorization Act of 2004 requires SFAs to distribute
household applications rather than individual student applications.
1. SFAs may not request a separate application for each child in the household who attends different
sites within the same district.
2. If a household does submit a separate application for each student in the household, the SFA should:
a. Staple all individual applications pertaining to the same household together.
b. Make sure all information on each application is the same; if so, approve or deny the application
as usual.
c. If the information is different, contact the household to clear up any questions and document
correct information. Once correct information is obtained, approve or deny the application as
usual.
d. Count all individual student applications pertaining to the same household as ONE application
when calculating the number that needs to be verified.
C. Application for Free and Reduced-Price Meals—Refer to page 65 for a prototype application. NOTE: If
an SFA changes the prototype, the changed application must be approved by the Oklahoma State
Department of Education (the State Agency) before the SFA is allowed to use it.
The application and Letter to Household cannot be accepted or processed by an SFA prior to July 1 of
each school year. (Reference Eligibility Manual for School Meals, January 2008, page 8.)
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 26
1. Categorical Applications based on Supplemental Nutrition Assistance Program (SNAP) (formerly Food
Stamp), Temporary Assistance to Needy Families (TANF), and/or Food Distribution Program on
Indian Reservations (FDPIR) Households
The application MUST request that the household provide the following:
a. Names of all household members.
b. A SNAP, TANF, or FDPIR case number for any household member. One case number will qualify
all enrolled students to receive free meal benefits within that household. (Reference USDA
Memo SP-38-2009.)
(1) SNAP:* A valid SNAP number may begin with the letters A, B, C, D, H, J, or T followed by
six to nine digits. All valid numbers MUST be Oklahoma-issued. Some numbers could also
include a dash, followed by two additional numbers.
(2) TANF:* A valid TANF number is recognized by a six- to nine-digit number beginning with
the letter C or H. All valid numbers MUST be Oklahoma-issued. This number could be
followed by a dash with two additional numbers.
(3) FDPIR:* An FDPIR number may appear to be any combination of letters and/or numbers. It
has no identifiable format. NOTE: A number starting with KK should not be considered an
FDPIR number.
* If an application contains a single case number for SNAP, TANF, or FDPIR, all enrolled children listed on the
application must be approved for free meal benefits. Any income information on an application containing a
SINGLE/CORRECT SNAP, TANF, or FDPIR case number should be disregarded. (Reference USDA Memo SP-38-
2009.)
* If there is any doubt of the validity of a case number submitted on an application, the SFA should contact the
appropriate SNAP, TANF, or FDPIR official and document the findings. (This is only for numbers that are not
formatted as Oklahoma numbers.)
c. The signature of an adult household member
2. Categorical Applications Based on Foster Children
Section 102 of the Healthy, Hunger-Free Act of 2010 amends Section 9(b)(12)(A) of the Richard B.
Russell National School Lunch Act (NSLA) to provide categorical eligibility for free meals, without
further application, to any foster child whose care and placement is the responsibility of the state or
who is placed by a court with a caretaker household. In addition, the Act amends Section 9(b)(5) of the
NSLA to allow certification of a foster child for free meals without application if the local education
agency or other CNP institution obtains documentation from an appropriate state or local agency
indicating the status of the child as a foster child whose care and placement is the responsibility of the
state or that the foster child has been placed with a caretaker household by a court. These provisions
were effective October 1, 2010.
It is important to note that these provisions only apply to foster children formally placed by a state
child welfare agency or a court. They do not apply to informal arrangements that may exist outside of
state- or court-based systems.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 27
This change to allow categorical eligibility for free meals for foster children necessitates changes in
the way free and reduced-price applications are handled. Previously, a separate application for free
and reduced-price meals was submitted for a foster child who was considered a household of one.
Now, the foster child is categorically eligible and may be certified without an application. Households
with foster and nonfoster children may choose to include the foster child as a household member, as
well as any personal income earned by the foster child on the same household application that
includes their nonfoster children. This will streamline the application process and may help the foster
family’s nonfoster children qualify for free or reduced-price meals based on household size and
income.
In processing the application, the SFA would certify the foster child for free meals and then make an
eligibility determination for the remainder of the household based on the household’s income (includ-ing
personal income earned by the foster child) or other categorical eligibility information reported on
the application. As before, foster payments received by the family from the placing agency are not
considered income and do not need to be reported. Please note that the presence of a foster child in
the household does NOT convey eligibility for free meals to all children in the household in the
same manner as SNAP, TANF, AND FDPIR participation does.
3. Income Applications
a. The names of all household members, including each child for whom the application is made
b. The amount of gross income received in the prior month by each member and the source of the
income
c. The last four digits of the social security number of the adult household member who signs the
application or an indication that the household member does not have one (Reference USDA
Policy Memo SP-19-2011.)
d. The signature of an adult household member
4. Temporary Income Application
Even though there is a yearlong eligibility, temporary approvals are very important in situations where
households will be experiencing changes in income or household size that would affect children’s
eligibility for free and reduced-price meals or free milk. Therefore, when warranted, school districts are
encouraged to approve households on a temporary basis when their need for assistance appears to
be short-term.
a. A temporary approval may be warranted when the household reports zero income or has a
temporary reduction in income.
(1) The time period for temporary approvals is 45 days.
(2) When a household reports zero income or a temporary reduction in income (such as work
layoff or recovering from a minor injury that temporarily prevents a household member from
working), eligibility must be determined based on the present rate of income rather than on
regular annual income.
28 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
(3) At the end of the temporary approval (45 days), school officials must reevaluate the
household’s situation and should contact the household to determine if the household’s
circumstances have changed.
(4) If the household’s situation at the end of the temporary approval (45 days) remains the same,
the school district may either:
(a) Continue eligibility on a temporary basis and reevaluate the situation at another 45-day
period.
(b) Make the approval valid for the duration of the current school year, which would allow
for carryover of that status into the next school year.
(c) If the household’s situation at the end of the temporary approval (45 days) has changed,
school officials must request that the household file a new application or have the
household update the information on the existing application and initial the changes.
The school district must implement the new status within three operating days. Because
these are temporary approvals that expire at the end of the time period, a notice of
adverse action is not required.
b. Eligible children should receive temporary approval in the following types of economic situations:
• Zero income, for whatever reason (except foster children and institutionalized children)
• Temporary layoffs
• Strikes (voluntary work stoppages)
• Temporary disability
D. Foreign Language Translations
Where a significant number or proportion of the population eligible to be served in the SFA needs information
in a language other than English, SFAs MUST make reasonable efforts, considering the size and concentration
of such population, to send appropriate non-English-language household letters or notices and application
forms to such households. USDA provides copies of these applications, which include the following
languages: Arabic, Cambodian, Chinese (Mandarin), Farsi, French, Greek, Haitian, Hindi, Hmong, Japanese,
Korean, Kurdish, Loatian, Polish, Portuguese, Russian, Samoan, Serbo-Croatian, Somali, Spanish, Sudanese,
Tagalog, Thai, Urdu, and Vietnamese. Log onto www.fns.usda.gov/cnd/FRP/frp.process.htm. Click on
the language desired, and print. (Reference All State Directors’ Memo 2007-CN-10.)
Sites are encouraged to provide households with assistance in completing applications through the use of
personnel proficient in foreign languages.
E. Processing of Applications
1. Free and Reduced-Price Reimbursement
The SFA or school MUST have on file an approved application or a list of directly certified students
showing the name of each student served a meal or milk which meets program requirements.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 29
2. Benefits Prior to Processing: Applications cannot be backdated; they are only effective from the date
they are approved by the SFA.
Before applications are processed for the school year, the SFA may only claim and be reimbursed for
free and reduced-price meals or free milk served to:
a. Children from households with approved applications on file from the previous year.
b. New children in an SFA from households with children who were approved for benefits the
previous year.
c. Transfer Students: Previously approved children who transfer from one district to another, as
long as the receiving site obtains a copy of the prior year’s or current year’s application from the
sending SFA.
3. Carryover Applications (Reference Eligibility Manual for School Meals, January 2008, pages 16-17.)
a. SFAs MUST carry over the eligibility status from the previous year for any child enrolled in the
current school year.
b. Currently enrolled students’ eligibility status from a prior year is only valid for the first 30 operating
days of the school year (beginning with the first day of school in which meals are served and
claimed for reimbursement after July 1). This means that if a site within the district operates a
summer school in which meals are served under NSLP and/or SBP, and the summer school
continues into the month of July, the first day of the 30-day operating period for that particular
site would begin on the first day summer school is in session in July.
c. SFAs CANNOT establish a shorter time frame for carryover applications. (Reference Eligibility
Manual for School Meals, January 2008, page 16.)
d. Once a new application is obtained and approved, the carryover application is no longer valid. If
a new application is not received within the 30-day period, benefits are terminated for the child on
Day 31. A letter of adverse action is not necessary if terminating benefits for this reason. However,
if the eligibility status has changed, the SFA would report the student’s eligibility in both categories
for the month that the new application was approved.
For example: The first 30 days of the new school year ends September 15. A student who
qualified for free meals in the previous school year submits an application for the new school year
on September 10. The school has ten days from receipt of an application to approve or deny and
issue benefits if any apply. The SFA approves the new application at a reduced-price status on
September 11; therefore, the SFA would report this student in the free eligible category from
September 1 through 10 and claim the meals served to him or her accordingly. Effective September
11 through 30, the student would be reported in the reduced-price eligibility status and meals
served to him or her during that time would be claimed as reduced-price. Beginning October 1,
this student would be reported and claimed in the reduced-price category only.
e. If students listed on the household application attend different sites and each site begins school
on a different date, each child’s benefit on the household application would then expire on a
different date.
30 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
4. Application Processing Time Frame
Applications should be reviewed and an eligibility determination must be made within ten operating
days of the receipt of the application. (Reference Eligibility Manual for School Meals, January 2008,
page 16.)
NOTE: The SFA must not delay approval of the application if the household fails to provide only
information that is not required.
Example: If the household does not provide its address, approval must not be delayed.
5. Eligibility Criteria
a. For a child to be eligible for free or reduced-price benefits, the child MUST have been directly
certified or the household MUST have submitted a complete application and be either categorically
eligible or income-eligible. This includes students attending public school during the day, but
who reside in an institution.
(1) Complete Application—An application that contains all required information for making an
eligibility determination.
(2) Categorical Eligibility—If SNAP, TANF, or FDPIR benefits are received for a household, all
children in that household would be eligible for free meals or milk when the household
submits a complete application. NOTE: Foster children are automatically eligible for free
meal benefits.
(3) Income Eligibility—Children from a household that submits a complete application, and the
sum of the reported income for the household is at or below the income-eligibility guidelines,
are eligible for either free or reduced-price benefits, as applicable.
b. The determining official MUST review each incoming application to ensure that the household
has submitted a complete application. If the application is complete, the official MUST then
determine whether the household is categorically eligible or income-eligible for benefits.
c. Applications for households that are not categorically eligible or income-eligible cannot be
approved for benefits.
d. United States citizenship is NOT a condition of eligibility for free or reduced-price benefits. SFAs
MUST apply the same eligibility criteria for citizens and noncitizens.
6. Computation of Current Income
a. Each household MUST provide the amount of gross income. Income MUST be identified with
the individual who received it and the source of the income (such as wages or welfare). It is the
responsibility of the determining official to compute the household’s total current income and
compare the total amount to the income-eligibility guidelines. A copy of the Income-Eligibility
Guidelines (IEG) is on page 69.
b. Income received at different intervals: Households may have income from different sources
which are paid on different schedules. For example, the household may receive paychecks on a
weekly basis and child support on a monthly basis. This section explains when conversion of
income is required and how conversion is done.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 31
(1) No conversion is required if there is only one source of income; or if all sources are received
in the same frequency, no conversion is required. The SFA would total all sources and
compare them to the appropriate IEG. For example, if a household of three reported receiving
a monthly social security check and monthly child support, those amounts would be added
together and the result compared to the monthly IEG for a household of three.
(2) Conversion is required if there are multiple income sources with more than one frequency;
the SFA must annualize all income by multiplying:
* Weekly income by 52.
* Every other week income by 26.
* Twice a month income by 24.
* Monthly income by 12.
NOTE: SFAs CANNOT use conversion factors such as 4.33 to convert weekly income or
2.15 to convert biweekly income to monthly amounts. Software used must reflect this policy.
(Reference Eligibility Manual, January 2008, page 19.)
(3) Do not round the values resulting from each conversion.
(4) Add all of the unrounded, converted values, and compare the unrounded total to the
appropriate IEG for annual income for the household size.
NOTE: In situations where income is reported weekly, every two weeks, monthly, or twice a
month, and the software has no provision for dealing with dollars and cents, calculations should
be done manually to arrive at the most accurate annual income. (Reference USDA Policy Memo
2001-CN-8.) All computerized software must include both the dollar amount and the cent amount,
unless the cents are computed manually.
7. Application Approval or Denial
a. Households that submit an incomplete application cannot be approved. If any REQUIRED
information is missing, the information MUST be obtained before an eligibility determination can
be made.
b. To get the required information, the school may return the application to the household or
contact the household either in person, by phone, or in writing. The determining official must
document the details of the contact and date and initial the entry. Applications missing the
signature of an adult household member MUST be returned for signature.
c. Every reasonable effort should be made to obtain the missing information prior to denying the
application.
d. If there are any inconsistencies or questions concerning the required eligibility information
provided, the household’s application MUST be denied unless the inconsistencies or questions
are resolved. For instance, if it is unclear whether the household provided weekly or monthly
income, this issue MUST be resolved before an eligibility determination can be made. The official
may contact the household prior to denial, document the details of the contact, and date and
initial the entry.
32 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
8. Homeless, Migrant, Runaway Children (Reference All State Directors’ Memos 2002-SP-13, 2004-CN-08,
2004-CN-10, 2004-CN-12, 2005-CN-02.)
a. Documentation of free meal eligibility:
Rather than an approved Application for Free and Reduced-Price Meals, site officials must accept
documentation from the local educational liaison/coordinator or a director of a shelter where the
child resides to establish free meal benefits. Documentation to substantiate free meal eligibility
must consist of the child’s name or a list of names, effective date(s), and the signature of the local
educational liaison/coordinator or the director of the shelter.
To implement these procedures, school officials must work closely with the educational liaison/
coordinator or director of a shelter to ensure that the child is provided free meal benefits as soon
as possible.
Exception: Because of delays in receiving documentation from appropriate agencies or officials,
a school official may submit an application on behalf of a child that he or she knows to be
categorically eligible due to his or her status as a migrant, homeless, or runaway child. These
applications must be done in accordance with the temporary approval procedures.
Once the documentation is received, that information must be noted on the application and the
child’s eligibility status is effective for the remainder of the school year and also would carry over
for up to 30 operating days in the next school year. If no documentation is received to confirm the
child’s status as a migrant, homeless, or runaway child, the child’s benefits are terminated and a
new application must be filed, either by a school official or by the child’s parent or guardian.
(Reference Eligibility Manual for School Meals, June 2008, page 23.)
b. Homeless, migrant, runaway children residing with another household:
A child or family may temporarily reside with another household and still be considered homeless
under the definition of homeless in the McKinney-Vento Homeless Assistance Act. In these
cases, the household size and income of the host family is NOT taken into consideration in
determining the free meal eligibility for the child designated by the local educational agency
liaison/coordinator.
Additionally, when a host family applies for free or reduced-price meals for their own children, the
host family may include the homeless/migrant family or runaway children as household members
if the host family provides financial support to the homeless/migrant family or runaway children,
such as shelter, utilities, clothing, or food. In such cases, the host family must also include any
income received by the homeless/migrant family or runaway children. Site officials must determine
eligibility for the host family in the traditional manner. However, free meal eligibility for the
homeless/migrant/runaway child is based on the documentation provided by the local education
liaison/coordinator, even when the child is included on the host family’s Application for Free and
Reduced-Price Meals.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 33
If the host family meets the free or reduced-price meal eligibility criteria, school officials should
provide the host family with approval for free or reduced-price meal benefits, as appropriate.
c. Continuing certification:
Public Law 108-265 also amended the Richard B. Russell National School Lunch Act to establish
that, once a homeless/migrant or runaway child is certified as eligible to receive free meals,
eligibility remains effective for the remainder of the school year. Further, SFAs are allowed to
continue the child’s eligibility from the previous year for 30 operating days into the subsequent
school year or until a new eligibility determination is made. This determination must be reconfirmed
with the liaison each school year.
9. Households That Fail to Apply
a. School officials may complete an application for a student known to be eligible if the household
fails to apply. When exercising this option, the school official MUST complete an application on
behalf of the student based on his or her knowledge of household-size and income information.
The source of the information MUST be noted on the application. Names of household members
and the social security number and signature of an adult household member need not be secured.
These applications should be excluded from verification. However, the household MUST be
notified that the student has been certified and is receiving free meal benefits.
b. This option is intended for LIMITED use in INDIVIDUAL situations and must not be used to
make eligibility determinations for categories or groups of students. This option IS NOT
INTENDED to be used for households who qualified in the previous year but for some reason
have failed to apply in the current school year.
10. Notice to Households of Approval/Denial of Benefits
a. All households MUST be notified of their eligibility status.
b. Households DENIED benefits or approved for benefits through Direct Certification MUST be
given written notification of the denial or approval. A copy of Notice to Households of Approval/
Denial of Benefits is found on page 71. The notification MUST advise the household of:
(1) The reason for the denial of benefits.
(2) The right to appeal.
(3) Instructions on how to appeal.
(4) A statement that households may reapply for free or reduced-price benefits at any time
during the school year.
34 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
c. Duration of free and reduced-price eligibility determination.
(1) The Child Nutrition and WIC Reauthorization Act of 2004 states that once a household is
approved for free and reduced-price benefits, the household will remain eligible for those
benefits for the remainder of the school year plus a maximum of 30 operating days in the
subsequent school year. Also, the family is no longer required to report income increases;
loss of SNAP, TANF, or FDPIR eligibility; or family-size reductions. (Reference USDA
Policy Memos 2004-CN-07, 2004-CN-09, 2004-SP-02, and 2004-SP-03.)
(2) There are four exceptions in which the duration of an application would not last the entire
school year.
(a) Application error: The SFA finds that it made an error in initial approval.
(b) Verification: Through the verification process, documentation does not support initial
approval.
(c) Temporary Income Application: Family has been approved based on temporary income,
which is temporary for the first 45 days.
(d) Family refuses benefits: Family notifies SFA to decline any meal benefit.
(3) If a family notifies the SFA later in the year which would result in benefits less than initially
approved at the beginning of the school year (e.g., from free to reduced-price or full-price),
the family MUST be given the option to continue with the benefits approved at the beginning
of the year or choose the reduced benefits. If the family chooses the reduced benefits, the
SFA must provide a notice of adverse action. However, if a family notifies the SFA later in the
year which qualifies them for increased benefits (e.g., from reduced-price to free), the increase
in benefits must be provided. (Reference Eligibility Manual for School Meals, June 2008,
page 23.)
11. Record Keeping
a. All free and reduced-price applications, including applications from households denied benefits
and inactive applications, MUST be kept on file for a minimum of three years after the final claim
is submitted for the fiscal year to which they pertain, and they MUST be readily retrievable by
school site. Files MUST be kept longer if they are required by an audit. If audit findings have not
been resolved, the applications MUST be maintained as long as required for resolution of the
issues raised by the audit.
NOTE: Provision 2 and Provision 3 schools must maintain base year applications for as long as
the schools are participating in Provision 2 or Provision 3.
b. For applications from households approved for benefits, the determining official must indicate
the date each application is approved and the level of benefit for which each child is approved.
The determining official must also sign or initial the application.
c. For applications from households denied benefits, the determining official MUST identify and
retain on file the reasons for the denial. Records should also include the date of the denial, the
date the denial notice is sent, and the name of the determining official. These may be noted
directly on the application.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 35
d. If there are changes in application status (i.e., approval errors, verification, parental request, etc.),
determining officials should note the change and the date of the change on the application and
on any rosters used. Thorough annotation includes:
(1) The date the change was reported.
(2) Why the change was made.
(3) Who called and reported the change.
(4) The initials of the person making the change.
e. When a child transfers to another site within the SFA or transfers to another district within the
state, a copy of the application MUST be retained at both the sending and receiving sites and the
date of the transfer noted, unless applications are filed centrally. Current applications MUST be
on file, and there MUST be records to support transfers of students in and out of the site.
(Reference Eligibility Manual, January 2008, page 24.)
12. Computerized Application Approval (Reference USDA Policy Memo 2001-SP-14.)
a. Any computerized approval process:
A signature of approval is not required on each application if the approval process is computerized.
A list of the children approved for free or reduced-price meals needs to be printed, signed, and
dated to indicate approval of the applications. If changes are made, a new roster should be
printed, signed, and dated at least monthly.
b. Scanner system:
(1) The SFA is assured that the scanner system is accurately and reliably capturing the
Application for Free and Reduced-Price Meals information. It must be capturing both the
dollar and cent amounts reported by the household unless computed manually. (Reference
USDA Policy Memo 2007-CN-04.)
(2) If software is used to determine eligibility from the scanned applications, the SFA must
ensure that manual edits are in place to secure accurate free and reduced-price determinations.
(Reference USDA Policy Memo 2007-CN-04.)
(3) Access or security procedures are maintained to ensure confidentiality of the information.
(4) The paper copies of applications are maintained in any current year. Electronically scanned
copies must be maintained for a minimum of three years after the submission of the final claim
for reimbursement for the fiscal year or longer as required for audit resolution.
(5) Procedures are developed to make an accurate count of the Applications for Free and Reduced-
Price Meals prior to the scanning of each batch. This count must be compared to applications
successfully scanned to ensure that all applications are entered into the system.
(6) The State Agency may require that the paper copies be retrieved by school (if desired) if the
electronically scanned versions of the applications are not operationally accessible in a
timely manner or for any other reason.
36 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
(7) Paper copies of the applications must be retained for any sites on Provision 1, 2, or 3 for three
years beyond the establishment of a new base year or longer as needed for audit resolution.
(8) Adequate backup is maintained for the electronic files.
c. Electronic signatures and applications (Public Law 108-265, Section 105).
A household application may be executed using an electronic signature if:
(1) The application is submitted electronically.
AND
(2) The electronic application filing system meets confidentiality standards established by USDA.
13 . Child Nutrition Programs (CNP) Roster
a. Once applications are approved, the SFA is responsible for maintaining current eligibility status
of all students. Benefit issuance rosters are lists of students eligible to receive free, reduced-price,
or full-price meals. As with the Application for Free and Reduced-Price Meals, these rosters
are to be considered confidential and used only by persons directly involved with the CNP. An
example of a CNP Roster is on page 73.
Although most SFAs are computerized in their meal-counting and meal-claiming process, most of
these systems do not provide all the necessary information that the roster reflects.
b. Rosters should include the following information:
(1) The date a student became eligible for benefits.
(2) The date a student withdraws from school or transfers to another school.
(3) The date a student’s eligibility category changes as a result of verification or reported
change in household status.
c. If multiple rosters are used (e.g., one in the office for benefit issuance and one at the point of
service for meal counts), it is essential that all rosters be updated and printed on a regular basis
(at least monthly) to reflect current eligibility status.
F. Eligibility Definitions
Although school officials may have to use their own discretion in some instances, the following guidelines
are intended to provide assistance in answering questions from households and in making income-eligibility
determinations.
1. Determining Household Size
a. Adopted Child—An adopted child for whom a household has accepted legal responsibility is
considered to be a member of that household. If the adoption is a SUBSIDIZED adoption
(children who are difficult to place), the subsidy is included in the total household income.
b. Child Attending an Institution—A child who attends but does not reside in an institution is
considered a member of the household in which he or she resides.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 37
c. Child Away at School—A child who is temporarily away at school (e.g., attending boarding
school or college) should be considered as a member of the household.
d. Child Living With One Parent, Relatives, or Friends—In cases where no specific welfare agency
or court is legally responsible for the child or where the child is living with one parent, other
relatives, or friends of the family, the child is considered to be a member of the household with
whom he or she resides. Children of divorced or separated parents are generally part of the
household that has custody.
e. Emancipated Child—A child living alone as a separate economic unit is considered to be a
household of one.
f. Family Members Living Apart—Family members living apart on a temporary basis are considered
household members. Family members not living with the household for an extended period of
time are not considered members of the household for purposes of determining eligibility, but any
money made available by them or on their behalf for the household is included as income to the
household.
g. Foreign Exchange Student—A foreign exchange student is considered to be a member of the
household in which he or she resides; i.e., the household hosting the student.
h. Foster Child—A foster child is a child who is living with a household but who remains the legal
responsibility of the welfare agency or court. The household keeping the foster child DOES
include the foster child in its family size, and it does include as part of the household income any
monies the foster child receives. However, the household does not report any monies the foster
parents are receiving for the care of the foster child. NOTE: Because some adopted children
were first placed in families as foster children, parents may not be aware that once a child is
adopted, he or she must be determined eligible based on the economic unit and all income
available to that household, including any adoption assistance, is counted when making an
eligibility determination. (Reference Eligibility Manual for School Meals, January 2008, page 31.)
i. Homeless—An individual who lacks a fixed, regular, and adequate nighttime residence is
considered homeless. The definition includes:
(1) Children and youths who are sharing the housing of other persons due to loss of housing,
economic hardship, or a similar reason; living in motels, hotels, trailer parks, or camping
grounds due to the lack of alternative accommodations; living in emergency or transitional
shelters; abandoned in hospitals; or awaiting foster care placement.
(2) Children and youths who have a primary nighttime residence that is a public or private place
not designed for or ordinarily used as a regular sleeping accommodation for human beings.
(3) Children and youths who are living in cars, parks, public spaces, abandoned buildings,
substandard housing, bus or train stations, or similar settings.
(4) Migratory/runaway children who qualify as homeless because the children are living in
circumstances described on page 32 in Item 8.
j. Household/Economic Unit—A group of related or unrelated individuals who are not residents
of an institution or boarding house, but who are living as one economic unit and who share
housing and/or significant income and expenses of its members. Generally, individuals residing
in the same house are an economic unit. However, more than one economic unit may reside
together in the same house. Separate economic units in the same house are characterized by
prorating expenses and maintaining economic independence from one another.
38 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
k. Institutionalized Child—An institutionalized child is a child who resides in a residential-type
facility that the state has determined is not a boarding school. Such a child is considered a
household of one.
l. Joint Custody—In cases where joint custody has been awarded and the child physically changes
residence, the SFA has the authority to assign the child’s eligibility to the household that best
benefits the child. This eligibility does not extend to members of the second household.
m. Military Family Member—For the purpose of determining household size, deployed service
members should be considered as family members living apart on a temporary basis. A school or
an institution would instruct families to include the names and only that portion of the deployed
service member’s income made available by the service member, or on his or her behalf, to the
household where the children are staying should be counted as income for eligibility determination
purposes. (Reference USDA Policy Memo 2005-CN-05.)
2. Determining Household Income
a. Reportable Income
(1) Income is any money received on a recurring basis, including GROSS earned income, unless
specifically excluded by legislation. Specifically, gross earned income means all money
earned before deductions for employee’s income taxes, social security taxes, insurance
premiums, bonds, savings programs, and/or other income deductions.
(2) Income includes the following:
(a) Adopted Child Subsidy—The subsidy a household receives for a child that has been
adopted is counted as income.
(b) Alimony and Child Support—Any money received by a household in the form of
alimony or child support is considered as income to the receiving household. However,
any money paid out for alimony or child support may not be deducted from that
household’s reported gross income.
(c) Child’s Income—The earnings of a child who is a full-time or regular part-time employee
MUST be listed on the application as income. However, occasional earnings such as
income from occasional baby-sitting or mowing lawns should not be listed on the
application as income.
(d) Current Gross Income—Households MUST report current income (before taxes) on an
Application for Free and Reduced-Price Meals.
Current income means income received by the household. For the purposes of
certification of eligibility for free or reduced-price meals or free milk, the household must
provide its current income which is based on the most recent information available. This
may be for the current month, the amount projected for the first month the application is
made for, or for the month prior to application. If the household’s current income is not
a reflection of income that will be available over the school year, the household should
contact the SFA for assistance. The SFA would determine the amount and frequency of
income available during the school year for households. (Reference Eligibility Manual
for School Meals, January 2008, pages 18 and 19.)
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 39
(e) Earnings From Work—Wages, salaries, tips, commissions, net income from self-owned
businesses and farms, strike benefits, unemployment compensation, and workers’
compensation.
(f) Foster Child’s Income—A foster child is a child who is living with a household but who
remains the legal responsibility of the welfare agency or court. The household keeping
the foster child DOES include the foster child in its family size, and it does include as
part of the household income any monies the foster child receives. However, the
household does not report any monies the foster parents are receiving for the care of the
foster child. NOTE: Because some adopted children were first placed in families as
foster children, parents may not be aware that once a child is adopted, he or she must be
determined eligible based on the economic unit and all income available to that household,
including any adoption assistance, is counted when making an eligibility determination.
(Reference Eligibility Manual for School Meals, January 2008, page 31.)
(g) Garnisheed Wages and Bankruptcy—Income is the gross income received by a
household before deductions. In the case of garnisheed wages and income ordered to
be used in a specified manner, the total gross income MUST be considered, regardless
of whatever portions are garnisheed or used to pay creditors.
(h) Income for the Self-Employed—Self-employed persons may use last year’s income as
a basis to project their current year’s net income, unless their current net income provides
a more accurate measure. Self-employed persons are credited with net income rather
than gross income. Net income for self-employment is determined by subtracting business
expenses from gross receipts.
1) Gross receipts include the total income from goods sold or services rendered by the
business.
2) Deductible business expenses include the cost of goods purchased, rent, utilities,
depreciation charges, wages and salaries paid, and business taxes (not personal,
federal, state, or local income taxes).
3) Nondeductible business expenses include the value of salable merchandise used
by the proprietors of retail businesses.
4) For a household with income from wages and self-employment, each amount MUST
be listed separately. When there is a business loss, income from wages may not be
reduced by the amount of the business loss. If income from self-employment is
negative, it should be listed as zero income.
(i) Institutionalized Child’s Income—Payments from any source directly received by the
institution on a child’s behalf are not considered as income to the child. Only the income
a child earns from full-time or regular part-time employment and/or personally receives
while in residence at the institution is considered as income.
(j) Lump Sum Payments–When lump sum payments are put into a savings account and
the household regularly draws from that account for living expenses, the amount
withdrawn is counted as income.
40 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
(k) Military Benefits—Gross income, including base pay, regular housing allowance (BAH,
VHA, BAQ), subsistence (BAS), clothing allowance, hazardous duty, hostile fire, flight
pay, incentive, etc., must be included for military families. The only exceptions are as
follows:
1) U.S. Armed Forces Family Subsistence Supplemental Allowances (FSSA).
(Reference USDA Policy Memo 2006-CN-10.)
2) Privatized housing refers to the Military Housing Privatization Initiative, a program
operating at a number of military installations. This initiative puts the operation of
military-owned housing under private contractors. Under this privatization initiative,
a housing allowance appears on the leave and earnings statement of service members
living in privatized housing. It is important to note that this income exclusion is
only for service members living in housing covered under the Military Housing
Privatization Initiative. It is not an allowable exclusion for households living off
base in the general commercial/private real estate market. (Reference USDA Policy
Memos 2004-CN-06, 2004-CN-01, 2003-CN-17, 2003-CN-16.)
3) During Operation Enduring Freedom, where a household member is deployed to
any location, regardless of the specific military operation, only the income made
available to the household is to be counted and the deployed household member is
to be counted as part of the household.
Additionally, USDA has provided clarification regarding household-size and income
determination where both parents are deployed military and their children are staying
with friends or relatives. Consistent with the above policy, the children would be
counted as part of the household where they are staying; however, both parents
would also be included in the household and only the funds provided to the
household by the deployed military parents would be included in total household
income. (Reference USDA Policy Memo 2003-CN-06.)
4) Military Combat Pay. This exclusion is authorized by the Agriculture, Rural
Development, Food and Drug Administration, and Related Agencies Appropriations
Act, 2010 (P.L. 111-80; October 21, 2009).
As set forth in the statute, combat pay is defined as an additional payment made
under Chapter 5 of Title 37 of the United States Code, or as otherwise designated by
the Secretary to be excluded, that is received by the household member who is
deployed to a designated combat zone. Combat pay is excluded if it is:
• Received in addition to the service member’s basic pay.
• Received as a result of the service member’s deployment to or service in an
area that has been designated as a combat zone.
AND
• Not received by the service member prior to his or her deployment to or service
in the designated combat zone.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 41
A combat zone is any area that the President of the United States designates by
Executive Order as an area in which the U.S. Armed Forces are engaging or have
engaged in combat. As with other types of income commonly received by military
personnel (such as the Basic Allowance for Housing or Basic Allowance for
Subsistence payments), combat pay received by service members is normally
reflected in the entitlements column of the military Leave and Earning Statement
(LES). Information regarding deployment to or service in a combat zone may also
be available through military orders or public records on deployment of military
units. Deployed service members are considered members of the household for
purposes of determining income eligibility for the CNP. (Reference USDA Memo
SP-06-2010.)
5) Deployment Extension Incentive Pay (DEIP)
The exclusion of combat pay, as described in P.L. 111-80, is extended to DEIP. DEIP
is given to active-duty service members who agree to extend their military service
by completing deployment with their units without reenlisting. This exemption
applies only until the service members return to their home station. Any additional
DEIP payments provided to service members serving at their home station is
considered income as they are no longer considered deployed. (Reference USDA
Policy Memo SP-06-2011.)
6) The Earned Income Tax Credit (EITC). (Reference USDA Policy Memo 2003-CN-
13.)
7) Any payments made under the Agent Orange Compensation Exclusion Act.
8) Any payments made or any mandatory salary reduction related to the Veteran’s
Educational Assistance Act of 1964 (GI Bill).
(l) Other Income—Net rental income; annuities; net royalties; disability benefits; interest;
dividend income; cash withdrawn from savings; income from estates, trusts, and/or
investments; regular contributions from persons not living in the household; and any
other money that may be available to pay for the children’s meals.
(m) Pensions/Retirements/Social Security—Pensions, retirement income, social security,
supplemental security income (SSI), and veterans’ payments.
(n) Seasonal/Temporary Workers—Seasonal workers such as migrants and others whose
income fluctuates so that they usually earn more money in some months than in other
months. In these situations, the household may project its annual rate of income and
report this amount as its current income. If the prior year’s income provides an accurate
reflection of the household’s current annual rate of income, the prior year may be used
as a basis for the projected annual rate of income.
(o) Welfare—Public assistance payments/welfare receipts (General Assistance, General
Relief, etc.).
42 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
b. Income Exclusions—Income NOT to be reported or counted as income in the determination of a
household’s eligibility for free or reduced-price benefits includes:
(1) Any cash income or value of benefits a household receives from any federal program that
excludes such income by legislative prohibition, such as the value of assistance provided
under SNAP, TANF, or FDPIR benefits.
(2) Student financial assistance provided for the costs of attendance at an educational institution,
such as grants and scholarships, awarded to meet educational expenses and not available to
pay for meals.
(3) The foster parent does not include as part of the household income any monies the foster
parent receives from the welfare agency for shelter and care.
(4) LOANS, such as bank loans, since these funds are only temporarily available and MUST be
repaid.
(5) The value of in-kind compensation such as housing for clergy or any other noncash benefit.
(6) Occasional earnings received on an irregular basis; e.g., nonrecurring, such as payment for
occasional baby-sitting or mowing lawns.
(7) Lump sum payments or large cash settlements are not counted as income since they are not
received on a regular basis. These funds may be provided as compensation for a loss that
MUST be replaced, such as payment from an insurance company for fire damage to a house.
(8) Any subsidy that a household receives through the prescription drug discount card program
is not considered income. (Reference USDA Policy Memo 2004-CN-04.)
(9) Military exclusions—see pages 40 and 41.
(10) Earned Income Tax Credit: The federal earned income tax credit may be a refund of taxes
withheld, a credit against taxes withheld, or a cash payment in excess of what was withheld.
(Reference USDA Policy Memo 2003-CN-13.)
(11) Payments made under the National Flood Insurance Act of 1968 for flood mitigation activities.
(Reference USDA Policy Memo 2006-CN-04.)
This list is not inclusive. Legislation is periodically enacted that excludes income for the purposes of
the school meals/milk programs. Go to <http://www.ssa.gov/OP Home/cfr20/416/416-ap01.htm.> for a
complete listing.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 43
G. Automatic Eligibility of Unenrolled Children
1. Head Start
a. Children enrolled in FEDERALLY funded Head Start centers are considered categorically eligible
for free meals in the NSLP no matter what the income level of the household. Public Law 110-134
makes any child enrolled in Head Start automatically eligible for free meals without further
application or eligibility documentation. (Reference USDA Policy Memo 2008-CN-05.) The
following documentation is needed for meeting this criteria:
(1) Documentation for Head Start Enrollees—The SFA must obtain documentation of the
Head Start participants in order to confirm automatic eligibility for free meals. The
documentation may be a list of the names of the Head Start participants. The documentation
must also include the signature of a Head Start employee authorized to provide the certification
on behalf of the Head Start office, as appropriate, and the date. Verification of eligibility from
the household is not required when documentation of categorical eligibility is obtained from
Head Start officials. Refer to page 75 for a copy of the Even Start/Head Start Federally
Funded Enrollment form.
(2) Annual Update–At the beginning of each year, the determining official must establish whether
each child continues to be enrolled in Head Start.
(3) Record Retention–The Head Start list of participants must be maintained on file and readily
available for review by USDA, the State Agency, or other appropriate agencies for a minimum
of three years from the end of the fiscal year to which the information applies or as otherwise
specified in program regulations.
b. Head Start children do not need to be enrolled in the school, but if they are not enrolled in the
school, they cannot be counted in the school’s free and/or reduced-price eligibles count, but the
meals served to the children can be counted and claimed for reimbursement.
c. The categorical eligibility of a Head Start child does NOT extend to the other children in the
household.
2. Even Start
For a child to be categorically eligible for free meals based on his or her participation in Even Start, the
child MUST be enrolled as a participant in a FEDERALLY funded Even Start Family Literacy Program
and MUST be at the prekindergarten level.
a. Categorical eligibility does NOT apply to other family members.
b. Documentation for Even Start Enrollees—The SFA must obtain documentation of the Even
Start participants. The documentation may be a list of the names of the Even Start participants
and a statement certifying that those children are currently enrolled as participants in the Even
Start program. The documentation must also include the signature of an Even Start employee
authorized to provide the certification on behalf of the Even Start office, as appropriate, and the
date. Verification of eligibility from the household is not required when documentation of
categorical eligibility is obtained from Even Start officials. Refer to page 75 for a copy of the Even
Start/Head Start Federally Funded Enrollment form. Confirmation that the child has not yet
entered kindergarten must also be included in the documentation from the Even Start official.
Once a child has entered kindergarten, that child loses his or her categorical eligibility for
free meals based upon Even Start.
44 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
c. Recertification of Categorical Eligibility–At the beginning of each year, the official responsible
for determining Even Start participation must update each child on the list to ensure each one has
not entered kindergarten.
d. Meal Reimbursements for Adults Participating in Even Start
(1) Reimbursements may be claimed for adults participating in Even Start programs when the
adults are enrolled in a General Educational Development (GED) program that meets in the
school during the school day. GED students are not enrolled in the school; thus, they
cannot be counted in the school’s free and/or reduced-price eligible counts. NOTE: If the
adult is not enrolled in a GED program, he or she should be treated as a visitor.
(2) In the case where the adult student is enrolled in a school of high school level or under (not
in a GED program), meals served may also be claimed for reimbursement. The adult student
would be included in the SFA’s total enrollment of students for funding and other purposes
the same as other students of high school level or under. Any adults meeting either of these
criteria who wish to obtain free or reduced-price benefits under the NSLP/SBP must complete
an application for meal benefits. (Reference USDA Policy Memo 2002-SP-08.)
(3) If an adult is enrolled in only English as a second language (ESL) classes that are not part of
a regular high school completion program, he or she should be treated as a visitor. (Reference
FNS Instruction 776-7.)
3. Preprimary
Preprimary is defined as a child or group of children ranging from birth to school age.
Preprimary classes are eligible to participate in the NSLP and SBP when they are conducted in a school
having classes of primary or higher grades, regardless of whether such preprimary classes are recognized
as part of the educational system of the state. They may be approved for meal benefits by completing
Applications for Free and Reduced-Price Meals. If these children are NOT enrolled, they must not be
reported as part of the site’s free and/or reduced-price eligible counts on the claim for reimbursement
nor the Low-Income Student Count Report. Only the meals served to these children may be reported
on the claim for reimbursement.
H. Direct Certification
1. Direct Certification is a simplified method of determining some children’s eligibility for free meals
under the NSLP, SBP, or free milk under the SMP without having the family complete an Application
for Free and Reduced-Price Meals or a free milk application. The SFA obtains documentation from the
appropriate state or local SNAP or TANF agency that enables the SFA to determine that children are
members of households currently certified to receive SNAP or TANF benefits. This procedure may
also be used to certify children whose households participate in FDPIR.
The Oklahoma Department of Human Services SNAP Office will do a mass mailout to ALL households
receiving SNAP or TANF benefits sometime after July 1 of each year. This mailout will remind families
that because they do receive SNAP or TANF benefits, their children are eligible to receive free meal
benefits. The annual notice will instruct the families to take the documentation to the school cafeteria
to receive these benefits. An example of the annual notice is on page 78. Further, the DHS SNAP
Office will send the same type of information to any new SNAP or TANF households as they become
eligible. An example of the initial notice is on page 77. These procedures will fulfill the requirement
that all institutions participating in the NSLP must also participate in Direct Certification. (Reference
Public Law 108-265.) This is the last year that USDA will allow the letter method under Direct
Certification.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 45
a. USDA regulations do not allow a school to backdate Direct Certification benefits. Approval of
the free-meal benefits begins on the date that the school looks at the Direct Certification
documentation.
b. Under Direct Certification, if one child in the household is Directly Certified, then all children in
that household that are enrolled in the school must be given free meal benefits. (Reference SP-38-
2009.)
c. If an application for directly certified children is received at any time during the school year, the
school should disregard the application. The Child Nutrition and WIC Reauthorization Act of
2004 states that once a household is approved for free or reduced-price benefits, the household
will remain eligible for those benefits for the remainder of the school year plus a maximum of 30
operating days in the subsequent school year. Also, the family is no longer required to report
income increases; loss of SNAP, TANF, or FDPIR eligibility; or family-size reductions. (Reference
USDA Policy Memos 2004-CN-07, 2004-CN-09, 2004-SP-02, and 2004-SP-03.)
2. Required Documentation
a. Documentation to establish children’s eligibility for free meals under Direct Certification (and to
substantiate claims for reimbursement) MUST include:
(1) Names of children currently certified to receive SNAP/TANF/FDPIR benefits.
(2) A statement certifying that the child is a member of a SNAP, TANF, or FDPIR household.
(3) At least two pieces of identifying information that will match each child with a child attend-ing
a particular school. Examples of identifiers include:
(a) Name of child
(b) Social security number
(c) Birth date
(d) Parent’s name/legal guardian
(e) Sex
(4) The date.
(5) The signature of a SNAP, TANF, or FDPIR official.
b. The documentation MUST be retrievable by school to ensure proper delivery of benefits and to
allow substantiation of the number of children eligible for free meals or milk.
c. The SFA MUST notify the household in writing that (Reference USDA Regulation § 245.6[c][1]):
(1) A child is eligible for free benefits.
(2) No further application is necessary.
(3) The household MUST notify school officials if it does not want free benefits for its children.
46 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
d. SFAs MUST ensure that families receive either a Direct Certification notification or an Application
for Free and Reduced-Price Meals. Households eligible under Direct Certification must receive
a letter notifying them that their children are eligible for free benefits. Refer to page 81 for a copy
of the Direct Certification Notice form. SFAs are not required to distribute application information
to households that are directly certified.
3. Delivery of Benefits
a. The SFA MUST provide benefits promptly. Eligible students may receive benefits immediately,
and the SFA may assume consent if refusal has not been received by a certain number of days as
determined by the SFA.
b. If the household refuses benefits, the SFA MUST discontinue benefits immediately and document
the refusal.
4. Implementation of Direct Certification
a. Direct Certification: Zip Code Listing
(1) The Healthy, Hunger-Free Kids Act of 2010 (Public Law 111-296) requires Direct Certification
to be conducted three times per year; therefore, the SFA is required to request zip code lists
for its serving area before the August, December, and March claims for reimbursement may
be submitted.
(2) Each year a statewide list of SNAP and TANF children, separated by zip code, is forwarded
to the State Agency from the DHS. A school must make a request to the State Agency any
time after July 1, but no later than September 10, of each year to obtain a listing of the
children within the district’s zip code areas who are eligible for SNAP or TANF benefits.
School districts MUST submit their requests for zip code information through eClaims. Refer
to page 83 to see what it looks like under eClaims. Once the zip code request is certified by
the SFA, the list of children by zip code area(s) requested will be e-mailed to the school
district via a password-protected workbook, along with instructions on how to access the
files. Upon receipt of the information, it is the responsibility of the SFA to compare each child
enrolled in the SFA, using at least two identifying pieces of information; i.e., name of child,
social security number, birth date, name of parent or legal guardian, or sex. When a child
matches on at least two identifying pieces of information, the child automatically qualifies for
free meal benefits. In addition, any other children within the same household who are
enrolled in school will also qualify for free meal benefits. The SFA should identify the
children on the Direct Certification list who are enrolled in the SFA along with any other
children identified as part of that household who are enrolled. An example of this would be
highlighting each child’s name on the list that matches the SFA’s enrollment. The SFA must
then notify the parent or legal guardian of the child’s/children’s eligibility.
b. Direct Certification: FDPIR Listing
(1) SFAs may request or accept a listing provided by tribal authorities indicating households
that participate in the FDPIR program.
Oklahoma State Department of Education School Food Service Compliance Document, July 2011 47
(2) Upon receipt of the information, it is the responsibility of the SFA to compare each child
enrolled in the SFA, using at least two identifying pieces of information; i.e., name of child,
social security number, birth date, name of parent or legal guardian, or sex. When a child
matches on at least two identifying pieces of information, the child automatically qualifies for
free meal benefits. In addition, any other children within the same household who are
enrolled in school will also qualify for free meal benefits. The SFA should identify the
children on the Direct Certification list who are enrolled in the SFA along with any other
children identified as part of that household who are enrolled. An example of this would be
highlighting each child’s name on the list that matches the SFA’s enrollment. The SFA must
then notify the parent or legal guardian of the child’s/children’s eligibility.
(3) An SFA may also receive a notice from a tribe that a particular household receives FDPIR
benefits. Upon receipt of this type of form, the SFA can automatically certify the children
listed as well as the other children within that household who are enrolled in school as being
directly certified to receive free meal benefits. An example of this form is on page 79.
I. Confidentiality/Disclosure of Eligibility Information
1. General Information
a. The issues of privacy and confidentiality of personal data are complicated as well as sensitive.
SFAs may disclose children’s free or reduced-price meal eligibility information to programs,
activities, and individuals who are specifically authorized access under the NSLA. This is an
option, not a requirement; therefore, funds in the nonprofit school food service account cannot
be used to pay the costs associated with collecting and processing such information. (Reference
Eligibility Manual, January 2008, page 12.)
b. The eligibility status of a child by a noncustodial parent must not be released without a court
order.
c. The SFA or the school administration may opt to disclose children’s eligibility information to
Sooner Care Benefits officials if the household does not decline to have its children’s eligibility
information released.
d. The SFA may disclose aggregate information to any program or individual, such as the number
of children eligible for free or reduced-price meals. Information in the aggregate does not
identify individual children. Therefore, parental notification and parental consent are not needed.
e. The NSLA specifies that persons directly connected to the administration or enforcement of
certain programs or activities are permitted to have access to children’s eligibility information.
The Comparison Chart for Eligibility Information That May Be Disclosed on page 85 lists
programs, the extent of information that may be disclosed (only eligibility status or all eligibility
information), and whether the program may have access to children’s eligibility information
without parental consent or without the opportunity to decline the disclosure.
f. Although a program or person may be authorized under the NSLA to receive free and reduced-price
eligibility information, there MUST be a legitimate need to know to provide a service or carry
out an authorized activity.
g. The Oklahoma Health Care Authority (which administers the Sooner Care Benefits Program)
receiving children’s free and reduced-price meal or free milk eligibility information MUST use that
information to enroll eligible children in the Sooner Care Benefits Program.
48 Oklahoma State Department of Education School Food Service Compliance Document, July 2011
h. No Child Left Behind (NCLB): Because NCLB is a federal education program, school district
officials may disclose a child’s eligibility status to persons directly connected with, and who have
a need to know, a child’s free or reduced-price meal eligibility status in order to administer and
enforce the NCLB requirements. However, other information obtained from free and reduced-price
meal application or obtained through Direct Certification cannot be disclosed. School
district officials must keep in mind that the intent of the confidentiality provisions is to limit the
disclosure of a child’s eligibility status to those who have a need to know for proper administration
and enforcement of a federal education program. School districts must establish procedures that
limit access to a child’s eligibility status to as few individuals as possible. (Reference Eligibility
Manual for School Meals, January 2008, pages 54 and 55.)
i. The WAVE is Oklahoma’s secure electronic student information system (SIS). There is a
mandatory element in the SIS where a district must indicate whether a student qualifies for free,
reduced-price, or none (paid) meal benefits. Although this is confidential information, other
elements in the SIS are also confidential. Therefore, meal-eligibility information must be entered
into the SIS or provided to the SIS staff in some manner.
2. Parental Notification About Disclosure to Programs Other Than Sooner Care Be