Verification for Cause in the School Meals Program

This Management Bulletin (MB) addresses concerns brought to the attention of the U.S. Department of Agriculture (USDA) about school district employees possibly misrepresenting their incomes on applications for free or reduced-price school meals for their children.

The USDA issued Policy Memorandum SP-13-2012 in response to a question of whether a local educational agency (LEA) could use the salary information of their employees as a tool to implement verification for cause.

Verification for Cause

LEAs must annually verify eligibility of children from a sample of household applications approved for free and reduced-price meals. In addition to the annual verification, Title 7, Code of Federal Regulations, Section 245.6a(c)(7) requires LEAs to verify any questionable application for cause. Verification for cause may take place anytime during the school year. The USDA supports the use of verification for cause when appropriate.

Determination Regarding School Employees’ Income

LEAs can use verification for cause to review approved applications for free or reduced-price meals when known or available information indicates school district employees may have misrepresented their incomes on their application to receive free or reduced-price meals for their children. However, before verifying any of these applications, the USDA recommends that LEAs consult with their legal counsel to establish the parameters of verification for cause for school district employees.

After legal counsel has established the LEAs parameters and if the LEAs conduct verification for cause for school district employees, verification for cause cannot automatically be used to verify the households of all school district employees whose children are certified for free or reduced-price meals. LEAs can use salary information available to them to identify questionable applications and then conduct verification for cause on those questionable applications. Under the regulatory procedures, any modifications to a student’s eligibility status cannot occur until the district completes its review and any appeal is completed.

Policy Memorandum SP-13-2012 is available on the USDA School Meals Policy Memos Web page at http://www.fns.usda.gov/school-meals/policy.

As a reminder, any situation of suspected fraud should be reported to the USDA’s Office of the Inspector General by phone at 800-424-9121 or by e-mail at usda.hotline@oig.usda.gov. 

If you have any questions regarding this MB, please contact your assigned School Nutrition Program (SNP) specialist. The SNP specialist list is available in the Child Nutrition Information and Payment System, Download Forms section, Form ID Caseload. You can also contact an SNP Office Technician by phone at 916-322-1450, 916-322-3005, or 800-952-5609, Option 2 to be directed to your SNP specialist.