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Reminder: Direct Certification is Mandatory


Nutrition Services Division Management Bulletin

Purpose: Policy, Action Required, Beneficial Information

To: School Nutrition Program Sponsors

Number: NSD-SNP-08-2012

Attention: Food Service Directors, Business Officials, Data Coordinators, Administrators, Superintendents

Date: April 2012

Subject: Reminder: Direct Certification is Mandatory in Federal Meal Programs for All Agency Types

Reference: U.S. Department of Agriculture (USDA) 2004 Reauthorization Implementation Memo SP-8; Information Alert NSD-SNP-05-2008

This Management Bulletin (MB) serves as a reminder to local educational agencies (LEAs) participating in federal meal programs (sponsors) that federal law requires all agency types, including private schools, public school districts, charter schools, county offices of education (COEs), and residential child care institutions (RCCIs) with day students that participate in the National School Lunch Program or School Breakfast Program, to implement a system of Direct Certification (DC) for CalFresh (formerly Food Stamps) and California Work Opportunity and Responsibility to Kids (CalWORKs). It has come to our attention that some charter and private schools do not have a DC matching system in place.

If your district/agency does not have a system for directly certifying students for free meals in place, you must comply with this requirement as soon as possible, but no later than the beginning of the 2012–13 school year (July 1, 2012).

Direct Certification

Direct Certification is the federally mandated process that sponsors must use to certify school-age recipients of CalFresh (formerly Food Stamps) and CalWORKs benefits as eligible for free school meals without further application. Charter schools may implement DC by using either a local data match through their county’s Department of Social or Welfare Services and/or using the California Longitudinal Pupil Achievement Data System (CALPADS). Private schools may implement DC by using a local data match with their county’s Department of Social or Welfare Services.

Local Level Data Matching

Private schools, public school districts, charter schools, and COEs (sponsors) may establish a local agreement with the county Department of Social or Welfare Services to match enrolled students against those children receiving CalFresh (and CalWORKs) benefits. 

These sponsors may use the Direct Certification Implementation Checklist to help them implement DC through an agreement with the county Department of Social or Welfare Services. The checklist is located at the California Department of Education (CDE) School Nutrition Forms Web page at http://www.cde.ca.gov/ls/nu/sn/fm.asp.

You can obtain local welfare or social service office contacts (to verify CalFresh participation) on the CDE CalFRESH County Contacts for Direct Certification page at http://www.cde.ca.gov/ls/nu/sn/directcertcountycontacts.asp.
State Data Matching

The CDE has established a statewide DC system that matches data from the student information stored in the CALPADS against statewide data on CalFresh and CalWORKs recipients. The CALPADS provides the DC results to all public schools, COEs, and charter schools through its electronic notification process.

Sponsors will find instructions on how to implement DC using CALPADS on the CDE Direct Certification Web Page at http://www.cde.ca.gov/ls/nu/sn/directcert.asp#calpads.

If a sponsor directly certifies a student as eligible for free meals, the sponsor must send an eligibility notification to the student’s household. The CDE prototype eligibility notification sample is available on the CDE School Nutrition Program Eligibility Materials Web page at http://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp.

Statement of Confidentiality

California has state laws that protect and govern free and reduced-price meal applications, and these state laws are more restrictive than the applicable federal regulations. California Education Code (EC) governs the disclosure of meal records. Specifically, EC Section 49558(a) states:

All applications and records … concerning any individual made or kept by any public officer or agency in connection with the administration of any provision of this code relating to free or reduced-price meal eligibility shall be confidential, and may not be open to examination for any purpose not directly connected with the administration of any free or reduced-price meal program, or any investigation, prosecution, or criminal or civil proceeding conducted in connection with the administration of any free or reduced-price meal program.

This EC section does not prohibit districts from sharing meal eligibility information to ensure that individual students continue to receive school meals when moving from one school district to another, either at the beginning of or during the school year. Both districts must ensure that the information remains confidential and is used solely for determining a student’s eligibility in a meal program. Please see the CDE MB on this issue at the School Nutrition MB Web page at http://www.cde.ca.gov/ls/nu/sn/mbnsdsnp122010.asp.

Child Nutrition Information Payment System

As a reminder, sponsors must report the method they are using to directly certify their students in the Child Nutrition Information Payment System (CNIPS). In the CNIPS Sponsor Application, number A38, select state-level data match if you are using the CALPADS to directly certify students; otherwise, select “other method” (e.g., county Department of Social Services or Welfare list).

If you have any questions regarding this MB, please contact the appropriate SNP specialist listed on form Caseload SNP in the Download Forms section of the Child Nutrition Information and Payment System. You may also contact the SNP Unit Secretary by phone at 916-322-1450 or 800-952-5609.

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