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Extending Categorical Eligibility


Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information

To: School Nutrition Program Sponsors, Child Care Agencies participating in the Child and Adult Care Food Program, Summer Food Service Program Sponsors

Number: USDA-CNP-03-2009

Attention: Food Service Director, Business Official, Food Program Director

Date: October 2009

Subject: Extending Categorical Eligibility to Additional Children in a Household

Reference: United States Department of Agriculture, Food and Nutrition Service, Policy Memo SP 38-2009; Title 7, Code of Federal Regulations, Section 245.2(b)

This Management Bulletin (MB) provides information regarding a policy change for determining categorical (automatic) eligibility of children who are members of a household currently receiving assistance (benefits) under the following programs: the Supplemental Nutrition Assistance Program (known in California as CalFresh), Food Distribution Program on Indian Reservations (FDPIR), Temporary Assistance to Needy Families (TANF) (known as the California Work Opportunities and Responsibility to Kids [CalWORKs] Program in this state) and the Kinship Guardianship Assistance Payment (Kin-GAP) Program.

This policy change represents the United States Department of Agriculture’s (USDA) attempt to increase access to child nutrition programs and streamline the meal/milk eligibility process. Therefore, beginning in school year 2009–10, if one member of the household is certified as eligible for CalFresh, FDPIR, CalWORKs or Kin-GAP via direct certification and/or meal applications with case numbers for these programs, all children in the household are categorically eligible for free meals. This means that all children in a household who are on a meal eligibility application are eligible for free meals if at least one of the children on the application has a CalWORKs, Kin-GAP, or CalFresh case number. As a reminder, Title 7, Code of Federal Regulations, Section 245.2(b) defines the household as “…a group of related or nonrelated individuals, who are not residents of an institution or boarding house, but who are living as one economic unit.”

If a local educational agency (LEA) does not have a meal application as a reference, it may use school district enrollment records to also determine children who are part of the household of a certified child, but who were perhaps not originally identified through direct certification to receive free meals or milk. For example, if two out of three children in a household are included on a direct certification list, but the third child is not, LEAs can use school district enrollment records to certify that additional child for free meals/milk.

Any income information is disregarded on a meal application submitted by a categorically eligible household. Further, for the purpose of carry-over into the new (2009–10) school year, LEAs must extend categorical eligibility to any newly enrolled siblings in the same household.

This policy supersedes the policy provided in the January 2008 edition of the USDA Eligibility Manual for School Meals and extends to the Child and Adult Care Food Program and the Summer Food Service Program when collecting household applications. Please note that this policy does not extend to other categorically eligible programs such as the Head Start or the Migrant Education Programs.

Frequently Asked Questions
  1. How does this policy affect direct certification?
  2. The direct certification designation extends to all children in the household if at least one child in the household is on the direct certification list.  Therefore, all children in the household are eligible for free meals/milk.
  1. How do I determine additional children who are part of the family if they are not listed on the direct certification list and I do not have a meal application for the family?
  2. LEAs may use district enrollment records to determine additional children who are part of the family to qualify them for free meal/milk benefits.
  1. If an application has a valid CalFresh, CalWORKs or FDPIR case number for only one child on the application, are the other children on the application eligible for free meal benefits even though they do not have a case number?
  2. Yes, if at least one child in the household has a valid case number then the LEA must extend eligibility for free meals or milk to all children in the household.
  1. Do I still need to look at the income on an application if at least one child has a valid case number on the application?
  2. No, disregard any income information provided on an application with a valid case number.
  1. Does the 30 day carryover rule for eligibility status from the previous year extend to newly enrolled children from the same household?
  2. Yes, LEAs must carryover the eligibility status from the previous year into the beginning of the new school year. This includes extending free meal/milk benefits to newly enrolled children from households receiving CalFresh, FDPIR, CalWORKs, or Kin-GAP.
  1. When is this policy effective?
  2. This policy is effective immediately and with the beginning of the 2009-10 school year. LEAs should ensure that all students considered categorically eligible based on this new policy are given free meal/milk benefits.
  1. How do I notify households of a change in eligibility based on this policy?
  2. Any household with meal status changes based on this new policy should be sent either the “Direct Certification Eligibility Notification” letter (if the changes made are due to direct certification eligibility) or the “Approval/Denial Notification” letter (if the change is based on a Free and Reduced Price Meal Application). These letters can be found under the section titled “Eligibility Materials for Free and Reduced-Price Meals” at the following Web page: http://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp

If you have any questions regarding this MB, please contact one of the following School Nutrition Program, Child and Adult Care Food Program, or Summer Food Service Program Specialists at the contact information provide below:

School Nutrition Program Specialists

Naaz Rathore at 916-445-4839 or nrathore@cde.ca.gov; or Evonne Morrissey at 916-322-8315 or emorriss@cde.ca.gov

Child Care Center Specialist

Patty Atherton at 916-322-5116 or patherto@cde.ca.gov

Summer Food Service Program Specialist

Melissa Garza at 916-322-5885 mgarza@cde.ca.gov

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