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Direct Certification

A federally mandated process that sponsors must use to certify school-age recipients of CalFresh and CalWORKs benefits as eligible for free school meals without further application.

Direct certification (DC) is the federally mandated process that School Nutrition Program operators must use to certify children who are eligible for free meals or milk without completing an application. Charter schools, public school districts, and county offices of education may implement DC by using a local data match through their county’s department of social or welfare services, and by using the California Department of Education’s California Longitudinal Pupil Achievement Data System. Private schools, residential child care institutions, and nonpublic schools with day students may implement DC by using a local data match with their county’s department of social or welfare services.

The DC process uses information provided by state or local agencies administering assistance programs and Other Source Categorically Eligible programs. Assistance programs include the Supplemental Nutrition Assistance Program (SNAP [known as CalFresh in California]), Temporary Assistance for Needy Families (TANF [known as CalWORKs in California]), and Food Distribution Program on Indian Reservations. Other Source Categorically Eligible programs include foster, migrant, homeless, runaway, and Head Start.

Student eligibility for free and reduced-price meals is determined by meal application or by DC. DC eliminates the need for paper applications. The DC matching process, whether automated or manual, requires no action by the household. Children from households with incomes at or below 130 percent of the federal poverty level are eligible for free school meals. Children from households with incomes between 130 and 185 percent of the federal poverty level are eligible for reduced-price meals.

As stated in Title 7, Code of Federal Regulations, Section 245.6(b), if a household submits an application for directly certified children, the DC eligibility determination will take precedence and the application must be disregarded. The application must be retained and the date of disregard must be documented. Please note this does not apply to households who are directly certified for reduced-price meals through Medi-Cal then submit an income application demonstrating eligibility for free meals. The most favorable meal benefit level a family qualifies for always takes precedence, regardless of the method of eligibility.

Definitions

Automated Data Matching: Automated data matching is the most common direct certification (DC) method used to directly certify children. Matches are made between student enrollment records and benefit recipient records from assistance programs, foster care agencies, Head Start programs, Migrant Education programs, and agencies working with homeless and runaway children, or other appropriate state or local agencies to establish categorical eligibility.

CalFresh: A federally mandated, state-supervised, and county-operated government entitlement program that provides monthly food benefits to assist low-income households in purchasing the food they need to maintain adequate nutritional levels.  Children from households that receive benefits under CalFresh are deemed categorically eligible for free school meals. CalFresh is federally known as Supplemental Nutrition Assistance Program (SNAP).

California Longitudinal Pupil Achievement Data System (CALPADS): A longitudinal data system used to maintain individual-level data including student demographics, course data, discipline, assessments, staff assignments, and other data for state and federal reporting.

California Work Opportunity and Responsibility to Kids (CalWORKs): A federally designated, state-funded and county-operated public assistance program that provides cash aid and services to eligible families that have a child(ren) in the home. Children from households that receive benefits under CalWORKs are deemed categorically eligible for free school meals. CalWORKs is federally known as Temporary Assistance for Needy Families (TANF).

Child Nutrition Information and Payment System (CNIPS): The California Department of Education’s (CDE) web-based system for administering the federal and state School Nutrition Programs including the National School Lunch and School Breakfast, Food Distribution, Special Milk, Child and Adult Care Food, Summer Food Service, and Seamless Summer Option Programs.

Categorical Eligibility: Automatic eligibility for free meals or free milk due to a child’s (or any household member’s) receipt of benefits under an assistance program (e.g., CalFresh, Food Distribution Program on Indian Reservations [FDPIR], or CalWORKs). Categorical eligibility for free meal benefits is extended to all children in a household (Title 7, Code of Federal Regulations [7 CFR], Section 245.6[b][7]).

Direct Certification (DC): Determining children eligible for free or reduced-price meal benefits based on documentation obtained directly from appropriate state or local agencies or other authorized individuals. DC of a child’s eligibility status should not involve the household. The communication exchange should be between an appropriate agency and the state agency, local educational agency, or school.

Direct Certification for Assistance Programs: A process conducted through automated data matching or an exchange of information between the assistance program agency and the state agency or local educational agency. No application from the household is necessary. Letters from TANF (CalWORKs in California) or Food Distribution Programs on Indian Reservations agencies submitted by households are considered DC. However, DC for SNAP (CalFresh in California) households must be conducted using an automated data matching process (7 CFR, Section 245.6[b][1]). If a household provides a SNAP eligibility letter to the
local educational agency (LEA) or school, the letter must be used to establish eligibility, but it is not considered DC for reporting purposes.

Direct Verification: The use of public records as a means to verify children’s eligibility for free and reduced-price meal benefits determined by application. Direct verification may be conducted with assistance program agencies or appropriate officials of Other Source Categorically Eligible programs to confirm eligibility for free meals. Direct verification may be used for applications included in the verification sample or those verified for cause (7 CFR, Section 245.6a[g]).

Extension of Categorical Eligibility for Assistance Programs: A child or other household member’s receipt of benefits from an assistance program automatically extends eligibility for free benefits to all children who are members of the household (7 CFR, Section 245.6[b][7]).

Food Distribution Program on Indian Reservations (FDPIR): FDPIR is a federal program that provides U.S. Department of Agriculture (USDA) foods to low-income households living on Indian reservations. Children from households that receive benefits from FDPIR are deemed categorically eligible for free school meals.

Foster Child: An Other Source Categorical Eligibility program designation for a child who is formally placed by a court or a state child welfare agency. Whether placed by the state child welfare agency or a court, in order for a child to be considered categorically eligible for free meals, the state must retain legal custody of the child. This definition does not apply to informal arrangements or permanent guardianship placements that may exist outside of state or court-based systems (7 CFR, Section 245.2).

Free Meal: A meal served in the National School Lunch Program or School Breakfast Program to a child from a household eligible for such benefits under 7 CFR, Part 245 and for which neither the child nor any member of the household pays or is required to work.

Head Start: An Other Source Categorically Eligible program, which refers to federal Head Start and any state-funded prekindergarten programs that use eligibility criteria that are identical to or more stringent than federal Head Start (7 CFR, Section 245.2).

Homeless: An Other Source Categorical Eligibility program designation for a child who is identified by the LEA’s homeless liaison or by an official of a homeless shelter as lacking a fixed, regular, and adequate nighttime residence (7 CFR, Section 245.2).

Household: A group of related or nonrelated individuals who are living as one economic unit. The term “family” has the same definition as “household” under 7 CFR, Section 245.2.

Local Educational Agency (LEA): A public board of education, or other public authority, legally constituted within a state for either administrative control or direction of or to perform a service function for public elementary schools or secondary schools in a city, county, township, school district, other political subdivision of a state, or for a combination of school districts or counties as are recognized in a state as an administrative agency for its public elementary schools or secondary schools.

Medicaid: The program of medical assistance established under Title XIX of the Social Security Act, Title 42, United States Code (42 U.S.C.) 1396 et seq. This definition encompasses both regular Medicaid programs and expanded Medicaid programs where states have used funding from Title XXI of the Social Security Act to fund Medicaid expansions to reach children in families with higher incomes. California is currently participating in a demonstration project to directly certify students for free and reduced-price meals based on family size and income as determined by the California Department of Health Care Services. The data exchange between state departments and local educational agencies takes place securely without disclosing a student’s Medicaid status, health information, or specific income data. Medicaid is known as Medi-Cal in California.

Medi-Cal: The program of medical assistance established under Title XIX of the Social Security Act, Title 42, United States Code (42 U.S.C.) 1396 et seq. This definition encompasses both regular Medi-Cal programs and expanded Medi-Cal programs where funding has been used from Title XXI of the Social Security Act to fund Medi-Cal expansions to reach children in families with higher incomes. California is currently participating in a demonstration project to directly certify students for free and reduced-price meals based on family size and income as determined by the California Department of Health Care Services. The data exchange between state departments and local educational agencies takes place securely without disclosing a student’s Medi-Cal status, health information, or specific income data. Medi-Cal is federally known as Medicaid.

Migrant: An Other Source Categorical Eligibility designation for a child who is enrolled in the Migrant Education Program, as determined by the state or local Migrant Education Program coordinator; or as documented by an appropriate LEA official, such as the homeless liaison (7 CFR, Section 245.2).

National School Lunch Program (NSLP): A federally funded program that assists schools and other agencies in providing nutritious lunches to children at reasonable prices. In addition to financial assistance, the program provides donated USDA Foods to help reduce lunch program costs. The USDA is responsible for overseeing the program nationally. In California, the program is administered by the CDE Nutrition Services Division.

Other Source Categorical Eligibility: Categories that make children automatically eligible for free benefits, either through DC or application. A child’s eligibility for free benefits under Other Source Categorical Eligibility does not extend to any other child in the household. A child is Other Source Categorically Eligible if they are:

  • Enrolled in federal Head Start
  • Determined to be homeless by the LEA’s homeless liaison or by an official of a homeless shelter
  • Determined to be a migrant by the state or local Migrant Education Program coordinator or homeless liaison
  • Determined to be a runaway who is identified by the local education liaison as receiving assistance through a program under the Runaway and Homeless Youth Act
  • Determined to be a foster child whose care and placement is the responsibility of the state, or who is formally placed by a court with a caretaker household through which the state retains legal custody of the child

An individual child’s eligibility for free benefits under any of the Other Source Categorical Eligibility programs does not convey to other children in the household (7 CFR, Section 245.6[b][8]). Except for a foster child, the household indication of Other Source Categorically Eligible status must be confirmed through documentation prior to certifying the child’s eligibility for free meals. If documentation does not confirm eligibility for an Other Source Categorical Eligibility, the household should be asked to resubmit the application and include income information.

Reduced-price Meal: A meal served in the National School Lunch Program or School Breakfast Program to a child from a household eligible for such benefits under 7 CFR, Part 245; for which the price does not exceed the maximum allowable reduced price specified under 7 CFR, Part 245; and for which neither the child nor any member of the household is required to work.

Runaway: An Other Source Categorical Eligibility designation for a child who is identified by the LEA’s homeless liaison or a program official as receiving assistance from a program under the Runaway and Homeless Youth Act. (7 CFR, Section 245.2)

School Breakfast Program (SBP): The SBP is a federally funded program which assists schools and other agencies in providing nutritious breakfasts to children at reasonable prices. The USDA is responsible for overseeing the program nationally. In California, the program is administered by the CDE Nutrition Services Division.

Supplemental Nutrition Assistance Program (SNAP): Known as CalFresh in California, SNAP offers nutrition assistance to millions of eligible, low-income individuals and families and provides economic benefits to communities. Children from households that receive benefits under SNAP are deemed categorically eligible for free school meals.

Temporary Assistance for Needy Families (TANF): Known as CalWORKs in California, TANF is a federal designation for a state-funded program under Part A of Title IV of the Social Security Act. Categorical eligibility for free benefits is limited to beneficiaries in states with TANF standards that are comparable to or more restrictive than those in effect on June 1, 1995.

Without Further Application: “Without further application” means that no action is required by the household of a child who has been directly certified to receive free meal benefits (42 U.S.C. 1758[b][4][G][i]).

Questions:   School Nutrition Programs Unit | snpinfo@cde.ca.gov | 800-952-5609
Last Reviewed: Friday, March 07, 2025
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