Direct Certification Requirements in the SNPs

This management bulletin supersedes management bulletins 00-102, issued in February 2000, and NSD-SNP-08-2012, issued in April 2012, regarding direct certification (DC) requirements for local educational agencies (LEA) participating in the federal School Nutrition Programs (SNP). This management bulletin provides guidance on changes in California Education Code (EC) Section 49501.5(a)(2)(B), which requires school districts, county offices of education (COE), and charter schools to conduct direct certification matching through the California Longitudinal Pupil Achievement Data System (CALPADS) on a monthly basis. This update emphasizes California’s commitment to ensuring eligible students are automatically certified for free meals with minimal administrative burden on families and schools.

Background

Federal law mandates that all agency types, including private schools, public school districts, charter schools, COEs, nonpublic schools and residential child care institutions (RCCI) with day students participating in the National School Lunch Program (NSLP) and/or School Breakfast Program (SBP) implement a DC system that certifies children as eligible for free meal benefits without further application. DC can be conducted through either a state or local level match. DC 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 known as CalFresh in California, California Work Opportunities and Responsibility to Kids (CalWORKs), Food Distribution Program on Indian Reservations (FDPIR), and Medi-Cal. Other Source Categorical Eligibility programs include Head Start, homeless, migrant, runaway, and foster.

Please note, children directly certified through Medi-Cal must also meet income thresholds, and as a result can only be directly certified through the state level match in the CALPADS. Children receiving Medi-Cal benefits with a confirmed household income at or below 185 percent of the federal poverty level will automatically be directly certified for free or reduced-price meals.

State Level Data Matching

The California Department of Education (CDE) has established a statewide DC system that matches data from the student information stored in the CALPADS against statewide data on CalFresh, CalWORKs, and Medi-Cal recipients. The CALPADS provides DC results to all public schools, COEs, and charter schools through its electronic notification process. For detailed guidance on how to perform state level data matching through the CALPADS, please visit the CDE Direct Certification web page at https://www.cde.ca.gov/ls/nu/sn/directcert.asp.

Local Level Data Matching

Local level DC is conducted when an NSLP or SBP LEA establishes a memorandum of understanding with the county department of social or welfare services to match enrolled students against those children receiving CalFresh and CalWORKs benefits. School food authorities (SFA) can also work with homeless, migrant, runaway, FDPIR, and foster liaisons in school districts to directly certify additional students. Private schools, nonpublic schools, and RCCIs with day students do not have access to the CALPADS and must use a local level match process to comply with the federal DC requirements.

Frequency of Direct Certification in California

EC Section 49501.5(a)(2)(B) requires public school districts, charter schools, and COEs to conduct a state level DC match, through the CALPADS, on a monthly basis. A monthly match is required for all school sites, regardless of participation in a federal provision, such as the Community Eligibility Provision or Provision 2. The requirement set forth in EC Section 49501.5(a)(2)(B) applies to all public schools, charter schools, and COEs. Private schools, nonpublic schools, and RCCIs with day students must still comply with the federal requirements outlined in 7 CFR, Section 245.6(b)(3)(ii) which states, at a minimum, LEAs operating standard counting and claiming must conduct DC:

• At or around the beginning of the school year;
• Three months after the initial effort; and
• Six months after the initial effort.

SFAs must report the method they are using to directly certify their students in the Child Nutrition Information and Payment System (CNIPS). In the CNIPS Sponsor Application, number A50, select “state-level data match” if you are using the CALPADS to directly certify students; otherwise, select “other” (e.g., county Department of Social Services or Welfare list).

Extension of Direct Certification Benefits

Eligibility for free or reduced-price meal benefits is extended to all school-aged children in a household if any member has been identified through the DC process as eligible for benefits under the assistance programs (CalFresh, CalWORKs, FDPIR, Medi-Cal). These children are also considered directly certified. To the extent possible, SFAs must take appropriate steps to identify children who are part of an assistance program household but were not identified through DC via either state or local level data matching. For additional information on extending meal benefits please see the CDE Extending Categorical Eligibility management bulletin at https://www.cde.ca.gov/ls/nu/sn/mbusdacnp032009.asp and Extending Categorical Eligibility Questions and Answers management bulletin at https://www.cde.ca.gov/ls/nu/sn/mbusdacnp052010.asp.

Please note, extending benefits to other children in a household only applies to children directly certified through an assistance program. DC through one of the Other Source Categorical Eligibility categories does not extend to other members of the household and would only apply to the individual child directly certified.

If you have any questions regarding this Questions and Answers, please contact the appropriate SNP Specialist listed on the SNP Specialist directory web page at https://www.cde.ca.gov/ls/nu/sn/snpcontacts.asp. You can also email SNPInfo@cde.ca.gov to be directed to your SNP Specialist.