Eligibility Requirements for SNP

This Management Bulletin (MB) provides guidance on eligibility requirements and available resources for the School Nutrition Programs (SNP).

The U. S. Department of Agriculture (USDA) issued Policy Memorandum SP 34-2016: Revised Prototype Free and Reduced Price Application Materials for School Year (SY) 2016–17. You can view this policy memo on the USDA School Meals Policy Web page at http://www.fns.usda.gov/school-meals/policy. This policy memo highlights changes for SY 2016–17 household Application for Free and Reduced-price (F/RP) Meals with features that are either currently required or will become required by SY 2017–18. The application is used to qualify students for F/RP meals or free milk.

General Information

There is no requirement for school food authorities (SFA) to use the California Department of Education (CDE) prototype eligibility materials, which are available on the CDE SNP Eligibility Materials Web page at http://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp. However, use of the CDE prototype eligibility materials guarantees compliance with federal and state requirements monitored by the CDE during an SNP administrative review. All eligibility materials must be in compliance with the USDA Eligibility Manual for School Meals; Title 7, Code of Federal Regulations (7 CFR), Part 245; and California Education Code (EC) 49557.

The CDE offers the following prototype SNP eligibility materials:

• Application for F/RP Meals and Instructions
• Application for F/RP Meals with CalFresh Option and Instructions
• Application for the Special Milk Program
• Application for F/RP Meals: State Meal Program
• Letter to Households (pricing and nonpricing)
• Media Release
• Direct Certification Notification Letter
• Notification Letter for Other Source Categorical Programs
• Notification Letter for F/RP Meals
• Verification Materials

Policy Clarifications Effective SY 2016–17

The policies listed below were previously established in USDA Policy Memo SP 33-2015 or discussed in CDE MB SNP-30-2015: 2015–16 Revised Prototype Household Application. All SNP eligibility materials must include the following:

1. Streamline income reporting for students: Since many students do not receive income on a regular basis, the new prototype application provides a single reporting field in which the household can report the total income earned by all students. Adults and all other nonstudents must report their income by source and frequency.
2. Indication of “No Income”: The application must have a field for applicants to enter a zero to represent no income and cannot require a separate indication (i.e., check box). Instead, the application must include clear and easy to understand instructions that communicate to applicants that any blank income field is a positive indication of no income and certifies that there is no income to report for that household member. This policy allows SFAs to process the application as complete even if any income fields are left blank. Applications must be verified for cause if SFA officials know or have information available that a household has intentionally misreported their income or information.
3. Survey of Race and Ethnicity: The racial and ethnic categories are required elements on the application, but optional for the household to complete. All SFAs are required to collect racial and ethnic data each year for each site. For additional information, please review the CDE Description of Racial and Ethnic Categories Web page at http://www.cde.ca.gov/ls/nu/sn/racialethniccat.asp.
4. USDA Nondiscrimination Statement: All forms of communication available to the public regarding program availability, except menus, must contain the appropriate USDA nondiscrimination statement. The current nondiscrimination statement, including the Spanish statement, is available on the USDA Nondiscrimination Statement Web page at https://www.fns.usda.gov/cr/fns-nondiscrimination-statement.
5. Kin-GAP: The Kinship Guardianship Assistance Payment (Kin-GAP) Program no longer conveys categorical (automatic) eligibility for free meals or milk to all children in the household. Only the individual Kin-GAP child qualifies for free meal benefits. The household may apply for their non-Kin-GAP children and must include any income received from the Kin-GAP Program.

Foreign Language Translations

SFAs must provide meaningful and easily accessible materials to households comprised of limited English proficiency (LEP). In order to diminish any language barriers, the application and other household materials (letter to household, instructions, direct certification letter, approval/denial letter, and verification materials) must be available in a language that the LEP individual can understand. SFAs can develop their own eligibility materials in languages applicable to the community and may use their nonprofit food service account (Cafeteria Funds) to pay for translation services (allowable expenditure). 

To assist SFAs with LEP households, the USDA and CDE provide translated resources available on the following Web pages:

• USDA School Meals Translated Applications at http://www.fns.usda.gov/school-meals/translated-applications
• CDE SNP Eligibility Materials at http://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp
  • Please note: The Nutrition Services Division (NSD) is working with the Clearinghouse for Multilingual Documents (CMD) within the CDE to translate all eligibility materials in order to provide SFAs with compliance documentation. The NSD will send a notification once the translated eligibility materials are available. 

For additional information on LEP, please review CDE MB SNP-09-2016: Limited English Proficiency, located on the CDE SNP MB Web page at http://www.cde.ca.gov/ls/nu/sn/mb.asp. 

California Specific Requirements for Meal Eligibility Materials

SFAs that choose to use the USDA translated eligibility materials must modify the documents to comply with California EC as follows: 

• Add EC Section 49557(a): “Applications for free and reduced-price meals may be submitted at any time during a school day. Children participating in the federal National School Lunch Program will not be overtly identified by the use of special tokens, special tickets, special serving lines, separate entrances, separate dining areas, or by any other means.” This statement must be placed on the application in at least 8-point boldface type.

• Change all references from the Supplemental Nutrition Assistance Program (SNAP) to CalFresh.

• Change all references from Temporary Assistance for Needy Families (TANF) to California Work Opportunity and Responsibility to Kids (CalWORKs).

• Exclude the document “Sharing Information with Medicaid/State Children's Health Insurance Program (SCHIP)” found within the USDA family friendly application package. SFAs must adhere to provisions of EC Section 49557.2 and MB SNP-18-2015, located on the CDE SNP MB Web page at http://www.cde.ca.gov/ls/nu/sn/mbsnp182014.asp, which specifies requirements for SFAs to share students’ school meal information with Medi-Cal offices.

Assembly Bill 402

Assembly Bill (AB) 402 (Statutes of 2011) promotes the sharing of income eligibility data between SFAs and local CalFresh offices to increase CalFresh participation, as well as direct certification rates in California. The CDE designed a prototype household application that incorporates the requirements of AB 402 by including a section for the parent/guardian to authorize sharing their household eligibility information with local CalFresh offices.

For additional information about AB 402 and sharing meal applications, please review MB SNP-31-2015: Assembly Bill 402—Sharing School Meal Applications with CalFresh Offices, located on the CDE SNP MB Web page at http://www.cde.ca.gov/ls/nu/sn/mb.asp.

Senate Bill 708

Senate Bill (SB) 708 amended EC Section 49557, which requires public school districts and county offices of education (COE) to make paper applications available to students at all times during each regular school day or by offering them an online application. Public school districts and COEs opting to offer an online application are required to meet certain criteria. 

If public school districts and COEs choose to offer an online application, the application must include Web links to the following resources that are not currently required to be provided with the paper application:

• Translated meal applications posted by the USDA with instructions in the appropriate language, which inform the applicant how to submit the application.

• Online application for CalFresh, the state health care system, and summer meal program within the same city or school district.

• Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) with instructions on how to apply.

SB 708 requires that the online application comply with the privacy rights and disclosure protections established by the federal National School Lunch Act and the federal Children’s Online Privacy Protection Act. This bill also prohibits an online application from being made available or accessible if the online application allows for the information provided by an applicant to be used by a private entity for any purpose not related to the administration of a school food program, or if the online application requires an applicant to waive any right or to create a user account in order to submit the application.

SB 708 is intended to improve access to translated school meal applications, streamline required information collected for eligibility determination, add hyperlinks to connect households with support programs such as CalFresh, add privacy protections for applicants, and include clear instructions to households.

Public Media Release

Near the beginning of each school year, all SFAs must notify the public of their participation in the F/RP meals and free milk programs. Residential Child Care Institutions (group homes and youth facilities) are not required to submit a media release to local agencies, unless their enrollment includes day students.

The media release must contain the same information supplied in the Letter to Households, except the media release must contain both the F/RP Income Eligibility Guidelines (IEG). However, a media release that only refers to the Special Milk Program (SMP) should not contain the reduced-price IEGs.

Letter to Households

SFAs must distribute letters to all households, either before the beginning of or very early into the new SY, informing them about the SNP, that F/RP meals or free milk may be available to their children, and how to apply for benefits. SFAs may distribute these letters by mail, e-mail, or include them in a back-to-school information packet provided to students.

Schools participating in the NSLP or SBP may only include the reduced-price IEGs with an explanation that households with income at or below the reduced-price limits may be eligible for either F/RP meals. SFAs that participate in the SMP may only include the free IEGs.

Policy Changes Effective SY 2017–18

The following will be a required element on the application beginning in SY 2017–18:

• Social Security Number: Households applying only on the basis of income must provide the last four digits of an adult household member’s Social Security number (SSN) or an indication that the household member does not have one. The SSN field must be incorporated into the income reporting section. Households applying based on non-income criteria (categorical eligibility) are not required to provide their SSN.

Resources

The USDA Eligibility Manual for School Meals can be downloaded as a Portable Document Format (PDF) file from the USDA Guidance and Resources Web page at http://www.fns.usda.gov/school-meals/guidance-and-resources.

SFAs can access 7 CFR, Part 245, on the U.S. Government Publishing Office Electronic Code of Federal Regulations Web page at http://www.ecfr.gov/cgi-bin/text-idx?SID=c0e2c0bb87b6faeda9c66dffc2f805d4&mc=true&node=pt7.4.245&rgn=div5.

SFAs can access the EC on the California Legislative Information Web page at http://leginfo.legislature.ca.gov/.

The prototype eligibility materials (application, letters to households, notification letters, media release, verification) for F/RP meals or free milk are located on the CDE SNP Eligibility Materials Web page at http://www.cde.ca.gov/ls/nu/sn/eligmaterials.asp.

SNP Income Eligibility Scales are located on the CDE Rates, Eligibility Scales, and Funding Web page at http://www.cde.ca.gov/ls/nu/rs/.

Contact Information

If you have questions regarding this MB, please contact your SNP county specialist. The SNP county specialist list is available in the Child Nutrition Information and Payment System Download Forms section, Form ID Caseload.