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SNP FAQ: Verification, Direct Certification, P2

This page contains frequently asked questions (FAQ) to assist with School Nutrition Program (SNP) operators with Verification, Direct Certification, and Provision 2 (P2).

On November 2, 2020, the U.S. Department of Agriculture (USDA) released Policy Memorandum SP 04-2021, CACFP 03-2021, SFSP 03-2021. This Policy Memorandum includes questions and answers intended to provide clarification to State agencies and program operators of the National School Lunch Program (NSLP), School Breakfast Program (SBP), Seamless Summer Option (SSO), Summer Food Service Program (SFSP), and the Child and Adult Care Food Program. View the USDA Nationwide Waiver Questions and Answers #3.

Some School Nutrition Program highlights covered in the USDA Policy Memo include:

  • Question #7—Verification: All local educational agencies (LEA) that collected school meal applications during School Year (SY) 202021 are required to conduct verification. The USDA has extended the verification deadline to February 28, 2021.

  • Question #8—Provision 2 base year: Schools that operated SFSP/SSO for all or a portion of SY 202021 will not have complete base year counting and claiming data to establish claiming percentages. Therefore, schools will be unable to establish Provision 2 base years in SY 202021.

  • Question #11—Direct certification: Regardless of operational status, all NSLP participating LEAs are expected to conduct direct certification with SNAP (CalFresh in California) at least three times per year.

The Nutrition Services Division (NSD) recognizes the challenging shift in operational processes this guidance imposes on LEAs. Please refer to the frequently asked questions below to assist with your operations.

Frequently Asked Questions
Verification
  1. We plan to operate SSO/SFSP the entire SY and previous guidance from NSD stated we do not have to complete verification. What do we do now?

    Per USDA policy memorandum SP 04-2021, LEAs that collected meal applications will need to complete verification no later than February 28, 2021.

  2. Our LEA collected some meal applications at the start of the SY, but retroactively claimed all meals under the SSO/SFSP. Are we required to complete verification?

    Yes. Per the USDA Policy Memo SP 04-2021, all LEAs that collected school meal applications are required to complete verification no later than February 28, 2021.

  3. Our LEA is operating SSO/SFSP for the entire school year and we have not collected any meal applications for SY 2020–21, what are we to do with verification?

    LEAs that did not collect any meal applications for the 2020–21 SY are not required to complete verification.

  4. Our LEA collected meal applications and then switched to collecting alternative income applications. Do we have to complete verification?

    Yes, verification must be conducted for school meal applications. Alternative income applications are used to determine income eligibility for local control funding formula (LCFF) purposes and are not subject to verification procedures.

Provision 2 base year
  1. We were approved to establish a Provision 2 base year in SY 2020–21. We plan to operate NSLP all year, do we need to establish a new base year in the following school year?

    No, Provision 2 schools that operate NSLP the entire school year will have sufficient data to establish a base year in SY 2020–21 and will not be required to reestablish in SY 2021–22. However, Provision 2 schools that operated SSO/SFSP for all or part of the school year, will need to reestablish a base year in SY 2021–22.

  2. We were approved to establish a Provision 2 base year in SY 2020–21. If we operated SSO/SFSP for all or part of the school year do we need to reapply to establish a new base year in SY 2020–21?

    At this time the NSD plans to automatically update SY 2020–21 approved Provision 2 cycles to begin a new base year in SY 2021–22. Provision 2 schools will be provided an opportunity to opt out should they no longer want to establish a base year in SY 2021–22.

  3. We were approved for Provision 2 streamlined base year. However, our collection of meal applications has been greatly reduced due to distance learning. How will this affect our base year?

    The NSD is considering options to assist schools with a streamlined base year. The solutions will depend on the individual circumstances of the LEA. Please consult your School Nutrition Programs analyst.

Direct Certification
  1. Why is direct certification required if we are operating SSO/SFSP all year?

    While eligibility determinations are not required for summer meal programs, USDA policy states that direct certification must be completed at least three times a year.

    The NSD supports the ongoing effort to complete direct certification because it supports the following: identified student population for the community eligibility provision; supplemental and concentration grant funding for LCFF; identified students to carry out the Every Student Succeeds Act; identified students for Medi-Cal enrollment; and other student benefits defined locally.

Contact Information

If you have any questions regarding this subject, please contact your School Nutrition Program (SNP) County Specialist. The SNP County Specialist list is available in the Download Forms section of CNIPS, Form ID Caseload. You can also contact the SNP Office Technicians, by phone at 916-322-3005 or 916-322-1450 to be directed to your SNP County Specialist.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Friday, November 6, 2020
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