Sample Size for Annual Verification

This Management Bulletin (MB) transmits new information on National School Lunch Program (NSLP) verification requirements resulting from the Child Nutrition and WIC Reauthorization Act of 2004 (Public Law 108-265). The United States Department of Agriculture’s (USDA) guidance memo regarding this information, SP 27-2006, is available at http://www.fns.usda.gov/sites/default/files/SP_27-2006.pdf. [Note: the preceding web address is no longer valid.]

New Verification Guidance

1. School Food Authorities (SFAs) can no longer choose to verify 100 percent of approved Applications for Free and Reduced-Price Meals.
   
   Note: As in the past, SFAs must continue to verify all questionable applications (for cause). Any verification conducted “for cause” is in addition to the sample required for error-prone, random, or focused sampling.
   
   
2. The number of applications an SFA verifies cannot exceed the basic sample size or alternate sample size. (See below for sample size information.)

Amendments to Verification Provisions

Since September 2005, the California Department of Education (CDE), Nutrition Services Division (NSD), has conveyed through bulletins and trainings that the Child Nutrition Reauthorization Act of 2004 (Public Law 108-265) made several changes in the annual process to verify NSLP meal applications. One of the changes pertained to how districts select and determine the number of the free or reduced-price meal (F/RP) applications to verify.

For verification guidance, please refer to 2005-06 NSD training materials, NSD Verification Alert #1, and USDA’s verification guidance at the following USDA Web pages:

1. Reauthorization Implementation Memo SP-9, November 19, 2004
   http://www.fns.usda.gov/sites/default/files/2004-11-19.pdf [Note: the preceding web address is no longer valid.]
2. Reauthorization Memoranda - Fiscal Years 2004 and 2005
   http://www.fns.usda.gov/cnd/Governance/Reauthorization_Policy_04/Reauthorization_04/Reauthorization_2004.htm [Note: the preceding Web address is no longer valid.]
3. School Meals Policy Memoranda
   http://www.fns.usda.gov/school-meals/policy

Summary of Sample Sizes

Basic Sample Size

The basic sample size for verification continues to be the lesser of 3 percent of all approved applications on file as of October 1 or 3,000 applications. As of July 1, 2005, the basic sample must be drawn from approved error-prone applications (applications that list household income within $100 below the monthly or $1,200 below the annual F/RP eligibility guidelines for that household size). If there are not enough error-prone applications to comply with the required sample size, SFAs must randomly select additional applications to fulfill the percentage or number requirement.

Qualifying to Use an Alternate Sample Size

In lieu of the basic sample size, SFAs may be able to use one of two alternate sample sizes. To do so, an SFA must meet the following conditions:

• SFA has 20,000 or fewer students approved for F/RP school meals as of October 1, AND the non-response rate (the percentage of approved household applications selected for verification for which the SFA did not obtain verification information by November 15) for the preceding school year as of November 15 is less than 20 percent; OR
• SFA has more than 20,000 children approved for F/RP school meals as of October 1, AND the non-response rate for the preceding school year as of November 15 is at least 10 percent below the verification non-response rate for the second preceding school year.

Alternate Sample Size

SFAs that meet the above qualifying criteria can choose to verify applications using one of two alternate sample sizes:

• Random Sampling: Verify 3 percent or 3,000, whichever is less, of all approved applications on file on October 1.
• Focused Sampling: Verify 1 percent of all applications selected from error-prone applications or 1,000 error-prone applications, whichever is less, AND verify the lesser of .5 percent (½ of 1 percent) or 500 applications approved based on categorical eligibility (the application included a case number to indicate participation in food stamps, California Work Opportunities and Responsibility to Kids [CalWORKs], Kin-GAP, or Food Distribution Program on Indian Reservations [FDPIR]).

For more information on verification sample sizes, refer to USDA’s Reauthorization Implementation Memo SP-9, dated November 19, 2004, at http://www.fns.usda.gov/sites/default/files/2004-11-19.pdf. [Note: the preceding web address is no longer valid.]

If you have any questions regarding this MB, please contact your Nutrition Services Division Child Nutrition Consultant in the Field Services Unit at 916-445-0850 or 800-952-5609. You may also contact Sabina Kohls, School Nutrition Programs Specialist, at 916-324-9876 or by e-mail at skohls@cde.ca.gov.