Understanding WCPSS's Participation in the National School Lunch and Breakfast Programs
Wake County Public School System (WCPSS) participates in the National School Lunch and Breakfast Programs and is, under the provisions of that program, required to make meals available to all students who wish to participate. In addition, free and reduced-price meals must be made available to students who are eligible. In the process of implementing the programs, WCPSS must make sure that: students are treated fairly; students receiving benefits are not segregated or overtly identified; the names of students receiving benefits are not disclosed outside federal regulations; students are not discriminated against; and households are given rights to appeal and have fair hearings.
The United States Department of Agriculture (USDA) establishes policies and procedures for the National School Lunch and Breakfast Programs. In North Carolina, the programs are administered through the North Carolina Department of Public Instruction (NCDPI). Within WCPSS, the Child Nutrition Services Department (CNS) is responsible for administration of the national School Lunch and Breakfast programs. Annually the superintendent must execute an agreement with the USDA stating that WCPSS will participate in the programs.
The USDA establishes guidelines for determining eligibility for receipt of free or reduced-price lunch and breakfast, based upon the parents’ or guardians’ income levels. Currently, if the annual income is less than 130 percent of the poverty level as defined by USDA (the level varies according to family size), the family is eligible for free meals; if the annual income is less than 185 percent of the poverty level, the family is eligible for reduced-price meals.
In administering the programs within WCPSS, the CNS Department has two distinct and separate functions: 1) the application process; and 2) the verification process.
The application process begins when NCDPI sends updated policy information, generally in late May or June, depending on when it receives information from USDA. The changes to the policy documents from year to year are minor, but all new materials are provided on request for school system use if needed. Any local changes or revisions made in any area of policy must be submitted for NCDPI approval prior to use in the school system.
WCPSS informs families of Child Nutrition Programs through media releases and letters that are sent home with the Application for Free and Reduced-Price Meals. In North Carolina, DPI’s Child Nutrition Services issues a statewide media release that meets the requirements for all sponsors. WCPSS sends to year-round and modified school administrators a “Letter to Households”, along with the “Free and Reduced-Price Meal Application,” for students to take home on the first day of school (due to the short time between receipt of DPI’s information and the start of school, letters are not mailed to each household). The Letter to Households contains an income eligibility chart for the free and reduced-price meal eligibility, and is provided in both English and Spanish. The same information is mailed to each household of students attending traditional schools. The applications that are mailed are preprinted with student names and NCWISE numbers. WCPSS uses personnel proficient in foreign languages to provide assistance in completing these forms. Parents or guardians are responsible for filling out the application and returning it to the school or CNS office; USDA regulations do not require proof of income with the application form.
While many students obtain eligibility for free or reduced-price meals through applications, about one-fourth of WCPSS’ eligible students are automatically qualified for free meal benefits as “direct certified” students. The Wake County Department of Human Services (DHS) sends WCPSS a file of all students in the county whose parents or guardians receive benefits. The families receive a letter in July notifying them of their status and stating that their children may bring home an Application for Free and Reduced-Price Meals at the start of school--just like every other student--but that they are to disregard the application, unless there are additional students in the household not named in the letter.
When applications are received in the CNS processing center, they are reviewed for completeness and accuracy, computer-scanned into the software program, and automatically determined to be free, reduced or denied. The system generates letters that are mailed to the families, and overnight the system communicates the students’ status to the school sites so that meal benefits may begin immediately. Status is given for the entire school year and that status is honored for the first 15 days of the following school year. If a student’s status should change and the student become no longer eligible for free or reduced-price meals, the parents are given a ten-day notice to begin paying for meals. Parents may apply or re-apply for benefits at any time during the school year. Parents or guardians enrolling a child in a school for the first time shall be supplied with appropriate meal application materials regardless of the time of the year the child is registered. If a child transfers from one school to another under the jurisdiction of the same Local Education Agency, his/her eligibility for free or reduced-price meals will be transferred to and honored by the receiving school. While USDA requires that applications and documentation of determinations made be maintained for a period of three years following the end of the school year to which they pertain, CNS retains records for five years.
USDA has established a prescriptive process for verification of families’ eligibility to receive free or reduced-price meals. The verification activity must begin on October 1 and must be completed by November 15 of each year. The number of applications verified must, at a minimum, be the appropriate percentage of the number of applications on file district-wide as of September 30. The school system may pull additional family applications to verify for cause, if there has been a reported suspicion of false information on an application. The first step in the verification process is for the CNS staff to review applications for duplication and for any students who may have withdrawn from the school system since the time that applications were submitted and the time that verification takes place.
The method of verification is a “focused sample”, which means that CNS must verify three percent of all approved family applications with household incomes within $1,200 of the annual eligibility limit, which varies depending on family size. The sampling is selected by computer. Households with food stamp or Work First benefits are not selected for verification, because proof of income is provided to DHS. Administrators in schools determine if a student is classified as migrant, runaway, or homeless and notifies CNS, which maintains a file of those students who are directly certified by one of these status types. Students in these categories are not selected for verification.
CNS maintains a rigorous verification process, which includes: verification letters sent to the sampling of families, along with a list of required documents and a self-addressed envelope; second letters sent to non-responders; and telephone calls made to families who fail to respond to the second letters. Parents or guardians are responsible for returning proof of income by the November 15 deadline. If parents or guardians fail to respond or are unable to provide adequate verification of their income, they are removed from eligibility for free or reduced-price meals. In some instances, the parent’s or guardian’s income information may substantiate a change in eligibility between the free and reduce-price categories of eligibility. Documentation is entered into the computerized system and status determined automatically. Copies of documents are maintained for a period of five years following the end of the school year to which they pertain. The computer system generates a letter notifying the parents of any change in status. Ten days are given for the family to begin sending money for meals if a change occurs. On November 16, any children in families that do not respond to the verification process are removed from the program and must pay full price for meals. Verification information is forwarded to NCDPI. Applications may be filed at any time during the year; parents or guardians who are denied benefits due to failure to respond to verification must provide the documents required before another application will be processed.
It should be noted that the three percent sample of approved applications is not a sample that is representative of the entire number of students approved as eligible for free or reduced-price meals, because it is focused on only those students whose annual family income is within $1,200 of the cut-off amount—the range that may be most prone to errors. The rate of errors in this sample cannot be extrapolated to the entire number of students determined to be eligible. While some applicants may knowingly provide incorrect data on the application for free and reduced-price meals, many applicants may not return the verification form or may make honest errors as a result of: change in income or number of family wage earners between dates of application and verification; inability to understand or intimidated by an official form; inability to read or to calculate monthly or annual income; or lack of documentation to support income.
NCDPI reviews WCPSS CNS’ application and verification processes annually, and every five years conducts an extensive Coordinated Review Effort audit. WCPSS has a history of accuracy in application and verification processes. The reviews have shown that CNS staff is familiar with the correct way to handle all the written records and tasks associated with managing the eligibility determination for free and reduced-price meal benefits.