TECHNICAL ASSISTANCE NOTE
No. 2006-06
School Business Services
Food and Nutrition Management
Contact: Robin Miles-
Tennille
Department of Education
John L. Winn,
ommissioner
C
Verification Confirmation Reviews – Reauthorization 2004:
Implementation Memo – SP 18
(850) 245-9253
SC 205-9253
DATE:
January
3
0, 200
6
TO:
Sponsors of the National School Lunch and School Breakfast Programs
FROM:
Diane Santoro, Administrator
Food and Nutrition Management
SUBJECT:
Verification Confirmation Reviews – Reauthorization 2004: Implementation
Memo – SP 18
This document supports the mission of Florida’s K-20 education system to increase the proficiency of
all students within one seamless, efficient system. Through this and other modes of assistance, the
office of Food and Nutrition Management (FNM) supports the State Board of Education’s goal to
deliver quality, efficient services (Section 1008.31(3), Florida Statutes).
The United States Department of Agriculture (USDA), Food and Nutrition Service (FNS), issued the
following guidance on verification confirmation reviews. This guidance states, “Section 105 of the
Child Nutrition and WIC Reauthorization Act of 2004 (Public Law 108-265) amended section 9(b)(3)
of the Richard B. Russell National School Lunch Act (NSLA) by adding subparagraph (E), which
addresses confirmation activities. The NSLA now requires that local education agencies (LEAs)
review all applications selected for verification prior to conducting any other verification activity.
The law uses the term
preliminary review.
To avoid confusion, [the USDA/FNS has opted to call] it a
confirmation review
because its purpose is to check the accuracy of the initial eligibility
determination. This provision became effective July 1, 2005.”
The purpose of this technical assistance note is to clarify USDA’s position on what should take place
when a confirmation review finds an error in the eligibility determination after a household has been
notified of its status. This guidance also concerns the timing of the confirmation review and is
intended to reinforce the verification guidance already set forth in the FNS implementation memo,
“Verification Activities
,
” SP-13, dated March 10, 2005.
The additional guidance below is reprinted from USDA memo regarding verification confirmation
reviews dated September 27, 2005.
DIANE SANTORO, ADMINISTRATOR
FOOD AND NUTRITION MANAGEMENT
325 W. GAINES STREET • SUITE 1014 • TALLAHASSEE, FL 32399-0400 • (800) 504-6609 • www.fldoe.org
Suncom 205-0460 • FAX (850) 245-9263• diane.santoro@fldoe.org
Technical Assistance Note 2006-06
January
3
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Page 2
Conducting a confirmation review
•
This review must be conducted by someone other than the person who made the initial
determination.
•
Please note that, as reported in our March 10, 2005
,
memo [FNM’s Technical Assistance Note
#2005-38], the confirmation review requirement may be waived if the LEA has a technology-
based system that demonstrates a high-degree of accuracy. Any LEA that has an automated
system for processing applications must contact the State agency (your area representative) to
determine if its system qualifies.
Timing of a confirmation review
The confirmation review can occur in one of two ways:
1.
It can occur immediately after the initial review and consequently be part of the certification
process. This would be the practice in schools that routinely double check the determination
of all applications before implementing the eligibility determination.
2.
The other approach would be to do the confirmation review as part of the verification process,
and only do a double check on those applications selected for verification. In this situation the
household has already been notified of the eligibility decision. When the confirmation review
is part of the verification process, the following requirements apply:
Timing of notification to the household of its changed eligibility status
•
If the confirmation review indicates that the new eligibility status is to the household’s
benefit, the LEA should make the change as soon as possible and proceed with
verification.
•
If the confirmation review shows that there should be a decrease in benefits, the LEA
proceeds with and completes verification before any notification of a new eligibility status
is given. These procedures are designed to avoid a possible unnecessary reduction in
benefits.
Verification notice
•
The verification notice requirements are not changed by adoption of the confirmation
review; that is, the verification notice continues to explain that the application was
selected, to detail the process and required documentation, to assign a deadline for receipt
of documentation, and to provide a no-charge phone number to call for assistance.
Technical Assistance Note 2006-06
January
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0, 200
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Adverse Action
•
Schools must continue to follow adverse action requirements as appropriate when
verification activities result in a reduction of benefits or should the household fail to
cooperate with verification efforts, as detailed in 7 CFR 245.6a(e).
If there are any questions concerning this policy, please contact Robin Miles-Tennille at
(800) 504-6609 or robin.miles@fldoe.org.
DS/IW/set