Record Keeping (Specialty Sites)
In section two we will be discussing recordkeeping requirements for specialty sites. Specifically Closed enrolled, camp, and migrant sites. In order to determine that a migrant site is eligible you must obtain documentation from Homeless/Migrant Coordinator shows that at least 50% of children served at the sites are from migrant families. Migrant sites, may serve up to 3 meals per day with State Agency Approval and they receive reimbursement for all children served (if not operating closed enrolled or camp skip to next section).
For Closed Enrolled sites and Camps each child that you claim must be enrolled or registered. To show that each child is enrolled, you must have an updated enrollment record. If you are claiming meals served to a child that doesn’t have an completed and current enrollment record, we would have to take back all of the money that you received in reimbursement for that child’s meals. On a review, we will go through 100% of your enrollment records to verify that all of the children being claimed have the enrollment records needed. Before you submit your claim each month, you’ll want to be sure that you have an updated enrollment record for each child that is being claimed. For Closed enrolled sites located in an area eligible area no income eligibility forms are required. If a closed enrolled site is not area eligible then at least 50% of the children enrolled must qualify for F/R meals and have a correctly approved IEF for each child they list as qualified or have obtained Income Eligibility information from the child’s school. If a closed enrolled site continues to enroll participants throughout the summer they must maintain 50% F/R qualification.
Next we’ll move on to Income Eligibility Forms. We refer to these as IEFs. The IEF is how you’ll determine whether a child qualifies for based on the Free or Reduced income guidelines or IEGs. For the Summer Program there is only one rate for reimbursement so if a family meets the free or reduced guidelines they are considered program eligible. Closed enrolled and camp sponsors may obtain eligibility information from the School Food Authority where the child attended school during the school year. Documentation such as an e-mail or letter from the SFA on kept on file may be used in place of an IEF. Children enrolled in Headstart are automatically eligible for F/R price meals. Documentation listing qualifying children can be obtained from the Headstart and kept on file as proof of eligibility. For camps any child that you are claiming at the free or reduced price rate needs to have a current and complete IEF or documentation of eligibility. Eligibility information must be obtained and approved prior to claiming meals.
New IEFS are released each year in July. The SFSP uses the same form as do Child care centers and School Sponsors. All household children are listed in step 1 above and you will mark yes or no if the child listed is enrolled in your program. Once the parent completes the IEF and gives it back to you, you must approve the IEF and make sure that the children on the IEF are being claimed in the correct benefit category. There are two ways an IEF can be approved: Categorically or by income. A “Categorical” IEF is determined when there is at least one of three case numbers included on the IEF. The first of the three case numbers is Supplemental Nutrition Assistance Program (SNAP) case number, SNAP used to be called Food Stamps. The second is a Family Employment Program (FEP) case number; this number is issued if assistance is given from DWS. The third number is a case number given from the Food Distribution Program on Indian Reservations (FDPIR). The second way to determine an IEF is through the total household income and the number of persons in the household.
A categorical IEF must have three areas filled out. The first being the children enrolled in child care. The 2nd is the case number. Only one number needs to be listed, even if there is more than 1 child enrolled that has a case number. A case number would need to be listed, not just the word SNAP. If a number such as a Medicaid, Social Security #, Horizon Card Number or any other number is listed other than the 3 qualifying case numbers, then that number would not qualify the family as categorically eligible. If a family fills out the IEF with a case number other than the SNAP, FEP, or FDPIR you would talk to the parent about this to clarify the requirements. With that said, your roll is not to “police” case numbers, you should take the IEF at face value. You don’t need to see proof from DWS of a case number. The 3rd and last area to be completed is the parent/guardian signature.
Enrolled Headstart children categorically qualify automatically. You would not need to include a case number in this instance. However if other children, who are not enrolled in Headstart, are on the IEF those children would need a corresponding case number or would need to qualify by household income in order to be claimed at the free or reduced price rate. This also applies the same with foster children. They automatically qualify in the same way as a Headstart child; a parent would check foster child and the child automatically qualifies categorically for free meals, but if there are other children on the IEF, they would need to qualify with their own case number or by household income. Keep in mind that this applies only to children who have been placed by the state in a foster care situation. An unofficial family guardianship situation would not apply.
In addition to determining their income correctly, you would need to ensure that the following information is completed in order to approve an IEF correctly by income: List of all enrolled children, List of all household members found, Income of all household members How much total income and how often paid, Signature of the parent or guardian, Last 4 digits of the social security number of the parent or guardian. We’ll go through an example of an IEF. In this example, it’s showing how to complete the IEF electronically. You’re welcome to print off the IEFs and have the parent complete a hard copy.
Once you have determined you have a complete income IEF you will compare the income and frequency listed to the federal Income Eligibility Guidelines, which are often referred to as IEGs. As you can see, the IEGs are in a table format so that you can compare the family size to the amount of income. If the family’s income is greater than that listed in either the free or reduced ranges for their household size they would not be considered income eligible for the Summer Food Service Program. IEG’s change every year starting on July 1st. Make sure that you’re using the current IEGs. For children and campers enrolled prior to July 1st they are approved for the duration of the summer. You do not need to re-determine eligibility as of July 1st. However if a site continues to enroll new children or campers throughout the summer you would use the new eligibility guidelines starting July 1st.
Our office has an IEF calculator which is an excel workbook that can help you to determine if a household qualifies when multiple incomes or income frequencies are listed. We have included this calculator in your list of handouts. Please be aware that this calculator expires on June 30th and a new form would need to be obtained from our office each year.
An IEF is not complete unless it has your approving signature and date. If we came out on a review and saw an IEF for a child being claimed was fully completed by the parent, however not signed and dated by the sponsor, we would have to disallow all meals served to that child. This could even make a site that was barely 50% completely ineligible for the SFSP. An IEF is good from the beginning of the month in which it is signed and expires at the end of the same month the following year. For example if an IEF is approved May 26 then it applies starting on May 1st and will expire on May 30th of the following year. Also each year a new IEF must be completed, not just updated. You can’t require a parent to fill out an IEF.
We’ll go through some frequently encountered situations that we see. If a parent does not fill the IEF out completely then you would not count the child as income eligible until the complete information is received and you are able to fully approve the form. Keep in mind that if there is missing information on an IEF you may call the parent and add information from the information gathered from the phone call; if information is added, a date, initial, and source should be included with the added information to the IEF. For example, the parent turns in an IEF. When you go to approve it, you realize that even though you know this child goes to head start, the parent didn’t mark the head start box. You could call and confirm with the parent that it’s ok for you to check this box, then you would put your initials, the date, and “phone” by the box that you check. Once done, the IEF is completed and can then be approved.
If an IEF has expired, the child is ineligible until a new IEF has been completed by the parent/guardian and has been approved by the sponsor. What if the family income has changed? If a family’s income has changed, they are not required to complete a new IEF if their current IEF has not expired. However, if their changed income now qualifies the child(ren) for the reduced-price or free rate, you can encourage the family to complete a new IEF. Again, however, they are not required to do so if their current IEF has not expired.
A few last tips and reminders with IEFs. It’s not infrequent for us to see issues with IEFs when we go out on reviews, so please take special care with IEFs. Remember that every child being claimed complete and current IEF. Each IEF must be signed by the parent/guardian and the approving official to be valid. There are a lot of details with IEFs that need to be completed. For this reason, we would suggest that you have a second set of eyes looking at the IEFs. The second individual would go through the same approving process as the first to make sure that it was approved correctly. Each year, a new IEF must be completed, the parent can’t simply initial and date the previous year’s IEF. Last but not least, IEFs contain very sensitive information and must be kept confidential. Only those who approve IEFs should have access to them. Make sure that you keep the IEFs in an area that is not accessible to everyone. A locked filing cabinet in the directors office is an example of a secure place for the IEFs.
In addition to the IEF, there are instructions and a parent letter that you will need to distribute to the parents. You’re welcome to print these off and give them to each parent along with the IEF, you’re welcome to email them. If you have any questions or would like information on where to find additional training on any of the topics discussed in this section please contact our office.
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