2025-2026 School Year Income Verification Procedures

File Attachments: 

*Printer-friendly version of the full booklet is available in Word and in PDF.

School Food Authorities (SFAs) participating in the School Breakfast Program (SBP) and/or National School Lunch Program (NSLP) that are operating in the Base Year of Provision 2, in one or more schools, are required to select and verify a sample of their approved free and reduced-price meal applications on file as of October 1st by November 15th of this year. This process is called Income Verification and is a federal requirement that will ensure meal claims are based on accurate eligibility determinations.

This guidance manual contains important information on how to conduct Income Verification and includes template letters that should be used to correspond with families.

List of SFAs Required to Conduct Income Verification

SFAs that are required to conduct income verification are listed on the Income Verification website.

Verification Collection Report

All SFAs required to conduct income verification must complete and submit the Verification Collection Report on the Child Nutrition Management System (CNMS) by December 15, 2025.

SFAs operating the Community Eligibility Provision (CEP) or operating in a non-base year of Provision 2 SFA-wide are not required to conduct Income Verification or complete the Verification Collection Report.

Additional Resources

USDA Eligibility Manual for School Meals

USDA Verification Tool Kit

Income Verification & Verification Collection Report Snip-It

If you have any questions regarding Income Verification, please contact your Child Nutrition Program representative at 518-473-8781.

Attachments

It is recommended that Attachment A be sent to all households selected for verification. The other attachments are available to be used as needed.

Attachment A

Page 1 of 4: Letter to Households- Notification of Selection for Verification of Eligibility

Page 2 of 4: USDA Nondiscrimination Statement

Page 3 of 4: Adult Household Members

Page 4 of 4: Verification Information for Free and Reduced Price Benefits

Attachment B

Letter of Verification Results and Change in Eligibility

Attachment C

Letter of Change in Eligibility for SNAP/TANF/FDPIR Households

Attachment D

Notification of Continuation of Benefits as a Result of Verification

Attachment E

Verification Summary/Recordkeeping

Verification Collection Report and Instructions

School Food Authority (SFA) Verification Collection Report and Instructions

See Verification Collection Report for more information.

Verification Collection Report

File Attachments: 

Note: Please be sure to carefully read the Verification Collection Report Instructions at the end of this guidance to ensure the report is completed accurately.

SFAs must report all data elements requested on the Verification Collection Report in the Child Nutrition Management System (CNMS) by December 15th.

SED is required to analyze, summarize, and submit the results to USDA.

Failure to submit a completed Verification Collection Report by the required deadline, December 15, will result in your Child Nutrition Programs being placed on reimbursement hold.

Only USDA required elements are requested on the Verification Collection Report. Be sure you review it carefully to capture the required information that documents your SFAs efforts.  Carefully follow the directions for completing the form. 

Requests to extend the November 15th verification deadline must be submitted in writing to your Child Nutrition Program Representative at the State Education Department. All such requests must document extenuating circumstances beyond the SFAs control and should be received by the Child Nutrition Program office by October 15th.

A step-by-step tutorial on how to complete the Verification Collection Report is posted on the Child Nutrition Knowledge Center website. SFAs are strongly encouraged to review the tutorial when completing their report.

Introduction

Federal regulations require that all School Food Authorities (SFAs) participating in the School Breakfast Program (SBP) and/or National School Lunch Program (NSLP) and using standard counting and claiming procedures, including those operating base year of Provision 2, must select and verify a sample of their approved free and reduced-price meal applications on file as of October 1st by November 15th of each year. This process is called Income Verification.

Verification is only required when eligibility is determined through the application process, and is not required for eligibility determinations made through the direct certification process.

Verification must include either confirmation of income eligibility or confirmation that the child or any member of the household is receiving assistance under Supplemental Nutrition Assistance Program (SNAP), Food Distribution Program on Indian Reservations (FDPIR) or Temporary Assistance for Needy Families (TANF) or that a child is Other Source Categorically Eligible. Verification may also include confirmation of any other information required on the application, such as household size.

It is essential that verification efforts be completed on time, that changes in federal meal benefit status are implemented for all family members and that adequate records of your efforts are maintained. The selection of applications cannot target discrimination against anyone on the basis of race, color, national origin, age, sex, or disability.

Getting households to respond to verification requests can be challenging for SFA staff. If households do not respond, they lose their federal meal benefit status regardless of their actual eligibility. In addition, the number of approved applications an SFA is required to verify is impacted by the number of responses they were able to obtain the previous year.

To assist SFAs with addressing these issues, USDA has developed a Verification Toolkit. The Toolkit contains a collection of resources that SFAs can use in their efforts to improve verification response rates and the overall efficiency of the process. These resources were developed by FNS but feature input from State and local officials from around the country. They were informed by two years of formal studies conducted by FNS and the Office of Evaluation Science’s Social & Behavioral Sciences Team, as well as through a public contest and from informal conversations with program operators. To view the Toolkit, please visit https://www.fns.usda.gov/school-meals/verification-toolkit.

SFAs must report the results of the income verification process by completing and submitting the Verification Collection Report on the Child Nutrition Management System (CNMS) by December 15th.

How To Conduct Verification

Verification must be conducted for all schools operating in the base year of Provision 2.

Allow yourself enough time to complete the verification process by the required deadline.

Establishing the Sample Pool

To establish the sample pool, SFAs must count the number of approved free and reduced applications on file for the entire SFA as of October 1. The sample pool depends on the number of approved applications, paper or electronic, and is not based on the number of children eligible for free and reduced priced benefits. If October 1 falls on a weekend or a school break, use the next operating day to establish the sample pool.

SFAs have the option to begin verification prior to October 1, once they begin the application approval process for the current school year. This option may ease the administrative burden for particularly large SFAs who receive several household income applications. However, the sample pool must still be based on the number of applications on file as of October 1. See page 6 for additional details.

Applications submitted for “mixed households,” which include children who are eligible based on income and others based on Other Source Categorical Eligibility, are subject to verification and must be included in the sample pool.

Applications with case numbers that are not certified through direct certification are subject to verification and should be included in the sample pool.

Verification must take place after an application has been approved.

Do NOT include:

  • Households that are matched through the Direct Certification Matching Process (DCMP) for SNAP/Medicaid, and those students who have been identified as living in the same household as the certified student receiving SNAP/Medicaid benefits
  • Certification letters for SNAP/TANF from the local assistance agencies
  • Foster children who are identified by a list or letters from social services and voluntary placement agencies
  • Migrant children who have been identified by the district's Migrant Education Program
  • Runaway or homeless children who have been identified by the district's McKinney-Vento school district liaison
  • Children participating in federally funded Head Start/Even Start

Beginning Verification Prior to October 1

The National School Lunch Act states that verification must be based on a school’s sample size as of October 1 each school year.  However, SFAs are now allowed to begin verification once they begin the application approval process for the current school year and have approved applications on file. This means SFAs are not required to wait until October 1 to initiate the verification process and may instead choose to begin conducting verification once they begin the application approval process for the current school year.

When beginning verification prior to October 1, SFAs must:

  • Decide how often to sample applications (weekly, every other week, etc.)
  • Include in each sample pool only applications approved since the last sample was selected
  • Select either 3 percent or 1.5 percent of approved applications, as required by the sampling method, each time. Round down to the nearest whole number to prevent over sampling

On or around October 1:

  • Sample the final set of applications, selecting only from the applications approved since the last sampling
  • Calculate the number of applications selected for verification to date (including the October sample)
  • Calculate 3% or 3,00 (or 1.5%, if applicable) of all applications approved as of October 1, rounding up to the next whole number
    • If the number of applications selected to date is less than 3%/1.5% number, fill the remainder of the sample by selecting randomly from error prone, categorically eligible, or all applications, approved since the beginning of the school year as required for the sampling method
    • If there are not enough applications of the required type, then sample randomly from all applications

Please note that all existing statutory and regulatory requirements continue to apply when using this approach, but the timing and sampling process is tailored to accommodate the extended timeframe during which verification is being conducted.

Selecting Your Sample Size

Using the sample pool, SFAs will calculate the required sample size (number of applications that must be verified) using one of the following methods:

  • Error Prone (Standard) Sampling Method
  • Random Sampling Method (Alternate 1)
  • Focused Sampling Method (Alternate 2)

The Error Prone (Standard) Sampling Method must be used by an SFA unless it qualifies to use one of the alternate sampling methods.

When determining the sample size, regardless of the verification method used, SFAs must always round up to the nearest whole number. For example, if your sample size is 3.18 you must verify 4 applications. You may not verify any more or any less than the required sample size allowed.  Please note, at least one application must always be verified.

Error Prone (Standard) Sampling Method

New SFAs and SFAs that had less than 80 percent response rate to verification in the 2024-2025 school year MUST use the Error Prone (Standard) Sampling Method to conduct verification in the 2025-2026 school year.

For Error Prone (Standard) Sampling Method, SFAs must verify the lesser of three percent (3%) or 3,000 of the approved applications on file as of October 1. The applications to be verified must be selected randomly from applications that meet the definition of an Error Prone application.

*Error prone applications are those with a reported income within $24 per week, $100 per month, or $1,200 per year of the applicable Income Eligibility Guidelines.

If the SFA does not have enough error prone applications to produce a three percent (3%) sample, the SFA must use income applications and/or applications that report a SNAP/TANF/FDPIR number selected at random to meet the required sample size under the error prone sampling method. 

SNAP/TANF/FDPIR applications will not be selected unless there are too few applications that meet the error prone criteria.

Note: When approving applications, SFAs should flag those that meet the error prone definition (see definition above) in order to facilitate this process.

Alternate Sampling Methods (Random Method & Focused Method)

SFAs that had an 80 percent (80%) or greater response rate in the 2024-2025 school year may choose to select an alternate option for verification. These schools may choose to use the Error Prone Sampling Method (explained above) or may choose one of the following sampling methods:

Random Sampling Method (Alternate 1)

SFAs must verify the lesser of three percent (3%) or 3,000 of the total number of approved applications on file as of October 1. The applications to be verified must be selected randomly.  The random sample should include both income applications and categorically eligible applications for children receiving SNAP/TANF/FDPIR benefits whose names do not appear on the direct certification matching list.

Focused Sampling Method (Alternate 2)

SFAs must verify the lesser of one percent (1%) or 1,000 of the total number of approved applications selected from income applications nearest the income eligibility guidelines (error prone applications); PLUS the lesser of half percent (½ %) or 500 of approved applications which reported a SNAP/TANF/FDPIR case number on an application instead of income information.

Example:

The Focused Sampling Method could be accomplished as follows:

SFA with 900 approved applications which include 600 applications that reported a SNAP/TANF/FDPIR case number

  1. Count all approved applications, including applications reporting a SNAP/TANF/FDPIR case number to determine the number required to fill the one percent of income sample size

.01 (1%) x 900 = 9

  1. Separate applications into two groups:  
  • Income Applications (non-SNAP/TANF/FDPIR)
  • Applications reporting a SNAP/TANF/FDPIR case number
  1. From the income applications (non-SNAP/TANF/FDPIR) group, select the sample of households (9) from error prone applications. If you do not have enough error prone applications, select the remainder at random from the income applications.
  1. From the applications with a SNAP/TANF/FDPIR case number, determine the number required to fill the .5 percent sample size

.005 (.5 percent) x 600 = 3

  1. Choose the applications (3) from those that reported a SNAP/TANF/FDPIR case number.
  2. Perform the confirmation review on all selected applications and continue with all steps of verification.

*Note: 12 applications were verified in this example (9 income and 3 SNAP/TANF/FDPIR)

Confirmation Review

Prior to conducting any verification activity, an individual other than the original reviewing official must review each approved application selected for verification to ensure that the initial determination was accurate. The confirmation review must be done by an individual other than the individual who made the initial eligibility determination. A confirmation review is not required if the SFA uses a technology-based system that demonstrates a high level of accuracy in processing an initial eligibility determination.  

If an SFA is using “eligibility determining” software, it is the SFA’s responsibility to ensure that the "eligibility determining" software conforms to USDA regulations.

Depending on the outcome of each confirmation review, the SFA must take one of the following actions:

No Change in Status
  • Verifies the application
Status Change From Reduced Price to Free
  • Change the federal meal benefit status immediately
  • Notify the Household of change in federal meal benefit status
  • Verify the application
Status Change From Free to Reduced Price
  • Do not change the child’s status
  • Verify the application
  • Notify the household of the correct federal meal benefit status after verification is completed and, if required, send the household a notice of adverse action.
Status Change From Free or Reduced Price to Paid
  • Immediately send the household a notice of adverse action
  • Do not verify the application
  • Select a similar application (example- another error prone application) to verify
  • Begin the verification process with the newly selected application. The second reviewing official must review the application.

Replacing Applications

The SFA may, on a case-by-case basis, replace up to five percent (5%) of the applications selected for verification. Applications may be replaced when the SFA believes that the household would be unable to satisfactorily respond to the verification request.  The SFA must document why the application was replaced. Any application removed must be replaced with another approved application selected on the same basis (i.e., an error prone application must be substituted for a withdrawn error prone application). The newly selected application must then have a confirmation review prior to being verified. In those SFAs where five percent of total applications result in less than one, one application may still be replaced. All results of the five percent calculation are rounded up to the next whole number.

When an application is selected for verification and, prior to hearing back from the household in question, that household is found on a direct certification list, the application does not have to be replaced in the verification sample pool. The application would be marked as a direct certification in the appropriate box in Section 3 of the verification collection report. SFAs should include these applications in Field 5-5 (Number of applications selected for verification) of the verification collection report and indicate the number of these applications that are being converted to direct certification in the remarks portion of the verification collection report.

Notifying Households of Selection

When a household is selected for verification, the SFA must provide the household with a letter or an email if the parent or guardian contact information is known informing a household of its selection and must provide a list of the documents or other forms of evidence the household must submit to the SFA. When the SFA uses agency records or direct verification to confirm eligibility, a letter informing the household of its selection for verification is not required, as verification is completed. Please see the “Direct Verification” section of this booklet for more information on direct verification.

It is recommended that SFAs use the NYSED prototype “Letter to Households-Notification of Selection for Verification of Eligibility” letter (Attachment A) as this prototype letter contains all required information.

The notification letter must include:

  • An indication that the household was selected for verification
  • If a child’s federal meal benefit status is based on income, a list of the types of acceptable information that may be provided to confirm current income:
    • Pay stubs;
    • Award letters from assistance agencies for benefits such as Social Security or SSI; or
    • Support payment decrees from court
  • If a child’s federal meal benefit status is based on categorical eligibility, the household may provide proof that a child or any household member is receiving benefits under an Assistance Programs (SNAP/TANF/FDPIR) or that a child is Other Source Categorically Eligible instead of providing income information
  • A warning that information must be provided by a date specified by the SFA and that failure to do so will result in a change in federal meal benefit status
  • Notice that documentation of income or receipt of assistance may be provided from any point in time between the months prior to application and the time the household is required to provide income documentation
  • A modified Use of Information Statement as follows:

The Richard B. Russell National School Lunch Act requires the information requested in order to verify your children’s eligibility for free or reduced-price benefits. If you do not provide the information or provide incomplete information, your children may no longer qualify for free or reduced-price federal meal benefits.

  • Name of an SFA official who can answer questions and provide assistance
  • A toll-free number for parents to obtain assistance. This can be a local number within the district.  It cannot be a long-distance call
  • The full USDA Nondiscrimination Statement.

Note:  You do not need to collect social security numbers of all adults in the household as part of the verification process. Ensure all notification letters are updated and do not request this information.

Any communications with households concerning verification must be in an understandable and uniform format and, to the maximum extent practicable, in a language that parents and guardians can understand.

Verification of Eligibility

All applications selected for verification must be resolved.  All families selected must provide information that verifies or confirms their eligibility, or the families must be notified formally in writing that their federal meal benefit status will change.  Changes in eligibility must be updated at the point of service for all family members in the SFA.

Correctly approved applications are effective for the entire school year. If a family selected for verification submits information that confirms either their income or receipt of SNAP/TANF/FDPIR benefits for the time period beginning the month before they applied through the time the application is verified, the child's eligibility remains in effect. You may not change their status to reduced or paid if the family substantiates they were eligible for the free benefits when they applied.  This is true even if current income proves at the time of verification, they are no longer eligible.

Regardless of the Verification outcome, students must continue to receive school meals at no charge through the federal Provision 2 and NYS Universal Free School Meals program. 

Written Evidence

Written evidence is the primary source of eligibility confirmation for all households, including TANF, FDPIR, Other Source Categorical Eligibility Programs, and foster child households. Written evidence most often includes pay stubs from employers or award letters from assistance agencies or other government agencies.

Acceptable Written Evidence

Income Eligible

Contains:

  • The name of the household member
  • Amount of income received
  • Frequency received
  • The date the income was received

*A pay stub with no dates would be insufficient

Categorically Eligible:

Assistance Program

An official letter or notice indicating that the child or any household member is receiving benefits from that program, such as a notice of eligibility.

*A document from an Assistance Program that does not specify the certification period does not meet the documentation for verification.

*For example, the identification cards for SNAP or TANF would be insufficient unless it contains an expiration date.

Categorically Eligible:

Other Source

An official letter, notice, or list from the appropriate State agency, social service agency, program office or coordinator, or court.

Note: Tax returns may be used to verify income of self-employed household members ONLY. 

When a Household Provides Pay Stubs

Households may provide pay stubs with income from employment. If a weekly pay stub is representative of what the household normally receives each week, one pay stub is sufficient.

If the household submits a pay stub that includes overtime, the determining official should work with the household to determine whether the overtime for the month being verified is representative of overtime received in other months. If the overtime is a one-time or sporadic source of income, income should be calculated based on the regular monthly income without overtime.

Indication of “No Income”

If a household is selected for verification, or the application is being verified for cause and the application indicates zero income, the SFA must request an explanation of how living expenses are met and may request additional written documentation or collateral contacts.  For example, the collateral contact may be asked to document the duration and type of assistance that is provided to the household.

Collateral Contacts

A collateral contact is a person outside of the household who is knowledgeable about the household’s circumstances and can give confirmation of a household’s income level or participation in Assistance Programs or Other Source Categorical Eligibility Programs. Collateral contacts include employers, social service agencies, migrant workers’ agencies, and religious or civic organizations. The verifying official should request a collateral contact only in cases when the household has not been able to provide adequate written evidence.

The verifying official must give the household the opportunity to designate the collateral contact. However, the verifying official may select a collateral contact if the household fails to designate one or designates one who is unacceptable to the verifying official. In either case, no contact may be made without first notifying the household and obtaining its permission. At the time of the notice, the household may consent to the contact or provide acceptable documentation in another form. If the household refuses to choose one of these options, the household’s federal meal eligibility will be terminated in accordance with normal verification procedures. Households which dispute the validity of information acquired through collateral contacts or a system of records must be given the opportunity to provide other documentation.

All collateral contacts may be written or oral and must be documented, dated, and initialed. The SFA will examine any written information provided by the collateral contact or evaluate any oral information. If the collateral contact is unwilling or unable to provide the requested information, the SFA must contact the household to complete the verification process.

Foster Children

If a household application is selected for verification in which a foster child is listed as a family member, and State or local documentation certifying the foster child for free meal benefits has been provided to the school, then only the family income or SNAP/TANF/FDPIR case number must be verified for the other students listed on the application.

If the family application is the only form of certification for the foster child, then documentation verifying the foster child’s status would be required.  Documentation from a State or local foster agency or the court where the foster child received placement is acceptable for verification.

SNAP/TANF/FDPIR

Verification consists of confirming current receipt of SNAP (only for children not found in the direct certification matching process), TANF or FDPIR benefits for each child/household listed. If at least one member of the household confirms receipt of SNAP/TANF/FDPIR, the remainder of the children residing in the household shall remain eligible through confirmation of school enrollment records. Verification of eligibility for households that provided an Assistance Program case number on the application may be accomplished by submitting a list of names and Assistance Program case numbers to the local SNAP or assistance office for confirmation of certification of receipt of benefits from agency records or by directly verifying eligibility using the Direct Certification Matching Process (DCMP) data. Please see the “Direct Verification” section of this booklet for more information.

It is essential to cooperatively discuss and work out a mutually effective and efficient means for handling requests for verification of current SNAP/TANF participation by school officials and school meal applicants with local SNAP/TANF agencies. Please note local SNAP/TANF agencies may not be able to provide this service. The SFA is encouraged to first utilize the DCMP data prior to conducting direct verification with local SNAP/TANF agencies.

Note: EBT cards cannot be used to confirm eligibility in SNAP or TANF.

Direct Verification

 

Direct verification is a method that can be used to confirm eligibility for verification. Direct verification uses records from public agencies to verify assistance program participation which can help reduce the burden upon families and eliminate non-responders. Results of Direct Verification must be reported on the School Food Authority Verification Collection Report.

SFAs are not required to conduct direct verification but are encouraged to utilize this method. Direct verification was put in the federal law to make it easier for eligible families to retain benefits and is an excellent means to address the non-response rates of households selected for verification. It is not an opportunity to run a computer check for all children in your school.  Direct verification should be used only to check students selected in your verification sample.

Direct verification must be conducted prior to contacting the household for documentation. Direct verification can be used for the sample selected for verification via the error prone method, the random sample, or the focused sample. SFAs must have security measures to ensure the confidentiality of the information.

SFAs will conduct the direct verification process by using the Direct Certification Matching Process (DCMP) data. Direct certification electronic records will provide data for the current school year and will be available to authorized users of the New York State Student Identification System (NYSSIS).

To directly verify students using the direct certification matching system SFAs must:

  • Have a username and password to access the SED Business Portal with entitlements to the NYSSIS system
  • Search the direct certification data by last name or date of birth for a specific student that was selected for verification
  • If the student is found on the list, the student is eligible for free benefits. Verification is considered complete and further documentation is not needed from the family to confirm eligibility.
  • If the student is not found on the direct certification list, you must continue verification efforts. You must notify the family that they have been selected for verification and request documentation to confirm eligibility.
  • Keep a record of directly verified students on file for 3 years plus the current year 

Verification of eligibility for households that provided an Assistance Program case number on the application may also be accomplished by submitting a list of names and Assistance Program case numbers to the local SNAP or assistance office for confirmation of certification of receipt of benefits from agency records.

If information provided by the public agency does not verify eligibility or if you are not able to find the student through the direct certification matching data, the SFA must proceed with regular verification activities. The SFA must complete direct verification immediately following the October 1 verification sample selection, so that households not directly verified can be contacted for verification information in a timely manner.

If information obtained through this process verifies that the household is participating in an assistance program no additional verification is required. The eligibility status of the child or children listed on the application is considered verified and a letter informing the household of its selection for verification is not required.

When an application is selected for verification and, prior to hearing back from the household in question, that household is found on a direct certification list, the application does not have to be replaced in the verification sample pool. The application would be marked as a direct certification in the appropriate box in Section 3 of the verification collection report. SFAs should include these applications in Field 5-5 (Number of applications selected for verification) of the verification collection report and indicate the number of these applications that are being converted to direct certification in the remarks portion of the verification collection report.

 

Verification Follow-Up

To continue the verification process subsequent to household notification, the SFA must either determine:

  • If the household has submitted adequate information to complete its individual verification activity; or
  • If follow-up with the household is needed

Following Up with Households

SFAs must make at least one attempt to contact the household when the household does not adequately respond to the request for verification. The required follow up can be done in writing (letter or e-mail), or by telephone or text message. The SFA must document that contact was attempted and ensure the LEP households are provided adequate language assistance and understand the need to respond to the verification request.  Please see the “Non-Responders” section of this booklet for steps to take if a family does not respond to verification.

The SFA must make a follow-up attempt when the household:

  • Does not respond to the initial request for verification
  • Submits insufficient or obsolete written evidence
  • Does not designate collateral contacts
  • Collateral contacts are unable or unwilling to provide the requested evidence

When following up with households, the SFA:

  • Must inform the household that failure to provide adequate written evidence or to designate an adequate collateral contact will result in termination of federal meal benefit status
  • Must attempt to obtain the missing written evidence or collateral contact information
  • Must contact the household to complete the verification process, if the collateral contact is unwilling or unable to provide the requested information

SFAs are encouraged but not required to do additional follow-up attempts if a household fails to provide adequate documentation after the required follow-up. If the household does not respond or fails to provide adequate documentation after the required follow-up and, if applicable, additional follow-ups, verification is considered complete for the household when notice of adverse action is sent.

Results of Verification

If, after at least one follow-up attempt, the household responds and provides all needed evidence, verification is considered complete for this household.

The SFA would complete verification by:

  • Informing the household that there is no change in federal meal benefit status;
  • Notifying the household that its federal meal benefit status will be increased; or
  • Sending notice of adverse action

It is recommended that SFAs use the NYSED prototype letters of verification results as these prototype letters contain all required information.

  • If verification results in higher benefits (e.g., a child who is moved from reduced price to free category), the change is effective immediately and must be implemented no later than 3 operating days.
  • All households for whom their federal meal benefit status is to be reduced or terminated as a result of verification must be given 10 calendar days advance written notice of the change.

Note: If a family’s federal meal benefit status are reduced as a result of verification (e.g., because they failed to respond or did not submit sufficient information to substantiate their income) and during the school year the family re-applies, the SFA must verify the new application prior to the family being approved for federal meal benefits.  If the family refuses to provide the required information, their free or reduced-price federal meal benefit status must be denied.

Non-Responders

Any household which fails to submit requested verification documentation by the date specified by the SFA or submits verification information which does not support the initial determination of eligibility, must be sent a notice that their federal meal benefit status will be reduced or terminated in 10 calendar days. Please see the prototype “Letter of Verification Results and Change in Eligibility.”

SFAs must take the following actions if the household fails to cooperate with verification efforts:

  • SFAs must follow up with families who do not respond to initial verification efforts with at least one attempt in writing (including to a parent or guardian’s email) or by telephone or text message. All attempts must be documented and ensure that LEP households are provided adequate language assistance and understand the need to respond to the verification request.  Additional follow up after this is encouraged but not required.
    • SFAs may contract with a third party to make additional attempts to follow up with non-responders.
  • Prior to actual reduction in federal meal benefit status or termination of federal meal benefit status, 10 calendar days advance written notification must be provided to the household.
    • The first day of the 10-calendar day advance notification must be the day the notice is sent to the household.
  • The notice must advise the household of a change in federal meal benefit status, reason for the change, the right to appeal and that an appeal must be filed within the 10 calendar days advance notice period to ensure continued federal meal benefit status while awaiting a hearing and decision, how and when the appeal must be filed, and that the household may re-apply to change their federal meal benefit status.
    • If the household provides information that confirms their eligibility within the 10 calendar days, the family’s federal meal benefit status must continue.
    • If there is no response, the federal meal benefit status must be terminated on day 11
  • Reductions or changes in federal meal benefit status must be extended to all children in the household who were originally determined to be eligible by information that no longer supports the federal meal benefit status.
  • Households that appeal the reduction or termination of federal meal benefit status within the 10-calendar day notice must continue in the original federal meal status until the decision of the hearing official is made.  

When Verification is Considered Complete

The following demonstrates how an SFA determines whether or not the household adequately responded and whether follow-up is required.

  • The household submits either adequate written evidence or collateral contact corroboration of income or categorical eligibility:
    • Verification is considered complete for this household;
  • The household submits either adequate written evidence or collateral contact corroboration of income which indicates that the child(ren) should receive either a greater or lesser federal meal benefit status:
    • Verification is considered complete for this household when the notice of adverse action is sent, or household is notified that its federal meal benefit status will be increased or decreased;
  • The household indicates, verbally or in writing, that it no longer wishes to receive a free or reduced-price federal meal benefit status:
    • Verification is considered complete when the notice of adverse action is sent;
  • The application provides case numbers, and it is determined that no household member is receiving benefits from an Assistance Program:
    •  Verification is considered complete when the notice of adverse action is sent.
  • The household does not respond or fails to provide adequate documentation after the required follow up or the household refuses to cooperate with verification efforts.
    • Verification is considered complete when the notice of adverse action is sent.

Verification Recordkeeping

The SFA must retain all documents submitted by the household or duplicates of those documents, including all relevant correspondence between the SFA and households. You may document and/or note information directly on the application when contacting families for further information.  A separate sheet of paper can also be attached. If the documents cannot be kept, the verifying official must make a written record of the documents submitted. Copies of all relevant correspondence between the households selected for verification and the school must be maintained with program records for three years plus the current year.

For each application verified, SFAs must maintain records documenting:

  • The source of information used to verify the application
    • Documentation may include a wage stub or documentation from employer or collateral contacts
  • Any changes in federal meal benefit status as a result of verification, including:
    • the changes
    • the reason for the changes
    • date the changes were made
    • records of follow-up attempts and results

Program regulations also require SFAs to maintain a description of their verification activities.

This includes:

  • the total number of applications on file as of October 1
  • a summary of the verification efforts, including the selection process
  • the percentage and number of applications that have been verified
  • the SFA must also be able to demonstrate compliance with the confirmation review requirement and provision of a no-cost telephone number for assistance in the verification process

Verification for Cause

The procedures discussed above refer to the required verification process. Applications that are verified “for cause” are in addition to the annually required verification process. SFAs have an obligation to verify all questionable applications (verification “for cause”). SFAs must verify any questionable application including, on a case-by-case basis, verifying any application for cause when the SFA is aware of additional income or persons in the household.

Only after the federal meal benefit status determination has been made can the SFA begin the verification process. Determining officials are strongly encouraged to contact the household during the certification process to clarify any information that is unclear or questionable, before certifying the application and proceeding with verification for cause. Once households have been requested to provide documentation for cause, the SFA must complete the verification process for these households.

It is important to note that the restriction on sample size does not apply to a State’s ability to conduct application verification activities connected to its general oversight responsibilities. For cause may include, but is not limited to, situations where school officials have knowledge of household circumstances that would cause them to verify the information on the application.

SFAs should follow the verification procedures outlined above when verifying an application “for cause”.

If the household fails to submit requested verification information by the date specified by the SFA or submits verification information that does not support the initial determination of federal meal benefit status, the household must be sent a notice of adverse action to terminate the free or reduced federal meal benefit status.

The number of applications verified "for cause" and the results of verifying those applications must be reported on the Verification Collection Report (Question VC1). The applications “verified for cause” do not contribute toward your required sample size for the annual verification requirement. Please read the Verification Collection Report Instructions carefully.

Verification for Cause of School District Employees

Verification for cause must not be used to automatically verify the households of all SFA employees whose children are certified for free or reduced-price federal meal benefits.  However, from among the list of children approved for free or reduced-price federal meal benefit, an SFA could identify children of SFA employees and use SFA salary information available to them to identify questionable applications and then conduct verifications for cause on those questionable applications.

SFAs can use verification for cause to review approved applications for free or reduced-price federal meal benefits when known or available information indicates SFA employees may have misrepresented the income on their applications to receive free or reduced-price federal meal benefit statuses for their children.  USDA recommends that an SFA consult with legal counsel in establishing the parameters of verification for cause for school district employees.

Verification Questions and Answers

1. What if an application is selected for verification, but the household transfers out of the SFA before the information can be verified?

Verification is considered complete when a household's eligibility for the level of benefits for which it was approved is either confirmed or the household is sent a letter of change in federal meal benefit status.  If a household selected for verification transfers out of the SFA before the information can be verified, verification cannot be completed. To meet the minimum verification requirements, a new application must be selected.

2. How is overtime income counted for the purpose of verification?

The school official should work with the household to determine whether the overtime for the month being verified is representative of overtime received in other months.  If the overtime is a one-time or sporadic source of income, it should not be used in calculating regular income.

3. Am I verifying eligibility at the time of application or current eligibility?

Verification is intended to establish eligibility for any point in time between the months prior to application and the time the household is required to provide income documentation.  However, if the family income decreases making them eligible for increased benefits, then the school should verify current income.

4. If a household is paid weekly and submits a pay stub for a week, must I go back and ask for pay stubs for a whole month?

No.  If the weekly pay stub is representative of what the household normally receives each week, one pay stub is sufficient.

5. Must the SFA select the sample size to verify from each school within the SFA or from the SFA as a whole?

SFAs are required to select and verify a sample of their approved free and reduced-price applications SFA wide. The SFA as a whole must meet the required sample size requirement. This does not mean that each school has to verify the required number of applications.

6. If my sample size is 4.2 applications, do I verify 4 or 5?

Decimals must always be rounded up to the next whole number.  Therefore, you must verify 5 applications.

7. Do we have to maintain the actual documentation from verification or just the results of verification?

You are required to maintain a description of your verification efforts including the selection process, the total number of applications on file as of October 1, and the number of applications that were/will be verified by November 15th. For each application verified, the SFA must keep records of the source of information used to verify the application such as wage stubs or names and titles of collateral contacts. In addition, the applications selected must be readily retrievable by school, and the SFA must document correspondence between the selected households and the school.  The verification official must retain the documents, a photocopy, or annotations that indicate which documents were submitted by the household and the date of submission.  You must also keep a record of any change in eligibility as a result of verification procedures, the reason for the change, and the date the change was made. Please also see the “Recordkeeping” section of this manual and the “USDA Eligibility Manual for School Meals” for additional information on record keeping requirements.

8. When a notice of adverse action has been sent to a household, may I claim reimbursement for that child during the period covered by the notice?

Yes.  The household must be given 10 calendar days advance written notice that a change is being made in the child's federal meal benefit status.  During that time, the child’s original federal meal benefit status must continue and the SFA may continue to claim reimbursement for meals served to the child in the original federal meal benefit status during this period.

9. If an SFA chooses to select more than 3 percent or the minimum number of required households to verify, and some of those households fail to respond, has the SFA completed the verification requirement as long as 3 percent or the minimum number of required households respond?

No. First, the SFA cannot select any more or any less applications than the 3% sample size determined based on the method of verification performed. Second, all households selected for verification must either respond or have benefits terminated after appropriate notification.

10. If an application contains three sources of income, how many should be verified?

All three sources of income must be verified.  All sources originally noted by the family at the time of application must be verified.

11. What if the SFA forgets to do verification?

Verification is an annual requirement.  We will contact an SFA that has not submitted the Verification Collection Report by the required deadline of December 15th each year.  If income verification is not completed, the SFA jeopardizes its State and federal reimbursement for free and reduced meals served after November 15th of that school year.

12. When should an application be verified "for cause"?

If an SFA is informed, even anonymously, that an applicant may not be eligible, the SFA must follow up on the allegation using the verification process.  The SFA has an obligation to verify all questionable applications (applications that are reported to be fraudulent or suspicious). Verification that is done for cause is in addition to the sample required for either error prone/random/focused sampling.  Verification must take place after the application was approved on the face value of the application.

13. What information must be submitted online to the Child Nutrition Program office by December 15th?

All information reported on the Verification Collection Report must be reported on the on-line form on the Child Nutrition Management System (CNMS).  All other verification documentation, along with a copy of the verification worksheet, must be kept on file for three years plus the current year.  SFAs in Provision 2 must retain all verification information from the base year for three years plus the current year after the end of the cycle.

14. If a foster child is listed on a family’s application as a household member and that household happens to be selected for verification, does the school need anything extra for verification?

It depends on the situation.  If a household is chosen for verification and the foster child included on the application was identified by a State or local foster agency, then no additional verification is needed for the foster child. However, to verify the other children in the household, the family must provide verification documentation to confirm eligibility.

If the foster child is not identified by a State or local foster agency, then documentation verifying the foster child’s status would be required. Additionally, to verify other children in the household, the family must provide verification documentation to confirm eligibility.

15. What documentation must be provided for a foster child listed on a household application that is selected to be verified?

Documentation from a State or local foster care agency or the court where the foster child received placement is acceptable for verification.  Direct contact from the foster care agency or court (for example, a list of foster children sent to the SFA) is also acceptable documentation for verification.

16. What should I do if a family was approved for free meals based on a SNAP number but sends in a paystub for verification that makes them ineligible?

The SFA should first conduct direct verification to confirm the family’s eligibility for SNAP. If the SFA cannot verify eligibility through direct verification, they should contact the family to determine if they can document their SNAP eligibility for the month prior to submitting their application.  If they can document their eligibility at that time, the free benefits must continue, and verification is complete. If the required SNAP documentation is not provided, the income stub must be used to determine their eligibility.

17. What if I receive an application for a child and then receive the child's name on a list from either the Migrant Education Program Coordinator or Homeless Liaison?

The list from the Migrant Education Program Coordinator and Homeless Liaison supersedes the application. The application should be discarded and should not be included in determining the number of applications on file. The child should not be selected for verification.

SFAs Required to Conduct Income Verification

SFAs that are required to conduct income verification are listed below.



SFA LEA Code SFA Name
130801996542 Anderson Center For Autism
500308990003 Arc Rockland Co Chap Prime Time
660405030000 Ardsley UFSD
222201155866 Augustinian Academy-Elementary
580101030000 Babylon UFSD
342800226480 Bais Yaakov Academy For Girls
342700226221 Bais Yaakov Ateres Miriam
280215226664 Bais Yaakov Of The Five Towns
332100229811 Barkai Yeshivah
580505020000 Bayport-Blue Point UFSD
660102060000 Bedford CSD
280207020000 Bellmore UFSD
280253070000 Bellmore-Merrick Central HS District
010306060000 Bethlehem CSD
280521030000 Bethpage UFSD
342700228636 Bnos Bais Yaakov Of Far Rockaway
331300996473 Brooklyn Independent
520101060000 Burnt Hills-Ballston Lake CSD
661201060000 Byram Hills CSD
280411030000 Carle Place UFSD
250201060000 Cazenovia CSD
010100997850 Center For Disability Services
661004060000 Chappaqua CSD
620600997425 Childrens Home Kingston Grove St Aca
140203806578 Christian Central Academy
140801060000 Clarence CSD
500101060000 Clarkstown CSD
580402060000 Cold Spring Harbor CSD
580410030000 Commack UFSD
441600229607 Congregation Mesifta Ohr Hatalmud
580507060000 Connetquot CSD
471701040000 Cooperstown CSD
571000808888 Corning Christian Academy
440301060000 Cornwall CSD
660202030000 Croton-Harmon UFSD
400400136417 Desales Catholic Elementary School
660403030000 Dobbs Ferry UFSD
140301030000 East Aurora UFSD
490301060000 East Greenbush CSD
580234020000 East Moriches UFSD
280219030000 East Rockaway UFSD
280402030000 East Williston UFSD
580912060000 Eastport-South Manor CSD
421800997437 Elmcrest Childrens Center
261301060000 Fairport CSD
421001060000 Fayetteville-Manlius CSD
280222020000 Floral Park-Bellerose UFSD
280217020000 Franklin Square UFSD
280218030000 Garden City UFSD
440601040000 Goshen CSD
141501060000 Grand Island CSD
280407030000 Great Neck UFSD
260501808815 Greece Christian School
320800716855 Greek American Inst Of NY
010802060000 Guilderland CSD
480401040000 Haldane CSD
141601060000 Hamburg CSD
580406060000 Harborfields CSD
660501060000 Harrison CSD
660404030000 Hastings-On-Hudson UFSD
580506030000 Hauppauge UFSD
280227227943 Hebrew Academy of Nassau County
280215227128 Hebrew Academy-Lower School
280409030000 Herricks UFSD
261101060000 Hilton CSD
081200185526 Holy Family School
260901060000 Honeoye Falls-Lima CSD
141301060000 Iroquois CSD
660402020000 Irvington UFSD
280515030000 Jericho UFSD
310200630024 Jewish Child Care Assoc Of NY
662300990001 Julia Dyckman Andrus Memorial Inc
660101030000 Katonah-Lewisboro UFSD
150601040000 Keene CSD
580805060000 Kings Park CSD
010100115705 La Salle School
151102040000 Lake Placid CSD
141901060000 Lancaster CSD
280205030000 Levittown UFSD
400301060000 Lewiston-Porter CSD
580603021005 Little Flower Children's Services
280503060000 Locust Valley CSD
280220030000 Lynbrook UFSD
280407226666 Magen Ephraim Sephardic Academy
480101060000 Mahopac CSD
660701030000 Mamaroneck UFSD
280406030000 Manhasset UFSD
310300226796 Manhattan Day School
421101060000 Marcellus CSD
280523030000 Massapequa UFSD
332100225701 Mazel Day School
280215226038 Mesivta Ateres Yaakov-Gr Long Island
342700226097 Mesivta Shaarei Chaim
580208020000 Miller Place UFSD
660801060000 Mt Pleasant CSD
580207020000 Mt Sinai UFSD
280405020000 New Hyde Park-Garden City Park UFSD
180300877197 New York State School For The Blind
151001040000 Newcomb CSD
530301060000 Niskayuna CSD
280204020000 North Bellmore UFSD
010623060000 North Colonie CSD
280229020000 North Merrick UFSD
661301040000 North Salem CSD
280501060000 North Shore CSD
280407226636 North Shore Hebrew Academy
420303060000 North Syracuse CSD
530600998000 Northeast Parent & Child Society
580404030000 Northport-East Northport UFSD
180300137112 Notre Dame High School
280211030000 Oceanside UFSD
141800137227 Olv Human Services - 777 Ridge Rd
142301060000 Orchard Park CSD
342400640003 Outreach Development Corp
280506060000 Oyster Bay-East Norwich CSD
010100996557 Parsons Child And Family Center
500308030000 Pearl River UFSD
661601030000 Pelham UFSD
261201060000 Penfield CSD
261401060000 Pittsford CSD
280518030000 Plainedge UFSD
280504060000 Plainview-Old Bethpage CSD
660809030000 Pleasantville UFSD
660802040000 Pocantico Hills CSD
580206020000 Port Jefferson UFSD
280404030000 Port Washington UFSD
131500010000 Poughkeepsie City SD
641401040000 Putnam CSD
480503040000 Putnam Valley CSD
142801137104 Queen Of Heaven School
131801040000 Rhinebeck CSD
261600997046 Rochester School For The Deaf
280221030000 Rockville Centre UFSD
280403030000 Roslyn UFSD
661901030000 Rye Neck UFSD
580305020000 Sag Harbor UFSD
140203136333 Saint Peter & Paul School
321000226424 Salanter Akiba Riverdale Acad
580504030000 Sayville UFSD
530501060000 Schalmont CSD
280501890176 Sco Family Of Services
280206030000 Seaford UFSD
310200226718 Sephardic Academy-Manhattan
030200185471 Seton Catholic Central Jr/Sr High
091101159175 Seton Catholic School
520302060000 Shenendehowa CSD
580601040000 Shoreham-Wading River CSD
421601060000 Skaneateles CSD
580801060000 Smithtown CSD
400900806712 Solid Rock Academy
662101060000 Somers CSD
500301060000 South Orangetown CSD
131602020000 Spackenkill UFSD
471101997806 Springbrook New York, Inc
142601136293 St Amelia School
010100997791 St Catherine'S Center For Children
141604136402 St Francis High School
140203136273 St Gregory The Great School
400701325766 St John Lutheran School
140101136379 St John The Baptist School
142601136418 St John The Baptist School
141901136283 St Mary'S Elementary School
580801177172 St Patrick's School
401001060000 Starpoint CSD
400301136253 Stella Niagara Educ Park
500304998107 Summit School
280502060000 Syosset CSD
580201060000 Three Village CSD
342700226701 Torah and Language Academy
280300206622 Torah High School Long Beach
142801325775 Trinity Lutheran School
660302030000 Tuckahoe UFSD
660805030000 Valhalla UFSD
490804998235 Vanderheyden Hall
260501996191 Villa Of Hope
011003060000 Voorheesville CSD
280223030000 Wantagh UFSD
442101060000 Warwick Valley CSD
261901060000 Webster CSD
420101060000 West Genesee CSD
580509030000 West Islip UFSD
440901996121 West Point Middle School
661100226120 Westchester Torah Academy
140203060000 Williamsville CSD
490804020000 Wynantskill UFSD
280215229558 Yeshiva Ketana Of Long Island
342500229646 Yeshiva Ketana Of Queens
321000229709 Yeshiva Ohavie Torah of Riverdale
310600226845 Yeshiva Rabbi S R Hirsch
280214226407 Yeshiva Toras Chaim - South Shore 2
590501226115 Yeshiva Zichron Mayer
332100227684 Yeshivah Of Flatbush ES
662402060000 Yorktown CSD