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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. 

Last updated
September 23, 2022

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In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity.

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  1. mail:
    U.S. Department of Agriculture
    Office of the Assistant Secretary for Civil Rights
    1400 Independence Avenue, SW
    Washington, D.C. 20250-9410; or
  2. fax:
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