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 determination of eligibility 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 eligibility, the household must be sent a notice of adverse action to terminate the free or reduced meal benefits.

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 meals.  However, from among the list of children approved for free or reduced-price meals, 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 meals when known or available information indicates SFA employees may have misrepresented the income on their applications to receive free or reduced-price meals for their children.  USDA recommends that an SFA consult with legal counsel in establishing the parameters of verification for cause for school district employees.