School Nutrition Program Online Application Webinar

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School Nutrition Program Online Application Webinar

okay Sean can you guys hear me through
the conference call line for Kelly Kelly is just getting on the line, Lynette just a second Yepp, I can hear you okay okay I’m gonna go ahead and mute
everybody on the conference call line okay good afternoon
we’ll go ahead and get started my name is Lynette Osner I’m a child nutrition
consultant for the school team this afternoon we are going to be conducting
the online application webinar for school year 18-19 our purpose today is to
cover the requirements and responsibilities of using an online
application for child nutrition program benefits, by the end of this webinar you
will have the tools to understand the requirements of online applications, ask
software vendors to ensure compliance with state and federal regulations, test
for proper functionality of your online application and to ensure
confidentiality. Our agenda today will be to discuss confidentiality, the required
skills of the online application determining eligibility, administrative
review implications related to the online applications and how to complete
the online application review process with the Child Nutrition and Wellness team
at KSDE. Any sponsor looking to use an online
applications of child nutrition program benefits must accept full responsibility
for the software chosen. USDA policy memo SP 12-2006 was clear that pursuant to
federal law each sponsor is responsible for proper program management, accurate
income eligibility applications and claims, maintenance of confidential
information in a secure manner and ensuring that computer and software
programs function properly. It also states that each sponsor is
responsible for guaranteeing the accuracy of any electronic application
technology which includes electronic signatures and of its claims for
reimbursement as well as for ensuring that free reduced price
eligibility information remains confidential. What this policy means is
that it is the sponsor’s responsibility to ensure that the system is following
all state and federal regulations it is not the responsibility of the software
vendor, at the end of the very it is the sponsor who will be liable if the system
is not meeting requirements. As with paper applications record
retention requirements apply, all free reduced-price applications including
applications from households determined ineligible for benefits must be kept on
file for a minimum of three years after the final claim is submitted
for the fiscal year to which they pertain. When selecting an online
application system sponsors very responsible for ensuring that records
are accessible as needed even if switching software vendors. Some
questions you may want to ask your software vendors
it’s how they ensure that the sponsor will maintain access to the application
even if the software agreement is terminated or not renewed. Maintaining
confidentiality of free/reduced eligibility information must be of the
utmost importance to all sponsors of child nutrition programs this is also
true when applications are available online sponsors are responsible for ensuring
that vendors understand confidentiality requirements and should test systems
periodically to make sure that confidentiality features within the
software are activated and functioning properly. as a reminder in fact the disclosure of
participant information may result in a fine of up to $1,000 or
imprisonment of up to one year or both even if the software system is
improperly disclosing information it is the sponsors who is
liable it is very important to understand how the participants
confidential information is protected by the system and to test the system to
ensure that it is operating correctly A commonly asked question is if a
sponsor contract with a third party server to store electronic applications
through confidentiality and disclosure requirements still applies the answer
would be yes confidentiality and disclosure requirements surrounding the
school meal applications applies regardless of the application type the
information must be protected and only moved and or released according to
guidelines. Sponsors that contract with a third party must have an agreement in
place that clearly delineates FNS requirements for eligibility for
confidentiality and that comes straight out of the eligibility manual for school
meals. Regardless of how a family qualifies for program benefits the
sponsor must obtain informed consent before providing eligibility information
to the district for additional benefits often times we see additional benefits
such as textbook fees, activity fees or sports fees. Remember that it is the
sponsor’s legal duty to ensure the position of not disclosing confidential
information and improper disclosure may result in a fine of up to $1,000 or up
to one year of prison time or both Individuals from the sponsor can
face fines and imprisonment for improper disclosure of information, it is
important to ask detailed questions regarding how the computer system
handles confidential information, a few questions that could be asked include
how the system ensures that program benefits are kept confidential, what
settings are built into the systems to allow for sharing of eligibility
information when appropriate, how can I be sure no one can find a student’s free
or reduced status within the system and how does the system knows that gets
waived fees and who doesn’t, it is recommended that not only should the
sponsor ask questions such as these but the sponsor should also periodically
check their systems to ensure that proper confidentiality is maintained page 81 of the USDA eligibility manual
for school meals says that electronic applications must contain the
information required of all applications next we will look at what is required
for an application what is optional and what cannot be on
an application. All applications both paper and electronic must contain the
use of information statement, in Kansas federal program language regarding the
Supplemental Nutrition Assistance Program also known as SNAP or the
Temporary Assistance for Needy Families must be replaced with the Kansas
language for SNAP the use of information statement should use the term food
assistance with the abbreviation of FA and for Temporary Assistance for Needy
Families the use of information statement should use the term temporary
assistance for family with the abbreviation of CAF and on this slide we
give you the sole of information statements and we will
post handouts of the slides either here shortly or at the end of the
presentation. Questions that you could ask your software vendors: does the
online application include the use of information statements and how does a
sponsor make it reflective of state specific language, an attestation
statement is also required on both paper and electronic applications the
attestation statements must be included included directly above the signature
blocks of the finding adults to certify the person finding that’s providing true
information the application is being made in connection with receipt of
federal funds that school officials may verify the information on the
application and deliberate misrepresentation of the information may
subject applicants to prosecution under state and federal statutes. Questions to
ask your software vendor about the attestation statement could include
does the online application include the attestation statement what is the
exact language of the attestation statement used within the system and
does the attestation statement meet federal requirements as with a paper application the online
application must provide a space to identify the case number of any
household members who receive benefits from an assistance program assistance
program language must match the state program language so that is what we
talked about a couple slides ago so instead of snap it needs to reflect
food assistance or FA and then also temporary assistance for families which
is the abbreviation of PAS so a questions that you could ask your
software vendor would be how does how do you as the sponsor makes the case number
fields reflect the state specific information the online application has
also provided space to indicate status and the other source categorical
eligibility programs such as migrant homeless runaway or foster program paper
applications must include a field for reporting the total number of members
present in the household a web-based application may accomplish this by
requiring household confirmation of a total computed by the
application this is an accountability safeguard and encourages the household
choice for all members who are present electronic applications may be exempt
from explicitly following this requirement if they otherwise ensure the
household has been given a clear opportunity to report all household
members it looks like we have a question about can we just use the applications
provided by KSDE I think you’re probably talking about our Excel application that
we provide to help you determine benefits you can certainly use that to
double check online applications that have been submitted or paper
applications but we don’t allow you to publish that to be used for an online
application so hopefully that answered that question if not maybe when we open
the phone lines and unmute everybody you can provide further clarification if the
question was intended to be something different okay questions to ask your
software vendors about the total household member reporting field would
be how the system handles the total household members reporting field
is it by manual entry that the house will have to enter the total in their
household or does the system automatically calculate that number and
have the household certify the number that the system is calculated all
applications both paper and electronic must survey the children’s race and
ethnicity although answering these questions is optional they must be
included on all forms of the application be sure to ask software vendors about
whenhow household surveys when and how our households surveyed about race and
ethnicity so a question for your vendor would be when in the application process
are they surveyed about their ethnicity and races of the children a great feature
of online applications is the ability to omit questions that we not pertain to
the household application this makes the application process easier and faster for
many families however sponsors must be aware of which fields are required and
which fields are not for example only households applying on the basis of
income are required to provide the last four digits of an adult household member’s social security number or indicate that they do not have a social
security number households that applied based on a categorical eligibility
status only cannot be required to provide this information sponsors should
test various scenarios within their system to make sure households are not
being required to fill out more information than necessary dependent
upon the application type so we would encourage you to run multiple types of
applications through your online application software so that you can
ensure that it’s functioning properly and not requiring more information than
it needs to with regards to additional fields some systems will help with the
matching households and families within the student information system they may
ask for a student identification number or a child’s birth date however the
household must be informed that these data fields are not required by the
National School Lunch Program school breakfast program or school special milk
program since it is not a required field for a child certification of eligibility
the applicant must still be able to advance through and submit the
application without submitting information in those fields so on page
82 of the eligibility manual they have this commonly asked question may web
based application system ask for a student identification number or student
birthdate and they provide you the answer of a web based application system
may ask for a student identification number research student birth dates if
they sponsor notified possible to see two data fields are not required by the
lunch breakfast or special milk program your sponsor also must ensure a
paper-based application is available to households who do not wish to provide
the additional information this notification should be included on the
webpage portal the disclaimer should indicate
the availability of a paper-based application and provide a contact number for further assistance as we mentioned before sponsors are responsible
for testing their systems to ensure that households are not being required to
answer additional questions or complete fields that are not required by USDA
common fields included would be the birth date of a child
the school of attendance or the grade level of the child any letters with a
household the applicants are notified that leaving an income field blank is an
intentional signal of zero income page 79 of the eligibility manual recommends
that incomplete responses in income field or any other required fields
present the application from progressing or making a submission in these cases it
is also recommended to include an error or warning message to indicate what
information is missing and if possible direct the applicant to field where
that information must be submitted sponsors should test how the system
processes applications with machine information required fields should not
be able to be left blank and non required fields to never be required
different types of applications have different required field, sponsors again
must understand the different requirements and test the computer
systems for various scenarios another commonly asked question and this is from
page 21 of the eligibility manual is may schools include income eligibility
guidelines for free school meals in addition to including the reduced
price to income eligibility guidelines when sending out the application and descriptive materials the answer would be no the application and any descriptive
materials distributed to the household may only contain income levels for
reduced-price school meal eligibility this requirement is statutory sponsors
should ask software vendors about when in their program applicants are able to
view the income eligibility guidelines for the online applications sponsors
should also review the income eligibility guidelines as they appear to households and ensure that they match the reduced-price guidelines for the upcoming
program year notification of approved application households must be notified
either in writing or verbally of their child’s eligibility status within 10
operating days of receiving the application sponsors are permitted to
communicate the written notification via email to the adult household members who
signed the application the eligibility manual states that if a computer system
is used the system can be used to capture the original date of approval
benefit level of each child and the basis for determination the system may
also be used to update the status of applications to
account for transfers withdrawals terminations and other changes a
notation such as the date and initial should be made to an electronic file notifying households of denied
applications federal regulation states that if a household provides an incomplete
application or does not meet the eligibility criteria for free or
reduced-price benefit the application must be denied the sponsor must document
and retain the denied applications and reasons for ineligibilities for three
years the notification may be provided by mail or email to the adult household
member who signed the application posting the denial of the notification
phase of an online system does not meet this requirement so if they would submit
an online application and be denied you would still have to notify them via mail
or email and I believe they need to retain their denied applications and
documentation that should have been for five years instead of three questions to
ask your software vendors how does the system notify households their
application has been submitted does the system provide immediate approvals or
denials to the households upon submission of an application sponsors are required to also take
reasonable steps to ensure meaningful access for individuals with limited
English proficiency failure to do so may result in the sponsor discriminating on
the basis of national origin applications should contain a notice
informing individuals with limited English proficiency or disabilities of
how they can get assistance completing the form so a question for your software
vendors would be where’s the notice for individuals with limited English
proficiency it is important to be sure that the application includes this
information sponsors should walk through their own application and ensure that an
LED notification is provided to all households during the application process other requirements for online
applications include having the letters of household to inform the household how
to access the system in order to apply for benefit the letter must also explain
the household still has the option to submit a paper application from the
school and must indicate how the household may obtain and submit a paper
application from school the application must contain the information required of
all applications the system must include a question or data field to indicate a
child’s migrant runaway foster or homeless status it must provide
households with instructional materials similar to those included with prototype
application and it also must include the full USDA non-discrimination statement thorough testing of online
systems can help sponsors ensure that their online applications meet
federal requirements it is important to understand how the required parts of the
system work both as the administrator of the software but also as a household
what experiences software vendors should be able to explain how the letters to
hospitals is generated and displayed in the system and what to do with the
information and the letters of the household needs to be changed sponsors
needs to know what data fields exist in the system and be able to determine if
the appropriate fields are being required or if they’re not being
required sponsors are also responsible for ensuring the full USDA
non-discrimination statement is displayed to the household during each
online application process and so these are some questions on your slide that
could be asked of your software vendors to help you gain a better understanding
of your online application so moving on to what online applications may
have with online applications the sponsor may but keep in mind that you’re
not required to prefill an application with data other than income data from
the prior year or from another school source this can be beneficial to
households filling out information that there can also be pitfalls questions to
ask software vendors include what if any data is prefilled from previous
applications or some other data sources and how is the data matched to the
appropriate household application if an online application utilizes pre-filled
data field caution must be used to ensure that it only that it is only
appropriate fields are populated income can never be pre filled for a
household this data makes matching can sometimes be tricky it is important to
allow systems to pre-fill data that has been
thoroughly tested especially if one system is importing data from another
source consider how data might be prefilled in a situation with students
who are members of multiple households there’s also important to note as those
paper applications online applications may not require a separate or multiple
applications for each child and mixed household that includes children who are
other sorts categorically eligible and children to apply based on household
income they may not require a household to submit an application and it may not
request additional information to determine eligibility for other programs
if the information requested creates a real or perceived barrier to
participation in the child nutrition program and it also may not request the
applicant provide information regarding citizenship some online applications
determine eligibility while others are only used to collect application data
and then the sponsor manually determines the eligibility the next section
outlines what needs to be considered when using an application that
determines eligibility for the sponsor as a basic starting points online
applications must determine eligibility using the same method as
required when determining eligibility based on a paper application those
online applications are required to follow the same determination processes
as manually processing an application this same income conversion factors
apply so if you have a weekly income listed it would be x 52 if you have
bi-weekly income listed it will see x 26 multiply the month income by 24 and monthly
by 12 and you would only convert in common sources if more than one income
source of income frequency is listed the eligibility manual does state that
sponsors cannot use conversion factors such as 4.33
to convert weekly income or 2.15 to convert by weekly income to monthly
amount if the sponsor uses software or applications for certification purposes
the software cannot use conversion factors and cannot automatically convert
income unless there are different frequencies the questions that you could
ask your software vendors would be how the system converts income for
applications with multiple income frequencies it is important that
sponsors communicate to software vendors the requirements for calculating income
and understand how the system handles income conversions the frequently asked
question in the eligibility manual is if a sponsor uses a computer system to
generate eligibility determination must the determining official sign or
initial each application the answer is the sponsor is ultimately responsible
for determining eligibility for free or reduced meals the sponsor must
ensure their computer system meets all requirements and performs all functions
as outlined in this guidance with a high degree of accuracy the determining
official may sign or initial and date a separate sheet of paper that could then
be attached to a batch of applications alternatively the official may make a
note to the electronic file the computer system should be able to capture the
original date of the approval and the basis for determination such as that it
was approved based on household size and income
and then you can update the status of applications to account for transfers withdrawals terminations and any other changes and now we will discuss
administrative review implications the eligibility manual clearly states that
USDA and FNS do not currently evaluate recommend approve or endorse any
software used for certifications or verification purposes
sponsors are responsible for assuring that any automated certification and
verification processes meet all regulatory requirements and policies
including the calculation of household income when multiple frequencies are
reported as a reminder online applications are a part of the sponsor
certification and benefit issuance process
this means the applications collected online fall within in a critical area of the
administrative review and it and are a part of performance standard one from
the administrative review manual the KSDE must ensure that the sponsor is in
compliance with federal regulation this law outlines the general requirements for
applications eligibility and certification of children for free and
reduced-price meals and milks errors found in this area of the administrative
review can trigger fiscal action the final section of our webinar today will
cover how to complete the online application review process with
Child Nutrition and Wellness the first step is to complete form
7F the request to use the online application for child nutrition program
benefits this form can be found in Chapter seven of food service facts on the website signatures from the sponsored food
service directors, director of technology and legal counsel we will not be
accepting any scanned copies of the for this year since we have to have original
signatures anyways it will be a lot less burdensome on us for us to only accept
the original copy when it receives at the Topeka office so please once you get
those forms with original signatures go ahead and mail them to our Topeka office address which is provided on the form as well as on the slides currently
by signing and submitting forms 7F the sponsor acknowledges and certifies the
successor is responsible for ensuring that certifications verification and
confidentiality processes meets all regulatory requirements and policies
under the National School Lunch Program and the federal and state privacy law
this includes the software used to perform all or part of the meal
application eligibility certification or verification process in addition the
sponsor must assure the software used is performing correctly and meets all
requirements the second step will be email notification sent from KSDE
so once the 7F forms have been reviewed an email notification will be sent to the
authorized representative and contact person listed on the 7F form for each district notification will include the next steps and the process the test
scenarios and the program year 19 online application sponsor checklist the sponsor is responsible for then
completing the sponsor online application checklist which is part of
step 3 so you will complete the checklist in
all of the test scenarios and then email the completed checklist back to Julie
Henry It is important to note that this process
includes a more detailed testing process by the sponsor than it has in the
previous years please make sure you are planning for adequate time to complete
the checklist and review of your online application also note that the review
can not be completed until all parts of the tech list are complete and the
sponsor has certified the application meets all requirements step four is
system demonstration at random KSDE Child Nutrition and Wellness will select
sponsors to provide a demonstration of their system this demonstration is to
ensure that the sponsor fully understands the operations and
functionality of its software and the sponsor meets the requirements outlined
in the sponsor checklist this sponsor must download or have access to Skype,
which Skype is free to use online in order to complete this step the
demonstration must be conducted solely by a representative from the sponsor and
software vendors may not provide a demonstration or assist with the
demonstration on the sponsors behalf if you are randomly chosen you will be
notified and given more detailed instructions if you are selected to do a
system demonstration once the online application review is complete sponsors
will receive an email of the review completion from Child Nutrition and Wellness your online application may then be posted for use on your public website
and each sponsor is responsible for guaranteeing the accuracy of any
electronic application technology including electronic
signatures and of its claims for reimbursement as well as for ensuring
that free reduced-price eligibility information remains confidential so that completes the webinar so thank you all for attending if you
have questions or concerns regarding the online application process please
contact anyone from our online application team that is Lynette Osner Julie Henry Rachel Jueneman or Sean
Hoffman or you can contact the Topeka office at seven eight five two nine six
two two seven six and they will get you in touch with one of us from the online
application team so and we look forward to helping you through the new
review process this summer for online applications I know we’re very excited
for this new process and so I think it’s this point we’ll go ahead and start
answering questions from the chat box and then I will go ahead and unmute the
line for those of you who may want to ask a question over the phone or through
Skype so let’s see can the person from the sponsor be the text department from
Shelley Gunderson and Shelley I think you’re probably talking about the
demonstration part and I think that would be fine
our only requirement is that it has to be somebody from the district or the
sponsor that is demoing the application and understands the application when
we’re doing the the demo part that cannot be conducted by a staff member
from their software vendor and then Heather says the original deadline for
application is June 1 what is the final deadline for completion of all the
checklists and verifications so there is no final deadline it’s just as
we will move as quickly as you get the information to us so if you’re wanting
to submit your 7F in the middle of July and not roll out your online application
themselves you know mid August early September that’s completely fine by us we will make that work so we actually review online applications all
school year long so the sooner you get it in and get your system and everything
done the faster you can review it but if you’re kind of wanting to hold off and
wait that’s perfectly fine too so there’s no cutoff deadlines in order to
get your online application up when will form 7F be available it is currently
available it was posted in mid-march it’s in Chapter 7 of food service facts on
our website are the slides going to be posted yes we will post them if you
can’t see them and if you can’t see them currently please send put your
email in the chat box I think where is the sponsor checklist we will send that
out to you once we have your 7F form and it has been reviewed and then there’s a
question about can we give up a list of approved vendors
Nate if you want to contact me I can provide you a list of software companies
that districts have used in the past and we don’t actually approve online
applications we just review as trying to be helpful to use to try this helps
get you through the process so that hopefully there are no errors we’re kind
of a we look at this as a second set of eyes to help you protect yourself so I’m
going to go ahead and open up unmute everybody and Cheryl
or Kelly if you want to chime in on any of those comments feel free Skype
should be unmuted now and then I will unmute the conference call line okay so
if anybody wants to verbally ask questions that’s that’s fine I think you
should be able to do so now there’s a question about how many districts
actually used the online application process last year we were pushing 50 I
believe we might have been a few less or a few over that but you have
quite a few that are using online application other questions so we will stick around for the next
couple of minutes if anybody else has other questions otherwise a change on
that concludes our webinar thank you all for attending today all I’ll say on the
webinar for probably another 10 minutes or so and then Kelly how long should we
keep it and we can keep the chat open for another 10 or 15 minutes that’s fine
Lynette you’d like us to do you think it’s okay
to shut the conference call line off yes I think we can shut the conference call line off
there’s questions about who is approved and and I think it’s really important
that Lynette says there aren’t any USDA or state approved software vendors you
have to look at each online application in each school district because it can
be put in place differently with different questions for each school
district but Lynette does have a list of ones that we have seen as we have done
reviews in Kansas and we are considering at KSDE are writing a grant so that we
might someday develop an online application that even smaller districts
that could use and not have to procure but that’s probably several years down
the road because we’ll have to write the grant first given that program we will
post the slides under what’s new that’s a question that we got and I will and
make note of that in the monthly update we did try to record it and if we can
get it close caption we’ll have it on YouTube so that you can listen as well
hopefully soon okay you can you can do a step in a concurrent week for year
18-19 we’re currently accepting those and then Patty could you send us
your email address and we’ll get you the slides Lynette
Kelly had her address she already said I’m taking care of all the folks that
need the handout so we’re good I have a question okay do you have to have the
signature of the district legal counsel recommended I’m not sure sorry Jill from
USD 290 did you want me to email you yeah yeah we can give you let’s see it is
290 what what Ottawa we use the form that USDA recommends from the policy
memo and that is something that they have on that form that Lynette can give
you some ideas I’m sure if you’re having trouble having a legal counsel review
but I would definitely recommend it because you’re talking about thousands
of dollars here with an incorrect eligibility and so it’s important your
legal counsel stands behind what you do with your online application okay on that yeah hey this is Mary Jo from
Lindsborg we have a question on the attestation statement uh-huh the
application that we have now is that the is that considered the attestation
statement about the signature do you know paper application uh-huh on the
paper application yeah uh-huh yeah so I like to tell people to compare your
online application to what you see on your paper application okay on your
online application is on your paper application okay thanks so much Lynnette since we don’t seem to have any
more questions I think we’ll go ahead and shut down and thanks again for
presenting today and for Shawn for recording and everyone who took part in
the webinar appreciate it a lot have a great rest of the afternoon bye guys bye

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