DEPARTMENT OF HEALTH & HUMAN SERVICES 
Centers for Medicare & Medicaid Services 
7500 Security Boulevard, Mail Stop S2-26-12 
Baltimore, Maryland   21244-1850 
 
 
 
CMCS Informational Bulletin  
 
DATE:   February 12, 2016 
    
FROM:   Vikki Wachino  
Director 
Center for Medicaid and CHIP Services 
 
SUBJECT:   United States Department of Agriculture (USDA) Demonstration Project to Test 
Using Medicaid Enrollment to Qualify Children for Free and Reduced Price 
School Meals 
 
The Healthy Hunger-Free Kids Act of 2010 amended section 1902(a)(7) of the Social Security Act 
(the Act) to permit Medicaid agencies to enter into data-sharing agreements with state agencies that 
administer the National School Lunch Program and School Breakfast Program.  These data-sharing 
agreements allow the state agencies to directly certify students to receive both free and reduced price 
school meals based on the childs Medicaid eligibility and verified income.  Direct certification has 
the potential to improve student access to school meals, reduce administrative burden for schools and 
families, and improve certification accuracy.   
 
On January 27, 2016, the USDA Food and Nutrition Service (FNS) issued a Request for Applications 
inviting state agencies that administer school meal programs to participate in a new demonstration 
project to evaluate the impact of direct certification for both free and reduced price school meals.  
Medicaid state agencies are key partners in these demonstrations, and CMS encourages Medicaid 
agencies to work with their state agencies in considering this opportunity.   
 
Changes in Medicaid eligibility and processes since 2014, including the shift to using Modified Adjusted 
Gross Income (MAGI) and the presence of new or modernized eligibility systems in state Medicaid 
agencies, may increase the identification of children eligible for both free and reduced price meals.  The 
new demonstrations will evaluate the potential of direct certification to enroll new children, certify 
currently enrolled children, and impact participation in the school lunch and breakfast programs. 
 
Applications for the 2016-2017 school year must be received by FNS by April 15, 2016; and 
applications for the 2017-2018 school year must be received by FNS by September 16, 2016. States 
will be able to apply for funding to cover the associated project costs.  Additional states will be able 
to apply to participate in the demonstrations in future years.  
 
For purposes of these demonstrations, the Medicaid program is defined as both Medicaid under 
Title XIX and Medicaid expansion programs funded under Title XXI of the Act.  CMCS Informational Bulletin  Page 2 
 
Direct certification will not be conducted with separate CHIP programs. To be eligible for direct 
certification under the demonstrations, a child must receive, or live in a household with a child who 
receives, medical assistance under the Medicaid program. The child must also be a member of a 
family with income, as measured by the Medicaid program before the application of the standard 5 
percent MAGI disregard that does not exceed 130 percent of the Federal Poverty Level (FPL) for 
free school meals, and 185 percent of the FPL for reduced price school meals. For children who 
may be eligible for Medicaid on a non-MAGI basis, family income must be below the eligibility 
levels specified above, before the application of any expense, block, or disregard to reduce the 
family income. 
 
State agencies that administer the school meals programs and are selected to participate in the 
demonstration projects must have an agreement in place with the partner Medicaid state agency 
before the data matching process begins.  Under the HIPAA Privacy Rule [45 CFR 164.512(k)(6)(i)], 
the State Medicaid agency is permitted to share with the school meals program individually 
identifiable information related to Medicaid eligibility and enrollment, provided that the Medicaid 
agency only discloses the minimum amount of information needed to certify or verify the childs 
school meal eligibility. 
 
State Medicaid agencies are encouraged to work with school meal administrators to streamline 
enrollment in these important nutrition programs.  As part of the application process, Medicaid 
agencies must submit a letter of commitment with the state agencys application package, submitted 
to FNS. Medicaid agencies may also assist in the application process by submitting copies of current 
data sharing agreement(s) between the state agency and the Medicaid agency, if they exist, or 
establishing a data sharing agreement if one does not exist.  
 
For more information, contact: Vivian Lees, Senior Technical Advisor, Program Monitoring 
& Operational Support Division, Child Nutrition Programs, USDA Food and Nutrition 
Service, vivian.lees@fns.usda.gov. 
 
FNS Public Website link to Memorandum SP 23-2016 and RFA attachments: 
http://www.fns.usda.gov/request-applications-participate-new-demonstrations-evaluate-direct-
certification-medicaid