Nutrition Assistance Program Report Series 

The Office of Analysis, Nutrition and Evaluation 

Special Nutrition Programs Report No. CN-04-AV3 

Case Study of National School Lunch Program 

Verification Outcomes in Large Metropolitan 

School Districts 

United States Food and 

Department of Nutrition 

Agriculture Service 

April 2004
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Case Study of National School Lunch Program 

Verification Outcomes in Large Metropolitan 

School Districts 

Authors:

From Mathematica Policy Research, Inc. 

John Burghardt 

Tim Silva 

Lara Hulsey 

Submitted to: 

USDA, Food and Nutrition Service 

Office of Analysis, Nutrition and Evaluation 

Room 1014 

3101 Park Center Drive 

Alexandria, VA 22302 

Project Officer:

Paul Strasberg 

Submitted by: 

Mathematica Policy Research, Inc. 

P.O. Box 2393 

Princeton, NJ 08543-2393 

Telephone: (609) 799-3535 

Facsimile: (609) 799-0005 

Project Director: 

John Burghardt 

Principal Investigator: 

Philip Gleason 

This study was conducted under Contract number GS-10F-00502 with the Food and Nutrition Service. 

This report is available on the Food and Nutrition Service website: http//www.fns.usda.gov/oane.

Suggested Citation:

Burghardt, J., Silva, T., and Hulsey, L. “Case Study of National School Lunch Program Verification Outcomes in 

Large Metropolitan School Districts.” Special Nutrition Program Report Series, No. CN-04-AV3. Project Officer: 

Paul Strasberg. U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and 

Evaluation, Alexandria, VA: 2004. 

United States Food and 

Department of Nutrition 

Agriculture Service 

April 2004

Special Nutrition Programs

Report No. CN-04-AV3
 iii 

ACKNOWLEDGMENTS 

The authors gratefully acknowledge the assistance of the many organizations and individuals 

who played a role in completing this study. 

 

FNS regional office staff and staff in the state child nutrition agencies of California, Florida, 

Massachusetts, Minnesota, Oklahoma, Utah, and Virginia arranged for the participation of 

individual districts in the study. We would especially like to thank the districts that participated 

in the study and the individuals who helped us arrange and complete the verification data 

collection. 

Boston, Massachusetts, metropolitan area: 

Helen Mont Ferguson, Boston Public Schools 

Donna Lombardi, Worcester Public Schools 

Anne Marie Sheehan, Lawrence Public Schools 

Norfolk-Newport News, Virginia, metropolitan area: 

Carol R. Clark, MS, RD Hampton City Schools 

James G. Ratliff, Jr., Virginia Beach City Public Schools 

Douglas H. Vaughan, Newport News Public Schools 

Orlando, Florida, metropolitan area: 

Dan Andrews, Seminole County School District 

Jim Hill, Lake County School District 

Jean Palmore, Osceola School District 

Janet Williams, Orange County School District 

Los Angeles, California, metropolitan area: 

Geri Dee and Ileana Siu, Hacienda La Puente Unified School District 

Terry Pangborn, Anaheim Union High School District 

Judy Pollock, Orange Unified School District 

Cecilia Slater, Long Beach Unified School District 

Minneapolis, Minnesota, metropolitan areas: 

Jo Ellen Miner, Minneapolis Public Schools 

Allison Bradford, Anoka-Hennepin Independent School District 

Salt Lake City, Utah, metropolitan area: 

Kim Carter, Granite School District 

Marilyn Clayton, Jordan School District 

Kelly Orton, Salt Lake City School District 

Tulsa, Oklahoma, metropolitan area: 

Lisa Griffin, Tulsa Public Schools 

Jill Poole, Broken Arrow Public Schools 
 iv 

Paul Strasberg at the Office of Analysis, Nutrition and Evaluation served as the primary 

point of contact for school district and state agency staff. He also served as the contracting 

officer’s technical representative for the contract under which Mathematica Policy Research, Inc. 

conducted the case study. His close involvement in site recruiting, data collection, and the 

analysis and report preparation have shaped the study and this report. The study has also 

benefited from the insights of Jay Hirschman and John Endahl of the Office of Analysis, 

Nutrition, and Evaluation, and Todd Barrett of FNS’s Child Nutrition Division. 

The authors also wish to thank their many colleagues at Mathematica Policy Research, Inc. 

who contributed to the study and to this report. Rhoda Cohen designed the abstraction and study 

survey and oversaw the data collection. Keith Appleby, Julie Ladinsky, Charles Nagatoshi, and 

Claire Wilson helped explain the study to district staff and conducted the visits to each district to 

review verification files. Julita Milliner and Anne Self helped manage the field data collection. 

Barbara Kolln provided programming support to the field data collection. Jaclyn Wong, Michael 

Bloom, Justin Humphrey, Lucy Lu, and Patricia Seunarine provided research programming 

support. Philip Gleason, Michael Sinclair, and James Ohls provided review, advice, and 

guidance on aspects of the analysis and report preparation. Jill Miller, Marjorie Mitchell, Walter 

Brower, and Patricia Ciaccio provided production and editorial support. 
 v 

CONTENTS 

Chapter Page 

 EXECUTIVE SUMMARY .......................................................................................... xv 

I INTRODUCTION .......................................................................................................... 1 

A. PROGRAM BACKGROUND................................................................................ 1 

B. STUDY OBJECTIVES........................................................................................... 4 

II STUDY METHODS AND CHARACTERISTICS OF STUDY DISTRICTS.............. 7 

A. STUDY METHODS ............................................................................................... 7 

1. Overview ......................................................................................................... 7 

2. Selection of Districts ..................................................................................... 10 

3. Data Abstraction............................................................................................ 12 

4. In-Person Interviews ..................................................................................... 14 

5. Follow-Up Data on Postverification Eligibility Status ................................. 16 

6. Analysis Methods.......................................................................................... 16 

B. CHARACTERISTICS OF CASE STUDY DISTRICTS AND ALL 

 DISTRICTS NATIONWIDE................................................................................ 19 

III OUTCOMES OF VERIFICATION ............................................................................. 27 

A. OVERALL OUTCOMES ..................................................................................... 28 

1. Summary for All Households........................................................................ 28 

2. Summary of Results Based on How Households’ Initial Eligibility Was 

 Determined .................................................................................................... 31 

3. Placing the Verification Outcome Results in Perspective............................. 34 

B. VERIFICATION OUTCOMES BY DISTRICT CHARACTERISTICS............. 37 

1. District Enrollment........................................................................................ 37 

2. Percentage of Students Approved for Free or Reduced-Price Meals............ 39 

3. Use of Direct Certification ............................................................................ 42 

4. Use of Multichild Versus Single-Child Applications ................................... 44 

C. REAPPROVAL RATES AMONG NONRESPONDERS.................................... 44 
 vi 

Chapter Page 

IV INCOME ELIGIBILITY STATUS OF TWO GROUPS OF CASES SELECTED 

 FOR VERIFICATION.................................................................................................. 49 

A. APPROACH AND INTERPRETATION OF THE ESTIMATES....................... 49 

B. FINDINGS ON INCOME ELIGIBILITY STATUS............................................ 51 

1. Findings on the Income Eligibility Status of Nonresponders to 

 Verification.................................................................................................... 51 

2. Findings on the Income Status of Cases with No Change in Benefits.......... 54 

3. Accuracy of Meal Price Certification for Nonresponders and 

 No-Change Cases .......................................................................................... 56 

V CHARACTERISTICS OF NONRESPONDING HOUSEHOLDS THAT WERE 

 REAPPROVED AND THAT WERE NOT REAPPROVED BY MARCH 1............. 59 

A. ELIGIBILITY ....................................................................................................... 60 

B. OTHER CHARACTERISTICS ............................................................................ 63 

C. PARTICIPATION IN THE NSLP........................................................................ 64 

VI INCOME ELIGIBILITY STATUS OF REAPPROVED NONRESPONDERS: 

COMPARING MEAL PRICE STATUS ASSIGNED BY THE SFA WITH INCOME 

ELIGIBILITY ESTIMATED FROM THE CASE STUDY INTERVIEW ................. 67 

A. DATA AND METHODS...................................................................................... 69 

B. COMPARING MEAL PRICE STATUS AS DETERMINED BY THE SFA 

 AND MEAL PRICE STATUS BASED ON THE SURVEY............................... 71 

C. UNDERSTANDING THE DIFFERENCES IN STATUS AS 

 DETERMINED BY THE DISTRICT AND BY THE SURVEY......................... 73 

1. Categorical Eligibility or Foster Child Present ............................................. 74 

2. Income and Household Size Agree but Meal Price Status Differs ............... 74 

D. ESTIMATING THE PORTION OF THE DIFFERENCE IN RATES OF 

 INELIGIBILITY OF NO-CHANGE CASES DUE TO CHANGING 

 CIRCUMSTANCES ............................................................................................. 78 

 REFERENCES ............................................................................................................ 81
 vii 

Chapter 

 APPENDIX A: ADDITIONAL TABULATIONS 

 APPENDIX B: INCOME ELIGIBILITY OF NONRESPONDERS AND 

 NO-CHANGE CASES FOR GROUPS OF CASE STUDY 

 DISTRICTS 

 APPENDIX C: DETAILS OF THE ESTIMATE OF THE PERCENTAGE 

 INELIGIBLE IN MARCH WHO HAD A CHANGE IN 

 ELIGIBILITY FROM DECEMBER TO MARCH 
ix 

TABLES 

Table Page 

 II.1 CASE STUDY OF VERIFICATION OUTCOMES: INTERVIEW SAMPLES 

 AND RESPONSE RATES.................................................................................... 15 

 II.2 AVERAGE CHARACTERISTICS OF ALL DISTRICTS NATIONWIDE 

 AND THE CASE STUDY DISTRICTS............................................................... 20 

 II.3 CHARACTERISTICS OF CASE STUDY DISTRICTS...................................... 23 

 III.1 SUMMARY OF VERIFICATION OUTCOMES FOR ALL 

 HOUSEHOLDS, OVERALL AND BY SAMPLING METHOD USED............. 29 

 III.2 SUMMARY OF VERIFICATION OUTCOMES, BY BASIS FOR 

 INITIAL APPROVAL, OVERALL AND BY SAMPLING METHOD USED .. 32 

 III.3 SUMMARY OF VERIFICATION OUTCOMES, OVERALL AND BY 

 SAMPLING METHOD USED ............................................................................. 38 

 III.4 SUMMARY OF VERIFICATION OUTCOMES BY DISTRICT 

 ENROLLMENT AND SAMPLING METHOD USED ....................................... 40 

 

 III.5 SUMMARY OF VERIFICATION OUTCOMES BY PERCENTAGE 

 OF STUDENTS APPROVED FOR FREE AND REDUCED-PRICE 

 MEALS AND SAMPLING METHOD USED..................................................... 41 

 III.6 SUMMARY OF VERIFICATION OUTCOMES BY DIRECT 

 CERTIFICATION POLICY AND SAMPLING METHOD USED..................... 43 

 III.7 SUMMARY OF VERIFICATION OUTCOMES BY MULTICHILD 

 APPLICATION POLICY AND SAMPLING METHOD USED......................... 45 

 III.8 MEAL PRICE STATUS OF NONRESPONDERS TO VERIFICATION 

 INITIALLY APPROVED ON THE BASIS OF INCOME, AS OF MARCH 1, 

 2003, OVERALL AND BY ORIGINAL STATUS.............................................. 46 

IV.1 INCOME STATUS OF HOUSEHOLDS APPROVED ON THE BASIS OF 

 INCOME AND HOUSEHOLD SIZE THAT FAILED TO RESPOND TO 

 VERIFICATION REQUEST ................................................................................ 52 

 IV.2 INCOME STATUS OF HOUSEHOLDS APPROVED ON THE BASIS OF 

 INCOME AND HOUSEHOLD SIZE THAT HAD NO CHANGE IN NSLP 

 BENEFITS AS A RESULT OF VERIFICATION ............................................... 55 
TABLES (continued)

Table Page

x

 IV.3 CERTIFICATION ACCURACY OF HOUSEHOLDS WITH SELECTED 

 VERIFICATION OUTCOMES ............................................................................ 58 

 V.1 CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT 

 FAILED TO RESPOND TO VERIFICATION THAT WERE REAPPROVED 

 AND THAT WERE NOT REAPPROVED.......................................................... 61 

 VI.1 MEAL PRICE STATUS ACCORDING TO THE STUDY SURVEY AND 

 ACCORDING TO THE SFA DETERMINATION AFTER 

 REAPPLICATION................................................................................................ 72 

 VI.2 REASONS FOR DIFFERENCE BETWEEN MEAL PRICE STATUS 

 ASSIGNED BY SFA AND MEAL PRICE STATUS BASED ON THE 

 SURVEY AMONG NONRESPONDERS TO VERIFICATION WHO 

 WERE REAPPROVED......................................................................................... 75 

 A.1 OUTCOMES OF NSLP VERIFICATION IN 21 LARGE METROPOLITAN 

 DISTRICTS......................................................................................................... A.1 

 A.2 OUTCOMES OF NSLP VERIFICATION IN 21 LARGE METROPOLITAN 

 DISTRICTS, BY SAMPLING METHOD USED .............................................. A.2 

 A.3 RANGE OF OUTCOMES OF NSLP VERIFICATION ACROSS ALL 21 

 PARTICIPATING DISTRICTS.......................................................................... A.3 

 A.4 RANGE OF OUTCOMES ON SUMMARY MEASURES OF NSLP 

 VERIFICATION RESULTS ACROSS ALL 21 PARTICIPATING 

 DISTRICTS......................................................................................................... A.4 

 A.5 RANGE OF REAPPROVAL RATES FOR NONRESPONDERS TO 

 VERIFICATION AS OF MARCH 1, 2003, ACROSS ALL 21 

 PARTICIPATING DISTRICTS.......................................................................... A.5 

 A.6 INCOME STATUS OF GROUPS OF HOUSEHOLDS SELECTED FOR 

 NSLP VERIFICATION IN 21 LARGE METROPOLITAN SFAs.................... A.6 

 A.7 INCOME STATUS OF GROUPS OF HOUSEHOLDS SELECTED FOR 

 NSLP VERIFICATION IN 21 LARGE METROPOLITAN SFAs, BY USE 

 OF FOCUSED OR RANDOM SAMPLING FOR VERIFICATION ................ A.7 
TABLES (continued)

Table Page

xi

 A.8 CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT 

 FAILED TO RESPOND TO VERIFICATION WHO REAPPLIED AND 

 DID NOT REAPPLY, IN DISTRICTS USING RANDOM SAMPLING 

 FOR VERIFICATION ........................................................................................ A.8 

 A.9 CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT 

 FAILED TO RESPOND TO VERIFICATION WHO REAPPLIED AND 

 DID NOT REAPPLY, IN DISTRICTS USING FOCUSED SAMPLING 

 FOR VERIFICATION ...................................................................................... A.10 

 A.10 TOTAL SAMPLE AND NUMBER OF COMPLETED INTERVIEWS, 

 BY SUBGROUP AND DISTRICT................................................................... A.12 

 B.1 INCOME ELIGIBILITY STATUS IN DISTRICTS WITH SELECTED 

 CHARACTERISTICS......................................................................................... B.1 
xiii 

FIGURES 

Figure Page 

 II.1 CASE STUDY OF VERIFICATION OUTCOMES IN 21 LARGE 

 METROPOLITAN SFAs ........................................................................................ 9 

 C.1 ELIGIBILITY STATUS AT TWO POINTS IN TIME OF CASES WITH 

 NO CHANGE DUE TO VERIFICATION ......................................................... C.2 

 C.2 ELIGIBILITY STATUS AT TWO POINTS IN TIME OF CASES WITH 

 NO CHANGE DUE TO VERIFICATION ASSUMING NO CASES 

 APPROVED IN DECEMBER CHANGED FROM INELIGIBLE TO 

 ELIGIBLE ........................................................................................................... C.4 
 xv 

EXECUTIVE SUMMARY 

The National School Lunch Program (NSLP) and the School Breakfast Program (SBP) 

provide federal financial assistance and commodities to schools serving lunches and breakfasts 

that meet required nutrition standards. Under the NSLP and the SBP, millions of American 

students receive a free or reduced-price lunch and/or breakfast every school day. 

Concern has grown recently that many students who participate in the program may in fact 

be ineligible for the benefits they receive. School Food Authorities (SFAs) that operate the 

NSLP must verify the eligibility of a small sample of approved applications by requiring 

documentation of income or receipt of food stamps or cash assistance. The verification process 

is designed to identify and deter errors in each district. However, the system does not provide 

data on the accuracy of benefit determination nationwide. 

This report presents the results of a case study of verification in 21 large metropolitan SFAs 

around the country. The study examined outcomes of the verification process and made an 

independent assessment of income eligibility of households with specific verification outcomes 

using data from in-person interviews with families. 

CASE STUDY OBJECTIVES 

The study had the following three objectives: 

1. Assess outcomes of the verification process. Determine the number and percentage 

of verified applications that fall into various categories defined by combinations of 

preverification status and postverification status. 

2. Verify incomes of nonresponding households. Independently determine the income 

level of households who were initially approved on the basis of income provided on 

an application (were not categorically eligible), were selected for verification, and 

did not respond to SFA requests for documentation of their income. 

3. Verify incomes of households with no change in benefits. Independently determine 

the income level of households who were initially approved on the basis of income, 

were selected for verification, and whose benefit levels were unchanged as a result of 

the verification process. 

Under the first objective, the study provides data on the proportions of verified households 

for whom verification results in no change in benefits, in reduction or termination of benefits due 

to information provided, in an increase of benefits due to information provided, or in no response 

to the verification request, in which circumstance the SFA is required to terminate benefits. 

Under the second objective, the study provides information on the proportion of nonresponding 
 xvi 

households with income that would make them eligible if they complied with the request for 

verification. Under the third objective, it provides a check on the accuracy of the benefit 

determination conducted in the verification process among households that responded to the 

verification request. 

CASE STUDY DESIGN 

The Case Study of Verification Outcomes in Large Metropolitan School Districts used a 

purposively selected sample of 21 large districts in seven metropolitan areas. Food and Nutrition 

Service regional office staff recruited two to four SFAs in each of seven metropolitan areas 

(Boston, Massachusetts; Orlando, Florida; Virginia Beach-Norfolk-Newport News, Virginia; Los 

Angeles, California; Salt Lake City, Utah; Tulsa, Oklahoma; and Minneapolis-St. Paul, 

Minnesota). In each SFA, the study reviewed the verification outcomes of all cases selected for 

verification during fall 2002. 

We conducted in-home interviews with 632 households who did not respond to the district’s 

verification request and with 532 households who had no change in benefits due to verification. 

The interview methodology was similar to that used in the Evaluation of the NSLP 

Application/Verification Pilot Projects. Interviews were conducted in February and March 2003. 

These interviews obtained data on household membership and income in the month before the 

interview (January or February 2003). A limitation of comparing the results of the verification 

process and the household interviews is that the two measures of household circumstances are 

made at different times two to three months apart. As a result, changes in circumstances during 

the intervening two to three months may contribute to differences in household eligibility as 

assessed at verification and through the study survey. 

The study also collected information on whether individuals who were nonresponders to 

verification had reapplied and been reapproved for benefits by March 1, 2003. For the 

nonresponders selected for in-home interviews, data were collected on household size and 

income as reported on the new application. 

The analysis of nonresponders to verification and cases with no change in benefits due to 

verification included households who had initially been approved on the basis of income and 

household size. This analysis excluded cases initially approved as categorically eligible based on 

the household providing a Temporary Assistance for Needy Families, Food Stamp Program, or 

Food Distribution Program for Indian Reservations case number. 

It is important to emphasize that the verification system and the information derived from it 

presented in this report are not designed to provide information on the accuracy of benefit 

determination in individual districts or nationwide. Instead, the system is designed to identify 

and deter certification errors in each district. To this end, federal regulations allow districts to 

target their verification efforts to specific groups of cases whose circumstances are such that the 

case has a higher likelihood of being ineligible for the benefit it receives. Nearly half the districts 

included in this case study use such focused sampling to select cases for verification. This 

district decision very likely leads to a greater incidence of ineligibility in the verification sample 

than would be found if all approved cases had the same chance of being selected for verification. 
 xvii 

Because of this feature of the verification process, caution must be used in drawing conclusions 

from the case study about underlying rates of certification inaccuracy in the participating 

districts. 

CASE STUDY FINDINGS 

Outcomes of Verification 

On average across the districts, half of households selected for verification did not 

respond to the request for verification. The review of verification records indicated that: 

• 50 percent responded to the request for verification by the December 15, 2002, 

deadline, and 50 percent did not. 

• Among the 50 percent who responded: 

- 32 percent had no change in their benefit. 

- 1 percent had their benefit increased from reduced-price to free. 

- 9 percent had their benefit reduced from free to reduced-price. 

- 8 percent had their benefit terminated (changed from free or reduced-price to 

paid status). 

Approximately 13 percent of all households verified were categorically eligible, and 87 

percent were approved on the basis of income. Categorically eligible households were less likely 

to have their benefits reduced or terminated and more likely to have had no change in benefits. 

The percentage of households selected for verification who did not respond to the 

verification request was larger in districts using focused sampling, and the percentage with no 

change was smaller. Nonresponding cases were 56.0 percent of cases in focused-sampling 

districts and 45.3 percent in random-sampling districts. No-change cases were 23.1 and 39.5 

percent of the total in focused- and random-sampling districts, respectively. 

About one-fourth of households approved on the basis of income who did not respond 

to verification had been reapproved for free or reduced-price meal benefits by March 1, 

2003. Since households approved on the basis of income who did not respond made up 47 

percent of cases verified, the nonresponders who were reapproved made up 12 percent of all 

verified cases. 
 xviii 

Income Eligibility of Nonresponders 

Just over one-half of nonresponder households were eligible for at least the benefit they 

had been receiving prior to verification. 

• Among nonrespondents who had been approved for free meals: 

- 51 percent were eligible for free meals. 

- 26 percent were eligible for reduced-price meals. 

- 23 percent were not eligible for either free or reduced-price meals. 

• Among nonrespondents who had been approved for reduced-price meals: 

- 23 percent were eligible for reduced-price meals. 

- 31 percent were eligible for free meals. 

- 46 percent were not eligible for either free or reduced-price meals. 

In random-sampling districts, 55.8 percent of nonresponders were eligible for at least the 

benefit they were initially approved to receive. In focused-sampling districts, 49.1 percent were 

eligible for this level of benefit. 

More than three-fourths of the nonresponding households who were reapproved by 

March 1, 2003, were eligible for at least the benefit for which they had been reapproved. 

Among reapproved households who completed the study survey: 

• 64 percent were eligible for exactly the level of benefits for which they had been 

reapproved. 

• 14 percent were eligible for a higher benefit than they had been reapproved for. 

• 22 percent were not eligible for the benefits they had been approved for. 

Income Eligibility of Households with No Benefit Change 

About one-third of households whose benefits were unchanged as a result of 

verification were ineligible for their approved benefit level two to three months after 

completing the verification process. 

• Among free-approved students whose meal price status was unchanged, the study 

found that, as of February/March 2003: 

- 64 percent were eligible for free meals. 

- 27 percent were not eligible for free meals but were eligible for reduced-price 

meals. 

- 9 percent were not eligible for either level of benefits. 
 xix 

• Among reduced-price approved students whose meal price was unchanged, the study 

found that, as of February/March 2003: 

- 42 percent were eligible for reduced-price meal benefits. 

- 25 percent were eligible for free meal benefits. 

- 33 percent were not eligible for either level of benefits. 

In random-sampling districts, 30.1 percent of no-change cases were not eligible for the 

benefit they were receiving. In focused-sampling districts, 39.2 percent were not eligible. 

A part of the difference in the percentage found eligible in the survey compared to the 

verification process may be due to changes in household circumstances. Based on the nearly 

contemporaneous data from the new applications of reapproved cases and the study survey, we 

estimate that as much as 30 to 40 percent of the difference between the survey estimate of 

income eligibility and the SFA’s determination at the point of verification may be due to changes 

in household circumstances between the period covered in documentation and the period 

reported in the study’s survey. Eliminating this part of the difference suggests that 

approximately 20 percent of those whose benefits were unchanged in verification were ineligible 

for the benefit they were receiving at the time of verification. 
 
 1 

I. INTRODUCTION 

The National School Lunch Program (NSLP) and the School Breakfast Program (SBP) 

provide federal financial assistance and commodities to schools serving lunches and breakfasts 

that meet required nutrition standards. Under the NSLP and the SBP, millions of U.S. students 

receive a free or reduced-price lunch and/or breakfast every school day. 

Recently, concern has grown that many students who participate in the program may in fact 

be ineligible for the benefits they receive. This report presents the findings of a case study of 

verification outcomes and in-depth in-person interviews with families selected for verification in 

21 large metropolitan school districts around the country. It is part of a growing body of 

research conducted by and for the Food and Nutrition Service (FNS) and other agencies of the 

U.S. Department of Agriculture (USDA) to gauge the nature and extent of the problem of 

certification inaccuracy. 

The rest of this chapter provides background on the NSLP application and verification 

processes. It then describes the objectives of the case study. 

A. PROGRAM BACKGROUND 

Responsibility for administering the NSLP and SBP at the local district level rests with the 

School Food Authority (SFA), which provides meals that meet nutritional requirements. So it 

can claim reimbursement from USDA, the SFA keeps counts of meals served free, at reduced 

price, and at full price. The SFA also is responsible for (1) notifying families that free and 

reduced-price meals are available to children from families that meet certain income-for-familysize standards; (2) distributing blank application forms and instructions and receiving completed 

applications; (3) reviewing the information on forms to establish which students are approved 
 2 

(certified) and which applying students are not eligible (and, therefore, are not certified); and 

(4) notifying families of their children’s certification status. 

Eligibility for free or reduced-price meals in the NSLP is based on information that parents 

or guardians provide on an application at the start of the school year. Applicants list all the 

students living in the household and indicate whether each student receives welfare benefits 

(Temporary Assistance for Needy Families [TANF]), participates in either of two nutritionrelated programs (the Food Stamp Program or the Food Distribution Program for Indian 

Reservations [FDPIR]), or is a foster child. Students who receive TANF, food stamps, or FDPIR 

qualify for a free lunch; they are considered “categorically eligible” if their case number is 

reported on the application. Other applicants must list all people living in their household and 

report the total income received by each household member, including students. For students not 

categorically eligible for a free lunch, SFA personnel consider total household size and income, 

using federally published guidelines, to determine whether students qualify for free or reducedprice meal benefits. Students from households whose income is less than 130 percent of the 

federal poverty level (FPL) are eligible for free meals. Students from households whose income 

is between 130 and 185 percent of the FPL are eligible for reduced-price meals. Students from 

households whose income exceeds 185 percent of the FPL must pay full price for a school lunch, 

although the cost of “full price” lunches also reflects a small federal subsidy. Finally, SFAs may 

also use “direct certification” to determine that students are eligible for free meals. If SFAs 

receive information documenting participation in TANF, the Food Stamp Program, or FDPIR 

directly from officials responsible for those programs, households need not submit an application 

for NSLP. 

Congress instituted the NSLP verification process to detect and deter applicant misreporting 

that caused meal benefits to be directed to students not eligible to receive them when it passed 
 3 

the Omnibus Budget Reconciliation Act of 1981. Currently, each SFA must conduct 

verifications of a small fraction of approved applications by December 15 of each year. Districts 

initiate the verification process (usually in October or November) by sending selected families 

whose children are approved for free and reduced-price meals a request for documentation of 

their income or food stamp/TANF/FDPIR status. If the family provides documents showing 

their income is below the free threshold, and if they had been approved for reduced-price meal 

benefits, the SFA increases their benefits to free status. If the family provides documents 

showing their income exceeds the eligibility limit, their benefits are reduced or terminated. If a 

family does not provide documentation, the SFA is required to terminate free or reduced-price 

meal benefits. Upon such termination, children may obtain NSLP meals at the paid rate. At any 

time after verification, a household may submit a new application, with documentation of its 

family circumstances, to seek approval for their children to receive free or reduced-price meals. 

SFAs have the option of conducting verification of a random sample of applications, a 

focused sample of applications, or all applications. A random sample is supposed to be a simple 

random sample of all approved applications. If a random sample is used, it must include the 

lesser of 3,000 or three percent of applications. In a focused sample, verification efforts center 

on students in families that have incomes close to the upper cutoff of eligibility or that receive 

TANF or food stamps. Such a sample must include the lesser of 1 percent of all applications or 

1,000 students selected from families that listed income within $100 monthly or $1,200 annually 

of the free and reduced-price guidelines for that household size, plus 0.5 percent of all 

applications or 500 selected from those receiving food stamps/TANF/FDPIR. 

 The verification sample includes only students who were approved on the basis of an 

application. This means that two groups of children entitled to receive free and reduced-price 

meals are not subject to verification. First, students who are directly certified are excluded from 
 4 

verification samples. Second, students attending schools using Provision 2 or 3 under the 

Special Assistance Certification and Reimbursement Alternatives in years other than the base 

year are excluded from the district’s verification sample.1

 

B. STUDY OBJECTIVES 

FNS stated the nature of its concerns about the application and verification processes in 

guidance issued to SFAs in 2001: 

The U.S. Department of Agriculture (USDA) has become aware that a significant and increasing number of 

ineligible children are being certified for free and reduced price school meals as a result of inaccurate 

information provided by some households. When ineligible children receive free and reduced price benefits, 

USDA meal reimbursement is misdirected, as are significant amounts of State, Federal, and in some cases, 

local education funds. Furthermore, questions about the integrity of the certification and verification process 

undermine public confidence in a program that has long enjoyed the support of the American people.

Given these concerns, FNS wanted more-detailed information to better understand the 

nature and scope of the problem. Therefore, the agency contracted with Mathematica Policy 

Research, Inc. (MPR) to conduct a study of the outcomes of the verification process in selected 

school districts. The study had the following three objectives: 

1. Assess outcomes of the verification process. Determine the number and percentage 

of verified applications that fall into various categories defined by combinations of 

preverification status and postverification status. 

2. Verify incomes of nonresponding households. Independently determine the income 

level of households that were initially approved on the basis of income provided on 

an application (that is, were not categorically eligible), who were selected for 

 1

Provision 2 or 3 allows schools in which high percentages of students are income eligible 

for free or reduced price meals to use an alternative to the standard certification and meal 

claiming procedure. In a base year, provision 2 or 3 schools require applications of all students 

in order to receive free or reduced price meals, and claim federal reimbursement following 

standard procedures. In years after the base year, no applications are required. Instead all 

students in the school receive free meals, and the district claims federal reimbursement for these 

meals by applying the base year percentages of meals served free, at reduced price, and at full 

price to the total number of reimbursable USDA meals served in each year. 
 5 

verification but did not respond to SFA requests for documentation, and who 

remained enrolled in the school district. 

3. Verify incomes of households with no change in benefits. Determine independently 

the income level of households that were initially approved on the basis of income, 

were selected for verification, and whose benefit levels were unchanged as a result of 

the verification process. 

Under the first objective, the study provides information about the proportion of verified 

households for whom verification results in no change in benefits, in reduction or termination 

due to information provided, in increase due to information provided, and in termination for 

failure to comply with the request to document income. Under the second objective, it provides 

information on the proportion of nonresponding households with income that would make them 

eligible if they complied with the request for verification. Under the third objective, the survey 

provides a check on the accuracy of the benefit determination conducted in the verification 

process. 
 
 7 

II. STUDY METHODS AND CHARACTERISTICS OF STUDY DISTRICTS 

This chapter describes the study methods. It also compares the characteristics of the 21 

districts participating in the study with the characteristics of all districts nationally. 

A. STUDY METHODS 

We first provide an overview of the study structure. We then present additional details on 

key elements of the methodology. 

1. Overview 

The Case Study of Verification Outcomes in Large Metropolitan School Districts used a 

purposively selected sample of districts. We undertook three types of data collection. First, we 

abstracted data from the files of all cases selected for verification in each participating district. 

For each case, we identified whether its preverification basis for approval had been income and 

household size or categorical. Among all cases in each district that were approved on the basis 

of an application with income and household size, we identified two groups: (1) applications of 

households that did not respond to the request for verification, and (2) applications that had no 

change in certification status as a result of verification. Second, we selected simple random 

samples within each of the two groups in each district and conducted in-depth personal 

interviews in which we collected detailed information about household membership and income. 

We used the interview data to estimate total household income and the number of people in the 

household, from which we calculated the household’s income as a percentage of the FPL to 

examine certification accuracy. Third, we contacted SFA staff to determine which members of 

the nonresponder group had been reapproved for free or reduced-price meals as of March 1, 

2003, after their nonresponse to verification (as of December 15, 2002). For the randomly 
 8 

selected subset of the families within this group of reapplying nonresponders who were selected 

for a study interview, we also acquired data on household size and income as reported on the 

new application. 

Figure II.1 shows how the elements of the study relate to the universe of all students 

approved for free or reduced-price meals. This universe includes three broad groups: 

(1) students approved for free or reduced-price meals on the basis of an application, (2) students 

directly certified for free meals, and (3) students attending a Provision 2 or 3 school that was not 

in its base year. In the average case study districts, 18 percent of students approved for free or 

reduced-price meals were directly certified.1

 Among certified students nationally, 14 percent 

were directly certified in school year 2001-2002.2

 Two districts in the case study had one or 

more schools that used Provision 2 or 3. While this study did not collect data on the number of 

such students in the two case study districts, 5.6 percent of students nationally attend schools 

using Provision 2 or 3 (Gleason et. al. 2003). 

The verification process applies only to those households approved on the basis of an 

application, of whom each SFA selects a small sample for verification. The verification sample 

consists of students approved on the basis of income and household size and students approved 

on the basis of their eligibility for food stamps or cash assistance. For each group, the possible 

outcomes of verification are (1) no change in benefits, (2) an increase in benefits, (3) reduction 

 1

Estimate computed from estimates of total number approved and the total number directly 

certified that were provided by SFA staff. In 4 of the 17 districts known to be using direct 

certification, SFA staff could not provide an estimate of the number directly certified. We 

computed the mean percentage directly certified in the 13 districts for which we had an estimate 

and imputed that value for the 4 districts known to be using direct certification but for which we 

did not have an estimate of the number directly certified. 

2

Gleason et al. (2003). 
Universe of Students 

Approved for Free and Reduced-Price Meals

SFA Verification 

Sample Verification Outcomes Household Interviews to Measure Eligibility

Approved on the Basis 

of an Application

Approved Based on 

Income

No Change in Benefits

Benefits Increased

Responded, Benefits 

Reduced or 

Terminated

Did Not Respond

Yes

NoNo

Yes

Approved Based on 

Categorical Eligibility

No Change in Benefits

Responded, Benefits 

Reduced or 

Terminated

Did Not Respond

NoNoNo

Obtain Data on 

Reapplication by 

March 1

n.a.n.a.

No

Yes

NoNoNo

Directly Certified for 

Free Meals

Not Subject to 

Verification n.a. n.a. n.a.

FIGURE II.1

CASE STUDY OF VERIFICATION OUTCOMES IN 21 LARGE METROPOLITAN SFAs

9

Note: indicates group is included in the corresponding data collection. n.a. means “not applicable.”

Attends School Using 

Provision 2/3 and Not 

in Base Year

Not Subject to 

Verification n.a. n.a. n.a.
 10 

or termination of benefits on the basis of documentation provided, or (4) termination of benefits 

for failure to provide documentation. The objective of the case record abstraction work was to 

determine the proportion of verified students in each of these groups. 

As the figure indicates, we attempted interviews to measure household eligibility status with 

two groups defined by their verification outcomes: (1) students approved on the basis of income 

provided on the application who had no change in benefits, and (2) students approved on the 

basis of income provided on the application who did not respond to the SFA verification request 

by the deadline. 

Finally, for all nonresponders, we gathered data on whether the student was reapproved for 

benefits. Some of these reapproved nonresponders were in the interview sample and some were 

not. 

2. Selection of Districts 

In planning this project, FNS wanted a set of districts that would include large urban and 

suburban districts in metropolitan areas across the country. To implement this strategy, the FNS 

project officer first identified all metropolitan areas, as defined by the Office of Management and 

Budget, in which were located at least four SFAs that each had a minimum of 10,000 students. 

The FNS project officer then sent the list of these metropolitan areas and the SFAs within 

each one to the FNS special nutrition staff in each of the seven FNS regional offices. Regional 

office staff were asked to identify three or more SFAs in one metropolitan area in the region that 

would be willing to participate in the case study. Regional office staff members contacted state 

agencies and school districts, explained the study, and sought cooperation at both the state and 

district levels. 

Participation required facilitating a visit by MPR staff to abstract information from the 

verification files on individual verifications and providing names, addresses, and contact 
 11 

information for households selected for the interviewing portion of the study. Within the single 

large metropolitan area, the goal was to recruit one SFA with enrollment over 60,000 and two 

SFAs with enrollments between 10,000 and 60,000. An additional goal was to select at least one 

central city school district and at least one suburban district. To contain data collection costs, we 

considered for inclusion in the study only SFAs that could make application and verification data 

available at a central location; we excluded districts in which individual schools administer 

verification and the relevant data are stored only at each school. 

Using the list of SFAs that agreed to participate, the project officer and the MPR project 

director developed a list of districts that met the size and metropolitan status area requirements of 

the study and would be diverse in racial and ethnic composition. The FNS project officer then 

informed the SFA directors about the study and told them that MPR would be contacting them to 

discuss the details of the SFA’s participation. MPR staff then called each SFA to gather basic 

background information that would confirm the suitability of the SFA for the study, answer 

questions about the study, and schedule the visit. Participation was encouraged but not required, 

and some districts that MPR initially contacted ultimately decided not to participate. 

The following 21 school districts, located in seven large metropolitan areas, participated in 

the case study: 

Boston, Massachusetts 

Boston Public Schools 

Lawrence Public Schools 

Worcester Public Schools 

Los Angeles, California 

Anaheim Union High School District 

Hacienda La Puente Unified School District 

Long Beach Unified School District 

Orange Unified School District 
 12 

Minneapolis, Minnesota 

Anoka-Hennepin Independent School District 

Minneapolis Public Schools 

Norfolk-Newport News, Virginia 

Hampton City Schools 

Newport News Public Schools 

Virginia Beach City Public Schools 

Orlando, Florida 

Lake County School District 

Orange County School District 

Osceola School District 

Seminole County School District 

Salt Lake City, Utah 

Granite School District 

Jordan School District 

Salt Lake City School District 

Tulsa, Oklahoma 

Broken Arrow Public Schools 

Tulsa Public Schools 

These purposefully selected districts are not statistically representative of the full set of 

school districts nationwide that participate in the NSLP or of any subset or category of 

participating districts. However, the selection process sought to ensure diversity in region of the 

country, ethnic composition of students, and operational features of the NSLP. Accordingly, the 

case study districts provide general insights into the verification process in large urban school 

districts, which account for a high percentage of the students approved for a free or reduced-price 

lunch. In Section B, we provide data that allow comparison of the selected districts with all 

districts nationally. 

3. Data Abstraction 

MPR sent data abstractors to the 21 districts in mid-January 2003, about one month after 

SFAs were required to have completed the verification process. Abstractors reviewed SFA 
 13 

records (such as original applications, summary reports, and submitted documentation) for every 

household that was part of the verification sample. Using laptop computers, abstractors entered 

into a database the following information from applications on file for every household selected 

for verification: 

• Household size 

• Monthly income 

• Number of students 

• Name, school, and grade level of one student from the household (randomly selected 

in cases with more than one student) 

• Whether participation in the Food Stamp Program, TANF, or FDPIR was reported on 

the application (yes/no) 

• Whether the application reported that the child was a foster child (yes/no) 

• District’s initial determination of eligibility status (free, reduced-price, denied, 

missing) 

• Result of verification process (no change, free to reduced-price, free to paid, reducedprice to free, reduced-price to paid, missing) 

• Reason for status change, if applicable (change in income, change in household size, 

change in food stamp/TANF/FDPIR participation, refusal to cooperate or no 

response, other, missing) 

Depending on the data entered for these items and the size of the district, a computer 

program determined whether abstractors needed to record additional data about each household. 

Two groups of households were selected for this additional data collection: (1) those who were 

initially eligible for a free lunch based on household income (were not categorically eligible) or 

eligible for a reduced-price lunch and whose eligibility status did not change as a result of 

verification, and (2) those who were initially eligible for a free lunch based on household income 

(were not categorically eligible) or eligible for a reduced-price lunch and who did not respond to 

verification. For all nonresponders to verification, the MPR data abstractor attempted to 
 14 

determine whether the child was still enrolled in the district. Both of these two groups were 

potentially eligible for in-person interviews. If the estimated number of households in these 

categories exceeded the number to be interviewed, a computer program randomly selected 

households for whom contact information was collected during the abstracting phase; in this 

way, we collected information only for the households we would seek to interview. The contact 

information included parent name, home address, home and work phone numbers, and social 

security number. 

4. In-Person Interviews 

As noted, the study plan called for in-person interviews with parents or guardians in two 

groups of households—those who were from households whose initial eligibility status was 

either free based on income (not categorical eligibility) or reduced-price, and who either (1) 

responded appropriately and had a certification status that remained the same, or (2) did not 

respond to requests for verification information and whose NSLP benefits were to be terminated 

due to nonresponse. In each district, the goal was to interview up to 32 of the group who 

responded but had no change in meal price status and up to 42 of the group who did not respond 

to verification. We conducted computer-assisted personal interviews at the homes of selected 

families using data collection instruments and methods that were similar to those used to conduct 

the in-person part of the interviewing for the Evaluation of the NSLP Application/Verification 

Pilot Projects. These interviews focused on a few types of information: household composition, 

reported household income by person and by source, and documentation of reported income. We 

mailed a letter requesting cooperation and a brochure describing the research study to all 

households selected for interviews. We conducted interviews during February and March 2003. 

To maximize response rates, we offered a financial incentive of $20 to complete the in-home 

interview and provide the requested documentation. Table II.1 shows the number of cases 
 15 

TABLE II.1 

CASE STUDY OF VERIFICATION OUTCOMES: INTERVIEW SAMPLES AND 

RESPONSE RATES 

Nonresponder to 

Verification 

No Change as a 

Result of 

Verification 

Total Sample 889 665 

Ineligible Samplea 40 26 

Total Eligible Sample 849 639 

Completed Interviews 632 532 

Response Rate (Percent) 74.4 83.3 

Note: Data by district are presented in Table A.10. 

a

Ineligible sample included households selected for interview who no longer resided in the 

district or whose child no longer attended a district school. 
 16 

selected, number of selected cases that were ineligible for interview, number of completed 

interviews, and the response rates. Appendix Table A.10 provides these data by district. 

5. Follow-Up Data on Postverification Eligibility Status 

In March 2003, we recontacted all the case study districts to determine the free or reducedprice approval status—as of March 1—of each household that did not respond to the verification 

request by December 15, 2002. Such households could have fallen into one of three groups: 

(1) still on paid status, (2) approved for free status, (3) approved for reduced-price status. Use of 

the March 1 reference date meant that households had at least 10 weeks from the date by which 

they were supposed to provide verification during which they could submit a new application 

with the appropriate documentation. FNS was aware, based on anecdotal evidence, that a 

substantial proportion of households removed from the program each year after not responding 

to the verification requirement reapply and become certified again. The study aimed to 

document systematically the extent to which this occurred in the 21 sample districts. We 

provided each district with a list of the households that, according to our data abstraction, had not 

responded to the SFA’s verification request by December 15, 2002. The districts then returned 

the lists with an indicator of the March 1 status of each household—free, reduced-price, or paid. 

6. Analysis Methods 

Our goal was to select simple random samples of approximately equal size in each SFA to 

estimate the income status of two groups of cases selected for verification: (1) nonresponders to 

verification, and (2) cases with no change in benefits as a result of verification. We judged that 

the simple average of outcomes across districts overall and for each subgroup analysis was the 
 17 

most appropriate way to summarize the case study data. Equal samples by district minimize the 

variance of the district-level estimates.3

While the initial goal was to select approximately 42 nonresponders and approximately 32 

no-change cases per SFA, we learned in the data abstraction process that some study SFAs had 

fewer than the target numbers of cases in these groups. We compensated by increasing the 

samples in other study SFAs with more verified cases to achieve target samples of 881 

nonresponders (42 per SFA on average, with the actual number ranging from 8 to 52) and 665 

no-change cases (about 32 per SFA on average, with the actual number of cases ranging from 9 

to 41). 

For the main analysis, we calculated each outcome for each SFA and then calculated the 

mean of these SFA-level estimates. We refer to this as the mean outcome across districts in 

analytical tables in this report. We also calculated the simple means and percentages of all cases 

in the sample, which are presented in Appendix Table A.6 and A.7. 

In most parts of the analysis, we present tabulations for (1) all districts in the sample, (2) 

districts that used random sampling to select the verification sample, and (3) districts that used 

focused sampling to select the verification sample. The tabulations for all districts in the sample 

are presented to summarize verification outcomes of cases selected for verification and the 

eligibility status of verified cases with certain verification outcomes in the 21 case study districts. 

It is very important to bear in mind that these data for all districts may not accurately reflect 

the eligibility status of all students approved for free or reduced-price meals in the case study 

 3

An alternative would have been to select cases with probability proportional to size (with 

larger samples for SFAs with more cases in the group) or to reweight the data to reflect the 

probability of selection of each case. This approach would have been optimal for projecting 

results to the population of students in the selected groups in the 21 case study SFAs. 
 18 

districts or the verification outcomes that would have been found in a representative sample of 

students approved for free and reduced-price meals in the case study districts. A key reason for 

this limitation is that verification samples in focused-sampling districts are specifically designed 

to include a higher incidence of cases whose circumstances might lead them to become ineligible 

than would be expected to occur in the overall population. Specifically, the requirement that 

focused samples be selected from applications on which monthly income is within $100 of the 

monthly income eligibility cutoff for the approved benefit is designed to increase the likelihood 

that cases whose circumstances have changed to make them ineligible for their benefit are 

included in the sample. The rationale for this method of sampling is that the NSLP verification 

process is intended to deter households from providing false information and to uncover changes 

in circumstances and that oversampling these error-prone cases may be advantageous. The 

verification system was not designed to provide information about the eligibility or ineligibility 

of all students approved for benefits. 

Accordingly, because of the way samples are selected in focused-sampling districts, it is not 

appropriate to draw inferences about the eligibility status of all students approved for free or 

reduced-price meals from the study tabulations for all districts. However, these tabulations do 

support valid inferences about the verification outcomes and eligibility status of students with 

particular verification outcomes in all case study districts. While it was not within the scope of 

this study to examine the eligibility of all students approved for free or reduced-price meals in 

the case study districts, the study data can be used to address this issue. To facilitate such 

analysis, the report presents estimates of mean outcomes separately for the 11 random-sampling 

districts and the 10 focused-sampling districts. 
 19 

B. CHARACTERISTICS OF CASE STUDY DISTRICTS AND ALL DISTRICTS 

NATIONWIDE 

The districts participating in the study were not selected to be representative of all regular 

public districts nationwide. Indeed, on several dimensions, the participating districts as a group 

differed considerably from the average district nationally. Because much of the analysis 

examines outcomes separately for districts that used focused sampling and districts that used 

random sampling, we compare the characteristics of the focused-sampling and random-sampling 

districts included in the study. Table II.2 shows selected characteristics of (1) all districts 

nationally, (2) all districts included in the study, (3) study districts using random sampling, and 

(4) study districts using focused sampling. 

The most notable differences between the case study districts and all districts nationally 

relate to their size and location. The case study districts were, on average, about 10 times larger 

than the average public school district, both in the number of schools they operate and their total 

student enrollment. In addition, more than half the case study districts were urban (that is, in the 

central city of the metropolitan area), and none was rural; in contrast, only about six percent of 

all districts are urban, and more than half are rural. Compared with all districts, a higher 

proportion of the case study districts were in the South and West, and a much lower proportion 

were in the Midwest. 

The demographic characteristics of students in the case study districts also differed 

substantially from those in the average district. In the case study districts, a higher proportion of 

students were members of a racial/ethnic minority group (52 versus 21 percent) and a higher 

proportion had limited English proficiency (14 versus 5 percent). 

On some measures of poverty, however, the participating districts were not substantially 

different from the average district nationally. For example, the poverty rate among school-age 
 20 

TABLE II.2 

AVERAGE CHARACTERISTICS OF ALL DISTRICTS NATIONWIDE AND THE CASE STUDY DISTRICTS 

 

Districts Participating in the Case Study of Verification 

Outcomes 

All Regular 

School Districts 

Nationwide All Districts 

Districts Using 

Random 

Sampling 

Districts Using 

Focused 

Sampling 

Region (Percent) 

 

Northeast 15.6 14.3 18.2 10.0 

South 25.3 42.9 54.6 30.0 

Midwest 37.3 9.5 9.1 10.0 

West 21.7 33.3 18.2 50.0 

Urbanicity (Percent) 

Urban (primarily serves a central city of an MSA) 5.8 52.4 36.4 70.0 

Suburban (serves an MSA, but not primarily its 

central city) 41.5 47.6 63.6 30.0 

Rural (does not serve an MSA) 52.7 0.0 0.0 0.0 

Number of Schools (Mean) 6.9 69.1 54.2 85.5 

Total Number of Students (Mean) 3,619 49,725 36,809 63,932 

Enrollment Range (Percent) 

0 to 999 47.0 0.0 0.0 0.0 

1,000 to 2,499 23.4 0.0 0.0 0.0 

2,500 to 4,999 15.1 0.0 0.0 0.0 

5,000 to 9,999 8.2 0.0 0.0 0.0 

10,000 to 24,999 4.4 14.3 18.2 10.0 

25,000 to 49,999 1.2 47.6 63.6 30.0 

50,000 or more 0.7 38.1 18.2 60.0 

Title I Schools (Percent) 62.5 46.3 43.3 49.6 

Schoolwide Title I Schools (Percent) 23.4 36.6 34.2 39.4 

Percentage of Students Certified for NSLP (Mean) 

Free 29.0 36.4 32.8 40.2 

Reduced-Price 8.6 9.6 9.2 10.0 

Range Certified for Free or Reduced-Price Meals 

(Percent) 

0 to 33 52.2 23.8 27.3 20.0 

33 to 50 23.3 33.3 45.5 20.0 

50 or more 24.5 42.9 27.3 60.0 

Poverty Rate Among School-Age Children (Mean) 15.0 16.7 16.3 17.1 

Student Race/Ethnicity (Percent) 

White, Non-Hispanic 78.6 48.0 56.8 38.3 

Black, Non-Hispanic 7.6 18.8 14.2 23.8 

Hispanic (any race) 9.6 25.0 22.8 27.5 

Native American/Alaskan 3.3 1.5 1.9 0.9 

Asian, Pacific Islander 1.8 6.7 4.1 9.6 

Students Classified as Having Limited English 

Proficiency (Mean) 4.9 13.8 9.7 18.4 

Sample Size 12,845a

 21 11 10 
TABLE II.2 (continued) 

 

 21 

Sources: Child poverty data are from the Census Bureau’s 1999 Current Population Survey. All other data come from the 

National Center for Education Statistics’ Common Core of Data (CCD) for the 2001-2002 school year, except that in 

four districts we used estimates of the number of students approved for free and reduced-price meals furnished by SFA 

officials at the beginning of our study. These data were missing from CCD for the three districts in the Boston area. 

Data were available for Anaheim Union High School District, but do not reflect the fact that the SFA also serves an 

elementary district. In all four cases, we used NSLP eligibility data provided by SFA officials at the beginning of our 

study. 

Note: Averages for enrollment and NSLP eligibility among case study districts reflect the entire area served by the Anaheim 

SFA, which includes an elementary district. All other averages are based on data only for Anaheim Union High 

School District. 

a

Sample size was smaller than indicated on some items due to missing data. The minimum sample size was 10,773 on limited 

English proficiency. 

MSA = metropolitan statistical area. 

Regions are defined as follows: 

 Northeast: CT, MA, ME, NH, NJ, NY, PA, RI, VT 

 South: AL, AR, DC, DE, FL, GA, KY, LA, MD, MS, NC, OK, SC, TN, TX, VA, WV 

 Midwest: IA, IL, IN, KS, MI, MN, MO, ND, NE, OH, SD, WI 

 West: AK, AZ, CA, CO, HI, ID, MT, NM, NV, OR, UT, WA, WY 
 22 

children was about 17 percent, on average, in the case study districts and 15 percent, on average, 

across all districts. Furthermore, and most relevant to this study, the two groups were fairly 

close in their students’ participation in the NSLP. Among the case study districts, an average of 

32 percent of students were certified as eligible for free meals, and an additional 9.3 percent were 

certified at the reduced-price level. At all districts nationwide, the comparable rates were 29 

percent and 8.6 percent. 

The data also indicate that districts using focused sampling that were included in the case 

study exhibited marked differences in their characteristics and the characteristics of their students 

from the random-sampling districts included in the study. The focused-sampling districts had 

larger average enrollment (63,932 versus 36,809), and they were more likely to serve a central 

city of their metropolitan area (70.0 versus 36.4) percent and less likely to serve a suburban area 

within the metropolitan area. The focused-sampling districts had more schools in which some 

students were eligible for Title I (49.6 versus 43.3 percent), more schools in which all students 

were eligible for Title I (39.4 versus 34.2 percent), a higher percentage of students approved for 

free and reduced-price school meals (50.2 versus 42.0 percent), and a higher rate of poverty 

among school-age children (17.1 versus 16.3 percent). Finally, focused-sampling districts had a 

larger percentage of students who were black, non-Hispanic, Hispanic, or Asian or Pacific 

Islander (60.9 versus 41.1 percent) and a smaller percentage of students who were white, 

non-Hispanic or Native American or Alaskan (39.2 versus 58.7 percent). 

Table II.3 shows data from the National Center for Education Statistics’ Common Core of 

Data (CCD) for each participating district. 
 23 TABLE II.3 CHARACTERISTICS OF CASE STUDY DISTRICTS Boston, Massachusetts Los Angeles, California Minneapolis, Minnesota Boston Lawrence Worcester Anaheim Hacienda – La Puente Long Beach Orange Annoka- Hennepin Minneapolis Region (N=Northwest, S=South, M=Midwest, W=West) N N N W W W W M M Urbanicitya (U=Urban, S=Suburban, R=Rural) U U U U S U S S U Number of Schools 134 22 50 21 37 90 42 59 144 Percent Title I Eligible 92.5 86.3 72.0 42.9 62.2 80.0 31.0 28.8 57.6 Percent Schoolwide Title I 92.5 86.3 72.0 28.6 43.2 65.6 31.0 0.0 57.6 Total Enrollment 62,141 12,697 25,826 52,000 25,282 96,488 31,689 41,419 48,155 Students Certified for NSLP (Percentage) Free 64.1 62.4 47.3 48.1 41.4 57.0 27.9 9.4 57.5 Reduced-Price 9.0 14.0 7.9 15.4 13.4 9.9 6.7 5.8 9.1 Poverty Rate Among School-Age Children 29.7 38.0 30.9 16.3 13.9 29.3 10.0 4.9 23.2 Student Race/Ethnicity (Percentage) White, Non-Hispanic 14.7 11.2 51.5 27.3 10.0 17.3 43.6 90.0 26.6 Black, Non-Hispanic 47.5 2.7 11.2 3.4 2.9 19.5 1.7 3.7 43.9 Hispanic (any race) 28.4 82.8 28.7 52.6 69.3 46.7 39.8 1.6 11.1 Native American 0.4 <0.1 0.6 0.5 0.4 0.3 1.1 1.1 4.1 Asian, Pacific Islander 8.9 3.3 8.0 16.2 17.1 16.1 12.5 3.6 14.3 Students Classified as Having Limited English Proficiency (Percentage) 21.0 21.4 12.7 27.3 25.4 32.9 23.2 3.1 24.0 

Method of Selecting Verification Sample Focused Random Random Focused Focused Focused Random Random Focused 
 24 TABLE II.3 (continued) Newport News, Virginia Orlando, Florida Hampton Newport News Virginia Beach Lake County Orange County Osceola County Seminole County Region (N=Northwest, S=South, M=Midwest, W=West) S S S S S S S Urbanicitya (U=Urban, S=Suburban, R=Rural) U U U S S S S Number of Schools 37 47 85 52 184 48 72 Percent Title I Eligible 40.5 38.3 15.3 48.1 44.6 29.2 27.8 Percent Schoolwide Title I 5.4 31.9 3.5 26.9 44.6 22.9 26.4 Total Enrollment 23,192 32,907 75,970 30,689 157,433 37,779 62,786 Students Certified for NSLP (Percentage) Free 29.7 35.5 16.5 31.3 34.0 35.7 20.0 Reduced-Price 8.3 9.7 8.7 8.7 9.8 12.5 7.6 Poverty Rate Among School-Age Children 14.5 17.0 8.5 16.9 14.8 15.5 9.7 Student Race/Ethnicity (Percentage) White, Non-Hispanic 36.3 36.6 62.0 73.6 42.6 47.3 69.1 Black, Non-Hispanic 59.0 55.8 28.0 16.2 28.9 9.5 13.9 Hispanic (any race) 2.4 4.2 4.0 8.9 24.5 40.5 13.7 Native American 0.3 0.9 0.3 0.2 0.4 0.2 0.3 Asian, Pacific Islander 1.9 2.5 5.6 1.0 3.6 2.5 3.0 Students Classified as Having Limited English Proficiency (Percentage) 1.1 0.7 1.0 3.1 11.6 16.7 3.1 

Method of Selecting Verification Sample Focused Random Focused Random Focused Random Random 
 25 TABLE II.3 (continued) Salt Lake City, Utah Tulsa, Oklahoma Granite Jordan Salt Lake City Broken Arrow Tulsa Region (N=Northwest, S=South, M=Midwest, W=West) W W W S S Urbanicitya (U=Urban, S=Suburban, R=Rural) S S U S U Number of Schools 98 81 42 22 84 Percent Title I Eligible 16.3 12.3 47.6 36.4 61.9 Percent Schoolwide Title I 16.3 7.4 45.2 0.0 61.9 Total Enrollment 72,082 73,494 25,161 14,725 42,302 Students Certified for NSLP (Percentage) Free 24.4 11.3 42.8 14.6 52.7 Reduced-Price 9.5 6.4 10.1 8.2 11.0 Poverty Rate Among School-Age Children 8.3 4.2 17.0 6.0 21.8 Student Race/Ethnicity (Percentage) White, Non-Hispanic 74.8 91.8 53.9 84.4 43.1 Black, Non-Hispanic 1.4 0.5 4.1 4.1 35.6 Hispanic (any race) 16.1 5.2 30.3 3.0 11.3 Native American 1.2 0.4 2.0 7.0 8.6 Asian, Pacific Islander 6.5 2.0 9.7 1.4 1.3 Students Classified as Having Limited English Proficiency (Percentage) 15.0 5.7 33.5 1.8 6.0 Method of Selecting Verification Sample Random Focused Focused Random Random Sources: Child poverty data are from the Census Bureau’s 1999 Current Population Survey. All other data come from the National Center for Education Statistics’ Common Core of Data (CCD) for the 2001-2002 school year, except for NSLP eligibility data for four districts. The data were missing from the CCD for the three districts in the Boston area. Data were available for Anaheim Union High School District but do not reflect the fact that the SFA also serves an elementary district. In all four cases, we used NSLP eligibility data provided by SFA officials at the beginning of our study.

Note: For Anaheim, data on enrollment and NSLP eligibility reflect the entire area served by the SFA, which includes an elementary district. All other data 

pertain only to Anaheim Union High School District. 
 26 TABLE II.3 (continued) aUrban = primarily serves a central city of an MSA; Suburban = serves an MSA, but not primarily its central city; Rural = does not serve an MSA. MSA = metropolitan statistical area. Regions are defined as follows: Northeast: CT, MA, ME, NH, NJ, NY, PA, RI, VT South: AL, AR, DC, DE, FL, GA, KY, LA, MD, MS, NC, OK, SC, TN, TX, VA, WV Midwest: IA, IL, IN, KS, MI, MN, MO, ND, NE, OH, SD, WI West: AK, AZ, CA, CO, HI, ID, MT, NM, NV, OR, UT, WA, WY
 27 

III. OUTCOMES OF VERIFICATION 

This chapter presents the results of the abstraction of verification outcomes for the average 

of the 21 case study districts, and separately for the 11 random-sampling districts and 10 

focused-sampling districts. Study team members reviewed each case selected for verification in 

each participating district, and recorded, among other variables, the initial meal price status of 

the case and the outcome of verification. Because we reviewed all cases selected for verification 

in the 21 districts, the tabulations are a census of the verification outcomes in these districts in 

the 2002-2003 school year. 

Care must be exercised in drawing inferences on the basis of verification outcomes about 

rates of eligibility or ineligibility for benefits of the underlying populations of students approved 

for free or reduced-price school meals in these districts. First, as discussed more fully in the next 

chapter, we found that, for some cases, information from the study’s survey led to a different 

NSLP eligibility status than the one the SFA approved. At least some of this difference appears 

to be due to the fact that some households underreported their income to the district, and some is 

due to errors by the SFA in processing information that households provided. Second, 10 of the 

21 case study districts used focused sampling, which targets for verification those households 

with a higher likelihood that changes in income or household size could affect eligibility. 

Because of this sampling method, the results of verification in focused-sampling SFAs and in the 

average study SFA do not necessarily reflect the underlying circumstances of the population of 

all students approved for free and reduced-price meals in the districts participating in the study. 

On the other hand, to the extent that random-sampling SFAs used a procedure that approximated 

a scientifically valid procedure for selecting their verification samples, the results from 
 28 

verification represent an unbiased estimate of the verification outcome results we would expect if 

all students subject to verification sample selection had been verified in these SFAs. 

A. OVERALL OUTCOMES 

With the information available on key variables (status before and after verification, whether 

or not the household responded, child enrollment status at the end of the verification period, and 

basis of initial certification—income, categorical, and foster child), we found that households 

were distributed across 26 unique categories. Appendix Tables A.1 and A.2 present detailed 

tabulations showing all categories. In the following sections, we discuss the main groups of 

outcomes. 

1. Summary for All Households 

On average, about two-thirds of households (67.1 percent) had a verification outcome that 

required a reduction or termination of benefits (Table III.1): 50.4 percent of all households did 

not respond to the SFA’s request for verification, and 16.7 percent provided documentation that 

led the SFA to reduce or terminate their benefit. Of the latter group, 11.9 percent responded to 

their district’s request for documentation, but the SFA determined, based on the information 

provided, that they were not eligible for free meals at the time of verification. In an additional 

4.8 percent of cases initially approved for reduced-price meals, the SFA determined that the 

documentation provided showed the household was not eligible for reduced-price meals. 

 Almost one-third of households (31.7 percent) had no change in their benefits. On the basis 

of documentation provided, the SFA concluded that the household was eligible in December for 

the benefit it had been approved for earlier in the fall. On average, 23.8 percent of cases selected 

for verification were approved for free meals initially and had no change in status, and 

7.9 percent maintained their approval for reduced-price meals. 
 29 

TABLE III.1 

SUMMARY OF VERIFICATION OUTCOMES FOR ALL HOUSEHOLDS, OVERALL AND 

BY SAMPLING METHOD USED 

 (Mean Percentages Across Districts) 

 All Districts 

Districts That 

Used Random 

Sampling 

Districts That 

Used Focused 

Sampling 

Responder: No Change in 

Benefits 31.7 39.5 23.1 

Free to free 23.8 31.0 15.9 

Reduced-price to reduced-price 7.9 8.5 7.2 

Responder: Benefits Increased 1.2 1.5 0.9 

Reduced-price to free 1.2 1.5 0.9 

Responder: Benefits Reduced or 

Terminated 16.7 13.6 20.0 

Free to reduced-price 8.8 7.3 10.5 

Free to paid 3.1 3.6 2.4 

Reduced-price to paid 4.8 2.7 7.1 

Nonresponder 50.4 45.3 56.0 

Initially free 33.8 33.9 33.7 

Initially reduced-price 16.6 11.4 22.3 

Total 100 100 100 

Note: Excluded are 3 of the original 5,183 households—those approved as foster child and for 

which key information (for example, on outcome status) was missing or possibly 

miscoded. 
 30 

Households rarely had their benefit level increased as a result of verification. Only 1.2 

percent of cases had their eligibility status changed from reduced-price to free. There are two 

possible reasons for such a change: (1) the household had lower incomes and/or more members 

than it had reported on their original application, or (2) it had begun participating in one or more 

of the programs (TANF, the Food Stamp Program, or FDPIR) that would have made it 

categorically eligible for free meals.1

Overall, 50.4 percent of verified cases did not respond to the verification request and were 

subject to having their benefits terminated. Withdrawals from the district did not appear to be a 

major reason for nonresponse to the verification process. Abstractors attempted to determine 

whether the sampled children in nonresponding households initially approved on the basis of 

income were still enrolled in the district at the conclusion of the verification period (on or about 

December 15, 2002); if they had withdrawn, that would be a possible explanation for the 

nonresponse. On average, however, only 2.4 percent of nonresponders had withdrawn, while 

84.6 percent were still enrolled; we could not determine enrollment status for the remaining 13.1 

percent.2

Table III.1 also shows the outcomes of verification separately for the case study districts that 

used random sampling to select cases for verification and the case study districts that used 

focused sampling. As described in Chapter I, districts using random sampling select cases for 

verification from among all approved cases. They must select the lesser of three percent or 3,000 

applications. Districts using focused sampling devote their verification efforts to cases in which 

 1

There was considerable variability about the means across sites; see Appendix Table A.4.

2

Computed from rows D-I and M-R in Table A.1. (For child enrolled: (24.7 + 0.9 + 13.1 + 

0.8)/46.7 = .846; child not enrolled: (0.6 + 0.4 + 0.1)/46.7 = .024; for child enrollment status 

missing: (3.4 + 0.5 + 1.9 + 0.3)/46.7 = .131). 
 31 

monthly income is within $100 of the cutoff of eligibility or who receive TANF or food stamp 

benefits. The sample is required to include the lesser of 1 percent of all applications or 1,000 

applications that are selected from all applications within $100 of the monthly income limit plus 

0.5 percent of all applications or 500 applications selected from cases receiving TANF or food 

stamps. Because of these differences in the way verification samples are selected, it is important 

to examine verification outcomes separately for districts in the study using each method. The 

middle section of Table III.1 presents basic verification outcomes for case study districts that 

used random sampling and the right-hand section presents this information for case study 

districts that used focused sampling. 

Table III.1 shows marked differences in verification outcomes of random- and focusedsampling districts. A smaller percentage of verified cases had benefits reduced or terminated in 

random-sampling districts than in focused-sampling districts—58.9 percent, compared to 76.0 

percent. Correspondingly, random-sampling districts had a larger percentage of verified cases 

with no change in benefits (39.5 percent, compared to 23.1 percent) and a slightly larger 

percentage with an increase in benefits (1.5 percent, compared to 0.9 percent). 

2. Summary of Results Based on How Households’ Initial Eligibility Was Determined 

In this section, we summarize verification outcomes separately for households that were 

initially approved on the basis of income and household size and those that were approved on the 

basis of categorical eligibility (participating in TANF, the Food Stamp Program, or FDPIR). 

Overall, 87.2 percent of cases were in the first group and 12.8 percent were categorically eligible 

(Table III.2). 

The outcome distribution for households approved on the basis of income was generally 

similar to the distribution overall. On average, just over half (53.1 percent) were nonresponders. 
 32 TABLE III.2 SUMMARY OF VERIFICATION OUTCOMES, BY BASIS FOR INITIAL APPROVAL, OVERALL AND BY SAMPLING METHOD USED (Mean Percentages Across Districts) All Districts Districts That Used Random Sampling Districts That Used Focused Sampling Approved Based on Incomea Categorically Eligible Approved Based on Incomea Categorically Eligible Approved Based on Incomea Categorically Eligible Percentage of Cases Verified 87.2 12.8 92.7 7.3 82.2 17.8 Responder: No Change in Benefits 27.6 62.1 34.5 65.1 19.9 58.7 Free to free 18.1 62.1 23.5 65.1 12.1 58.7 Reduced-price to reduced-price 9.5 n.a. 11.0 n.a. 7.8 n.a. Responder: Benefits Increased 1.5 2.0 0.9 Reduced-price to free 1.5 n.a. 2.0 n.a. 0.9 n.a. Responder: Benefits Reduced or Terminated 17.9 4.3 14.8 6.1 21.3 2.3 Free to reduced-price 10.2 0.7 9.3 1.3 11.3 0 Free to paid 2.3 3.6 2.1 4.8 2.4 2.3 Reduced-price to paid 5.4 n.a. 3.4 n.a. 7.6 n.a. Nonresponder 53.1 33.7 48.8 28.8 57.8 39.1 Initially free 34.3 33.7 34.8 28.8 33.7 39.1 Initially reduced-price 18.8 n.a. 14.0 n.a. 24.1 n.a. Total 100 100 100 100 100 100 aExcluded are 41 of the original 5,183 households—those approved as foster child cases. n.a. = not applicable. 
 33 

Of the responders, 17.9 percent had their benefits reduced (10.2 percent) or terminated (7.7 

percent), almost 28 percent had no change, and just under 2 percent had their benefits increased 

from reduced-price to free. 

Verification outcomes for categorically eligible households differed markedly from the 

outcomes for households approved on the basis of reported income. Just less than two-thirds of 

categorically eligible households (62.1 percent, on average) had no change in benefits, an 

average of about one-third did not respond (33.7 percent), and the rest responded and had their 

benefits reduced or terminated (4.3 percent) (Table III.2). The average rate of nonresponse to 

verification differed by basis of eligibility: about one-third of categorically eligible households 

failed to respond (33.7 percent), compared to over half of households whose eligibility was based 

on their reported income (53.1 percent). 

Districts using random sampling had a smaller fraction of categorically eligible verified 

cases than districts using focused sampling. Less than 1 in 10 verified cases in random-sampling 

districts were categorically eligible (7.3 percent), compared to just under 2 in 10 (17.8 percent) in 

focused-sampling districts. We cannot determine from the available data the extent to which this 

difference reflects underlying differences in the percentage of all students certified who are 

categorically eligible and the extent to which it results from the method of selecting the 

verification sample. 

Districts using random sampling and districts using focused sampling had similar patterns of 

outcomes when comparing cases approved on the basis of income with categorically eligible 

cases. Under both sampling methods, cases approved on the basis of income had smaller 

percentages with no change in benefits due to verification, larger percentages with benefits 

reduced or terminated on the basis of a response, and larger percentages who were 

nonresponders than did categorically eligible cases. 
 34 

The pattern that random-sampling districts had larger fractions of cases with no change and 

smaller fractions with benefits reduced or terminated than did focused-sampling districts holds 

separately for cases approved on the basis of income and categorically eligible cases. In randomsampling districts, 34.5 percent of the cases approved on the basis of income had no change, 

compared to 19.9 percent in focused-sampling districts. Likewise, among categorically eligible 

cases, in random-sampling districts 65.1 percent cases had no change, compared to 58.7 percent 

in focused-sampling districts. Benefits were reduced or terminated among 63.6 percent of cases 

approved on the basis of income in random-sampling districts and among 79.1 percent in 

focused-sampling districts. Among categorically eligible cases, the benefit reduction and 

termination rate was 34.9 percent in random-sampling districts, compared to 41.4 percent in 

focused-sampling districts. 

3. Placing the Verification Outcome Results in Perspective 

To gain perspective on the findings reported in this chapter, it is useful to compare the main 

results with those of other studies. The results presented in Table III.1 for the 21 case study 

districts can be directly compared with the findings of a recent survey of a nationally 

representative sample of SFAs sponsored by the USDA Economic Research Service (ERS) 

(Gleason et al. 2003). In the ERS study, interviews were conducted with SFA representatives, 

who were asked to report the outcomes of verification in their district in school year 2001-2002. 

The main differences between the recent ERS study and the present case study are that (1) the 

ERS study is nationally representative and this study is not; and (2) the ERS study obtained 

aggregate data on outcomes through reports from SFA staff, whereas the present case study 

reviewed the outcomes of each case selected for verification. 

A second study with which our findings can be compared was conducted by FNS in school 

year 2001-2002 (Strasberg 2003). In the 2003 FNS study, FNS regional office staff who are 
 35 

expert in application and verification rules recorded information from the verification case files 

of representative samples of households selected for verification in 14 large metropolitan SFAs 

across the country. As in the case study, the 14 large metropolitan SFAs were a convenience 

sample; they are not statistically representative. Both the data collection methodology and 

method of selecting the sample of SFAs were similar in the case study and the FNS regional 

office verification study. 

a. Comparing the Case Study with the ERS Study 

The 21 case study districts had a larger percentage of cases whose benefits were reduced, 

terminated or subject to termination and a smaller percentage with no change than the ERS study 

found nationwide. On average, districts in the ERS study reported that 69 percent of cases 

selected for verification in school year 2002-2002 had no change in benefits, 2 percent had 

benefits increased, 6 percent had their benefits reduced, and 23 percent had their benefits 

terminated (Gleason et al. 2003). In contrast, in school year 2002—2003, the 21 case study 

districts had 32 percent of verified cases with no change, 58 percent either did not respond or 

responded and had benefits terminated, 9 percent had benefits reduced, and just over 1 percent 

had benefits increased. This comparison indicates that the 21 case study districts have more 

cases in which benefits are reduced or terminated as a result of verification and fewer in which 

they remain unchanged than occurs in the typical district nationwide. 

The case study included districts in metropolitan areas whose enrollment ranged from just 

over 10,000 students to approximately 157,000. The case study did not include any districts with 

fewer than 10,000 students or any very large districts. Gleason et al. (2003) also present data for 

districts with enrollment of 10,000 students or more for a national sample that includes very 

large districts. The average percentage of verified cases whose benefits were reduced or 
 36 

terminated or subject to termination for nonresponse (the benefit reduction termination rate) 

among districts with 10,000 or more students is about 50 percent. This compares with a benefit 

reduction termination rate of 64 percent in the average case study district. The difference 

indicates that, on average, the districts in the case study had a higher benefit 

reduction/termination rate than the typical district nationwide with enrollment exceeding 10,000 

students. These differences underscore the need for caution in applying the case study findings 

nationally. 

b. Comparing Verification Outcomes in the Case Study and the FNS Regional Office 

Verification Study 

Findings of the case study and the FNS regional office verification study are similar. In the 

case study, about 13 percent of cases selected for verification were categorically eligible. In the 

FNS regional office verification study, on average across the 14 sites, 18 percent of cases were 

categorically eligible.3

 The percentage of all cases with no change was 31.7 percent in the case 

study, compared to 36.1 percent in Strasberg (2003).4 Similarly, the percentages of cases whose 

benefits were reduced or terminated on the basis of a response or who did not respond were 67.1 

percent in the case study (16.7 percent reduced or terminated based on a response and 50.5 

 3

To make the estimates as comparable as possible, data for the Regional Office Verification 

Study are computed as the simple means across sites of the data shown by site in Table 2 in the 

FNS study (Strasberg 2003). 

4

Calculated from Table 4 in Strasberg (2003). Among districts using random sampling, the 

average percentage with no change was 40 percent in the Case Study and 47 percent in the 

Regional Office Verification Study. Among districts using focused sampling, the average 

percentage with no change was 23 percent in the Case Study and 28 percent in the Regional 

Office Verification Study. 
 37 

nonresponders), and 62.4 (14.4 percent reduced or terminated based on a response and 48 

percent nonresponders in Strasberg [2003]).5

B. VERIFICATION OUTCOMES BY DISTRICT CHARACTERISTICS 

We explored whether verification outcomes differed for groups of districts that were 

identified on the basis of common characteristics. In addition to the method of selecting the 

verification sample, these characteristics included the size of the district as measured by total 

enrollment, the percentage of the district’s students approved for free or reduced-price meals, 

whether the district uses direct certification, and whether the district uses one multichild 

application per family or requires a separate application for each child in the family. We 

obtained the data necessary to form the groups during initial or follow-up telephone discussions 

with SFA authorities about this study.6

 Table III.3 and the following tables present the results of 

this analysis, with outcomes condensed into 10 categories. Next we describe some highlights 

from these analyses, focusing on two summary measures: (1) the percentage of cases with no 

change in benefits as a result of verification, and (2) the percentage of cases whose benefits were 

reduced, terminated, or did not respond to the verification request. 

1. District Enrollment 

As described in Chapter II, all districts in this study are large relative to the average district 

nationwide. However, we compared the verification outcomes of districts that enroll between 

 5

Among districts using random sampling, the average percentage with benefits reduced, 

terminated or subject to termination for nonresponse was 58 percent in the Case Study and 50 

percent in the Regional Office Verification Study. Among districts using focused sampling, the 

average percentage with benefits reduced, terminated, or subject to termination for nonresponse 

was 76 percent in the Case Study and 71 percent in the Regional Office Verification Study. 

6

In two cases, we obtained missing data from the CCD. 
 38 

TABLE III.3 

SUMMARY OF VERIFICATION OUTCOMES, OVERALL AND BY SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

Group 

All 

(n=21) 

District Used 

Random 

Sampling 

(n=11) 

District Used 

Focused 

Sampling 

(n=10) 

Income-Eligible Householdsa 

 Responded—no change 23.4 27.9 18.5 

 Responded—benefit terminated 6.8 4.6 9.3 

 Responded—benefit reduced 8.8 7.2 10.5 

 Responded—benefit increased 1.2 1.5 0.9 

 Nonresponder 47.0 41.0 53.6 

 Subtotal 87.2 82.2 92.7 

Categorically Eligible (TANF, Food Stamps, 

FDPIR) 

 Responded—no change 8.2 11.5 4.5 

 Responded—benefit terminated 1.1 1.8 0.2 

 Responded—benefit reduced 0.1 0.2 0.0 

 Responded—benefit increased 3.4 4.2 2.5 

 Subtotal 12.8 17.8 7.3 

Total Responded—No Change 31.6 39.4 23.0 

Total Benefits Reduced, Terminated, or Did 

Not Respond 67.2 59.0 76.1 

a

Excluded are 41 of the original 5,183 households—those approved as foster child. 
 39 

10,000 and 50,000 students with the outcomes of districts that enroll between 50,000 and 

157,000 students (Table III.4). For the smaller-size group, we also present outcomes separately 

for the nine random-sampling and four focused-sampling districts within the size group. For the 

larger-size group, which contains two random-sampling districts and six focused-sampling 

districts, the number of districts was too small to support separate estimates. 

Overall, compared to the smaller-district group, the larger-district group has a smaller 

percentage of verified cases with no change (23.5 versus 36.6 percent, in the next to last row of 

Table III.4) and a larger percentage with benefits reduced, with benefits terminated, or who did 

not respond (75.4 versus 62.1 percent, in the last row of Table III.4). However, a high degree of 

overlap exists between the size grouping and the method of sampling—9 of 13 smaller districts 

used random sampling, and 6 of 8 larger districts used focused sampling. Furthermore, the four 

smaller districts that used focused sampling have outcomes similar to those for the large-district 

group, in which focused-sampling districts predominate. For example, 27.6 percent of verified 

cases in the small districts that used focused sampling had no change, compared to 23.5 percent 

in the large-district group. Correspondingly, the percentages benefits reduced, terminated, or 

who did not respond were 75.4 and 71.6, in the small-district group using focused sampling and 

the large-district group, respectively. This pattern leads us to suspect that method of sampling, 

rather than size, is the reason for the overall differences between the small and large districts. 

2. Percentage of Students Approved for Free or Reduced-Price Meals 

We compared outcomes in case study districts with less than 50 percent of their students 

approved for free or reduced-price meals with the outcomes in districts with more than 50 

percent of their students approved (Table III.5). Overall, the group with less than 50 percent of 

students approved had a larger percentage with no change (36.4 versus 25.4 percent) and a 

smaller percentage with benefits reduced, terminated, or who did not respond (62.2 versus 74.0 
 40 

TABLE III.4 

SUMMARY OF VERIFICATION OUTCOMES BY DISTRICT ENROLLMENT 

AND SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

District Enrollment 10,000 to 50,000 

Group 

All 

(n=13) 

District Used 

Random 

Sampling 

(n=9) 

District Used 

Focused 

Sampling 

(n=4) 

District 

Enrollment 

Over 50,000 

(n=8) 

Income-Eligible Householdsa 

 Responded—no change 25.7 27.4 21.9 19.6 

 Responded—benefit terminated 5.2 4.5 6.7 9.5 

 Responded—benefit reduced 8.2 7.5 9.7 9.7 

 Responded—benefit increased 1.3 1.5 0.9 1.1 

 Nonresponder 43.6 39.8 52.2 52.4 

 Subtotal 84.1 80.8 91.4 92.3 

Categorically Eligible (TANF, Food 

Stamps, FDPIR) 

 Responded—no change 10.8 13.1 5.7 3.9 

 Responded—benefit terminated 1.7 2.3 0.3 0.1 

 Responded—benefit reduced 0.2 0.3 0.0 0.0 

 Responded—benefit increased 3.3 3.5 2.6 3.7 

 Subtotal 15.9 19.2 8.6 7.7 

Total Responded—No Change 36.6 40.5 27.6 23.5 

Total Benefits Reduced, Terminated, or 

Did Not Respond 62.1 57.9 71.6 75.4 

a

Excluded are 41 of the original 5,183 households—those approved as foster child. 
 41 

TABLE III.5 

SUMMARY OF VERIFICATION OUTCOMES BY PERCENTAGE OF STUDENTS APPROVED FOR 

FREE AND REDUCED-PRICE MEALS AND SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

Less than 50 Percent of Students 

Approved for Free or Reduced-Price 

Meals 

More than 50 Percent of Students 

Approved for Free or ReducedPrice Meals 

Group 

All 

(n=12) 

District 

Used 

Random 

Sampling 

(n=8) 

District 

Used 

Focused 

Sampling 

(n=4) 

All 

(n=9) 

District 

Used 

Random 

Sampling 

(n=3) 

District 

Used 

Focused 

Sampling 

(n=6) 

Income-Eligible 

Householdsa

 

 

 Responded—no change 25.6 30.7 15.5 20.5 20.5 20.5 

 Responded—benefit 

terminated 6.3 5.0 8.7 7.6 3.4 9.7 

 Responded—benefit 

reduced 7.1 6.8 7.9 10.3 8.2 12.3 

 Responded—benefit 

increased 1.4 1.7 0.8 1.0 1.1 0.9 

 Nonresponder 43.9 37.2 57.4 51.1 51.1 51.0 

 Subtotal 84.4 81.4 90.3 90.4 84.3 94.3 

Categorically Eligible 

(TANF, Food Stamps, 

FDPIR) 

 Responded—no change 10.8 13.1 6.2 4.9 7.4 3.5 

 Responded—benefit 

terminated 1.8 2.5 0.5 0.1 0.2 b 

 Responded—benefit 

reduced 0.1 0.1 0.0 0.2 0.6 0.0 

 Nonresponder 3.0 3.0 3.0 4.3 7.6 2.2 

 Subtotal 15.6 18.6 9.7 9.6 15.7 5.7 

Total Responded—No 

Change 36.4 43.7 21.6 25.4 27.9 23.9 

Total Benefits Reduced, 

Terminated, or Did Not 

Respond 62.2 54.6 77.6 74.0 71.1 75.1 

a

Excluded are 41 of the original 5,183 households—those approved as foster child. 

b

Rounds to less than one-tenth of one percent. 
 42 

percent) than did districts with more than 50 percent of their students approved. However, this 

difference by percentage of students approved is due entirely to the districts that used random 

sampling. Among districts using focused sampling, outcomes were similar by size category. For 

example, the percentage who had their benefits reduced, terminated, or who did not respond was 

54.6 percent in random-sampling districts with less than 50 percent of students approved, 

compared to 71.1 percent in random-sampling districts with more than 50 percent of students 

approved. In contrast, among focused-sampling districts, the percentage who had their benefits 

reduced, terminated or who did not respond was 77.6 percent in districts with less than 50 

percent of students approved and 75.1 percent in districts with more than 50 percent of students 

approved. 

In a nationally representative study, Gleason et al. (2003) found the opposite relationship 

between the percentage of students approved and the percentage of students whose benefits were 

reduced or terminated or who did not respond to the verification request: districts with larger 

percentages of students approved had lower benefit reduction and termination rates.7

 

3. Use of Direct Certification 

The verification results for districts that used direct certification were very similar to those 

for districts that did not use it (Table III.6). The percentage of cases with no change was 31.7 

percent among districts using direct certification and 30.9 among districts not using it. The 

percentage of cases whose benefits were reduced, terminated, or who did not respond was also 

similar—66.8 percent in districts using direct certification and 68.6 percent in districts not using 

it. 

 7

Gleason et al. (2003), Table III.3. 
 43 

TABLE III.6 

SUMMARY OF VERIFICATION OUTCOMES BY DIRECT CERTIFICATION POLICY 

AND SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

District Used Direct Certification 

Group 

All 

(n=17) 

District Used 

Random 

Sampling 

(n=8) 

District Used 

Focused 

Sampling 

(n=9) 

District Did 

Not Use 

Direct 

Certification 

(n=4) 

Income-Eligible Householdsa

 

 Responded—no change 23.6 29.9 18.1 22.4 

 Responded—benefit terminated 6.7 4.6 8.5 7.5 

 Responded—benefit reduced 8.5 6.8 10.1 9.7 

 Responded—benefit increased 1.4 1.9 0.9 0.5 

 Nonresponder 46.6 36.5 55.6 48.4 

 Subtotal 86.9 79.7 93.2 88.5 

Categorically Eligible (TANF, Food 

Stamps, FDPIR) 

 Responded—no change 8.1 12.6 4.1 8.5 

 Responded—benefit terminated 1.3 2.5 0.2 0.0 

 Responded—benefit reduced 0.1 0.3 0.0 0.1 

 Responded—benefit increased 3.6 4.8 2.4 2.9 

 Subtotal 13.1 20.3 6.8 11.5 

Total Responded—No Change 31.7 42.5 22.2 30.9 

Total Benefits Reduced, Terminated, or 

Did Not Respond 66.8 55.6 76.8 68.6 

a

Excluded are 41 of the original 5,183 households—those approved as foster child. 
 44 

Among the 17 case study districts using direct certification, 8 used random sampling and 9 

used focused sampling. Among the four case study districts, two used random sampling and two 

used focused sampling. Thus the mix of random and focused sampling is similar among the 

group of districts using direct certification and the group not using it. Within the group of 

districts that used direct certification, we observe the same pattern of difference between 

random-sampling and focused-sampling districts as is evident among all districts—larger 

percentages of cases with no change and smaller percentages whose benefits were reduced or 

terminated or who did not respond in the random-sampling districts. 

4. Use of Multichild Versus Single-Child Applications 

The verification results for districts that used multichild applications were generally similar 

to those for districts that used single-child applications (Table III.7). Again, within the group of 

16 districts that used a multichild application, we observe the same pattern of difference between 

random-sampling and focused-sampling districts as is evident among all districts—larger 

percentages of cases with no change and smaller percentages whose benefits were reduced or 

terminated or who did not respond in the random-sampling districts. 

C. REAPPROVAL RATES AMONG NONRESPONDERS 

An average of about one-fourth of households whose benefits had been terminated because 

they failed to provide adequate documentation during verification had been recertified for free or 

reduced-price meals by March 1, 2003—16 percent for free meals and 8.3 percent for reducedprice meals. About 71 percent were still in paid (full-price) status as of March 1, 2003, about 10 

weeks after the verification period ended, according to SFA records (Table III.8). About four 
 45 

TABLE III.7 

SUMMARY OF VERIFICATION OUTCOMES BY MULTICHILD APPLICATION POLICY 

AND SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

District Used Multichild Applications 

Group 

All 

(n=16) 

District Used 

Random 

Sampling 

(n=8) 

District Used 

Focused 

Sampling 

(n=8) 

District Used 

Single Child 

Applications 

(n=5) 

Income-Eligible Householdsa 

 Responded—no change 23.1 26.2 19.9 24.5 

 Responded—benefit terminated 6.9 4.1 9.8 6.5 

 Responded—benefit reduced 9.2 7.3 11.1 7.3 

 Responded—benefit increased 1.2 1.5 0.9 1.2 

 Nonresponder 45.6 40.8 50.5 51.3 

 Subtotal 86.1 79.9 92.2 90.7 

Categorically Eligible (TANF, Food 

Stamps, FDPIR) 

 Responded—no change 8.7 12.2 5.1 6.6 

 Responded—benefit terminated 1.1 2.1 0.2 0.9 

 Responded—benefit reduced 0.2 0.3 0.0 b 

 Responded—benefit increased 3.9 5.5 2.4 1.8 

 Subtotal 13.9 20.1 7.8 9.3 

Total Responded—No Change 31.8 38.5 25.1 31.1 

Total Benefits Reduced, Terminated, or 

Did Not Respond 66.9 60.0 74.0 67.8 

a

Excluded are 41 of the original 5,183 households—those approved as foster child. 

b

Rounds to less than one-tenth of one percent. 
 46 

TABLE III.8 

MEAL PRICE STATUS OF NONRESPONDERS TO VERIFICATION INITIALLY 

APPROVED ON THE BASIS OF INCOME, AS OF MARCH 1, 2003, 

OVERALL AND BY ORIGINAL STATUS 

(Mean Percentages Across District) 

 All Districts 

Districts Using 

Focused 

Sampling 

Districts Using 

Random 

Sampling 

Overall 

 

Reapproved, free 16.0 12.3 19.3 

Reapproved, reduced-price 8.3 9.3 7.3 

Paid 70.9 74.9 67.2 

Withdrawn 3.9 2.8 5.0 

Missing 1.0 0.6 1.2 

Original Status Free 

 

Reapproved, free 23.3 18.2 27.9 

Reapproved, reduced-price 8.5 11.0 6.2 

Paid 62.6 66.0 59.4 

Withdrawn 4.4 3.8 5.0 

Missing 1.3 1.0 1.5 

Original Status Reduced-Price 

 

Reapproved, free 4.3 4.9 3.7 

Reapproved, reduced-price 8.8 8.1 9.4 

Paid 82.2 84.6 80.0 

Withdrawn 4.1 1.9 6.0 

Missing 0.7 0.4 1.0 

Source: SFA records. 

Note: Sample sizes in this analysis were as follows: A total of 1,614 households were 

originally approved for free meals, 632 in SFAs that use a focused sample and 982 in 

SFAs that use a random sample; a total of 763 households were originally approved 

for reduced-price meals, 395 in SFAs that use a focused sample and 368 in SFAs that 

use a random sample. 
 47 

percent of students, on average, had withdrawn from the district, and we were unable to obtain 

information on March 1 status for an average of one percent of nonresponding households.8

Across all districts, the average reapproval rate was much higher among households 

originally approved for free meals than among those originally approved for reduced-price 

meals. Among nonresponders originally certified for free meals, an average of 31.8 percent were 

reapproved—23.3 percent at the same benefit level and 8.5 percent at the reduced-price level. 

Among nonresponders originally certified for reduced-price meals, 13.1 percent, on average, 

were reapproved—8.8 percent at the same benefit level and 4.3 percent for free meals. 

Overall, average reapproval rates were somewhat higher in the 11 districts that used random 

sampling (26.6 percent) than in the 10 that used focused sampling (21.6 percent). This finding, 

however, did not carry across all subgroups. The average reapproval rate for households 

originally certified for reduced-price meals was the same in districts that used focused sampling 

and those that used random sampling (13 percent). However, the average reapproval rate for 

households originally certified for free meals was 5 percentage points higher in districts that used 

random sampling than in those that used focused sampling (34 and 29 percent, respectively). 

 8

As with other data previously presented, there was considerable variation around the mean 

results presented in Table III.8. For example, overall, the reapproval rate for free meals ranged 

from 0.5 to 43 percent, and the reapproval rate for reduced-price meals ranged from 0 to 21 

percent. See Appendix Table A.5 for the response ranges for the overall outcomes presented in 

Table III.8. 
 
 49 

IV. INCOME ELIGIBILITY STATUS OF TWO GROUPS OF CASES SELECTED 

FOR VERIFICATION 

This chapter presents independent estimates of income eligibility of two important groups 

within the sample of cases selected for verification in the 21 case study districts. The two groups 

are (1) households that were initially approved on the basis of income and who failed to respond 

to the SFA’s verification request (nonresponders), and (2) households that were initially 

approved on the basis of income and whose benefits were unchanged as a result of verification 

(no-change cases). These nonresponders are 47.0 percent of all cases, and these no-change cases 

are 23.4 percent (Table III.3). Thus, these two verification outcome groups accounted for 70 

percent of all cases selected for verification on average across the study districts. Figure II.1 

shows how these two groups relate to the broader population of all students approved for free 

and reduced-price meals. 

The analysis shows that just over half of nonresponders were eligible at the time of the study 

survey in early 2003 for the preverification benefit they were approved to receive in fall 2002. 

Just under half of nonresponders were not eligible for their preverification benefit. 

Approximately 7 of 10 nonresponders were income-eligible for either free or reduced-price 

meals. Two-thirds of no-change cases were eligible in early 2003 for the benefit level for which 

they provided documentation in late 2002, and one-third were not eligible for this benefit level. 

Section A describes our basic approach and the interpretations of the estimates, and Section B 

presents the estimates. 

A. APPROACH AND INTERPRETATION OF THE ESTIMATES 

The analyses for nonresponders and no-change cases address different questions. Because 

(by definition) nonresponders did not comply with the request for documentation, the 
 50 

independent estimates of household eligibility status provide information about a group for 

whom no evidence of income eligibility is available from verification. It is useful to know what 

fraction of nonresponders would have been eligible to receive benefits had they complied with 

the reporting requirement and what fraction would not have been eligible. Information on this 

question will help policymakers assess the extent to which the current verification system may 

create barriers to the receipt of benefits for some income-eligible families. 

For no-change cases, the independent estimates of household eligibility status provide 

policymakers with information on the extent to which the verification process accurately reflects 

the income eligibility of households one to three months after verification. Each SFA 

determined, on the basis of income documentation provided between November 1 and December 

15, 2002, that each no-change household continued to be eligible for the benefit it was initially 

approved to receive at, or shortly after, the start of the school year. The survey reflects 

household membership and income in January or February 2003. Therefore, differences in 

income eligibility as determined through verification and as determined through the study survey 

can occur because of inaccuracies in the verification process, short-term changes in households’ 

circumstances, or inaccuracies in the survey. 

To address the study questions about the extent to which nonresponders and no-change cases 

are eligible for the benefits they are receiving and the distribution of their income, our analysis 

focuses on the simple means of eligibility outcomes across the 21 case study districts. We first 

compute the mean outcome in each district, then the average of these district-level means. 

It is important to emphasize that these estimates do not provide information about the 

eligibility of all students approved for free or reduced-price meals or about the eligibility of all 

students selected for verification. Making inferences about all approved students requires 

information about the eligibility status of a representative sample of all approved students. As 
 51 

Figure II.1 shows, a representative sample of all students would need to include five groups that 

are not included in the case study survey. The results we present here for no-change cases and 

nonresponders can be combined with other information about the groups not included in the 

survey to arrive at an estimate of the eligibility of all approved students.1

B. FINDINGS ON INCOME ELIGIBILITY STATUS 

The first section presents estimates of income eligibility for nonresponders. The second 

presents those for no-change cases. The third section presents several alternative measures of 

certification accuracy for nonresponders and no-change cases. 

1. Findings on the Income Eligibility Status of Nonresponders to Verification 

Table IV.1 presents the data for the sample of cases that failed to respond to the request for 

verification and whose benefits were to be terminated. The top section of the table shows mean 

values across all 21 case study districts, the middle section shows mean values for the 11 districts 

that used random sampling, and the bottom section shows mean values for the 10 districts that 

used focused sampling. Each section shows separately for students approved for free meals and 

for reduced-price meals, as well as for both groups together, the mean across districts of the 

percentage of the meal price status group in selected outcome categories.2

 1

An important qualification is that such estimates are feasible only for random-sampling 

sites, in which the method of verification sampling approximates a simple random sample of all 

applications approved. In districts using focused sampling for verification, the method of 

selecting the verification sample is specifically designed to include in the sample a higher 

proportion of cases whose circumstances may change and who may thus be ineligible for their 

benefits at the time of verification than would be found in a simple random sample of all 

approved students. Because the verification samples in focused-sampling districts are designed 

not to be representative of all approved students, they cannot be used to draw conclusions about 

the eligibility of all approved students. 

2

Appendix Table A.6 presents the percentage of all households interviewed that are in each 

income category. 
 52 

TABLE IV.1 

 INCOME STATUS OF HOUSEHOLDS APPROVED ON THE BASIS OF INCOME AND 

HOUSEHOLD SIZE THAT FAILED TO RESPOND TO VERIFICATION REQUEST 

(Mean Percentages Across Districts)

 Initial Meal Price Status 

Income Status Based on Study Interview Free Reduced-Price Total 

All Districts 

Income Relative to FPL 

Income <130 percent FPL 51.3 31.4 44.1 

130 to 185 26.0 22.8 24.7 

186 to 250 14.0 29.2 19.7 

251 to 400 7.3 13.8 9.5 

>400 1.4 2.8 1.9 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 51.3 54.2 52.6 

Number in Sample 417 209 626 

Random-Sampling Districts 

Income Relative to FPL 

Income <130 percent FPL 56.9 32.2 49.2 

130 to 185 25.2 20.3 23.5 

186 to 250 10.4 32.7 18.0 

251 to 400 6.3 13.3 8.0 

>400 1.3 1.5 1.3 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 56.9 52.5 55.8 

Number in Sample 235 77 312 

Focused-Sampling Districts 

Income Relative to FPL 

Income <130 percent FPL 45.1 30.5 38.6 

130 to 185 26.9 25.5 26.0 

186 to 250 18.0 25.4 21.5 

251 to 400 8.4 14.3 11.2 

>400 1.6 4.3 2.6 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 45.1 56.0 49.1 

Number in Sample 182 132 314 

Note: The 21 case study districts were selected and recruited for the study by FNS regional office staff. Within 

each district, samples were selected to be representative of households whose NSLP benefits were 

terminated for failure to respond to the verification request. Each sample is representative of cases in the 

subgroup whose initial application was approved on the basis of income and household size; applications 

approved because the household was receiving TANF, food stamp, or FDPIR benefits or because the 

child was a foster child are excluded from the sample. Findings do not generalize to all students 

approved for free and reduced-price meals in the case study districts. Therefore, findings apply only to 

students in the specific verification outcome groups within the 21 study site districts. 
 53 

Of the cases that were initially approved for free meals, 51.3 percent on average had income 

less than 130 percent of FPL at the time of the interview. Of the cases approved for reducedprice meals, 31.4 percent had incomes below 130 percent of FPL (and would have qualified for 

free meals) and 22.8 percent had incomes between 130 and 185 percent of FPL (and were thus 

eligible for reduced-price meals). The mean percentage of all nonresponder cases whose income 

and household size made them eligible at the time of the interview for at least the benefit they 

were initially approved to receive was 52.6 percent. The balance, or just under half 

(47.4 percent), had incomes above the threshold of income eligibility for their initial benefit. 

Note that 26.0 percent of the households that were initially approved for free meals (about 

17 percent of all nonresponders interviewed) reported incomes that would have made them 

eligible for reduced-price benefits had they reapplied. Furthermore, 31.4 percent of cases 

initially approved for reduced-price meals (about 10 percent of the combined free-plus-reducedprice group) reported incomes that made them eligible for free meals, a higher level of benefit 

than they were initially receiving. As a result, 68.8 percent of all nonresponder cases were 

eligible for free or reduced-price meals at the time of the interview (44.1 and 24.7 percent, 

respectively). 

The data on random- and focused-sampling districts reveals different patterns of income 

eligibility in the two groups of districts. Nonresponders in random-sampling districts were more 

likely than those in focused-sampling districts to have incomes that made them eligible for free 

or reduced-price meals at the time of the survey. In random-sampling districts, 72.7 percent of 

nonresponders had incomes below 185 percent of the FPL (49.2 percent plus 23.5 percent). In 

focused-sampling districts, 64.6 percent of nonresponders had incomes below 185 percent of the 

FPL. Correspondingly, nonresponders in the random-sampling districts were more likely to be 
 54 

eligible for at least the benefit they were initially approved to receive (55.8 percent versus 49.1 

percent in the focused-sampling districts). 

2. Findings on the Income Status of Cases with No Change in Benefits 

Table IV.2 presents data for cases that had no change in benefits as a result of verification. 

For these cases, the SFA received documentation in November or December in response to the 

verification request, and the documentation confirmed that the household was income-eligible at 

that time for the benefit it had been awarded at the start of the school year. On average across 

the 21 SFAs, two-thirds of no-change cases were eligible for at least the level of benefits they 

were approved to receive (65.5 percent). Just under two-thirds of households certified for free 

meals were eligible for them, and just over two-thirds of households certified for reduced-price 

meals reported incomes and household membership that made them eligible for either free or 

reduced-price benefits. 

As with the nonresponder sample, we observe some cases apparently eligible for reducedprice meals but approved for free meals, and vice versa. In particular, 27.4 percent of free 

approved cases have incomes between 130 and 185 percent of the FPL (about 18 percent of all 

cases with no change). Furthermore, 24.8 percent of cases approved for reduced-price meals 

(about 8 percent of all cases) are eligible for free meals. Although about two-thirds of no-change 

cases were eligible according to the survey for at least the benefit they were receiving, and onethird were not eligible, 83.3 percent were eligible for either free or reduced-price meals. 

Again, as with the nonresponder sample, no-change cases in random-sampling districts have 

lower incomes, on average, and are more likely to be eligible for benefits than their counterparts 

in focused-sampling districts. 
 55 

TABLE IV.2 

INCOME STATUS OF HOUSEHOLDS APPROVED ON THE BASIS OF INCOME AND HOUSEHOLD SIZE 

THAT HAD NO CHANGE IN NSLP BENEFITS AS A RESULT OF VERIFICATION 

(Mean Percentages Across Districts)

 Initial Meal Price Status 

Income Status Based on Study Interview Free Reduced-Price Total 

All Districts 

Income Relative to FPL 

Income <130 percent FPL 63.7 24.8 50.1 

130 to 185 27.4 42.4 33.2 

186 to 250 5.2 25.0 11.4 

251 to 400 2.6 5.4 3.5 

>400 1.2 2.5 1.8 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 63.7 67.2 65.5 

Number in Sample 359 167 526 

Random-Sampling Districts 

Income Relative to FPL 

Income <130 percent FPL 69.4 26.3 55.3 

130 to 185 23.2 43.9 30.9 

186 to 250 3.3 25.9 9.5 

251 to 400 2.6 3.9 3.1 

>400 1.5 0.0 1.1 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 69.4 70.2 69.7 

Number in Sample 216 83 299 

Focused-Sampling Districts 

Income Relative to FPL 

Income <130 percent FPL 57.4 23.2 44.4 

130 to 185 32.0 40.6 35.6 

186 to 250 7.3 23.9 13.5 

251 to 400 2.5 7.1 3.9 

>400 0.8 5.2 2.5 

Cases Eligible for at Least the Level of Benefit They 

Were Approved to Receive 57.4 63.8 60.8 

Number in Sample 143 84 227 

Note: The 21 case study districts were selected and recruited for the study by FNS regional office staff. Within 

each district, samples were selected to be representative of households whose NSLP benefits were 

unchanged as a result of verification. Each sample is representative of cases in the subgroup whose initial 

application was approved on the basis of income and household size; applications approved because the 

household was receiving TANF, food stamp, or FDPIR benefits or because the child was a foster child 

are excluded from the sample. Findings do not generalize to all students approved for free and reducedprice meals in the case study districts. Therefore, findings apply only to students in the specific 

verification outcome groups within the 21 study site districts. 
 56 

3. Accuracy of Meal Price Certification for Nonresponders and No-Change Cases 

This section presents data on meal price accuracy for nonresponders to verification and 

cases with no change in benefits due to verification using measures of meal price certification 

accuracy similar to those used in Volume I of the Evaluation of the NSLP

Application/Verification Pilot Projects (Burghardt et al. 2004). The four measures are: 

1. Percentage of free approved students who are eligible for free meals (CA_1) 

2. Percentage of free and reduced-price students who are eligible for exactly the level of 

benefits they are approved to receive (CA_2) 

3. Percentage of free and reduced-price students who are eligible for at least the level 

of benefits they are approved to receive (CA_3) 

4. Percentage of free and reduced-price students who have income not over 185 percent 

of the FPL (CA_4) 

The first measure pertains to free approved students only, while the second, third, and fourth 

pertain to those approved for free and reduced-price meals. The measures for those approved for 

free and reduced-price meals differ in how “appropriately certified” is defined. In the second 

measure, only students certified for exactly the level of benefits they are entitled to receive are 

considered appropriately certified—students certified for a lower level of benefits and a higher 

level of benefits are considered inappropriately certified. In the third measure, students certified 

for at least the level of benefits they are entitled to receive are considered appropriately certified. 

Thus, in contrast to the second measure, students certified for a lower level of benefits than they 

are entitled to receive are considered appropriately certified according to the third measure. The 

fourth measure considers as appropriately certified all students whose income is at or below 185 

percent of the FPL, the income that makes a student eligible for reduced-price meals. The fourth 

measure differs from the third in considering as appropriately certified students who are certified 

for free meals although their incomes are between 130 and 185 percent of the FPL. While this 
 57 

group is not eligible for the benefit they are receiving, they are eligible for a lower level of 

benefit. 

Table IV.3 presents the data on the four measures of certification accuracy for 

nonresponders and no-change cases in all districts, random-sampling districts, and focusedsampling districts. Among nonresponders in all case study districts, 51.3 percent of students 

initially approved for free meals in fall 2002 were eligible for free meals at the time of the survey 

in January and February 2003. Of all students approved for free and reduced-price meals in the 

nonresponder group, 41.7 percent were eligible for exactly the benefits they are approved to 

receive, 52.6 percent were eligible for at least the benefit they are approved to receive, and 68.7 

percent had incomes of 185 percent of the FPL or less at the time of the survey. Nonresponders 

in districts using random sampling had higher rates of eligibility according to each measure than 

did nonresponders in districts using focused sampling. 

Among cases in all study districts that had no change in benefits due to verification in 

December 2002, 63.7 percent of free-approved students were eligible for free meals. Among all 

no-change cases approved for free and reduced-price meals, 57.9 percent were eligible for 

exactly the benefits they are approved to receive, 65.5 percent were eligible for at least the 

benefit they are approved to receive, and 83.1 percent had incomes of 185 percent of the FPL or 

less. Again, no-change cases in districts using random sampling had higher rates of eligibility 

according to each measure than did no-change cases in districts using focused sampling. 
 58 

TABLE IV.3 

CERTIFICATION ACCURACY OF HOUSEHOLDS WITH SELECTED 

VERIFICATION OUTCOMES 

(Mean Percentages Across Districts)

All 

Districts 

RandomSampling 

Districts 

FocusedSampling 

Districts 

Nonresponders to Verification 

Free Approved Students Who Are Eligible for Free 

Meals (CA_1)a 51.3 56.9 45.1 

Free and Reduced-Price Approved Students Who Are 

Eligible for Exactly the Level of Benefits They Are 

Approved to Receive (CA_2)b

 41.7 46.3 36.7 

Free and Reduced-Price Approved Students Who Are 

Eligible for at Least the Level of Benefits They Are 

Approved to Receive (CA_3)c

 52.6 55.8 49.1 

Free and Reduced-Price Approved Students Who Have 

Income Not Over 185 Percent FPL (CA_4)d

 68.7 72.4 64.6 

Cases with No Change in NSLP Benefits as a Result of Verification 

Free Approved Students Who Are Eligible for Free 

Meals (CA_1)a

 63.7 69.4 57.4 

Free and Reduced-Price Approved Students Who Are 

Eligible for Exactly the Level of Benefits They Are 

Approved to Receive (CA_2)b

 57.9 63.0 52.2 

Free and Reduced-Price Approved Students Who Are 

Eligible for at Least the Level of Benefits They Are 

Approved to Receive (CA_3)c

 65.5 69.7 60.8 

Free and Reduced-Price Approved Students Who Have 

Income Not Over 185 Percent FPL (CA_4)d 83.1 86.2 79.8 

Note: The 21 case study districts were selected and recruited for the study by FNS regional office staff. Within 

each district, the nonresponder samples were selected to be representative of households whose NSLP 

benefits were terminated for failure to respond to the verification request, and the no-change samples 

were selected to be representative of cases whose benefit was unchanged due to verification. Each 

sample is representative of cases in the subgroup whose initial application was approved on the basis of 

income and household size; applications approved because the household was receiving TANF, food 

stamp, or FDPIR benefits or because the child was a foster child are excluded from the sample. Findings 

do not generalize to all students approved for free and reduced-price meals in the case study districts. 

Therefore, findings apply only to students in the specific verification outcome groups within the 21 study 

site districts. 

a

Percentage with income <=130 percent FPL among those certified for free meals by application. 

b

Percentage with income <=130 percent FPL and certified free or with income between 131-185 percent FPL and 

certified reduced-price among all those certified for free or reduced-price meals. 

c

Percentage with income <=130 percent FPL and certified free or with income <=185 percent FPL and certified 

reduced-price among all those certified for free or reduced-price meals. 

d

Percentage with income <=185 percent FPL among those certified for free or reduced-price meals. 
 59 

V. CHARACTERISTICS OF NONRESPONDING HOUSEHOLDS THAT WERE 

REAPPROVED AND THAT WERE NOT REAPPROVED BY MARCH 1 

Program rules require SFAs to terminate the NSLP benefits of families who fail to respond, 

by a deadline in December, to a request for verification of their income. On average across the 

case study districts, about half the cases selected for verification were nonrespondents (45 

percent in random-sampling districts and 56 percent in focused-sampling districts). Families 

terminated for failure to comply with verification requirements can reapply for benefits and be 

reapproved at any time, provided they submit documentation verifying their income and are 

eligible for benefits. As Table III.8 shows, 24.3 percent of nonresponder cases in the case study 

districts reapplied and were approved for free or reduced-price meal benefits by March 1, 2003 

(26.6 percent in random-sampling districts and 21.6 percent in focused-sampling districts). 

The study conducted interviews with 632 nonresponders across the 21 case study districts. 

Of this interviewed sample, 160 had reapplied and were reapproved by March 1, 2003, and 472 

had not been reapproved by March 1, 2003.1

 In this chapter, we compare the characteristics of 

nonresponders who applied and were reapproved with the characteristics of nonresponders who 

were not reapproved to address two questions: 

1. Are nonresponders who reapply and are reapproved more likely to be eligible for 

benefits than nonresponders who do not become reapproved? 

2. Does information about other characteristics or reported experiences in the NSLP 

offer any insights into the reasons that some families reapply and are reapproved, 

while other families are not? 

 1

For cases in our sample that were not reapproved, we did not determine whether they 

reapplied. It is possible that none, some, or all nonrespondent households that were not 

reapproved submitted new applications and were denied benefits. 
 60 

Table V.1 shows selected characteristics for and differences between the nonresponders who 

did and did not become reapproved by March 1. Appendix Tables A.8 and A.9 show these data 

separately for random- and focused-sampling districts. 

A. ELIGIBILITY 

Survey data indicate that reapproved nonresponders were more likely than nonresponders 

that were not reapproved to have family income below 185 percent of the FPL and less likely to 

have income above 185 percent of the FPL. About 87 percent of reapproved cases had incomes 

below 185 percent of poverty, which made them eligible for free or reduced-price meals, 

whereas 63 percent of nonrespondent families that did not become reapproved by March 1 had 

incomes below 185 percent of poverty. 

Reapproved families were more likely than those not reapproved to be receiving food 

stamps or TANF benefits and thus to be categorically eligible for NSLP benefits if they chose to 

apply on this basis. About 15 percent of reapproved cases reported receiving food stamps, and 3 

percent reported receiving TANF, compared to 5 percent and 2 percent, respectively, of 

households that were not reapproved.2

 All families selected for the survey were initially 

approved in fall 2002 on the basis of an application on which they provided information on 

income and household size. Households that were initially categorically eligible were excluded 

from the survey sample. 

The patterns of differences in the eligibility of households reapproved and those not 

reapproved observed across all study districts are similar to the patterns observed in districts 

using random and focused sampling (Appendix Tables A.8 and A.9). In random-sampling 

 2

There is substantial overlap in these percentages, since some households receiving TANF 

also received food stamps. 
 61 

TABLE V.1 

CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT FAILED TO RESPOND TO VERIFICATION 

THAT WERE REAPPROVED AND THAT WERE NOT REAPPROVED 

(Mean Percentages Across Districts) 

Characteristics 

Nonresponders Who 

Were Reapproved 

Nonresponders Who 

Were Not Reapproved Difference 

Household Size 

 Number of household members (mean) 

 Number of children in household (mean) 

4.6 

2.4 

4.5 

2.2 

0.1 

0.2 

Household Structure (Percentages) 

 Two-parent household 

 Single-parent household 

 Other household structure 

44.0 

51.4 

4.6 

53.9 

38.7 

7.4 

–9.8 

12.7 

–2.9 

Survey Respondent’s Educational Attainment 

(Percentages) 

Lacks a high school diploma 

High school diploma only 

Some postsecondary education but lacks a college 

degree 

College degree or more 

35.1 

33.6 

28.5 

2.7 

26.4 

34.1 

34.0 

5.4 

8.7 

–0.5 

5.5 

–2.7 

Employment Status of Household Members 

Survey respondent is employed (percentage) 

Number of employed adults in household (mean) 

61.5 

1.0 

71.8 

1.4 

–10.4 

–0.3 

Household Income (Percentages) 

 Less than 130 percent of FPLa

 131 to 185 percent of FPL 

 186 to 250 percent of FPL 

 251 to 400 percent of FPL 

 More than 400 percent of FPL 

63.5 

23.2 

6.4 

3.7 

3.1 

37.1 

25.5 

24.1 

11.2 

2.1 

26.4 

–2.2 

–17.7 

–7.5 

1.0 

Percentage Receiving Public Assistance 

Percentage receiving food stamp benefits 

Percentage receiving TANF 

Percentage receiving other benefits 

14.7 

2.9 

7.9 

4.6 

2.1 

9.8 

10.1 

0.8 

–1.9 

Race/Ethnicity (Percentages) 

White, non-Hispanic 

Black, non-Hispanic 

Hispanic 

Native American 

Asian, Pacific Islander 

Other 

Mixed race 

21.1 

25.6 

33.5 

0.0 

6.5 

0.0 

13.4 

31.7 

22.3 

26.7 

1.5 

4.6 

0.6 

12.5 

–10.7 

3.3 

6.7 

–1.5 

1.8 

–0.6 

–0.9 

English Primary Language Spoken at Home (Percentage) 62.9 69.7 –6.8 

Grade Level of Child (Percentages) 

Grade 9 to 12 

Grade 6 to 8 

Grade 3 to 5 

Grade 1 to 2 

Kindergarten or pre-K 

14.5 

29.7 

30.2 

17.5 

8.2 

26.8 

22.4 

27.5 

15.8 

7.5 

–12.3 

7.2 

2.7 

1.7 

0.7 
TABLE V.1 (continued) 

 62 

Characteristics 

Nonresponders Who 

Were Reapproved 

Nonresponders Who 

Were Not Reapproved Difference 

Parents’ Views on Administration of School Meal 

Programs (Percentages) 

Believes school lunch program at child’s school is 

well run 

Believes the application process to receive 

free/reduced-price meals is fair 

89.4 

83.5 

85.4 

74.6 

4.0 

8.9 

Students’ Perceptions of Quality/Taste of School Meals 

(Percentages) 

 Satisfied with amount of food in school lunches 

 Satisfied with quality/taste of school lunches 

88.1 

81.3 

75.2 

75.5 

12.9 

5.8 

Number of Days per Week Usually Eats School Lunch 

(Self-Reported) 

0 

1 

2 

3 

4 

5 

2.5 

0.3 

2.0 

9.8 

3.0 

82.4 

17.3 

3.1 

5.6 

8.0 

5.4 

60.7 

–14.8 

–2.7 

–3.6 

1.8 

–2.4 

21.7 

Percentage of Students (Based on Self-Reported Meal Price 

Status) 

Free 

Reduced-price 

Paid 

71.9 

20.4 

7.7 

18.2 

9.4 

72.4 

53.7 

11.0 

–64.7 

Sample Size 160 472 

FPL = federal poverty level. 

a

The lowest income category (less than 130 percent of FPL) includes families categorically eligible for free meals (based on 

receipt of TANF or food stamps or foster child status), regardless of their actual income. 
 63 

districts, we found somewhat larger differences between reapproved households and households 

not reapproved in rates of free meal eligibility and food stamp receipt but somewhat smaller 

differences in their rates of free or reduced-price eligibility. Districts that used focused sampling 

had higher rates of ineligibility both among reapproved and not reapproved households than did 

districts that used random sampling. This finding is not surprising, because focused sampling 

targets households near the thresholds of eligibility. Therefore, we expect that more 

nonresponder households in the focused-sampling districts will have moved across the eligibility 

threshold to become ineligible. 

B. OTHER CHARACTERISTICS 

Families who were reapproved after not responding were different from families who were 

not reapproved. Reapproved households were more likely to be single-parent households than 

households not reapproved (51.4 percent versus 38.7 percent of households not reapproved). 

Parents in households that were reapproved were more likely to lack a high school diploma (35.1 

percent versus 26.4 percent). They were also less likely to be currently employed (61.5 percent 

versus 71.8 percent). Finally, reapproved households were somewhat more likely to be black, 

non-Hispanic (25.6 percent vs. 22.3 percent of households not reapproved), more likely to be 

Hispanic (33.5 versus 26.7 percent), and less likely to speak English as the primary language in 

the home (62.9 percent versus 69.7 percent). 

Most of these differences between households that were reapproved and households that 

were not reapproved were similar in the random- and focused-sampling districts. While the 

levels varied somewhat across random- and focused-sampling districts, the differences between 

reapproved and not reapproved households were similar in both random- and focused-sampling 

districts to the differences in all sites for most characteristics considered (Tables A.8 and A.9). 

One notable difference was in the percentage of households that were single-parent households. 
 64 

The percentage of reapproved households headed by single parents was considerably greater in 

focused-sampling districts than in random-sampling districts. There were also some small 

differences in patterns of difference by ethnic group. 

C. PARTICIPATION IN THE NSLP 

Reapproved households reported higher rates of regular participation in the NSLP than did 

households not reapproved. Among reapproved households, 82.4 percent said their child eats a 

school lunch every day, compared to 60.7 percent of those who were not reapproved. 

Furthermore, only 2.5 percent reported that their child never eats a school lunch, compared to 

17.3 percent of nonreapproved households. Reapproved households were more likely to report 

satisfaction with the amount of food (88.1 percent, compared to 75.2 percent) and quality of 

school meals (81.3 percent, compared to 75.5 percent). The sample child in families that were 

not reapproved was more likely to be in high school grades, which tend to have lower NSLP 

participation rates than the elementary and middle school grades.3

Because of timing of the survey, we expected that most, if not all, households that reapplied 

and whose reapplication was approved would have been certified for free or reduced-price meals 

at the time of the survey. We further expected that most households that were not reapproved 

would have had their benefits terminated at that time and therefore would have reported that their 

child was not certified for free or reduced-price meals.4

 As expected, 92.3 percent of reapproved 

households reported being certified (71.9 percent for free meals and 20.4 percent for reduced-

 3

See Gleason (1995). 

4

Interviews were conducted between February 13, 2003, and April 2, 2003; data on 

reapproval status were based on whether the student was approved to receive free or reducedprice meals as of March 1, 2003. 
 65 

price meals).5 However, 28 percent of households that were not reapproved also reported that 

their child was certified. The fact that some households whose benefits should have been 

terminated for nonresponse either were still approved for free or reduced-price meals or were 

unaware that their benefits had been terminated may help explain why they did not reapply.6 

The students in some of these households may not have been participating in the NSLP, as 

suggested above, or may have participated only a few times a week. It is also possible that their 

free or reduced-price certification status had not actually been changed, despite the findings from 

the verification process.7

All of these differences between reapproved households and households not reapproved that 

were related to NSLP participation were found both in districts using random sampling and in 

those using focused sampling (Tables A.8 and A.9). However, most of the differences were 

considerably larger in random-sampling districts. 

 5

The eight percent that reported not being certified either were mistaken or may have been 

interviewed before reapplying and being recertified. 

6

We did not collect data on whether termination of benefits had actually taken place in 

households that failed to respond to verification (although we might reasonably assume 

termination was actually carried out for families that later reapplied, since they would have had 

no reason to reapply if their benefits had not been terminated), so it is possible that children 

actually were still receiving free or reduced-price meals in some households that had failed to 

respond to verification requests. 

7

In its study of free and reduced-price eligibility determination in 14 large SFAs in school 

year 2001-2002, FNS found that 31 percent of nonresponder households that had not reapplied 

were approved to receive free or reduced-price meals at the end of the 2001-2002 school year 

(memorandum from Paul Strasberg to Mathematica Policy Research, Inc., January 29, 2004). 
 
 67 

VI. INCOME ELIGIBILITY STATUS OF REAPPROVED NONRESPONDERS: 

COMPARING MEAL PRICE STATUS ASSIGNED BY THE SFA WITH INCOME 

ELIGIBILITY ESTIMATED FROM THE CASE STUDY INTERVIEW 

In this chapter, we examine factors that account for the differences observed between 

eligibility status of no-change cases as determined in the survey and their meal price status as 

determined by the SFA. We found that 65.5 percent of no-change cases were eligible for at least 

the level of benefits for which SFAs had received documentation in response to the verification 

request, and 34.5 percent were not eligible for this level of benefits. Thus, a substantial fraction 

of households that documented their income in December appeared not to be eligible for those 

benefits at the time of the study interview in March. In this chapter, we seek to understand why 

a substantial fraction of households whose income had recently been documented to the SFA 

were not eligible for the level of benefits they were receiving according to the survey. 

Possible reasons for the difference in eligibility rates as determined by the verification 

process and the survey include the following: 

1. Changes in Household Circumstances. The request for verification was sent out in 

October or November 2002, and the household was required to respond by early 

December. Thus, the documentation that no-change cases provided is likely to have 

pertained to income during the months of October or November. However, the 

survey was conducted in February or March 2003, and households were asked about 

income in January or February 2003. The income of some families and people living 

in the household may have changed between the period October-November 2002 

covered by the verification documents and February-March 2003, the period about 

which interview respondents provided data. 

2. Inaccurate Reporting of Circumstances in Providing the Verification. No-change 

cases selected for verification could have reported circumstances inaccurately, either 

intentionally or unintentionally. Omitting adult household members, omitting sources 

of income, and providing a different income amount in the survey for a source that 

was reported on the application are some ways this could have occurred. 

3. Inaccurate Reporting of Circumstances in the Household Interview. The household 

could have reported circumstances inaccurately in the study interviews. A large 

literature indicates that respondents to a structured survey do not report their income 
 68 

by source accurately, even when asked detailed questions about a long list of possible 

sources, which is designed to aid recall.1 

4. Errors by SFA Staff Processing the Data. The verification system requires that SFA 

staff review the information to determine the correct monthly income amount for each 

source. Several potential errors can arise in this process. If the documentation does 

not show the period covered by the income, the SFA staff member reviewing it could 

make an error in determining the full gross monthly income amount. If a piece of 

information is missing or incomplete, the SFA staff member might make assumptions 

that are inaccurate. Similarly, SFA staff must correctly count household members 

and sum the income amounts per person source. All these steps are subject to some 

level of error.2

This chapter uses data from the reapplications of nonresponders who were reapproved for 

benefits by March 1, 2003, to provide insights into the sources of error. Our analysis makes use 

of the fact that the data furnished on new applications (and for which documentation was 

provided) pertain to nearly the same period of time as the survey data. Thus, differences 

between the survey data and the application-based data are very unlikely to be due to differences 

in circumstances at the time of the survey and the time of the application. 

We found that 77.6 percent of the nonresponder households that were reapproved were 

eligible, according to the survey, for at least the level of benefits they were approved to receive. 

Among cases in which the survey data and the application data produced a different level of 

benefits, differences in the number of people for whom income was reported accounted for onethird of the differences. In most of these cases, the benefit calculated from the survey data was 

lower than the benefit calculated from the application data. This pattern suggests that 

households systematically underreported the number of people receiving income on the 

 1

See Moore et al. (2000). 

2

Strasberg 2003 reports that, in a study of 14 SFAs, 94.3 percent of applications approved on 

the basis of household income and size were approved for the correct level of benefits, based on 

the information provided on the application, and 5.7 percent were approved inaccurately.
 69 

applications. Apparent administrative errors also accounted for about seven percent of the 

differences. The remaining errors reflecting differences in the number of sources or types of 

income and in the amount of income reported were as likely to result in a smaller benefit as in a 

larger one, according to the survey data, which suggests that these types of errors are random 

measurement errors. 

Finally, we used the estimate of the difference in the contemporaneous survey and 

application data for the reapproved households to estimate the proportion of the difference 

between the survey and application-based estimate of eligibility of the no-change cases that is 

due to change in circumstances and the proportion due to all other factors. 

In the following section, we describe the data used to compare information reported to the 

SFA with information reported on the study survey. 

A. DATA AND METHODS 

Senior MPR data collection staff telephoned staff at each participating SFA and asked each 

SFA representative to determine and report on the meal price status on March 1, 2003, of one 

student in each household that did not respond to the district’s request for verification. For each 

household in which the student was approved for free or reduced-price meals as of March 1, 

2003, the MPR interviewer requested detailed information on the documentation provided. For 

households that reported receiving food stamps or TANF benefits or in which the child was a 

foster child, the SFA staff was asked to report on the nature of the documentation received and 

used for verification. For other households, the MPR interviewer obtained a count of the number 

of adults and number of children in the household and asked the SFA staff to list all adults in the 

household. The MPR interviewer then asked whether any income was reported for each adult. 

For each person who was reported to have received income, the MPR interviewer asked what 
 70 

each source of income was. For each source of income, the MPR interviewer asked the gross 

amount, period covered, and whether documentation had been provided.

With this information, MPR analysts calculated the household’s total gross income and, with 

the number of people in the household, their income relative to the FPL. We used this estimate 

of income relative to the FPL, the data on TANF and food stamp receipt, and the indicator of 

whether the child was a foster child to estimate whether the household was eligible for the 

benefits it had been approved to receive, based on the information in the documentation file. We 

performed a similar calculation of income relative to the FPL using data reported on the study 

interview. 

The timing of the SFA administrative data and the timing of the study survey are important 

to the analysis. The reapproved cases submitted new applications and supporting documentation 

at some point between December 15, 2002 (the last date for submitting documentation for 

verification) and March 1, 2003. Because schools were closed for the holidays in the latter part 

of December, we believe most of the new documentation would have been submitted in January 

and February. Given this schedule for submitting the documentation, the documentation would 

have provided information about household circumstances during December or January. The 

study survey was conducted in the period late February through the end of March 2003, and it 

asked about income during January or February. Accordingly, the documentation submitted as 

part of the reapproval process covers the period December 2002-January 2003, whereas the study 

survey obtained data on income and household composition in January-February 2003. 

Although the correspondence is not perfect, it is considerably closer than the match between the 

period covered by the initial verification documentation of the no-change cases and the study 

survey. 
 71 

B. COMPARING MEAL PRICE STATUS AS DETERMINED BY THE SFA AND 

MEAL PRICE STATUS BASED ON THE SURVEY 

How do estimates of meal price status based on the study survey compare with the meal 

price status assigned by SFAs in response to new applications and documentation that the family 

submitted to be reapproved after failing to provide verification by December 15, 2002? 

Table VI.1 shows this basic comparison between survey-based eligibility and reapplicationbased certification status, both overall and separately for districts that used random-sampling 

methods to select households for verification and districts that used focused sampling.3 

Certification status on March 1, 2003, matched the eligibility category from the survey data in 64 

percent of households in all districts (102 of the 160 households for which we have both survey 

and March 1 meal price status).4

 Forty-nine percent were certified for, and eligible for, free 

meals, and 15 percent were certified for, and eligible for, reduced-price meals. The percentage 

matching is higher (71 percent of households) in districts using random sampling and lower (56 

percent of households) in districts using focused sampling. About 23 percent of reapproved 

households overall were receiving a higher level of benefits than the survey data indicated they 

were eligible for, and 14 percent were receiving a lower level.5 Reapproved households in 

 3

The numbers in this table are unweighted percentages of all households that failed to 

respond to verification but later reapplied and were reapproved. 

4

These percentages do not include households that did not reapply and become recertified 

for NSLP benefits after nonresponse to verification and, thus, cannot be used as an indicator of 

the accuracy of certification status of all terminated households. Since some of the households 

that did not reapply are probably eligible, including these households with zero benefits, the 

calculation would show a larger proportion of households receiving a lower level of benefits than 

the survey suggests they are entitled to. 

5

This 23 percent receiving a higher level of benefits includes 11 percent that were certified 

free but deemed eligible for reduced-price meals according to the survey data, 7 percent that 

were certified free but deemed ineligible for free or reduced-price meals, and 5 percent that were 

certified reduced-price but deemed ineligible. The 14 percent receiving a lower level of benefits 

were all certified reduced-price but deemed eligible to receive free meals. 
 72 

TABLE VI.1 

MEAL PRICE STATUS ACCORDING TO THE STUDY SURVEY AND ACCORDING 

TO THE SFA DETERMINATION AFTER REAPPLICATION 

(Percentage of All Reapproved Cases) 

 Income Eligibility Status According to Survey 

Meal Price Status According to SFA 

Free 

(Percent) 

ReducedPrice 

(Percent) 

Paid 

(Percent) Total 

In Districts Using Random Sampling 

 Free 61.5 8.4 7.2 77.1 

 Reduced-price 8.4 9.6 4.8 22.9 

 Total 69.9 18.1 12.0 100.0 

 Eligible for at least the benefit they 

were approved to receive 79.5 

 Sample size 83 

In Districts Using Focused Sampling 

 Free 35.1 13.0 6.5 54.6 

 Reduced-price 19.5 20.8 5.2 45.5 

 Total 54.6 33.8 11.7 100.1 

 Eligible for at least the benefit they 

were approved to receive 75.4 

 Sample size 77 

In All Districts 

 Free 48.8 10.6 6.9 66.3 

 Reduced-price 13.8 15.0 5.0 33.8 

 Total 62.5 25.6 11.9 100.1 

 Eligible for at least the benefit they 

were approved to receive 77.6 

 Sample size 160 

Note: Benefits of verified cases were supposed to be terminated by December 15, 2002. New 

applications were submitted between December 15, 2002, and March 1, 2003. Survey 

interviews were conducted from February 15 to March 31, 2003. 
 73 

districts that used random sampling were somewhat less likely to be receiving a higher level of 

benefits than the survey data indicated they were eligible for (20 percent, compared to 24 percent 

of households in districts that used focused sampling), and they were considerably less likely to 

be receiving a lower level of benefits than they were eligible for according to the survey than 

were households in districts that used focused sampling (8 percent, compared to 20 percent). 

C. UNDERSTANDING THE DIFFERENCES IN STATUS AS DETERMINED BY THE 

DISTRICT AND BY THE SURVEY 

For most cases, the measure of income as a percentage of poverty calculated from the survey 

data differs at least somewhat from the same measure calculated from application data. Even in 

households whose eligibility category (free, reduced-price, or paid) matches in the two data 

sources, the precise income as a percentage of poverty calculated from the survey rarely exactly 

matches that from the reapplication. In only 18 percent of households is the survey-based 

continuous measure of total household income as a percentage of poverty within 10 percentage 

points of the reapplication measure of the same variable. About 44 percent of households overall 

reported incomes as a percentage of poverty more than 10 percentage points higher on the survey 

than on their reapplication, and another 39 percent reported incomes as a percentage of poverty 

more than 10 percentage points lower on the survey than on their reapplication.6

 

Since meal price status determined by the SFA from reapplications does not match the meal 

price status calculated from the survey in more than one-third of households, it is useful to 

understand the reasons for the differences. Potential reasons include differences in the number 

 6

Even among households whose meal price status matched in the two sources, 73 percent 

reported incomes as a percentage of poverty that differed by at least 10 percentage points 

between the two data sources. Households that used income documentation at the time of the 

survey did not yield closer matches than households that did not use documentation in 

responding to the interview questions. 
 74 

of household members, differences in the sources of income or individual income amounts 

reported, differences in categorical eligibility, and computational error on the part of SFA staff. 

Table VI.2 presents the incidence of these reasons for differences between reapplication and 

survey meal price status.7 Reasons are in order of precedence, such that if two different reasons 

apply to a given household, that household is included in the higher row in the table. For 

example, if both the number of household members who reported income differs and the 

numbers of source or type of income differ, the number of household members is considered to 

be the reason for the overall difference. 

1. Categorical Eligibility or Foster Child Present 

In three households, the eligibility category determined from the survey data did not match 

the certification status because information on whether the household received food stamps or 

TANF, or whether the child was a foster child differed. Two of these three households reported 

being categorically eligible or containing a foster child on the reapplication but not on the 

survey. The third reported receiving food stamps on the survey but did not report food stamp 

receipt when it reapplied. This household was then certified eligible only for reduced-price 

meals on the basis of income and family size. 

2. Income and Household Size Agree but Meal Price Status Differs 

For four households, the survey-based meal price eligibility category did not match the meal 

price certification status because our calculation of total household income as a percentage of 

poverty based on information provided on the new application differed from the meal price status 

 7

Some of the reasons for differences described below may also exist in cases where the 

survey eligibility category matched the certification status after reapplication, but the table and 

discussion focus only on those cases where these did not match. 
 75 

TABLE VI.2 

REASONS FOR DIFFERENCE BETWEEN MEAL PRICE STATUS ASSIGNED BY SFA 

AND MEAL PRICE STATUS BASED ON THE SURVEY AMONG NONRESPONDERS 

TO VERIFICATION WHO WERE REAPPROVED

 Cases in Group for Which Each Reason Applies 

 Benefits per Survey Less than 

Benefits per Application 

Benefits per Survey Exceed 

Benefits per Application Total 

 Number Percentage Number Percentage Number Percentage 

Categorical Eligibility or Foster 

Child Status Differs 2 5.6 1 4.6 3 5.2 

Computational Error 

(Calculation of Eligibility 

Differs) 3 8.3 1 4.6 4 6.9 

Income Differs Reflecting That 

Number of Household Members 

Who Reported Income Differs 15 41.7 4 18.2 19 32.8 

Total Household Income 

Matches, but Number of 

Household Members Differs 1 2.8 0 0.0 1 1.7 

Income Differs Reflecting That 

Number of Sources or Type of 

Income Differs 9 25.0 4 18.2 13 22.4 

Income Amounts by Type 

Differ 6 16.7 12 54.6 18 31.0 

Total 36 100 22 100 58 100 
 76 

assigned by the SFA, although total income and household size were the same in both sources. 

In these cases, the meal price eligibility category based on the two different data sources (survey 

and reapplication) matched, according to our own calculations of both, but this category did not 

match the meal price status assigned by the SFA. The data we collected did not allow us to 

determine the reason for this discrepancy. 

Number of Household Members Who Reported Income. The most common reason for 

differences between survey-based meal price eligibility status and the meal price status assigned 

by the SFA was differences in the number of household members who reported income. 

Differences in the number of household members who reported any income accounted for onethird of the differences in meal price eligibility status between the two data sources. Most of 

these households (15 of the 19) reported more members with income on the survey than were 

shown on the reapplication. This suggests that (1) the survey collected data on some people who 

were not listed as household members on the reapplication, (2) the survey collected income data 

on some household members who were listed on the reapplication as having no income, or (3) 

real changes in the number of household members with income occurred in the short period 

between the date of reapplication and the date of the survey. The detailed income questions 

asked on the survey may have reminded respondents of income sources for household members 

they had not considered relevant when completing the reapplication.8

 In one other household, 

 8

Of these 15 households, 6 reported more household members on the survey than they 

included on their reapplication. This may imply that these six cases left some household 

members with income off their reapplication, while the other nine cases included all household 

members on their reapplication but left off income sources for some. However, we cannot be 

sure, since we were unable to determine for certain which individual household members in one 

data source were the same individuals in the other data source. 
 77 

the meal price status failed to match because, although the total household income amount from 

the two data sources was the same, the number of household members differed.9

Number of Sources or Types of Income Differ. In 13 households (22 percent), the survey 

meal price status failed to match the SFA’s meal price status after reapplication due to a different 

number of income sources for at least one household member (nine cases) or due to a difference 

in the types of income sources, even though the number of sources of income was the same (four 

cases).10 Of these 13 households, 9 reported a greater amount of income on the survey than on 

the reapplication, and 4 reported a lesser amount on the survey. 

Individual Income Amounts. In the remaining 18 households (31 percent), the sources or 

types of income for household members are consistent, but the survey-based eligibility category 

did not match the recertification status, due to a difference in one or more person/source monthly 

income amounts.

11 This was the second most common reason for differences. This was also the 

only type of difference that more often resulted in a higher estimate of benefits based on the 

survey data than on the reapplication data. Of these 18 households, 12 reported lower income 

amounts on the survey than on their reapplication. The other six reported higher income 

amounts on the survey than on their reapplication. 

 9

The household actually reported the same number of people in the survey and on the 

reapplication. However, one person did not meet our survey definition for inclusion in the 

household economic unit, so we did not collect income data on that person. 

10The survey asked about income from 21 different types of income sources, including jobs, 

unemployment compensation, social security, supplemental security income, and child support. 

11In 3 of these 18 cases, the households had provided incomplete income data on the survey, 

so all or part of their household income was imputed. Incomplete income data were imputed 

based on actual income amounts reported by other cases in the data, using hot-decking or 

median-fill methods. For more information on imputation procedures, see “Volume II: 

Description of Study Methods and Supplementary Tables of the Evaluation of the National 

School Lunch Program Application/Verification Pilot Projects” report. 
 78 

In summary, most of the differences between our survey-based eligibility determinations 

and the certification status after reapplication were associated with discrepancies between the 

number of household members for whom income was reported on the two data sources and 

between the component income amounts reported for an individual person/source. In cases 

where the data sources did not match due to differences in the number of people with income, 

households tended to report fewer household members with income on their reapplications than 

in the survey. In cases where the data sources did not match due to differences in individual 

amounts, however, households tended to report lower income amounts (given person/source) in 

the survey data. 

D. ESTIMATING THE PORTION OF THE DIFFERENCE IN RATES OF 

INELIGIBILITY OF NO-CHANGE CASES DUE TO CHANGING 

CIRCUMSTANCES 

The interviews of no-change-at-verification households were conducted in February and 

March 2003. Table IV.2 shows 65.5 percent of these households were eligible for at least the 

benefits they were approved to receive. Thus, 34.5 percent of households in this sample were 

found to be ineligible, at the time of the survey in March 2003, for the NSLP benefits that they 

were certified for in December 2002. This is a substantial number, and it raises the question of 

whether the verification process failed to identify that these households were ineligible or 

whether changes in household circumstances made some of them ineligible after the verifications 

had been completed. While it is not possible to distinguish precisely between these two potential 

explanations, it is possible to draw on various survey results already reported to place bounds on 

the relative importance of the two possible explanations. We explore this next. 

Following are key facts for our discussion: 

• First, as noted above, about 34 percent of the no-change-at-verification households 

were ineligible for benefits as of approximately March 15, 2003. 
 79 

• Second, we know from Table V1.1 that approximately 22 percent of households that 

initially failed to respond to a verification request but subsequently reapplied were 

ineligible for the benefits they applied for upon reapplication according to the study 

survey in March 2003. We believe that this provides a reasonable estimate of the 

percentage of the no-change-at-verification cases that were ineligible as of 

approximately December 15, at the end of the fall verification activities. 

The 12 percentage point difference in these two numbers (34 – 22 = 12 percent) represents a 

reasonable lower-bound estimate of the percentage of cases certified for benefits in December 

who became ineligible due to subsequent changes in household circumstances. It is a lowerbound estimate, because some of the 22 percent of households estimated to be ineligible in 

December may not have remained ineligible, but may have become eligible again by March. 

The above analysis implies that at least 35 percent (that is, 12 percent divided by 34 percent) 

of the no-change-at-verification households found to be ineligible in the March survey were 

probably ineligible due to relatively recent changes in household circumstances that had occurred 

since the verification process. As noted, this is a lower-bound estimate. For reasons discussed in 

Appendix C, where we present the above discussion more formally, we believe that a plausible 

most likely estimate of this percentage would probably be 45 to 60 percent. 
 
81

REFERENCES 

Gleason, Philip M. “Participation in the National School Lunch Program and the School 

Breakfast Program.” American Journal of Clinical Nutrition, vol. 61 (suppl.), 1995, pp. 

213s-220s. 

Gleason, Philip, Kenneth Jackson, Patricia Nemeth, Tania Tasse, John Hall, and Bidisha Ghosh. 

“Direct Certification and Its Impact on Errors in the National School Lunch Program: Data 

Collection and Descriptive Report.” Report submitted to the U.S. Department of Agriculture, 

Economic Research Service. Princeton, NJ: Mathematica Policy Research, Inc., August 

2002. 

Gleason, Philip, Tania Tasse, Kenneth Jackson, and Patricia Nemeth. “Direct Certification in the 

National School Lunch Program: Impacts on Access and Program Integrity.” Publication 

no. E-FAN-03-009. Report submitted to the U.S. Department of Agriculture, Economic 

Research Service. Princeton, NJ: Mathematica Policy Research, Inc., October 2003. 

Moore, Jeffrey C., Linda L. Stinson, and Edward J. Welniak, Jr. “Income Measurement Error in 

Surveys: A Review.” Journal of Official Statistics, vol. 16, no. 4, 2000, pp. 331-361. 

Strasberg, Paul J. “School Food Authority Administration of National School Lunch Program 

Free and Reduced Price Eligibility Determination.” Report no. CN-03-AV. Alexandria, VA: 

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition 

and Evaluation, August 2003. 

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and 

Evaluation. “National School Lunch Program Application/Verification Pilot Project Report 

on First Year Experience.” Report no. CN-02-AV. Alexandria, VA: USDA, August 2002. 
 
APPENDIX A 

ADDITIONAL TABULATIONS
 
 A.1 

TABLE A.1 

OUTCOMES OF NSLP VERIFICATION IN 21 LARGE METROPOLITAN DISTRICTS 

(Mean Percentages Across Districts) 

Group Initial Status

Status at 

Conclusion of 

Verification 

Process 

Responded to 

SFA 

Child Enrolled on 

12/15/02 

Percent of All 

Households in 

Category 

Initial Application Approved on the Basis of Income and Household Size

A Free Free Yes n.a. 15.3 

B Free Reduced-price Yes n.a. 8.7 

C Free Paid Yes n.a. 2.0 

D Free Paid No Yes 24.7 

E Free Paid No No 0.6 

F Free Paid No Missing 3.4 

G Free Missing/uncertain No Yes 0.9 

H Free Missing/uncertain No No b 

I Free Missing/uncertain No Missing 0.5 

J Reduced-price Free Yes n.a. 1.2 

K Reduced-price Reduced-price Yes n.a. 7.9 

L Reduced-price Paid Yes n.a. 4.8 

M Reduced-price Paid No Yes 13.1 

N Reduced-price Paid No No 0.4 

O Reduced-price Paid No Missing 1.9 

P Reduced-price Missing/uncertain No Yes 0.8 

Q Reduced-price Missing/uncertain No No 0.1 

R Reduced-price Missing/uncertain No Missing 0.3 

Initial Application Approved on the Basis of Categorical Eligibility 

(Receipt of TANF, Food Stamps, or FDPIR)

S Free Free Yes n.a. 8.1 

T Free Reduced-price Yes n.a. 0.1 

U Free Paid Yes n.a. 1.0 

V Free Paid No n.a. 3.0 

W Free Missing/uncertain No n.a. 0.4 

Initial Application Approved on the Basis of Foster Child Status

X Free Free Yes n.a. 0.4 

Y Free Paid No n.a. 0.3 

Z Othera 0.1 

N = 5,118 households. 

a

Foster child cases for which key information was missing or miscoded. 

b

Rounds to less than one-tenth of one percent. 

n.a. = not applicable; we did not check enrollment status for these cases; only for income-eligible nonresponders. 
 A.2 

TABLE A.2 

OUTCOMES OF NSLP VERIFICATION IN 21 LARGE METROPOLITAN DISTRICTS, 

BY SAMPLING METHOD USED 

(Mean Percentages Across Districts) 

Group Initial Status

Status at Conclusion 

of Verification 

Process 

Responded 

to SFA 

Child 

Enrolled on 

12/15/02 

Districts 

Using 

Focused 

Sample 

(n=10) 

Districts 

Using 

Random 

Sample 

(n=11) 

Initial Application Approved on the Basis of Income and Household Size

A Free Free Yes n.a. 11.2 19.0 

B Free Reduced-price Yes n.a. 10.5 7.1 

C Free Paid Yes n.a. 2.2 1.9 

D Free Paid No Yes 26.3 23.3 

E Free Paid No No 0.8 0.5 

F Free Paid No Missing 2.3 4.3 

G Free Missing/uncertain No Yes 1.4 0.5 

H Free Missing/uncertain No No 0 b 

I Free Missing/uncertain No Missing 0.3 0.6 

J Reduced-price Free Yes n.a. 0.9 1.5 

K Reduced-price Reduced-price Yes n.a. 7.2 8.5 

L Reduced-price Paid Yes n.a. 7.1 2.7 

M Reduced-price Paid No Yes 17.8 8.8 

N Reduced-price Paid No No 0.7 0.2 

O Reduced-price Paid No Missing 2.2 1.6 

P Reduced-price Missing/uncertain No Yes 1.1 0.5 

Q Reduced-price Missing/uncertain No No 0.2 0.0

R Reduced-price Missing/uncertain No Missing 0.4 0.2 

Initial Application Approved on the Basis of Categorical Eligibility 

(Receipt of TANF, Food Stamps, or FDPIR)

S Free Free Yes n.a. 4.5 11.3 

T Free Reduced-price Yes n.a. 0.0 0.2 

U Free Paid Yes n.a. 0.2 1.8 

V Free Paid No n.a. 2.4 3.7 

W Free Missing/uncertain No n.a. 0.2 0.5 

Initial Application Approved on the Basis of Foster Child Status

X Free Free Yes n.a. 0.2 0.6 

Y Free Paid No n.a. 0.2 0.5 

Z Othera 0.0 0.1 

a

Foster child cases for which key information was missing or miscoded. 

b

Rounds to less than one-tenth of one percent. 

n.a. = not applicable; we did not check enrollment status for these cases; only for income-eligible nonresponders.
 A.3 

TABLE A.3 

RANGE OF OUTCOMES OF NSLP VERIFICATION ACROSS ALL 21 PARTICIPATING DISTRICTS 

(Complements Table A.1) 

Group Initial Status

Status at Conclusion of 

Verification Process 

Responded 

to SFA 

Child 

Enrolled on 

12/15/02 

Lowest 

Percentage 

Highest 

Percentage 

Initial Application Approved on the Basis of Income and Household Size

A Free Free Yes n.a. 6.4 37.5 

B Free Reduced-price Yes n.a. 1.3 21.4 

C Free Paid Yes n.a. 0 4.9 

D Free Paid No Yes 2.9 44.2 

E Free Paid No No 0 2.4 

F Free Paid No Missing 0 12.7 

G Free Missing/uncertain No Yes 0 4.3 

H Free Missing/uncertain No No 0 0.4 

I Free Missing/uncertain No Missing 0 5.5 

J Reduced-price Free Yes n.a. 0 3.6 

K Reduced-price Reduced-price Yes n.a. 2.7 13.3 

L Reduced-price Paid Yes n.a. 0 13.4 

M Reduced-price Paid No Yes 3.6 29.3 

N Reduced-price Paid No No 0 3.4 

O Reduced-price Paid No Missing 0 7.3 

P Reduced-price Missing/uncertain No Yes 0 4.2 

Q Reduced-price Missing/uncertain No No 0 1.2 

R Reduced-price Missing/uncertain No Missing 0 2.1 

Initial Application Approved on the Basis of Categorical Eligibility 

(Receipt of TANF, Food Stamps, or FDPIR)

S Free Free Yes n.a. 0.9 35.6 

T Free Reduced-price Yes n.a. 0 1.5 

U Free Paid Yes n.a. 0 15.4 

V Free Paid No n.a. 0 14.1 

W Free Missing/uncertain No n.a. 0 1.8 

Initial Application Approved on the Basis of Foster Child Status

X Free Free Yes n.a. 0 2.2 

Y Free Paid No n.a. 0 3.8 

Z Othera 0 0.5 

a

Foster child cases for which key information was missing or miscoded. 

n.a. = not applicable; we did not check enrollment status for these cases; only for income-eligible nonresponders.
 A.4 

TABLE A.4 

RANGE OF OUTCOMES ON SUMMARY MEASURES OF NSLP VERIFICATION 

RESULTS ACROSS ALL 21 PARTICIPATING DISTRICTS 

(Complements Table III.1) 

Lowest 

Percentage 

Highest 

Percentage 

Responder: No Change 

 

Free to free (Groups A, S, X) 9.3 48.1 

Reduced-price to reduced-price (Group K) 2.7 20.0 

Responder: Benefits Increased 

Reduced-price to free (Group J) 0 3.6 

Responder: Benefits Reduced or Terminated 

Free to reduced-price (Groups B, T) 1.3 21.4 

Free to paid (Groups C, U) 0.5 15.4 

Reduced-price to paid (Group L) 0 13.1 

Nonrsponder 

Initially free (Groups D, E, F, G, H, I, V, W, Y) 7.7 62.9 

Initially reduced-price (Groups M, N, O, P, Q, R) 4.8 30.4 

Notes: Excluded are 3 of the original 5,183 cases—those approved as foster child and for which 

key information (for example, on outcome status) was missing or possibly miscoded. 

 

 Groups A, B, C, ...Y are those shown in Table A.1. 
 A.5 

TABLE A.5 

RANGE OF REAPPROVAL RATES FOR NONRESPONDERS TO VERIFICATION AS OF 

MARCH 1, 2003, ACROSS ALL 21 PARTICIPATING DISTRICTS 

(Complements Table III.8) 

 Lowest Percentage Highest Percentage 

Overall 

 

Reapproved, free 0.4 29.7 

Reapproved, reduced-price 0 17.5 

Paid 51.9 93.7 

Withdrawn 0 8.6 

Missing 0 5.5 

Original Status Free 

 

Reapproved, free 0.5 42.7 

Reapproved, reduced-price 0 20.6 

Paid 40 94.1 

Withdrawn 0 14.8 

Missing 0 6.7 

Original Status Reduced-Price 

 

Reapproved, free 0 11.3 

Reapproved, reduced-price 0 23.2 

Paid 65.2 100 

Withdrawn 0 14.8 

Missing 0 8.3 
 A.6 

TABLE A.6 

INCOME STATUS OF GROUPS OF HOUSEHOLDS SELECTED FOR NSLP VERIFICATION IN 21 LARGE 

METROPOLITAN SFAs 

(Percentage of All Students in this Group)

 Initial Meal Price Status 

Estimated Income Status Based on Study Interview Free Reduced-Price Total 

Households Who Had No Change in NSLP Benefits as a Result of Verification 

Income <130 Percent FPL 63.8 25.7 51.7 

130 to 185 25.6 42.5 31.0 

186 to 250 5.8 24.0 11.6 

251 to 400 3.1 5.4 3.8 

>400 1.7 2.4 1.9 

Percent Eligible 65.2 

Number in Sample 359 167 526 

Households Who Failed to Respond to Verification Request 

Income <130 Percent FPL 50.3 30.1 43.6 

130 to 185 23.7 24.4 24.0 

186 to 250 15.3 28.7 19.8 

251 to 400 8.6 13.9 10.4 

>400 1.9 2.9 2.2 

Percent Eligible 51.7 

Number in Sample 417 209 626 

 

Note: The 21 case study districts were selected and recruited for the study by FNS regional office staff. Within 

each district, samples were selected to be representative of households who had no change in meal price 

benefits as a result of verification or households whose NSLP benefits were terminated for failure to 

respond to the verification request. Each sample is representative of cases in the subgroup whose initial 

application was approved on the basis of income and household size; applications approved because the 

household was receiving TANF, food stamp, or FDPIR benefits or because the child was a foster child 

are excluded from the sample. 
A.7 

TABLE A.7 

INCOME STATUS OF GROUPS OF HOUSEHOLDS SELECTED FOR NSLP VERIFICATION 

IN 21 LARGE METROPOLITAN SFAs, BY USE OF FOCUSED OR RANDOM SAMPLING 

FOR VERIFICATION 

(Percentage of All Students in the Group) 

 Focused Sampling Random Sampling 

Estimated Income Status Based on Study Interview Free Reduced-Price Total Free Reduced-Price Total 

Households Who Had No Change in NSLP Benefits as a Result of Verification 

Income <130 Percent FPL 58.0 25.0 45.8 67.6 26.5 56.2 130 to 185 29.4 39.3 33.0 23.1 45.8 29.4 186 to 250 8.4 23.8 14.1 4.2 24.1 9.7 251 to 400 2.8 7.1 4.4 3.2 3.6 3.3 >400 1.4 4.8 2.6 1.9 0.0 1.3 Percentage Eligible 60.3 68.9 Number in Sample 143 84 227 216 83 299 

Households Who Failed to Respond to Verification Request 

Income <130 Percent FPL 44.5 29.5 38.2 54.9 31.2 49.0 130 to 185 27.5 25.8 26.8 20.9 22.1 21.2 186 to 250 17.6 26.5 21.3 13.6 32.5 18.3 251 to 400 8.2 14.4 10.8 8.9 13.0 9.9 >400 2.2 3.8 2.9 1.7 1.3 1.6 Percentage Eligible 49.0 54.5 Number in Sample 182 132 314 235 77 312 Note: The 21 case study districts were selected and recruited for the study by FNS regional office staff. Within each district, samples were selected to be 

representative of households who had no change in meal price benefits as a result of verification or households whose NSLP benefits were terminated for failure to respond to the verification request. Each sample is representative of cases in the subgroup whose initial application was approved on the basis of income and household size; applications approved because the household was receiving TANF, food stamp, or FDPIR 

benefits or because the child was a foster child are excluded from the sample. 
 A.8 

TABLE A.8 

CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT FAILED TO RESPOND TO 

VERIFICATION WHO REAPPLIED AND DID NOT REAPPLY, IN DISTRICTS 

USING RANDOM SAMPLING FOR VERIFICATION 

(Mean Percentages Across Districts) 

Characteristics 

Nonresponders 

Who Were 

Reapproved by 

March 1, 2003 

Nonresponders 

Who Were Not 

Reapproved by 

March 1, 2003 Difference 

Household Size 

 Number of household members (mean) 

 Number of children in household (mean) 

4.9 

2.6 

4.5 

2.2 

0.4 

0.4 

Household Structure (Percentages) 

 Two-parent household 

 Single-parent household 

 Other household structure 

47.1 

47.5 

5.3 

50.6 

39.6 

9.8 

–3.5 

7.9 

–4.4 

Survey Respondent’s Educational Attainment 

(Percentages) 

Lacks a high school diploma 

High school diploma only 

Some postsecondary education but lacks a 

college degree 

College degree or more 

39.0 

32.9 

26.7 

1.4 

31.0 

33.0 

32.3 

3.6 

7.9 

–0.2 

–5.6 

–2.2 

Employment Status of Household Members 

Survey respondent is employed (percentage) 

Number of employed adults in household (mean) 

59.1 

1.0 

69.4 

1.4 

–10.4 

–0.4 

Household Income (Percentages) 

 Less than 130 percent of FPLa

 131 to 185 percent of FPL 

 186 to 250 percent of FPL 

 251 to 400 percent of FPL 

 More than 400 percent of FPL 

70.1 

18.2 

5.4 

5.1 

1.3 

40.9 

26.3 

22.8 

8.6 

1.3 

29.2 

–8.2 

–17.4 

–3.5 

–0.1 

Percentage Receiving Public Assistance 

Percentage receiving food stamp benefits 

Percentage receiving TANF 

Percentage receiving other benefits 

18.8 

3.2 

9.8 

6.1 

1.8 

11.4 

12.7 

1.4 

-1.5 

Race/Ethnicity (Percentages) 

White, non-Hispanic 

Black, non-Hispanic 

Hispanic 

Native American 

Asian, Pacific Islander 

Other 

Mixed race 

25.3 

20.3 

36.5 

0.0 

3.1 

0.0 

14.8 

34.9 

22.7 

24.2 

1.3 

3.0 

0.3 

13.6 

–9.7 

–2.5 

12.3 

–1.3 

0.2 

–0.3 

0.1 
TABLE A.8 (continued) 

 A.9 

Characteristics 

Nonresponders 

Who Were 

Reapproved by 

March 1, 2003 

Nonresponders 

Who Were Not 

Reapproved by 

March 1, 2003 Difference 

English Primary Language Spoken at Home 

(Percentage) 59.6 67.2 –7.5 

Grade Level of Child (Percentages) 

Grade 9 to 12 

Grade 6 to 8 

Grade 3 to 5 

Grade 1 to 2 

Kindergarten or pre-K 

12.7 

40.8 

21.1 

21.3 

4.1 

32.1 

21.8 

21.1 

15.4 

9.7 

–19.3 

19.0 

0.1 

5.9 

–5.6 

Parents’ Views on Administration of School Meal 

Programs (Percentages) 

Believes school lunch program at child’s school 

is well run 

Believes the application process to receive 

free/reduced-price meals is fair 

89.7 

87.3 

87.5 

76.1 

2.2 

11.2 

Students’ Perceptions of Quality/Taste of School 

Meals (Percentages) 

Satisfied with amount of food in school lunches 

 Satisfied with quality/taste of school lunches 

87.4 

86.5 

74.6 

77.2 

12.8 

9.3 

Number of Days per Week Usually Eats School 

Lunch (Self-Reported) 

0 

1 

2 

3 

4 

5 

3.1 

0.0 

0.0 

4.9 

3.3 

88.7 

18.1 

1.7 

4.8 

6.5 

7.3 

61.6 

–15.1 

–1.7 

–4.8 

–1.5 

–4.0 

27.8 

Percentage of Students (Based on Self-Reported 

Meal Price Status) 

Free 

Reduced-price 

Paid 

76.0 

19.5 

4.5 

18.6 

8.9 

72.5 

57.4 

10.6 

–68.0 

Sample Size 83 232 

FPL = federal poverty level. 

a

The lowest income category (less than 130 percent of FPL) includes families categorically eligible for free meals 

(based on receipt of TANF or food stamps or foster child status), regardless of their actual income. 
 A.10 

TABLE A.9 

CHARACTERISTICS OF SURVEY SAMPLE OF HOUSEHOLDS THAT FAILED TO RESPOND TO VERIFICATION 

WHO REAPPLIED AND DID NOT REAPPLY, IN DISTRICTS USING FOCUSED SAMPLING FOR VERIFICATION 

(Mean Percentages Across Districts) 

Characteristics 

Nonresponders Who 

Were Reapproved by 

March 1, 2003 

Nonresponders Who 

Were Not Reapproved 

by March 1, 2003 Difference 

Household Size 

 Number of household members (mean) 

 Number of children in household (mean) 

4.3 

2.2 

4.5 

2.2 

–0.2 

–0.0 

Household Structure (Percentages) 

 Two-parent household 

 Single-parent household 

 Other household structure 

40.9 

55.3 

3.8 

57.4 

37.7 

4.9 

–16.5 

17.6 

–1.0 

Survey Respondent’s Educational Attainment 

(Percentages) 

Lacks a high school diploma 

High school diploma only 

Some postsecondary education but lacks a college 

degree 

College degree or more 

31.7 

34.3 

30.1 

3.8 

21.3 

35.3 

35.9 

7.4 

10.4 

–1.1 

–5.8 

–3.6 

Employment Status of Household Members 

Survey respondent is employed (percentage) 

Number of employed adults in household (mean) 

63.9 

1.1 

74.5 

1.4 

–10.6 

–0.3 

Household Income (Percentages) 

 Less than 130 percent of FPLa

 131 to 185 percent of FPL 

 186 to 250 percent of FPL 

 251 to 400 percent of FPL 

 More than 400 percent of FPL 

57.0 

28.3 

7.4 

2.3 

5.0 

32.9 

24.5 

25.5 

14.1 

3.0 

24.0 

3.8 

–18.8 

–11.8 

2.0 

Percentage Receiving Public Assistance 

Percentage receiving food stamp benefits 

Percentage receiving TANF 

Percentage receiving other benefits 

10.6 

2.5 

6.0 

2.9 

2.4 

8.1 

7.7 

0.1 

–2.0 

Race/Ethnicity (Percentages) 

White, non-Hispanic 

Black, non-Hispanic 

Hispanic 

Native American 

Asian, Pacific Islander 

Other 

Mixed race 

17.3 

30.4 

30.7 

0.0 

9.4 

0.0 

12.2 

28.2 

21.9 

29.5 

1.7 

6.5 

0.9 

11.3 

–10.9 

8.5 

1.2 

–1.7 

3.0 

–0.9 

0.9 

English Primary Language Spoken at Home (Percentage) 65.8 72.5 –6.7 

Grade Level of Child (Percentages) 

Grade 9 to 12 

Grade 6 to 8 

Grade 3 to 5 

Grade 1 to 2 

Kindergarten or pre-K 

16.2 

18.6 

39.3 

13.6 

12.3 

21.1 

23.1 

34.5 

16.2 

5.1 

–4.8 

–4.5 

4.7 

–2.5 

7.2 
TABLE A.9 (continued) 

 A.11 

Characteristics 

Nonresponders Who 

Were Reapproved by 

March 1, 2003 

Nonresponders Who 

Were Not Reapproved 

by March 1, 2003 Difference 

Parents’ Views on Administration of School Meal 

Programs (Percentages) 

Believes school lunch program at child’s school is 

well run 

Believes the application process to receive 

free/reduced-price meals is fair 

89.1 

79.7 

83.0 

73.0 

6.1 

6.7 

Students’ Perceptions of Quality/Taste of School Meals 

(Percentages) 

 Satisfied with amount of food in school lunches 

 Satisfied with quality/taste of school lunches 

88.9 

76.1 

75.9 

73.6 

12.9 

2.5 

Number of Days per Week Usually Eats School Lunch 

(Self-Reported) 

0 

1 

2 

3 

4 

5 

2.0 

0.7 

4.0 

14.7 

2.6 

76.0 

16.4 

4.5 

6.4 

9.7 

3.2 

59.7 

–14.4 

–3.9 

–2.4 

5.0 

–0.6 

16.4 

Percentage of Students (Based on Self-Reported Meal Price 

Status) 

Free 

Reduced-price 

Paid 

67.7 

21.3 

11.0 

17.7 

9.9 

72.4 

50.0 

11.3 

–61.4 

Sample Size 77 240 

FPL = federal poverty level. 

a

The lowest income category (less than 130 percent of FPL) includes families categorically eligible for free meals (based on 

receipt of TANF or food stamps or foster child status), regardless of their actual income. 
A.12 

TABLE A.10 

TOTAL SAMPLE AND NUMBER OF COMPLETED INTERVIEWS, BY SUBGROUP AND DISTRICT 

 Nonresponders to Verification No Change Cases 

Total 

Sample 

Ineligible 

Sample 

Eligible 

Sample 

Completed 

Interviews 

Response 

Ratea

 Total 

Sample 

Ineligible 

Sample 

Eligible 

Sample 

Completed 

Interviews 

Response 

Ratea

District Anaheim Union High School CA 48 0 48 39 81.3 39 0 39 27 69.2 

Anoka-Hennepin MN 32 1 31 5 16.1 37 1 36 22 61.1 

Boston MA 48 1 47 35 74.5 38 0 38 32 84.2 

Broken Arrow OK 8 1 7 7 100.0 23 4 19 19 100.0 

Granite UT 40 1 39 32 82.1 31 1 30 24 80.0 

Hacienda La Puente CA 46 1 45 32 71.1 32 1 31 27 87.1 

Hampton City VA 40 4 36 28 77.8 9 0 9 7 77.8 

Jordon UT 28 1 27 17 63.0 17 0 17 16 94.1 

Lake County FL 47 3 44 27 61.4 38 1 37 31 83.8 

Lawrence MA 51 3 48 35 72.9 32 2 30 27 90.0 

Long Beach Unified CA 48 1 47 33 70.2 41 3 38 26 68.4 

Minneapolis, MN 53 4 49 38 77.6 35 1 34 29 85.3 

Newport News City VA 40 1 39 26 66.7 30 1 29 23 79.3 

Orange County FL 48 1 47 40 85.1 39 0 39 34 87.2 

Orange Unified CA 48 0 48 35 72.9 40 0 40 35 87.5 

Osceola County FL 48 2 46 40 87.0 39 1 38 34 89.5 

Salt Lake City UT 40 2 38 29 76.3 21 0 21 17 81.0 

Seminole County FL 48 3 45 36 80.0 39 1 38 33 86.8 

Tulsa OK 40 5 35 31 88.6 30 8 22 20 90.9 

Virginia City Beach VA 40 2 38 26 68.4 17 0 17 16 94.1 

Worcester MA 48 3 45 41 91.1 38 1 37 33 89.2 

Total 889 40 849 632 74.4 665 26 639 532 83.3 

Mean 42.3 1.9 40.4 30.1 74.5 31.7 1.2 30.4 25.3 84.1 aDefined as number of completed interviews divided by eligible sample. 
APPENDIX B 

INCOME ELIGIBILITY OF NONRESPONDERS AND NO-CHANGE CASES 

FOR GROUPS OF CASE STUDY DISTRICTS
 
 B.1 

We tabulated mean outcomes for several different groupings of SFAs in which the groups 

are defined by SFA characteristics, other than method of sampling. However, because randomsampling districts may differ from focused sampling districts, we also tabulate the mean 

percentage eligible separately for cases in random- and focused-sampling districts with a specific 

characteristic. The tabulation by random versus focused is not performed when any grouping 

contains less than three districts. 

Table B.1 displays the pertinent data. Characteristics are displayed in the row heads of the 

table. The first three columns show the number of districts in each group defined in the 

corresponding row head. The second set of three columns shows for nonresponders the number 

of households, and the third set of three columns shows the mean percentage of eligible 

nonresponder households. The fourth and fifth sets of three columns show number of cases and 

mean percentage eligible for no-change cases. 
B.2 

TABLE B.1 

INCOME ELIGIBILITY STATUS IN DISTRICTS WITH SELECTED CHARACTERISTICS 

(Mean Percentages Across Districts) 

 Households Who Failed to Respond to Verification Households Who Had No Change Due to Verification 

Number of 

Districts 

Number of 

Cases 

 Mean Percentage Eligible for 

Their Benefit 

Number of 

Cases 

 Mean Percentage Eligible for 

Their Benefit 

 SFA Sampling Method SFA Sampling Method SFA Sampling Method SFA Sampling Method SFA Sampling Method SFA Characteristics All Focused Random All Focused Random All Focused Random All Focused Random All Focused Random District Enrollment 

10,000 to 50,000 13 4 9 372 126 246 51.0 45.7 53.3 322 80 242 65.4 60.2 67.7 >50,000 8 6 2 254 a a 55.3 a a 204 a a 65.7 a a 

Percentage of Students Approved for Free and Reduced-Price Meals 

≤50 12 4 8 316 111 205 57.0 52.6 59.2 293 73 220 68.8 60.6 72.9 

>50 9 6 3 310 203 107 46.8 46.8 46.6 233 154 79 61.1 61.0 61.4 

Use of Direct Certification 

Use Direct 

Certification 17 9 8 472 275 197 54.1 48.6 60.3 398 200 198 67.4 60.2 75.5 

Do Not Use Direct 

Certification 4 1 3 154 a a 46.2 a a 128 a a 57.4 a a 

Application Type 

Single-child 5 3 3 160 a a 54.6 a a 141 a a 68.1 a a Multichild 16 8 8 466 248 218 52.0 49.6 54.4 385 173 212 64.7 59.8 69.5 

Note: Hypothesis tests were not performed. aThe number of SFAs in either the random-sampling or focused-sampling subgroups with this characteristic is too small (less than three) to report statistics separately for those using different sampling 

methods. 
APPENDIX C 

DETAILS OF THE ESTIMATE OF THE PERCENTAGE INELIGIBLE IN MARCH 

WHO HAD A CHANGE IN ELIGIBILITY FROM DECEMBER TO MARCH
 
 C.1 

From the survey data analyzed in Chapter IV, we can draw additional insights into the 

reasons for differences in meal price status as determined by the SFA and from the survey. To 

estimate the proportion of cases ineligible according to the survey that were eligible when the 

SFA determined their eligibility but became ineligible by the time of the survey, as well as the 

proportion who were ineligible at both points, we can compare the percentage of cases ineligible 

for the benefits for which they were approved among (1) households who failed to respond to 

verification requests but were subsequently reapproved for benefits, and (2) households that had 

no change in benefits due to verification.

One potentially important source of difference between information reported on an 

application and information provided as part of the NSLP verification process is that the family’s 

circumstances changed between the time of application and the time of verification. 

Applications for free and reduced-price meals are typically submitted at the beginning of the 

school year, but the SFA does not request documentation until the verification process is 

conducted later in the fall. In the intervening months, family members may have entered or left 

the household, and employment patterns or income from other sources may have changed. 

Although program rules require that families report increases in their household income of $50 

per month or more, anecdotal information suggests families rarely report any changes. 

Changing family circumstances and the exact period to which information applies are also 

likely to play a role in explaining differences between meal price status as determined by the 

SFA and meal price eligibility status as determined through the study interviews. Here, we use 

results from Chapter IV and Chapter VI to estimate how much changes in household 

circumstances may contribute to the finding that some children are certified for a greater level of 

benefits than the survey indicates they are eligible to receive. For cases that had no change in 

certification status, survey data collection occurred approximately 10 weeks after the SFA had 
 C.2 

determined eligibility at verification. However, survey data collection and the SFA’s eligibility 

determination occurred at approximately the same time for nonrespondent cases that reapplied 

for benefits. These differences in timing of data provided to SFAs relative to the study survey 

allow us to estimate what proportion of ineligibility observed among the sample of no-change 

cases (reported in Chapter IV) might have been due to changes in their circumstances between 

the time of reapplication and the time of the survey. 

The interior cells of Figure C.1 show the possible eligibility statuses in December and 

March of those cases who had no change in their meal price status as a result of verification. 

Eligibility status as of March 15, 2003, is the eligibility status found in the Case Study survey. 

Eligibility status as of December 15, 2002, is the eligibility status that would have been found if 

the survey had been conducted at that point in time. 

FIGURE C.1 

ELIGIBILITY STATUS AT TWO POINTS IN TIME OF CASES WITH NO CHANGE 

DUE TO VERIFICATION 

(Includes Cases Approved for Benefits in December 2002) 

 Actual Eligibility Status as of December 15, 2002 

Actual Eligibility Status as 

of March 15, 2003 Yes No Total 

Yes Group 1 Group 2 Group 1+2 

No Group 3 Group 4 Group 3+4 

Total Group 1+3 Group 2+4 Group 1+2+3+4 

• Group 1 was approved by the SFA in December and eligible according to the survey 

in both December and March. 

• Group 2 was approved in December and not eligible at that time but had a change in 

circumstances that made the household eligible in March. 

• Group 3 was approved in December and eligible in December but had a change in 

circumstances that made the households ineligible in March. 
 C.3 

• Group 4 was approved in December and not eligible in December and not eligible in 

March. 

From the interviews with no-change cases, we estimate that 35 percent of these cases were 

not eligible in March for the benefits they were approved to receive at the time of verification 

prior to December 15. However, we do not know what proportion of this ineligible group was 

eligible in December but had a change in income by the time of the survey (Group 3) and what 

portion was also ineligible in December (Group 4). To assess whether the verification process 

correctly determines eligibility status, we need to estimate Group 4—the proportion of nochange cases approved by the SFA that were not eligible in December and not eligible in March. 

Our approach to forming an estimate of Group 4 uses survey-based estimates of the row and 

column totals, in conjunction with an assumption about one of the interior cells, to estimate the 

other three interior cells. From Table IV.2, we estimate that the total for Group 1+2 is .66 and 

the total for Group 3+4 is .34. We use the estimate of the percentage of reapplicants in the 

nonresponder group who were eligible and ineligible for their benefits—78 percent and 22 

percent, respectively (Table VI.1)—as an estimate of the Group 1+3 and Group 2+4 totals in 

Figure C.2. 

While this measure is not ideal, we believe it provides a reasonable proxy, for two reasons. 

First, SFA staff were supposed to follow the same procedures in conducting verification and in 

processing the reapplications submitted after nonresponse to verification: all families were 

required to provide documentation of each source of income of each adult in the household. 

Second, the study’s questions and the income verification documents received by SFA staff 

covered nearly the same period for this group. Survey interviews were conducted in February 

and March, and households were asked to report about income in January or February. The 

verification documents received by SFA staff during the January to February period when 
 C.4 

FIGURE C.2 

ELIGIBILITY STATUS AT TWO POINTS IN TIME OF CASES WITH NO CHANGE 

DUE TO VERIFICATION ASSUMING NO CASES APPROVED IN DECEMBER 

CHANGED FROM INELIGIBLE TO ELIGIBLE 

(Includes Cases Approved for Benefits in December 2002) 

 Actual Eligibility Status as of December 15, 2002 

Actual Eligibility Status as of 

March 15, 2003 Yes No Total 

Yes .66 .0 .66 

No .12 .22 .34 

Total .78 .22 

nonresponders were reapplying would most likely have provided data on the period December to 

February. Thus, the period covered by the survey and the period covered by the verification 

documents were very close to the same.1

 A significant limitation of using the information on 

nonresponders who reapplied as a proxy for information on cases who responded initially and 

had no change in benefits is that the two groups could have a different likelihood of reporting 

accurately on the study survey and/or a different likelihood of providing complete, accurate 

documentation of their income to the SFA. Our analysis makes the untestable assumption that no 

such differences exist. 

Finally, to identify the proportion in Group 4, we need information on one of the internal 

cells of Figure C.2. We can place an upper and lower bound on the proportion in Group 4 by 

assuming that (1) all cases in the Group 2+4 total are in Group 4 and none are in Group 2, and 

(2) all cases in the Group 2+4 total are in Group 2 and none are in Group 4. This gives an upper-

 1

 In contrast, documents used by the SFAs for verification would have pertained to the 

period October to November, and so the information from the survey and the verification process 

was not contemporaneous. 
 C.5 

bound estimate of Group 4 of 34 percent and a lower-bound estimate of Group 4 of 22 percent. 

If 22 percent of 34 percent were ineligible at both points, this implies that 65 percent of cases 

found ineligible in March were also ineligible in December, and 35 percent of those found 

ineligible in March had a change in circumstance between verification and the interview. 

Accordingly, 35 percent is a lower bound on the percentage of those ineligible who are ineligible 

due to a change in circumstance. 

We believe that a reasonable assumption is that the proportion of all cases in Group 2 is 

small or close to zero. If 5 percent are in Group 2, then 17 percent are in Group 4. This 

reasoning suggests that, of the 34 percent of no-change cases observed to be ineligible at the time 

of the interview, between 50 and 60 percent were also ineligible at the time of verification, and 

between 40 and 50 percent were eligible at the time of verification and became ineligible 

between the point of verification and the survey interview.