Nutrition Assistance Program Report Series 

The Office of Analysis, Nutrition and Evaluation 

Special Nutrition Programs Report No. CN-03-AV 

School Food Authority Administration of National 

School Lunch Program Free and Reduced Price 

Eligibility Determination 

United States Food and 

Department of Nutrition 

Agriculture Service 

August 2003
Non-Discrimination Policy 

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, gender, religion, age, disability, political beliefs, sexual orientation, and 

marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require 

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contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). 

To file a complain of discrimination, write USDA, Director, Office of Civil Rights, Room 326-W, Whitten 

Building, 14th and Independence Avenues, SW, Washington, DC 20250-9410 or call (202) 720-5964 (voice and 

TDD). USDA is an equal opportunity provider and employer. 
 School Food Authority Administration of National 

School Lunch Program Free and Reduced Price 

Eligibility Determination

Author: 

Paul J. Strasberg, Ph.D. 

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

Suggested Citation:

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and Evaluation, School Food 

Authority Administration of National School Lunch Program Free and Reduced Price Eligibility Determination, CN-03-AV, 

by Paul J. Strasberg. Alexandria, VA: 2003.

United States Food and 

Department of Nutrition 

Agriculture Service 

August 2003

Special Nutrition Programs

Report No. CN-03-AV
School Food Authority Administration of National School Lunch Program 

Free and Reduced Price Eligibility Determination 

Table of Contents 

List of Tables ........................................................................................................................i 

List of Figures .......................................................................................................................i 

Acknowledgements.............................................................................................................. ii 

Executive Summary............................................................................................................ iii 

Section 1: Introduction...................................................................................................1 

Section 2: The Current F/RP Eligibility Determination System....................................3 

Section 3: Research Objectives......................................................................................4 

Section 4: Study Methods ..............................................................................................5 

Section 5: Study Results ..............................................................................................12 

Section 6: Conclusions.................................................................................................28 

References...........................................................................................................................29 

Appendix A.........................................................................................................................30 

Appendix B .........................................................................................................................34 

Appendix C .........................................................................................................................35
i

List of Tables 

Table 1 Characteristics of School Food Authorities included in this study, October 2001 ........9 

Table 2 Initial certification status of verified applications reviewed by FNS...........................13 

Table 3 Accuracy of applications approved on the basis of income and household size..........15 

Table 4 Summary of verification determinations .....................................................................17 

Table 5 Summary of verification determinations for applications approved on the basis 

of income and household size......................................................................................18 

Table 6 Summary of verification determination of categorically approved applications .........21 

Table 7 Was SFA verification decision appropriate based on FNS review? ............................22 

Table 8 Reapplication among households w/ benefits reduced or terminated..........................24 

Table 9 Accuracy of end of year meal ticket status ..................................................................25 

List of Figures 

Figure 1 Overview of current NSLP free and reduced price eligibility determination 

process ..........................................................................................................................3 

Figure 2 Certification status of students in 14 study SFAs ........................................................10 

Figure 3 Certification status of children in NSLP schools, October 2001 .................................10 

Figure 4 Pre-verification status of verification applications in study SFAs...............................14 

Figure 5 Accuracy of SFA eligibility determinations among income-based applications .........14 

Figure 6 Verification results in 14 study SFAs ..........................................................................19 

Figure 7 Accuracy of SFA verification determinations .............................................................19 

Figure 8 Reapplications patterns among non-respondents.........................................................27 

Figure 9 Accuracy of end of year meal ticket status of applications selected for 

verification .................................................................................................................27 
ii

ACKNOWLEDGEMENTS 

Several staff members in the Office of Analysis, Nutrition and Evaluation (OANE), Food 

and Nutrition Service, US Department of Agriculture contributed to the analyses and 

production of this report: Dr. Paul Strasberg had primary responsibility for data 

collection, analysis and writing. Ginneh Stowe provided important analytical support and 

developed many of the graphics. Dr. John Endahl, Rich Lucas, Cindy Long and Jay 

Hirschman (OANE) provided important guidance in the study design and analysis and 

commented on earlier drafts. Todd Barrett of the Child Nutrition Division provided 

assistance in the design of data collection protocols and training of Regional Office staff 

that conducted data collection. Terry Bowman and John Kwit from the Midwest 

Regional Office helped to design a study in one large Midwest SFA that preceded this 

larger effort. 

The following FNS Regional Office and Headquarters staff members conducted data 

collection: 

Northeast: Mary Ellen Blundell, Donna Kirby and Maureen Rankin 

Mid-Atlantic: Mark Durma, Sallie Ellner, Jonita Larkins 

Midwest: Michael Roach, Roberta Van House 

West: Mike Jacob, Doraetta Mozon, Reese Payton, Michael Woodbridge 

Mountain Plains: Joe Fisher, Jerry Stankorb 

Southeast: Kirk Farquharson, Robert McCosh 

Southwest: Rex Carey, Paul Schmitz 

Headquarters: Winnie McQueen, Karen Smith 

The school food service staff in study SFAs and State Child Nutrition Agencies in all 14 

study States (Arkansas, Arizona, California, Colorado, Georgia, Florida, Louisiana, 

Maryland, Massachusetts, Michigan, Missouri, New York, Ohio and Virginia) were 

supportive in explaining this project to their SFAs, and in several cases provided 

assistance in data collection. 
iii

School Food Authority Administration of National School Lunch Program 

Free and Reduced Price Eligibility Determination 

EXECUTIVE SUMMARY 

Background 

• From July to September 2002, the Food and Nutrition Service reviewed the free 

and reduced price (F/RP) eligibility determination process (i.e., application, 

verification, reapplication, meal ticket status) for each of 3,474 applications 

selected for verification in 14 large School Food Authorities in the 2001-02 

school year. These SFAs enroll nearly one million children, among whom 45 

percent were approved for free meals and 7 percent were approved for reduced 

price meals as of October 31, 2001. 

Verification Results 

• Overall results: On average, 43 percent of applications verified in study districts 

had their benefit levels unchanged as a result of the verification process, while 55 

percent had a benefit reduction / termination and 2 percent had an increase in 

benefits from reduced price to free. 

• Respondent ineligibility: Among respondents to verification, 21 percent had a 

benefit reduction or termination. In random sampling districts 14 percent of 

respondents had a benefit reduction or termination; in focused sampling districts 

40 percent of respondents had a benefit reduction or termination. Four percent of 

respondents to verification had a benefit increase from reduced-price to free meal 

eligibility. 

• Reasons for benefit change: Non-response to the verification process accounted 

for most of the applications that had benefits reduced or terminated. Seventyseven percent of benefit reductions / terminations (BRT) in focused sampling 

districts were due to non-response while 80 percent of all BRTs in random 

sampling districts were the result of non-response. Random sampling SFAs had a 

higher rate of benefit increase from reduced price to free (3 percent) compared to 

focused sampling SFAs (1 percent). 

• Results from income applications v. categorical applications:

o Income and household size applications: Among applications approved 

on the basis of income and household size selected for verification, 57 

percent had benefits reduced or terminated. Among respondents, 23 had 

their benefits reduced or terminated. The average rate of benefit reduction 

or termination among respondents was lower in random sampling districts 

(18 percent) than in focused sampling districts (34 percent). 
iv

o Categorically approved applications – where households that report a 

Food Stamp / Temporary Assistance for Needy Families / Food 

Distribution Program on Indian Reservations (FS/TANF/FDPIR) case 

number as the basis of their eligibility - were less likely to have a benefit 

reduction or termination as a result of the verification process than income 

and household size applications. Among categorically-approved 

applications, there was a 30 percent rate of benefit reduction / termination 

compared to a 57 percent rate among income and household size 

applications.1

Accuracy of SFA review of applications and verifications 

• Application review: On average, 94 percent of initial approvals by SFAs for free 

and reduced price meal benefits where applicants reported household income and 

size were accurate based on information provided on the applications while 6 

percent of initial approvals were inaccurate. 

• Verification determinations: 92 percent of verification decisions by SFAs were 

appropriate – consistent with the documentation provided by parents -- and 8 

percent of verification decisions were inappropriate. 

• Meal ticket status: Among children whose applications and verifications we 

reviewed, the end of year meal ticket status was accurate in 83 percent cases 

while it was inaccurate in 17 percent of cases. 

• Direction of inaccuracy: Over 75 percent of all SFA administrative errors 

identified in this study resulted in households being approved for a greater level 

of benefit than was supported by the materials provided by households to SFAs. 

Less than 25 percent of all errors resulted in households being approved for a 

lower level of benefit than to which they were entitled based on material they 

provided SFAs. 

Reapplication of non-responders to verification 

• 29 percent of households that had their benefits terminated in the verification 

process reapplied later in the 2001-02 school year in study SFAs. An average of 

93 percent of such reapplications were approved for free or reduced price meal 

benefits, while 7 percent were denied. 

 

1

 The rate of benefit reduction of categorically approved applications, in all likelihood, overstates the rate of 

income-ineligibility at the time of verification among this population. A 2002 FNS study estimated, for 

example, that 4 percent of FS/TANF/FDPIR recipients in July 2001 selected for verification in a pilot 

project were income-ineligible by December 2001. 
1

School Food Authority Administration of National School Lunch Program 

Free and Reduced Price Eligibility Determination 

Section 1 

INTRODUCTION 

Each school year, School Food Authorities (SFAs) make a determination of the eligibility 

of applicants for free and reduced price school meals at the time households submit 

applications. In recent years, this application review process has resulted in the approval 

of more than 14 million children for free or reduced price meals. The Food and Nutrition 

Service estimates that application-based approvals are responsible for the certification of 

more than 2/3 of all free and reduced price approved children in a typical school year.2

 

As such, SFA administrative accuracy in the application review process is essential to 

program integrity. 

Eligibility determinations are based on SFA review of self-reported income and 

household size information or self-reporting of a Food Stamp Program / Temporary 

Assistance for Needy Families / Food Distribution Program on Indian Reservations 

(FS/TANF/FDPIR) case number. The bulk of initial determinations are made within the 

first several weeks of each school year, though households may submit applications for 

free and reduced price school meals at any time during the school year. 

SFAs make a second eligibility determination for a small sample of household 

applications between the time of initial eligibility determination and December 15 of each 

school year – this is known as the verification process. The verification process was 

established in the National School Lunch Program (NSLP) in the early 1980s to serve as 

a deterrent with respect to household misreporting eligibility information. It was argued 

that verification of a small proportion of households approved for free or reduced price 

meal benefits would deter against ineligible households from applying for and being 

approved for free and reduced price meal benefits. 

In the verification process, SFAs request documentation of household income or 

FS/TANF/FDPIR status from households.3

 Households are required to respond to the 

verification request; if they do not respond, SFAs are obligated to change such children’s 

meal ticket status to paid. The accuracy of children’s meal ticket status is fundamental to 

program integrity. For each meal served, SFAs receive reimbursement which varies 

depending on the meal ticket status of the participating child. In school year 2001-02, 

FNS provided SFAs a reimbursement of $2.235 in cash and commodities for free meals 

 

2

 A recent USDA-sponsored study estimates that the number of children approved for free and reduced 

price meal benefits thru two other methods – direct certification and Provision II and Provision III – 

accounted for approximately 1/3 of all free and reduced price approvals in the 2001-02 school year (USDA 

/ ERS, forthcoming ). 

3

 For applications initially approved on the basis of a FS/TANF case number, SFAs may seek verification 

of current eligibility by requesting this information from local or State FS/TANF agencies. 
2

served, while for reduced price and paid meals the reimbursement rates were $1.835 and 

$0.345, respectively. 

 

Responding to a growing concern about inaccurate certifications, FNS has conducted 

several activities from 2000 to 2003 to better understand free and reduced price 

certification accuracy. To learn about the effects of alternative eligibility determination 

systems, FNS initiated the NSLP Application / Verification Pilot Projects.4

 In the Pilot 

Projects, 22 SFAs have tested three alternative methods of eligibility determination for 

free and reduced price meals. Findings from the pilot project evaluation will be released 

in the near future. 

To improve understanding of the accuracy of the current eligibility determination system 

in 2002, FNS also carried out a review in 14 large SFAs of 3,474 applications selected for 

verification. Each of these SFAs had enrollments between 24,000 and 178,000 children in 

2001-02. In aggregate, these 14 large SFAs enroll approximately 950,000 children, of 

whom 52 percent were approved for free and reduced price meals as of October 31, 2001. 

This report provides the results of the review of SFA administrative records regarding 

applications, verifications and meal ticket status. Data collection was conducted by FNS 

Regional Office staff members. The report examines: 

a) the accuracy with which SFAs conduct the application and verification processes 

within the National School Lunch Program (NSLP); 

b) the results of the verification process in 14 large SFAs; 

c) the rate at which children whose benefits are terminated in the verification process 

reapply for free and reduced price meal benefits following termination; and 

d) the accuracy at the end of the 2001-02 school year of the meal ticket status of 

children selected for verification.5

 

 

4

 See NSLP Application / Verification Pilot Projects: Report on First Year Experience. (FNS, 2002) and 

Evaluation of the NSLP Application / Verification Pilot Projects (FNS, forthcoming). 5

 FNS Midwest Regional Office staff and FNS-Headquarters staff collected data in one SFA in January 

2002 to accomplish goals similar to the goals of the current study. From that activity – the results of which 

are found in Appendix B – FNS designed the current study. 
3

Section 2 

THE CURRENT F/RP ELIGIBILITY DETERMINATION SYSTEM

Under current program rules, SFAs across the country are required to follow a set of 

procedures articulated in Federal regulations (7 CFR 245). These procedures provide that 

SFAs may: 

• Certify children for free meals for the school year on the basis of documentation 

from State of local government agencies which establish that the student is a 

member of a household that is eligible for FS/TANF/FDPIR, (i.e., Direct 

Certification); or 

• Certify children for F/RP meal benefits for the school year on the basis of an 

application submitted by the children’s household on which current receipt of 

FS/TANF/FDPIR is documented or where monthly income of all household 

members and household size are self-reported. 

SFAs are required to verify a small percentage of approved F/RP applications each 

school year. Typically SFAs verify 3 percent or less of approved applications.6

 In this 

process, for each household selected for verification, SFAs are required to determine 

whether the household’s current FS / TANF / FDPIR status or household income and size 

are consistent with the household’s certification status and to take action with regard to a 

household’s eligibility, if warranted. The eligibility of directly-certified children is not 

subject to verification under standard program regulations. Figure 1 provides an 

overview of the current F/RP eligibility determination process. 

Figure 1 

Overview of Current NSLP

Free and Reduced Price Meal Eligibility Determination Process

Not Approved

Verify Small Sample Not Verify Majority

Approved for Free or

Reduced Price Meals

SFA Determines Eligibility Based on Application

Information on Household Size and Income

Households Apply

No Documentation

May be Directly Certified

for Free Meals

Households Receive

TANF, Food Stamps, or FDPIR

 

6

 The requirements for SFA verification sample selection are found in the Eligibility Guidance for School 

Meals Manual (FNS: 2001) available at: http://www.fns.usda.gov/cnd/Guidance/default.htm 
4

Section 3 

RESEARCH OBJECTIVES 

This report addresses the following objectives: 

1) Accuracy of initial eligibility determinations: determine the accuracy with 

which large SFAs make free and reduced price (F/RP) eligibility determinations 

based on a review of application materials submitted by households and processed 

by SFAs; to the extent that errors occur in this process, determine the type of 

errors made.7

2) Verification process results: determine the percentage of application-based 

children approved for free and reduced price meal benefits that were verified and 

had their meal benefits unchanged, reduced, terminated and increased; determine 

the rate of non-response among households selected for verification. 

3) Accuracy of verification determinations: among applications verified, 

determine the percentage of correct and incorrect decisions made by SFAs.8

4) Reapplication patterns: among households with benefits reduced or terminated, 

what is the percentage that reapply9 within the same school year; and what is the 

approval status of such applications? 

5) Accuracy of meal ticket status: among applications verified, what percent of 

students have accurate meal ticket status, where accuracy is defined as reflecting 

the most current application and related materials received by the SFA at the end 

of the school year? 

 

7

 A USDA-sponsored study estimated that 4.6 percent of all applications reviewed by SFAs in 1986-87 

were improperly classified due to SFA administrative error. Two point four (2.4) percent were approved 

for free meals but should have been reduced price, 1.6 percent were approved for reduced price but should 

have been free and 0.6 percent were declared free or reduced price but should have been paid. (FNS, 1990) 

A 1981 study found that, among a sample of 38,414 students approved for free or reduced price meal 

benefits, 7 percent were incorrectly certified for the following reasons: 2.5 percent were in the wrong 

benefit category; 2.5 percent lacked information on the application for proper certification; applications 

were not in SFA files for 1.8 percent; and 0.3 percent were incorrect for other reasons (General Accounting 

Office, 1981). 

8

 A USDA-sponsored study estimated that 2.5 percent of applications verified had inaccurate verification 

decisions in school year 1986-87. The audit of SFA verification decisions in that study decomposed these 

errors as follows: 1.9 percent of verified applications were determined to receive a greater level of benefits 

than supported by the income documentation provided while 0.6 percent of verified applications were 

determined to receive a lower level of benefits than supported by the income documentation provided. 9

 FNS regulations require that households verified whose benefits are reduced or terminated in a given year 

that wish to reapply must include documentation of their household income by source or provide 

documentation of their current eligibility for FS/TANF/FDPIR benefits. 
5

Section 4 

STUDY METHODS

4.1 Data Collection 

This study is based on case record abstractions prepared by reviewing a random sample 

of 3,474 applications selected for verification by these 14 school districts in the 2001-02 

school year. To obtain the data, staff members from the seven Regional Offices of the 

Food and Nutrition Service (FNS) visited these districts for a period of between two to 

four days. During these visits, conducted between July 5 and September 27, 2002, FNS 

staff members knowledgeable10 in NSLP certification and verification procedures 

conducted the following activities: 

1. Identified all applications verified by the SFA in the 2001-02 school year11; 

2. Selected a random sample within each SFA of up to approximately 300 of the 

applications verified12; 

3. Located salient documentation associated with the application, verification and reapplication processes for the sampled households. 

4. Completed one questionnaire for each application. 13 

5. Completed one questionnaire for each SFA visited to collect district-wide 

statistics relating to enrollment and certifications as of October 31, 2001.14

While completing questionnaires for each application verified, staff members focused 

particular attention on certain aspects of the eligibility determination process. In the data 

collection process some important simplifying assumptions were made: 

1. Income and household size information on applications were examined and other 

types of errors were ignored. To the extent that applications did not have all 

required elements (e.g., signature of an adult household member, Social Security 

Number, etc.) reviewers ignored this and did not consider it to be inaccurate. 

2. SFAs are required, at the conclusion of verifying an application, to record an 

eligibility determination decision and notify the household of that decision if a 

change is warranted. In some cases, SFAs selected an application for verification 

 

10 FNS staff members that collected data in this study are experts in child nutrition policy and participated 

in a two day training program in June 2002 at FNS Headquarters in Alexandria, VA. 

11 In a limited number of SFAs, necessary files were at a large number of schools across the district. In 

such cases, FNS did not review all applications. Rather FNS reviewers used procedures designed to obtain 

a random sample among all applications verified. 

12 FNS staff members used procedures designed to obtain a simple random sample among all applications 

selected for verification in the study year. Note that the sample frame from SFAs selected their verification 

sample is required to include all applications approved as of October 31, and does not include applications 

approved after that date through the remainder of the school year. 

13 An example of the data collection forms used by FNS Regional Office staff members in this activity is 

included as Appendix A. 

14 Between September 15 and December 15, 2002, data entry and cleaning was conducted within the Office 

of Analysis, Nutrition and Evaluation. During the data entry and processing stage, FNS researchers 

interacted with FNS RO staff who had conducted the site visits to ensure a high level of data accuracy. 
6

but did not record any outcome. These incomplete verifications were classified as 

being in error. 

3. Reviewers sought to determine if the children of verified households left the 

school district after being selected for verification. To the extent that changes in 

enrollment were identified, these cases were excluded from the analysis following 

their departure from the district. 

4.2 Sample Size, Generalizability and Statistical Weights 

The 14 SFAs included in this study verified a total of 7,223 applications in school year 

2001-02. FNS abstracted records for 3,474 applications verified among the 14 SFAs, or 

an average of 248 applications per study SFA. FNS reviewed 48 percent of all 

applications verified by study SFAs in 2001-02.

In three SFAs – Little Rock, AR, Prince William County, VA, and Boston, MA – FNS 

collected data on all verifications conducted by December 15, 2001. (See Table 1.) For 

the remaining 12 study SFAs, FNS collected information for a random sample of between 

5 and 99 percent of all applications selected for verification. 

For each set of results in this report, weighted averages are presented for the six districts 

that used random sampling and for the eight districts that used focused sampling. To 

obtain average results for the group of random sampling study districts and the group of 

focused sampling districts, weights were computed to reflect the proportion of 

application-based free and reduced price approved children in each district. If, for 

example, one of the eight focused sampling SFAs had 20 percent of all F/RP applicationbased F/RP approved children, that SFA would contribute 20 percent to the focused 

sampling district averages presented in the report. 

Likewise, a 14 SFA average is presented. The 14 SFA averages are weighted such that 

random sampling and focused sampling districts comprise 69 and 31 percent, 

respectively, of the average. These weights reflect the most recent estimate of the 

proportion of children approved for free and reduced price meals that attend school in 

random sampling and focused sampling districts, respectively (USDA / ERS, 2003). 

Notwithstanding the weighting procedures used in this study, an important limitation 

relates to the statistical generalizability of applications selected for verification to the 

population of all applications in study SFAs. Conceptually, in random sampling districts, 

the sample selection techniques of the verification process were designed to provide a 

proxy for a scientific sample of all application-approved households. In practice in the 

school setting, however, procedures used by random sampling districts may not reflect a 

scientific sample in which each application has an equal probability of selection. For 

example, some study districts selected all verified applications from a random sample of 

schools; some schools were excluded from selection because they had been sampled in 

recent years. 
7

Focused sampling is designed to select: 

a) a random sample of households whose reported monthly income was $100 or less 

below the income eligibility threshold for free and for reduced price meals; and 

b) a random sample of categorically-approved applications. 

As such, results for the focused sampling districts do not reflect a simple random sample 

of all approved applications. Conceptually, households approved on the basis of income 

and household size whose incomes are more than $100 below the income eligibility 

threshold for free and for reduced price meals are excluded from selection. In the current 

study, however, we found that 25 percent of applications reviewed in focused sampling 

districts fell outside the income range. (See Appendix C.) 

In sum, in terms of statistical generalizability, caution should be exercised in interpreting 

verification results from the six random sampling districts, the eight focused sampling 

districts and the combined 14 district sample in light of the verification sampling 

techniques described above. 

4.3 Limitations of the Benefit Reduction Termination Rate to Proxy for Ineligibility 

In the income verification process, SFAs determine on the basis of household response in 

December that some children are not income eligible for the level of benefits for which 

they were approved near the beginning of the school year. SFAs also are required to 

change to paid the meal ticket status of non-respondent households. On the basis of SFA 

experience in the verification process, this study provides estimates of the benefit 

reduction / termination rate (BRT). For several reasons, the BRT may have limited 

usefulness in proxying for the rate of income-ineligibility among F/RP approved children. 

A 1990 USDA-sponsored study showed that, notwithstanding SFA administrative errors, 

the BRT consists of two parts: 

1. error attributable to misreporting at the time of application, and 

2. error attributable to a failure of households to declare changes in household 

circumstances that occurred during the school year. 

The study estimated that 61.5 percent of all households verified by SFAs (whether or not 

their benefits were changed) had a change in monthly income of $50 or more between the 

time of application and the time of verification. The study also found that 22.2 percent of 

those households with income changes of $50 or more result in a decrease (from free to 

reduced price or free or reduced price to paid) in the household’s income eligibility status 

while 1.8 percent of income changes resulted in an increase in the household’s income 

eligibility status (from reduced price to free). (USDA, 1990) 

The study also estimated, based on in-home interviews with non-respondents, that 67 

percent were income-eligible for the benefits for which they had been approved prior to 

verification and 81 percent were eligible for either free or reduced price meal benefits. 
8

For these reasons, results from the verification process should not be interpreted as being 

a proxy for either a) income-eligibility and income-ineligibility among free and reduced 

price approved households; or b) the accuracy of the application process. 

4.4 Data processing and quality control 

FNS Regional Office (RO) staff conducted data collection in two ways. For 12 of 14 

study SFAs, RO staff recorded information on paper forms as shown in Appendix A 

while in the remaining two SFAs RO staff recorded the information electronically using a 

Microsoft Excel 2000 version of the paper form. Upon completion of data collection, RO 

staff sent the original copies of completed questionnaires to the Office of Analysis, 

Nutrition and Evaluation (OANE) while retaining either a paper or electronic copy of 

these documents. Data entry was conducted using SPSS/PC 10.0 software. During and 

subsequent to data collection, there was frequent interaction between OANE and RO staff 

to ensure accurate interpretation of many questionnaires. 

4.5 Characteristics of SFAs studied in this activity 

FNS collected information in 14 SFAs. The SFAs selected have wide geographic 

representation; in each of seven FNS Regions, two SFAs were selected. A list of SFAs 

included in this study, and some of their characteristics are found in Table 1. These 14 

SFAs enrolled 949,747 children as of October 31, 2001, among whom 45 percent were 

approved for free meals and 7 percent were approved for reduced price meals. Table 1 

and Figures 2 and 3 also show that study SFAs had a higher percentage of students 

approved for free meals than that found in all NSLP schools – 33 percent - according to 

information reported by State Agencies and contained in FNS’ National Data Bank. 

However, 7 percent of children enrolled in these districts are approved for reduced price 

meals, lower than the national average of 8 percent.15

St. Louis, MO and Buffalo, NY had the highest percentage of children approved for 

either free or reduced price (F/RP) meals at 82 and 78 percent, respectively. Jefferson 

County, CO (13 percent) and Anne Arundel County, MD (16 percent) had the lowest 

F/RP approval rate among enrolled children. 

Detroit was the largest of study SFAs with an enrollment of 178,084 students. The 

smallest study SFA was Little Rock, Arkansas with 24,460 students. 

 

15 The presentation of results in this study does not reveal the identity of the districts from which they are 

drawn. The presentation of results provides statistics for the group of six random sampling districts and the 

group of eight focused sampling districts. However, these results do not associate district names with 

results from any given district. The appendix tables, rather, identify districts using a letter code such that a 

given district maintains its identity thru all tables. 
Type of 

Application Enrollment

Approved Free as 

Percentage of 

Enrollment

Among free 

approved, 

percentage 

directly certified

Among free 

approved, 

percentage 

application-based

Approved Reduced Price 

as Percentage of 

Enrollment

Applications 

Selected for 

Verification

Applica

Reviewe

Analyzed 

U.S. Total 47,925,735 33% 25% / 17%* 75% / 83%* 8%14 SFA Total 949,747 45% 22% 78% 7% 7,223 3,476 Random SFA Total 361,348 40% 15% 85% 8% 4,693 1,728 Focused SFA Total 588,399 48% 26% 74% 7% 2,530 1,74Random Sampling Districts

Anne Arundel Co, Maryland multi child 75,141 11% 1% 99% 5% 502 253 DeKalb County, Georgia multi child 96,262 45% 8% 92% 10% 1,946 299 Lee County, Florida individual child 61,830 33% 14% 86% 10% 857 300 Little Rock, Arkansas individual child 24,460 52% 31% 69% 7% 310 310 St. Louis, Missouri individual child 41,336 78% 45% 55% 5% 564 324 Tucson, Arizona multi child 62,319 45% 15% 85% 9% 514 243 Focused Sampling DistrictsBoston, Massachusetts multi child 63,445 59% 12% 88% 9% 298 298 Buffalo, New York individual child 46,869 65% 17% 83% 13% 462 298 Cincinnati, Ohio multi child 44,872 53% 35% 65% 6% 191 190 Detroit, Michigan multi child 178,084 58% 48% 52% 4% 716 300 E Baton Rouge, Louisiana multi child 50,475 59% 28% 72% 8% 182 173 Jefferson Co, Colorado multi child 86,006 10% 16% 84% 3% 91 89 Prince William Co, Virginia multi child 58,010 16% 19% 81% 6% 71 71 Santa Ana, California individual child 60,638 60% 0% 100% 15% 519 326 Source: Review conducted by FNS RO staff (2002) and forthcoming USDA-sponsored report (USDA/ERS, 2003)* The first percentage represents districts that used direct certification; the second percentage represents all districts. These percentages also include children approved for free meals and reduced price meals in Provision 2/3 schools where annual eligibility determinations are done in accordance with these regulatory provisions.

Table 1. Characteristics of School Food Authorities Included in this Study, October 2001.

9
10

Figure 2. Certification Status of Children in 14 Study SFAs

Free- Direct 

Certification

22%

Free- Application 

Based

78%

Free

45%

Reduced Price

7%

Not Approved

48%

Figure 3. Certification Status of Children in NSLP 

Schools in the 50 States and District of Columbia, 

October 2001

Not Approved

59%

Reduced Price

8%

Free

33%

Free- Application 

Based

83%

Free- Direct 

Certification

17%
11

Six of the 14 study SFAs select their verification sample using a random approach while 

the remaining eight used a focused sample selection approach.16 FNS selected districts to 

be included in this study on the basis of their verification sample selection method. A 

balance of SFAs that used random and focused methods for verification was sought. Six 

SFAs that used random sampling and eight SFAs that used focused sampling were 

selected and included in this study. 

FNS regulations exclude directly certified children from the verification process. 

Thirteen of the 14 study SFAs used direct certification in 2001-02 to approve children for 

free meals; Santa Ana, CA was the only study SFA that did not use direct certification in 

the study year. On average, 22 percent of free approved children were directly certified 

across these districts. Therefore, on average 78 percent of free approved children were 

approved on the basis of an application and were subject to the verification process. All 

reduced price approved applications are subject to being sampled in the verification 

process. 

 

16 FNS regulations provide SFAs with an option of selecting a sample of approved applications for 

verification thru either a random or focused approach. These procedures are outlined in Eligibility 

Guidance for School Meals Manual (FNS, 2001). 
12

Section 5 

STUDY RESULTS 

5.1 Characteristics of Verified Applications 

Table 2 and Figure 4 show that among the 14 SFAs included in this study, an average of 

63.5 percent of applications in the verification sample were approved for free meals on 

the basis of income and household size, 17.5 percent were approved for free meals on the 

basis of categorical eligibility17 and 19.0 percent were approved for reduced price meals. 

5.2 Accuracy of the SFA Application Review Process 

Table 3 and Figure 5 show that, on average, 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 applications.18 Approval accuracy rates across the 14 

SFAs where application materials were reviewed by FNS staff ranged from a low of 84.3 

percent to a high of 98.4 percent. 

With regard to the 5.7 percent of applications approved inaccurately, FNS found that, on 

average 4.9 percent were approved for a greater level of meal benefits than was supported 

by information on the application. In 0.9 percent of approved applications, households 

were provided for reduced price meal benefits but should have been approved for free 

meal benefits. 19 To the extent that inaccurate determinations were made among 

applications reviewed by FNS, it was more common that households were provided with 

a greater level of benefits than supported by their application rather than less benefits 

than supported by their application. FNS did not examine applications submitted by 

households that had resulted in benefits being denied to households. As such, we do not 

have information on the accuracy of determinations regarding denied applications and 

what number may have been denied in error by SFAs. 

 

17 Categorical eligibility is defined as the process by which a household reports a FS/TANF/FDPIR case 

number on an application for free or reduced price meal benefits. Such household applications do not 

require information on household income and size. 

18 FNS reviewers did not make an assessment about the accuracy of applications approved on the basis of 

categorical eligibility. The rates reported in Table 3 are representative of applications approved for free or 

reduced price meals on the basis of income and household size. Results do not take into account the 

accuracy of applications submitted by households where benefits were denied by the SFA. 19 Results reflect the accuracy of applications approved for F/RP meal benefits and do not reflect 

applications submitted by households that were denied benefits. FNS did not review denied applications at 

study SFAs. To the extent that SFAs denied applications appropriately, this would increase the application 

approval accuracy rate. 
Table 2. Initial certification status of verified applications reviewed by FNS

Reduced Price

Categorical Income & HH Size

14 SFA Average 17.5% 63.5% 19.0%6 Random SFA Total 18.5% 64.5% 17.0%8 Focused SFA Total 15.3% 61.3% 23.3%Random Sampling Districts

A 8.0% 67.7% 24.3%B 15.1% 66.6% 18.4%

C 17.7% 68.1% 14.2%D 29.2% 45.5% 25.3%

E 33.0% 63.9% 3.1%

F 19.3% 65.0% 15.6%

Focused Sampling Districts

H 16.8% 63.6% 19.7%

I 9.9% 43.7% 46.5%

J 12.9% 69.0% 18.1%

K 33.2% 48.9% 17.9%

L 14.0% 61.3% 24.7%

M 1.0% 72.5% 26.5%

N 32.2% 44.6% 23.2%

P 6.7% 73.0% 20.2%

Free

-- percent of verified applications reviewed by FNS --

Source: Review conducted by FNS RO staff (2002).

13
14

Figure 4. Pre-Verification Status of Verified 

Applications in Study SFAs

Reduced 

Price

19.0%

Free - 

Categorical 

17.5%

Free - 

Income and 

Household 

Size

63.5%

Figure 5. Accuracy of SFA Eligibility 

Determinations Among Income-Based Applications

Correct 

Decision

94.3%

More Benefits 

Than 

Application 

Justified

4.9%

Less Benefits 

Than 

Application 

Justified

0.9%

Incorrect 

Decision

5.8%
Table 3. Accuracy of applications approved on the basis of income and household size reviewed

Decision 

Correct

Certified for Less Benefits 

Application Justified

F but 

Should 

Have Been 

RP

F but 

Should 

Have Been 

P

RP but 

Should 

Have Been 

P Total RP but should have been 

14 SFA Average 94.3% 4.1% 0.3% 0.5% 4.9% 0.9%6 Random SFA Total 94.5% 4.1% 0.1% 0.4% 4.6% 0.9%8 Focused SFA Total 93.7% 4.0% 0.5% 1.0% 5.5% 0.9%Random Sampling Districts

A 96.7% 1.8% 0.0% 0.4% 2.2% 1.1%B 94.9% 3.1% 0.0% 0.8% 3.9% 1.2%

C 91.8% 7.1% 0.4% 0.4% 7.8% 0.4%D 97.8% 1.7% 0.0% 0.0% 1.7% 0.6%

E 90.8% 9.2% 0.0% 0.0% 9.2% 0.0%

F 94.4% 4.1% 0.5% 0.0% 4.6% 1.0%

Focused Sampling Districts

H 96.5% 2.8% 0.0% 0.0% 2.8% 0.7%

I 98.4% 0.0% 0.0% 1.6% 1.6% 0.0%

J 92.3% 5.3% 1.1% 0.4% 6.7% 1.1%

K 96.9% 2.4% 0.8% 0.0% 3.1% 0.0%

L 90.3% 6.6% 0.4% 1.2% 8.1% 1.6%

M 94.7% 0.6% 0.6% 2.9% 4.1% 1.2%

N 98.0% 1.5% 0.5% 0.0% 2.0% 0.0%

P 84.3% 14.5% 0.0% 1.2% 15.7% 0.0%

Note: 42 percent of applications were not available for review in District M. Results are reflective of applications reviewed by FNS.

* Note: FNS review did not examine whether categorical application determinations were accurate.

Source: Review conducted by FNS RO staff (2002)

Income & HH Size 

Certified for Greater Benefits than Application 

Justified

15
16

5.3 Results of the Verification Process 

Table 4 and Figure 6 show that, on average, 43 percent of applications verified in the 14 

study districts had their benefit levels unchanged as a result of the verification process, 

while 55 percent had a benefit reduction / termination and 2 percent had an increase in 

benefits from reduced price to free. Non-response to the verification process accounted 

for over 70 percent of applications that had benefits reduced or terminated. Focused 

sampling SFAs had a higher rate of benefit reduction / termination (75 percent) compared 

to random sampling SFAs (46 percent). The higher benefit reduction / termination rate in 

focused SFAs v. random sampling SFAs is associated with a higher non-response rate (58 

percent v. 37 percent) among verified households. Random sampling SFAs had a higher 

rate of benefit increase from reduced price to free (3 percent) compared to focused 

sampling SFAs (1 percent). 

Tables 5 and 6 decompose verification results between those applications: 

 

• initially approved on the basis of income and household size; and 

• initially approved on the basis of categorical eligibility. 

A) Income and Household Size Applications 

Table 5 presents the results of the verification process for applications initially approved 

on the basis of income and household size. This table shows three noteworthy patterns: 

1) On average, nearly one-half of verified applications had benefits 

terminated due to non-response. While the average rate of nonresponse was 44.8 percent; the average non-response rate was higher 

in focused sampling districts (51.8 percent) than in random sampling 

districts (41.7 percent).20

2) Overall, there is a lower average rate of benefit reduction / termination 

in random sampling districts (52.4 percent of verified applications) 

than in focused sampling districts (68.4 percent). 

3) Among respondents, there is also a lower average rate of benefit 

reduction / termination in random sampling districts (18.3 percent of 

respondent households) than in focused sampling districts (34.4 

percent). 

 

20 In three of 14 study districts, FNS reviewers determined that the SFA began but did not complete the 

verification process for some approved income and household size applications. For the purpose of this 

study, we define such cases as inaccurate verification determinations. This represented an average of 1.6 

percent of free approved applications verified and 1.0 percent of reduced price approved applications 

verified. In these instances, the SFAs made no changes to the benefit level of affected children. 
Benefits 

unchanged

Benefits 

increased

Benefits 

reduced or 

terminated 

due to 

response

Benefits terminated due to nonresponse

14 SFA Average 43% 2% 12% 43%6 Random SFA Total 51% 3% 9% 37%8 Focused SFA Total 25% 1% 17% 58%Random Sampling Districts

A 19% 3% 9% 69%B 59% 4% 7% 29%

C 30% 1% 7% 62%D 47% 3% 5% 45%

E 64% 0% 3% 33%

F 65% 2% 19% 15%

H 24% 1% 24% 50%

I 28% 1% 31% 39%

J 22% 1% 18% 59%

K 38% 0% 16% 45%

L 15% 0% 10% 75%

M 15% 1% 19% 64%

N 49% 2% 14% 35%

P 31% 1% 20% 48%

SFA Verification Determination

Table 4. Summary of verification determinationsFocused Sampling Districts

Source: Review conducted by FNS RO staff (2002)

17
Benefits 

unchanged

Benefits 

increased

Benefits 

reduced or 

terminated 

due to 

response

Benefits 

terminated due to 

non-response

Total benefit 

reduction or 

termination 

Among 

responders, 

rate of benefit 

reduction / 

termination

14 SFA Average 35.3% 2.5% 12.5% 44.8% 57.3% 22.7%6 Random SFA Total 44.4% 3.2% 10.7% 41.7% 52.4% 18.3%8 Focused SFA Total 15.0% 0.8% 16.6% 51.8% 68.4% 34.4%Random Sampling Districts

A 15.3% 3.3% 10.2% 71.3% 81.5% 35.5%B 56.3% 5.1% 7.5% 31.1% 38.6% 10.9%

C 27.5% 1.6% 8.2% 62.7% 71.0% 22.1%D 29.1% 3.9% 6.7% 60.3% 67.0% 16.9%

E 49.5% 0.5% 4.6% 45.4% 50.0% 8.5%

F 56.6% 2.0% 23.0% 18.4% 41.3% 28.1%

H 22.2% 1.4% 25.7% 50.7% 76.4% 52.1%

I 20.3% 1.6% 34.4% 43.8% 78.1% 61.1%

J 16.6% 1.1% 21.2% 61.1% 82.3% 54.5%

K 19.7% 0.0% 24.4% 55.9% 80.3% 55.4%

L 7.4% 0.0% 11.6% 81.0% 92.6% 61.2%

M 15.6% 1.0% 19.3% 64.1% 83.4% 53.8%

N 33.7% 2.5% 20.3% 43.6% 63.9% 36.0%

P 28.1% 1.2% 22.0% 48.7% 70.7% 42.9%

SFA Verification Determination

Focused Sampling Districts

Table 5. Summary of verification determinations for applications approved on the basis of income and household size.Source: Review conducted by FNS RO staff (2002).

18
19

Figure 6. Verification Results in 14 Study SFAs

No Change

43%

 NonResponse

43%

 Reduced / 

terminated 

w/response

12%

Benefits 

Increased

2%

Figure 7. Accuracy of SFA Verification 

Determinations

Too Low

1.7%

 Too High

6.7%

Appropriate

91.6%
20

Benefit reduction v. termination: What can we learn about the income levels of 

households approved for free meals on the basis of income and household size? 

Households approved for free meals that respond to the SFA verification request can 

have their benefit level unchanged, reduced or terminated. A benefit reduction should 

occur when a household is determined, at the time of verification, to have income 

between 130 and 185 percent of the Federal Poverty Level (FPL); a termination changing 

the child’s meal ticket status to paid should occur when a household reports income 

above 185 percent FPL. 

Among free approved applications selected for verification in which households 

responded and had a benefit change, 72.4 percent of children had their benefits lowered to 

reduced price while 27.6 percent had their benefits terminated. This finding is consistent 

with those from a USDA-sponsored study of the 1986-87 school year that found 70.1 

percent of free-approved households that responded to the verification request that had 

their benefits changed were changed to reduced price. (USDA, 1990) 

B) Categorical applications 

Categorical applications – those initially approved on the basis of household provision of 

a FS/TANF/FDPIR case number – may be verified in one of two ways by SFAs. In one 

approach, the SFA may send a verification notice to the household requesting 

documentation of either continued FS/TANF/FDPIR eligibility of documentation of 

current income and household size. In an alternative method, the SFA may seek 

confirmation from a local FS/TANF/FDPIR office of the household’s continued receipt 

of program benefits. If the FS/TANF/FDPIR agency does not affirm the household’s 

receipt of program benefits, the SFA must notify the household of this information and 

request that the household respond to the verification request. 

Table 6 shows that 70.4 percent of categorical applications, on average, had their meal 

benefit levels unchanged in the verification process on the basis of either a household 

response or an FS/TANF confirmation of contemporaneous receipt in these programs.21 

A higher percentage of categorical applications remained unchanged in random sampling 

districts (78.3 percent) than in focused sampling districts (52.8 percent). 

The average benefit reduction / termination rate among categorically approved 

applications was 29.6 percent. This represents administrative ineligibility in accordance 

with FNS regulations though it does not address the question of income ineligibility. 

5.4 Accuracy of SFA verification decisions 

FNS reviewers assessed the accuracy of SFA verification decisions on the basis of 

information provided by households in the verification process. Table 7 and Figure 7 

 

21 FNS analysis of SFA administrative records indicates that 2.5 percent of categorical applications verified 

had benefits unchanged because the SFAs began but did not complete the verification process. 
Non-response by HH by 

December 15, 2001 and / or 

FS/TANF Agency did not 

confirm current eligibility

F RP P P

14 SFA Average 70.4% 2.2% 0.1% 27.3%6 Random SFA Total 78.3% 2.4% 0.0% 19.2%8 Focused SFA Total 52.8% 1.7% 0.4% 45.1%Random Sampling Districts

A 62.5% 0.0% 0.0% 37.5%B 73.3% 6.7% 0.0% 20.0%

C 40.0% 0.0% 0.0% 60.0%D 91.9% 1.4% 0.0% 6.8%

E 93.2% 0.0% 0.0% 6.8%

F 97.9% 0.0% 0.0% 2.1%

H 34.5% 13.8% 3.4% 48.3%

I 100.0% 0.0% 0.0% 0.0%

J 54.8% 0.0% 0.0% 45.2%

K 76.2% 0.0% 0.0% 23.8%

L 59.5% 0.0% 0.0% 40.5%

M 0.0% 0.0% 0.0% 100.0%

N 82.3% 2.1% 0.0% 15.6%

P 66.7% 0.0% 0.0% 33.3%

Table 6. Summary of verification determination of categorically approved applications.Source: Review conducted by FNS RO staff (2002).Focused Sampling Districts

Based on HH response with documentation 

or FS/TANF agency response

SFA Verification Determination

21
Table 7. Was SFA verification decision appropriate based on FNS review?

Appropriate Too high Too low

14 SFA Average 91.6% 6.7% 1.7%6 Random SFA Total 89.4% 8.8% 1.8%8 Focused SFA Total 96.4% 2.1% 1.5%Random Sampling Districts

A 97.0% 2.7% 0.3%B 89.3% 7.4% 3.3%

C 98.4% 1.3% 0.3%D 97.6% 0.4% 2.0%

E 69.7% 29.1% 1.2%

F 90.1% 8.6% 1.2%

Focused Sampling Districts

H 94.8% 1.7% 3.5%

I 98.6% 1.4% 0.0%

J 94.2% 1.8% 4.0%

K 98.9% 1.1% 0.0%

L 96.7% 3.3% 0.0%

M 96.3% 2.3% 1.3%

N 99.0% 0.7% 0.3%

P 94.3% 3.4% 2.3%

* Note: FNS review did not examine whether categorical applications were appropriate.

Source: Review conducted by FNS RO staff (2002)

Verification decision resulted in benefit level that was:

* Note: For a total of 87 income & household size applications, the FNS reviewer could not obtain complete 

 -- percent of applications verified --

documentation and thus could not assess the accuracy verification process.

22
23

shows that, on average, 91.6 percent of verification decisions were appropriate and that 

8.4 percent of verification decisions were inappropriate. 22 On average, where SFAs 

made verification determination errors, the errors were much more likely to result in an 

inappropriately high level of benefits for households, rather than an inappropriately low 

one, by a ratio of 6.7 percent to 1.7 percent. There was wide variation in the accuracy of 

SFA verification determinations across the 14 SFAs. Four SFAs had a verification 

determination accuracy rate that exceeded 98 percent. One SFA had a verification 

determination accuracy rate of 69.7 percent; in this SFA the bulk of inaccurate 

determinations were a result of the SFA not completing the verification process. On 

average, focused sampling SFAs had a higher verification accuracy rate (96.4 percent) 

than random sampling SFAs (89.4 percent). 

5.5 Reapplication patterns and SFA accuracy 

Households whose free or reduced price meal benefits are terminated during the 

verification process may reapply for meal benefits during the same school year. FNS 

regulations require that such reapplications must be accompanied by documentation of 

household income and size or of current FS/TANF/FDPIR receipt.23 Table 8 and Figure 

8 show that, on average, 28.9 percent of households that had benefits reduced or 

terminated in the verification process across the 13 SFAs where reviewers were able to 

gather this type of information reapplied for free or reduced price meal benefits during 

the remainder of the school year. The reapplication rate was higher in random sampling 

districts (37.7 percent) than in focused sampling districts (9.3 percent). 

Table 8 provides information about the SFA decision regarding reapplicants’ free and 

reduced price eligibility on the basis of their reapplication materials. FNS reviewers 

determined that 69.4 percent of reapplications were approved for free meals and 23.5 

percent of reapplications were approved for reduced price meals. In 7.1 percent of 

reapplications, SFAs determined that households were not eligible for free or reduced 

price meal benefits on the basis of information submitted.24 

Table 8 shows that a greater percentage of reapplications were approved for free or 

reduced price meal benefits in random sampling districts (95.5 percent) than in focused 

sampling districts (87.0 percent). 

Further, with regard to reapplications, the accuracy of 256 SFA determinations was 

reviewed. We found that in 95 percent (or 242 cases) of reapplications SFAs made an 

accurate determination on the basis of information provided by households while in 5 

percent (or 14 cases) of reapplications SFAs made an inaccurate decision. Because of 

small sample sizes, we do not present district-level results of reapplication determination 

accuracy. 

 

22 For purposes herein, all applications selected for verification where the SFA did not complete the 

verification process are classified as inappropriate decisions. 23 In one study SFA, FNS did not review whether any households whose benefits had been reduced or 

terminated in the verification process had submitted a new application later in the 2002-03 school year. 

This district is excluded from the multi-SFA averages for all computations shown in this table. 24 In 15.5 percent of cases where FNS determined that households reapplied, FNS reviewers were not able 

to determine the decision made by the SFA. These cases are excluded from this analysis. 
Table 8. Reapplication among households w/ benefits reduced or terminated

Yes No F RP Paid

14 SFA Average 28.9% 71.1% 69.4% 23.5% 7.1%6 Random SFA Total 37.7% 62.3% 69.5% 26.0% 4.5%8 Focused SFA Total 9.3% 90.7% 69.1% 17.9% 13.0%Random Sampling Districts

A n.a. n.a. n.a. n.a. n.a.B 26.4% 73.6% 67.6% 21.6% 10.8%

C 53.8% 46.2% 76.5% 23.5% 0.0%D 34.9% 65.1% 0.0% 100.0% 0.0%

E 3.6% 96.4% 100.0% 0.0% 0.0%

F 75.0% 25.0% 77.8% 22.2% 0.0%

Focused Sampling Districts

H 14.4% 85.6% 30.0% 40.0% 30.0%

I 7.7% 92.3% 33.3% 66.7% 0.0%

J 14.3% 85.7% 70.0% 23.3% 6.7%

K 15.5% 84.5% 85.7% 14.3% 0.0%

L 5.2% 94.8% 75.0% 16.7% 8.3%

M 3.2% 96.8% 60.0% 0.0% 40.0%

N 12.2% 87.8% 92.9% 7.1% 0.0%

P 2.0% 98.0% 100.0% 0.0% 0.0%

* Note: FNS review did not examine whether categorical applications were appropriate.

Source: Review conducted by FNS RO staff (2002)

Reapplied, excluding 

cases FNS was not able 

to review?

Among households that 

reapplied, the determination by 

SFA was:

24
Correct Incorrect

Incorrect 

verification 

decision

Did not make 

necessary change to 

meal ticket status, 

but verification 

decision correct Too high T

14 SFA Total 82.6% 17.4% 57.5% 42.5% 78.6% 2

6 Random SFA Total 77.9% 22.1% 58.6% 41.4% 78.8% 28 Focused SFA Total 93.1% 6.9% 55.0% 45.0% 78.1% 2

Random Sampling Districts

A n.a. n.a. n.a. n.a. n.a. B 79.0% 21.0% 51.8% 48.2% 82.1% 1

C 96.7% 3.3% 50.0% 50.0% 90.0% 1D 93.7% 6.3% 44.4% 55.6% 66.7% 3

E 39.0% 61.0% 59.7% 40.3% 98.6% 

F 89.1% 10.9% 78.3% 21.7% 60.9% 3

Focused Sampling Districts

H 90.3% 9.7% 100.0% 0.0% 33.3% 6

I 98.6% 1.4% 100.0% 0.0% 100.0% 

J 91.5% 8.5% 70.4% 29.6% 51.9% 4

K 98.9% 1.1% 50.0% 50.0% 100.0% 

L 91.4% 8.6% 33.3% 66.7% 100.0% 

M 94.2% 5.8% 58.8% 41.2% 76.5% 2

N 94.8% 5.2% 20.0% 80.0% 93.3% 

P 90.4% 9.6% 57.1% 42.9% 71.4% 2

Source: Review conducted by FNS RO staff (2002).Table 9. Accuracy of end of year meal ticket status

End of year status 

Among those that were not correct, 

why?

Among those that w

correct, was end of y

ticket status too high o

25
26

5.6 Accuracy of end of year meal ticket status 

FNS reviewers sought to examine the end of year meal ticket status of applications 

studied in this project that remained enrolled in the SFA thru the end of the 2001-02 

school year. There were 828 out of 3,470 salient cases where end of year status 

information was not available at the time of data collection.25 

The meal ticket status represents the level of benefits (i.e., free, reduced price or paid) 

that is recorded in the SFA’s counting and claiming system for children that obtained a 

school lunch. Table 9 and Figure 9 show that the average rate of accuracy26 of end of 

year meal ticket status among cases reviewed by FNS was 82.6 percent. Or, the meal 

ticket status of 17.4 percent of applications selected for verification was reviewed by FNS 

was incorrect. 

The meal ticket status accuracy in three of 13 districts studied was over 96 percent 

correct, seven others had accuracy rates ranging from 90 to 96 percent, while the 

remaining three SFAs had accuracy rates of 89.1 percent, 79.0 percent and 39.0 percent. 

Table 9 decomposes cases that had inaccurate meal ticket status at the end of the school 

year. In 57.5 percent of these cases, the reason for incorrect meal ticket status was that 

the verification determination was incorrect compared to the documentation provided by 

the household. 

In 42.5 percent of cases with inaccurate meal ticket status, the reason was that the SFA 

had not made the appropriate change in the meal ticket status required as a result of the 

verification process.27 

Table 9 also addresses the question: Among those students with incorrect meal ticket 

status, was the actual meal ticket status too high or too low? On average, 78.6 percent of 

cases with incorrect meal ticket status had benefit levels that were too high, while the 

remainder, or 21.4 percent had meal ticket status that was too low (reduced price but 

should have been free). In 12 of 13 SFAs studied, FNS found that it was more frequent 

that children were approved for a level of benefits higher than the level consistent with 

their application / verification file than vice versa.

 

25 FNS reviewers were not able to examine the end of year meal ticket status for an average of 23.7 percent 

of verified applications reviewed in 14 SFAs. In one SFA, FNS reviewers did not examine the meal ticket 

status of any applications included in this study. In the remainder of study SFAs, we examined the meal 

ticket status of most, but not all applications reviewed in this study. 

26 Accuracy is defined as consistency between all application and verification materials and related SFA 

determinations in a household’s file and the meal ticket status found for children in that household by FNS 

reviewers as of the last day of the 2001-02 school year. When a child was classified as free or reduced 

price at the end of the school year, but either the verification process a) was begun but not completed by the 

SFA; or b) initially resulted in a benefit reduction / termination by the SFA with no further action after the 

verification process was completed, the meal ticket status of these students is also considered inaccurate. 27 Excluded from this definition of incorrect meal ticket status are those where reapplication following 

verification resulted in a new determination (See Table 8). 
27

Figure 8. Reapplication Patterns Among NonRespondents

Reapplied

28.9%

Did Not 

Reapply

71.1%

Free

70.5%

RP

22.4%

Paid

7.1%

Figure 9. Accuracy of the End of Year Meal Ticket 

Status of Applications Selected for Verification

Correct

82.6%

Incorrect 

Verification 

Determination

10.0%

Verification 

Correct, Other 

Error

7.4%
28

Section 6 

CONCLUSIONS 

In this study we found 55 percent of applications verified across 14 study districts in 

2001-02 had their free and reduced price meal benefits reduced or terminated due to the 

verification process. Non-response to the verification process accounted for over 70 

percent of these benefit reductions or terminations. Among non-respondents that 

remained enrolled, we found that 29 percent were approved for free or reduced price 

meal benefits later in the school year on the basis of a new application with 

documentation of their household circumstances. 

This study analyzed the accuracy of SFA decisions in the administration of the free and 

reduced price eligibility determination process and found a significant level of 

inaccuracy. That is, on the basis of information provided by households to the SFA, we 

found 

• 5.7 percent of approved income applications had inaccurate initial determinations 

• 8.4 percent of verified applications had inaccurate determinations by SFAs

• 17.4 percent of verified applications had inaccurate end of year meal ticket status 

• 5.0 percent of reapplications had inaccurate determinations by SFAs 

At least three-quarters of all errors resulted in households being approved for a greater 

level of benefit than was consistent with the information they had provided the SFA. 

Based on this analysis, FNS believes that it is important to develop strategies that will 

facilitate increased accuracy at the local level to administer FNS eligibility determination 

procedures. 
29

REFERENCES 

General Accounting Office. “Analysis of Department of Agriculture Report on Fraud and 

Abuse in Child Nutrition Programs”. (Report Number CED-81-81) Washington, 

DC: GAO: 1981. 

US Department of Agriculture, Economic Research Service. “A Study of Direct 

Certification in the National School Lunch Program.” Washington, DC: USDA: 

forthcoming. 

US Department of Agriculture, Food and Nutrition Service. “Evaluation of the NSLP 

Application / Verification Pilot Projects.” Alexandria, VA: USDA: forthcoming. 

US Department of Agriculture, Food and Nutrition Service. “NSLP Application / 

Verification Pilot Projects: Report on First Year Experience.” Alexandria, VA: 

USDA: August 2002. 

US Department of Agriculture, Food and Nutrition Service. “Eligibility Guidance for 

School Meals Manual.” Alexandria, VA: USDA: 2001. 

US Department of Agriculture, Food and Nutrition Service. “A Study of Income 

Verification in the National School Lunch Program.” Alexandria, VA: USDA: 

1990. 
30

Appendix A: 

FNS Regional Office NSLP Verification Survey 

Information Collection Protocol – Complete one copy of this form for this SFA 

__________________ SFA1 Name of SFA visited

__________________ SFA2 Does SFA have Food Service Mgmt Co (1 = Yes 0 = No) 

___________________ SFA3 FNS Reviewer(s) 

___________________ SFA4 Date of data collection visit to SFA 

___________________ SFA5 Title of individual responsible for conducting verification process 

___________________ SFA6 Is SFA’s application – 

1 = individual child 2 = multi-child 

As of October 31, 2001: 

________________ A. SFA enrollment 

________________ B. Free approved children 

________________ C. Free approved thru direct certification 

________________ D. Free approved applications 

________________ E. Number of these applications approved for Free meal benefits on basis of 

FS/TANF case number

________________ F. Number of these applications approved for Free meal benefits on basis of 

income & hh size

________________ G. Reduced price approved 

________________ H. Date on which the SFA selected its verification sample 

________________ I. Number of applications selected for verification 

 

Describe process of verification sample selection and include whether the SFA states that they used a random 

approach, a focused approach, or some combination of approach(es): 

________________________________________________________________ 

________________________________________________________________ 

________________________________________________________________ 
31

INDIVIDUAL APPLICATION INFORMATION - Page 1 of 3 

Complete one form for each application verified at this SFA 

__________________________ School district 

_______ # of verification at this district ____________________ Name on Application 

SECTION 1 – Application approval process 

___________ S1 1 Number of children whose F/RP eligibility is associated with this application 

___________ S1 2 Initial status of application 

 1 = Free w/ Food Stamp or TANF case # (skip to Section 2) 

 2 = Free w/ Household Income and household size 

 3 = Reduced-Price 

Table A - If application was initially approved on basis of hh income & size, complete table. 

1st name of individuals w/ 

income- exclude last name 

Last month’s income and how often it was received 

Earnings from work 

before deductions 

Welfare, child support, 

alimony 

Pensions, retirement, 

Social Security 

Other 

$/time period $/time period_____ $/time period_____ $______/________ 

 $____/_________ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

___________ S1 3 Total amount of monthly income reflected on application 

___________ S1 4 Total amount of monthly income determined by approving official 

___________ S1 5 Number of household members listed on application 

___________ S1 6 Based on this information, for what level of benefits should this application have been 

approved in school year 2001-02? 

 1 = Free 2 = Reduced price 3 = Paid 

___________ S1 7 Date school notified household of verification selection 

___________ S1 8 Did household respond to school by deadline provided by school? 

 1 = Yes 0 = No (skip to Section 3) 

___________ S1 9 Did hh response provide household size & income or FS/TANF #? 

 1 = Household size and income 2 = FS/TANF case number

__________ S1 10 Date of latest check stub / other documentation / FS/TANF receipt that is documented? 

(If documents were submitted with more than one date, write down latest of these 

dates. For check stub, write down the date the check was issued.) Skip to Section 3 
32

INDIVIDUAL APPLICATION INFORMATION - Page 2 of 3 

SECTION 2: Complete this section ONLY for applications where the initial basis of free approval 

was FS/TANF case number provided by household 

___________ S2 1 Did school seek - 

 1 = Verification from FS/TANF office 

 2 = Verification from household (Skip to S2 3) 

___________ S2 2 If FS/TANF verification sought, did FS/TANF office confirm current FS/TANF receipt? 

1 = Yes (Skip to Section 3) 0 = No 

___________ S2 3 If school notified household, on what date? 

___________ S2 4 Did household provide documentation of current eligibility by deadline provided by 

school district? 

 1 = Income & hh size 2 = FS /TANF receipt 3 = No (Skip to Section 3) 

__________ S2 5 Date of latest check stub / other documentation / FS/TANF receipt that is documented? (If 

documents were submitted with more than one date, write down the latest of these dates. 

For a check stub, write down the date the check was issued.)

SECTION 3: Complete this section for all applications verified:

___________ S3 1 Status immediately after verification process: 

 1 = Free 2 = Reduced-Price 3 = Paid 

 4 = process not completed by SFA (data collection complete for this application) 

Table B. If verification was income-based, complete Table B based on documentation provided by hh: 

1st name of individuals w/ 

income- exclude last name 

Last month’s income and how often it was received 

Earnings from work 

before deductions 

Welfare, child support, 

alimony 

Pensions, retirement, 

Social Security 

Other 

$/time period $/time period_____ $/time period_____ $______/________ 

 $____/_________ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

 $______/_______ $______/_______ $______/_________ $______/_______ 

___________ S3 2 Total amount of monthly income reflected on verification submission 

___________ S3 3 Number of household members listed on verification submission 

___________ S3 4 Based on this information, for what level of benefits should this application have been 

approved following verification? 1 = Free 2 = Reduced price 3 = Paid 

_________ S3 5 Based upon reviewer’s assessment, did the school make the appropriate decision in 

verification? 1 = Yes (Skip to S3 8) 0 = No
33

INDIVIDUAL APPLICATION INFORMATION - Page 3 of 3 

__________ S3 6 If no, what should the decision have been based upon your review? 

 1 = Free 2 = Reduced-Price 3 = Paid 

___________ S3 7 Reviewer’s comments about the accuracy of the decision: 

________________________________________________________________ 

________________________________________________________________ 

__________ S3 8 What was the student’s eligibility status at end of school year? 

1 = Free 2 = Reduced-Price 3 = Paid 

4 = Can not determine based on information available (skip to Section 4) 

__________ S3 9 Upon what basis did reviewer determine end of 2001-02 eligibility status? 

 1 = Point of service roster 2 = Inspection of meal ticket 

__________ S3 10 Based upon reviewer’s assessment, is eligibility status appropriate? 

1 = Yes (Skip to Section 4) 0 = No 

__________ S3 11 If no, what should the status have been based upon your review? 

 1 = Free 2 = Reduced-Price 3 = Paid 

___________ S3 12 Reviewer’s comments about the accuracy of the decision: 

________________________________________________________________ 

________________________________________________________________ 

SECTION 4: RE-APPLICATION 

__________ S4 1 Did the household submit a F/RP application after having benefits changed because of 

verification in SY 01-02? 

 1 = yes 0 = no (data collection complete for this application) 

2 = cannot be determined (data collection complete for this application)

__________ S4 2 Status of re-application 

 1 = Free w/ Food Stamp or TANF case # 

 2 = Free w/ Household Income and household size 

3 = Reduced-Price 

_________ S4 3 Did household provide documentation of income or FS/TANF eligibility in their 

reapplication? 1 = Yes 0 = No

_________ S4 4 Based upon reviewer’s assessment, did the school make the appropriate decision in 

reviewing this re-application? 1 = Yes (data collection complete for this application) 0 = No

__________ S4 5 If no, what should the decision have been based upon your review? 

 1 = Free 2 = Reduced-Price 3 = Paid 

___________ S4 6 Reviewer’s comments about the accuracy of the decision: 

________________________________________________________________ 

(data collection complete for this application)
34

Appendix B: 

Findings from data collection regarding the verification process in one Midwest Region SFA 

Executive Summary 

FNS staff members visited 31 randomly selected schools in January 2002 to learn about how the SFA 

implements the income verification process. Key findings, based on a review of 344 verified 

applications include: 

Section 1: Verification sample characteristics 

• 66 percent of applications selected for verification were initially approved as categorically 

eligible whereas such applications represented only 36 percent of applications approved at 

these schools. This suggests that the SFA may be using a non-random process to select 

applications for verification tilted in the direction of categorically eligible applications. 

• 7 schools selected only categorically eligible applications in their verification sample even 

though categorically eligible applications represented between 29 and 75 percent of approved 

applications at these schools. 

Section 2: Reduction/termination rate

• 89.1 percent of applications verified had their benefit level unchanged while 10.5 percent of 

applications verified had their benefit level reduced or terminated. Benefits were increased for 

0.3 percent of applications verified. 

• The rate of benefit reduction / termination among categorically eligible applications (1 

percent) was much lower than that for income-based applications (28 percent). 

Section 3: Appropriateness of SFA verification decisions 

• 13 percent of verification decisions were inappropriate and in each case the decision resulted 

in a greater level of approval for F/RP meal benefit than FNS reviewers found appropriate 

according to FNS guidelines. 

Section 4: Reduction/termination rate based upon FNS review 

• Had SFA made appropriate decisions with regard to all applications selected for verification, 

23 percent of applications selected for verification would have had their benefits reduced or 

terminated. 

Section 5: Meal ticket status and verification findings 

• In 19 percent of cases (or 7 applications) where the verification process found a F/RP benefit 

reduction/termination was required, it appears no change was made. 
35

Appendix C. Supplementary Tabulations 

Table C.1 Distribution of verified income & hh size applications by whether the reported income was more than $100 lower than the threshold for focused 

sampling 

 

 Free approved applications Reduced price approved applications 

 

More than $100 less than 

focused sampling 

threshold 

Within $100 less than 

focused sampling 

threshold 

More than $100 less than 

focused sampling threshold 

Within $100 less than 

focused sampling threshold

 

14 SFA Total 72% 28% 73% 27% 

6 Random SFA Total 93% 7% 92% 8% 

8 Focused SFA Total 24% 76% 29% 71% 

Random sampling districts 

A 92% 8% 91% 9% 

B 91% 9% 93% 7% 

C 96% 4% 97% 3% 

D 96% 4% 92% 8% 

E 91% 9% 100% 0% 

F 96% 4% 86% 14% 

 

Focused Sampling Districts 

H 19% 81% 24% 76% 

I 13% 87% 9% 91% 

J 14% 86% 17% 83% 

K 28% 72% 22% 78% 

L 35% 65% 57% 43% 

M 24% 76% 19% 81% 

N 24% 76% 24% 76% 

P 32% 68% 11% 89% 

 

Source: Review conducted by FNS RO Staff (2002).