Child & Adult Care Food Program
Income Eligibility Forms can be error free
by Susan Petersen, Consultant, Nutrition Services
from the Spring 1997 issue of Child Caring; updated 2002
The most common errors resulting in overclaims can be easily avoided. Most of the errors which our staff encounter during compliance reviews are on Income Eligibility Forms (IEFs). The common mistakes that may cost your center money are 1) not having an IEF on file for a participant whose meals are claimed in the free or reduced price categories, 2) IEFs that are missing information, such as a food stamp or TANF case number, signatures of adult household members, monthly income by category, or social security numbers, 3) IEFs that have been determined in the wrong eligibility category or 4) IEFs that have been determined correctly, but the meals served to the participant were claimed in the wrong eligibility category and 5) the incorrect assumption that receiving Title XX benefits automatically qualifies a participant's meals to be claimed in the free category.
While all of those errors listed are important, the last one needs to be re-emphasized If your center has a Title XIX or XX authorization for a child or adult participant, this does NOT mean that the participant automatically qualifies for meals in the free category. You MUST obtain an Income Eligibility Form from the participant's household, ascertain that it is a complete application and make a determination of the participant's eligibility category based upon the information provided by the household.
If you do not have a current IEF on file for any participant, the meals served to that participant MUST be claimed in the Paid category until the time that an IEF is on file and is determined in the free or reduced price categories.
In recent years, Nutrition Services has instituted several practices to help centers ease the process of soliciting IEFs. The usage dates for IEFs are now consistent with the dates that Income Eligibility Guidelines are in effect: July 1 through June 30. The CACFP program year has also been changed to this time period.
New IEFs should be solicited from all households during June for the fiscal year beginning July 1. This eliminates the need to solicit new IEFs every month. Knowing that it often takes households several days to complete and return IEFs to the center, Nutrition Services allows centers to make the effective date of the IEF the first day of the month in which the IEF was determined by the center official. This effective date is dependent upon the date the participant was enrolled at the center. Center staff should make every effort to make eligibility determinations on IEFs as soon as households return them to the center.
Organizing and Filing IEFs
A simple filing system for Income Eligibility Forms will not only help your compliance review or audit go smoothly, but should also make things easier for you as well.
Nutrition Services recommends that IEFs not be filed in participant's individual folders. As a center owner or director, you know that there is much confidential information contained in these files, and neither our staff nor the auditors have authority to view any confidential information other than what relates to the CACFP.
Instead, we encourage you to use either file folders or a loose-leaf binder for your IEFs. The first folder or section in your binder should include IEFS determined Free; the second folder or section should include IEFs determined Reduced; and the third folder should include IEFs determined Paid. A fourth folder or section could be labeled as either "Inactive" or "Terminated" if you chose to keep these IEFs separate from those for currently enrolled participants. We also suggest (not required) that your filing system also include a current roster of names of participants and their eligibility category. This will assist you in assuring that you have current IEFs on file and that meals are being claimed appropriately. Check the codes for each participant on the Record of Meals and Supplements Served (meal count sheets) with this roster each month to assure that meals are claimed in the correct eligibility category.
Within each folder, you may chose to alphabetize the IEFs, although this is not required. If a household submits a new IEF during the year due to a change in household size or income, staple the most recent IEF on top of the previous IEF completed by the household. This chronological filing procedure will aid either our staff or auditors in determining on which date a participant's eligibility code may have changed from one category to another. This will also aid you in claiming meals in the correct eligibility category.
This set of folders or binder should only include IEFs for the current fiscal year. Once you have solicited new IEFS for July of each year, you can file the old forms elsewhere, clearley labeling them for storage with the appropriate fiscal year.
What is a complete application?
Eligibility determination on an application can only be made if you have a complete application. What determines if an application is complete?
According to the USDA's Eligibility Guidance for School Meals Manual , the following information is required for categorical eligibility for Food Stamp, TANF and FDPIR households:
name of participant
the appropriate Food Stamp, TANF or FDPIR number (or Medicaid or SSI number for adult care program participants)
signature of an adult household member
For households not receiving Food Stamp, TANF, FDPIR, the following items must be included on an IEF:
names of all household members including the name of the participant for whom application is made
the social security number of the adult who signs the application or an indication that the household member does not have a social security number
the current amount of income received by each household member identified by the individual who receives it, and the source of the income, such as wages, welfare, alimony, etc. and
signature of an adult household member
For foster children, IEFs must include
the name of the child
the child's personal use income, if any
signature of an adult household member
Other information requested on the form is optional, such as the race/ethnic identity. Addresses, telephone numbers, etc. are generally used for identification purposes for pricing institutions or the determination of residency status in adult care centers. Adult centers are required to have on file the ages of all participants, and there is a place for the age to be listed.
In some instances, we have found centers that had on file copies of "Direct Certification" letters for eligibility to receive free meals in the National School Lunch Program. At this time, USDA has not allowed this direct certification procedure to be used in the CACFP other than in programs sponsored by local education agencies.
What are the "Red Flags"?
During compliance reviews and audits, there are certain indications on IEFs that will set off a "red flag" and create suspicion for a reviewer. Among these red flags would be if certain information is crossed out, or "whited-out" or dates are scribbled over. A center official should not alter ANY of the information that is provided by the household. The determination by the center official must be made based upon the information that is submitted on the IEF.
It is, however, acceptable for center officials to obtain additional information on IEFs for clarification purposes. For example, an income may be listed as an hourly wage, rather than monthly. You might call the household and determine the monthly income over the telephone. In this case, you could write the information on the IEF and make the notation "as per telephone call from Ms. Smith." Then date and initial the notation.