|DATE:||March 9, 2016|
|POLICY MEMO:||SP 29-2016|
|SUBJECT:||Reporting Instructions for Form FNS-874 “Local Educational Agency Second Review of Applications” (formerly FNS-742a)|
Special Nutrition Programs
Child Nutrition Programs
Section 304 of the Healthy, Hunger-Free Kids Act of 2010 requires local educational agencies (LEAs) that demonstrate high levels of, or a high risk for administrative error associated with certification, verification and other administrative processes to conduct an independent review of the initial eligibility determinations for free and reduced price school meal applications for accuracy prior to notifying households of eligibility. The final rule Independent Review of Applications Required by the Healthy, Hunger-Free Kids Act of 2010, published in the Federal Register on Feb. 6, 2014, established in 7 CFR 210 and 245 the requirements related to the second review of applications process, which became effective in school year (SY) 2014-15. This memorandum provides important guidance concerning the state agency's report on the results of the second review of applications, which is required in 7 CFR 245.11.
For SY 2014-15, the state agencies reported the results of the second review of applications to the Food and Nutrition Service (FNS) via email on the form FNS-742a “Local Educational Agency Second Review of Applications.” For SY 2015-16, there are a number of changes and state agencies must submit the reports as specified in this memorandum.
Reporting instructions for submitting SY 2015-16 results:
- The “Local Educational Agency Second Review of Applications” form has been renumbered to FNS-874. Form number FNS-742a is now obsolete.
- FNS-874 must be submitted via the Food Program Reporting System (FPRS) for SY 2015-16 (FY 2016) and for all subsequent years.
- FPRS reporting rights have been transferred from the FNS-742 for all users. State agency and FNS regional office staff who have permission to access the FNS-742 in FPRS as of December 2015 have the same level of permission (enter, validate, certify, or post data) for the FNS-874. See Attachment A for more information.
- A reporting template is available in FPRS for uploading the data. The format and data elements have not changed from the SY 2014-15 template with the exception of some columns that are now system-calculated in FPRS (see Attachment A).
- Reporting due dates have not changed. Annual reports are due from all state agencies (certified in FPRS) on or before March 15th. FNS regional offices are responsible for reviewing and posting the reports on or before March 30th.
If state agencies experience delays in gaining access to the FNS-874 in FPRS, a provisional 15-day extension of the due dates is authorized for FY 2016 reporting only. All other reports are expected to be submitted by the due date. State agencies should notify their respective FNS regional offices of FPRS access issues and contact the FPRS Help Desk if necessary. Regional offices should notify the national office of any issues via email to: firstname.lastname@example.org with “[State] FNS-874” as the subject line.
State agencies are reminded of the criteria for the selection of LEAs to be included on the FNS-874 as follows:
Criteria 1: All LEAs with 10 percent or more of certification/benefit issuances in error, as determined by the state agency during an administrative review; and
Criteria 2: LEAs that the state agency considers at risk for certification error but not selected under Criterion 1. State agencies have the discretion to determine what risk factors are necessary to be selected under Criteria 2 however state agencies are strongly encouraged to include those LEAs that are found to have certification/benefit issuances in error between 5-10 percent as determined during an administrative review. State agencies should also consider selecting LEAs that: 1) are new to the National School Lunch and School Breakfast Programs; 2) have recently hired new administrative staff; and 3) implemented a new electronic system.
All state agencies must submit an FNS-874. FNS anticipates that every state will have some LEAs that either demonstrate high levels of, or are at risk for administrative error. These LEAs should be identified by the state agency and selected to conduct a second review of applications.
If after conducting an assessment using Criteria 1 and 2, a state agency has not identified any LEA at a high level of, or at risk of administrative error, the state agency may contact their respective FNS regional office to determine if additional criteria under Criteria 2 should be considered. If still no LEAs meet the criteria, the state agency should submit the FNS-874 in FPRS by entering zero (0) in the SFA/LEA ID column; “None” in the SFA/LEA Name column; the applicable School Years; and zeros (0) in data columns 1-1 through 1-5.
LEAs are reminded that this report is designed to capture the activity of the second review of initial eligibility determinations. That is, if an initial eligibility determination error is recognized on a selected application then the LEAs should report where the error originated (such as in category: A. Determined Free) and then record what action was taken and why to correct the error (such as: 2. Changed to Reduced Price, because of: a. Incomplete application error). All results from the second review activity should be reported on the FNS-874.
Previous guidance regarding this report is available in SP 44-2014 Questions and Answers Related to the Independent Review of Applications, issued April 30, 2014; and SP 62-2014 Release of the new Local Educational Agency Second Review of Applications Report, issued Sept. 8, 2014.
State agencies with questions should contact the appropriate FNS regional office.
Sarah E. Smith-Holmes
Program Monitoring and Operational Support Division
Child Nutrition Programs