Frequency of Direct Certification Matching Activities Beginning in SY 2011-2012

The interim rule, Direct Certification and Certification of Homeless, Migrant and Runaway Children for Free School Meals, was published on April 25, 2011. One of the provisions in this rule concerns the frequency of direct certification matching activities with the Supplemental Nutrition Assistance Program (SNAP) and is effective July 1, 2011. The provision, found at 7 CFR 245.6(b)(3), requires that direct certification matching activities with SNAP be done at least three times per school year:

• At or around the beginning of the school year;
• Three months after the initial effort; and
• Six months after the initial effort.

As discussed in the preamble of the interim rule, the purpose of the additional matching activities is to facilitate participation of children in the school meals programs and to work towards on-going direct certification with SNAP through computer matching.

We recognize that this is a very short deadline and want to assure state agencies and local educational agencies (LEAs) that we know that increasing the frequency of direct certification matching activities may need to be phased-in for some locations. We expect those state agencies and LEAs unable to accomplish SNAP direct certification at least three times in School Year (SY) 2011-2012, to work toward this goal and comply with the requirement no later than SY 2012-2013. Appropriate actions for SY 2011-2012 include:

• Revising agreements between the Child Nutrition state agency and the SNAP state agency to increase the frequency of matches annually;
• Budgeting and using any appropriate grant funds and other resources, such as state Administrative Expense funds, to support needed changes. (Information about available grant opportunities to improve direct certification is located on the FNS Child Nutrition Division’s grant website at: http://www.fns.usda.gov/cnd/grants.htm. Also refer to Memorandum SP 27- 2011, Expansion of Opportunities for Additional States to Apply for Direct Certification Planning and Implementation Grants); and
• Requesting extensions of full compliance until SY 2012-2013, if needed

We are working with SNAP to facilitate compliance with the requirement for increasing the frequency of direct certification matching activities. SNAP will work with their state agencies to promote cooperation. State agencies should direct any questions concerning this guidance to the appropriate FNS regional office. Regional offices should contact the Child Nutrition Division.

Cindy Long
Director
Child Nutrition Division