Here’s a copy of the formal comment we recently submitted on the federal register:
These comments are submitted in response to the Notice issued by Food and Nutrition Service on 1/13/20116, “Determining Eligibility for Free and Reduced Price Meals and Free Milk.”
As noted in the supplementary information provided, the collection of household size and income to determine eligibility for participation in the Child Nutrition Programs effects nearly 5.5 million respondents. Fortunately, since implementation of direct certification, the burden for School Meals Program agencies providing the National School Lunch, School Breakfast, and to a lesser extent the Child and Adult Care Food and Summer Food Service Programs has somewhat diminished the associated paperwork and staff hours. It has also diminished the hours required by state agencies in determining accuracy of individual applications submitted by households not directly certified.
However, in the Child and Adult Care Food and Summer Food Service Programs, the use of direct certification is only available to school food authorities. The majority of the agencies are required to collect individual household applications. The paperwork burden for households, local participating agencies as well as the state agencies involved in the collection of Income Eligibility Applications, certifying their completion and determining eligibility, as well as determining accuracy as part of administrative reviews and management evaluations, while necessary, also represents one of the predominant areas where errors are found.
Having experience with a state agency and working with a technology company, making the Income Eligibility Applications available electronically by allowing electronic signatures would lessen the paperwork burden experientially. We are part of a mobile society where parents would be able to complete the form electronically. Technology applications can ensure that all information fields are completed, compute eligibility, and be stored by participating agencies also improving the integrity of the programs. The number of staff hours also would be drop proportionally. At a minimum, the use of electronic signatures should be considered in the programs where area eligibility is not an option. We would welcome the opportunity to pilot this concept.