The objective of direct certification is to give access to free meals quickly and easily to eligible students without a need for the household to submit an application and for the SFA to process that application. Direct certification is most effective when it happens soon after a household attains SNAP eligibility. If there is a delay in the household obtaining free meal benefits, the household would have to submit an application with their categorical eligibility information, thereby defeating the purpose of direct certification.
Direct Certification is typically performed by the SFA running a match of a categorical eligibility file against their student database. The direct certification files may contain data for various types of categorical eligibility such as SNAP, TANF, FDPIR, Homeless, Migrant, Runaway and more recently, Foster, Medicaid, etc. Direct Certification performance has historically been low for various reasons but primarily because not enough attention was paid to it. Once USDA started to focus on the task of improving direct certification rates, there has been a steady and noticeable improvement in that area over the last several years. USDA’s focus has primarily been on direct certification of SNAP eligible students and most of the discussion that follows is related to SNAP direct certification.
Source: USDA’s Report to Congress on Direct Certification in the National School Lunch Program: State Implementation Progress, School Year 2012–2013

Changes to Direct Certification

The 2010 Child Nutrition Reauthorization, more commonly known as the Healthy Hunger-Free Kids Act (HHFKA), mandated significant changes to Direct Certification. Congress viewed direct certification as a critical tool to improve access, increase accuracy, and reduce paperwork in school nutrition programs. Let us take a look at some of the key changes.

Elimination of Letter Method

Letter method of direct certification is no longer valid. This method, where school districts would require a letter from the SNAP agency to certify the student as free, was antiquated. I doubt if more than a state or two were using this method even in 2010 and I believe no state is using the method currently. More information on the elimination of the letter method of direct certification can be found in the USDA memo SP 13-2011, Letter Method for Direct Certification.

Direct Certification Frequency

HHFKA also required that direct certification be performed at least 3 times a year – at the beginning of the school year, 3 months after the initial effort and 6 months after the initial effort. In the past, many states performed direct certification only once a year. A large portion of the SNAP eligible students may become directly certified during the first round of direct certification but waiting three months before attempting it again leaves too many students having to submit applications or forego benefits. It is good to see that many of the states are now performing direct certification every month which is a significant step in the right direction. With the level of automation currently available, it is not a far-fetched idea for states and districts to perform direct certification on a daily basis.
More information on this topic can be found in the USDA memo SP31-2011, Frequency of Direct Certification Matching Activities Beginning in SY 2011-2012.

Performance Benchmarks and Continuous Improvement Plan

The performance benchmarks set by HHFKA get quite stringent especially for 2013-14 and beyond. As you can see from the above table, the national average easily beat the benchmark in 2011-12 even though some states did not reach the benchmark level. In 2012-13, the national average fell slightly short of benchmark. You will also notice that overall improvement shows a significant slowdown – only 3 percentage point increase in 2012-13 compared to a 9 percentage point improvement in the previous year. Most of early increases came from just taking advantage of the low hanging fruit. It is much harder to improve from current levels to reach the benchmark 95% level.
Continuous improvement plans will be required from states that do not meet the benchmark. I could be wrong but my assumption is that State agencies find these continuous improvement plans very tedious and time consuming as do school districts with regards to corrective action plans.
More information on this topic can be found in the USDA memo SP32-2011, Direct Certification Benchmarks and Continuous Improvement Plans.

Performance Awards

Over the last three years, DC performance awards provided an additional incentive for states to focus on direct certification performance improvement. An award of $2 million for Outstanding Performance and another award of $2 million for Substantial Improvement were being given out each year for 2011-12, 2012-13, and 2013-14. Each of these awards can be split between up to 15 winners. You had to apply to win a substantial improvement award. The outstanding performance awards did not need an application. Unfortunately, there is no indication of more awards in the future. Here is a look at the winners for the past two years.
More information on this topic can be found at SP33-2011, Direct Certification Performance Awards and Use of Funds

Where is your state?

Most states have improved their direct certification performance over the last several years and it is encouraging to see 16 states already above the 95% benchmark.
Source: USDA’s Report to Congress on Direct Certification in the National School Lunch Program: State Implementation Progress, School Year 2012–2013
However, changes made to the calculation method for SY 2013-14 in the FNS-742 Verification Report are likely to adversely impact performance in the next report for most states. I will discuss Direct Certification performance calculations and factors that impact performance in future blog posts.
What is your experience? Are you seeing benefits in your state or school district from these direct certification improvements? Tell us in the comments section below.