Academy Comments to USDA re Evaluation of the Direct Certification with Medicaid for Free and Reduced-Priced Meals Demonstration

August 23, 2017

Desk Officer for Agriculture
Office of Information and Regulatory Affairs
Office of Management and Budget (OMB)
Departmental Clearance Office, USDA
OCIO, Mail Stop 7602
Washington, DC 20250-7602

Re: Evaluation of the Direct Certification with Medicaid for Free and Reduced-Priced (DCM-F/RP) Meals Demonstration (OMB Control Number 0584-New)

Dear Sir or Madam,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments related to the proposed collection from the Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA), "Evaluation of the Direct Certification with Medicaid for Free and Reduced-Priced (DCM-F/RP) Meals Demonstration," published in the Federal Register on July 24, 2017. Representing over 100,000 registered dietitian nutritionists (RDNs),a nutrition dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition to meet the health needs of all citizens, including millions of students in schools nationwide.

The Academy supports the USDA's ongoing efforts to test the effectiveness of direct certification using income data available in Medicaid administrative records to determine eligibility for reduced-price school meals. By collecting, aggregating, processing, validating, evaluating, and reporting data, schools, local educational agencies (LEAs), state agencies, and the USDA can work together to protect the public fisc while ensuring all children — regardless of their family's income — have access to nutritious school meals.

Direct certification using Medicaid records will reduce administrative and financial burdens on School Food Authorities (SFAs), and will enable them to focus their attention on their number one goal — feeding as many children healthy breakfasts and lunches as possible to ensure they get the nutrition they need. The overall responsibility of taking free/reduced applications and determining eligibility is a tremendous burden on SFAs, and any way FNS can lift some of the burden is a project worth pursuing. We are particularly concerned with the burden of verification on smaller districts, those with various student populations, and those with various staff sizes and we encourage FNS to ensure it appropriately samples them to ascertain an accurate measure of the burden imposed.

Academy members with significant experience completing verification cycles report that the process locating parents and their financial records can be difficult, very labor intensive, and needs greater evaluation and study. We would be grateful for the opportunity to open a dialogue to improve the process and reduce the burden. Students who are eligible do not always get benefits because their parents do not fill out a paper application for various reasons, including language barriers, students not bringing home the application, students being embarrassed to turn in application, and parents forgetting to complete application. Additional issues regarding the burden of verification include the amount of time required to complete the verification, the timing of studies (e.g., coinciding with particularly busy times at the beginning of a school year or summer program), and the nature of the previously uncollected data sought remain significant concerns.

The Academy supports balancing time for ensuring accountability (e.g., data gathering, aggregation, and submission) and time for state agencies to provide technical assistance to LEAs with the time required for local personnel to produce nutritious school meals that children look forward to eating. If some of the SFA's students could be directly certified for reduced-price meals based on income gathered through another agency such as Medicaid, it would go a long way to reduce the number of paper applications that might be prone to errors or would have to be verified. The Academy does not have any negative concerns about this proposed collection. We expect the data collected will show direct certification will reduce paperwork, increase participation, and decrease errors in qualifying individuals for reduced-price school meals.

The Academy appreciates the opportunity to comment on the proposed data collection. Please contact either Jeanne Blankenship at 312/899-1730 or by email at or Pepin Tuma at 202/775-8277, ext. 6001 or by email at with any questions or requests for additional information.


Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Senior Director
Government & Regulatory Affairs
Academy of Nutrition and Dietetics

a The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.