Appendix 5 School Meals: USDA Could Improve Verification Process for Program Access (GAO-15-634T)

5. Sch Meals USDA Could Imp Verif Process for Prog Access GAO 15-634T.pdf

Study of Non-Response to the School Meals Application Verification Process

Appendix 5 School Meals: USDA Could Improve Verification Process for Program Access (GAO-15-634T)

OMB: 0584-0638

Document [pdf]
Download: pdf | pdf
Supporting Statement for OMB Clearance for the Study of Non-Response to the
School Meals Application Verification Process
Appendix 5
School Meals: USDA Could Improve Verification Process for Program Access
(GAO-15-634T)

United States Government Accountability Office

Testimony

Before the Subcommittee on Early
Childhood, Elementary, and Secondary
Education, Committee on Education and
the Workforce, House of Representatives
For Release on Delivery
Expected at 10:00 a.m. ET
Tuesday, May 19, 2015

SCHOOL MEALS
USDA Could Improve
Verification Process for
Program Access
Statement of Jessica Lucas-Judy, Acting Director,
Forensic Audits and Investigative Service

GAO-15-634T

May 19, 2015

SCHOOL MEALS
USDA Could Improve Verification Process for
Program Access
Highlights of GAO-15-634T, a testimony
before the Subcommittee on Early Childhood,
Elementary, and Secondary Education,
Committee on Education and the Workforce,
House of Representatives

Why GAO Did This Study

What GAO Found

In fiscal year 2014, 30.4 million
children participated in the National
School Lunch Program and 13.6
million children participated in the
School Breakfast Program, partly
funded by $15.1 billion from USDA. In
May 2014, GAO issued a report on (1)
steps taken to help identify and prevent
ineligible beneficiaries from receiving
benefits in school-meal programs and
(2) opportunities to strengthen USDA’s
oversight of the programs.

In May 2014, GAO reported that the U.S. Department of Agriculture (USDA) had
taken several steps to implement or enhance controls to identify and prevent
ineligible beneficiaries from receiving school-meals benefits. For example:

This testimony summarizes GAO’s
May 2014 report (GAO-14-262) and
January 2015 updates from USDA. For
the May 2014 report, GAO reviewed
federal school-meals program policies,
interviewed program officials, and
randomly selected a nongeneralizable
sample that included 25 approved
applications from civilian federalemployee households out of 7.7 million
total approved applications in 25 of
1,520 school districts in the Dallas,
Texas, and Washington, D.C., regions.
GAO performed limited eligibility
testing using civilian federal-employee
payroll data from 2010 through 2013
due to the unavailability of other data
sources containing nonfederalemployee income. GAO also
conducted interviews with households.
GAO referred potentially ineligible
households to the USDA Inspector
General.
In its 2014 report, GAO recommended
that USDA explore (1) using computer
matching to identify households with
income that exceeds program-eligibility
thresholds for verification, and (2)
verifying a sample of categorically
eligible households. USDA generally
agreed with the recommendations and
is taking actions to address them.

•

•

USDA worked with Congress to develop legislation to automatically enroll
students who receive Supplemental Nutritional Assistance Program benefits
for free school meals; this program has a more-detailed certification process
than the school-meals program.
Starting in the 2013–2014 school year, USDA increased the frequency with
which state agencies complete administrative reviews of school districts from
every 5 years to every 3 years. As part of this process, state agencies review
applications to determine whether eligibility determinations were correctly
made.

In its May 2014 report, GAO identified opportunities to strengthen oversight of the
school-meals programs while ensuring legitimate access, such as the following:
•

•

If feasible, computer matching income data from external sources with
participant information could help identify households whose income exceeds
eligibility thresholds. As of May 2014, school districts verified a sample of
approved applications deemed “error-prone”—statutorily defined as those
with reported income within $1,200 of the annual eligibility guidelines—to
determine whether the household is receiving the correct level of benefits
(referred to as standard verification in this testimony). In a nongeneralizable
review of 25 approved applications from civilian federal households, GAO
found that 9 of 19 households that self-reported household income and size
information were ineligible and only 2 could have been subject to standard
verification.
Verifying a sample of categorically eligible applications could help identify
ineligible households. GAO reported that school-meal applicants who
indicate categorical eligibility (that is, participating in certain public-assistance
programs or meeting an approved designation, such as foster children) were
eligible for free meals and were generally not subject to standard verification.
In a nongeneralizable review of 25 approved applications, 6 households
indicated categorical eligibility, but GAO found 2 were ineligible.

Results of GAO’s Analysis of a Nongeneralizable Sample of 25 Approved Household
Applications from the 2010–2011 School Year

View GAO-15-634T. For more information,
contact Jessica Lucas-Judy at (202) 512-6722
or [email protected].
United States Government Accountability Office

Letter

Letter

Chairman Rokita, Ranking Member Fudge, and Members of the
Subcommittee:
I am pleased to be here today to discuss the findings of our May 2014
report on oversight of federal school-meals programs.1 A well-balanced
and nutritional diet for school children is essential for their overall health
and well-being, and helps promote academic achievement. With children
spending a considerable amount of their day at school, meals served
during the school day play an important role in providing such a diet.
During fiscal year 2014, about 30.4 million children participated in the
National School Lunch Program and about 13.6 million participated in the
School Breakfast Program.2 Both of these programs are administered by
the U.S. Department of Agriculture’s (USDA) Food and Nutrition Service
(FNS) through state agencies that oversee local entities that provide
school meals. The federal government provides cash reimbursements for
each meal that meets nutritional requirements that is served at schools
that participate in the lunch and breakfast programs. In fiscal year 2014,
USDA spent about $15.1 billion on these programs.
Students who participate in these programs may qualify for free or
reduced-price meals depending on their household income and
household size.3 School districts determine individual student or
household eligibility for free or reduced-price meals by reviewing
applications submitted by households or through a process referred to as
“direct certification.” Under direct certification, state agencies provide
school districts with a list of students whose households receive certain
public-assistance benefits, such as through the Supplemental Nutrition
Assistance Program (SNAP), and school districts confer eligibility for free
school meals to these students. Thus, directly certified participants are
automatically certified for school-meals benefits without having to fill out a
separate school-meals application. Students receiving certain publicassistance benefits or meeting an approved designation, such as if they

1
GAO, School-Meals Programs: USDA Has Enhanced Controls, but Additional Verification
Could Help Ensure Legitimate Program Access, GAO-14-262 (Washington, D.C.: May 15,
2014).
2

This figure includes all 50 states, the District of Columbia, Guam, Puerto Rico, and the
Virgin Islands, as well as children of Department of Defense armed forces personnel
attending schools overseas.
3

Students may also pay full price for these meals.

Page 1

GAO-15-634T

are homeless or foster children, are categorically eligible for free-meal
benefits. School districts can certify categorically eligible students into the
school-meals program either through review of an application or through
direct certification.
The Office of Management and Budget (OMB) has designated the
National School Lunch Program as 1 of 13 federal “high-error” programs
due to its large estimated improper payments—approximately $1.7 billion
in fiscal year 2014.4 According to OMB guidance, an improper payment is
any payment that should not have been made; that was made in an
incorrect amount (including overpayments and underpayments) under
statutory, contractual, administrative, or other legally applicable
requirements; or for which insufficient or no documentation was found.5
My remarks today highlight the key findings of our May 2014 report on
oversight of school-meals programs. Specifically, like the report, this
testimony discusses (1) USDA’s steps taken to help identify and prevent
ineligible beneficiaries from receiving benefits in school-meal programs
and (2) opportunities to strengthen USDA’s oversight of the school-meals
programs. Because of limited salary and income data available for all
U.S. households, our case-study examples were limited to civilian
executive-branch employees and United States Postal Service (USPS)
employees.6
My statement is based on our May 2014 report with selected updates
from USDA related to the status of our recommendations. For our May
2014 report, we reviewed FNS policies and regulations and interviewed

4

High-error programs are those programs that reported roughly $750 million or more in
improper payments in a given year, did not report an error amount in the current reporting
year but previously reported an error amount over the threshold, or have not yet
established a program error rate and have measured components that were above the
threshold. USDA estimates that approximately $959 million of its fiscal year 2014 improper
payments represents certification errors and approximately $789 million represents
school-district counting and claiming errors. USDA estimates that the School Breakfast
Program had approximately $923 million in improper payments in fiscal year 2014. USDA
uses extrapolations from statistical models to develop estimates of improper payments for
school-meals programs.

5

Improper payment estimates reported by federal agencies are not intended to be an
estimate of fraud in federal agencies’ programs and activities.
6

Throughout this testimony, we use the term “federal employees” to refer to both civilian
executive-branch employees and USPS employees.

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GAO-15-634T

program officials. We also randomly selected a nongeneralizable sample
that included 25 applications from federal-employee households out of
the 7.7 million approved household applications from 25 of 1,520 school
districts in the Dallas, Texas, and Washington, D.C., regions—areas with
different federal-employee concentrations—in the 2010–2011 school
year.7 We performed limited eligibility testing using civilian federalemployee payroll data from 2010 through 2013 due to the unavailability of
other data sources containing nonfederal-employee income. We also
conducted interviews with the 25 households. Households we identified
as potentially ineligible were referred to the USDA Office of the Inspector
General for further examination.8 Further details on our scope and
methodology are included in the May 2014 report.9 For the selected
updates, in January 2015 USDA provided us information on the status of
its implementation of our recommendations. The work upon which this
statement is based was conducted in accordance with generally accepted

7

The Washington, D.C., and Dallas, Texas, metropolitan regions ranked 1st and 18th,
respectively, among the 50 metropolitan regions with the largest number of executivebranch federal employees during fiscal year 2012. The Washington, D.C., region includes
Washington, D.C.; Maryland; and Virginia. We initially obtained data from 28 school
districts for our review—14 located in the Dallas, Texas, metropolitan region and 14 in the
Washington, D.C., metropolitan region, which includes Washington, D.C., and its
Maryland and Virginia suburbs. In the Dallas, Texas, metropolitan region we selected
school districts with student enrollment over 10,000 students. We selected all school
districts in the Washington, D.C., metropolitan region excluding 56 charter school districts
in Washington, D.C. However, we did not use data from 3 school districts—1 located in
the Dallas, Texas, metropolitan region and 2 located in the Washington, D.C.,
metropolitan region—because the data were not reliable for our purposes. During the
2010–2011 school year, there were 57 school districts in Washington, D.C.; 49 in
Maryland; 1,260 in Texas; and 154 in Virginia for a total of 1,520. This selection is not
representative of all states, school districts, or school-meal participants. For our May 2014
report, we also selected 23 households that were directly certified in to the program in the
selected school districts. Of the 25 selected school districts, 2 did not have any directly
certified households that matched with federal-employee payroll data. Our analysis of the
23 directly certified households is not discussed in this testimony.
8
In addition, we referred the cases to the appropriate school district and state oversight
agency. As of May 2015, school districts had followed up on many of these referrals, while
some were still under review. For example, one school district conducted for-cause
verification of five households we referred as being potentially ineligible for school-meals
benefits. As a result of this verification, all five households were removed from the
program because they failed to respond to the verification request. Another school district
to which we referred potentially ineligible households told us that it removed two
households from the program after conducting verification.
9

GAO-14-262.

Page 3

GAO-15-634T

government auditing standards and standards prescribed by the Council
of the Inspectors General on Integrity and Efficiency.

Background

Within USDA, FNS has overall responsibility for overseeing the schoolmeals programs, which includes promulgating regulations to implement
authorizing legislation, setting nationwide eligibility criteria, and issuing
guidance. School-meals programs are administered at the state level by a
designated state agency that issues policy guidance and other
instructions to school districts providing the meals to ensure awareness of
federal and state requirements. School districts are responsible for
completing application, certification, and verification activities for the
school-meals programs, and for providing children with nutritionally
balanced meals each school day. The designated state agency conducts
periodic reviews of the school districts to determine whether the program
requirements are being met. Schools and households that participate in
free or reduced-price meal programs may be eligible for additional federal
and state benefits.
Depending on household income, children may be eligible for free or
reduced-price meals. Children from families with incomes at or below 130
percent of the federal poverty level are eligible for free meals; the income
threshold for a family of four was $28,665 in the 2010–2011 school year.
Those with incomes between 130 percent and 185 percent of the federal
poverty level are eligible for reduced-price meals. Income is any money
received on a recurring basis—including, but not limited to, gross
earnings from work, welfare, child support, alimony, retirement, and
disability benefits—unless specifically excluded by statute.10
In addition, students who are in households receiving benefits under
certain public-assistance programs—specifically, SNAP, Temporary
Assistance for Needy Families (TANF), or Food Distribution Program on
Indian Reservations (FDPIR)—or meet certain approved designations
(such as students who are designated as homeless, runaway, or migrant;

10
Income not to be counted in the determination of a household’s eligibility includes, but is
not limited to, the value of benefits under SNAP or Food Distribution Program on Indian
Reservations (FDPIR), student financial assistance benefits, and loans. 78 Fed. Reg.
17628 (Mar. 22, 2013). Children from families with incomes over 185 percent of the
federal poverty level pay full price, although their meals are still subsidized to some extent.

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GAO-15-634T

or who are foster children) are eligible for free school meals regardless of
income.

USDA Has Taken
Steps to Help Identify
and Prevent Ineligible
Participants from
Receiving Benefits

In May 2014, we reported that USDA had taken several steps to
implement or enhance controls to identify and prevent ineligible
beneficiaries from receiving school-meals benefits.11 For example:
USDA worked with Congress to develop legislation to automatically
enroll students who receive SNAP benefits for free school meals;
SNAP has a more-detailed certification process than the school-meals
program. For our May 2014 report, USDA officials told us that they
were emphasizing the use of direct certification, because, in their
opinion, it helps prevent certification errors without compromising
access. Direct certification reduces the administrative burden on
SNAP households, as they do not need to submit a separate schoolmeals application. It also reduces the number of applications school
districts must review. The number of school districts directly certifying
SNAP-participant children increased from the 2008 through 2013
school years. For example, during the 2008–2009 school year, 78
percent of school districts directly certified students, and by the 2012–
2013 school year, this percentage had grown to 91 percent of school
districts, bringing the estimated percentage of SNAP-participant
children directly certified for free school meals to 89 percent. USDA
was also conducting demonstration projects in selected states and
school districts to explore the feasibility of directly certifying children
that participate in the Medicaid program.
USDA requires state agencies that administer school-meals programs
to conduct regular, on-site reviews—referred to as “administrative
reviews”—to evaluate school districts that participate in the schoolmeals programs. Starting in the 2013–2014 school year, USDA
increased the frequency with which state agencies complete
administrative reviews from every 5 years to every 3 years. As part of
this process, state agencies are to conduct on-site reviews of school
districts to help ensure that applications are complete and that the
correct eligibility determinations were made based on applicant
information. School districts that have adverse findings in their
administrative reviews are to submit a corrective-action plan to the

•

•

11

GAO-14-262.

Page 5

GAO-15-634T

state agency, and the state agency is to follow up to determine
whether the issue has been resolved.
In February 2012, USDA distributed guidance to state administrators
to clarify that school districts have the authority to review approved
applications for free or reduced-price meals for school-district
employees when known or available information indicates schooldistrict employees may have misrepresented their incomes on their
applications.

•

USDA Could Explore
Options to Enhance
the Verification
Process to Further
Strengthen Integrity
While Ensuring
Legitimate Access

In our May 2014 report, we identified opportunities to strengthen oversight
of the school-meals programs while ensuring legitimate access, including
clarifying use of for-cause verification, studying the feasibility of electronic
data matching to verify income, and verifying a sample of households that
are categorically eligible for assistance.

For-Cause Verification

As described in USDA’s eligibility manual for school meals, school
districts are obligated to verify applications if they deem them to be
questionable, which is referred to as for-cause verification.12
We reported in May 2014 that officials from 11 of the 25 school districts
we examined told us that they conduct for-cause verification. These
officials provided examples of how they would identify suspicious
applications, such as when a household submits a modified application—
changing income or household members—after being denied, or when
different households include identical public-assistance benefit numbers
(e.g., if different households provide identical SNAP numbers). However,
officials from 9 of the 25 school districts we examined told us that they did
not conduct any for-cause verification. For example, one school-district
official explained that the school district accepts applications at face
value. Additionally, officials from 5 of the 25 school districts told us they
only conduct for-cause verification if someone (such as a member of the

12

7 C.F.R. § 245.6a(c)(7).

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GAO-15-634T

public or a state agency) informs them of the need to do so on a
household. Although not generalizable, responses from these school
districts provide insights about whether and under what conditions school
districts conduct for-cause verifications.
In April 2013, USDA issued a memorandum stating that, effective for the
2013–2014 school year, all school districts must specifically report the
total number of applications that were verified for cause. However, the
outcomes of those verifications would be grouped with the outcomes of
applications that have undergone standard verification. As a result, we
reported in May 2014 that USDA would not have information on specific
outcomes, which it may need to assess the effectiveness of for-cause
verifications and to determine what actions, if any, are needed to improve
program integrity. While USDA had issued guidance specific to schooldistrict employees and instructs school districts to verify questionable
applications in its school-meals eligibility manual, we found that the
guidance did not provide possible indicators or describe scenarios that
could assist school districts in identifying questionable applications.
Hence, in May 2014, we recommended that USDA evaluate the data
collected on for-cause verifications for the 2013–2014 school year to
determine whether for-cause verification outcomes should be reported
separately and, if appropriate, develop and disseminate additional
guidance for conducting for-cause verification that includes criteria for
identifying possible indicators of questionable or ineligible applications.
USDA concurred with this recommendation and in January 2015 told us
that FNS would analyze the 2013–2014 school year data to determine
whether capturing the results of for-cause verification separately from the
results of standard verification would assist the agency’s efforts to
improve integrity and oversight. USDA also said that FNS would consider
developing and disseminating additional guidance, as we recommended.

Income Verification

In addition to for-cause verification, school districts are required to
annually verify a sample of household applications approved for free or
reduced-price school-meals benefits to determine whether the household
has been certified to receive the correct level of benefits—we refer to this

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GAO-15-634T

process as “standard verification.”13 Standard verification is generally
limited to approved applications considered “error-prone.” Error-prone is
statutorily defined as approved applications in which stated income is
within $100 of the monthly or $1,200 of the annual applicable incomeeligibility guideline. Households with reported incomes that are more than
$1,200 above or below the free-meals eligibility threshold and more than
$1,200 below the reduced-price threshold would generally not be subject
to this verification process.
In a nongeneralizable review of 25 approved civilian federal-employee
household applications for our May 2014 report, we found that 9 of 19
households that self-reported household income and size information
were not eligible for free or reduced-price-meal benefits they were
receiving because their income exceeded eligibility guidelines. Two of
these 9 households stated in their applications annualized incomes that
were within $1,200 of the eligibility guidelines and, therefore, could have
been selected for standard verification as part of the sample by the
district; however, we determined that they were not selected or verified.
The remaining 7 of 9 households stated annualized incomes that fell
below $1,200 of the eligibility guidelines and thus would not have been
subject to standard verification.
For example, one household we reviewed submitted a school-meals
application for the 2010–2011 school year seeking school-meals benefits
for two children. The household stated an annual income of
approximately $26,000 per year, and the school district appropriately
certified the household to receive reduced-price-meal benefits based on
the information on the application. However, we reviewed payroll records
and determined that the adult applicant’s income at the time of the
application was approximately $52,000—making the household ineligible
for benefits. This household also applied for and received reduced-meal
benefits for the 2011–2012 and 2012–2013 school years by understating

13

Pursuant to statute, school districts are required to verify a random sample of applicants.
The sample size is equal to the lesser of 3 percent of approved applications, selected from
error-prone applications, or 3,000 error-prone applications unless an alternative sample
size is used. For the purposes of standard verification, federal law defines error-prone
applications as approved applications with monthly income within $100 of—or with annual
income within $1,200 of—the income eligibility limits for free or reduced-price meals.
Households that indicate categorical eligibility on an application and households that enter
the program through direct certification are generally not subject to the standard
verification process.

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GAO-15-634T

its income. Its 2012–2013 annualized income was understated by about
$45,000.
Because the income stated on the application during these school years
was not within $1,200 per year of the income-eligibility requirements, the
application was not deemed error-prone and was not subject to standard
verification. Had this application been subjected to verification, a valid pay
stub would have indicated the household was ineligible.
One method to identify potentially ineligible applicants and effectively
enforce program-eligibility requirements is by independently verifying
income information with an external source, such as state payroll data.
States or school districts, through data matching, could identify
households that have income greater than the eligibility limits and follow
up further. Such a risk-based approach would allow school districts to
focus on potentially ineligible families while not interrupting program
access to other participants. Electronic verification of a sample of
applicants (beyond those that are statutorily defined as error-prone)
through computer matching by school districts or state agencies with
other sources of information—such as state income databases or publicassistance databases—could help effectively identify potentially ineligible
applicants.
In May 2014, we recommended that USDA develop and assess a pilot
program to explore the feasibility of computer matching school-meal
participants with other sources of household income, such as state
income databases, to identify potentially ineligible households—those
with income exceeding program-eligibility thresholds—for verification. We
also recommended that, if the pilot program shows promise in identifying
ineligible households, the agency should develop a legislative proposal to
expand the statutorily defined verification process to include this
independent electronic verification for a sample of all school-meals
applications. USDA concurred with our recommendations and told us in
January 2015 that direct-verification computer matching is technologically
feasible with data from means-tested programs, and that data from SNAP
and other programs are suitable for school-meals program verification in
many states. USDA said that FNS would explore the feasibility of using
other income-reporting systems for program verification without
negatively affecting program access for eligible students or violating
statutory requirements. Depending on the results of the pilot program,
USDA said that FNS would consider submitting a legislative proposal to
expand the statutorily defined verification process, as we recommended.

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GAO-15-634T

Verification of Categorical
Eligibility

In May 2014, we found that ineligible households may be receiving free
school-meals benefits by submitting applications that falsely state that a
household member is categorically eligible for the program due to
participating in certain public-assistance programs—such as SNAP—or
meeting an approved designation—such as foster child or homeless. Of
the 25 civilian federal-employee household applications we reviewed, 6
were approved for free school-meals benefits based on categorical
eligibility. We found that 2 of the 6 were not eligible for free or reducedprice meals and 1 was not eligible for free meals, although that household
may have been eligible for reduced-price meals.
For example, one household applied for benefits during the 2010–2011
school year—providing a public-assistance benefit number—and was
approved for free-meal benefits. However, when we verified the
information with the state, we learned that the number was for medicalassistance benefits—a program that is not included in categorical
eligibility for the school-meals programs. On the basis of our review of
payroll records, this household’s annualized income of at least $59,000
during 2010 would not have qualified the household for free or reducedprice-meal benefits. This household applied for school-meals benefits
during the 2011–2012 and 2012–2013 school years, again indicating the
same public-assistance benefit number—and was approved for free-meal
benefits.
Figure 1 shows the results of our review.

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GAO-15-634T

Figure 1: Results of GAO’s Analysis of a Nongeneralizable Sample of Approved Applications

Note: There are two ways children may be classified as categorically eligible: (1) through participation
in certain public-assistance programs, such as the Supplemental Nutrition Assistance Program
(SNAP) or Temporary Assistance for Needy Families (TANF), or (2) through meeting an approved
designation, such as homeless or foster child.

Because applications that indicate categorical eligibility are generally not
subject to standard verification, these ineligible households would likely

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GAO-15-634T

not be identified unless they were selected for for-cause verification or as
part of the administrative review process, even though they contained
inaccurate information. These cases underscore the potential benefits
that could be realized by verifying beneficiaries with categorical eligibility.
In May 2014, we recommended that USDA explore the feasibility of
verifying the eligibility of a sample of applications that indicate categorical
eligibility for program benefits and are therefore not subject to standard
verification. USDA concurred with this recommendation and told us in
January 2015 that FNS would explore technological solutions to assess
state and local agency capacity to verify eligibility of a sample of
applications that indicate categorical eligibility for school-meals-program
benefits. In addition, USDA said that FNS would clarify to states and local
agencies the procedures for confirming and verifying the application’s
status as categorically eligible, including for those who reapply after being
denied program benefits as a result of verification.
Chairman Rokita, Ranking Member Fudge, and Members of the
Subcommittee, this concludes my prepared remarks. I look forward to
answering any questions that you may have at this time.

GAO Contact and
Staff
Acknowledgments

(192460)

For further information on this testimony, please contact Jessica LucasJudy at (202) 512-6722 or [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this statement. Individuals making key contributions to
this testimony include Gabrielle Fagan, Assistant Director; Marcus Corbin;
Ranya Elias; Colin Fallon; Kathryn Larin; Olivia Lopez; Maria McMullen;
and Daniel Silva.

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U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548

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File Typeapplication/pdf
File TitleGAO-15-634T, SCHOOL MEALS: USDA Could Improve Verification Process for Program Access
AuthorU.S. Government Accountability Office, http://www.gao.gov
File Modified2017-07-18
File Created2015-05-15

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