With the increasing use of direct certification and families submitting applications containing both income data and a Medicaid number (or SNAP/TANF), school business officials must navigate these applications carefully to stay compliant with USDA regulations and state privacy laws.
This guide outlines the correct procedure for evaluating such applications under the National School Lunch Program (NSLP) and ISBE practices.
What’s in the income application?
It’s common for families to submit an NSLP household application that includes:
- Household income data
- A Medicaid case number (or SNAP/TANF)
Does the Medicaid number alone make the student eligible for free meals?
Short answer: No, unless the student is directly certified.
Step by step process of reviewing the application
Step 1: Check for direct certification match
Before reviewing income, check if the student is on the direct certification (DC) list:
- Medicaid-based eligibility only counts if the student is identified through state-level matching (ISBE + DHS).
- Listing a Medicaid number on an application is not enough — it must be verified through the DC match file.
➡ If the student appears on the DC list via Medicaid:
✔ Approve the student for free meals, regardless of income reported on the application.
➡ If the student is not on the DC list:
Proceed to Step 2.
Step 2: Evaluate income on the application
If there is no direct certification match, treat the application as an income-based submission:
- Review total household income and household size.
- Compare against the current USDA income eligibility guidelines, also shown on the PushCoin application page.
➡ If income qualifies:
✔ Approve for free or reduced-price meals as appropriate.
➡ If income does not qualify:
✘ Deny the application — even if it includes a Medicaid number.
Stay vigilant: compliance and audit risk
Approving students without a valid DC match or income eligibility:
- Violates USDA NSLP regulations
- Risks audit findings and corrective actions
- Could result in loss of reimbursement funds if discovered in a program review
Direct certification takes priority over income-based applications only when there’s an actual match in the DC system.
Guidelines are subject to change; reach out to ISBE’s Nutrition Department for up to date guidance.