Comment on FR Doc # 2012-01835

Even though the rule states that we need the count of children ages 5-17 who are receiving assistance under SNAP, the state of Idaho has children ages 6-18 defined as school age children. It is curious why you have defined this age group and not listed it as “school age children as defined by state statutes”. This may give an unfair advantage to states that define their school age children as 5-17 years old. We are asking to use the state’s age grouping in the calculation of Percent of SNAP children directly certified for free school meals. Also in Idaho, we have numerous home schooled children, however there is no requirement to have the children registered, so this is an unknown number. There are also numerous Charter and Private schools that are not on the School Lunch program. While we may be able to get the number of Children enrolled in those Charter schools, the private schools may be a more difficult number to ascertain. Those schools on Provision 2 for both breakfast and lunch chose that option to streamline their application process. This seems to be taking a step backwards in that regard. While some of these schools do have their enrollment in the state database, those schools that do not would have to upload a list into our direct certification system in order to directly certify children that do not need to be directly certified. While you may say that it is in regulations that they do it, you are creating a barrier for the foodservice department that may be ill equipped to start doing that process. Also I can expect this to happen in our Tribal Schools, making it a perceived barrier due to race. Idaho, with its smaller population would need fewer unmatched children to fall into Corrective Action Plans every year. While our Direct Certification program is matching children on a nightly basis, this may not be adequate to rise to the 95% match rate that is required due to our diverse population. This is a barrier placed on our state with lim