Community Eligibility Provision Catherine Digilio Grimes, MS, RDN, LDN, SNS Director, Office of School Nutrition Programs VA Department of Education.

Community Eligibility Provision

Catherine Digilio Grimes, MS, RDN, LDN, SNSDirector, Office of School Nutrition Programs

VA Department of Education

What is the Community Eligibility Provision

• An alternative to collecting household applications for free and reduced price meals in high poverty School Divisions and schools.

• Allows schools with a high percentage of needy children to serve free meals to all enrolled students

• Eligible School Divisions/schools agree to serve all students free lunches and breakfasts for 4 successive school years.

What Makes CEP Different?• CEP does not require

the collection of applications

• CEP relies on data matching from other assistance programs, like SNAP and TANF

CEP Benefits

Students:• Enjoy free,

healthy meals at school

• No stigma attached to a free meal

Parents:• No household

applications

• Do not have to worry about refilling meal accounts

Schools:• Reduces

paperwork and administrative costs

• Streamlines meal service operation

• No unpaid meal charges

How do I Qualifying for CEP• School Divisions, schools or groups of

schools must have an identified student percentage (ISP) of at least 40% as of April 1st of the school year prior to implementing CEP

• Participate in NSLP and SBP

• Has a record of administering the Programs in accordance with regulations

Participation Requirements• School Divisions or schools electing CEP must

– Offer lunches and breakfasts At No Charge to all enrolled students for a cycle of 4 years

– Count total lunches and total breakfasts served to students daily

– Not collect household applications for free and reduced price meals

Identified Student Percentage• Students certified for free meals without

submitting a school meal application. • Directly certified for free meals on the basis of their

participation in the – Supplemental Nutrition Assistance Program (SNAP) and – Temporary Assistance for Needy Families (TANF);

• Includes students who are certified for free meals without application because they are – in Foster care– in Head Start, Even start– Are Homeless, runaway and/or migrant

Identified Student Percentage is NOT

• The same as the total number of students eligible for free and reduced priced meals.

• Applications with SNAP/TANF numbers.

• Applications which indicate homeless, migrant, runaway or foster

• Not the same as the total number of students eligible for free and reduced priced meals.

Definitions- Enrolled Students

• Students enrolled and attending the schools participating in Community Eligibility Provision who have access to at least one meal service daily. (SNP membership)

• Students who do not have access to either breakfast or lunch due to the times they are attending school would not be included in the count of enrolled students

How is the Identified Student Percentage (ISP) calculated?

• The ISP may be determined by: – an individual participating school– a group of participating schools in the LEA – entire Division if all schools participate

Total # of Identified Students

Total # of enrolled students (SNP Membership)

X 100=IdentifiedStudent %

How to Determine Identified Student Percentage

Example: # DC students = 525

# Enrolled (Access to NSLP and SBP) = 1000

525 1000 = 0.525 X 100 = 52.5% ISP

Identified Student Determinations

• Must be at least 40% for –an individual school, –the group of schools, or –entire School Division if all schools

participate

How Can Schools Participate• By school division

– All schools in the division participate as a single group with the same free claiming percentage as long as it is 40% or higher

• By individual school– Individual schools with

40% or more Identified Students participate in community eligibility

• By group– Divisions may choose to group

schools any way they wish and calculate the free claiming percentage for the group of schools as a whole, using their combined enrollment and total number of Identified Students, as long as the percentage is 40% or higher

– There is no limit to the number of groups

– Within the same school division, some schools can participate individually and some can participate as a group

How are schools grouped?• When schools are grouped, ISP is calculated using the

identified student and enrollment totals for all schools in the group

• Schools that would not be eligible to participate in CEP individually may participate as part of a group, provided that the group’s ISP is still at least 40%

• LEAs can enroll multiple groups in CEPNOTE

• not all schools in the group or in the School Division if electing for the entire Division have to meet the 40% threshold

Reasons for Grouping Schools

• Schools can be grouped to maximize federal reimbursement in schools with ISPs 62.5% and above.

• Grouping can be used to bring in additional schools below the 40% ISP cut off

• If a division cannot make the finances work Divisionwide, they can choose a combination of schools (e.g. all elementary schools)

Grouping Example• In this example, three schools are grouped

together:

  Identified students Enrollment ISP

School 1 60 120 50%

School 2 38 100 38%

School 3 150 200 75%

Group of schools 248 420 59%

Total identified students for group (248) Total enrollment for group (420)

How Are Meals Claimed• ISP is multiplied by a factor of 1.6 to determine

the % of total meals served that will be reimbursed at the Federal FREE rate– 1.6 multiplier approximates free and reduced % if applications

were still collected

• The remaining % of total meals is reimbursed at the Federal paid rate

• Any meal costs in excess of the total Federal reimbursement must be covered through non-Federal sources

Where did the 1.6 come from?• Analysis showed that on average for every 10

identified students there were 6 more students certified based on an income application

• If you multiple the identified student percentage by 1.6 you are approximating the free and reduced price percentage

• On average means that some schools will be on the higher end and some on the lower but it serves as a proxy across many low income schools

Percentage Identified Students Percentage Free Paid

40% 64% 36%

45% 72% 28%

50% 80% 20%

55% 88% 12%

60% 96% 4%

65% 100% 0

Meal Reimbursements with Community Eligibility

How to Determine Identified Student Percentage

Example: # DC students = 525

# Enrolled (Access to NSLP and SBP) = 1000

525 1000 = 0.525 X 100 = 52.5% ISP

CEP Claiming Percentages

Free claiming percentage

(52.5% X 1.6) = 84%

Paid claiming percentage

(100% - 84%) = 16%

Example - ISP= 52.5%

Applying The Claiming Percentage

Number of free meals

(1,000 X 84%) = 840

Number of paid meals

(1,000 – 840) = 160

Total meals served= 1,000

Claiming ALL at Free rate

The lowest possible percentage of identified students that would allow for claiming all meals at the free rate

62.50%

Financial Viability• Ensuring financial viability is key when

electing CEP

• An evaluation study of pilot States found that the average identified student percentage was around 55% or higher

• USDA Estimator Tool– http://www.fns.usda.gov/school-meals/com

munity-eligibility-provision

After The First YearUpdating The Claiming Percentages

• A new identified student percentage may be established each year

• During the 2nd, 3rd and 4th years, the School Division/school may select the higher of the identified student percentage from:– the year directly prior; OR– the year prior to the first year of operating CEP

New Cycle• To begin a new 4-year cycle, School Divisions or

schools must establish a new identified student percentage as of April 1 of the fourth year of the previous cycle

• School Divisions may begin a new 4-year cycle if all eligibility criteria is met, with State agency concurrence

• School Divisions/schools in year 4 with an identified student percentage of less than 40% but more than 30% may elect for an additional year (a grace year)

Things to Think About• Absence of application data

– school meal application data used to distribute other sources of funding? (Title I, E-rate, State, Local, etc)

• Potential financial issues when less than 100 percent claimed at free rate (62.5 percent student identifier).

• Anticipated level of Federal reimbursement• Non-Federal resources available

FEDERAL, STATE & LOCAL EDUCATION FUNDING

Title I,

E-Rate discounts,

Impact on other programs

Title I - Implications

• Title I Guidance–ISP and/or ISP times 1.6 multiplier

•Ranking of schools for Title I funding

• Identification of Economically Disadvantaged Students

How does CEP impact Title I school ranking?

• The LEA must use a common poverty metric to rank order schools and allocate Title I funds on an equitable basis

• If an LEA selects National School Lunch data as its poverty measure and participates in CEP, the CEP data will be used by the LEA for within-district allocations

• An LEA will not use CEP data for Title I school ranking until a school is in its second year implementing CEP (2015-2016 or later)

3 Options -CEP and non-CEP schools

Option #1 – Use the Multiplier for CEP SchoolsSchool Total

Enrollment# Direct Cert

# Household Apps

Apply Multiplier

# Low Income

Percent Low-Income

School 1 CEP

100 60 -- 1.6 96 96%

School 2 CEP

100 50 -- 1.6 80 80%

School 3 Non-CEP

100 30 10 -- 40 40%

3 Options -CEP and non-CEP schoolsOption #2 – Use ONLY Direct Certification

(IS) Data for ALL schools

School TotalEnrollment

# Direct Cert

# Househol

d Apps

Apply Multiplier

# Low Income

Percent Low-

Income

School 1 CEP

100 60 -- -- 60 60%

School 2 CEP

100 50 -- -- 50 50%

School 3 Non-CEP

100 30 10 -- 30 30%X

3 Options -CEP and non-CEP schools

Option #3 – Use Direct Certification Data and the Multiplier for ALL schools

School TotalEnrollment

# Direct Cert

# Household

Apps

Apply Multiplie

r

# Low Incom

e

Percent Low-

Income

School 1 CEP

100 60 -- 1.6 96 96%

School 2 CEP

100 50 -- 1.6 80 80%

School 3 Non-CEP

100 30 10 1.6 48 48%X

CEP SCHOOLS

The CEP identified students definition will be used to identify the economically disadvantaged subgroup for accountability purposes in all CEP schools.  

Identification of Economically Disadvantaged Students for Federal Accountability

Identification of Economically Disadvantaged Students for Federal Accountability

NON CEP SCHOOLSSchools not participating in CEP will continue to use traditional methods for the identification of the economically disadvantaged subgroup for accountability purposes as allowed under Title I and that comply with the data elements outlined in the Student Record Collection (for example, student eligibility for Free/Reduced Meals, students receiving TANF, and students eligible for Medicaid).

VDOE Title 1Contact Information

Dr. Lynn Sodat, Title I [email protected]

804-371-2934

E-Rate Discounts

• The Federal Communications Commission (FCC) has also released guidance on Federal Funding for the E-Rate program, detailed in USDA policy memo SP-08-2015: http://www.fns.usda.gov/sites/default/files/cn/SP08-2015os.pdf

• SY 2014-15: CEP schools may use the NSLP eligibility data that they previously submitted for the most recent funding year in which they did not participate in CEP

• SY 2015-16: CEP schools may use

claiming percentage (ISP x 1.6)

What about State and local education funding?

• State funding: DOE Division of Finance and Operations is evaluating this

• Local funding: communicate with stakeholders; determine options

What about other Federal Child Nutrition programs?

• The CEP free claiming percentage serves as a proxy for free and reduced price certifications (ISP X 1.6)

• May be used when determining area eligibility for Child Nutrition Programs

CEP’s Success Continues to Grow

• Numerous positive success stories from across Virginia and the Nation

• Higher participation in school meal programs frequently reported

• CEP elections likely to increase for SY 2015-2016

What impact will CEP have on other Child Nutrition Programs?

Other Child Nutrition Programs will be able to utilize the percent of meals claimed free to

determine their eligibility:

• Summer Food Service Program (SFSP)• Fresh Fruit and Vegetable (FFVP)• After School Snacks• Child and Adult Care Food Program – After

School at Risk Meals Program