The Community Eligibility Provision (CEP)

1. The Community Eligibility Provision (CEP) The Newest Alternative Provision

2. Overview • Background • Notification & Publishing Requirements • Data Sources • Questions & Discussion

3. Background

4. History • Healthy, Hunger-Free Kids Act of 2010 • Provides an alternative to household applications for free and reduced price meals • Offers all students free meals in high poverty LEAs and schools • CEP schools do not take applications, but use existing data to provide free meals to all students • Intended to improve access to free meals in high poverty areas while reducing administrative burdens

5. Background • Phased in over a period of three years in a limited number of States • District of Columbia, Illinois, Kentucky, Michigan, New York, Ohio, West Virginia, Florida, Georgia, Maryland, and Massachusetts • Will be available nationwide beginning July 1, 2014

6. Community Eligibility Is Being Phased In

7. Nearly 1 Million Children Are Already Benefitting From Community Eligibility

8. Who is eligible to elect the CEP? • SFAs may elect CEP for all sites, individual schools, or a group of schools. • To be eligible, the LEA, individual school, or group of schools must have an identified student percentage of at least 40%. • Identified students are those certified for free meals either through direct certification (SNAP, or notification/letters from FDPIR, TANF, Migrant, Headstart, etc)

9. Requirements for Participation • Have a minimum percentage (≥ 40%) of identified students in the school year prior to implementing CEP • Serve free lunches AND breakfasts to all students for 4 years • Count total breakfasts and total lunches served to students daily • CEP schools will not collect household applications for free and reduced price meals and will not conduct verification

10. Election and Eligibility Criteria • Eligible school or group of schools must have an identified student percentage of at least 40% (reflective of April 1st) of the school year prior to implementing CEP. • LEAs can submit applications by June 30 to begin CEP in the SY beginning July 1. • Participation is an LEA level decision but requires concurrence from the State agency.

11. State Approval Process • An LEA must obtain State agency concurrence to administer CEP. • The State agency must review documentation submitted by the LEA to ensure the LEA/school: • Meets the minimum identified student percentage (40%) • Participates in both the NSLP and SBP • Has a record of administering the meal program in accordance with program regulations (“in good standing”)

12. Who Are “Identified Students”? Children certified for free meals without submitting a school meal application Includes children who are directly certified (through data matching or letter-method) for free meals because they live in households that participate in the Supplemental Nutrition Assistance Program (SNAP) Temporary Assistance for Needy Families Cash Assistance (TANF) Food Distribution Program on Indian Reservations (FDPIR) Applications with case-numbers are categorically eligible for free-meals, but they are not included in the “identified student” percentage Includes children who are certified for free meals without application because they are in Foster care in Head Start are homeless or are migrant

13. Calculating Identified Student Percentage Identified Students X 100 = Identified Student Total Enrollment Percentage • Identified Students and Enrollment should be reflective of April 1st of the year before starting CEP • Total Enrollment is of all students with access to NSLP/SBP programs

14. Claiming Percentages • Identified student percentage multiplied by a factor of 1.6 equals the % of total meals served reimbursed at the Federal free rate • 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

15. Claiming Percentages Example Lobitos School District: Total enrollment as of April 1, 2014 = 1352 Identified students = 733 Identified Student percentage = (733/1352)*100 = 54.2% Free Reimbursement Rate = 54.2% * 1.6 = 86.72% Paid Reimbursement Rate = 100 – 86.72 = 13.28% Lobitos SFA’s November 2014 claim = 22,984 total mealsFree meals = 22,984 * 86.72% = 19,932Paid meals = 22,984 * 13.28% = 3,052Edit Check: 19,932 + 3,052 = 22,984

16. Meal Reimbursements with CEP The reimbursement rate for both lunch and breakfast is determined by multiplying the percent of Identified Students by a 1.6 multiplier. The resulting number is the percent of meals reimbursed at the “free” reimbursement rate, with the rest reimbursed at the “paid” rate.

17. Financial Viability

18. General Procedures • LEAs/schools should notify the State no later than June 30th of the school year prior to the first year of electing CEP. States may extend this deadline with FNS approval • A new identified student percentage may be established each year of the four year cycle for use in the following year • LEAs/schools may elect to stop CEP for the next year by notifying the State no later than June 30th of the current school year

19. Specific Procedures • During the 2nd, 3rd and 4th years, the LEA/school may select the higher of: • Identified student percentage from the year directly prior; or • The year prior to the first year of receiving benefits • LEAs/schools in year 4 with an identified student percentage <40% but ≥ 30% are permitted to elect for an additional year (a grace year) • LEAs/schools that do not meet the threshold must return to normal counting and claiming procedures the following SY

20. Notification & Publishing Requirements

21. Notification generally • No later than April 15 of each SY, • LEAs should submit to the State agency a list of schools • State Agency must notify LEAs about their CEP district wide eligibility status and provide participation guidance • Alternative methods can be approved and deadlines extended if necessary • No later than May 1 of each SY, • State agency should publish lists of LEAs on their website • Provide the link to FNS.

22. LEA Responsibility: list of schools • April 15th of each year, LEAs should supply the State agency with a list of schools: • With an identified student percentage of at least 40% • With an identified student percentage greater than 30% but less than 40% • In the 4th year of electing the Provision with an identified student percentage of at least 30%

23. State responsibility: LEA notification • State agencies should notify LEAs of district wide eligibility status by April 15th of each year: • With an identified student percentage of at least 40% • With an identified student percentage greater than 30% but less than 40% • Currently participating districts • In the 4th year of electing the Provision with an identified student percentage of at least 30% • The State agency must provide participation guidance and procedures for CEP

24. State responsibility: Publication • By May 1, State agencies should make the list of schools readily accessible on the State agency Web site in a format prescribed by FNS. • FNS has developed a template for State agencies to use in displaying the required information. • In lieu of having State agencies submit the list of LEAs to FNS for publication, FNS is developing a CEP Web site which would link to the applicable portion of the State agencies’ Web sites that identify both the list of schools and the list of LEAs.

25. Notification data • Two levels of data required: • LEA district wide data • School level data • Notification data must reflect current school year. • Lists containing both LEA wide data and school level data must be published on State agency websites. • FNS will link to the State agency websites to fulfill the public notification requirement.

26. Notification Data: LEA level • State’s are encouraged to use existing data from the FNS-742 • The sum of Section 3 on the revised FNS-742 is the number of identified students • Enrollment data is captured in Section 1 The district wide identified student percentage = Sum of Section 3 Enrollment data in Section 1 X 100

27. Notification Data: Lea Level • Section 1 of the FNS-742: Enrollment information

28. Notification data: LEA Level • Section 3 of the FNS-742: Number of Identified Students

29. Notification Data – School Level • LEAs should provide State agencies with school level eligibility status information no later than April 15. • State agencies with access to school level data may exempt LEAs from this requirement. • The percentage of enrolled students in the school divided by direct certifications with SNAP may be used as a proxy for the identified student percentage. • Proxy percentage provides an indicator of potential school level eligibility and/or near eligibility.

30. Notification Data - Template • FNS strongly encourages State agencies to use the FNS template to publish the notification lists. • Data in the recommended format should be published on State agency websites. • Template is an excel file with two tabs • LEA district wide eligibility data • School level eligibility data

31. Notification Data –Template: LEA level • LEA district wide data template:

32. Notification Template: School Level • School level data template:

33. Title I and Poverty Data • NSLP data is sometimes used by schools for State funding purposes or Title I • An LEA’s CEP data may be used (in combination with general NSLP data) for the purpose of Title I • Please see FNS memo SP 19-2014os for specific details.

34. Resources USDA CEP Website http://www.fns.usda.gov/school-meals/community-eligibility-provision USDA CEP Proposed Rule: http://www.gpo.gov/fdsys/pkg/FR-2013-11-04/pdf/2013-25922.pdf FRAC School Board Presentation: http://frac.org/federal-foodnutrition-programs/national-school-lunch-program/community-eligibility/

35. Questions & discussion