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The C o mmunity E l igibility Provision (CEP ) Arkansas Department of Education, Child Nutrition Unit March 2014. History. Heal thy , Hunge r -Fre e Kid s A c t o f 20 1 0 Provides an alternative t o househo l d ap p lication s fo r free and reduced pric e meals
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TheCommunityEligibility Provision(CEP) Arkansas Department of Education, Child Nutrition Unit March 2014
History • Healthy,Hunger-FreeKids Actof2010 • Provides an alternativeto householdapplicationsforfree and reducedprice meals • Offersall studentsfree mealsinhigh povertyLEAsandschools • ProposedrulepublishedinFederalRegisteronNovember4,2013 • 60day commentperiod(Nov4, 2013 to Jan 3,2014)
Background • Theintentof CEP is: • Toimprove access to free schoolmealsineligiblehigh poverty LEAsandschools • To eliminateadministrativeburden of collecting householdapplications
Implementation • CEP was phasedinoveraperiodofthree yearsinalimitednumberofStatesselectedby FNS • WillbeavailablenationwidebeginningJuly 1,2014 • CurrentlyLEAsandschools inEleven Statesareparticipating: • DistrictofColumbia,Illinois,Kentucky,Michigan,New York,Ohio, WestVirginia,Florida,Georgia,Maryland, and Massachusetts
Implementation • CEP schools use only “direct certification” data to determine the Federal cash reimbursement for school lunches provided by USDA. • Reimbursement will also include Severe Need for Breakfast, Safety Net for Lunch and the Performance Based Certification Reimbursement if the district is certified to receive this
Definitions • Identified Students – the number approved as free eligible who are not subject to verification. SNAP, determined homeless by liaison and on homeless list, income-eligible Head Start, pre-K Even Start, on Migrant list, runaways, and non-applicants approved by local officials. Foster children certified through means other than application are also included and students on SNAP letter provided by the household. • DOES NOT INCLUDE students who are categorically eligible based on submission of a free and reduced price application
Definitions • Identified Student Percentage – Identified Students = % of identified students Enrollment • Claiming Percentage % of Identified Students (40% minimum to qualify for CEP) x 1.6 (USDA multiplier) = % to be used to calculate # of meals to claim for reimbursement
Definitions • Non-Federal Sources – any funds other than Federal reimbursement available to the nonprofit school food service account may be used. The use of non-Federal funds is only necessary if the total amount of Federal reimbursement through the CEP does not cover the costs of serving free meals to all students. • Examples of non-Federal sources – State revenue matching funds, profits from a la carte sales, cash donations, and in-kind contribution funds from outside sources such as volunteer services. (PTA)
Requirementsfor Participation • Have aminimumpercentageofidentifiedstudents inthe schoolyearPRIORto implementingCEP, SO as of April 1, 2014 • Identifiedstudents_ x100%≥ 40% • Totalenrolledstudents • Servefreelunchesandbreakfaststo all students • Householdapplications for free and reducedprice mealsare not collected
ElectionandEligibility • LEAs mayelecttheProvisionfor: • allschoolsin theLEA • agroup ofschoolsor • anindividualschool • Eligibleschoolorgroupofschoolsmusthavean aggregateidentified studentpercentageofatleast40percent • LEAs wouldberequired tosubmitbyJune30tobeginCEP intheSYbeginningJuly 1 • ElectionisanLEAleveldecisionbutrequiresapproval fromtheStateagency
StateApprovalProcess • The Stateagency would berequiredto confirmthe LEAs eligibility to participatein CEP • The proposedrulewould requirethe Stateagency to review documentationsubmittedbythe LEAto ensurethe LEA/school(s): • Meetsthe minimumidentified student percentage • ParticipatesinboththeNSLPandSBP • Isadministeringthemealprograminaccordancewithprogram regulations
Process • Identifiedstudentpercentagemultipliedbya factorof 1.6 equalsthe percentoftotal mealsserved thatwillbe reimbursedat the Federal freerate • Theremainingpercentof total meals served is reimbursedat the Federal paid rate • Anymeal costsin excess of thetotal Federal reimbursementmustbe covered throughnon-Federal sources
Examples • District percentage of identified students is 40%. Identified students /enrollment = 40% • 40% x 1.6 = 64%. The district can claim 64% of meals served as free. The remaining 36% is claimed as paid. NO REDUCED IS CLAIMED • District percentage of identified students is 50% • 50% x 1.6 = 80%. The district can claim 80% of meals served as free. The remaining 20% is claimed as paid. NO REDUCED IS CLAIMED. • District percentage of identified students is 60% • 60% x 1.6 = 96%. The district can claim 96% of meals served as free. The remaining 4% is claimed as paid. NO REDUCED IS CLAIMED.
Will the 1.6 Multiplier Change? • FNS is permitted to change the multiplier between 1.3 and 1.6. • Districts/Schools will retain the multiplier set at the start of the CEP cycle
Other Programs • Districts/schools can use the CEP percentage (identified students x 1.6) for determining area eligibility in the • Summer Food Service Program through DHS • Seamless Summer through ADE Child and Adult Care Food Program (CACFP) At-Risk-Afterschool snacks, • Afterschool Snacks through the NSLP • Fresh Fruit and Vegetable Program • CONTACT STATE AGENCY FOR FURTHER GUIDANCE
Procedures: General • LEAs mustnotifytheStatenolaterthanJune30thofthe schoolyearpriortothefirstyearofelectingCEP • A newidentifiedstudentpercentagemaybeestablishedeach yearofthefouryearcyclefor useinthefollowingyear • LEAs mayelecttostopCEP forthenextschoolyearfor oneor moreparticipatingschoolsbynotifyingtheStatenolaterthan June30thof the currentschool year • IfanLEAorschoolelectsto stop CEP, LEAsmayrestore standardmeal countingandclaimingatany timeduring thecurrent SYorthe nextSY
AnnualPercentageSelection • During the 2nd,3rd and4th years,theLEA/school mayselectthehigherof: • Identifiedstudentpercentage from the immediatelyprecedingschool year; or • Theyear priorto thefirst year of participatingin CEP (your originalISP)
Grace Year • LEAs/schoolsinyear4with anidentifiedstudent percentageless than40percentbut not less than30percentare permittedto electforan additionalyear • LEAs/schoolsthatdo notmeetthe thresholdmust returnto normal counting andclaiming procedures the followingSchool Year
LEA Requirement:Listof Schools • By April15th of eachyear, the State agencymust obtain fromthe LEAalist ofschools: • Withanidentifiedstudentpercentageofatleast 40percent • Withanidentifiedstudentpercentagegreaterthan30percent but less than40 percent • In the 4thyearof electing the Provision with anidentified studentpercentageofatleast 30percent
StateRequirement:LEANotification • ByApril15thof eachyear, theStatemustnotifyLEAs: • Withanidentifiedstudentpercentageofatleast40percentoftheir eligibility • Withanidentifiedstudentpercentagegreaterthan30percentbut lessthan40percentoftheirpotentialfutureeligibility • Whoarecurrentlyparticipating • Whoareinthe4thyearofelectingtheProvisionwithanidentified studentpercentageofatleast30percent
StateRequirement:PublicNotification • ByMay 1, Stateagenciesmustmakethe list of schoolsreadilyaccessibleontheState agencyWebsite inaformat prescribedbyFNS. • In lieuofhaving Stateagenciessubmit thelist of LEAsto FNS forpublication,FNSisdeveloping aCEP Website whichwouldlinkto the applicable • portionoftheStateagencies’Websitesthatidentify both the list ofschools andthe list ofLEAs.
Benefits ofImplementingCEP • Servefreelunches and breakfasts to all students • Reducedpaperworkfor householdsand school food servicebecausenohouseholdapplicationsarecollectedand processed • Reducedchance ofovertidentificationand stigma
School/LEAConsiderations • Planfor issuessurroundingthe absenceof eligibilitydata • Implementtheprovisionin awaythat resultsin full studentparticipation • Participation byindividual schools,groups of schoolsor theentireLEA • Anticipatedlevelof Federalreimbursementand resourcesto supportprogramcoststhatexceed reimbursement
CEP Reimbursement Estimator www.fns.usda.gov/cnd/governance/Policy-Memos/2013/SP15-2013a2.xls • calculator to estimate Federal reimbursement the district/school may receive, or the non-Federal funds the district/school will need to put into the child nutrition account. • tracking form to show percentage of identified students for each year the district/school is on CEP • Reimbursement rates
USDA Memos • SP 21-2014 – Community Eligibility Provision: Guidance and Q & A’s • SP 19 – 2014 – Community Eligibility Provision: Department of Education Title 1 Guidance
Questions • (501) 324-9502 ADE, CNU • Email • Patricia.winders@arkansas.gov • Donna.ratliff@arkansas.gov • Stephanie.starks@arkansas.gov