It’s Only Money… The New Poverty Index & New Student Meal Charging Policy Requirements 2016 SCASBO Fall Conference – 11/03/16

Presenters Ellen Mason (803) 734-8199 emason@ed.sc.gov Walter Caudle (803) 734-4586 wcaudle@ed.sc.gov SC Department of Education Office of Health & Nutrition

But First… Post-Hurricane Matthew Meal Service & Free Meal Eligibility Guidelines for Displaced Families

Disaster Feeding at a Shelter The Red Cross should reimburse the cost of purchased foods & labor. Meals can’t be double-claimed through Red Cross & SCDE. SCDE &/or USDA will provide reimbursement or entitlement credit for USDA Foods used. FEMA may cover other expenses.

Disaster Feeding NOT at a Shelter Existing (2014, 2015, & 2016) SSO & SFSP sponsors can feed children during emergencies. SCDE will waive advance notice requirements for new or changed SSO or SFSP sites. Awaiting USDA decision on emergency approval of new sponsors CACFP supper sponsors should contact DSS.

Free Meal Eligibility & Displaced Families Displaced families are considered “homeless” under McKinney-Vento guidelines. Acceptable documentation: statement from homeless coordinator; statement from emergency shelter; or F&R application self-reported as “homeless” (no income or validation needed). Free meal eligibility remains in effect for the remainder of the 2016-2017 school year & the 1st 30 operating days of the 2017-2018 school year.

The NEW Poverty Index… Reacting to the USDA Community Eligibility Provision (CEP)

Traditional Free & Reduced Eligibility Application with self-reported income & household size Application with self-reported categorical (Free) eligibility by SNAP/TANF number, or foster child status Categorical (Free) eligibility via McKinney-Vento (homeless & runaway) or Migrant Education Programs SCDE Direct (Free) Certification (SNAP, TANF, Foster) All are counted for “free & reduced lunch rate.” Medicaid does NOT qualify as categorical eligibility.

Medicaid 101 Medicaid is low cost or free health coverage for children who meet specific income requirements. Districts can bill Medicaid directly for services & receive federal reimbursement for activities that support Medicaid (like outreach) through School District Administrative Claiming (SDAC). More accurate identification & reporting of students on Medicaid will increase Medicaid funding & leverage the local poverty index calculation.

Community Eligibility Provision (CEP) All children in affected schools eat at no out-of-pocket cost. No household F&R applications are needed. Can be implemented in individual schools, clusters of schools, or district-wide School eligibility is based on the “Identified Student Percentage” (ISP) of students pre-certified as Free through SCDE-SCDSS Direct Certification (SNAP, TANF, Foster), McKinney-Vento (homeless/runaway), or Migrant Education Program documentation. Medicaid is NOT considered in the equation.

More on CEP The ISP must be at least 40% to qualify. The ISP is then factored by 1.6 to determine the “Claiming Rate” of meal reimbursement at the Free rate. The balance is reimbursed at the Paid rate: ISP (60%) x 1.6 = 96% of meals claimed at Free rate 4% of meals claimed at Paid rate The district must absorb the loss of student payments from reduced & full-paying students. ISP documentation for individual students must be maintained & updated throughout the school year.

The Paradigm Shift The “free & reduced lunch rate” no longer exists for CEP schools. The only way to achieve an accurate comparison of schools or districts is to migrate to the ISP.

Impact on Title 1 & Related Programs No impact on aggregate district funding levels May have a minor impact on: School ranking order School allocations (based on the number of students counted in 1st year only) Number of schools served (primarily the lower end of school rankings) Districts have local discretion on how to address these situations.

Impact on Federal E-Rate Funding Most funding %’s will stay the same or increase (more Direct Certification = higher E-Rate %) Reduced matching funds requirement Can’t count pre-K, Head Start, or adult ed. students that may be in the ISP count for CEP More students can be claimed as NSLP-Alternative, which may increase E-Rate Cat. 2 budget = “pre-discounted” $150 per student

The NEW Poverty Index Calculation The following data elements will be used to calculate poverty for state funding beginning with the 2017-18 school year: Foster (CEP element) TANF (CEP element) SNAP (CEP element) Medicaid (not a CEP element) New element – Migrant a.k.a. “Transient” (CEP element) New element – Homeless/Runaway (CEP element) Additional data elements may be added.

The PowerSchool Problem Districts must ensure accurate student data!!! The SCDE-SCDSS Direct Certification (SNAP, TANF, Foster) matching process is driven by student data, including addresses. Late submissions to SCDE, incomplete data fields, & inconsistent data entries have a negative impact! New data fields (2017) & Level Data software will improve the process… IF you use them!

The Future… Continued Change! More schools & districts are considering CEP. CEP thresholds & formulas are subject to change because of the pending federal reauthorization of USDA child nutrition programs. Medicaid could become a qualifying source of F&R eligibility (via USDA regulations) in the next few years. Ongoing enhancements to the SCDE-SCDSS Direct Certification process should increase match rates. Keep the conversations going!

New USDA Student Meal Charging Policy Requirements

USDA Directive on Charging Policies This new mandate is part of the ongoing implementation of the Healthy, Hunger-Free Kids Act of 2010. All districts must have a written policy/procedure by 07/01/2017. It does not have to be board-approved. This requirement is not applicable to universal-CEP districts. SFAs can control the scope & content, to include charge limits, alternative meals, etc.

But Wait, There’s More… The policy/procedure must be consistent in its treatment of reduced & paid students. The policy/procedure must be publicly communicated to all stakeholders. Immediate Action Item: Any district that currently has a charging policy/procedure &/or uses CEP is strongly encouraged to have the information easily accessible on their website now.

One Last Thing… Unpaid student charges may be recorded as an Accounts Receivable item as long as there are reasonable efforts being made to collect the debt. Once all reasonable collection efforts have been exhausted, the write-off of the uncollectable debt must include a 100% non-federal reimbursement to the non-profit school food service account. Decisions regarding collection efforts & write-offs must be consistent with other district policies.