Community Eligibility Provision, Title I and Accountability Bridgette Hires and Elena Sanders, 10/2/2014

Provide an Overview of the USDA Community Eligibility Provision Eligibility Requirements Advantages and disadvantages Title I considerations Accountability considerations Question and Answers Agenda

Considering the Community Eligibility Provision for National School Lunch Program

Provide an alternative to household eligibility applications for free and reduced price meals in high poverty districts and schools Community Eligibility Provision is a four-year reimbursement Provision for eligible high poverty districts and schools

Districts and schools may opt in or opt out each year A district may participate in the Community Eligibility Provision for some or all schools in the district

Community Eligibility Provision Requirements for Schools As of April 1, 2014 determine the school(s) has a minimum of 40% “identified” students based on enrollment (not free and reduced count). Agree to serve no cost lunches and no cost breakfasts to all students for up to four consecutive years in approved schools.

Community Eligibility Provision Requirements for Schools Agree to cover with non-federal funds any costs of providing no cost meals to all students above amounts provided in federal meal reimbursements. Do not collect free and reduced price applications from households for the purpose of the school meal program in participating provision schools. Maintain a total count of breakfasts and lunches served to students at the point the students receive the meal Residential Child Care Institutions are not eligible for this Provision.

Determining School Eligibility School eligibility is based on the number of students who meet the “identified” definition. Certified free using methods other than a paper free and reduced meal application. These include students who are: Directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program or Ohio Works First and the extension of benefits to students within the same household.

Determining School Eligibility “Identified” student categories also include: HomelessRunaway MigrantHead Start Foster Children

Determining School Eligibility The percent of identified students may be determined school-by-school, by a group of schools within the district, or in the aggregate for an entire district. % Identified Students = # of Identified Students as of April 1 x 100 Total Enrollment* as of April 1

Determining School Eligibility The percent of Identified Students is then multiplied by the USDA determined factor of 1.6 for SY *Enrollment is defined as number of students with access to the NSLP and SBP enrolled in the school as of April 1, 2014.

Determining School Eligibility The resulting answer is the percentage of total meals served reimbursed at the Federal free rate of reimbursement. The remaining percentage of meals is claimed and reimbursed at the paid rate.

Reimbursement Reiterated Reimbursement for meals served is based on the percentage of Identified Students times a multiplier* *Multiplier: (Range: )* 1.6 will be used through SY After that time, USDA is permitted to change the multiplier. Schools electing CEP will use the same multiplier for the entire four-year cycle.

Example School A has 100 students with access to the NSLP/SBP programs enrolled as of April of those students are determined to be in the “Identified Student” group School A has an Identified Student percentage of 50%.

Example 50% X 1.6 = 80% Free Reimbursement Rate, 20% Paid Reimbursement Rate.

Example At the end of the month, if you counted and served 10,000 reimbursable lunch meals, 8,000 (80%) will be claimed for free reimbursement and 2,000 (20%) for paid reimbursement.

Participation and Agreement Form An interested School Food Authority must submit a Community Eligibility Provision participation form and a participation worksheet to the department for approval.

Participation and Agreement Form If approved, the claiming percentages established are guaranteed for a period of four school years –May increase if the percent of Identified Students increases as of April 1 of the current school year.

Participation and Agreement Form A participating school may stop participating during the four-year cycle by notifying the department no later than June 30 of the school year prior to when it wants to return to normal counting and claiming procedures.

Direct Certification Participating schools may wish to continue to conduct direct certification on an annual basis May result in an increase in the percent of Identified Students, increases the percent of meals claimed as FREE in subsequent years.

Direct Certification This is not required, but recommended for schools that have NOT reached the threshold of 62.5% Identified Students, which allows them to claim 100% of meals at the FREE reimbursement rate.

Direct Certification Schools that have already reached the threshold of 62.5% of Identified Students – it is not necessary to conduct direct certification until the end of the 4-year cycle.

Second, Third and Fourth Year Procedures Initial percentage of Identified Students used for determining reimbursement in the First Year, or Percentage of Identified Students as of April 1 of the next year of the cycle, whichever is higher.

Non-Federal Funding Sources Any funds other than Federal reimbursement available to the nonprofit school food service account may be used, to cover the costs over the reimbursement of providing a no cost breakfast and lunch to all students. Examples: Profits from a la carte sales. Profits from catering sales. In-kind contribution funds from outside sources, such as volunteer services or a cash donation.

Advantages of Community Eligibility Provision ALL students receive a no-cost breakfast and lunch. Eliminates overt identification issues for students. Improves nutrition to students at risk. Potential for attendance rate and test score improvement.

Advantages of Community Eligibility Provision Reduces paperwork at the school district level. Simplifies meal counting and claiming. Provides potential labor savings. Increases breakfast and lunch participation.

Disadvantages of Community Eligibility Provision Potential financial issues when less than 100% reimbursement is at the free rate SFA not collecting paper applications – to determine individual student economic status. School must identify other procedures to determine economic status of individual students.

Enrollment Period April 1 to June 30, 2014 close of business Call for more information Send Participation form and eligibility worksheet to

Title I, Part A Allocations Federal Title I funds are allocated through four statutory formulas that are based primarily on census poverty estimates and the cost of education in each state. The Community Eligibility Provision should not affect the total amount of Title I funds that a district receives. Community Eligibility Provision program participation affects how Title I funds are allocated to each school building.

Title I Part A in District Allocations Districts must use common poverty metric for all schools.

Measures of Poverty CEP Reimbursement Percentage (CEP schools) = Free and Reduced Lunch Counts (Non-CEP schools) Directly certified through SNAP percentage (CEP and Non-CEP Schools)

Title I CCIP Building Eligibility Page Options All districts that do not have CEP schools Free and Reduced Price Meals Student Count

Title I CCIP Building Eligibility Page Options Districts have CEP and Non-CEP schools Non-CEP schools: Free and Reduced Price Meals Student Count CEP schools: CEP Reimburse %

Title I CCIP Building Eligibility Page Options Districts have CEP and Non-CEP schools Districts have all CEP schools Percentage of students directly certified through SNAP

Where did the data on Title I CCIP Building Eligibility Page come from? Claims Reimbursement and Reporting System. The load for Fiscal Year 2015 is based on the October 2013 MR81 report.

Example Questions to Discuss

Can a larger per-pupil allocation be given to the school with a greater percentage of Identified Students to determine its allocations? Yes.

District follows Title I within-district allocation requirements Careful analysis needed Special focus for districts that have a combination of Community Eligibility Provision and non-Community Eligibility Provision schools.

If a district used a grouping of schools or the whole district as a group for Community Eligibility Provision to determine U.S. Department of Agriculture claiming percentage, can this percentage be used to determine Title I school allocations? No.

There must be a poverty percentage determined for each individual school. Although two or more schools are grouped for Community Eligibility Provision to determine the U.S. Department of Agriculture claiming percentage, for Title I purposes, each school would be ranked by their individual percentages.

How should a Community Eligibility Provision community school report Economically Disadvantaged Student data to the School Options Enrollment System?

Direct certify* by using the direct certification software provided by the Office of School Nutrition Students’ parents or guardians complete the Household Information Survey form. *All siblings of students that are directly certified are also eligible.

How should districts code their students from CEP schools for Accountability purposes in EMIS? Districts are advised to code all of their students from CEP participating schools as economically disadvantaged in EMIS.

Do community schools differentiate economically disadvantaged student data between EMIS and SOES? Yes. EMIS: All students are reported as economically disadvantaged. SOES: Only direct certified and students certified through Ohio household income verification form are reported as low income.

Web Resources education.ohio.gov Search keywords: Community Eligibility Provision

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