1. Community Eligibility Provision (CEP)
11/11/2018
Community Eligibility Provision (CEP)
Office of School Nutrition
Julie Griffith, MPH, RD
March 2015

2. 11/11/2018
Objectives
Provide an overview of the USDA’s Community Eligibility Provision (CEP)
Identify eligibility requirements
Provide information regarding SY implementation
Describe Colorado’s Success with CEP
Questions & Answers
Community Eligibility Provision (CEP) 2

3. The Link Between Nutrition and Education
11/11/2018
The Link Between Nutrition and Education
When a child’s nutritional needs are met, the child is more attentive in class, has better attendance and fewer disciplinary problems
Children who participate in school nutrition programs have superior nutritional intakes compared to those who bring lunch from home or otherwise do not participate
Low-income children who eat school breakfast have a better overall diet quality than those who eat breakfast elsewhere or skip breakfast
Source: FRAC: 3

4. 11/11/2018
What is the CEP?
Statutory requirement from the Healthy, Hunger-Free Kids Act of 2010
Provides an alternative to household applications in the NSLP and SBP
Allows schools with a high percentage of directly certified free students to serve free meals to all enrolled students
Eliminates burden of collecting household applications
District makes the decision to participate based on eligibility
CEP is designed to be easy for a school or district to adopt
Proposed Rule: Eliminating Applications Through Community Eligibility as Required by the HHFKA
The Community Eligibility Option was included in Section 104(a) of the Healthy, Hunger-Free Kids Act of 2010.
The main purpose of this regulation is to provide an alternative to the household eligibility applications.
NSLP – National School Lunch Program
SBP – School Breakfast Program 4

5. 11/11/2018
General Facts
Participating schools must meet a threshold of students directly certified (initially 40%) and agree to serve all meals free
No household applications are submitted for any students
State agencies are required to annually notify eligible SFAs
Claims are based on percentage of enrolled students directly certified multiplied by a factor of 1.6
An SFA may participate in CEP for some or all schools
Eligible LEAs/schools agree to serve all students free lunches and breakfasts for 4 successive school years
CEP is a four-year reimbursement option, which operates similar to Provision 2.
Eligible SFAs and individual schools may opt in or out of CEP each year. 5

6. CEP Benefits Students/Parents Enjoy free, healthy meals
11/11/2018
CEP Benefits
Students/Parents
Enjoy free, healthy meals
No household application is required
No stigma attached with a free meal
Schools
Reduced paperwork
Streamlines meal service operations
Less time waiting in lines and more time eating
In CEP schools, all students have access to free, healthy meals at school. When everyone getting free meals is the norm, there’s no stigma attached to getting a free meal, so participation tends to increase.
There are also benefits for parents -- they don’t have to complete a household application, worry about keeping enough money in meal accounts, or worry about whether their child has an opportunity to eat at school.
And, finally, for schools, the administrative burden is relieved by not having to process applications, but meal service operations can be streamlined and lunch lines move faster so kids have more time to eat. That means less food is thrown away and kids are better nourished. 6

7. Definitions Enrolled students Identified students
11/11/2018
Definitions
Enrolled students
Those students who are enrolled in and attending schools participating in the CEP and who have access to at least one meal service daily
Identified students
Those students who are certified for free meals NOT through individual household applications
Supplemental Nutrition Assistance Program (SNAP)
Homeless/Runaway
Migrant
Foster
Head Start
Non-applicant students approved by LEA officials
For more information regarding categorical eligibility and direct certification, please refer to the August 2014 Eligibility Manual for School Meals located on the OSN website: 7

8. How is the Identified Student Percentage Calculated?
11/11/2018
How is the Identified Student Percentage Calculated?
Identified student percentage (ISP)
Eligible SFAs/Schools
SFAs/Schools with an ISP of at least 40%
Potentially eligible SFAs/School
Schools with an ISP of at least 30% but less than 40%
# of Identified Students
Total Number of Enrolled
Students
X 100 8

9. 11/11/2018
How are meals claimed?
ISP = # of identified students/# of enrolled students x 100
Multiply by a factor of 1.6
Result  Percentage of total meals served at the federal free rate
Remaining percentage of total meals is reimbursed at the federal paid rate
Example:
Identified Students = 250 Enrolled Students = 500
250/500 x 100 = 50%
50% x 1.6 = 80% = free 20% = paid
Definition of “identified student percentage” – the percentage determined by dividing the number of “identified students” as of a specified time period by the number of “enrolled students” as of the same period of time and multiplying by 100. 9

10. Meal Reimbursements with CEP
11/11/2018
Meal Reimbursements with CEP
The reimbursement rate for both lunch and breakfast is determined by multiplying the percentage of Identified Students by a 1.6 multiplier. The resulting number is the percentage of meals reimbursed at the “free” reimbursement rate, with the rest being reimbursed at the “paid” rate.
Identified Student Percentage (ISP)
Percentage Free
Percentage Paid
40%
64%
36%
45%
72%
28%
50%
80%
20%
55%
88%
12%
60%
96% 4%
62.5%
100% 0%
This chart shows that the higher the ISP, the higher percentage of students who will receive the free reimbursement rate. There is incentive for SFAs and schools to increase their direct certification rates as much as possible. 10

11. SY2015-16 Important Dates April 1st May 1st April 15th April 10th
11/11/2018
SY Important Dates
April 1st
SFAs collect date on identified and enrolled students for each school
April 10th
SFAs submit collected data via claim system
April 15th
OSN notifies SFAs of districtwide eligibility status
May 1st
OSN posts SFAs districtwide and school level lists on website
Please reference the CEP Data Reporting document on the Provisional Programs webpage which includes instructions on how to submit CEP data for your district. 11

12. 11/11/2018
Other Factors
Each year of the 4-year cycle, SFAs or schools may use the ISP from the first year, or the updated ISP, whichever is higher
SFAs are required to submit a CEP Request Form no later than June 30th to begin CEP
SFAs choosing CEP must consider costs
SFA must pay the difference between serving meals at no charge and the federal reimbursement
Example: Revenue from a la carte sales or other revenue 12

13. Potential Implementation Issues
11/11/2018
Potential Implementation Issues
Impacts of the absence of student level poverty data used to distribute other assistance funding
Title I
Potential redistribution of school-level Title I funds
CEP does not impact the total amount of Title I, only the distribution
Need for alternative data for state and local funding formulas
Family Economic Data Survey
E-rate discount level determination
CEP schools may use the free claiming percentage
Local SFAs and schools will need to work with school administrators when considering the CEP and have discussions about October 1 data, Title I funding, potential for use of socioeconomic surveys, and E-rate discount level determination.
There are several resources regarding these topic on the OSN website under Provisional Programs - Community Eligibility Provision. 13

14. Colorado’s Success with CEP
11/11/2018
Colorado’s Success with CEP
Colorado SY
8 SFAs participated
6 districtwide
1 group of schools
1 individual school site
Feedback
Higher participation
Increased revenue
Support from administration
No applications
Counting and claiming process simplified
SY was the first year that Colorado implemented CEP.
A total of 8 SFAs chose to implement the CEP; 6 districtwide, 1 with a group of schools and 1 with one school site.
Feedback has been generally positive, especially for those SFAs that implemented CEP districtwide. Reports included increased participation, increased revenue, support from the administration and community, less paperwork for staff and families and a simplified meal count process.
The one barrier for Colorado is the requirement for households that are not directly certified to complete a Family Economic Data Survey Form for the district to obtain at-risk funding. This topic should be discussed with school administrators prior to choosing to implement the CEP. 14

15. 11/11/2018
Questions and Answers 15

16. What impact will CEP have on other school nutrition programs?
11/11/2018
What impact will CEP have on other school nutrition programs?
Other school nutrition programs will be able to utilize the percentage of free meals to determine their eligibility.
Summer Food Service Program (SFSP)
Seamless Summer Option (SSO)
Fresh Fruit and Vegetable Program (FFVP)
Afterschool Care Snack Program (ACSP) 16

17. How will the meal claiming process work?
11/11/2018
How will the meal claiming process work?
For CEP schools, the SFA will need to consolidate daily total reimbursable meal counts into monthly totals by site for breakfast and for lunch
The claiming system will use the SFA’s approved percentages for free and paid to automatically calculate the numbers of free and paid reimbursable meals for breakfast and lunch
Be sure to maintain proper documentation for meal counts for review purposes 17

18. What paperwork is required?
11/11/2018
What paperwork is required?
List of total enrolled students with access to NSLP and SBP as of April 1, 2015
List of identified students with access to NSLP and SBP as of April 1, 2015
Direct certification match results
Documentation for extended eligibility to additional children in a household with directly certified students
Lists of homeless, migrant, runaway, Head Start, foster (on a list from the county), and students determined eligible by the appropriate authority figure
Documents to support daily and monthly meal counts 18

19. Is Verification required with CEP?
11/11/2018
Is Verification required with CEP?
SFAs who implement CEP districtwide do NOT have to complete the verification process
Still need to complete the Verification Collection Report annually
SFAs with only some of their schools in the CEP will have to complete verification for the schools not operating under the CEP 19

20. What happens when a student transfers to a non-CEP school?
11/11/2018
What happens when a student transfers to a non-CEP school?
The student is not automatically free
New school must process a household income application or directly certify the student
School is encouraged to provide free meals to the student until an eligibility determination is made 20

21. 11/11/2018
OSN Resources
Please visit the Office of School Nutrition Provisional Programs webpage for additional resources. 21