1. The Community Eligibility Provision (CEP)
Good afternoon everyone and thanks for taking time out of your busy schedule to join us for this webinar. For those of you who may not know me, my name is Stephanie Robinson and I am the Director of the School Support Division for the Office of Child Nutrition. Today, I will present to you detailed information about the long awaited Community Eligibility Provision that was phased in over a period of three years in ten states, beginning in As many of you know we have developed a webpage devoted to this Provision, where you can download important information and resources. We will also place the webinar slides from today on that page later this week. Today’s webinar is in listen only mode. We will have some time at the end of the webinar for questions. You may also contact me or the School Support Help Desk at any time should you have questions.
Office of Child Nutrition
12/1/2018

2. The Community Eligibility Provision (CEP)
We will cover:
Overview of the CEP
Eligibility Requirements
Determining Eligibility and Federal Reimbursements
Reporting requirements for all SFAs
Due April 15, 2014
How to apply
During today’s, webinar we will cover the following information:
First, I will provide an overview of the Community Eligibility Provision
I will discuss the Eligibility Requirements
Next, you will learn how you will determine school and district level Eligibility and your potential federal Reimbursements under CEP
Lastly, I will talk about reporting requirements for all School Food Authorities that are due by April 15th
And, How to apply with the State Agency
12/1/2018

3. The Community Eligibility Provision (CEP)
Section 104(a) of the Healthy, Hunger Free Kids Act of 2010 amended Section 11(a)(1) of the Richard B. Russell National School Lunch Act (42 U.S.C. 1759a(a)(1)) to provide an alternative to household applications for free and reduced price meals in high poverty local educational agencies (LEAs) and schools. This alternative is referred to as the Community Eligibility Provision (CEP).
The Healthy, Hunger Free Kids Act of 2010 amended the National School Lunch Act to provide an alternative to household applications for free and reduced price meals in high poverty local educational agencies (LEAs) and schools. The alternative is referred to as the Community Eligibility Provision. Throughout this presentation I will refer to the Community Eligibility Provision as CEP.
12/1/2018

4. The Facts About CEP
Any school participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) and meeting the eligibility criteria to elect the CEP may participate.
CEP is a four-year reimbursement option for eligible LEAs and schools that have an Identified Student Percentage (ISP) of 40% of higher.
LEAs and schools may opt in or opt out each year.
Must notify the SA no later than June 30th of the prior school year
Here are some of the Facts about this Provision
Districts that have an agreement with the State agency (SA) to participate in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) and meet the eligibility criteria may participate in this provision
CEP is a four-year reimbursement option for eligible districts and schools that have an Identified Student Percentage (ISP) of 40% of higher. Please keep in mind that this is not your free/reduced percentage. I will clearly define the Identified Student Percentage later in the presentation.
LEAs and schools participating in CEP may opt in or opt out each year.
A participating district or school may stop participating in the CEP during the four‐year cycle by notifying the State agency no later than June 30th of the school year prior to when they want to return to normal counting and claiming procedures.
12/1/2018

5. CEP Requirements
Meet a minimum level (40%) of identified students for free meals in the year prior to implementing the CEP;
Agree to serve free lunch and breakfast meals to all students;
Not collect free and reduced price applications from households in participating schools;
Maintain a total count of breakfast and lunches served to students at the point the students receive the meal.
Agree to cover with non-Federal funds any costs of providing free meals to all students above amounts provided in Federal assistance.
Districts and schools electing to participate in the Community Eligibility Provision must meet specific program requirements. Participating schools must:
Meet a minimum level (40%) of identified students for free meals in the year prior to implementing the CEP;
Agree to serve free lunch and breakfast meals to all students;
Not collect free and reduced price applications from households in participating schools. Again, I want to emphasize that School Food Service Personnel are not permitted to collect or process applications for students in CEP participating schools.
CEP schools must maintain total counts of breakfast and lunch meals served to students at the point of service
And agree to cover with non-Federal funds any costs of providing free meals to all students above amounts provided in Federal assistance.
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6. Non-Federal Funding Sources
What may be counted as “funding from non-Federal sources”?
Any funds other than Federal reimbursement available to the nonprofit school food service account may be used.
Examples of non-Federal sources include, but are not limited to:
profits from extra food sales,
cash donations,
and in-kind contribution funds from outside sources such as volunteer services.
Non-Federal Funding Sources-Any funds other than Federal reimbursement available to the nonprofit school food service account may be counted as funding from non-Federal sources. Please note that, similar to Provision 2 and 3, 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 include, but are not limited to: profits from extra food sales, cash donations, and in-kind contribution funds from outside sources such as volunteer services.
12/1/2018

7. Determining School Eligibility
School eligibility is based on the number of students who meet the “Identified” definition. “Identified students” are those students approved as eligible for free meals who are not subject to verification. This includes, students directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP). The extension of benefits to students within the same household are also classified as “Identified Students” for the purpose of CEP.
Participation in the Community Eligibility Provision is determined based on the number of students who meet the “Identified” definition. “Identified students” are those students approved as eligible for free meals who are not subject to verification. This includes, students directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP). The extension of benefits to students within the same household are also classified as “Identified Students” for the purpose of CEP.
12/1/2018

8. Other “Identified Students”
The Identified Student definition also includes those students who are directly certified through TANF and the Food Distribution Program on Indian Reservations. As well as, children experiencing homelessness who are on the local liaison’s list; income eligible Head Start children; pre-K Even Start children, migrant youth, runaways and foster children who are certified through means other than a household application. Students who are categorically eligible based on a case number submitted through a free and reduced price application are NOT included in this definition.
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9. Multiplier: FNS is permitted to change between 1.3 and 1.6.
CEP Reimbursement
Reimbursement for meals served is based on claiming percentages derived from the identified student percentages times the multiplier*.
The claiming percentage established for a school is guaranteed for a period of four school years and may be increased if direct certification percentages rise for that school, group of school, or district.
Reimbursement for breakfast and lunch meals served is based on claiming percentages derived from the identified student percentages times the multiplier. The claiming percentage established for a school is guaranteed for a period of four school years and may be increased if direct certification percentages increase. The current multiplier is 1.6. FNS is permitted to change the multiplier to a number between 1.3 and If the multiplier is changed, schools electing the CEP will keep the same multiplier for their entire four-year cycle and do not have to implement changes to the multiplier until their next cycle if the CEP is elected again. Any change to the multiplier would be communicated in advance of implementation, through the Federal Register. The State Agency will notify you of such changes.
Multiplier: FNS is permitted to change between 1.3 and 1.6.
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10. Determining School Eligibility
The Identified Student Percentage (ISP) may be determined by an individual school, a group of schools in the LEA, or the entire LEA if all schools participate
In any case, the ISP must be 40% or higher
Rounding is not permitted.
Note: Not all schools in the group or in the LEA if electing for the entire LEA have to meet the 40% threshold.
A school district can determine the percent of Identified Students by individual schools, a group of schools within the district, or as an aggregate for all schools if all schools in the district are participating.
In any case, the Identified Student Percentage must be 40% or higher.
When determining the percentage of identified students you should NOT round. The percentage must be at least 40% to be eligible. A percentage of 39.98% does NOT meet the threshold.
Please note that not all schools in the group or in the LEA if electing for the entire LEA have to meet the 40% threshold as long as the group as a whole has an Identified Student Percentage of 40 percent or higher. This allows for some schools to be below the 40% threshold as long as the aggregate of the group of schools meets the threshold. The LEA must determine whether they can operate the program given the expected level of Federal reimbursement and other non-Federal resources available to them.
I will discuss more about “grouping” later in the presentation.

11. Determining School Eligibility and Federal Reimbursement
ISP = # of Identified Students as of April 1 x 100
Total Enrollment* as of April 1
****The ISP must be 40% or greater.****
The Identified Student Percentage (ISP) is then multiplied by the USDA determined factor of 1.6.
You will determine the ISP by dividing the total # of Identified Students as of April 1 by the Total Enrollment as of the same date and multiplying the total by The result must be 40% or greater to be eligible. Keep mind that total Enrollment is defined as the number of students with access to the NSLP and SBP enrolled in the school as of April 1st, not just those students participating in the program. Next you will multiply the result by 1.6.
*Enrollment is defined as the number of students with access to the NSLP and SBP enrolled in the school as of April 1, 2014
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12. Determining Federal Reimbursement
The resulting answer is the percentage of total meals served reimbursed at the federal free rate of reimbursement. The remaining percentage of meals are claimed and reimbursed at the paid rate.
The resulting answer is the percent of total meals served that will be reimbursed at the Federal free rate, the remaining percentage of meals are claimed and reimbursed at the paid rate.
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13. Meal Claiming Percentage Examples
District A has 2000 students with access to the NSLP/SBP programs as of April 1.
1000 of those students are determined to be in the “Identified Student” group
District A has an Identified Student Percentage of 50%
1000/2000 = .50 x 100 = 50%
Now we will look at an example. District A has 2000 students with access to the NSLP/SBP programs as of April of those students are determined to be in the “Identified Student” group.
District A will divide 1000 by 2000 and multiply the total by 100. District A has an Identified Student percentage of 50%. Next, the district will multiply the Identified Student Percentage by the 1.6 multiplier. The result is 80%. Therefore, 80% of the meals claimed will be reimbursed at the Federal Free Rate, and 20% will be reimbursed at the Paid Rate.
50% x 1.6 = 80%
80% Reimbursement at the Free Rate
20% Reimbursement at the Paid Rate
12/1/2018

14. Meal Claiming Percentage Examples
ISP x Multiplier (1.6)
40% x 1.6 = 64% Free, 36% Paid
60% x 1.6 = 96% Free, 4% Paid
62.5% x 1.6 = 100% Free
Free Rate $3.01, vs. Paid Rate $0.36
As you can see from the examples on this slide, a school or district with an ISP of 40% would only be able to claim 64% of their total meals at the free rate, while a school or district with an ISP of 62.5 or greater would be able to claim all meals at the free rate. A district with an ISP of 60% would claim 96% of their meals at the free rate and remaining 4% at the paid rate. The decreased administrative burden would make this highly feasible for a district.
12/1/2018

15. Grouping Schools within a District
School districts decide whether schools will participate individually, as part of a group, or district-wide.
Schools may be grouped in any way, as long as the group as a whole has an ISP of 40 percent or higher.
The ISP for a group of schools is calculated as follows:
The sum of the identified students for the entire group of schools divided by the sum of the total student enrollment for the entire group of schools
Districts can group schools in order to maximize federal reimbursements.
Now we will move on to grouping school within a district. As I previously mentioned, school districts may choose whether qualifying schools will participate in community eligibility individually, as part of a group, or district-wide. If schools are grouped, the Identified Student Percentage and free claiming percentage are calculated across the entire group. Schools may be grouped any way a district chooses, as long as the group as a whole has an Identified Student Percentage of 40 percent or higher. All schools in the group do not have to meet the 40% threshold as long as the group as a whole has an Identified Student Percentage of 40 percent or higher. The identified student percentage for a group of schools is calculated by taking the sum of the identified students for the entire group of schools divided by the sum of the total student enrollment for the entire group of schools. Districts can group schools in order to maximize federal reimbursements. One way to achieve this is to rank them by their Identified Student Percentage and form a group based on the free claiming percentage for the group as a whole.
12/1/2018

16. Grouping Schools within a District
This example lists four schools in a district. The first four rows indicate the Identified Student Percentage and free claiming percentage for each school if it were to participate individually in Community Eligibility Provision . If these schools participated individually in community eligibility, Schools A, B, and C would be able to claim 92 percent of their meals at the free rate and School D would be able to claim 85 percent of its meals at the free rate. The last row indicates the Identified Student Percentage and free claiming percentage if the schools were to participate in community eligibility as a group. All four schools would be able to claim 90 percent of their meals at the free rate, the remaining 10 percent would be reimbursed at the paid rate. By using Identified Student Percentages to group schools, school districts may be able to help low- income schools participate in community eligibility that might not receive adequate federal reimbursements if they participated individually.
12/1/2018

17. CEP Reimbursement Estimator
Allows school districts to estimate the federal reimbursement they will receive, taking into account anticipated participation increases and meal costs.
Developed by USDA
Excel Spreadsheet
Easy to use
Results can be printed
CEP Reimbursement Estimitator.xls
USDA has developed a calculator that allows school districts to estimate the federal reimbursements they will receive as to assess the financial viability of their school meals program under this Provision. The tool is in Excel, its easy to use and the results can be printed for your files and future reference.
Now I will show you how simple it is to enter data into the spreadsheet. (CLICK LINK) If you will recall our example from earlier. I will enter the same data here in the spreadsheet.
1000 Identified Students
2000 Enrolled
25,000 lunch
18,000 Breakfast
Select rates (2.95 paid lunch, .30 free lunch, 1.89 free breakfast, .28 paid breakfast)
Most of you have been approved for PBR so I will also select 6 cents.
Then do:
1000 IS/2510 enrollment= 39.84
As you can see the spreadsheet will not let you go on to the next step if the required Identified Student Percentage is not achieved.
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18. Updating the Claiming Percentage
A new “Identified Student” percentage may be established each year
During the 2nd, 3rd and 4th years, the LEA/school may select the higher of the identified student percentage from:
the year directly prior; OR
the year prior to the first year of operating CEP
A new “Identified Student” percentage may be established each year
During the 2nd, 3rd and 4th years, the LEA/school may select the higher of the identified student percentage from:
the year directly prior; OR
the year prior to the first year of operating the provision
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19. New Cycle
Participating schools that meet the minimum ISP (40%) may begin a new four‐year cycle (pending SA approval) after the initial cycle concludes.
Districts/schools in year 4 with an identified student percentage of less than 40% but more than 30% may elect for an additional year (a grace year), with SA approval.
LEAs/schools that do not meet the threshold must return to normal counting and claiming procedures the following School Year
Pending SA approval, participating schools that continue to meet the minimum Identified Student Percentage may begin another four‐year cycle after the initial cycle ends. Participating schools that have an ISP less than 40% but more than 30% at the end of their four‐year cycle, may be approved to continue participation for one “grace year.” Districts and schools that do not meet the threshold must return to normal counting and claiming procedures the following School Year.

20. Household Notification
LEAs that have elected to participate in CEP for at least one site must notify the households of children attending CEP school(s).
LEAs may use this sample household letter to serve as the required notification.
Household Notifications: Districts participating in Community Eligibility for one school or more must notify the households of children attending CEP schools to inform them of the school’s participation in the provision. You may use the sample household letter found on our website to serve as your required notification.
12/1/2018

21. Direct Certification under CEP
CEP participating districts must continue to conduct direct certification at least three times annually.
Benefits
Increased Identified Student percentage
Number of meals claimed at the FREE rate in subsequent years increases
CEP participating districts must continue to conduct direct certification at least three times annually.
The Eligibility Manual states that Direct Certification matches must occur
At or around the beginning of the school year (i.e., July 1);
 Three months after the beginning of the school year; and
 Six months after the beginning of the school year.
More frequent matches are strongly encouraged.
Ongoing DC matches will help you increase your identified student percentage, the number of meals reimbursed at the free rate and fulfil USDA reporting requirements for the “Special Provision Match” between SNAP records and student enrollment records. This match must occur in or close to October, but must occur no later than the last operating day in October. You will receive more information about this reporting requirement from the State Agency via or mail.
Perform required
“Special Provision Match” requirements that must occur during the month of October
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22. Do districts electing the CEP conduct Verification?
No, since applications are not collected, LEAs are exempt from verification for the schools electing CEP.
NOTE: All LEAs, including LEAs with all schools exempt from verification requirements, must complete applicable sections of the Verification Summary Report
Do LEAs electing the CEP conduct verification?
Since applications are not collected, LEAs are exempt from verification for the schools participating in CEP. LEAs with some, but not all schools participating in the provision must still conduct verification of a sample of the applications collected from students in non CEP participating schools.
12/1/2018

23. Required Reporting for all SFAs
This information must be received by
the State Agency no later than April 15, 2014
All SFAs (except RCCIs), even those that do not wish to participate in CEP must provide the State Agency with School Level Identified Student Percentages (ISP).
ISP for each school in your district must be reflective of April 1, 2014
School Level Data Form, located on our website
submission preferred,
CEP School Level Data Form.xlsx
As result of the implementation of the CEP, school districts now have an additional reporting requirement. No later than April 15th all SFAs (except RCCIs), even those that do not wish to participate in CEP must provide the State Agency with Identified Student Percentages for each school in the district. The information must be reported on the School Level Data Form located on our website. Also, the information provided must be reflective of April 1, The State Agency request that you submit this information as an attachment if at all possible. Now I will show you the excel form.
CLICK THE LINK
12/1/2018

24. How do I apply for my SFA? This information is due to the MDE-OCN
To participate in CEP, an interested SFA must submit the following:
CEP Participation Form
CEP Participation Worksheet
This information is due to the MDE-OCN
for approval, no later than June 30, 2014
So, how do you apply? School Food Authorities (SFAs) interested in participating in the Community Eligibility Provision (CEP) for one or more schools must submit the CEP Participation Form and Participation Worksheet to the Office of Child Nutrition, no later than June 30th, Both documents and the submission instructions are available on the CEP webpage.
CEP applicants will receive notification of approval/denial from MDE-OCN within 30 days of receipt of your CEP worksheet and form. If documentation is received prior to the June 30th deadline, we will provide notification within 30 days of the due date. Incomplete documentation will delay the processing of your application.
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25. What else Needs to be Considered?
Participation in the CEP eliminates the need for Free
and Reduced Lunch forms for the purpose of the school meal program.
Impacts:
Title I programs
E-rate funding
MAEP funding
State funding for economically disadvantaged students
There are several factors that school districts must think through while considering the Community Eligibility Provision. With the absence of free and reduced school meal applications, other programs within your district will be drastically impacted. Representatives within the Department of Education from areas such as Federal Programs, Title I, E-Rate, Special Education, etc. will collaborate to address such issue. A web based meeting has been tentatively scheduled to take place on the 25th of this month. School District superintendents will receive formal invitations when this meeting is confirmed. There are also resources on our CEP webpage that you can share with the administrative team in your district.

26. Benefits of CEP
There are many benefits to Community Eligibility, as you can see on this slide. The provision has been successfully implemented by thousands of schools in the 10 states selected to pilot the program. Those states, districts, and schools have recognized the opportunity to create hunger-free schools in low-income communities. The first two years of implementation show that schools that implement community eligibility provide healthy meals to more children, with especially strong impacts on breakfast participation. This is a significant accomplishment as many schools are working to expand access to their underutilized school breakfast programs. Community eligibility gives schools a cost-effective way to serve all breakfast and lunch meals at no charge while, reducing paperwork and streamlining program operations, it frees up resources that schools can invest in improving meal quality.
12/1/2018

27. We are here to help YOU! Contact:
Stephanie N. Robinson, Division Director or
the School Support Division Helpdesk at:
Visit the CEP webpage at:
QUESTIONS
Lastly, I would like all of you to know that we are here to assist you throughout this process. Please feel free to contact our office at any time. You may also visit our CEP webpage for detailed instructions and resources. Thank you for your attendance and have a great day.
12/1/2018