1. Community Eligibility Option (CEO) and Title I Update Suzette Cook Title I Coordinator Office of Federal Programs West Virginia Department of Education December 11, 2012

2. Objectives Provide a review of the USDA’s Community Eligibility Option (CEO) Identify School Eligibility Requirements Review working knowledge of CEO and Title I Questions and Answers????

3. CEO Background Section 104(a) of the Healthy, Hunger Free Act of 2010 amended the Richard B. Russell National School Lunch Act to provide an alternative to household eligibility applications for free and reduced price meals in high poverty local educational agencies (LEAs) and schools. CEO is a four-year reimbursement option for eligible high poverty LEAs and schools, which began with the 2012-2013 school term. LEAs and schools may opt in or opt out each year. An LEA may participate in CEO for some or all schools in the LEA.

4. CEO Requirements for Schools As of April 1, determine the school has a minimum level (40%) identified students (NOT your free/reduced count) in the year prior to implementing the option. – April 1, 2013 for the 2013-2014 school year. Agree to serve no-cost lunches and no- cost breakfasts to all students for up to four consecutive years in approved schools.

5. CEO Requirements for Schools Agree to cover with non-Federal funds any costs of providing free meals to all students above amounts provided in Federal assistance. Do not collect free and reduced price applications from households in participating schools during the period of participation in the CEO. Maintain a total count of breakfasts and lunches served to students at the point(s) students receive meals.

6. Identified Students Identified students: – Directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) and the extension of benefits to students within the same household. – Homeless – Runaway – Migrant – Head Start – Foster Child

7. Identified Students The percent of Identified Students may be determined school-by-school, by a group of schools within the LEA, or in the aggregate for an entire LEA. % Identified Students = # of Identified Students as of April 1 X 100 Total Enrollment* as of April 1 *Enrollment is defined as number of students with access to the NSLP and SBP enrolled in the school as of April 1, 2013

8. Identified Students The percent Identified Students is then multiplied by the USDA determined factor of 1.6 for SY 2013- 2014. The resulting answer, capped at 100%, 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.

9. Ranking schools over 100% For Title I purposes, in the event that schools reach more than 100% for meal reimbursement purposes – even though meal reimbursement is capped at 100% - LEAs may continue to ‘rank’ schools that are over 100% in order to determine rank order, per pupil allocations, school allocations, etc.

10. CEO Reimbursement Reimbursement is based on claiming percentages derived from the percentage of Identified Students times a multiplier* established in the law. The claiming percentages established for a school in the First Year are guaranteed for a period of four school years and may be increased if direct certification percentages rise for that school/group of school/district. *Multiplier: (Range: 1.3-1.6)* 1.6 will be used through SY 2013-2014. After that time, USDA is permitted to change the multiplier. Schools electing CEO will use the same multiplier for the entire four-year cycle.

11. Example School A has 100 students enrolled as of April 1 50 of those students are in the “Identified Students” group School A has an Identified Student percentage of 50%. 50% X 1.6 = 80% Free Reimbursement Rate and 20% Paid Reimbursement Rate 80 students X per pupil expenditure = Title I school allocation

12. Example of Grouping Schools# of DC Students Enrollment% of Identified Students Qualify for CEO A6613349.62Yes B225937.29No Grouping A & B8819245.8Yes For Title I project purposes, the numbers and percentage rankings remain as individual school numbers. Do not apply the grouping average to the Title I school allocation process. The grouping procedure is used only for CEO purposes.

13. Impact on Other Programs It is important for all stakeholders to understand CEO prior to making the decision to participate and/or to anticipate issues that may arise. Schools that participate in CEO will not have a student meal application process. You will not know if Student A is eligible for free, reduced price, or paid meal benefits. All students in a Title I CEO school would be eligible for Supplemental Education Services and priority for public school choice would be based only on lowest-achieving students. Students in a CEO school are all classified as ‘Low SES’ for accountability purposes.

14. Title I Guidance from U.S. Dept. of Education Conference calls with Todd Stevenson; Title I, U.S. Dept. of Ed. Letter to Chief State School Officers

15. Example of Allocations with a combination of CEO/non-CEO schools 123456789 SchoolCEO (Y/N) Enroll- ment 5-17 needy students Multi- plier X 1.6 Identified Students Number Percent of needy students Per pupil amount Title I Allocation PurkeyN500475N/A47595%$500$237,500 Craw- ford Y6003501.656093%$500$280,000 SaxeN450400N/A40089%450$180,000 HypesN400200N/A20050%450 $90,000 CookN500100N/A10020%N/A0 TotalN/A2450N/A 1,73571%N/A$787,500 Without CEO – Crawford School is 58% poverty, drops to fourth in the Rankings and receives an allocation of $157,500.

16. Questions Submitted by Email – What happens with possible new counties/schools being added to CEO participation? What data will be used for ranking schools for Title I purposes? » Direct Certified student data from April 2013 will be used to add new counties/schools. Counties/schools currently in the project use their data from April 2012 – unless the April 2013 data would give them a higher reimbursement rate; then, they could use the April 2013 data. – What data will be used for the FY ‘14 Title I plan? » Same as above – What data will be used for personnel planning? » The Office of Child Nutrition will make the December 2012 data readily available for personnel planning for the FY ‘14 project. This data will allow counties to have the most recent data available for the ‘personnel season’. However, the April 2012 and/or April 2013 data will be used for the Title I school ranking as stated above.

17. Questions Submitted by Email – What will be the multiplying factor for next year? » The multiplier will remain at 1.6 for the 2013-2014 school year. It will actually remain at 1.6 for three more years for all schools that were in the project this year. After the 2013- 2014 school year, the USDA may reduce the multiplier for new counties/schools joining the program – but not lower than 1.3. – How should counties focus Title I services when schools of more than one programmatic level appear in the ‘above 75% poverty’ group after the multiplier is applied. For example, a middle school or a high school is in the rankings above 75%. » All schools above 75% poverty must be ‘grouped together’ and considered before serving any schools below 75%. All schools above 75% must be served in rank order – but there is no requirement that all schools above 75% be served.

18. Questions Submitted by Email – If a county has some schools in CEO now, and would choose to opt out for FY ‘14, how would those schools get data for Title I ranking purposes? » The Direct Certified Students information for April 2013 would be used to rank these schools. At the beginning of the school term, the lunch application process would be put back into place – this would provide data for the FY ‘15 project.

19. Work Time County Data – 2011-2012 Title I Schools – October 2012 (5-17) Free/Reduced and CEO lunch data – Direct Certified Data Total # of Direct Certified Students Total Student Count Percentage Direct Certified % Meals Claimed as Free

20. Application and Synthesis 1.Review your county’s list of Title I schools for 2012-2013. 2.Use the October 2012 5-17/CEO report to rank the schools in your county in order of percent needy – highest to lowest. 3.Use the CEO Direct Certified List to rank the schools in your county in order of percent needy – highest to lowest. 4.Compare the list from Number 2 to the list from Number 3. Are the schools in the same rank order? Identify differences noted. Pay particular attention to any schools that are above 75% needy. 5.Review the ‘projected’ Title I schools list for 2013-2014– determine if ‘grouping’ is a process that might be useful to the final determination of schools to be served.

21. Questions