Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
Date: April 2014
To: School Nutrition Program Sponsors
Attention: Food Service Directors, Chief Business Officials, and District Superintendents
Reference: U.S. Department of Agriculture Food and Nutrition Service Policy Memoranda SP 32-2014, SP 21-2014, and SP 19-2014 at http://www.fns.usda.gov/school-meals/policy; Community Eligibility Proposed Rule at http://www.fns.usda.gov/sites/default/files/2013-25922.pdf
Subject: Community Eligibility Provision Application
This Management Bulletin (MB) provides information to local educational agencies (LEA) regarding the Community Eligibility Provision (CEP). Please review this MB prior to applying for participation in the CEP.
The CEP is a new four-year alternative school meal counting and collection Provision implemented as a result of the Healthy, Hunger-Free Kids Act of 2010. Beginning July 1, 2011, Illinois, Kentucky, and Michigan implemented the CEP as a pilot. Additional states were added to the pilot program in 2012 and 2013. Currently there are 11 states participating in the CEP. The California Department of Education (CDE) will make the CEP available to all LEAs statewide beginning in School Year (SY) 2014–15. Residential child care institutions may not participate in the CEP.
Benefits of the Community Eligibility Provision
The CEP is one of the federal Provisions to increase access to the National School Lunch Program (NSLP) and School Breakfast Program (SBP) while decreasing the administrative burden on the LEA. This is done specifically through an alternative method for claiming student meals in high poverty schools.
- The CEP allows all students to receive two nutritious meals at no cost to the household while reducing administrative costs and paperwork for the school.
- Schools on the CEP do not collect and certify NSLP applications to determine meal eligibility or complete the annual application verification process.
- Meal lines move faster because staff will not have to categorize each meal served as free, reduced-price, or paid.
- Students that have access to meals and nutrition tend to perform better academically, have better health, and maintain better school attendance.
- Issues regarding the overt identification of students’ meal benefit issues are eliminated.
- Breakfast and lunch participation increases.
Identified Student Percentage
The identified student percentage (ISP) is the percentage of students who qualify for a meal at no charge without completing meal applications, based on a school or a group of schools enrollment as of April 1 of the school year prior to participation in the CEP. This percentage includes all students who are directly certified for meals at no cost on the basis of their receiving CalFresh, California Work Opportunity and Responsibility to Kids (CalWORKS), or the Food Distribution Program on Indian Reservations benefits, and all other students in the same household to whom program benefits are extended. Also included are students certified as homeless, migrant, runaway, foster, and/or Head Start, and nonapplicants approved by local officials.
A new ISP may be established each year. In the first year of the four-year cycle, the LEA would use the ISP as of April 1 of the school year prior to the start of the CEP. In the second, third, and fourth years of the cycle, the LEA would have discretion to use either the ISP from April 1 of the preceding year or to use the ISP from year one, whichever is higher. The ISP will never be lower than the ISP established in the first year of the cycle. However, the ISP will not automatically increase to the higher ISP in the second, third, and fourth year of the cycle. The ISP will revert to the first year’s ISP at the end of each school year, unless the LEA submits a request to increase the ISP and it is approved by the CDE each school year.
Claim reimbursement is based on the ISP and a multiplier factor (multiplier) established by the U.S. Department of Agriculture (USDA). To determine the number of meals served to be reimbursed at the free rate, LEAs must multiply the ISP by the multiplier, which is currently 1.6. The remaining meals served are reimbursed at the paid rate, and no meals are reimbursed at the reduced-price rate.
For example, a school or a group of schools with an ISP of 50 percent would be reimbursed at the free rate for 80 percent of the breakfasts and lunches it served (50 percent x 1.6 = 80 percent), and the remaining 20 percent of meals served would be reimbursed at the paid rate. If the product of the calculation of meals to claim at the free reimbursement rate exceeds 100 percent, the free claiming percentage is capped at 100 percent. Schools, or a group of schools, with an ISP of 62.5 percent or higher are eligible to be reimbursed at the free meal rate for all meals served when using a multiplier of 1.6 (62.5 percent x 1.6 = 100 percent).
The USDA does not intend to change the multiplier for SY 2014–15. Schools electing to participate in the CEP would maintain the same multiplier for the entire four-year cycle.
Group of Schools
An LEA is eligible to participate in the CEP for a school or a group of schools. For a group of schools, the ISP is calculated with the total of identified students for that group of schools. Only schools in the same LEA can be grouped together for purposes of determining eligibility. When participating by group(s) there must be at least two school sites per group and there is no maximum number of schools that can be in a group. However, each site can only be in one group. The group(s) should be identified as Group 1, Group 2, etc. on the Policy Statement Addendum for the Community Eligibility Provision (Form SNP-19).
The CEP allows a school or a group of schools to participate in the CEP for an additional “grace year.” A school or a group of schools participating in the CEP that have an ISP lower than 40 percent, but equal to or greater than 30 percent as of April 1 in year four of the four-year cycle, would be allowed to continue the CEP for a grace year. The grace year is outside of the four-year cycle. Reimbursement for schools in a grace year would be based on the ISP as of April 1 in year four of the current four-year cycle.
To be eligible to participate in the CEP, the LEA must:
- Have an ISP of at least 40 percent as of April 1, 2014 for a school or a group of schools
- Agree to serve free breakfast and lunch to all children in the participating school(s)
- Have a record of administering the NSLP or SBP in accordance with program regulations
- Count total lunches and total breakfasts served to students daily
- Not collect household applications for free and reduced-price meals
- Agree to deposit nonfederal funds in an amount equal to the difference between federal reimbursement and the cost of serving lunches and breakfast at no charge to all participating children into the nonprofit school food service account
LEAs must complete a Form SNP-19 to amend their original Meal Count and Collection Procedures on file. The form is located in the Child Nutrition Information and Payment System (CNIPS) in the Download Forms section.
Form SNP-19 must be submitted to the CDE no later than June 30, 2014 [Note: extended to August 31, 2014], for LEAs to participate in the CEP for school year 2014–15. A copy of the documentation to support the ISP as of April 1, 2014, must be submitted for each school or group of schools requesting to participate in the CEP during the school year starting July 2014.
Once the form has been approved by the CDE, the LEA will be required to update the Provision section of site applications in the CNIPS for each school approved for the CEP.
Participation in the CEP will cover a period of four years. The LEA may stop participating at any time as long as the NSD has been notified. The LEA must submit a revised site application in the CNIPS and updated Meal Count and Collection Procedures form to the CDE and provide advance notification to households when returning to standard meal count and collection.
To learn more about the CEP, please visit the CDE CEP Web page at http://www.cde.ca.gov/ls/nu/sn/cep.asp. Included on the CDE CEP Web page is a Reimbursement Estimator created by the USDA. The CDE recommends that LEAs interested in applying for the CEP determine if this Provision is a good financial decision for a school or a group of schools by completing the USDA Reimbursement Estimator.
If you have any questions regarding this MB, please contact your School Nutrition Programs (SNP) County Specialist. The SNP County Specialist list is available in the CNIPS Download Forms section, titled Caseload SNP. You can also contact an SNP Office Technician by phone at 916-322-3005, 916-322-1450, or 800-952-5609 and they will direct your call.