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Determining Area Eligibility Based on School Data

Nutrition Services Division Management Bulletin
Purpose: Policy
To: Child Nutrition Program Sponsors Number: USDA-CNP-02-2013
Attention: Food Service and Program Directors Date: May 2013
Subject: Determining Area Eligibility Based on School Data
Reference: U.S. Department of Agriculture Policy Memos SP 06-2013, CACFP 03-2013, and SFSP 03-2013
Supersedes: Management Bulletin USDA-CNP-04-2011 (Revised) and U.S. Department of Agriculture Policy Memo SFSP 01-2011

This Management Bulletin (MB) provides guidance to Child Nutrition Program (CNP) sponsors regarding the use of school or census data to determine area eligibility in instances where school attendance areas may not accurately reflect the population of the school. This MB affects sites that are located in areas where the school district has an undefined attendance area. This MB supersedes the MB issued in June 2011, USDA-CNP-04-2011: Effects of Busing on Area Eligibility in Child Nutrition Programs (REVISED).


The previous MB mentioned above provided guidance from the U.S. Department of Agriculture (USDA) on situations where public schools routinely bused children from their neighborhood school to other schools. The busing of children to other schools caused the school meal data to inaccurately reflect the children living in the area. No other USDA guidance was available for other instances where school meal data was affected by moving, transferring, or busing children to alternate sites. 

New Qualifying Guidance for Affected Sites

When children in the public school system regularly attend schools outside a designated attendance area, the school meal data may not necessarily provide an accurate reflection of the children living in the attendance area of the school. Other instances that may affect school meal data are:

  • Children assigned to schools outside of their neighborhoods in order to achieve racial and economic diversity in the schools, often referred to as “busing”
  • Parents choosing the school within the school district that they wish to have their children attend, often referred to as “school choice”
  • Charter and private schools drawing students from multiple areas, resulting in school data that does not accurately reflect the economic conditions in the surrounding area

In school districts where busing or school choice policies are in place, Child and Adult Care Food Program (CACFP) and Summer Food Service Program (SFSP) sponsors located in a school site may always rely on the National School Lunch Program (NSLP) free and reduced-price meal data for that individual school. Additionally, in districts with defined school attendance areas and busing or school choice policies, school and non-school site eligibility may be determined based on the enrollment or attendance data obtained from either:

  • The school the children attend 
  • The school the children would have attended (i.e., the neighborhood school where the children live), provided “busing” or “school choice” policies were not in effect

CACFP and SFSP sponsors may determine a site to be area eligible under the second option described above when the School Food Authority (SFA) is able to document the percentage of children eligible for free and reduced-price meals at each school before and after students are reassigned. The sponsor must use the same method of determining site eligibility for all sites participating under a particular program to avoid duplicate counting.

Using Census Data to Qualify Sites

When school districts do not have defined school attendance areas, the use of school data is not permitted for non-school sites. In this case, census data must be used to determine area eligibility for the NSLP and the SFSP. Please note that census data may be used as a first choice for determining area eligibility for the NSLP and the SFSP, rather than using the options described above, even if school attendance areas are defined.

However, CACFP institutions participating in the at-risk, afterschool meal component of the CACFP may not use census data for purposes of determining area eligibility. As previously stated, if the proposed site is a school, the free and reduced-price meal data from the individual school site may be used to determine area eligibility. For non-school sites, however, if the school district does not have defined school attendance areas, the SFA should contact their CACFP Specialist.

If you have any questions regarding this MB, please contact your CNP specialist by phone at 916-445-0850 or 800-952-5609 or in the Download Forms section in the Child Nutrition Information and Payment System.

Questions:   Nutrition Services Division | 800-952-5609
Last Reviewed: Monday, August 3, 2015

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