Dear County and District Superintendents, Charter School Administrators:

2021−22 Guidance for Using the National School Lunch Program Application or the Alternative Household Income Form to Collect Data Used for Funding Allocations and P-EBT Eligibility

Under the summer meal programs, administered by the United States Department of Agriculture (USDA), schools may provide free meals to all students, and National School Lunch Program (NSLP) applications are not required. Due to the coronavirus pandemic (COVID-19), the USDA allowed schools to operate under summer meal programs rules in the 2020–21 school year and allowed local educational agencies (LEAs) to collect NSLP applications for the purpose of establishing student eligibility for Pandemic-Electronic Benefits Transfer (P-EBT) funds.

In California, NSLP applications are also used to identify students as low-income, referred to as “Free or Reduced-Price Meal (FRPM) eligible,” so that they may be included in LEAs’ Unduplicated Pupil Count (UPC) used to determine supplemental and concentration grants under the Local Control Funding Formula (LCFF). LEAs certify these data as part of the Fall 1 submission to the California Longitudinal Pupil Achievement Data System (CALPADS).  

On April 20, 2021, the USDA announced that schools may operate under the Seamless Summer Option (SSO), during the upcoming 2021−22 school year. The USDA announcement can be found on the USDA Food and Nutrition Service website at https://fns-prod.azureedge.net/sites/default/files/resource-files/COVID19NationwideWaiver85os.pdf [NOTE: The preceding web page URL is not currently working.]. As of the date of this communication, the USDA has not provided LEAs 2021−22 guidance that allows them to collect NSLP applications for P-EBT purposes; however, making such an allowance would be consistent with the guidance USDA provided in 2020−21.

Guidance for 2021−22

While the USDA has not officially stated whether schools operating under the SSO waiver may still collect NSLP applications, based on previous guidance and the obvious need for LEAs to collect NSLP applications for P-EBT purposes, the CDE believes that LEAs have two options for collecting the needed FRPM eligibility data in 2021−22 for LCFF and P-EBT:

• Collect the data using alternative household income forms. The LCFF statute established the Alternative Household Income form to collect the FRPM-eligibility status of students enrolled in schools that do not collect NSLP applications because they do not participate in NSLP, or because they operate an NSLP program under the Community Eligibility Provision (CEP) or Provision 2 or 3, which prohibits the collection of NSLP applications altogether or just in base-years. Data collected from alternative household income forms is acceptable for LCFF and P-EBT. The forms may be distributed and collected online and electronic signatures are acceptable.
• Collect the data using the NSLP application. LEAs collecting NSLP applications must adhere to all NSLP rules, which includes verifying a percentage of those applications.

The CDE will continue to keep LEAs informed as federal guidance is issued. In the meantime, Attachment A of this letter provides the FRPM eligibility requirements for LCFF and P-EBT, and guidance on which collection form to use based on meal program type. Other questions may be directed as follows:

• For questions related to LCFF funding and the alternative household income form, please contact PASE@cde.ca.gov.
• For questions about NSLP and SSO, please contact the School Nutrition Program Unit at SNPinfo@cde.ca.gov.
• For questions related to CALPADS, please contact the CALPADS Service Desk at calpads-support@cde.ca.gov.

Sincerely,

Kim Frinzell, Director
Nutrition Services Division                                   

Jerry Winkler, Director
Educational Data Management Division

JW/KF:pm

cc:
Chief Business Officers
Food Service Directors
CALPADS Administrators

Attachment A

2021−22 Supplemental Information on LCFF and P-EBT Eligibility Requirements and Meal Program Types

LCFF and P-EBT Eligibility Requirements

Eligibility Requirements for Local Control Funding Formula

For 2021−22, in order to be included in the Unduplicated Pupil Count (UPC) that determines supplemental and concentration grant funding under the Local Control Funding Formula (LCFF), a student must be identified in the California Longitudinal Pupil Achievement Data System (CALPADS) as enrolled on Census Day, October 6, 2021, and meeting one of the following criteria:

• Free and Reduced-Price Meal (FRPM) eligible based on one of the following:
• A Free Meal program record (181) or Reduced-Price Meal program record (182) in CALPADS with a start date on or before October 31, 2021, based on one of the following received or established on or before October 31, 2021:
• An alternative household income form
• A National School Lunch Program (NSLP) application
• A local direct certification match
• A direct certification match in one of the CALPADS 2021−22 monthly matches conducted through November 2021.
• A migrant, homeless, or tribal foster youth program record in CALPADS with a start date on or before Census Day, October 6, 2021.
• A foster youth on or before Census Day as identified through the statewide match or local match functionality in CALPADS.
• An English Learner (EL), identified in CALPADS on or before Census Day.

Local educational agencies (LEAs) are required to certify the data used to determine their UPC, by approving their Fall 1 CALPADS submission, which includes Report 1.17 – FRPM/English Learner/ Foster Youth Count in CALPADS. In order for the data to be used in First Principal Apportionment (P-1) LCFF funding calculations, the required records must be included in LEAs’ approved Fall 1 submission by the first certification deadline (December). To be used in Second Principal Apportionment (P-2) LCFF funding calculations, the required records must be included in LEAs’ certified Fall 1 submission by the close of the amendment window (January/February). Subsequent changes to CALPADS counts for LCFF can only be submitted through the audit process.

Eligibility Requirements for P-EBT

To be eligible for P-EBT, a student must be enrolled in a school that is participating in the NSLP or School Breakfast Program (SBP). All students enrolled in a participating school that is operating under a Community Eligibility Provision (CEP) or Provision 2 or 3 are eligible for P-EBT regardless of whether the student is individually eligible. Students enrolled in participating schools that are not operating under a provision must be “Free or Reduced-Price Meal (FRPM) eligible,” based on being directly certified or foster in CALPADS, or having one of the following program records in CALPADS valid during the school year: Free Meal (181) or Reduced-Price Meal (182) that is based on an NSLP application, Alternative Household Income form, or local direct certification, Migrant (135), Homeless (191), or Tribal Foster (193). The data used to identify whether students are eligible for P-EBT are based on the most updated cumulative data pulled from the CALPADS Operational Data Store (ODS) at announced times, and is not based on the point-in-time data certified in CALPADS on Census Day.

NSLP Application and Alternative Household Income Form

Free and Reduced-Price Meal Application

Schools are only allowed to collect data via the National School Lunch Program (NSLP) application if they are participating in NSLP or SBP, and they are not operating under CEP. Schools operating under a Provision 2 or 3 must collect NSLP applications only in base-years. Schools must evaluate and approve applications and are required to verify a specified percentage of applications within specified timeframes.

Alternative Household Income Form

The LCFF statute established the Alternative Household Income form to collect the FRPM-eligibility status of students enrolled in schools that do not collect NSLP applications because they do not participate in NSLP or SBP, or because they operate an NSLP and/or SBP under CEP or Provision 2 or 3, which prohibits the collection of NSLP applications all together or just in base-years. Data collected from alternative household income forms is acceptable for LCFF and P-EBT.

Alternative house income form prototypes can be found on the California Department of Education (CDE) LCFF Frequently Asked Questions web page at: https://www.cde.ca.gov/fg/aa/lc/lcfffaq.asp#PROV2and3.

Alternative household income forms may be distributed and collected online, and electronic signatures are acceptable. LEAs may also complete an alternative household income form on behalf of a student’s household by collecting the required information over the telephone provided the LEA documents: 1) the date, time, and name of the student’s adult household member spoken to, and 2) the date, time, name, and signature of the LEA staff member collecting the information.

Information on Collecting FRPM-Eligibility for LCFF and P-EBT Based on Meal Program Type

Schools Operating NSLP and SBP in a Community Eligibility Provision

All students enrolled in a school operating NSLP and SBP under CEP receive free meals, and schools are prohibited from collecting NSLP applications. Schools participating in CEP receive reimbursements for meals served based on the percentage of students who have been directly certified each year (in a four-year cycle, plus grace year).

LCFF: Since CEP schools are prohibited from collecting NSLP applications, California Education Code authorizes the collection of alternative household income forms for LCFF purposes. To minimize this data collection, the education code also authorizes CEP schools to determine students’ eligibility in an “LCFF base year” and to report that eligibility for those students in each of the following three school years, after which the school must establish a new LCFF base year. Therefore, CEP schools may either collect alternative income forms to establish an LCFF base year during the CEP cycle, or collect alternative income forms each year during the CEP cycle if the LEA chooses not to establish an LCFF base year.

CEP schools are reminded that schools that did not opt to establish a base year and collect forms annually, and those schools establishing an LCFF base year in 2021−22, will need to collect alternative household income forms this coming school year.

P-EBT: All students enrolled in a CEP school are eligible for P-EBT. Therefore, alternative household income forms are not required to establish a student’s eligibility for P-EBT.

Schools Operating NSLP or SBP in a Provision 2/3

Schools operating NSLP or SBP under Provision 2/3 receive reimbursement for meals served based on participation in a base year (of a four-year cycle for Provision 2; five-year cycle for Provision 3). These schools collect NSLP applications only in the base year, and are prohibited from collecting applications in subsequent years the school is on a Provision 2 or 3 status, except to reestablish a base year.

LCFF: For LCFF purposes, these schools can choose to establish an LCFF base year, during which they must collect NSLP applications. Schools may perform the LCFF base year data collection during the same year that they establish a “Provision 2/3 base year” under the NSLP or SBP, in which case, NSLP applications can be used for LCFF purposes. LEAs that choose not to establish an LCFF base year, may collect alternative income forms in Provision 2/3 non-base years of the Provision cycle.

Based on USDA guidance, the CDE’s Nutrition Services Division contacted LEAs approved for a Provision 2 base year in 2020−21 with options for restarting a base year in 2021−22. Therefore, LEAs that chose to operate standard NSLP or SBP can restart their base year in 2021−22 and will need to collect NSLP applications this fall.

P-EBT: All students enrolled in a provision school are eligible for P-EBT. Therefore, NSLP applications or alternative household income forms are not required to establish a student’s eligibility for P-EBT.

Schools Participating in Summer Seamless Option (not on a provision)

Information about the Summer Seamless Option (SSO) can be found on the CDE COVID-19 Guidance in the Child Nutrition Programs web page at https://www.cde.ca.gov/ls/nu/cnpcovid19guidance.asp.

School operating under the Summer Seamless Option may provide free meals to all students without collecting NSLP applications.

LCFF and P-EBT: These schools must collect individual FRPM-eligibility data for LCFF and P-EBT purposes. Schools opting to participate in SSO may use the NSLP application or the Alternative Household Income form to collect data required for the LCFF and P-EBT.

While the USDA has not yet issued guidance allowing LEAs to use the NSLP application for purposes of P-EBT even if they are operating under the SSO waiver, doing so would be consistent with guidance the USDA issued in the 2020–21 year.

The CDE recognizes that some LEAs may opt not to collect the NSLP application without official USDA guidance, and implementing the collection of an alternative income form may be challenging. To help overcome the challenge and facilitate the collection of this form, LEAs may complete an alternative household income form on behalf of a student’s household by collecting the required information over the telephone provided the LEA documents 1) the date, time, and name of the student’s adult household member spoken to, and 2) the date, time, name, and signature of the LEA staff member collecting the information.

Schools that choose to operate under the SSO waiver and collect NSLP applications must adhere to all NSLP rules for determining eligibility, including verifying a percentage of applications, and other requirements.