Area Eligibility in the Summer Meal Programs

This management bulletin (MB) updates guidance on the determination of area eligibility in the Summer Food Service Program (SFSP), and Seamless Summer Option (SSO) of the National School Lunch Program (NSLP). It also includes guidance on the Community Eligibility Provision (CEP) as it relates to area eligibility.

This MB supersedes MB CNP-04-2015, issued in August 2015, which addressed the use of school and census data and data release information.

Background

Operators may use school data or census data to qualify a summer meal site as area eligible. These are two of the methods of determining if a site meets the definition of “areas in which poor economic conditions exist.” (7 CFR, Section 225.2):

(1) The attendance area of a school in which at least 50 percent of the enrolled children have been determined eligible for free or reduced-price school meals under the NSLP and the School Breakfast Program (SBP); or

(2) A geographic area where, based on the most recent census data available or information provided from a department of welfare or zoning commission, at least 50 percent of the children residing in that area are eligible for free or reduced-price school meals under the NSLP and the SBP.

In addition, SSO operators may use either school or census data to qualify as area eligible per USDA Policy Memo SP 09-2017: 2017 Edition of Questions and Answers for the National School Lunch Program’s Seamless Summer Option. This policy memo is available on the USDA’s Policy Memo SP-2017 web page at https://www.fns.usda.gov/cn/2017-edition-questions-and-answers-national-school-lunch-programs-seamless-summer-option.

Duration of and Reestablishment of Area Eligibility

Area eligibility determinations based on school or census data are valid for five years (7 CFR, Section 225.6[g]). This applies even if the site transitions between Child Nutrition Programs (SFSP, SSO, or the Child and Adult Care Food Program [CACFP]), so long as it continuously operates as area eligible within the five-year eligibility duration. Operators are required to maintain area eligibility documentation for the duration of its use, plus an additional three years, unless there is an unresolved audit or administrative review to which they pertain.

The California Department of Education (CDE) encourages operators of sites in areas with declining eligibility to assess whether reestablishing eligibility on a more frequent basis would be beneficial, since doing so resets the five-year cycle.

Use of School Data

Operators may use school data to establish area eligibility for the SFSP and SSO, excluding camps, which must document the individual free or reduced-price meal eligibility of children. The program operator must indicate that the proposed summer meal site is located within a school’s attendance area where at least 50 percent of enrolled children are eligible for free or reduced-price school meals.

Some schools do not have attendance boundaries (e.g., most charter, continuation, and community schools). Schools without assigned attendance boundaries cannot be used to establish area eligibility for summer feeding sites in the community.

Provisions: Claiming Alternatives

Most schools in California that operate the School Nutrition Programs participate in claiming provisions, which are methods for reducing paperwork and other administrative burdens at the local level by simplifying the traditional operating procedures for determining free and reduced-price meal eligibility and meal counting. Schools that are approved to operate the CEP or Provision 2 (P2) during a non-base year may not collect applications for free or reduced-priced meals. Instead, they collect alternative household income information. Alternative income information may not be used to qualify a school attendance zone as area eligible.

Community Eligibility Provision

Schools electing to use the CEP establish identified student percentages (ISP) using direct certification data for children who are categorically eligible for free meals. Area eligibility determinations based on data from CEP schools must use the individual school ISP data. The school’s free meal percentage is calculated by multiplying the ISP by a factor of 1.6. If the result is equal to or greater than 50 percent, meal sites located in the attendance area of the school are area eligible. The minimum ISP required to be eligible using school data is 31.25 percent.

More information on the CEP can be found on the CDE CEP web page at http://www.cde.ca.gov/ls/nu/sn/cep.asp.

Provision 2

Schools electing to use P2 reduce the application collection process to once every four years. It also simplifies meal counting and claiming procedures by allowing a school to receive meal reimbursement based on claiming percentages established during a school’s P2 base year.

Area eligibility determinations based on data from P2 schools must use the data from the school’s base year. If at least 50 percent of students were determined to be eligible for free or reduced-price meals in the base year, meal sites located in the attendance area of the school are eligible.

More information on Provision 2 can be found on the Provision 2 web page at https://www.cde.ca.gov/ls/nu/sn/provisions.asp.

School Data Resources

When using school data to determine area eligibility, operators must first check the CDE’s Provision Status Workbook to determine what claiming provision a potentially eligible school may be on. The workbook can be found on the CDE Provision Status Workbook web page at https://www.cde.ca.gov/ls/nu/sf/documents/summerprovisionsdata.xlsx. If a school is not listed in the workbook, it is not on a claiming provision.

For schools not on a claiming provision, the CDE maintains a list of schools in the state, including elementary, middle, and high schools, where at least 50 percent of enrolled children are eligible for free or reduced-price school meals. The CDE provides this information each year on its Free or Reduced-Price Meal (Student Poverty) Data web page at https://www.cde.ca.gov/ds/ad/filessp.asp. The information is based on data submitted by public school districts and charter schools annually on census day, which is the first Wednesday in October. Please note that the data for schools on a claiming provision (in a non-base year for P2) contains data from alternative income information forms and therefore may not be used in determining area eligibility.

For assistance in obtaining school data, please download Form ID SSO 11, SSO School Area Eligibility Job Aid, or Form ID SFSP Job Aid 8, SFSP School Area Eligibility Job Aid in the Child Nutrition Information and Payment System’s (CNIPS) Download Forms section for your respective program, or contact your SFSP or SSO Specialist.

Use of Census Data

Operators may establish area eligibility for SFSP and SSO sites by using the most recent census data obtained by the USDA Food and Nutrition Service (FNS) from the Census Bureau. The FNS will annually announce the release of the new census data in October. You can subscribe to receive USDA FNS announcements on the USDA FNS Email Updates web page at https://public.govdelivery.com/accounts/USFNS/subscriber/new?pop=t.

Flexibilities with Census Data

When using census data, SFSP and SSO Operators may determine area eligibility using either census block groups (CBG) or census tracts. Census tracts are geographical units that consist of one or more CBGs. CBGs and census tracts in which at least 50 percent of children are eligible for free or reduced-price meals.

Additionally, up to three adjacent CBGs may be averaged to determine eligibility using a weighted average. At least 40 percent of children must be eligible for free and reduced-price meals in each of the CBGs being averaged. Census tracts may not be combined.

In summary, SFSP and SSO sites that use census tract data are considered area eligible under any of the following scenarios:

• If 50 percent or more of the children in a census tract are eligible for free or reduced-price school meals
  
  
• If 50 percent or more of the children in a CBG are eligible for free or reduced-price school meals
  
  
• If the percentage of children eligible for free or reduced-price meals in up to three adjacent CBGs, when averaged, is 50 percent or more; provided that at least 40 percent of children in each of the combined CBGs are eligible for free and reduced-price meals

These flexibilities may help sites located in a census block group that is ineligible on its own but is immediately adjacent to an eligible area to also become area eligible.

Census Data Eligibility Maps and Instructions

Census tract and CBG data are available through the FNS Area Eligibility Mapper on the USDA FNS Area Eligibility Mapper for CACFP and Summer Meals web page at http://www.fns.usda.gov/area-eligibility. The USDA provides instructions embedded in the mapper. This mapper allows operators to combine up to three CBGs to determine site eligibility.

The CDE also has job aids for using the Area Eligibility Mapper and combining CBG data. Operators can find their respective job aid in the CNIPS Download Forms section, Form IDs SFSP Job Aid 9 or SSO 12.

Other Approved Data Sources in the Summer Meal Programs

Area eligibility may be established for SFSP and SSO sites when using documentation from other approved sources that demonstrates 50 percent or more of the children in the defined area are eligible for free or reduced-price meals in accordance with 7 CFR, Section 225.2. These approved alternative sources are also considered valid for five years.

Approved alternative data sources may include the Department of Welfare, Zoning Commissions, USDA Rural Development housing authorities, Housing and Urban Development authorities, or local housing authorities. The alternative data source’s income eligibility requirements must be equivalent to or more restrictive than the SFSP/SSO requirements. The CDE will verify information provided in the alternative data source. Program operators must upload documentation of the alternative data source into CNIPS. If you have questions about alternative data sources, please contact your SFSP or SSO specialist.

Camp Sites

SFSP and SSO sites may operate at residential and non-residential day camps. Non-residential camp sites must offer a continuous schedule of organized cultural or recreational programs for enrolled children between meal services. Only meals served to children certified as eligible for free or reduced-price meals may be claimed for reimbursement. Camp sites may not use area eligibility; each child’s individual eligibility records must be kept on file for the latter of the current program year plus an additional three, or the close of an audit or administrative review (7 CFR, sections 225.2, 225.6[b][8], 225.6[i][14], 225.9[d][9], and 225.16[b][1][i]).

Migrant Sites

SFSP and SSO sites that predominantly serve children of migrant workers may establish area eligibility as a migrant site. To confirm migrant eligibility, operators must submit information obtained from a migrant organization that certifies the site serves children of migrant workers. Migrant sites are required to submit qualifying documentation annually. Migrant sites may operate like open or open-restricted sites, as defined in 7 CFR, Section 225.2, and may receive reimbursement for up to three meals per day served to all children in attendance (7 CFR, Section 225.16[b][4]).

Sites Serving Native American Children

SFSP and SSO sites that are located on tribal lands where 50 percent or more of the children in the defined area are eligible for free and reduced-price school meals may establish area eligibility with documentation from a tribal authority. This policy supports increased summer meal access for Native American children and reduces the paperwork burden for operators and families.

Questions

If you have any questions regarding this subject, please contact your agency’s SFSP or SSO Specialist:

SFSP: The SFSP Specialist Contact List is in the CNIPS Download Forms section, Form ID Caseload. You can also contact the Summer Nutrition Programs and Grants Unit by email at SFSP@cde.ca.gov to be directed to your SFSP Specialist.

SSO: The SSO Specialist Contact List is in the CNIPS Download Forms section, Form ID Caseload. You can also contact the Summer Nutrition Programs and Grants Unit by email at SSFO@cde.ca.gov to be directed to your SSO Specialist.