CEP Application and Increasing ISP
Nutrition Services Division Management Bulletin
Purpose: Policy, Beneficial Information
To: School Nutrition Program Sponsors
Attention: Food Service Directors
Date: February 2019
Reference: U.S. Department of Agriculture Food and Nutrition Service Policy Memorandum SP 15-2016: http://www.fns.usda.gov/school-meals/policy, Community Eligibility Final Rule: https://www.fns.usda.gov/school-meals/federal-register-documents, Community Eligibility Provision Planning and Implementation Guidance https://www.fns.usda.gov/fall-2016-edition-community-eligibility-provision-planning-and-implementation-guidance
Supersedes: Management Bulletin SNP-19-2016
Subject: Community Eligibility Provision Application and Increasing Identified Student Percentage
This management bulletin (MB) supersedes MB SNP-19-2016. It provides information regarding the Community Eligibility Provision (CEP) and provides instructions to local educational agencies (LEA) applying to participate in the CEP. 7 CFR 245.9(f)(4)(i) requires LEAs interested in applying for the CEP to submit required documentation to the state agency no later than June 30 of the prior school year.
The CEP is a four-year alternative meal counting and collection procedure provision implemented as a result of the Healthy, Hunger-Free Kids Act of 2010. The U.S. Department of Agriculture (USDA) made the CEP available nationwide to all LEAs beginning in School Year 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 established 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 benefits of CEP include:
- All students 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 do not have to categorize each meal served as free, reduced-price, or paid
- Breakfast and lunch participation increases
- Increased meal participation means improved student access to meals and nutrition leading to improved academic performance, decreased sick days, and better school attendance
- Elimination of overt identification of students eligible for free and reduced-price meals
- Elimination of meal debt
To be eligible to participate in the CEP, the LEA must:
- Have an Identified Student Percentage (ISP) of at least 40 percent as of April 1 of the year prior to implementing the CEP, for a school or 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 into the nonprofit school food service account in an amount equal to the difference between federal reimbursement and the cost of serving lunch and breakfast at no charge to all participating children
Identified Student Percentage
The ISP is the percentage of students who qualify for a meal at no charge without completing meal applications, based on the enrollment of a school or group of schools 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, Medi-Cal free benefits, 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, or Head Start, and nonapplicants approved by local officials.
To ensure that the LEA includes all students who are directly certified in the ISP calculation, those with access to the California Longitudinal Pupil Achievement Data System (CALPADS) can obtain a list of directly certified students from the CALPADS in addition to obtaining a list of directly certified students from the local county contact. LEAs without access to CALPADS must obtain a list of directly certified students from the local county contact. The CDE also recommends that LEAs obtain a list of students certified as homeless, migrant, runaway, or participating in a Head Start program. All student data must be current as of April 1 of the year prior to implementing the CEP. Each student may only be counted once regardless if they appear on multiple lists. County contact and additional information regarding direct certification (DC) is available on the California Department of Education (CDE) DC web page at https://www.cde.ca.gov/ls/nu/sn/directcert.asp.
Claim reimbursement is based on the ISP and a multiplier factor established by the USDA. To determine the number of reimbursable meals 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 is 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 are 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).
Schools electing to participate in the CEP 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 Form SNP-19. If the LEA needs to change any of the schools participating in a group during the four-year cycle, they must implement a new group and a new four-year cycle using the application process below.
To implement the CEP, the LEA must:
- Complete the CEP Application Checklist, Form SNP-71, to ensure a complete application packet is included. You can find this form in the Child Nutrition Information and Payment System (CNIPS) Download Forms section.
- Complete Form SNP-19 to amend their original Meal Count and Collection Procedures form on file. This form is also available in the CNIPS Download Forms section. Upload the completed SNP-19 in the original Excel format into the CNIPS as an attachment.
- After completing Forms SNP-71 and SNP-19, please mail to:
Nutrition Services Division
California Department of Education/SNPU
1430 N Street, Suite 4503
Sacramento, CA 95814
- After completing Forms SNP-71 and SNP-19, please mail to:
- Complete Form SNP-55 in order for the CDE to ensure accuracy of the ISP. This form is also available in the CNIPS Download Forms section.
- After completing Form SNP-55, upload it into the CNIPS as an attachment.
- After completing Form SNP-55, upload it into the CNIPS as an attachment.
- Upload all source documents used to determine the ISP into the CNIPS as attachments. Source documents may include CALPADS extract(s), local county direct certification list(s) containing CalFresh, CalWORKS, or foster data, foster list(s), homeless/runaway list(s), migrant list(s), and Head Start list(s). Refer to Form SNP-71 for details on where to locate these documents, and the correct formats in which they need to be uploaded.
If all documentation above is not submitted in the appropriate format in a timely manner, the CDE has the discretion to deny the LEA participation in the CEP.
Option to Apply for Identified Student Percentage Increase
In the first year of the four-year cycle, the LEA must use the ISP as of April 1 of the school year prior to the start of the CEP as stated on the CEP Policy Statement Addendum (Form SNP-19). In the second, third, and fourth years of the cycle, the LEA has the discretion to use either the ISP from April 1 of the preceding year or 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.
To increase the ISP for the following school year, an LEA must submit:
- CEP ISP Change Request (Form SNP-56)
- CEP Identified Students Preapproval Review (Form SNP-55)
- CEP Application Checklist (Form SNP-71)
- All source documents and enrollment lists used to determine the ISP
Forms SNP-56, SNP-55, and SNP-71 are posted in the CNIPS in the Download Forms section. It is important to note that unlike the ISP established in year one of participation in the CEP, an ISP increase is only valid for one school year. The increased ISP will automatically revert to the first year’s ISP at the end of each school year, unless an LEA submits the above bulleted documents by the application deadline and receives CDE approval each school year. If the ISP increases in years two, three, or four, the CDE recommends restarting the CEP cycle in order to secure the higher ISP for an additional four years. An LEA can reapply by submitting a new Form SNP-19, SNP-55, SNP-71, and all source documents and enrollment lists used to determine the ISP.
If requesting to increase the ISP for any school that is part of a group, the ISP must be recalculated for all schools within the group. Consideration should be given to ensure that the ISP for the group of schools has increased.
The CEP final rule requires LEAs to conduct data matches at least once annually to ensure that the school or group of schools is using the highest ISP possible. Data matches should be conducted by April 1 of each year that the LEA participates in the CEP and, if applicable, follow the steps above to request an increased ISP or restart the cycle.
Participation in the CEP covers a period of four years. The LEA may stop participating at any time as long as the CDE has been notified. The LEA must submit a revised site application in the CNIPS for each site no longer participating in the CEP and an updated Meal Count and Collection Procedures (Form SNP-03) to the CDE.If the LEA decides to end participation in the CEP between school years, schools will have time to notify families that they are returning to standard meal count and collection procedures and send out meal applications prior to the start of the next school year.
If the LEA decides to end participation midyear, a reasonable timeframe (at least 30 days) is required for the school to notify families and distribute, process, and certify meal applications. During this timeframe, students should continue to receive free meals to ensure their meal service routine is not disrupted. Meals served during this transition are claimed at the same free and paid claiming percentages used under CEP.
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, are allowed to continue the CEP for a grace year. The grace year is outside of the four-year cycle. The USDA bases the reimbursement for schools in a grace year on the ISP as of April 1 in year four of the current four-year cycle.
The LEA must make available all documentation to support the unduplicated count of students and ISP calculation submitted with the initial application, ISP Change Request, or Grace Year Extension for review or audit while participating in the CEP. The LEA must also retain proof of the annual DC data match. In addition, this documentation must be retained for three years after submission of the final claim for reimbursement for the last fiscal year of the CEP. This includes, but is not limited to, enrollment data and reports documenting student eligibility for benefits.
Desk Audit-Identified Student Percentage Review
The CEP Guidance Manual allows the CDE to perform a desk audit for LEAs establishing a new CEP cycle when the LEA is not scheduled for a School Nutrition Program (SNP) administrative review (AR). The CDE may conduct desk audit reviews at the LEA location (on site) or at the CDE (off site).
The CDE will review a statistically valid sample of the identified students, from all sites that have or will establish a new CEP cycle. If the total number of enrolled students is less than 100, the CDE will review all identified students.
The CEP Guidance Manual states that if a desk audit is performed, there will be no ISP review during the AR, but the CDE will review a site participating in the CEP as part of the AR site visits.
Similar to a desk audit, the CDE will review a statistically valid sample of students for an ISP review during an SNP AR. If the total number of enrolled students is less than 100, the CDE will review all identified students. The CDE must follow the procedures in the USDA Administrative Review Manual when completing an ISP Review. The Administrative Review Manual is available in the CNIPS Download Forms section.
Results of the Identified Student Percentage Review
The CEP Guidance Manual states that when errors are found, the CDE must determine the correct ISP.
If an error rate under 10 percent is determined, the CDE will recalculate the ISP based upon the error rate. The validated ISP will be provided to the LEA upon completion of the review.
If an error rate over 10 percent is determined and the ISP is below 40 percent, the LEA must return to standard meal counting and collection procedures.
If an error rate over 10 percent is determined and the ISP is over 40 percent, the LEA will be required to provide documentation that accurately substantiates the ISP. If the CDE is unable to validate an ISP with an error rate of less than 10 percent, or the LEA is unable to produce source documentation to substantiate the ISP, the LEA must return to standard meal counting and collection procedures.
Additional Community Eligibility Provision Information
To learn more about the CEP, please visit the CDE CEP web page at http://www.cde.ca.gov/ls/nu/sn/cep.asp.A Reimbursement Estimator developed by the USDA is included on the CDE CEP web page. The CDE recommends that LEAs interested in applying for the CEP complete the USDA Reimbursement Estimator to determine if the CEP is a good financial decision for a school or a group of schools.