Superintendent’s Memo #073-15

State seal, Commonwealth of Virginia

COMMONWEALTH of VIRGINIA
Department of Education

March 27, 2015

TO:  Division Superintendents

FROM:  Steven R. Staples, Superintendent of Public Instruction

SUBJECT: Community Eligibility Provision (CEP): Guidance and Procedures for School Year 2015-2016

The Community Eligibility Provision for the National School Lunch Program (NSLP) and School Breakfast Program (SBP) gives eligible local educational agencies (LEAs) and schools with high percentages of low-income children the option to offer free school meals to all children in those schools without collecting applications.

Under this provision, eligible LEAs and schools elect to provide meals to all students at no charge (free) and are reimbursed for both breakfast and lunch by the federal government through a formula using the percentage of “identified students” multiplied by a factor of 1.6. This percentage is then applied to the total school number of breakfast and lunch meals served to determine the number of meals reimbursed at the free reimbursement rates provided by the U.S. Department of Agriculture (USDA). This number is called the claiming percentage.  The remaining meals are reimbursed at the paid rate.  The claiming percentages, established for a school in the initial year, may be used for four school years and may be increased if the identified student percentages rise for the LEA and/or school.

Identified Students are defined as the number of students approved for free meals through means other than individual household applications. This definition includes students who are directly certified for free meals based on their participation in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF).  It also includes homeless students on the liaison list, runaways, migrant youth, Head Start, Even Start and foster children approved by means other than a meal application.  It does not include students who are categorically eligible based on information submitted on a free and reduced price application, such as a SNAP or TANF case number.

By April 15, 2015, all LEAs (including the school divisions currently operating under CEP) must complete the attached CEP Preliminary Data Collection Worksheet (attachment A) and submit it electronically to the Virginia Department of Education (VDOE), Office of School Nutrition Programs (SNP).
The report must list each school with:

School divisions with no schools that meet the criteria must return a report, with the RED BOX checked, indicating “no schools eligible.”

The Excel workbook must be submitted to SNPWEBDOC@doe.virginia.gov.  Please name the file as follows:

Division Name-divison-Number-2015 CEP Preliminary data as of 04012015
(For Example: ACCOMACK-001-2015 CEP Preliminary data as of 04012015)

The data submitted on this required report must reflect all students that were directly certified/ categorically eligible by means other than meal application as of April 1, 2015.

The Direct Certification (DC) lists maintained by each School Nutrition Program (SNP) must be updated with the most current (March 2015) direct certification data file provided by VDOE through the School Nutrition Programs Web system (SNPWeb).  School divisions are strongly encouraged to choose “ALL” for the download and match the combined direct certification file for all previous months of this school year to the LEA’s updated student enrollment database to capture any newly enrolled students that were not directly certified in the DC file match of the previous month’s files.  This will help to maximize the identified student percentage.

The documentation submitted by the LEA will be reviewed by VDOE and posted on the public Web site by May 1, 2015.    

CEP Eligibility Requirements - To be eligible to participate in CEP:

  1. LEAs and/or schools that participate in the National School Lunch Program (NSLP) and School Breakfast Programs (SBP) must have an identified student percentage of forty percent or greater as of April 1, 2015.  The 40 percent threshold may be determined by individual school, by a group of schools within the LEA, or for all schools collectively (divisionwide).  Grouping schools allows some schools to be below the 40 percent threshold as long as the aggregate percentage of the group of schools meets the 40 percent threshold.     
  2. LEAs must agree to:
    1. Accurately determine and report the identified student percentage of at least 40 percentand the identified student percentage greater than 30 percent but less than 40 percent for the LEA or each eligible school or group(s) of schools as of April 1, 2015.
    2. Provide both breakfast and lunch meals at no cost to all students.
    3. Cover any costs of providing meals at no cost to all students above amounts provided in federal reimbursements with nonfederal funds.
    4. Must apply and be approved by VDOE.

The CEP application process will be published separately as a Superintendent’s Memo in May 2015.  Training will be conducted for school divisions determined to be eligible to participate in the CEP. 

As part of the application process, the ISP, as submitted on the CEP application, will be validated by the VDOE Office of School Nutrition Programs before the first claim for reimbursement is filed to ensure the integrity of the data. This validated ISP shall be used for all other programs that will use ISP as an indicator of socioeconomic status.
 
Considerations for programs that traditionally use free and reduced eligibility:
Individual student eligibility data for free or reduced price meals will not be available for schools or divisions participating in CEP.  This may have an impact on other state programs that use this information for funding formulas such as Title I funds, Individuals with Disabilities Education Act (IDEA), E-Rate program, and other Child Nutrition Programs such as the Summer Food Service Program, Child and Adult Care Feeding Program, etc.

Title I and Community Eligibility Provision:
Identification of Economically Disadvantaged Subgroup in CEP Schools:
Each state and division that receives funding under Title I must assess and report annually on the extent to which the subgroup of economically disadvantaged students is making progress toward meeting the state’s academic achievement standards. As stated in Superintendent’s Memorandum Number 104-14, beginning with accountability results for the 2015-2016 school year, based on assessments administered in the 2014-2015 school year, Virginia will implement the use of direct certification data and other CEP-allowable categories (i.e. homeless, runaways, migrant youth, Head Start, Even Start and foster children approved by means other than a meal application) for the identification of the economically disadvantaged subgroup for accountability purposes in all CEP schools. (This is the number of identified students as defined above).  School divisions should ensure the correct identification of economically disadvantaged students in CEP schools in the Student Record Collection (SRC) according to the guidelines above, as the SRC coding directly impacts school accountability results for this subgroup. 

Schools not participating in CEP will continue to use traditional methods for the identification of the economically disadvantaged subgroup for accountability purposes as allowed under Title I and that comply with the data elements outlined in the Student Record Collection (for example, student eligibility for Free/Reduced Meals, students receiving TANF, and students eligible for Medicaid).

Identification of Title I Schools:
The Virginia Department of Education will continue to provide guidance on the impact of CEP on the identification of Title I schools and accountability during upcoming technical assistance opportunities. 

Questions about the identification of the economically disadvantaged subgroup in participating CEP schools or the identification of Title I schools in divisions participating in CEP should be directed to Veronica Tate, director, Office of Program Administration and Accountability, at (804) 225-2869 or veronica.tate@doe.virginia.gov, or to Dr. Lynn Sodat, Title I coordinator, at (804) 371-2934 or lynn.sodat@doe.virginia.gov

Individuals with Disabilities Education Act (IDEA) and Community Eligibility Provision:  
The Individuals with Disabilities Education Act (IDEA Part B) provides federal funds to local educational agencies.  IDEA has traditionally used the free and reduced price eligibility data to define “the relative numbers of children living in poverty” in allocating the funds. 

Funding allocations beginning with school year 2015-2016 will be as follows:

  1. Divisionwide CEP and CEP schools and/or groups of schools -- the validated Identified Student Percentage times the 1.6 multiplier (the claiming percentage for meals reimbursed at the free rate) will be used to determine the free and reduced eligibility status for these sites.  This number aligns more closely with the non-CEP school free and reduced eligibility.  The free and reduced eligibility list, posted on the VDOE Web site, should be used for this purpose as it has already performed the correct calculations using the validated ISP.
    http://doe.virginia.gov/support/nutrition/statistics/index.shtml 

  2. Non-CEP schools - schools not participating in CEP will continue to use the free and reduced eligibility data as the means of determining poverty status.

Questions about the identification of the economically disadvantaged subgroup in participating CEP schools for IDEA purposes should be directed to Tracie Coleman, Special Education Budget and Finance Manager, Division of Special Education and Student Services at (804) 225-2704 or tracie.coleman@doe.virginia.gov.

E-Rate and Community Eligibility Provision:
The E-rate program under the Federal Trade Commission allows schools to apply for discounted telecommunications services and Internet access. The new E-rate policy streamlines the discount calculation process for Community Eligibility Provision schools so that they do not face any additional burdens relative to other schools.  Beginning in the 2015-2016 school year, allschool divisions will determine the discount rate percentage at the division level, rather than for each individual school as follows:

  1. Divisionwide CEP - the validated Identified Student Percentage times the 1.6 multiplier (the claiming percentage for meals reimbursed at the free rate) will be used to determine the discount rate.

  2. Divisions with CEP schools and non-CEP schools - the validated Identified Student Percentage times the 1.6 multiplier (the claiming percentage for meals reimbursed at the free rate) will be used for CEP sites, and the traditional free and reduced eligibility will be used for non-CEP sites. The division level number will be applied against the student enrollment. The free and reduced eligibility report posted on the VDOE Web site should be used for this purpose as it has already performed the correct calculations using the validated ISP. http://doe.virginia.gov/support/nutrition/statistics/index.shtml.

Other Child Nutrition Programs and Community Eligibility Provision:
Several child nutrition programs use the free and reduced eligibility to determine if a site can participate in one of the USDA programs.  The validated Identified Student Percentage times the 1.6 multiplier (the claiming percentage for meals reimbursed at the free rate) will be used for CEP sites to determine area eligibility in the Summer Food Service Program, Seamless Summer, Child and Adult Care Food Program (CACFP) at-risk afterschool supper/snacks, CACFP tiering, and NSLP afterschool snacks. 

Attachment B is the updated USDA Frequently Asked CEP Questions document that provides detailed guidance.  Attachment C is the USDA CEP Calculator that will allow school divisions to assess and project the monthly federal reimbursement.

Questions regarding the Community Eligibility Provision may be directed to the school nutrition program specialist assigned to your division or Catherine Digilio Grimes, Director, Office of School Nutrition Programs at (804) 225-2074.

SRS/CDG/cc

Attachments:

  1. CEP Preliminary Data Collection Worksheet (Excel)
  2. USDA Frequently Asked Community Eligibility Provision (CEP) Questions (PDF)
  3. USDA CEP Calculator to Assess and Project the Monthly Federal Reimbursement (Excel)