Superintendent’s Memo #108-16

State seal, Commonwealth of Virginia

COMMONWEALTH of VIRGINIA
Department of Education

April 29, 2016

TO:  Division Superintendents

FROM:  Steven R. Staples, Superintendent of Public Instruction

SUBJECT: Community Eligibility Provision (CEP): Application for School Year 2016-2017

Superintendent’s Memorandum 072-16, dated March 25, 2016, provided guidance and general information about the Community Eligibility Provision (CEP) for school year 2016-2017.  All school divisions were required to submit a CEP Preliminary Data Collection Worksheet to the Virginia Department of Education (VDOE) by April 15, 2016.  This preliminary data detailed the school sites with 40 percent or greater identified students (IS) directly certified for free meals as of April 1, 2016.  This is the first criteria required to be eligible to participate in the Community Eligibility Provision.  The complete list of eligible divisions and schools is posted on the VDOE Web site at http://www.doe.virginia.gov/support/nutrition/statistics/index.shtml.

School divisions that meet the eligibility criteria outlined below may apply to participate in the Community Eligibility Provision for one or more schools. Participation in CEP is a local decision that requires consideration of multiple factors, including the fiscal impact.

CEP Eligibility Requirements: To be eligible to participate in CEP a school division, or one or more schools in the division, must:

  1. Participate in both the National School Lunch Program (NSLP) and School Breakfast Program (SBP);

  2. Have an identified student percentage (ISP) of forty percent or greater as of April 1, 2016; (The 40 percent threshold may be determined for an individual school, for a group of schools within the school division, 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 meets the 40 percent threshold.)

  3. Agree to provide both breakfast and lunch meals at no charge to all students and to pay the cost of providing such meals with non-federal funds, if the federal reimbursement is insufficient to cover the meal costs; and,

  4. Submit an application to participate in CEP and receive approval from VDOE.

How to apply:

An application must be submitted by the school division for one or more schools, and may not be submitted by individual schools.  CEP applications are due annually by June 30; USDA extended the deadline to August 31 this year.  Early submission of the application is encouraged.

The complete application for 2016-2017 includes the following items:

  1. Attachment A - Addendum to the Annual Agreement - Submit two copies with original signatures by U.S. Mail  to:
                Virginia Department of Education
                Office of School Nutrition Programs
                P.O. Box 2120 
                Richmond, VA 23218-2120

  2. Attachment B - Application to Participate in Community Eligibility Provision - Submit the application (in Excel format) by E-mail to SNPwebdoc@doe.virginia.gov.

  3. Attachment D – USDA CEP Federal Reimbursement Calculator - Submit the completed calculator (in Excel format) by E-mail to SNPwebdoc@doe.virginia.gov.

  4. Supporting Documents - Submit the confidential list of directly certified students used to determine the number of identified students reported in the CEP application for each school, group of schools, or the division. This documentation is the list(s) of names of all students who were directly certified as eligible for free meals without an application as of April 1, 2016, and must agree with the number reported in the April 1 CEP data collection.

Confidential direct certification documentation must be uploaded by the division to the secure Single Sign-on for Web Systems (SSWS) dropbox to be sent to the school nutrition specialist assigned to your division.  (Attachment C provides instructions on how to upload the files to the SSWS dropbox).  Do not send this confidential documentation to VDOE by E-mail or any other method.  

The VDOE must review the CEP application to ensure the division/group/school meets the minimum identified student percentage (ISP); participates in both the National School Lunch Program and the School Breakfast Program; and, has a record of administering the USDA school nutrition programs in accordance with federal and state regulations, including the financial status of the school nutrition program. 

School divisions should analyze the fiscal impact of CEP on the local school nutrition program.  Financial considerations should be based on the anticipated level of federal reimbursement and other nonfederal support that may be available to pay for any meal costs in excess of the projected federal reimbursement for CEP.  If the federal reimbursement is insufficient to cover the cost of providing breakfast and lunch meals to all students at no charge, non-federal funds must be used to offset the difference.  School divisions should use the USDA CEP Federal Reimbursement Calculator, which is Attachment D to this memorandum, to project the monthly federal CEP reimbursement.  The division should also assess the current net cash resources of the school nutrition program and the projected meal costs to determine if non-federal funds will be required.

The ISP, as submitted on the CEP application for each school site, will be validated by the VDOE, using the documentation submitted, prior to final CEP approval and 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 other programs that use individual student free and reduced eligibility

Individual student eligibility data for free or reduced price meals will not be available for participating schools in a CEP school division.  This may have an impact on other state or federal programs that use this information for identification of economically disadvantaged students for accountability purposes, for funding formulas, or for eligibility for other child nutrition programs.   

A Superintendent’s Memorandum that addressed the topic of economically disadvantaged identification for accountability purposes with SOL testing in schools using the Community Eligibility Provision was published in the 2013-2014 school year.  The Virginia Department of Education determined schools would use only those students determined eligible by direct certification in the non-base years as economically disadvantaged for tracking SOL accountability results in CEP schools.  The memorandum is available at: http://www.doe.virginia.gov/administrators/superintendents_memos/2014/104-14.shtml.  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 Dr. Lynn Sodat, acting director, Office of Program Administration and Accountability, at (804) 371-2934 or lynn.sodat@doe.virginia.gov

To comply with this policy and provide the required information, school nutrition programs in CEP participating school divisions should continue to directly certify all eligible students each year, including those in CEP schools, using the DOE/DSS SNAP/TANF list as well as the homeless, migrant, runaway, and Head Start data from the school division liaison(s).  The students in CEP schools who are directly certified each year should be identified as economically disadvantaged (ED) in the division’s student enrollment database even though that DC status would not be used by the school nutrition program to claim meals for individual students in CEP schools by category. 

In divisions where some schools are on CEP and others continue to collect household applications, there may be students in CEP schools who are determined free or reduced price eligible because they are a member of a household that has other students eligible on the basis of a household application who attend non-CEP schools.  The eligibility from the household application should be used to identify the student in the CEP school as ED in the student enrollment database for other purposes, such as accountability reports for SOL testing, but should not be used to determine eligibility for meals or to claim meals by category for the student who attends a CEP school.

For schools in a CEP division that do not participate in CEP (using the traditional counting method) any student who is determined free or reduced price eligible by either direct certification or application would be identified as ED in the student database.  This is the same as it was for all schools prior to CEP implementation and remains the same in the non-CEP schools. 

For other programs such as the Individuals with Disabilities Education Act (IDEA Part B), E-rate,  and other child nutrition programs, the validated Identified Student Percentage times the 1.6 multiplier (the claiming percentage for meals reimbursed at the free rate) is used to determine the free and reduced price eligibility percentage for CEP schools.  This number aligns more closely with the free and reduced price percentage used for non-CEP schools.  The annual October 31 free and reduced price eligibility report, posted on the VDOE Web site at http://doe.virginia.gov/support/nutrition/statistics/index.shtml shall be used for this purpose as it reports the calculated claiming percentage for all schools using the validated ISP.

If you have questions or need additional information, please contact the school nutrition program specialist assigned to your division, or Lynne A. Fellin, associate director, at (804) 225-2717 or by e-mail at lynne.fellin@doe.virginia.gov, or Catherine Digilio Grimes, school nutrition coordinator, at (804) 225-3969 or by e-mail at catherine.digilio-grimes@doe.virginia.gov.

SRS/LAF/idl

Attachments:

  1. Addendum to the Annual Agreement for the Community Eligibility Provision (PDF)
  2. Application to Participate in the Community Eligibility Provision 2016-2017 (Excel)
  3. Instructions for Uploading a File to the SSWS Dropbox (PDF)
  4. USDA CEP Federal Reimbursement Calculator 2016-2017 (Excel)