Region One ESC Food & Nutrition Program Differences Between Provision Schools and Traditional Meal Application Carmen Ocanas Lerma, Director September 2017 1
Objectives ▪ Provide an overview of the various Provisions in law regarding eligibility to participate in meal programs under USDA’s eligibility requirements ▪ Provide information on Determining Eligibility through a household meal application ▪ Provision 2 ▪ Community Eligibility Provision ▪ Direct Certification 2
What is Traditional Method/Determining Eligibility ▪ Household School Meal Application ▪ Eligibility Categories ▪ Categorical Eligibility ▪ Direct Certification ▪ Other Source Categorical Eligible Programs ▪ Very few School Districts in Region One Process meal applications today 3
What is Provision 2? ▪ Is an option designed to decrease the burden of paperwork on parents and CEs by reducing the requirements of taking household applications, verifying household applications, notifying the public, and submitting reimbursement claims by meal eligibility category. 4
Provision 2 Requirements ▪ There is not a required percentage or ratio of free, reduced-price, or paid meal participants for P2. ▪ CE-Wide/School. P2 may be applied at the CE/district level even if not all schools in the district operate P2. ▪ Under P2, CEs offer universal meal service or meals at no charge to all participants receiving a reimbursable meal beginning in the base year and continuing as long as the school participates in P2. ▪ A school site may choose to apply P2 for lunch, breakfast, or both. 5
Provision Base Year ▪ Base Year. During the base year, eligibility is determined by the normal processes as described in the Administrator’s Reference Manual (ARM), Section 4, which consists of the following: ▪ CE collects meal applications ▪ Determines F/R/P Percentage ▪ Annualizes these percentages District Wide ▪ Conducts Verification Process ▪ Files reimbursement claims using these established percentages 6
Provision 2 Remaining Years ▪ Remaining Years of the Four-Year Cycle. During the second, third, and fourth years, the CE uses the base year eligibility determinations for counting and claiming and does not use the normal free and reduced-price meal application process 7
What is the CEP? ▪ Requirement from the Healthy, Hunger-Free Kids Act of 2010 ▪ Provides an alternative to household applications in the NSLP and SBP ▪ Allows schools with a high percentage of directly certified free students to serve free meals to all enrolled students ▪ Eliminates burden of collecting household applications ▪ District makes the decision to participate based on eligibility ▪ CEP is designed to be easy for a school or district to adopt 8
CEP Requirements Participating schools must State agencies are An SFA may participate in meet a threshold of required to annually CEP for some or all students directly certified notify eligible SFAs schools (initially 40%) and agree to serve all meals free Claims are based on Eligible LEAs/schools percentage of enrolled agree to serve all students No household students directly certified free lunches and applications are multiplied by a factor of breakfasts for 4 submitted for any 1.6 successive school years students 9
Definitions ▪ Enrolled students ▪ Those students who are enrolled in and attending schools participating in the CEP and who have access to at least one meal service daily ▪ Identified students ▪ Those students who are certified for free meals NOT through individual household applications ▪ Supplemental Nutrition Assistance Program (SNAP) ▪ Homeless/Runaway ▪ Migrant ▪ Foster ▪ Head Start ▪ Non-applicant students approved by LEA officials 10
How is the Identified Student Percentage Calculated? ▪ Identified student percentage (ISP) # of Identified Students X 100 Total Number of Enrolled Students ▪ Eligible SFAs/Schools ▪ SFAs/Schools with an ISP of at least 40% ▪ Potentially eligible SFAs/School ▪ Schools with an ISP of at least 30% but less than 40% 11
How are meals claimed? ▪ ISP = # of identified students/# of enrolled students x 100 ▪ Multiply by a factor of 1.6 ▪ Result Percentage of total meals served at the federal free rate ▪ Remaining percentage of total meals is reimbursed at the federal paid rate Example: Identified Students = 250 Enrolled Students = 500 250/500 x 100 = 50% 50% x 1.6 = 80% = free 20% = paid 12
Meal Reimbursements with CEP The reimbursement rate for both lunch and breakfast is determined by multiplying the percentage of Identified Students by a 1.6 multiplier. The resulting number is the percentage of meals reimbursed at the “free” reimbursement rate, with the rest being reimbursed at the “paid” rate. Identified Student Percentage Free Percentage Paid Percentage (ISP) 40% 64% 36% 45% 72% 28% 50% 80% 20% 55% 88% 12% 60% 96% 4% 62.5% 100% 0% 13
CEP Factors ▪ Each year of the 4-year cycle, SFAs or schools may use the ISP from the first year, or the updated ISP, whichever is higher ▪ New SFAs are required to submit CEP Intent via TXUNPS no later than June 30 th to begin CEP ▪ SFAs choosing CEP must consider costs ▪ SFA must pay the difference between serving meals at no charge and the federal reimbursement ▪ Example: Revenue from a la carte sales or other revenue 14
Potential Implementation Issues ▪ Impacts of the absence of student level poverty data used to distribute other assistance funding ▪ Title I ▪ Potential redistribution of school-level Title I funds ▪ CEP does not impact the total amount of Title I, only the distribution ▪ Need for alternative data for state and local funding formulas ▪ Family Economic Data Survey ▪ E-rate discount level determination ▪ CEP schools may use the free claiming percentage 15
Distribution and Collection of Household Applications for Purposes Other Than Benefit Issuance for NSLP or SBP ▪ If a school is operating under a special provision option, the CE (or the school) must not collect or distribute free or reduced- price meal household applications or other types of household applications designed to collect student demographic or socioeconomic data unless the action is a requirement of the special option provision. ▪ For the two special provision options described, the distribution and collection of free and reduced-price meal household applications is permissible only in the base year of P2 16
Other than NSLP needs ▪ If the CE needs current information that would normally be collected on the free and reduced-price household meal application, all of costs for distribution, collection, and review for such efforts must be paid by non-school nutrition program (SNP) funds. This includes data used for ▪ PEIMS or other federal, state, or local programs 17
Texas Education Agency ▪ The Texas Education Agency (TEA) provides a template form to assist CEs in collecting socioeconomic data at ▪ www.tea.texas.gov/Workarea/DownloadAsset.aspx?id=2576981 6295 Sample Income Survey Template 18
Sample Form 19
Direct Certification ▪ Direct Certification is the process that allows school-age children residing in households that receive Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance to Needy Families (TANF) benefits to participate in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) without submitting an application and at no charge. ▪ The Child Nutrition and WIC Reauthorization Act of 2004 mandated that all Local Education Agencies (LEA), including private schools, would have direct certification systems in place by School Year 2008. 20
What is Direct Certification ▪ Process that provides certification for free meal benefits for eligible children without an application 21
How do you do Direct Certification? ▪ The Direct Certification process has several steps – confirming the current enrollment of students on the State Match list and searching for more eligible students through the CE Upload process or CE Search process. Then the CE must enter the information into the point-of-sale (POS) system. ▪ The state only matches students. It is the CE that certifies them. 22
Why is there so much focus on Direct Certification? ▪ It’s required by law. ▪ The state must meet a benchmark that 95% of eligible student are certified by LEAs participating in NSLP/SBP. ▪ All LEAs must report the number of students enrolled on the last day of October that have been directly certified. 23
Resources Texas Department of Agriculture ▪ http://www.squaremeals.org/Programs/NationalSch oolLunchProgram.aspx Texas Education Agency ▪ http://tea.texas.gov/About_TEA/Laws_and_Rules/NC LB_and_ESEA/Title_I,_Part_A_- _Improving_Basic_Programs/Community_Eligibility_ Provision/ 24
Questions and Answers 25
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