The community eligibility provision (CEP) is an option of meal reimbursement that allows schools with high rates of students who qualify for free or reduced meals to provide breakfast and lunch to all enrolled students at no charge. This program was authorized by the Healthy Hunger Free Kids Act of 2010, and after being piloted in select states from 2011-2013, was rolled out nationwide for the 2014-2015 school year. The CEP provision streamlines the mechanisms by which children qualify for free or reduced price school meals, and significantly decreases the administrative burden of schools. Broadly stated, this provision works by using a formula to determine a school or district’s percentage of eligible students, and eliminating individual household applications.
Participation in CEP is an option for local education agencies (LEAs), and can be implemented in individual schools, groups of schools, or entire districts. In order to qualify for CEP, the “identified student percentage” (ISP) must be at least 40% of enrolled students. Identified students are individuals who are directly certified through Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), Food Distribution Program on Indian Reservations (FDPIR), and Head Start, or who appear on lists of homeless, migrant, or runaway youth. For groups of schools or entire districts, the aggregate percentage of identified students is used, as opposed to the percentage from each individual school. Combining schools together may allow some schools to participate which wouldn’t qualify individually.
Other requirements include participation in both the National School Lunch Program (NSLP) and the School Breakfast Program (SBP).
A list of eligible schools by state has been compiled by Food and Nutrition Services (FNS). Interested LEAs should work with their State agency to determine what documentation is required, and will need to alert the State agency of their intent to participate prior to the start of the school year. Deadlines for notification vary.
Once approved by the State agency, schools may elect CEP for a 4-year cycle, using the ISP determined at the time of application for all four years. Schools may discontinue participation in CEP at any time, though they are discouraged from doing so mid-year to avoid confusion. If discontinuing, LEAs must notify the state agency and immediately return to collecting household applications.
The most important aspect of this provision is that all students, regardless of household income, are able to receive both breakfast and lunch each and every day at no charge. Besides providing children with two nutritious meals, the stigma associated with eating meals at school is reduced because all students receive meals at no charge. Since no money needs to be exchanged in the cafeteria (unless purchasing items a la carte), the process becomes more streamlined and children are able to spend less time in line, and more time eating their meals.
Other benefits to the streamlined reimbursement include: Parents no longer need to worry about maintaining meal accounts, school administration no longer need to spend resources tracking down parents for missed payments, and teachers no longer need to worry that some of their students may be hungry. Additionally, the initial pilot studies of CEP resulted in increased participation rates for both breakfast and lunch.
Electing CEP allows for many schools to do away with the annual household applications that are required to determine eligibility on an individual basis. These applications have been known to be time consuming, complicated, and confusing for families. It is important to note that some states and districts still currently require schools to collect individual income eligibility information for other purposes such as state funding. Alternative solutions to this challenge can be found in the Resource section below. For schools that are able to remove the individual applications, the elimination of paperwork reduces administrative burden significantly at the school level as well.
Determining whether CEP is the right choice will require LEAs to carefully consider the financial viability for a school or district. To assist LEAs with estimating costs, FNS has created an Excel-based tool to estimate monthly federal reimbursement. That can be accessed here, under the heading: Is CEP Right for You?
After determining the ISP, the percentage is multiplied by 1.6 to determine the percentage of total meals served that will be reimbursed at the federal free rate (up to 100%). The remaining percentage of total meals served will be reimbursed at the federal paid rate. LEAs must determine if the reimbursement they receive will be financially viable. For example, if a school with an identified student percentage of 40% elects to participate in CEP, their federal reimbursement will be 64% free, and 36% paid. In order to receive 100% reimbursement at the federal free rate, schools must have an ISP of at least 62.5%. If the federal reimbursement at the free rate does not equal 100%, schools use non-federal funds to make up the difference. This can include funds from state matching programs, donations, or profits from a la carte sales.
The 1.6 multiplier is an estimate of students who would be eligible for free or reduced priced meals, as the number of directly certified students does not represent the total number of students who would be eligible if submitting a household application. The multiplier may change in the future (between 1.3-1.6); however, once a school elects to participate in CEP, the multiplier is locked in for the entire 4-year cycle.
As mentioned above, electing CEP may also have an impact on state funding, specifically Title I funding. LEAs considering CEP are strongly encouraged to discuss the effect CEP may have on state funding with their State Agency.
For even more details, and answers to specific questions, FNS has set up a comprehensive resource center with a wide variety of helpful items including fact sheets, webinars, and Q & A’s. This website can be accessed here: http://www.fns.usda.gov/school-meals/community-eligibility-provision-resource-center
Katherine Greene, MPH, Cornell University, Center for Behavioral Economics in Child Nutrition Programs