Community Eligibility Provision

2. Community Eligibility Provision Oklahoma State Department of Education Child Nutrition Programs 2017-18 Patricia Beutler, Director of Training 405-522-5039

3. Community Eligibility Provision—CEP • ‒Section 104a of the HHFKA of 2010 • Provides an alternative to household applications for free and reduced-price meals • Offers all students free meals in high poverty local education authority (LEA) and schools • Made available to all eligible LEAs nationwide July 1, 2014

4. Benefits of CEP •Easing administrative burden •Increasing participation •Improving efficiency •Eliminating stigma •Fighting childhood hunger

5. Community Eligibility Provision—CEP Only “direct certification” data is usedSchool, groups of schools, or a district is eligible if at least 40 percent of students are directly certifiedTo account for low-income families not reflected by data, an established multiplier is used to set meal reimbursement levelsSchool year 2017-18 multiplier 1.6

6. Eligibility Criteria • Must meet the 40% Identified Student Percentage • Participate in both NSLP and SBP • Comply with CEP procedures • Reimbursed using a formula based on the identified student percentage (ISP) • Continually identify Directly Certified students at least annually • Must cover with non-Federal funds any costs of providing meals to students that exceed the Federal reimbursement.

7. Participation Requirements • -Must offer free lunches and breakfasts to all enrolled students for a cycle of 4 years • -Do NOT collect household applications for free/reduced-price meal benefits • -Count total lunches and total breakfasts served to students daily • -Maintain all documentation for 3 years AFTER 4-year cycle ends

8. Define: Enrolled students • Students • Enrolled in AND attending participating schools • Have access to at least one meal service daily • Students with no access to breakfast or lunch would NOTbe included in count of enrolled students

9. Define: Identified Students • Children certified for free meals WITHOUT household application • Students certified based on documentation of eligibility as described in 7 CFR §245: • Directly certified with SNAP, TANF • List from tribal organization of FDPIR benefits • Migrant, Homeless, Runaway list • Head Start list • Even Start list • Foster Child list (from DHS) • LEA officials

10. Identified Student Percentage (ISP) • The identified student percentage may be determined by: • An individual participating school (site) • A group of participating schools (sites) in the LEA • Entire LEA if all schools (sites) participate

11. SHOULD DIRECT CERTIFICATIONCONTINUE REGULARLY ???(Beginning of School Year for Student Information System)(April 1 to consider if a new base year would be beneficial)

12. Updating the Percentages The identified student percentage established in Year 1 may be maintained for the entire 4-year duration MUST be able to identify at least 40 percent or more of its enrollment in the 4th year During the 2nd, 3rd and 4th years, the LEA/school may select the higher of either: -The ISP reflective of the most recent April 1; OR -The ISP from the year prior to the 1st year of implementation (Base Year) *Grace Year – If less than 40 percent in 4th year?

13. Documentation to Participate • - Ensure documentation meets identified • student percentage threshold as of • April 1 • - Certify intent to participate to State • Agency by June 30 of year prior to • beginning CEP through Community Eligibility (Not Mandatory) tab

15. State Agency Requirements • Review the documentation certified by the SFA • Verify minimum identified student percentage • Verify participation in both NSLP and SBP • Verify LEA administers meal program in accordance with regulations

16. R E E R A T E • How are breakfast and lunch reimbursed? • ISP used for both Breakfast and Lunch • ISP times 1.6 is free meal percentage • Percentage applied to number of meals served • Remainder of the percentage reimbursed at the “Paid” rate

17. Paid lunch equity tool issues • CEP School sites would not be factored into the calculation for the average weighted price for the PLE requirements. • In districts with some CEP schools and some NOT CEP, only the schools that are not CEP will be factored into the PLE Tool. • Districtwide CEP schools would not complete the PLE Tool. (Non-pricing districtwide)

18. Will the 1.6 multiplier change? • 1.6 through 2017-2018 school year • Can change to anywhere between 1.3 and 1.6 • Schools keep the same multiplier for all 4 years of the cycle

19. What are the rounding rules for calculating free and paid eligible percentages?? -Carry the calculation to two decimal places before rounding (ex. 86.15) -Standard rounding rules apply

20. Example: Calculating ISP • Enrollment = 700 • # of Identified DC Students = 550 • Percentage of DC Students = 78.57% 550 DIVIDED BY 700 = .78571429 or .7857 Multiply by 100 to come up with 78.57 %

21. Figuring ISP if grouping several sites 1202 DIVIDED BY 2164 = .5554528 OR .5555 = 55.55%

22. EXAMPLE: Calculating the percentage of Meals Reimbursed at Free Rate • Multiply the ISP by 1.6 to get the percentage of meals reimbursed at the free rate. • Carry the calculation to a minimum of two decimal places using standard rounding. • EX. 86.154 – will not round up to the next higher number - 86.15 % • This free percentage will be used to calculate the claim for reimbursement.

23. What are the Number of Meals Reimbursed at the free rate? • Multiply percentage of meals reimbursed at the free rate by the total number of reimbursable meals. • Ex. 800 meals X 86.15 percent = 689.2 • (Adjust to 689 meals claimed free)

24. How many paid meals are claimed? • The total meal count minus the free meals claimed equal the total paid meal claimed (Ex. 800 total meals – 689 free meals = 111 meals reimbursed at the paid rate

25. Claiming meals • 800 meals served • Free claiming percentage is 86.15% • 800 X .8615 = 689.2 or 689 meals claimed at the free rate. • 800 • -689 • 111 meals claimed at the paid rate

26. Edit Checks • Edit checks are still required to ensure that a school is not claiming more total meals than allowed. • If discrepancies are found, provide documentation explaining why? • Ex. Visiting students

28. Transfer of Eligibility • Students must receive meals at no cost for up to 30 operating days when transferring from a Provision school to a non-Provision school in the same LEA or another LEA during the school year

29. Carryover of Eligibility • LEAs are allowed to provide up to 30 operating days of meals at no cost to students who attended any Provision school during the prior school year • This includes carryover eligibility for schools in the same LEA and between LEAs

30. Visiting students CEP Schools • CEP schools should NOT charge visiting students for meals • Include visiting students in total meal count Non-CEP Schools • FNS encourages non-CEP schools that host visiting students from CEP schools to provide them with a free meal • Meals should be claimed by the non-CEP school according to the claiming percentages of the CEP school

31. May group(s) be changed in year 2? • Anytime there is a change in student population or enrollment that impacts ISP, must recalculate • Choices: • Form new site or group with own ISP using data from April 1 before CEP participation • Form new group of all schools and calculate ISP using data April 1 before the new grouping

32. Is SFA permitted to drop CEP? • Yes, though not recommended • At any time – even mid-year • Consult State Agency for Technical Assistance • Prepare to return to applications and meal-counting and claiming procedures • Timeframe of 30 days to return to regular meal-counting and claiming procedures if within school year • Notify State Agency by June 30

33. Public Release Requirement • SFA should notify each household that the school is CEP and all students eat free • Use NEW Public Release found on eClaims

34. Claim for Reimbursement • If SFA is district-wide CEP, claim will show a CEP Section. • If SFA is Provision and CEP, then both sections will show up. • Totals from the Provision or CEP section must be carried down to the Lunch/Breakfast Reimbursement section. • All Breakfast meals are SN.

35. Claim Examples

36. Claim Examples

37. Claim Examples

38. Claim Examples

39. LOW INCOME REPORT MAKE SURE PERCENTAGE OF FREE ELIGIBLES AGREE WITH SITE DC % X 1.6

40. Low Income Examples

41. CEP Current Year Information Tab

42. CEP AND OTHER FUNDING SOURCES All other funding sources follow CEP Guidance for renewing direct certification percentages -If increase, may use new percentage -If decrease, may continue with original percentage Any change to multiplier is applied to all other funding sources Schools, groups of schools, or district may not exceed 100 percent

43. STATE AID AND E-RATE • Identified student percentage BY SITE times 1.6 = FREE percent for site • Each individual school’s percentage is used, NOT group percent or district percent • Low Income Report: Use the percentage of FREE • April 1 data in previous year compared to October 1 enrollment in current year for actual FREE student count

44. TITLE 1 • Direct certification percentages as of April 1, 2017 by site • Times multiplier – 1.6 • Compare free percentage to enrollment as of October 1, 2017 • Each individual school’s percentage is used, • NOT group percent or district percent for • Title 1

45. TITLE 1 QUESTIONS,CONTACT:Nancy HughesDirector of Finance Federal Programs405-521-3170Nancy.Hughes@sde.ok.gov

46. CEP QUESTIONS ???????????????

47. CHILD NUTRITION PROGRAMS 405-521-3327 • Oklahoma State Department of Education • Patricia Beutler • patricia.beutler@sde.ok.gov • 405-522-5039 • Judy Cowden-Smith • judy.cowden-smith@sde.ok.gov • 405-522-5045