1. The Community Eligibility Provision (CEP) Presented by the MDE Office of Child Nutrition (OCN) & Office of Federal Programs (OFP)

2. Office of Child Nutrition Scott Clements, Director

3. CEP History Healthy, Hunger-Free Kids Act of 2010 Provides an alternative to household applications for free and reduced price meals Offers all students free meals in high poverty LEAs and schools 3

4. School meal programs determine eligibility through: –Household income applications –Participation in assistance program (categorical eligibility) Through a case number on an application, such as Supplemental Nutrition Assistance Program (SNAP) Directly certified though matching participant lists with enrollment lists CEP determines eligibility by: –Eliminating household applications –Based on the percentage of directly certified students 4 Standard Procedures vs. CEP

5. Increases access to school meals for children in high poverty areas Eliminates household applications and administrative burden Reduces chance of overt identification Compares to other special provisions: no base year 5 Benefits of CEP

6. Phased in over a period of three years in a limited number of States LEAs and schools in eleven States are currently participating: –District of Columbia, Illinois, Kentucky, Michigan, New York, Ohio, West Virginia, Florida, Georgia, Maryland, and Massachusetts Available to all eligible schools July 1, 2014 6 Implementation

7. Requirements for Participation Minimum percentage (≥ 40%) of identified students in the school year prior to implementing CEP Serve free lunches and breakfasts to all students for 4 years May not collect household applications for free and reduced price meals 7

8. Election and Eligibility Criteria LEAs may elect the Provision for: –all district schools –a group of schools or –an individual school Eligible school or group of schools must have an identified student percentage of at least 40% by April 1 st of the school year prior to implementing CEP 8

9. Election and Eligibility Criteria LEAs are required to submit application by June 30 to begin CEP in the SY beginning July 1 Participation is an LEA level decision but requires concurrence from the State Agency (MDE Office of Child Nutrition) Residential child care institutions (RCCIs) may not participate in CEP 9

10. State Approval Process LEA must obtain OCN approval to participate OCN must review documentation submitted by the LEA to ensure the LEA/school: –Meets the minimum identified student percentage –Participates in both the NSLP and SBP –Is administratively capable 10

11. General Procedures LEAs and schools may opt in or opt out each year (June 30 th ) A new identified student percentage may be established each year of the four year cycle for use in the following year 11

12. Continuing CEP During the 2 nd, 3 rd and 4 th years, the LEA/school may select the higher of: –Identified student % from the year directly prior; or –The year prior to the first year of receiving benefits 12

13. Continuing CEP LEAs/schools in year 4 with an identified student percentage <40% but ≥ 30% are permitted to elect for an additional year (a grace year) LEAs/schools that do not meet the threshold must return to normal procedures the following SY 13

14. Notification No later than April 15 of each SY, –LEAs must submit to the State agency a list of schools –State Agency must notify LEAs about their CEP district wide eligibility status and provide participation guidance 14

15. LEA Responsibility By April 15 th of each year, LEAs must supply the State agency with a list of schools: –With an identified student percentage of at least 40% –With an identified student percentage greater than 30% but less than 40% 15

16. Identified Students, SNAP School eligibility is based on the number of students who meet the “identified” definition Directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP) and the extension of benefits to students within the same household. 16

17. Encouraged to update direct certification numbers annually to capture more current information. Non-CEP schools are required to conduct direct certification with SNAP files at least three times a year. Data are generally available through Statewide direct certification systems and for calculating State direct certification with SNAP performance measures. 17 Direct Certification Data

18. Other Identified Student Categories 18

19. Identified Student Percentage # of Identified Students as of April 1 x 100 Total NSLP Enrollment as of April 1 The percent of Identified Students is then multiplied by the USDA determined factor of 1.6 for SY 2014-2015 19

20. Applying the Multiplier School A has 600 students with access to the NSLP/SBP programs as of April 1 300 are in the “Identified Student” group Identified Student percentage of 50% 50% x 1.6 = 80% Free Reimbursement Rate, 20% Paid Reimbursement Rate 20

21. Meal Claiming Percentages Identified student percentage multiplied by a factor of 1.6 equals the % of total meals served reimbursed at the Federal free rate The remaining % of total meals is reimbursed at the Federal paid rate Any meal costs in excess of the total Federal reimbursement must be covered through non-Federal sources 21

22. Meal Claiming Percentages Examples 40% X 1.6 = 64% Free, 36% Paid 60% X 1.6 = 96% Free, 4 % Paid 62.5% X 1.6 = 100% Free Free Rate $3.01 vs Paid Rate $0.36 22

23. Office of Federal Programs Marcus E. Cheeks, Bureau Director

24. Within-District allocations Within-State allocations Equitable services to eligible private school students Accountability 24 Connections Between Title I and CEP

25. Tool to help school districts participating in CEP carryout Title I successfully Updates letters issued by ED in 2011 and 2012 –Clarifies options on within-district allocations and accountability –New section on equitable services Based primary on questions from the field during CEP phase-in Available at: http://www2.ed.gov/programs/titleiparta/13- 0381guidance.doc. http://www2.ed.gov/programs/titleiparta/13- 0381guidance.doc 25 New U.S. Department of Education (ED) Guidance

26. # of Identified students X 100 Identified Student%= Total # of enrolled students with access to NSLP/SBP The identified student percentage may be determined by: –An individual participating school –A group of participating schools in the LEA –Entire LEA if all schools participate 26 Identified Student Percentage

27. LEAs intending to elect CEP for some or all schools must: –Submit to the State agency (Office of Child Nutrition) documentation by June 30 th of the year prior to starting CEP –Ensure documentation demonstrates school or LEA meets the identified students percentage threshold as of April 1 st of the prior school year 27 Procedures-Documentation

28. Within-District Allocations 28

29. Title I ranking and serving procedures require school- level poverty data. Choices of school-level poverty measures include school lunch data as an option. CEP data are part of school lunch data. ED CEP guidance on within-district allocations applies when a school district has a CEP school and uses school lunch data to rank and serve schools. 29 Within-District Allocations

30. SCENARIOS WHERE SCHOOL DISTRICT HAS: CEP and non-CEP schools (Q18 in guidance) All CEP schools (Q19 in guidance) Grouped schools for CEP eligibility and reimbursement purposes (Q21 in guidance ) 30 Within-District Allocations

31. APPROACHES FOR CEP AND NON-CEP SCHOOLS (Q18) Using Multiplier for CEP schools –For CEP schools multiply the number of students identified by direct certification in a school by the 1.6 multiplier and divide by the enrollment in the school. –For non-CEP schools use the direct certification plus household application count. 31 Within-District Allocations EnrollmentCEP Identified students NSLP CountPercent Economically Disadvantaged 600350560 (350x1.6)93% (560/600)

32. APPROACHES FOR CEP AND NON-CEP SCHOOLS (Q18) Direct Certification: Rank all schools (CEP and non-CEP) solely on the basis of the percentage of students directly certified through SNAP (or another direct certification measure available annually for all schools). 32 Within-District Allocations EnrollmentDirect Certification (e.g. SNAP) Percent Economically Disadvantaged 75050067% (500/750)

33. ALL CEP SCHOOLS (Q19) An LEA may have all CEP schools. If so, the LEA may rank its schools by the percentage of directly certified students in each school, even though the multiplier is used to determine the USDA reimbursement amount. 33 Within-District Allocations

34. GROUPED SCHOOLS FOR CEP (Q21) An LEA may group schools to determine CEP eligibility and reimbursement. An LEA with an enrollment of at least 1,000 students must rank schools individually to determine Title I eligibility and allocations. 34 Within-District Allocations

35. CIRCUMSTANCE THAT MAY OCCUR: Multiple schools with 100 percent poverty rate (Q20 in guidance) More schools above school district- established cutoff for serving (Q22 in guidance) Timing of data for CEP and non-CEP schools (Q24 in guidance) 35 Within-District Allocations

36. MULTIPLE SCHOOLS AT 100 PERCENT POVERTY (Q20) Application of 1.6 multiplier may result in more than one school with a 100 percent poverty rate. Among those schools, an LEA may allocate a greater per-pupil amount to the school with a higher direct certification percentage. 36 Within-District Allocations

37. CEP SCHOOLS ABOVE SCHOOL DISTRICT CUTOFF (Q22) Application of 1.6 multiplier may result in more schools above LEA-established cutoff for allocating Title I funds. LEA options include: –Raising cutoff –Using another permitted poverty measure or composite of permitted measures 37 Within-District Allocations

38. TIMING OF CEP AND NON-CEP DATA (Q24) LEA may collect household applications from non-CEP schools at a different time than it identifies students in CEP schools (April 1). LEA options include: –Use data from the same school year. –Access direct certification data for non-CEP school on April 1 to use with household applications. –For Title I only, access direct certification data for CEP schools at the same time as accessing this information and collecting household applications for non-CEP schools. 38 Within-District Allocations

39. EQUITABLE SERVICES TO ELIGIBLE PRIVATE SCHOOL STUDENTS 39

40. In determining funding for Title I equitable services LEAs should continue to follow the current non-regulatory guidance titled Title I Services to Eligible Private School Children. Following consultation with private school officials, an LEA must identify the method it will use to determine the number of private school children from low income families who reside in participating public school attendance areas. 40 Equitable Services

41. METHODS FOR DETERMINING NUMBER OF PRIVATE SCHOOL CHILDREN FROM LOW-INCOME FAMILIES 1.Same poverty measure used by LEA for public schools students (e.g., school lunch data); 2.Comparable poverty data from a survey, extrapolating if complete data are unavailable; 3.Comparable poverty data from a different source; 4.Proportionality; or 5.Equated measure. The method selected determines if CEP data are relevant. 41 Equitable Services

42. CEP data are most relevant where an LEA uses school lunch data to allocate Title I funds for public schools and such data also are available for private school students. Title I funds for equitable services are generated on the basis of low income private school students who reside in a Title I public school attendance area. If a participating private school elects CEP, this does not necessarily mean that every private school student generates funds for equitable services. 42 Equitable Services

43. ED’s CEP guidance includes three scenarios describing how an LEA determines the amount of funds generated for equitable services if the LEA uses school lunch data for within-district allocations and there are public and/or private Community Eligibility schools. (Q29 in guidance) 1.LEA has no CEP public schools and serves students in a CEP private school. (Q29, Scenario 1) 2.LEA has CEP public schools and serves students in a CEP private school. (Q29, Scenario 2) 3.LEA has CEP public schools and serves students in a non-CEP private school. (Q29, Scenario 3) 43 Equitable Services

44. CEP PRIVATE SCHOOLS-GENERAL PRINCIPLES If a participating private school is a CEP school, the LEA multiplies the number of directly certified private school students who reside in a participating Title I public school attendance by the 1.6 multiplier to derive the number of low income students in each attendance area. This calculation must be done separately for each Title I public school attendance area in which the private school’s students reside. 44 Equitable Services

45. CEP PRIVATE SCHOOLS EXAMPLE 45 Equitable Services Public School Attendance Area Number of Private School Students by Attendance Area Number of Identified Students by Attendance Area Derived number of Low- Income Students A10080100 (80 x 1.6=128)¹ B301016 (10 x 1.6=16) C²1558 (5 x 1.6=8) ¹The derived number of low-income private school students cannot exceed the total number of private school students who reside in the attendance area. ² For purposes of this example, the public school in this attendance area is not a Title I school. Under these circumstances, the students would not generate funding for Title I equitable services.

46. An LEA need only take into account CEP data for a private school if the private school is a CEP school. To determine the number of low-income students in a non-CEP private school that reside in a participating public school attendance areas, an LEA would use one of the methods described in Q B-4 of the Title I Equitable Services Guidance. 46 Equitable Services

47. CEP AND PROPORTIONALITY After consultation with private schools, an LEA may choose to use proportionality to calculate the amount generated for equitable services. If a CEP public school’s poverty percentage for within-district allocations is 100 percent, every student in a private school that resides in that attendance area will generate funds for equitable services. 47 Equitable Services

48. 48 Questions/Contact Info Office of Child Nutrition 601.576.5000 Stephanie Robinson snrobinson@mde.k12.ms.us Office of Federal Programs 601.359.3499 Delicia Bennett dbennett@mde.k12.ms.us

49. Office of Career and Technical Education (601) 359-3461 Office of School Financial Services (601) 359-3294 Office of Special Education (601) 359-3498 Office of Management Information Systems (601) 359-3487 49 Additional Contact Information