School Nutrition Association March 2015 : Page 34

BY ARIANNE CORBETT, RD More Meals and a Lighter Load Making Community Eligibility Work for You School nutrition professionals love kids. They love being among the very few people in the school that sees every student, every day. They love to offer warm hugs and reassuring smiles. They love to fi ll hungry stomachs with nutritious meals. They love to see a child try a new vegetable, while encouraging a friend to do the same. School nutrition professionals do not love administrative hurdles and paperwork. They don’t love chasing down parents for meal applications, and they positively hate spending hours on the phone trying to collect meal charges. 34 School Nutrıtıon • MARCH 2015

More Meals and a Lighter Load: Making Community Eligibility Work for you

By Arianne Corbett, RD

School nutrition professionals love kids. They love being among the very few people in the school that sees every student, every day. They love to offer warm hugs and reassuring smiles. They love to fill hungry stomachs with nutritious meals. They love to see a child try a new vegetable, while encouraging a friend to do the same.

School nutrition professionals do not love administrative hurdles and paperwork. They don’t love chasing down parents for meal applications, and they positively hate spending hours on the phone trying to collect meal charges.

Fortunately, the new Community Eligibility Provision (CEP) is changing the business of school nutrition and offering operators more of what they love and less of what they don’t. Patricia Cunningham, supervisor of nutrition services for Seaford (Del.) School District, quickly has become a champion of the program. “We began Community Eligibility in July 2014 with nothing but positive results. Everyone receives a nutritious meal with no concerns about the cost and ability to pay. As I near the end of my career, it is a dream come true.”

What Is CEP?

CEP allows schools in high-poverty areas to offer nutritious meals through the National School Lunch (NSLP) and School Breakfast Programs (SBP) free of charge to all students without collecting and processing school meal applications. It’s the most advanced, streamlined funding option for school meal programs to date and can provide eligible operations with significant bottom line rewards, both in terms of labor cost savings (associated with applications administration) and the significant potential for higher student participation and, subsequently, greater federal reimbursements.

The Healthy, Hunger-Free Kids Act of 2010 (HHFKA) established the program and directed a four-year phase-in to its nationwide roll-out. A total of 11 states (Illinois, Kentucky, Michigan, Washington, Ohio, West Virginia, New York, Florida, Georgia, Maryland, Massachusetts) and the District of Columbia were early adopters and now, as of SY 2014-15, CEP is available in all states.

The program has experienced huge popularity and rapid expansion. As of SY 2014-15, 6.4 million children have been enrolled at nearly 14,000 CEP schools in 2,200 districts across the country—more than one of every 10 U.S. schools. “We knew CEP was going to be a game changer, but 14,000 schools and over 6 million kids is remarkable!” exclaims Jessie Hewins, senior child nutrition policy analyst for the Food Research and Action Center (FRAC).

How It Works

Designed to improve access by low-income children to valuable school meals, CEP streamlines existing processes for identifying students eligible for free and reduced-price meals and simplifies tracking and reimbursement for meals served. Schools agree to provide both breakfast and lunch to all students at no charge and receive, in exchange, a reduction in administrative work. Rather than rely on individual household applications for free or reduced-price meals, student eligibility is identified by other means. The majority of “identified students” are directly certified through data matching, because their households receive benefits from the Supplemental Nutrition Assistance Program (SNAP) or the Temporary Assistance Program for Needy Families (TANF). Homeless, migrant and Head Start students identified at the local level also count toward the eligibility total.

Any school district, individual school or group of schools (including any public, private or charter school) that participates in the NSLP and SBP and has 40% or more identified students enrolled as of April 1 of the previous school year is considered eligible to participate in CEP at the start of the following academic year. Schools and school districts that elect to participate in the CEP may stop collecting applications to determine free and reduced-price meal eligibility and instead rely solely on the identified students percentage (ISP) of students certified without an application.

CEP also reduces a school nutrition operation’s administrative burden of counting and claiming meals. Instead of tracking how many free, reduced-price and paid meals are served at both breakfast and lunch, schools can simply track the total number of meals served and apply the “free claiming percentage formula” to determine the reimbursement rate. This formula is determined by multiplying the percent of identified students enrolled in a school/ group/district by 1.6 to arrive at the percentage of meals that will be reimbursed at the maximum federal free meal reimbursement (capped at 100%). Any remaining percentage of meals is then reimbursed at the lower federal reimbursement rate for paying students. For example, a school with 50% identified students would be reimbursed at 80% of the breakfasts and lunches eaten at the free reimbursement rate and the remaining 20% at the paid rate.

Once enrolled in CEP, schools are guaranteed the same free claiming percentage for four years. If the ISP increases during the four-year cycle, the free claiming percentage can be adjusted upward each school year. However, even if the ISP decreases, the original free claiming percentage will remain in effect until the end of the four-year cycle. Schools do not collect any applications for free and reduced-price meal eligibility for the length of the CEP cycle.

Winners All Around

“Schools get to put more time into education and preparing healthy meals, instead of paperwork. Low-income parents don’t have to fill out a redundant form. And, most important, hungry children are fed in a stigma-free environment. With access to a healthy breakfast and lunch, they are ready to focus in the classroom,” emphasizes Zoë Neuberger, senior policy analyst for the Center on Budget and Policy Priorities (CBPP).

Seaford’s Cunningham agrees with these benefits. Her school district’s administration understands the correlation between good nutrition and learning. “It is a program that will benefit community families and their children, as well as the district,” she notes.

Early evaluations are showing positive outcomes. A USDA evaluation found CEP correlated with significantly higher student participation in both the NSLP (5.2%) and SBP (9.4%), than seen in non-participating local education authorities (LEAs). And because a higher proportion of meals were reimbursed as free meals, CEP increased average federal reimbursements about 6% for NSLP meals and 2% for SBP meals.

Another study looked at schools that implemented CEP in Kentucky, Illinois and Michigan in SY 2011-12. It found that breakfast participation increased by 25% and lunch participation increased by 13%. School districts that were able to imple-ment CEP district-wide, such as Detroit Public Schools, saw even greater gains in lunch participation. In Detroit during SY 2011-12, breakfast participation increased by 15% (7,400 additional students per day) and lunch participation increased by 30% (nearly 14,000 additional students per day) compared to the previous year.

Eliminating the lengthy application process frees up important time for stretched school nutrition operations. Dora Rivas, executive director of food and child nutrition services, Dallas Independent School District, describes the experiences of her first year participating in CEP: “I can’t begin to tell you how much easier the start of school was. We were able to focus our energy on food orders, quality and our nutrition initiatives. It was a hugely positive start to this school year!”

Jan Miller, foodservices director. Springfield (Ill.) School District, is using her newly “found” staff hours in the wake of CEP to support training and technical assistance efforts on the new nutrition regulations. “My assistant does not have to spend the first two months of school approving lunch applications, along with spending time on the phone trying to get the correct information from parents,” explains Miller. “She now spends that time visiting schools, helping to ensure we are following the new nutritional requirements. My managers at the schools are also saving time, because they are not constantly approving applications and collecting charges.” The additional revenue that CEP has brought to the Springfield operation has been a welcome change, too. “We will be putting that extra money toward new equipment this year,” adds Miller.

Another benefit is a more streamlined operation— especially when lunch periods are notoriously tight. “Our line goes much smoother. [The cashiers] just have to punch in a number. There is no collecting money,” describes Miller. Donna Martin, PhD, director of school nutrition programs for Burke County (Ga.) Public Schools, agrees, noting, “It really does speed up service, which is a great thing!” Some schools find that CEP allows them to implement alternative service methods, like breakfast in the classroom, more easily.

In West Virginia, the implementation of CEP, combined with a legislative requirement for breakfast after the bell, is having amazing results. “Community Eligibility has done so much for the state of West Virginia,” asserts Rick Goff, executive director of the office of child nutrition for the West Virginia Department of Education. “We have 55 [LEAs] participating, and the program is available district-wide in 17 districts. CEP, coupled with the success of our Feed to Achieve Act, has resulted in 52% breakfast participation across our state.” He adds, “There are lots of things we can’t help, [being] outside of the households of our food-insecure children. But one thing we can do is to give them a nutritious breakfast and get them ready for the day and ready to learn.”

Expect Bumps Along the Way

As a new program, there will always be some resistance to change—and the numbers won’t make this the right program for everyone. USDA’s evaluation of CEP found the challenges at the state level included the short window for implementation and subsequent difficulties in understanding— and addressing—the implications that using CEP would have on educational funding programs that rely on individual student meals certification data, such as Title I and E-Rate. Funding concerns extended to the LEA level, too.

Although it is USDA, and not the U.S. Department of Education that administers the NSLP, many School Nutrition readers know that there is a connection between the federal school-based child nutrition programs and several education programs operated under Title 1 of the Elementary and Secondary Education Act of 1965. This is because state agencies and LEAs frequently use free and reduced-price meal eligibility income data to determine Title 1 eligibility. In some communities, school administrators have expressed concern about how CEP participation will affect critical school funding.

Fortunately, the Department of Education has developed “extensive and flexible” guidance (visit to download) to show how states and LEAs can successfully use CEP data to implement Title 1 requirements. Agriculture and Education Secretaries Tom Vilsack and Arne Duncan also issued a joint letter supporting CEP in February 2014.

If you are interested in implementing CEP, be sure to arm yourself with this guidance. Goff credits West Virginia’s Community Eligibility Option coordinator with much of their state’s success in overcoming school administrator anxiety regarding Title 1. “She made herself a Title 1 and E-rate expert, so when she went into meetings, she knew as much as they did!”

Burke County’s Martin also recommends connecting your school administrators with those in neighboring school districts who are using CEP. “Talking to another county that has already implemented [the program] is a great way to get reassurance,” she explains.

Above all, having a conversation with champions for the program in your area can give you peace of mind. State agencies should able to provide information on identifying neighboring CEP programs, as they are required to publish lists of eligible and participating districts. In addition, FRAC, CBPP and other advocacy organizations maintain lists of participating districts, which you can access to find colleagues who can provide answers to tough questions about CEP. “It can be most powerful to hear from your peers, to hear firsthand from someone who speaks the same language. They can be really honest about the challenges and what can be done to overcome them,” explains Hewins at FRAC.

Bring stakeholders together. School nutrition, district administrators and staff responsible for Title 1, assessment, school funding, accountability and E-rate all should be at the table to discuss the pros and cons of bringing CEP to your district. USDA, SNA and FRAC have various online resources available, ranging from webinars to sample presentations and guidance, all of which can assist you in making the case. Remember, school districts can choose one school, a group of schools or the entire district to participate. If a district-wide program is too tough a sell, consider bringing on one high-need school, or group of schools, as a pilot.

It’s a Number Game

CEP doesn’t work everywhere. There is no magic formula to say which schools and districts are best suited for participation. The best way to figure it out is to run the numbers.

On its Bonus Web Content page, School Nutrition has posted a CEP estimator tool developed by USDA. You can base your expected level of reimbursement using enrollment, ISP and estimated participation data. Every district must look at its own individual situation—but it’s important to look beyond past reimbursements alone. Consider the decreased administrative costs, how much revenue the district is actually collecting, the amount time and money spent on recouping meal charges and what different types of participation is expected if all meals are free. By considering all factors, a district can make the most informed decision on which schools can operate under CEP and remain financially viable.

Think of the ISP provided by the state agency simply as a starting point. “You can’t take those figures at face value,” warns Rivas in Dallas. Often, name errors, misspellings and omissions can prevent students who should match from appearing on a direct certification list. When Martin set out to move her Burke County school meals program from Provision 2 to CEP, she and her team set their sights high. “We went through every name on the direct certification list. If the child wasn’t eligible, we looked them up in our school system. The biggest impact for us was correcting name changes and misspellings.” But spending that extra time upfront paid off, with an ISP of 63.5%—allowing her to gain the free meal rate reimbursement for all meals served.

Another way to potentially increase the ISP is to identify the siblings of those students that appear on the direct certification list. USDA requires that all children living in households receiving assistance under SNAP be directly certified for free school meals. This means if one child appears on the direct certification list, but has two siblings living in the same household, all three students count toward your ISP. School districts may have this information through the school office or school nutrition point-of-sale system. “By working with our [SNAP] office and closely monitoring sibling matches, we were able to increase our free meal percentage closer to 90%, making the program a whole lot more viable,” reports Rivas.

Maintain close relationships with your school’s homeless liaison and migrant coordinator, as well as with local foster care or placement agencies. Implement a system where the school nutrition operation is contacted any time a new student is identified through these entities.

Finally, maximize your reimbursement groupings. Rather than group schools by grade levels or neighborhoods, consider organizing them by ISP, then match schools with a higher and lower ISP to get the highest combined percentage.

Grouping schools may provide for the inclusion of schools that may not be eligible on their own. A sample grouping tool is available online as part of this month’s Bonus Web Content.

Become a Champion

Once your district has decided to embark upon CEP, be sure to spread the word! Publicize your participation through a press release, op-ed or letter to the editor. Use social media channels, like Facebook and Twitter, to share the news—and be sure to send a letter home to parents! Celebrate your CEP status with a website banner that promotes the fact that breakfast and lunch are available at no charge. Samples of these different communication tools are available online at

CEP provides healthy, nutritious breakfasts and lunches to the children that need it most and more than 2,000 schools districts have already made the decision to implement. Should you? “Districts that have adopted community eligibility are its biggest champions, because it’s a win-winwin opportunity. Leaders at the districts with eligible schools have a terrific opportunity this spring to take a fresh look at community eligibility to see whether they can bring its benefits to their students,” stresses CBPP’s Neuberger.

Goff, one of CEP’s true champions, sums it up: “It’s the right thing to do and in the children’s best interest. We’re talking about feeding children here. Children can’t pull themselves up by their bootstraps; they don’t have bootstraps. In the greatest country in the world, it’s a beautiful thing that we can do this. And it is something we should do!”

Arianne Corbett is managing director of Leading Health, LLC, in Tampa Fla., and a former manager of nutrition advocacy at SNA. Photography by


• CEP streamlines existing processes to identify free/reduced-eligible students and simplifies meals tracking and reimbursements.

• Schools don’t collect applications for the length of the four-year CEP cycle

• The Department of Education has developed guidance to show how states and districts can use CEP data for Title 1 funding.


The potential for CEP expansion is so exciting, and USDA, SNA and other child nutrition advocates have created a wide variety of tools and resources to help school nutrition professionals make the most of this opportunity. School Nutrition has collected several of these and made them available at

Read the full article at

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