Community Eligibility Provision (CEP) and Provisions 1,2 & 3 - M-1 CEP and Provisions

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Community Eligibility Provision (CEP) and Provisions 1,2 & 3 - M-1 CEP and Provisions
Community Eligibility
      Provision (CEP)
   and Provisions 1,2 & 3

M-1 CEP and Provisions
Community Eligibility Provision (CEP) and Provisions 1,2 & 3 - M-1 CEP and Provisions
CEP and Provisions 1, 2 & 3
      Overview of CEP ........................................................................................................... M-3
      Identified Students ........................................................................................................ M-4
      Meal Claiming ............................................................................................................... M-4
      Determining How to Setup CEP Participation ............................................................... M-5
      Individual, Group, District Worksheet ............................................................................ M-6
      Impact on Other Programs ............................................................................................ M-8
      Important Dates ............................................................................................................. M-9
      Provisions 1, 2 & 3 ........................................................................................................ M-9
      USDA Guidance on Provisions ................................................................................... M-10

 Notes

    M-2 CEP and Provisions
Community Eligibility Provision (CEP)
Overview of CEP

The Community Eligibility Provision (CEP) is an alternative to using household eligibility
applications in high poverty local educational agencies (LEA’s) and schools. To be eligible for
CEP, LEA’s and schools must:
   • Meet a minimum level (40%) of their students as Identified Students in the year prior to
       implementing CEP.
           o Identified Students are those students that are directly certified, students that
                were extended benefits, and students that are certified for free meals by the
                homeless liaison, migrant coordinator and/or Head Start coordinator.
   • Agree to serve lunch AND breakfast at no cost to ALL enrolled students.
   • Agree to cover any costs of providing meals above the amounts provided in federal
       assistance, with non-federal funds.

LEA’s and Schools that choose to participate in CEP must NOT:
   • Collect household eligibility applications from households during the period in which they
       are participating in CEP.
   • Be a Residential Child Care Institution (RCCI).

Reimbursement for CEP schools is based on a claiming percentage that is derived from the
percentage of Identified Students as of April 1 the year prior to implementing CEP. The
claiming percentage established for the first year of CEP is guaranteed for a period of four
school years, unless the school provides updated numbers each year by June 30th.

Updated numbers would only be used if they increase the schools claiming percentage. Any
submitted increase to ISBE after the first year is only good for one year. A year with no
submitted increase would default back to the first year claiming percentage. For example:

Year 1                                                      85.46% Free        14.54% Paid

Year 2 – submitted an increase to ISBE                      91.33% Free        8.67% Paid

Year 3 – no increase provided to ISBE (back to year 1)      85.46% Free        14.54% Paid

Year 4 – submitted an increase to ISBE                      89.79% Free        10.21% Paid

   M-3 CEP and Provisions
Identified Students

In order to be eligible for CEP an LEA, school, or group of schools, must have a minimum
Identified Student percentage of 40% as of April 1 the year prior to implementing CEP.
Identified Students include the following:
    • Directly certified for free meals on the basis of their participation in the Supplemental
         Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families
         (TANF) and the extension of benefits to students within the same household. (Electronic
         Direct Certification System in Illinois)
    • Directly certified Foster child (Not through use of a household application). Directly
         certified Foster children DO NOT provide and extension of benefits.
    • Homeless (certified by homeless coordinator listing)
    • Runaway (certified by runaway coordinator listing)
    • Migrant youth (certified by the migrant coordinator listing)
    • Head Start (certified by the Head Start coordinator listing)

Identified Students do NOT include the following:
   • SNAP/TANF number on an application
   • Foster child marked on a household application
   • Submission of a household application based on income

This number of Identified Students is as of April 1. LEAs can maximize Identified Student
numbers by ensuring the annual AND monthly direct certification files are used and that
students are provided an extension of benefits when appropriate.

An extension of benefits occurs when any member of a household is found in the Electronic
Direct Certification system. Those free benefits can be extended to all other members in that
household, therefore all students in that household would be directly certified for free meals and
would count as Identified Students in schools applying to participate in CEP. Ensure that you
maintain documentation of all Identified Students including all extensions of benefits.

Claiming Meals

Schools that apply to participate in CEP will be provided an approved free and paid claiming
percentage based on the number of Identified Students, multiplied by the USDA established
Claiming Factor. The USDA established Claiming Factor can change annually, but a school is
locked into the factor established in year one of CEP implementation for a 4 year cycle.

CEP schools will only need to track the total number of meals served each day, and will no
longer need to keep track of meals served by free, reduced and paid categories. This same
process is done for breakfast and lunch meals served each day. The total number of meals will
be broken down into FREE and PAID meals; there will not be any REDUCED-PRICED meals
claimed in CEP participating schools. Schools in CEP will still need to complete a meal count
edit form specific to CEP.

   M-4 CEP and Provisions
Example of determining the approved claiming percentage:
   • Number of Identified Students as of April 1: 241
   • Enrollment as of April 1: 407

            o   241 Identified Students divided by 407 Total Enrollment = 0.5921376
            o   0.5921376 x 1.6 (Current USDA Claiming Factor) = .94742016

            o   94.74% of all meals served are reimbursed at the FREE rate
            o   100 % minus 94.74 % equals 5.26%. 5.26% of all meals served are reimbursed
                at the PAID rate.

When completing claims in the WINS system monthly, only the total number of breakfasts and
lunches served each day needs to be reported. The system will apply the approved claiming
percentage to that total number of meals and automatically determine how many FREE and
PAID meals to be claimed each day.

Determining How to Setup CEP Participation (Site, Group, District)

Participation in CEP can be as an individual site, a group of sites or district wide. Districts can
also choose to have a mixture of individual sites and/or groups of sites within the district. LEAs
can determine how to setup sites for participation in CEP based on what will be most beneficial
to the LEA.

 Remember that an individual site, group of sites, or district must meet the minimum of
             40% of its students being Identified Students as of April 1.

Group(s) will need to add together the number of Identified Students and enrollment from all
schools in the group(s) to determine if the group is eligible for CEP. There can be multiple
groups within one LEA.

District wide participation in CEP would add together the number of Identified Students and
enrollment for all schools in the district. The percentage of Identified Students for the entire
district must be greater than 40%. A factor to keep in mind is that for grant purposes and
distribution of Title I, schools are grouped together for CEP would use their individual
percentage for applying for grants and also for the distribution of Title I funds to each school.

Examples:

                            Identified                  Approved Claiming Percentage (with
School                       Students     Enrollment                USDA factor)
                                                         Free Percentage    Paid Percentage
Lincoln Elem                    146           213              100%                0%
Washington Jr High              285           468             97.44%             2.56%
Reagan High School              279           607             73.54%             26.46%

Group together Lincoln
and Reagan for CEO              425           820             82.93%              17.07%

   M-5 CEP and Provisions
In the example, the LEA has chosen to group together Lincoln Elem and Reagan High School,
and Washington Jr. High School will participate individually. The approved CEP percentage for
the Lincoln and Reagan group will be 82.93% FREE and 17.07% PAID, and the approved CEP
percentage for Washington will be 97.44% FREE and 2.56% PAID.

If Lincoln Elementary were to apply for a grant the individual percentage of 100% FREE and 0%
PAID, would be used. The same goes for distribution of Title I funds, all three schools would
use individual claiming percentages for distribution of Title I, Lincoln and Reagan would not use
their group percentage for Title I or for grants.

CEP Worksheet

To assist LEA’s in determining if CEP is a better option for schools or districts then using the
traditional household eligibility applications, ISBE has developed a worksheet. The worksheet
only takes into account actual meal reimbursement and revenue from PAID and REDUCED-
PRICED meals. It does not take into account other savings, such as no longer printing, mailing
and processing household applications, and the completion of the verification process.

In order to complete the worksheet the following information will be needed:
    • Determine if the worksheet will be completed by individual site, group or district.
    • Claim data:
            • Breakfast – FREE, REDUCED-PRICE, PAID meals
            • Lunch – FREE, REDUCED-PRICE, PAID meals
    • Student prices:
            • Breakfast – REDUCED-PRICE and PAID
            • Lunch – REDUCED-PRICE and PAID
    • Enrollment (Individual site, group or district)
    • Identified Students (Individual site, group or district)
    • Rate of Reimbursement (NSLP and SBP)
    • Remember if sites are being grouped together or the whole district, combine claim data,
       enrollment, and Identified Student numbers.

   M-6 CEP and Provisions
LEAs will fill in the yellow highlighted boxes of the worksheet, and the results will be calculated
and auto-filled in at the bottom of the worksheet. There are four worksheet options to choose
from based on free and reduced eligibility rate and whether a school is severe need or non-
severe need breakfast.
    1) NSLP 60% rate and non-severe need breakfast – For a school/group/district that
       receives the higher reimbursement rate for the entire district being greater than 60% free
       and reduced eligible, but does not receive severe need breakfast reimbursement.
    2) NSLP 60% rate and severe need breakfast – For a school/group/district that receives the
       higher reimbursement rate for the entire district being greater than 60% free and
       reduced eligible and receiving the additional severe need breakfast reimbursement.
    3) NSLP less than 60% rate and non-severe need breakfast – For a school/group/district
       that does not have greater than 60% free and reduced eligible and the sites do not
       receive severe need breakfast reimbursement.
    4) NSLP less than 60% rate and severe need breakfast – For a school/group/district that
       does not have greater than 60% free and reduced eligible and does receive severe need
       breakfast reimbursement.

Example – Worksheet for an Individual school:
   • School Enrollment: 167
   • Number of Identified Students: 112
   • % Identified Students: 67.06%
   • Paid Student Meal Prices:
          • Lunch: $1.85
          • Breakfast: $1.30
   • Average Daily Participation %:
          • Lunch: 86.71%
          • Breakfast: 67.16%

   M-7 CEP and Provisions
Impact on Other Programs

Participation in CEP may impact other areas of the school district, areas outside of the meal
programs. The main change that will occur with CEP schools is that there will no longer be
eligibility data by individual student. In other words, there will no longer be free, reduced, and
paid determinations for the meal programs and therefore that data will no longer be available for
other programs to use. Some programs that may possibly be impacted by no longer having
individual student eligibility data include:
    • Title I
    • E-Rate
    • Illinois School Fee Waivers

To assist schools in determining individual student data that may be needed, a form has been
developed that is not tied to the National School Lunch Program (NSLP), but will assist schools
in gathering individual student socioeconomic data. The Household and Income Form (69-72)
is housed on the Student Information System (SIS) webpage under Demographics/Enrollment.

Title I
The United States Department of Education has issued guidance related to Title I and CEP
participating schools, a copy of the letter is available on the ISBE website. Total Title I funds will
not be affected by participation in CEP. However, the distribution of those Title I funds by
school building could possibly be impacted. Guidance instructs districts that Title I funds are to
be distributed based on the individual schools eligibility. This means that if schools are grouped
together for CEP, the district would not use the groups approved claiming percentage for the
distribution of Title I, the individual schools eligibility would be used.

Title I funds. If we use the same example we used earlier:

                             Identified                  Approved Claiming Percentage (with
School                        Students    Enrollment                 USDA factor)
                                                          Free Percentage    Paid Percentage
Lincoln Elem                    146           213               100%                0%
Washington Jr High              285           468              97.44%             2.56%
Reagan High School              279           607              73.54%             26.46%

Group together Lincoln
and Reagan for CEO              425           820              82.93%              17.07%

In this example Lincoln and Reagan are grouped together for CEP, but for Title I the individual
schools eligibility would be used. Lincoln’s would be 100% Free, and Reagan’s would be
73.54% Free.

For question related to Title I, please contact staff in the Innovation and Improvement Division of
the Illinois State Board of Education at (217) 524-4832.

   M-8 CEP and Provisions
E-Rate
The Federal Communications Commission has issued guidance related to E-rates and CEP
participating schools. A copy of the letter is available on the ISBE website. For E-rate the
guidance states that CEP schools should use the free and reduced eligibility from the year prior
to implementing CEP.

For question related to E-Rates, please contact staff in the Special Education Division of the
Illinois State Board of Education at (217) 782-5589.

Fee-Waivers
Under Illinois law, school districts are required to waive charges for textbooks and other fees for
children whose families are unable to afford them, including children eligible for the federal free
lunch and breakfast program, and for any other extenuating circumstances for which the school
board will waive fees as communicated in its adopted policy (e.g., reduced-price lunch or
medical emergencies). [105 ILCS 5/10-20.13 and 34-21.6]

CEP participating schools will NOT have eligibility status by individual student. Schools in CEP
must choose to:
   • Waive all fees; OR
   • Use Household and Income Form (69-72)

Important Dates Related to CEP

   •   April 1: Determine the number if Identified Students, Determine enrollment and
       Application for CEP available
   •   June 30: Deadline to apply for CEP; Due date to withdraw from CEP; and Due date to
       increase your claiming percentage.

                                          Provisions
    In an effect to reduce paperwork at the local level Congress enacted three special
 assistance alternatives, more commonly known as "Provisions" for the National School
     Lunch and School Breakfast Programs. Approval prior to implementation of the
                    provisions must be obtained from Nutrition Services.

Provision 1

This Provision reduces application burdens by allowing free eligibility to be certified for a 2 year
period. In schools where at least 80 percent of the children enrolled are eligible for free or
reduced meals, annual notification of program availability and certification of children eligible for
free meals may be reduced to once every 2 consecutive school years. All other households
must be provided a meal application and are allowed to apply for meal benefits each school
year. There is no requirement to serve meals at no charge to all students. Schools must
continue to record daily meal counts of the number of meals served to children by type as the
basis of calculating reimbursement claims.

   M-9 CEP and Provisions
Provision 2

This Provision reduces application burden and simplifies meal counting and claiming
procedures. It allows schools to establish claiming percentages and to serve all meals at no
charge for a 4 year period (base year plus three non-base years). It can be used for breakfast
and/or lunch. During the base year, the school makes eligibility determinations and takes meal
counts by type. During the next three years, the school makes no new eligibility determinations
and only counts the total number of reimbursable meals served. Reimbursement during these
years is determined by applying the percentages of free, reduced price and paid meals served
during the corresponding month of the base year to the total meal count for the claiming month.
Schools participating in this alternative must pay the difference between the Federal
reimbursement and the cost of providing all meals at no charge. The money to pay for this
difference must be from sources other than Federal funds. At the end of the 4 years, a 4 year
extension may be approved if the income of the school's population remains stable or declines.

Provision 3

This Provision reduces application burdens and meal counting and claiming procedures. It
allows schools to receive the same level of Federal reimbursement and commodity assistance
each year, with some adjustments for a 4 year period. Schools must serve meals to all
participating children at no charge for a period of 4 years. These schools do not make additional
eligibility determinations. Instead, they receive the level of Federal reimbursement and
commodity assistance paid to them the last year in which they made eligibility determinations
and meal counts by type, this is the base year. For each of the 4 years, the level of Federal
reimbursement and commodity assistance is adjusted to reflect changes in enrollment and
inflation. The base year is not included as part of the 4 years. Schools participating in this
alternative must pay the difference between the Federal reimbursement and the cost of
providing all meals at no charge. The money to pay for this difference must be from sources
other than Federal funds. At the end of each 4 year period, Nutrition Services may approve a 4
year extension if the income level of the school's population remains stable or declines.

Provision Guidance and Memorandums

Questions and Answers - Provision 1, 2, 3

USDA Food and Nutrition Service - Provision 1, 2, & 3

SP 37-2008 30 - Day Carryover and Delayed Implementation for Provision 2

SP 04-23 Free and Reduced Price Special Assistance Provision 2 & 3: Expanding Provision 2 & 3 District-wide

SP 01-02 School Meal Applications and Direct Certification During the Operation of Provision 2 and 3

SP 99-02 Special Assistance Certification and Reimbursement Alternative Provision 3: Two New Options

SP 99-04 Numbers of Free and Reduced Price Eligible Children for Title I Purposed in Provision 2 and 3 Schools

SP 99-26 Record Retention Requirements for Schools Implementing Special Assistance Certification and
Reimbursement Alternative - Provision 2 and Provision 3

SP 95-08 Extension of Provision 2 Procedures in Schools

SP 94-61 Free and Reduced Price Eligibility--Special Certification, Provision 2

 M-10 CEP and Provisions
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