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The Community Eligibility Provision: What Food Service Management Companies Need to Know

April 14, 2015
BY

Jessie Hewins (Food Research and Action Center) and Becca Segal (Center on Budget and Policy Priorities)

The Community Eligibility Provision (CEP) is a federal option for high-poverty schools to offer breakfast and lunch at no charge to all students without collecting school meal applications.  Created in the Healthy, Hunger-Free Kids Act of 2010, the provision was phased in, a few states at a time, for three years beginning in the 2011-2012 school year.  It became available in all states for the 2014-2015 school year. In the first year of nationwide availability, more than 14,000 high-poverty schools in 2,200 school districts are participating.  Over 6 million children now attend community eligibility schools and have access to two healthy meals at school each day.[1]

Benefits of the Community Eligibility Provision

Lessens administrative work.  School nutrition programs no longer have to collect and verify school meal applications or track student eligibility when serving meals, allowing them to focus on feeding children.

Increases participation.  Community eligibility eliminates the stigma that the school meal programs are only for low-income children and streamlines service in the cafeteria, resulting in increased participation.  In schools that implemented community eligibility in the 2011-2012 school year in Illinois, Kentucky, and Michigan:

  • Breakfast participation increased by 25 percent, from 44 percent in October 2010 to 56 percent in October 2012; and
  • Lunch participation increased by 13 percent, from 69 percent in October 2010 to 78 percent in October 2012.[2]

For school districts that implement community eligibility district-wide, like Detroit Public Schools, the effect is amplified. In Detroit, during the 2011-2012 school year, compared with the previous school year:

  • Breakfast participation increased by 15 percent, or 7,400 additional students per day; and
  • Lunch participation increased by 30 percent, or nearly 14,000 additional students per day.

Facilitates implementation of alternative breakfast service models.  When schools don’t have to collect fees or count each meal served by fee category, it is easier to implement breakfast in the classroom and “grab and go” service models that can further boost participation.

Improves the financial viability of school nutrition programs.  As a result of expanded student participation and reductions in administrative work, many community eligibility schools have reported increased revenues, resulting in stronger school nutrition programs overall.  When participation increases, food service management companies can take advantage of economies of scale.  The resulting savings, together with savings from reduced administrative burdens, can be reinvested to improve nutrition quality and provide staff training.

How the Community Eligibility Provision Works

Which schools are eligible?  Any school with 40 percent or more “Identified Students” can adopt community eligibility.  Identified Students are a subset of students who qualify for free or reduced-price school meals.  Identified Students include children who are directly certified (through data matching) for free meals because they live in households that participate in the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or Food Distribution Program on Indian Reservations (FDPIR), as well as children who are certified for free school meals without submitting a school meal application because of their status as being in foster care, enrolled in Head Start, homeless, runaway, or migrant students.

Does the whole school district have to participate?  Typically, schools with 75 percent or more free and reduced-price certified students will meet the 40 percent Identified Student requirement.  School districts with 40 percent or more Identified Students may participate district-wide or may group schools together to reach the 40 percent Identified Student threshold.  Grouping schools together can allow districts to increase the number of schools adopting community eligibility and maximize federal reimbursement.

How are meals reimbursed?  Reimbursements are calculated by multiplying the percentage of Identified Students by 1.6 to determine the percent of meals that will be reimbursed at the free rate. For example, a school with 50 percent Identified Students would be reimbursed for 80 percent (50 percent * 1.6 = 80 percent) of the breakfasts and lunches served at the free reimbursement rate and the remaining 20 percent at the paid rate.  No more than 100 percent of meals can be reimbursed at the free rate.  Once a school or group of schools adopts community eligibility, it can continue operating under community eligibility for four years.  If the Identified Student Percentage increases during that time, the share of meals reimbursed at the free rate increases for the next year.  Even if the Identified Student Percentage decreases, the share of meals reimbursed at the free rate does not fall below the share in the first year of the cycle.

   Identified
Student
Percentage
Meals Reimbursed
at Free Rate
Meals Reimbursed
at Paid Rate
40% 64% 36%
45% 72% 28%
50% 80% 20%
55% 88% 12%
60% 96% 4%
62.5% and above 100% 0

 

How does community eligibility compare to Provision 2?  The Community Eligibility Provision is akin to Provision 2, a longstanding federal option, in that students are served meals at no charge, but the reimbursement structure differs and community eligibility schools do not have to collect applications.  Districts can estimate their federal reimbursement under Provision 2 and community eligibility to decide which is a better fit for individual schools.  Some districts operate some schools under Provision 2 and others under community eligibility.

Key Steps to Adopting the Community Eligibility Provision

Determine Identified Student Percentages.  Districts must determine the number of Identified Students at each school and divide that by total enrollment at the school as of April 1 of each school year.  Each district reports the resulting Identified Student Percentage for each school to the state child nutrition agency.  Once the district knows the Identified Student Percentage for each of its schools, it can fully assess whether and how to adopt community eligibility.

Estimate the financial impact of community eligibility.  Use USDA’s calculator that allows districts to estimate their federal reimbursements under community eligibility.

Identify eligible schools.  By May 1, the state child nutrition agency will publish a list of schools that are eligible and near-eligible for community eligibility, as well as a list of districts that are eligible or near-eligible district-wide.  Comparing these lists to the database of schools that have already adopted community eligibility can help identify districts that might benefit from community eligibility.  

Opt to offer community eligibility.  Districts must notify the state child nutrition agency of their intent to adopt community eligibility for the 2015-2016 school year by August 31, 2015.  When providing Identified Student Percentages for reimbursement purposes, districts may use Identified Student Percentages for April 1 that are more complete than those published by the state child nutrition agency, if they are available.

Spread the word.  Once the district has decided to offer community eligibility, it is important to inform the school community and local media.  Successful strategies include sending letters to parents, using social media, and hosting a back to school media event in a community eligibility school.  Use these model materials to reach your school community.

Additional Resources

Food Research and Action Center Community Eligibility Resources
Center on Budget and Policy Priorities Community Eligibility Database
U.S. Department of Agriculture, Food and Nutrition Service Community Eligibility Policies and Tools

End Notes

End notes:

[1] Center on Budget and Policy Priorities, Take Up of Community Eligibility This School Year: More Than 6 Million Children Have Better Access to School Meals, February 25, 2015, http://www.cbpp.org/cms/index.cfm?fa=view&id=5273.

[2] FRAC and Center on Budget and Policy Priorities, Community Eligibility: Making High-Poverty Schools Hunger Free, October 1, 2013, http://frac.org/pdf/community_eligibility_report_2013.pdf.

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