Special Edition

This is an official communication between ODE CNP and Sponsors of NSLP

Inside This Issue

Community Eligibility Provision Overview

Community Eligibility Provision (CEP) is a non-pricing meal service option for schools and school districts in low-income areas. CEP allows schools and districts to serve breakfast and lunch at no cost to all enrolled students without collecting household applications. Instead, schools that adopt CEP are reimbursed using a formula supported by the percentage of students eligible for free meals based on their participation in other specific means-tested programs, such as the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) rather than household applications. To be eligible for CEP at least 40% of the enrolled students must participate in a means-tested program. For a full CEP program description refer to the USDA Community Eligibility Provision Manual.

How Oregon Supports CEP Participation

The Student Success Act has allocated additional state funding to certain CEP schools. These state funds are in addition to the federal reimbursement CEP schools receive making it possible for more schools to participate at a funding level that is more sustainable for the school.

The Community Eligibility Provision Incentive (CEPI) will be available in the school year 2022-2023. CEPI will supplement the federal free reimbursement up to 90% for those sites, groups, or sponsors that qualify for CEP, but receive less than 90% free claiming. By offering this supplemental, state-funded meal reimbursement, the legislature and the Oregon Department of Education (ODE) are encouraging more CEP eligible schools to participate in the provision. CEPI will benefit schools and ensure more students receive breakfasts and lunches at no charge.

How CEP Benefits Your Nutrition Program

Schools implementing CEP have experienced great success, allowing them to make numerous improvements to their nutrition program. CEP has benefited schools, communities, and children in many ways.

Schools:

• Eases administrative burden: By leveraging existing data from other federal programs, CEP schools can operate more efficiently. This results in less paperwork and lower administrative costs. Schools experience administrative relief from:
  • Processing household applications for free/reduced price meals;
  • Needing to conduct verification at the beginning of the school year;
  • Needing to submit the Paid Lunch Equity analysis; and
  • Counting and claiming processes that rely on student eligibility.
• Eliminates unpaid meal balances: Unpaid meal balances can be a significant financial burden. By providing meals at no cost, this burden is alleviated.
• Facilitates implementation of innovative breakfast service models: Since schools don’t have to collect school meal 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 boost breakfast participation further.

Students:

• Increases student participation: CEP eliminates the need for families to submit paperwork which increases meal access for students who may not submit a household application. Providing all students meals at no cost also incentivizes participation, which may increase program revenue.
• Improves the learning environment: Providing children with well-balanced breakfast and lunch ensures students come to class well-nourished and ready to learn.
• Eliminates the stigma associated with being on free/reduced meals.
• Financially benefits families: This can be a significant financial benefit for families. Especially families that fall just short of qualifying for meal benefits.

Is CEP Right for Our School?

When evaluating the benefits of CEP, there are other factors to consider before applying:

• How will we gather household income information for compensatory revenue and Title 1 funding?
• Do we have the proper staffing to support increased breakfast and lunch participation?
• Are there other effects to increased breakfast and lunch participation?
• Will we need to modify bus schedules to provide time for breakfast?
• Do we need to add cafeteria space and meal service times?
• Do we need to consider alternate serving locations?
• Does CEP make financial sense? Can we cover any additional costs?

For additional decision making support and CEP benefits, refer to the Community Eligibility Provision Decision Tree and the Benefits of Community Eligibility Interactive Graphic.

Future CEP Plans for Your School

In the February 16, 2022 SNP Newsletter, ODE CNP provided you a link to a survey where you could share with us your upcoming plans for CEP implementation. If you have not already completed the survey, it is important you do so. Survey results will be used to answer your questions, problem solve barriers, and help you plan for the future. ODE CNP wants to support you wherever you are in the decision making process. Whether that is beginning newly on CEP, updating your Identified Student Percentage, supporting you to begin a new four-year cycle or helping you make the decision that CEP is not right for your school.

Although sponsors have until June 30 to respond, if you have solid plans to continue, revise, or withdraw from CEP, please take a moment, if you have not already, and complete the survey.

Important Dates for CEP

• April 1: Active enrolled student list for all sites from Student Information System
• April 8: Cutoff date for methods of certifying students as identified for CEP (July 1, 2021 - April 8, 2022)
• April 15: State Agency must provide current year district-wide eligibility and procedures to sponsors (post on website)
• May 1: State Agency must post list of eligible and near eligible schools on public website
• June 30: Sponsors must submit completed CEP Election spreadsheet and primary source documents to State Agency

Determining Eligibility for CEP

To be eligible for CEP, an entire sponsor, group of schools, or school must:

• Ensure that at least 40 percent of enrolled students are identified students;
• Participate in both the NSLP and SBP; and
• Serve lunches and breakfasts to all enrolled students at no charge.

Sponsors may elect the provision for all schools (i.e., district-wide), a group of schools, or an individual school. This may include any public, private, and charter schools, but not Residential Child Care Institutions (RCCIs). RCCIs are not eligible to participate in CEP.

The electing entity, as a whole, must meet the eligibility criteria listed above. The ability to elect CEP for all schools or a group of schools allows some individual schools that are below the 40 percent identified student threshold to participate in CEP as long as the aggregate percentage of the group of schools electing together meets the 40 percent threshold. CEP is elected in 4-year cycles. Participating schools can end CEP participation at any time, or can begin a new 4-year cycle early after the original election, if the Identified Student Percentage (ISP) increases.

Enrolled Students

Enrolled students are students who are enrolled in and attending schools and have access to at least one meal service (SBP or NSLP) daily. The number of enrolled students includes all students with access to the SBP or NSLP, and not just those students participating in the programs. For schools participating in CEP, the ISP multiplied by 1.6 equals the percentage of meals claimed at the free rate. The remaining meals served, up to 100 percent, are reimbursed at the paid rate. The ideal ISP is 62.5 - this will earn that site a 100% free claiming rate. However, Oregon’s CEP Incentive (CEPI) Reimbursement Program will benefit sponsors who have an ISP of less than 56.25%. CEPI will provide additional state-funded reimbursement to reach 90 % of the federal free rate. See section, How Oregon Supports CEP Participation.

Identified Students

CEP is available to sponsors and schools with 40 percent or more “identified students” as of the most recent April 1 enrollment. The term identified students refers to children who are directly certified for free school meals based on their participation (or a household member’s participation) in other means-tested assistance programs, such as:

• The Supplemental Nutrition Assistance Program (SNAP);
• Temporary Assistance for Needy Families (TANF); or
• The Food Distribution Program on Indian Reservations (FDPIR).

Identified students are also children who are categorically eligible for free school meals without an application, and who are not subject to verification, including:

• Homeless children as defined under section 725(2) of the McKinney-Vento Homeless Assistance Act [42 U.S.C. 11434a(2)];
• Runaway and homeless youth served by programs established under the Runaway and Homeless Youth Act (42 U.S.C. 5701);
• Migrant children as defined under section 1309 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6399);
• Foster children certified through means other than a household application;
• Children enrolled in a Federally-funded Head Start Program or comparable State-funded Head Start or pre-kindergarten program; and
• Administrative Application students: approved by local education officials, such as a principal, based on available information.

Students who are categorically eligible based on information, such as a case number, submitted through an application may be included in the identified student count if LEA staff can verify the case number with the appropriate agency and convert the student to “directly certified” in the LEA’s certification system.

What does CEP do to my other programs? What other impact is there beyond meals? 

In addition to CEP impacting the school meals program, there are a number of other federal programs that are impacted either directly or indirectly by free and reduced lunch data. 

• Title I Funding: Total funding is not impacted, and distribution guidance is offered in the US DOE CEP Guidance.
• E-Rate: Based on individual site ISP X multiplier (currently 1.6). Additional guidance is offered in the USDA Updated E-Rate Guidance for Schools Electing CEP.
• School Profiles: CEP sites are reported as greater than 95% Free/Reduced Price Lunch, comparisons to similar schools.
• Educational Reporting: Free/Reduced eligibility %  reported from the last year applications were collected.
• Teacher Loan Forgiveness:  Use Free/Reduced eligibility %  for the last year applications were collected.
• Family requests for Free/Reduced Letters (for Community Programs [reduced fees for cable, internet, after school care, etc.]): Provide student specific information if the family has other students in non-CEP schools and eligibility has been established. May also use the Household Income Survey, on the ODE CEP webpage in 2 languages, which collects the same information and can use the same guidelines.
• Other food and nutrition service programs - Sites may qualify based on individual site ISP X multiplier (currently 1.6) for:
  • Child and Adult Care Food Program
  • Summer Food Service Program
  • Seamless Summer Option
  • Special Milk Program
  • Fresh Fruit and Vegetable Program
  • Afterschool Snacks - CEP claiming percentages do not apply to claiming for afterschool snacks.

Q & A and Other Considerations

The source for these questions and answers is the Community Eligibility Provision Planning & Implementation Guidance, Released in September 2016. We have selected a few items to include in this newsletter. The entire guidance is posted on the ODE Special Provision webpage.

Q: My school just barely meets the required 40 ISP. How long will the additional Community Eligibility Provision Incentive be available?

A: ODE CNP cannot determine an exact timeline. What we know right now is there is money available for the 2022-23 school year. As the funds get depleted, there may be adjustments to the funding level provided to schools. If at any point CEP becomes financially a burden for your schools, you may return to traditional counting and claiming.

Q: What are the definitions of “school” and "enrolled student" for CEP? Does the Head Start in my Elementary School count? What about Preschool Promise? Those students eat here, but they aren't registered in my school.

A: CEP follows parts (a) and (b) of the NSLP definition of “school” at 7 CFR 210.2. By law, “residential child care institutions” are not eligible to elect CEP [42 U.S.C.1759a(a)(1)(F)(ii)(cc)]. School means: (a) An educational unit of high school grade or under, recognized as part of the educational system in the State and operating under public or nonprofit private ownership in a single building or complex of buildings; or (b) any public or nonprofit private classes of preprimary grade when they are conducted in the aforementioned schools. (From SP 45-2015, CEP: Guidance and Updated Q & As, Page 4)

Only students who are enrolled in the sponsor's approved sites in CNPweb can be included in the ISP. Sponsors that provide food service to outside schools (e.g., private schools, charter schools) through a vended meal agreement, or similar situation, may not include students from those schools in the district’s ISP, unless the schools are listed as serving sites for that Sponsor in CNPweb.   

Preprimary students may be documented using alternate primary source documentation (district liaison list, Head Start class roster, etc.)

Q: Are new schools able to elect CEP?

A: Newly opened schools, and/or schools new to NSLP/SBP, will not have direct certification data from April 1 of the prior year, and instead may use direct certification data from a later month to establish CEP eligibility. If the number of identified students and total enrollment are available before the counting and claiming of meals begins and the new school meets the eligibility requirements (either individually or as part of a group), then the LEA may elect CEP. New schools can elect CEP only if the number of identified students and enrollment are available because the ISP is the basis for claims for reimbursement.

Oregon's School Nutrition Program recognizes new boundaries are essentially creating new schools, and recognize the same standard. Contact your assigned Child Nutrition Specialist to set a target date for the active enrollment list and CEP election spreadsheet due date.

Q: What about changes to the school/schools during the CEP cycle?

A: Each situation would need to be evaluated specifically, but in general, it would either have no impact on the CEP cycle or it would require a new CEP cycle for the impacted school or schools, depending on the CEP setup.  Some changes have no impact on a single CEP site, while others will impact a CEP group but not a district-wide CEP. The CEP guidance manual and your assigned specialist will help guide you. Here are the answers to more common situations:

• For sponsors participating district-wide, the ISP must be recalculated if the attendance area changes
• When a school or schools are added to or removed from a CEP group, the ISP must be recalculated
• ISP recalculations are not required mid-year for any changes in student population

Q: I added a Head Start program this September. They'll help my CEP percentage. How can I add them?

A: If the Head Start students have access to the School Breakfast Program or National School Lunch Program, you'll need to establish a new CEP cycle. The Head Start students will be included in both the total enrollment list for April 1 and count of students in means tested categories on the CEP election spreadsheet to create the Identified Student Percentage.  

CEP Data Collection Instructions  As in the previous year SY 2021-22, ODE CNP is going forward with a more streamlined approach to data collection to reduce the burden on NSLP/SBP sponsors. Student enrollment data and lists of categorically eligible students (McKinney-Vento, homeless, migrant, Head Start) from their respective district liaisons will be submitted to ODE. The ODE SNP team will perform the matching and calculations to determine CEP eligibility. The most important part of the CEP process is making sure you provide accurate counts of identified students which ODE will use to calculate your ISPs. ODE SNP has developed these CEP Data Collection Instructions to walk you through the entire process step by step. Primary Supporting Documents When electing Community Eligibility Provision (CEP), it is important to note the difference between Primary documentation and Secondary documentation. Primary documentation must be provided as the backup documentation to CEP election applications. Secondary documentation may be accepted in certain instances when Primary documentation is not available, but will often require further investigation and validation. This Primary vs. Secondary Documentation comparison sheet will help you know the difference. It is also available on the ODE Special Provision webpage.  Direct Certification on Demand Upload In our continuing effort to accurately identify all students who should be directly certified to receive meals at no cost, ODE CNP is pleased to announce that we are adding new functionality to the Direct Certification application. Our goal is to provide sponsors with the most up-to-date matches through an uploaded enrollment file which will generate a Match/No Match result file, thereby giving the sponsor Direct Certification results based on the most current data available. Direct Cert On Demand Upload File Format Tips: Upload files will have 19 columns (left to right) Column header names must be exact (TIP: Use the ODE template) All columns must be present and in the correct order Required fields must be populated with correctly formatted data Leave blank fields blank (no “NULL” or “N/A”) Do not include any commas in the data in any field Phone numbers must only have the digits, no parentheses, dashes, or spaces Zip Code must contain exactly the correct number of digits (5 – zip) This system may take a few tries to get the formatting just right, but once it is formatted and functioning correctly it is the single simplest method of finding students eligible for free meals - whether for CEP or for the standard eligibility process. Refer to the Direct Certification Upload Overview and File Formatting Instructions and the DC Upload Template for help. Extended Benefits Remember that for each student that is qualified as "identified" through SNAP, TANF or FDPIR programs, those meal benefits also apply to all other active enrolled students in the household. This is called "extended benefits" and ODE School Nutrition Programs has developed an Extending Benefits training video to show you exactly how to find those extra students. In this video, you can disregard references to the “Electing CEP Training” as it is no longer applicable.

To Group or Not to Group What are the rules for grouping? A Sponsor may participate in CEP for all schools, a single school, or elect CEP in only a certain group of schools, depending on eligibility and financial considerations. Grouping (or multiple schools participating as a single CEP group) is a flexible characteristic of CEP that may be used to maximize federal reimbursements, qualify schools that are below an ISP of 40 percent and create administrative efficiencies. Grouping represents a strategic decision for some sponsors. Sponsors have discretion in how to group schools to optimize CEP benefits and administrative ease. Grouping could allow some schools with an ISP below 40 percent to participate as long as the group ISP is at least 40 percent. The ISP for a group of schools is calculated by taking the sum of the identified students for the entire group of schools divided by the sum of the total student enrollment for the entire group of schools. This is different than the simple average of the ISPs for each school. Establish ALL site ISPs before deciding to group. The example below shows how grouping calculations can be completed. Example: LEA Groups Three Schools

To calculate the ISP for this group of schools: 

What happens with changes in grouped schools?

When a school or schools (and the attending students) are added to or removed from a CEP group, the ISP must be recalculated. The distinction in this requirement is intentional, because grouping is a flexible strategy that LEAs may choose to use. As such, the USDA has a strong interest in making sure that grouped schools are electing CEP using data that accurately reflects overall poverty and enrollment. Requiring a recalculation when a school is added or removed from a CEP group, or a grade level is added or removed from a school in a CEP group, helps to:

• Safeguard the grouping mechanism;
• Preserve the integrity of the grouping strategy; and
• Ensure grouping will continue to be an option for districts in the future.

However, if students are moved or reorganized among schools within a CEP group (e.g., a grade moves from one CEP school to another and both schools are in the same CEP group), an ISP recalculation is not required because the group’s total identified student and total enrollment numbers are the same. This logic applies to all CEP group changes, including school closings, schools merging, and one school splitting into two schools.

Financial Projections

Once you have determined each site in your district's ISP, you'll want to spend some time projecting how to maximize the financial impact of CEP for your School Nutrition Program - which will help you maximize the benefit to your students! This CEP vs Traditional Claiming Revenue Calculator  will help you to weigh those options. Be aware, this tool will not account for CEPI funding. The reports for yearly breakfast and lunch counts posted in the Eligibility Tools section of the ODE Special Provision webpage provide Oregon sponsors with site specific data to use in their projections.

Records Retention

CEP Recordkeeping Requirements

CEP participating schools and districts must retain the source documents (see Primary Supporting Documents section above) used to establish their ISP for an extended period of time. The standard record retention period is three years plus the current year.  With a 4 year Provision cycle, the CEP Primary Supporting Documents are what "prove" the free and paid CEP claiming percentages. That means you may need to access them for SNP review or state audit for up to 7 years. The best practice is to keep a copy of everything you send in for your final, approved CEP election spreadsheet. That includes any additional documents supplied throughout the process. That may include: 

• The election spreadsheet
• All primary source documentation saved to your CEP election folder. This includes: The clean enrollment list downloaded from the student database
• The On Demand Upload list (“Working Enrollment List”)
• The highlighted and saved non-match list downloaded from the ODE match system
• Any homeless, migrant, or other agency information used to certify students 

What is a Grace Year?

A Sponsor or school in the fourth year of CEP who evaluate their April 1 ISP to be less than 40 percent but at least 30 percent    may continue participating in CEP for one grace year (i.e., a fifth year). This gives Sponsors the opportunity to restore their eligibility status without immediately resuming standard counting and claiming procedures, and avoid disrupting universal meal service to students. Reimbursement for schools in a grace year is based on the ISP as of April 1 in year 4 of the current 4-year cycle. For example, the claiming percentages for participating schools in a grace year would be calculated as follows:

• Year 4 ISP as of April 1, 2018: 35.00%
• ISP × 1.6 multiplier (35.00% × 1.6): 56%
• Free claiming percentage: 56.00%
• Paid claiming percentage: 44.00%

If the LEA or school regains the 40 percent threshold as of April 1 of the grace year, the State agency may approve a new 4-year cycle to start the following school year. If the ISP as of April 1 of the grace year does not meet the 40 percent ISP requirement, the sponsor must return to standard counting and claiming, or enroll in the Provision 2 option for the following school year.

Ending CEP

A Sponsor may choose to end CEP participation and restore a school, group of schools, or all schools to standard meal procedures at any time if standard procedures better suit their program needs. Here is what you need to do:

• Prior to the change, notify the State agency of the intention to end CEP and seek State Agency guidance regarding a return to standard counting and claiming.
  • When standard counting and claiming procedures are resumed between school years, at the start of the next school year, the school would distribute and process school meal applications per usual certification procedures. Oregon's School Nutrition Department permits all children transitioning from provision to non-provision schools to receive free meals for up to 30 operating days at the beginning of the school year or until a new eligibility determination is made, whichever comes first.
  • When a CEP school resumes standard counting and claiming mid-year, a reasonable timeline (at least 30 days) is required to give the school time to notify families and distribute, process, and certify school meal applications. During the established time frame to resume standard procedures, students should continue to receive meals at no-cost to ensure their meal service routine is not disrupted. Meals served during this transition are claimed at the same free/paid claiming percentages used under CEP.
• Ensure your district charge policy is publicized and distributed to all staff involved in enforcing and communicating the policy, as well as to students and families before the policy is enforced.

School Nutrition Program Contacts

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