Lindsay Blough – Illinois Howard Leikert – Michigan Brigette Hires - Ohio

Lindsay Blough, M.S. - Illinois Illinois State Board of Education Nutrition & Wellness Programs. Website: www.isbe.net/nutrition

Howard Leikert, MBA, SNS - Michigan

Michigan Department of Education School Nutrition Programs Supervisor www.michigan.gov/schoolnutrition leikerth@michigan.gov

Brigette Hires, PhD, RD, LD - Ohio

Ohio Department of Education Office for Child Nutrition

Assistant Director www.education.ohio.gov

Learning Objectives

General information about CEP CEP’s Impact on other programs State Agency & LEA requirements State partner sharing points Q&A

Audience Poll Raise your hand if you are from a

state that is already implementing CEP.

Audience Poll Raise your hand if you are from a

State Agency.

Audience Poll Raise your hand if you are from a

school.

General Information about CEP

Howard Leikert - Michigan

Overview of CEP Section 104(a) of the Healthy, Hunger Free

Kids Act of 2010 amended the Richard B. Russell National School Lunch Act to provide an alternative to household eligibility applications for free and reduced price meals in high poverty Local Educational Agencies (LEAs) (or districts) and schools.

CEP is a 4-year reimbursement option for eligible high poverty LEAs and schools.

An LEA may participate in CEP for one school, a group of schools or all schools in the LEA.

What Does CEP Do? For eligible schools, it allows a school to serve all

of their students free breakfasts AND lunches without having to identify a student’s “status”

Free and reduced applications are NOT filled out Helps to eliminate the stigma for free and

reduced students Simplifies paperwork, POS counts, counting and

claiming Helps to make sure ALL students are able to

receive a nutritious meal in order to best prepare them for the school day.

CEP Phase In

2011-2012: CEO was made available in 3 states, Illinois, Michigan and Kentucky)

2012-2013: 4 more states were added - Washington D.C., New York, Ohio and West Virginia

2013-2014: 4 additional states Maryland, Massachusetts, Florida and Georgia

2014-2015: CEP is available nationwide

Program Requirements LEA and schools run direct certification matches

no later than April 1st of each year to obtain current counts of SNAP, TANF, and FDPIR participants.

Homeless, migrant youth, runaway and foster children lists are matched no later than April 1st of each year to include in the identified student percentage.

Each year of the 4-year cycle, LEAs or schools may use the identified student percentage from the year prior to the first year or an updated identified student percentage from the prior year, whichever is higher.

June 30 is the opt in and opt deadline for each year of participation.

Program Requirements Have a minimum level (40%) ‘Identified Students’ as of

April 1 in the year prior to implementing the option; Agree to serve free lunches AND breakfasts to all

students for up to four consecutive years (with minimum of 1);

Agree to cover with non-Federal funds any costs of providing free meals to all students above amounts provided in Federal assistance;

Not collect free and reduced price applications from households in participating schools during the period of participation in the CEP;

Count total breakfasts and lunches served to students; and

NOT be a residential child care institution (RCCI) as that term is set forth in the definition of “School” in 7 CFR 210.2.

What are Identified Students? • Identified Students are:

• Directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) and the extension of benefits to students within the same household. (Electronic Direct Certification System in Illinois and Michigan)

• 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) • Foster child (certified by means other than Household

Application – ex. DCFS)

• It does not include students who are eligible based on submission of a household eligibility application. This was the most common area of error when districts applied.

Calculating Reimbursements • Within a LEA, a school, a group of schools or the entire

district can participate in CEP if they have an identified student percentage of 40% or more

• When the school/group/district determines their identified student percentage, it is multiplied by 1.6.

• The resulting percentage is the percentage of total meals served that will be claimed and reiumbursed at the free rate, the remainder will be reimbursed at the paid rate.

• An example – XYZ district has an overall 50% identified student percentage. 50% X 1.6 = 80%. At XYZ district, they will be able to claim 80% of the meals served at the free rate and 20% of the meals at the paid rate.

• The “magic” percentage is 62.5% = 100% free reimbursement

Impact on Other Programs

Brigette Hires - Ohio

CEP Impact on Title 1 Funding Schools may be concerned about impact on Title 1

Funding CEP does not affect overall district Title 1 funding Within-district distributions is addressed in a

Federal Programs CEP guidance published in January 2014

US Department of Education and US Department of Agriculture issued a joint CEP letter February 25, 2014

Resources on the Ohio Department of Education (ODE) website:

Title 1 and U. S. Department of Agriculture Community Eligibility Provision State Guidance

CEP Impact on Title 1 Accountability January 2014 CEP guidance addresses

reporting from schools of accountability purposes CEP schools may elect to identify all

students as economically disadvantaged and thus the disadvantaged subgroup would be the same as the “all students” group

CEP schools could use updated direct certification or survey data to specifically identify students in the economically disadvantaged subgroup

CEP Impact on E-Rate Funding Federal Communications Commission funds the E-

rate program Discounts on telecommunication services FCC issued a guidance letter on July 31, 2012 CEP participating schools must submit eligibility

data from the most recent year of which they were not participating in CEP for E-rate application purposes

In effect until future guidance is published

FCC E-Rate

Impact of CEP on Other Child Nutrition Programs

Other Child Nutrition Programs are be able to utilize the percent of meal claimed free to determine their eligibility:

•Summer Food Service Program (SFSP) •Fresh Fruit and Vegetable (FFVP) •After School Snacks •Child and Adult Care Food Program – After School at

Risk Meals Program

CEP Impact on Grants and State Law

The Ohio Department of Education (ODE) reviewed state law to determine impact on funding, school resources and or required data sources. In Ohio, charter (community) schools must

report “current year” poverty data per pupil for state funding calculation purposes

Ohio revised code requires public schools to wave instructional fees for students qualifying for free meals

State Agency & LEA Requirements

Lindsay Blough - Illinois

Annual Notification Requirements

USDA Memo 32-2014 2 levels of data required State Agencies must provide districtwide

level eligibility data to LEA’s LEA’s must provide school level eligibility

info to State Agencies Data must be from the current

school year Due April 15th

Annual Notification Requirements If the State Agency has school level data

available to them, they can complete the LEA level requirement for the LEA’s.

If proxy data is used by the State Agency to gather the school level data, the notification must include a note that the data provided is a proxy and that LEA’s interested in applying must provide school level identified student and enrollment numbers as of April 1 in order to determine eligibility for CEP.

Annual Notification Requirements State Agency Requirement: Must notify LEA’s of their districtwide

eligibility & provide guidance to LEA’s on:

LEA’s with a districtwide identified student % of at least 40%

LEA’s with a districtwide identified student % >/= 30% but <40%

LEA’s currently participating districtwide

LEA’s in the 4th year of CEP with a districtwide identified student % >/= 30% but less than 40%

Districtwide = sum of the number of Identified Students for all schools in the LEA divided by the sum of the enrollments from all schools in the LEA.

Annual Notification Requirements

Requires a notification of schools in the following categories:

Schools with an identified student % of at least 40%

Schools with an identified student % >/=30% but <40%

Schools in the 4th year of CEP with an identified student % >/= 30% but less than 40%

LEA The State Agency can pull this data for the LEA

and do the notification if the State Agency has the required data.

State Partner Notifications - IL Our VSR requires site level identified student

data be entered. We use the VSR data to notify LEA’s if they

are possibly eligible districtwide and/or by school (we exempt the LEA’s from submitting data to us because we have the data from the VSR.)

Our email notifications are being sent to: LEA’s eligible districtwide LEA’s in which at least one site is possibly eligible LEA’s currently participating No LEA’s are currently in their 4th year – no notification

needed.

Annual Publication Requirements USDA Memo 32-2014 State Agencies must post the

list of LEA’s and schools to their website & must provide a link to their website to FNS at cepnotification@fns.usda.gov

Due May 1st

Annual Publication Requirements What needs to be published? LEA’s with a districtwide identified student

% of at least 40% LEA’s with a districtwide identified student

% >/= 30% but < 40% LEA’s currently participating districtwide Schools with an identified student

percentage of at least 40% Schools with an identified student

percentage >/= 30% but < 40%

State Partner Publications

Illinois:

State Agency Sharing Points

Illinois: Demographics Total SFA’s in CEP:

SY2011-2012 37 SFA’s 160 sites

SY2012-2013 57 SFA’s 476 sites

SY2013-2014 100 SFA’s 696 sites

Approximate number of SFA’s and sites in the federal School Based Child Nutrition Programs:

SFA’s = 1190 Sites = 4415

Zero schools have dropped out of CEP

IL - Claim Comparisons Aug.-Oct. 2010

Aug.-Oct. 2011

Difference Percent Change

Breakfast 915,375 1,111,520 +196,145 +21.43%

Lunch 1,774,028 1,982,075 +208,047 +11.73%

A word from our CEP Schools: Jan Miller,

Springfield School District

Has been in CEP for 3 years

31 sites in CEP

What is your favorite thing about CEP? Being able to spend more time on

production and menus instead of approving applications and collecting charges.

What are the positives to participation in CEP?

Not having to approve free/reduced lunch applications.

Students and Parents don’t have to worry about getting the free/reduced applications in or making sure their child has enough money on their account for breakfast/lunch.

Students go through the serving lines so much faster.

There is less stress for students, parents, & school staff.

A word from our CEP Schools:

Michael McKenzie, Peoria School District 150

Has been in CEP for 3 years

19 sites in CEP

Have you ran into any barriers to participation in CEP?

Our percentage of Direct Certified students brought our reimbursement to almost 99% so there was no financial barrier to participation. We have had to work hard to educate the public about the program. We have some schools that are not in the program so it is hard to explain how the rules are different at the different schools. One household may have students in different schools where some get free meals and they may have a sibling that gets reduced or paid meals at another school.

A word from our CEP Schools: What are the positives about CEP? The positives to participation are numerous,

beginning with ALL students being able to receive a breakfast and lunch at no charge. This is a huge help to all parents in our district. With paper work not having to be submitted and processed, has saved time for building secretaries and unit office staff. Not having to notify families of lunch balances and tracking this is a huge time saver. Students are being served quicker without having to stop and count change. End of the year balances for lunch charges are a thing of the past!

What are the negatives about CEP? Negatives, from my end are none. I'm sure

there are some, but how can they outweigh the fact that every student has the opportunity to have a breakfast and lunch?

Georia Marshall, Murphysboro CUSD 186

Has been in CEP for 3 years

4 sites in CEP

Resources & Contact Info Evaluation

Worksheets – compares traditional claiming to CEP claiming

Recorded Webinars

Sample Alternative Household form

Lindsay Blough lblough@isbe.net http://www.isbe.ne

t/nutrition/htmls/nslp-hhfka-ceo.htm

Michigan and the CEP SY 2011

Started informing districts of the potential during application process

Reached out to key districts that would give us significant Direct Cert enrollment numbers

Researched the potential financial impact of CEP for districts

Originally, NOT selected to be one of the first 3 pilot states Contacted in late July, final approval second week of

August Used Excel spreadsheets for application and approval

form Compared to State direct certification #’s Compared to monthly claim free/reduced numbers

Michigan and the CEP SY 2012

Informed districts of potential eligibility through complete site listing

Developed on-line application that pre-populated the Direct Cert counts with final editable fields for districts to complete

The on-line system improved the efficiency of approval

Requested last year participants to fill out application for data purposes

CEP had a positive image in the field

The Numbers SFAs 2011 84 SFAs 2012 120 SFAs 2013 156 Schools 2011 435 Schools 2012 539 Schools 2013 562 Enrollment 2011 192,295 Enrollment 2012 230,672 Enrollment 2013 248,977 Bottom Line – In the two school years under CEO, a

quarter million students in Michigan could receive a free breakfast and a free lunch every day without application and without any stigma.

From the Soapbox Even with a very difficult first year start up, CEP has

been successful from the start It has been a program embraced by both Food

Service Directors and district administration Yes, it poses some challenges in relation to socio

economic data, these challenges can be overcome

As great a program as it has been, I do not believe it is for all qualifying schools

Critical for schools to understand financial impact Be happy, it is a program that is great for your

students!!

Contact Information

Howard Leikert, MBA, SNS Michigan Department of Education Supervisor, School Nutrition Programs leikerth@michigan.gov www.michigan.gov/schoolnutrition 517-373-3892

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Profile of School Year (SY) 2013/ Year One of CEP in Ohio

78 LEAs participated in SY 2013 including: 21 public school districts 56 community schools 1 parochial school

303 building sites Larger school districts participating: Cleveland City Schools - Dayton Springfield - Akron Youngstown -Warren

Profile of School Year 2014/ Year Two CEP Schools in Ohio

Only 1 SFA representing 1 school

dropped participation Adopting CEP in 2014: 52 additional SFAs representing 100

schools Total: 129 SFAs and 402 sites

Ohio CEP Deployment: CEP Workgroup

ODE convened a work group of internal stakeholders including: Office for Child Nutrition Office for Federal Programs Office of School Finance Office of Community Schools Office for Assessment Office for Accountability ODE Legal Council Office of Fiscal Services – Grants Management Office for Policy and Research

Addressing CEP Barriers and Obstacles in Ohio

• Workgroup mission to identify and overcome potential barriers of CEP program participation both at the ODE and SFA level Workgroup publications: CEP webpage within the ODE website Ohio Household Income Form CEP Overview of Title 1 CEP Guidance – Accountability

CEP Deployment: Communication ODE conducts multiple webinars and

developed a CEP participant listserv. Webinar topics offered: Introductory webinar for all potential CEP

schools Commencing the CEP for SFAs that

adopted CEP The Verification Process and CEP Navigating the CEP Audit Process

CEP Deployment: CEP Audits In the initial year of participation, ODE audits

identified student records for CEP SFAs Recurrent issues included: Including foster children as an identified student

based on a paper application with no court documentation backup

Extending the direct certification benefits to additional household members without documentation

Counting withdrawn students in the enrollment and identified student count

Reporting free and reduced counts as the identified student count

Please go to one of the microphones to ask your question.

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Click the “Evaluate Your Sessions” link.

THANK YOU!

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