Community Eligibility Provision (CEP)

Title 1 funding is allocated to states via Title 1-A of the Elementary and Secondary Education Act (ESEA) to ensure fair and equitable high-quality education in communities with a large concentration low-income families.

The amount of Title I funds each state or local education agency (LEA) receives is based on the US census poverty data for school-age children and is not based on free and reduced-price school meal data.

Adopting the Community Eligibility Provision (CEP) in a school, group of schools, or entire school district does not impact the amount of Title 1 funding that a state or school district receives. 

Title 1 funding can be used to support extra instruction, materials, afterschool/summer programming, etc. In fiscal year 2023, $18.4 billion in Title 1 funding was provided via education grants, according to ESEA Title I-A Formulas: A Primer, Congress.gov.

To learn more about Title 1, check out these resources: 

• ESEA Title I-A Formulas: A Primer
• No Kid Hungry’s What School Nutrition Staff Need To Know About Title I Funding
• USDA's Title I Guidance for Schools Electing Community Eligibility

E-Rate is a universal service program from the Federal Communications Commission designed to provide eligible schools with affordable telecommunications services, e.g. broadband high-speed internet, communications equipment and software, maintenance and operations cost, etc. 

Eligible schools receive discounted services from 20% to 90% from vendors via the Universal Services Fund, based on school district poverty levels. Discounts are calculated by assessing the entire school district’s National School Lunch Program (NSLP) data, specifically the percentage of students eligible for free and reduced price meals (calculated by dividing the number of students eligible for free/reduced-price meals by the school district's total student enrollment), even if only one school in the district applies for the discount. 

CEP comes into play because it can be used as an alternative method of calculating the discount.  CEP data, specifically the school district’s Identified Student Percentage (ISP) times the 1.6 multiplier (ISP x 1.6), can be used in place of NSLP data. CEP data can be a more accurate assessment of low-income student populations in school districts because CEP uses multiple means tested data sets to determine eligibility, e.g. SNAP, TANIF, Medicaid*, etc., rather than relying on household income applications via NSLP. 

Any CEP-calculated E-Rate discount will remain valid for the four-year CEP cycle. If the ISP decreases during the 4-year cycle, the school/district may opt to keep the original ISP, and therefore the E-Rate discount, until the 4-year cycle ends. If the ISP increases, the school/district can begin a new 4-year cycle, at which time the E-Rate calculation must also be updated. 

For more information, visit USDA's E-Rate Guidance for Schools Electing Community Eligibility or the Universal Service Administrative Company's E-Rate page.

*As of June 2025, the following 44 states use Medicaid data to determine categorical eligibility for free school meals: Alabama, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Montana, Nebraska, Nevada, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.

States utilize various methods of data collection to assess poverty levels in schools, which is used to determine, among myriad other factors, appropriate and equitable funding given to school districts. School meal applications are a common example of this type of data collection. 

In some states, CEP data (ISP x 1.6) can be used as a proxy for free and reduced-price meal data. This can be a relatively easy way to submit data to states, as the data is often readily available in CEP schools. 

While CEP can be a good approximation of poverty in schools, it does not identify individual income levels of all children in the school or district. 

To learn what other data collection methods states use, visit the Food Research Action Center’s Alternative Approaches to Using School Meals Data in Community Eligibility (CEP) Schools resource. 

To learn more about the role states play in education funding, and the other ways schools are funded, check out How Is K-12 Education Funded?

Schools receive additional federal funding for things like classroom resources, field trips, technology, athletics, and college tests, based on the number of students eligible for free and reduced-price meals. When schools adopt CEP, free and reduced-price applications are no longer necessary to determine student eligibility. However, to still receive additional federal funding, schools must assess student eligibility in a different way, most often using Alternative Income Forms (also known as Education Benefit Forms, Household Information Reports, or Household Income Surveys). Alternative Income Forms are not used to certify students for free or reduced-priced meals, but rather to assess a school’s poverty level which determines federal funding allotment for other educational purposes, e.g., technology funding, college application discounts, athletic programs. Alternative Income Forms are often simpler to complete in comparison to school meal applications.

To learn more about Alternative Income Forms, check out No Kid Hungry’s Alternative Income Forms: Understanding What They Are, Why They're Important, & How They're Collected resource.

Raising the visibility of CEP amongst stakeholders can dramatically increase the success of the program. This means not only marketing CEP, but gaining critical buy-in from stakeholders, including students, district administrators, teachers and school staff. 

This No Kid Hungry CEP Communications Toolkit provides customizable social media graphics, banners, posters and more for you to spread the word about free school meals for all students in your district, with specific messaging for students, families, teachers and school nutrition departments. Additional suggestions for outreach and buy-in from stakeholders are below.

Students are the customers of the school meals program. When there is a change, it’s important to communicate the change, and how it will affect them.

Determine your messaging: What messages do you think will resonate most with the students in your school/district? Some schools choose to message CEP as a program that provides all meals “free” to all students. Other schools prefer the phrasing “no cost meals”. If only certain schools in the district operate CEP, those schools may choose to message CEP as a special benefit to those schools, akin to schools that get special music or stem supports. No matter what messaging you choose, be consistent and include a steady drum beat of information so the message is clear and persistent. 

Blast out your message: Spread the word far and wide about CEP. Put your messaging on posters and scrolling marquees, on the school website and social media. If you have morning announcements, share out that way. During breakfast and lunch, recruit school staffers to remind students that meals are free. Utilize the resources in the CEP Communications Toolkit, including social media posts and graphics, and fliers and posters. Send fliers home with students so parents and caregivers can be aware of the change as well. 

Beyond removing the financial barrier for children to access school meals, district administrators may need more convincing as to why CEP is a useful program. Here are some talking points that may resonate:

• No more school lunch debt. Under CEP, all meals are served to students at no cost to them. That means, no more school lunch debt for families, no alternative meals to students who’ve accrued lunch debt, and no negative press!
• Equity is centered. By eliminating the out-of-pocket cost of school meals for all students, school meals become a universal benefit, just like desks and textbooks.
• School nutrition budgets will see a boost. Because CEP increases participation in school meals, schools often see a higher financial return under CEP than under traditional counting and claiming by fee category (free & reduced-price meals).
• Title I funding Is not affected. CEP does not affect the level of Title I funds the district receives; however CEP may impact how a district distributes Title I funds to schools. For more information on state education funding, visit How CEP Affects Education Funding.
• Reduces stigma around school meals. Stigma students feel around getting free and reduced-price meals is a reason students choose not to eat school meals. With CEP, students are never identified as qualifying for free or reduced-price meals, and students are never singled out for having school lunch debt.
• Increase food security. A study published in the Journal of Hunger & Environmental Nutrition shows that CEP increases food security, and can improve  attendance rates and academic performance, as these are some of the things that are negatively impacted when kids are food insecure.
• Reduces administrative burden. Under CEP, families don’t have to complete meal benefit applications, which means school nutrition staff no longer must distribute, collect, and analyze school meals applications.
• Meals in the classroom just got easier. With CEP, teachers only need to count the total number of meals served to students in their classroom. By contrast, with free & reduced-price meals, teachers need to be trained to count the correct number of students for each claiming category (free, reduced, or paid meals). 

For more support, check out 

• CEP Talking Points for School Administrators
• CEP Financial Considerations for School Business Officials
• Template Letter to School Administrators about Adopting CEP

Teachers can play an important role in encouraging students and families to participate in school meals. Teachers are often trusted messengers for families, so when teachers talk about school meals, families listen. 

In order to gain buy-in from teachers, it’s important to illuminate how CEP can support them. For instance, CEP has shown to reduce food insecurity amongst students. This is because CEP removes the financial barrier students face in participating in school meals. When food insecurity is reduced, other positive impacts are seen, including improved academic performance and overall behavior, as well as higher attendance rates. These improvements impact classrooms! Teachers can focus on teaching, rather than disciplining students and trying to catch up students who are often absent. 

Additionally, if meals are served in the classroom, such as Breakfast in the Classroom, CEP provides an easier counting and claiming system for teachers. Instead of having to keep track of and specifically tally the kids who qualify for free meals, reduced-price meals, and paid meals, teachers can simply count the total number of meals eaten, as all meals are free under CEP.

Once teachers are bought into the benefits of CEP, they can communicate to families about the free meals, and can remind students to take part in the meals program, as the meals are free of charge!

Blasting out information about CEP broadly to the community will help ensure all families in the school/district know that free meals are available. This can be done via local radio and newspapers, social media posts, community events, and the like. Signs promoting free school meals on and around the school can be helpful as well. Keep a steady drumbeat of outreach going, as that will also help spread information by word of mouth (the more people who know about CEP, the more information will spread).

Maximizing your schools’ or districts’ Identified Student Percentage (ISP) can be one of the most effective ways to boost revenue in your school nutrition budget. The first step is ensuring every eligible student in your district is accounted for in your ISP.

Capture Every Eligible Student in Your District

Students are categorically eligible for CEP, and should be included in your ISP, if they are enrolled in:

• The Supplemental Nutrition Assistance Program (SNAP),
• Temporary Assistance for Needy Families (TANF),
• The Food Distribution Program on Indian Reservations (FDPIR), and
• in some states Medicaid*.

State agencies are required to conduct direct certification of children enrolled in SNAP. Connect with your state agency to identify sources for any missing data.

Students can also be included in the ISP if they are:

• Homeless,
• Migrant,
• Runaway,
• In Foster care, or
• Are enrolled in Head Start or Early Head Start.

Consult with your school or district’s McKinney-Vento liaison, social workers, homeless liaison, or someone who manages migrant services to ensure all eligible students are being included in the ISP. Connect regularly with these staffers to capture students who may be categorically eligible for CEP.

Learn more about how to maximize ISP with ISP Management: Increasing & Maximizing Your District’s ISP.

*As of June, 2025, The following states use Medicaid data to determine categorical eligibility for free school meals: Alabama, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Montana, Nebraska, Nevada, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin, Wyoming

Other Tips to Maximize Your ISP:

Are other students being claimed for reimbursable meals, but not being included in the ISP? Examine all possibilities of categorically eligible students:

1. Examine early childhood programs and alternative agreement schools:

• Early childhood programs: students enrolled in Pre-K and Kindergarten programs may count towards the ISP, as long as the district is claiming the meals served to them, and the students are categorically eligible for CEP.
• Alternative agreement schools: When a district provides meals to a neighboring school district (e.g., charter or private schools) through an alternative school food authority agreement, those additional students may be included in the ISP if they are categorically eligible. 

To find out more, check out Calculating Identified Student Percentage Using Early Childhood Program and Alternative Agreement School Data.  

2. Utilize extended Eligibility and Sibling Match: 

If a student lives in a household where another student in the same household qualifies for CEP via categorical eligibility (SNAP, TANIF, FDPIR, MEDICAID), that student would also be eligible, and can be included in the ISP.

This may take some sleuthing, but if you locate the addresses of directly certified students on your student rosters, and then search for additional students living at those same addresses, you can include those additional students in your ISP.

3. Check for direct certification errors:

Simple errors between datasets can often prevent students from being directly certified, such as misspelled names, partial social security numbers, or incorrect birthdays. 

Many state agencies will share lists of students who were not matched in the direct certification process but who are likely to match if further investigated. Obtain those lists from your state agency and compare them with your student rosters. Add any students to your ISP that you can verify. Notify your state agency of the new directly certified students and share any patterns that caused categorically eligible students to go unmatched so that the state’s direct certification system can be improved in the future.

Keep documentation of all certified students for administrative reviews. You must be able to show how each student included in your ISP was certified.

4. Conduct direct certification as often as possible:

The more often you conduct direct certification, the more likely you are to identify students who temporarily enroll in categorically eligible benefits. Even if a student only receives SNAP benefits for one month, that student will remain directly certified all year if you keep records of their enrollment. 

Depending on the sophistication of your state’s direct certification process, some LEAs can conduct direct certification daily or weekly. If you have a large student population, you may consider hiring temporary workers to support this process. Be sure to comply with confidentiality guidelines by talking to your state agency. 

LEAs report finding great benefit by directly certifying students at least monthly. While tedious, LEAs often find the increased reimbursement to be worth it. Additionally, if you can demonstrate an increased ISP to your state agency, you can start a new 4-year CEP cycle, giving you four more years of increased reimbursement rates.

5. Conduct SNAP outreach:

Because SNAP is the main program to directly certify students for CEP, the more eligible families that participate in SNAP, the higher your ISP! No Kid Hungry’s SNAP Outreach in Schools Toolkit includes sample SNAP outreach materials in English and Spanish that can be customized with the local details and specifics that best serve your community. Check out No Kid Hungry's SNAP in Schools webpage to learn more!

Increasing participation in school meals is critical to generating more revenue for your program and making CEP financially viable at any ISP. 

CEP often increases participation on its own, by virtue of offering meals for free to all students. However, there are additional strategies you can use to boost participation, including:

• Implement Breakfast After the Bell (BAB): BAB, where breakfast is served as part of the school day using models such as Breakfast in the Classroom, Grab and Go, and Second Chance Breakfast, is effective at addressing access barriers students encounter with school breakfast. The combination of CEP and BAB has been shown to create the most opportunity for students to participate in the school breakfast program, thereby increasing revenue for the school nutrition department. For additional support, visit No Kid Hungry’s School Breakfast Page.
• Promote Your Program: Offering free breakfast and lunch to all students is big news – share it!
  • Advertise it on banners, posters, and scrolling marquees around the school.
  • Share information on your school nutrition website, district website, and in student manuals.
  • Promote CEP via local press, news articles, radio shows, and local TV news stations.
  • Notify families via letters from the superintendent/principal explaining CEP and its benefits.

Check out No Kid Hungry’s CEP Communications Toolkit for downloadable graphics, letters, FAQs, and more!

• Engage Students: Students are the customers of school meals, and building student buy-in through engagement will only help your program.
  • Conduct surveys and taste tests on menu items to solicit feedback.
  • Post on social media to connect directly with students.

For more suggestions, check out School Breakfast Promotion Strategies.

• Incorporate Full-Scratch or Semi-Scratch Cooking: Students report a preference for hot, freshly prepared meals over pre-packaged meals. For full scratch and semi-scratch recipes, visit the Alliance for a Healthier Generation’s Smart Food Planner.
• Add More Points of Service: Increased participation could result in increased congestion at points of service. To ensure that students can move quickly through lines and have enough time to eat, consider adding more points of service in your cafeteria at breakfast or lunch. This could look like adding an additional line in the cafeteria during lunch, or another grab and go breakfast station in the mornings.
• Tally reimbursable meals: Rather than requiring students to swipe their IDs or enter their unique student numbers on a keypad, some schools favor tallying reimbursable meal counts via pen and paper or with a clicker. When operating CEP, only the total number of reimbursable meals served needs to be recorded for claiming purposes, therefore simply counting meals may create speedier lines.

For additional support, check out Strategies For Finding Success With CEP and the webinar recording You’ve Gone CEP, Now What? Tips and Tricks to Maximize CEP.

Managing program costs is another step in getting the most cost-efficiency out of CEP. Here are several creative ways to manage program costs:

• Determine food, labor, and other expenses: Assess what the costs of your food, labor and other expenditures are to run the school meals program, and compare those to the federal reimbursements you would receive while operating CEP. The following tools can help:
  • USDA’s CEP monthly federal reimbursement estimator tool - an excel-based tool providing state-specific reimbursement rates and estimated montly reimbursement amounts.
  • No Kid Hungry’s CEP Calculator – This excel-based tool provides side-by-side comparison of projected district annual revenue utilizing both CEP and standard NSLP (standard counting and claiming).
• Reduce food waste: There are many strategies school nutrition staffers can use to reduce food waste, including monitoring popular foods vs foods that go uneaten, seeking student feedback about food likes and dislikes, and rotating the menu regularly to keep new options coming into the food program. Additionally, exploring ‘offer-versus-serve’ (OVS), extending meal times, offering culturally diverse meals, and using share tables, can all be effective in reducing food waste. For more information, check out Strategies to Reduce Food Waste in School Meal Programs.
• Join a buying co-op (for smaller districts): Smaller school districts can achieve better food prices on commonly purchased goods if they can tap into larger economies of scale. Joining a buying co-op with other LEAs or institutions can help cut costs.
• Leverage USDA Foods in Schools Program:  Schools that participate in National School Lunch Program (NSLP), the Summer Food Service Program (SFSP). the Child and Adult Care Food Program (CACFP), can tap into USDA Foods’ 100% American grown and processed food, including fruits, vegetables, meats, dairy, and whole grains, all at budget friendly prices.
• Re-examine your staffing needs: Wait a few weeks after implementing CEP to determine staff needs. Because CEP requires less paperwork, school nutrition staff can use the time that was previously devoted to administrative tasks to support increased meal participation. If it’s determined more staff are needed, either permanently or temporarily, one option is to hire student workers. Employing students can save costs, increase student engagement, and provide student leadership opportunities. These resources share valuable information on the benefits of hiring student workers for meal programs: Benefits of Hiring Student Workers in Summer Non-Congregate Programs and The Summer Meals Student Workforce Toolkit. 

If you are simply looking for tools and resources to support your CEP education, implementation and outreach, No Kid Hungry has created these materials that range from CEP basics to more nuanced support.

How CEP Works & Success Strategies

• The Community Eligibility Provision (CEP) - Overview - offers a quick explanation of how CEP works, how schools/districts determine CEP eligibility, and how CEP is beneficial.
• CEP Video Series - provides five videos delvering insights into various aspects of CEP, including the financials of CEP and measuring CEP success.
• Strategies for Finding Success with CEP - highlights strategies that maximize the benefits of CEP by improving meal participation rates, increasing the Identified Student Percentage (ISP), and generating revenue with savvy business practices.
• CEP Opportunity Finder - identifies school distircts that are eligible for CEP, but not participating in the program.

Identified Student Percentage (ISP) Support

• Identified Student Percentage (ISP) Management: Increasing & Maximizing Your District's ISP - explains several options to help you raise your ISP by capturing every eligible student in your district.
• Calculating Identified Student Percentage Using Early Childhood Program and Alternative Agreement School Data - illustrates how early childhood programs and alternative agreement schools may contribute to and boost an associated school’s ISP.
• No Kid Hungry's CEP Calculator - enables districts to compare finacial analysis of CEP vs school meals counting & claiming scenarios, create different school groupings to maximize ISP, and test out how different meal participation rates would affect the budget.

Outreach/Communications

• Community Eligibility Provision (CEP) Communications Toolkit - provides strategies and tips to effectively communicate about CEP, including downloadable and customizable social media graphics, banners, posters and more.
• SNAP Outreach in Schools Toolkit - Supplemental Nutrition Assistance Program (SNAP) data is used to directly certify eligible students for CEP. Therefore, SNAP can be a powerful tool in ensuring eligible students are being counted in the ISP. This toolkit offers customizable scripts, website blurbs, webpage buttons, outreach materials, social media posts and graphics regarding The Supplemental Nutrition Assistance Program (SNAP) in school settings. Resources are available in English, Spanish, Chinese (Simplified and Traditional), Tagalog, and Vietnamese.
• CEP Talking Points for School Administrators - features general talking points to help prepare for conversations with school administrators about adopting or expanding CEP.
• Template Letter to School Administrators about Adopting CEP - provides a customizable template letter/email for your superintendent about adopting CEP.
• CEP Financial Considerations for School Business Officials - offers guidance on how to talk to school business officials about implementing CEP, with a focus on finances. 

Alternative Income Forms

• Alternative Income Forms: Understanding What They Are, Why They're Important, & How They're Collected - gives details about what alternative income forms are, why they are important, and how they are collected.
• Webinar Slides: Benefits for Everyone: Best practices and considerations for school meal applications and alternative income forms - learn best practices and considerations regarding alternative income forms for usage in school meals.

If CEP is not a good fit for a school or district to offer free meals, there are other options, including Provision 2 and non-pricing models, also known as locally funded universal free meals. 

Provision 2

Provision 2 of the National School Lunch Act enables any school to provide free meals to students. There are no eligibility requirements under Provision 2 as there are with CEP, and also unlike CEP, you can choose to offer universal breakfast and/or lunch. 

How It Works

Provision 2 schools distribute and collect school meals applications in year 1, or the "base year," of the four-year cycle. In this base year, Provision 2 schools serve free meals to all students but count and claim meals by fee category. In years two-four, schools receive reimbursement based on the percentage of meals served in each fee category during the base year and meals are served at no cost to all students.

When might Provision 2 be a better option than CEP? 

When a school's free and reduced-price student percentage is significantly greater than a school's ISP, Provision 2 may yield a higher financial return than CEP. This phenomenon is more common in areas where there is stigma associated with receiving public benefits like SNAP, or fear of participating in programs like SNAP, often out of fears for negative impacts on immigration status. In these situations, a school's base year percentages for reimbursement at the free, reduced-price, and paid categories may yield a greater financial return than the reimbursement rates set by the school's comparatively lower ISP. 

For example, if a school has an ISP of 50%, it will receive 80% of the meals it serves at the free rate and 20% at the paid rate under CEP. However, if that same school's average daily participation in school lunch is 78%, 15%, and 7% for participation in free, reduced-price, and paid categories, respectively, it may be more financially viable to operate Provision 2. When considering the reimbursement generated by the 15% of participants in the reduced-price category, 93% of the meals served at this school would be reimbursed at or near the highest reimbursement rate, while only 7% will be reimbursed at the significantly lower "paid" rate. Compared with 20% of meals being reimbursed at the "paid" rate under CEP, Provision 2 may be a better option for this school.

Non-Pricing

Non-pricing is another funding option for free school meals for all students where schools have financial support from the local government, school board, or private sources. Meals are served free to all students, and meals are counted and claimed by fee category (i.e., free, reduced, and paid). The difference between federal reimbursement and program costs would have to come from non-federal funding.

For a more in-depth comparison chart, view No Kid Hungry’s resource Providing Universal Free School Meals. You can also check out the this CEP Video Series to learn about the differences between and considerations for CEP, Provision 2, and traditional counting and claiming.