Community Eligibility Provision

Each year, a school district has until June 30 to declare their intent to implement CEP for the upcoming school year. To declare intent to implement CEP in a school or group of schools, a district's school nutrition director must notify their state agency by June 30. Check with your state agency on the process in your state.

Promoting CEP Adoption In Your State

To ensure widespread and effective adoption of CEP in your state, you can:

• Spread the word. Many schools are not aware of CEP and its benefits, especially those newly eligible due to COVID-19. Send a letter to the editor, use social media or encourage your governor or state agency officials to publicize CEP.
• Identify eligible schools. States are required to post lists of eligible schools and districts on their websites. Use this searchable database to find eligible schools in your state.
• Encourage eligible schools to participate. Work with relevant decision makers, such as administrators, school board members, school food service staff and others.

Schools that implement CEP often become advocates for it. CEP is an effective way to increase participation, reduce stigma, and support students’ health, education, and wellbeing. Check out this guide for advocates to promote CEP and learn how to effectively advocate for the program.

School administrators want the best for their students and communities. They want to make sure that students are succeeding and also that school budgets are healthy and balanced to support generations to come.

School nutrition professionals often are tasked with making the case for CEP adoption in their district. 

No Kid Hungry has resources to help:

• CEP Talking Points for School Administrators
• CEP Financial Considerations for School Business Officials
• Template Letter to School Administrators About Adopting CEP
• What School Nutrition Staff Need To Know About Title I Funding

Increasing participation in school meals is the key 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 may use to boost participation even more. Schools have found success employing the following strategies:

• 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 successful at creating 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 BAB resources webpage.
• Promote your program. Offering free breakfast and lunch to all students is big news – share it! Advertise breakfast on banners, posters, and scrolling marquees around the school. Include information about the program on your school nutrition website, district website, and in student manuals. Promote CEP throughout your community by engaging local press to write news articles, talk on radio shows, and feature CEP on local TV news stations. Send letters from the superintendent or principal to families explaining the new program and its benefits to parents. Check out No Kid Hugnry’s CEP Communications Toolkit for downloadable graphics, letters, FAQs, and more!
• Engage students. Regular student engagement can improve menus, create buzz around school breakfast, and boost breakfast participation rates. Consider doing surveys, taste tests, posting on social media, and connecting students to local farmers. Remember, students are the customers of school meals, and building student buy-in through engagement will only help your program. School Breakfast Promotion Strategies highlight ways that you can build awareness, generate excitement and ultimately increase school breakfast participation.
• Incorporate scratch cooking. Students report a preference for hot, freshly prepared meals over pre-packaged meals. Where possible, doing more scratch cooking can enhance participation. If meals can be cooked onsite, students are drawn to the cafeteria by the aroma of freshly cooked food and participate more often. 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 lunchtime or in your hallways if you are operating a Grab and Go breakfast.
• Tally reimbursable meals served to speed up lunch lines. Rather than swipe student IDs or punch in student numbers, some schools favor tallying - on paper or with a clicker - each reimbursable meal served. Because you only need to claim the total meals served under CEP, tallying may be a faster solution for schools concerned about how increased participation may slow down lunch lines.

Check out Strategies For Finding Success With CEP to learn about these strategies and more to make CEP a success in your district. You can also check out the webinar recording You’ve Gone CEP, Now What? Tips and Tricks to Maximize CEP to learn promising practices for CEP implementation.

Maximizing your Identified Student Percentage (ISP) can be one of the most effective ways to boost revenue in your school nutrition budget. 

Quantify Your ISP Goals

The No Kid Hungry Community Eligibility Provision (CEP) Identified Student Percentage (ISP) Outreach Calculator is a tool that calculates school-level and group-level ISPs and compares these actual ISP values to target ISP values. Districts can use this information to project the increase in ISP needed to meet specific targets. (This tool is a downloadable excel file) 

This information can also be used to increase outreach for participation in public benefit programs, such as SNAP and Medicaid, which can increase ISP. Through CEP's grouping methodology, the increase in ISP necessary for achieving group-level targets may be lower than the increase in ISP necessary for achieving school-level targets.

Capture Every Eligible Student in Your District

There are several options to help you raise your ISP by capturing every eligible student in your district. Learn more with ISP Management: Increasing & Maximizing Your District’s ISP.

Find out what student data your state includes in their direct certification system. Students are categorically eligible for free school meals and should be included in your ISP calculation 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), Medicaid, or if they live in a household where another student is enrolled in one of these programs (this is referred to as ‘extended eligibility’ or a ‘sibling match’ as outlined below).
• Homeless, migrant, runaway, in foster care, or enrolled in Head Start or Early Head Start. (Note that these categories do not confer eligibility to other students in the household.)

States are required to conduct direct certification of children enrolled in SNAP. However, state direct certification systems may not include all of the aforementioned datasets. Work with your state agency to find out what data is included and then identify sources for any missing data (e.g. departments of health for Medicaid data).

Early childhood programs and alternative agreement schools may contribute to their associated school’s ISP and therefore help boost the total ISP increasing the possibility of CEP eligibility and financial feasibility. Use this resource to learn how to determine if these special programs can count to your school's ISP.

Apply extended household eligibility. Students living in households with students who have already been directly certified can be automatically added to the ISP. This is referred to as extended categorical eligibility.

• Quick Tip: Locate the addresses of directly certified students on your student rosters, and then certify any additional students living at those same addresses.

Utilize connections with social workers and homeless liaisons. Team up with your district's homeless liaison responsible for supporting students who are experiencing homelessness, identified as migrant, and/or in foster care. They will have the most current information regarding these categorically eligible students. Check-in weekly or monthly to ensure that you capture students who may be categorically eligible and include them in your ISP.

Examine all possible direct certification matches. 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 to decide whether they are, in fact, matches. 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 direct certification system can be improved in the future.

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

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, for example, 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 help with this process, but first make sure that you are complying with all confidentiality guidelines by talking to your state agency. LEAs report finding great benefit by directly certifying students at least monthly. This may be tedious, but LEAs often find the increased reimbursement to be worth it.

• Quick Tip: You can work with your state agency to start a new 4-year CEP cycle if you can demonstrate an increase in ISP, which will establish a higher reimbursement rate.

*The following states use Medicaid data to determine categorical eligibility for free school meals: Illinois, Kentucky, New York, and Pennsylvania. The following states use Medicaid data to determine categorical eligibility for both free and reduced-price school meals: California, Connecticut, Florida, Indiana, Iowa, Massachusetts, Michigan, Nebraska, Nevada, Texas, Utah, Virginia, Washington, West Virginia, and Wisconsin

Conduct SNAP outreach. The more eligible families that participate in SNAP, the higher your ISP, the easier it is to make CEP financially viable. Our SNAP outreach 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!

What do I do if I can't implement CEP in all of my schools?

Sometimes, not all the schools in a district are eligible for CEP or CEP is not financially viable district-wide. In these cases, districts can still benefit from implementing CEP in some of their schools. This is often called site-based or partial CEP. Learn more with Tips for Making Site-based/Partial CEP Work.

Use the following best practices to leverage existing resources and explore creative ways to manage program costs:

• Calculate a ‘per plate’ cost and compare it to food and labor costs. To calculate ‘per plate’ costs, use the USDA’s Federal Reimbursement Calculator. Compare the ‘per plate’ cost to food and labor costs and make adjustments as needed.
• Monitor food waste. Adjust purchasing and preparation accordingly to manage costs. Additionally, explore ‘offer-versus-serve’ (OVS). At lunchtime, in particular, schools that implement OVS often find that they can better manage costs, i.e. when students are not required to take all meal components they end up throwing less away. As a bonus, operating an OVS model allows you to assess which foods students like most so that you can include them on the menu more often.
• Join a buying co-op. School nutrition departments can achieve better 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. LEAs should make full use of USDA Foods as a means to offset costs incurred through the traditional bidding process.
• Adhere to conservative hiring practices. Avoid immediately hiring new staff to support CEP. Wait a few weeks after implementing CEP to determine staff needs. Because CEP requires less paperwork, school nutrition staff can use that extra time to support increased meal participation. However, temporary cafeteria staff may be necessary to support the initial implementation of CEP.
• Employ students to work in the school nutrition program. Employing students can save costs, increase student engagement, and provide student leadership opportunities.

Increasing revenue can make CEP a financial success if districts with lower ISPs. Here are several successful options schools have used across the US:

• Provide afterschool meals. Operate the National School Lunch Program Afterschool Snack Program or the Child and Adult Care Food Program (CACFP) At-Risk Afterschool Meals Program to feed students an additional snack or meal after the end of the school day and to bring in additional revenue. For afterschool meals support, check out No Kid Hungry’s wealth of resources.
• Provide summer meals. Operate the Summer Food Service Program (SFSP) or the National School Lunch Program Seamless Summer Option (SSO) to make sure that students have access to healthy meals while school is out and to bring in additional revenue. For summer meals support, check out No Kid Hungry’s wealth of resources.
• Consider a la carte sales. A la carte sales may generate revenue, but they also could take away from students participating in reimbursable meals. Know your school’s context, and decide whether a la carte sales would help your program finances.
• Consider catering. Schools can generate additional revenue by catering school functions, such as school board meetings, as well as programs and events in the community.
• Disallow outside vendors/caterers in school. Do not allow outside vendors/caterers to sell food at school during the official school day. This removes the competition from vendors/caterers and can boost sales by the school nutrition department.
• Prepare student meals for field trips. Serving meals on field trips can ensure that students have access to meals and that school nutrition departments can receive reimbursement for those meals.

Check out Managing Costs in School Nutrition Programs to learn more strategies to reduce costs in your budget and increase revenue.

Raising awareness about the availability of free school meals for all students is critical to success. Marketing and outreach strategies should be tailored to the important stakeholders in your school community:

• Students
• Parents and families
• Teachers and school staff
• School nutrition department

No Kid Hungry's CEP Communications Toolkit provides school nutrition departments with strategies and tips to effectively communicate about CEP and the availability of free school meals for all students. The toolkit also has downloadable and customizable social media graphics, banners, posters and more for you to use to spread the word about free school meals for all students in your district.

If your state requires alternative income forms, check out No Kid Hungry's Alternative Income Forms: What They Are, Why They’re Important, and How They’re Collected.

Title I funds are distributed to school districts based on census data and the cost of education in each state; Title I funds are not distributed to districts based on free and reduced-price (FRP) meal data. Accordingly, adopting CEP does not impact the amount of Title I funds a district receives.

Adopting CEP could impact how Title I funds are allocated within a district. This is because districts often use an approach called "rank and serve," where individual schools are "ranked" by the level of need in that school (often estimated using FRP data) and then "served" Title I funds accordingly. However, there are a number of ways to distribute Title I funds that allow districts to adopt CEP fully or partially with little or no impact on how Title I funds are distributed. To learn more about these alternative distribution methods, check out What School Nutrition Staff Need to Know About Title I Funding. 

In districts fully adopting CEP (i.e. in every school), schools may be ranked by their ISPs, by their ISPs*1.6, or by student participation in another federal program like Medicaid.

In districts partially adopting CEP (i.e. in some but not all schools), districts can use ISP for all schools, ISP*1.6 for all schools, or a combination of FRP percentage in non-CEP schools and ISP*1.6 in CEP schools. (The 1.6 multiplier, when applied to the ISP, is a standard proxy for a school's FRP percentage.)

By working with school nutrition, district administration, and financial officers, districts can find ways to adopt CEP partially or fully with little or no impact to the way funding is distributed to schools within that district. Learn more with this resource from FRAC, Understanding the Relationship Between Community Eligibility and Title I Funding.

Since 1997, the Federal Communications Commission's E-rate program has helped ensure that eligible schools and libraries have affordable access to the Internet. Schools adopting CEP can calculate their use ISP*1.6 to apply for E-Rate funding, in place of free and reduced-price (FRP) meals application data. For more information, visit New Policy Makes It Easier for Community Eligibility Schools to Participate in E-Rate Program.

States differ in their approaches for distributing state education funding. Some states may require CEP schools to administer alternative income forms to capture free and reduced-price (FRP) meals application data, some states use ISP*1.6 as a proxy for FRP data, and some states don't use either. Luckily, the Food Research and Action Center developed a chart to make it easy to find your state's approach to state education funding.

Many benefits and discounts are available for children eligible for free and reduced-priced meals. When a school elects CEP, a new process must be put in place in order for students to receive those benefits. Learn more about what programs are impacted and the processes schools can implement to ensure their students still receive discounts and benefits on the second and third page of Alternative Income Forms: Understanding What They Are, Why They're Important, & How They're Collected. 

To receive exam fee waivers, families will need to complete additional forms. Information about applying for fee waivers:

• SAT and AP exams
• ACT exams

School districts have several school meal funding options to implement free school meals for all students, including the Community Eligibility Provision (CEP), Provision 2, and locally funded universal free meals (“non-pricing”). 

Every student deserves access to healthy food every day, and offering students meals at no cost to them is a great way to make that happen.

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 Day 1 video from CEP Week to learn about the differences between and considerations for CEP, Provision 2, and traditional counting and claiming.