Community Eligibility Provision (CEP)

The Community Eligibility Provision (CEP) is a special school meal funding option of the National School Lunch Act that enables schools to provide free meals to all students. Just like textbooks and desks, under CEP, school meals are available to all students at no cost to them.

CEP promotes equity by eliminating the out-of-pocket costs for families and by reducing stigma for school meals programs. A study published in the Journal of Hunger & Environmental Nutrition also finds significant benefits for students attending CEP schools, including higher attendance rates and more students advancing beyond 10th grade. 

To be eligible to operate CEP, a school or group of schools within a district must have an Identified Student Percentage (ISP) of 40% or higher. To calculate ISP, a school must count all of the students who are categorically eligible for free school meals and divide by total student enrollment. Students are considered categorically eligible 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.)

*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.

The following strategies, taken from this resource, can help schools maximize the benefits of CEP by improving meal participation rates, increasing the Identified Student Percentage (ISP), and generating revenue with savvy business practices.

Increase participation in school meals. 

Increasing participation in school meals is the key to generating more revenue for your program and making CEP financially viable at any ISP. LEAs 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 and Grab and Go, 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.
• 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.
• Require students to eat in the cafeteria. Many schools require students to eat on campus and in the cafeteria, as opposed to providing the option for dining at offsite restaurants. This requirement incentivizes participation in the school meals programs and typically makes for safer school campuses.

Increase your ISP

Increasing your ISP can be one of the most effective ways to boost revenue in your school nutrition budget. Below are several options to help you raise your ISP by capturing every eligible student in your district:

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[1], 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).

Apply extended categorical 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 LEA’s homeless liaison or social worker responsible for supporting homeless, migrant, runaway, and foster care students. 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.

Manage program costs

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.

Explore additional avenues for revenue generation

Get creative and provide meals outside of breakfast and lunch. Below are several successful options LEAs 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 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 fully operate, each day of the school year.

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

• Spread the word - community eligibility is a relatively new program and many key decision makers may be unaware of the program and its benefits. 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 quickly become advocates for it; it’s an effective way to increase breakfast participation. Check out this guide targeted at advocates to promote community eligibility and learn how to get involved as a CEP advocate.

To learn more about CEP and to compare it with two other options for providing universal free school meals, Provision 2 and non-pricing, check out this resource: Providing Universal Free School Meals.