Determining Eligibility for the Community Eligibility Option

Michigan Department of Education Grants Coordination and School Support

Community Eligibility Option (CEO) provides schools with an alternative way for counting and claiming student meals in high poverty School Food Authorities (SFAs). SFAs electing to participate in CEO agree to serve all students free lunches AND breakfasts. This guidance provides step by step instructions to assist schools in determining if they would benefit from participating in CEO. Schools, groups of schools within the same SFA, or entire districts must have a direct certification rate of 40% or more to participate. Following are steps to help calculate these percentages. In addition, information will be provided to assist in determining if CEO is the correct decision for your district.

Step 1: Determine Identified Students

Identified Students are defined as students who are determined free eligible based on:

a. Electronic Direct Certification,

b. Extension of benefits – these are students who live in the same household as a student who was directly certified based on receipt of SNAP/TANF by a member of the household,

c. Categorically eligible based on the homeless, migrant, runaway, or Head Start listing (provided by your school’s homeless or migrant liaison(s) or Head Start Coordinator), or

d. Foster children

Eligibility is determined based on a school, group of schools, or an entire district’s percentage of Identified Students. This data can be gathered either from the LEARS - Verification Summary Report on line 4-1 or based on your school’s records as of April 1.

The Excel document posted online – CEO Michigan Calculator - can help you with the manual process described below. Use the first tab of the Excel workbook to enter the pertinent data for determining the percentage of identified students by building. Below is an example of this sheet. If column H is greater than or equal to 40%, the school is eligible, on its own, for Community Eligibility Option.

of 7 Revised 8/12/2011 Note – For all pages of the CEO Michigan Calculator, do not enter data into shaded cells of any color. These cells contain formulas to automatically calculate information for you. Use the white cells only.

Step 2: Determining Participation in CEO – Individual Site, Groups, and Entire District

The descriptions of how to calculate the Percentage of Identified Students are described below. However, if you complete the above spreadsheet, these calculations will be made for you. The descriptions below also describe the three different ways a district may participate in the CEO – (1) individual sites, (2) groups of schools, and (3) the entire district.

Districts can participate in CEO in one of three methods:

1) Individual sites – the individual site must have an Identified Student percentage of 40% or greater. The percentage of Identified Students will be used later to determine claiming percentages.

Equation:

Total number of Identified Students from the LEARS - Verification Summary report or as of April 1 Divided by # of students with access to the NSLP

X 100 = Identified Students %

Example: 229 Identified Students / 415 students with access to NSLP = 0.5518 X 100 =

55.18% of the students are Identified Students

of 7 Revised 8/12/2011 2) Group of sites – sites can be grouped together. If grouping sites together, the percentage of Identified Students is required to be based on aggregate data. If utilizing this method, the district may want to test out different combinations of sites in order to determine which combination will provide them with the highest Identified Student percentage(s). A district may have some individual sites and some groups. This percentage will be used later to determine claiming percentages for all schools in the group.

Equation:

Total number of Identified Students for schools A, B and C from the Verification Summary report or as of April 1 Divided by Total number of students with access to NSLP for schools A, B and C

X 100 = Identified Student % for the group (A, B and C)

Example: School A has 114 Identified Students and 249 students with access to NSLP School B has 303 Identified Students and 522 students with access to NSLP School C has 288 Identified Students and 407 students with access to NSLP

114 + 303 + 288 = 705 Identified Students for schools A, B and C 249 + 522 + 407 = 1178 students with access to NSLP

705 / 1178 = 0.5984 X 100 = 59.84% of the students are Identified Students

3) District – all school sites in the district can be grouped together. The grouping of the entire district together will need to be based on aggregate data, not averages. See below for the equation to determine the district’s Identified Student percentage. This percentage will be used later to determine claiming percentages for the entire district.

Equation:

Total number of Identified Students for all schools from the Verification Summary report or as of April 1 Divided by Total number of students with access to NSLP for all schools

X 100 = Identified Students % for the district

of 7 Revised 8/12/2011 Example: There are 5 schools in the school district. School A has 114 Identified Students and 249 students with access to NSLP School B has 303 Identified Students and 522 students with access to NSLP School C has 288 Identified Students and 407 students with access to NSLP School D has 53 Identified Students and 98 students with access to the NSLP School E has 163 Identified Students and 239 students with access to the NSLP

114 + 303 +288 + 53 + 163 = 921 Identified Students for schools A, B and C 249 + 522 + 407 + 98 + 239= 1515 students with access to NSLP

921 / 1515 = 0.6079 X 100 = 60.79% of the students are Identified Students

TIP: How do I maximize my number of Identified Students (for SY2011-2012 implementation only)?

1) Pull any household applications that have SNAP (FIP/FAP) or TANF case numbers written on the applications.

2) Access the April 2011 Direct Certification Report in the Michigan Student Data System (if you have not already done so) and update your eligibility list(s) to include all directly certified students who attend your school. These students can be added to your Identified Students for that school site; document this by printing the April 2011 Direct Certification Report. Any students identified on direct certification reports who were already certified for meals based on a household application should be switched to being directly certified. Maintain the household application and a copy of the Direct Certification Report(s) for your records.

3) Ensure that the school has extended benefits to all household members of any students directly certified. For all students who are located on the Direct Certification Report, any other students living in that child’s household are eligible for the extension of benefits, which would certify them for free meals and include them in your Identified Students number. Keep a record on file of those students who were extended eligibility.

Step 2: Determine Free and Paid Claim Percentages

Once you have determined if you have individual schools that qualify for CEO, you can begin determining reimbursement rate percentages (free and paid) and the financial impact of changing to CEO. Start by entering actual data from a school(s) for a month (use a “typical” month) or full school year into the CEO Michigan

of 7 Revised 8/12/2011 Calculator worksheet “Data” tab. In order to complete this form, you will need the following information:

1) Total free, reduced and paid participation (breakfast and lunch) for each school you are considering participating in CEO.

2) Total number of Identified Students by building (column F of above worksheet). This will prepopulate from the first worksheet.

3) Enrollment (column F of above worksheet - total number of students with access to NSLP). This will also prepopulate from the first worksheet.

4) Meal prices, and, by building, if the building qualifies for Severe Need Breakfast.

Note - If you print out your SM-4012 claim form, you will have most of this information (not including Identified Student numbers).

You can use the “Data” page in a variety of ways. You can enter a single school and see the claiming percentages. You can enter a group of buildings to see what the claiming percentages are for each building and the average claiming percentage for the group (which is the one that would be used if claiming by group). Lastly, you can enter entire district data, either school by school, or by using the district totals from the SM-4012. The average percentages (free and paid) calculated for the district are the average percentages you will use for all schools. Please note – by either using the group or entire district methods, you can include schools with an Identified Student percentage of less than 40% as long as the group or district average exceeds the 40% threshold.

Using the percentage of Identified Students, the next step is to determine the percentage of meals that could be claimed at the free rate and at the paid rate. The equation for calculating these percentages is:

Percentage of Identified Students X 1.6 = percentage of meals that are claimed at the free rate

100% – Percentage of meals claimed at the free rate = percentage of meals claimed at the paid rate

Example:

Percentage of Identified Students: 57%

57 X 1.6 =91.20 *when determining claiming % use standard rounding procedures.

91% of meals served will be claimed at the free rate 100 – 91 = 9

9% of meals served will be claimed at the paid rate

of 7 Revised 8/12/2011 Schools will need to maintain daily meal counts. At the end of the month, these daily totals will be combined. The percentages of free and paid meals will then be applied to the total number of meals served. These numbers will be entered into the School Meals Program - SM-4012-SL electronic claim for reimbursement. The percentages you determine at the beginning of the school year will remain in effect for the entire school year.

Step 3: Determining Feasibility of CEO – Calculation of Gain/(Loss) in Revenues

The next step in this process is to figure out if CEO will financially benefit the school, group of schools, or district. As you enter data, by school, by group or by entire district, you can click on the “Calculations” tab. There is only one section of this page you need to fill in – the 2010-2011 reimbursement rates for lunch found on the top right of the sheet. If you click on the respective cells, a drop down arrow will appear. Click on the drop down arrow and enter the correct reimbursement rate for your district. After this is completed, the Calculations page will show you a variety of information, including how much you would have received under the current system of reimbursement and under the CEO system. In addition, it takes into account the revenue that you will not receive from paid students. The total financial impact is summarized in the bottom right box.

***Remember that you can use this worksheet by individual school, group of schools or by district. If using for a group of schools or district, be sure that you are entering claim data, enrollment and Identified Students for all schools in the group or district.

However, keep in mind that the financial implications of utilizing CEO are not just based on the reimbursement and total revenues the school(s) receive. Some other factors to keep in mind are:

1) An increase in meal participation may very well increase revenue under the CEO. This increased participation may offset any losses in revenues (if there are any).

2) Fewer work hours dedicated to processing household eligibility applications may help to save money for the school food service program.

3) Fewer work hours dedicated to the verification process. (Verification is required with CEO only at schools NOT participating. For example, if you are participating district-wide, no verification will be required.)

4) Meal counts only consist of the total number of meals served as opposed to tracking meals by free/reduced/paid categories. This can greatly increase the efficiency of the program with potential labor savings.

of 7 Revised 8/12/2011 Step 4: Commit to Participate in CEO

If a determination is made that it is feasible for a school, group of schools or the district to participate in CEO, the district must commit to CEO with the MDE. The CEO Participation documents are available at: www.michigan.gov/schoolnutrition.

For districts that choose to participate, the following documents are due to MDE by the later of the first day of school (for year around schools) or no later than September 15, 2011, for all schools.

Required documents to submit to MDE:

1) CEO Agreement – signed by the District Superintendent (public schools) or Administrator (non-public schools), and

2) CEO Participation Listing - breakdown of how the schools will participate – by school, group of schools or district. The listing form is available on our website in Excel.

After MDE receives the required documents, they will be reviewed by staff. Upon successful review and approval of your application, a copy of the signed agreement along with the claiming percentages will be sent back to the school district for its records.

Please submit the required documents to MDE (scan in the CEO agreement and attach the Excel CEO Participation Listing file via email to MDE- [email protected].

of 7 Revised 8/12/2011