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2 The School Meals Programs
Pages 16-48

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From page 16...
... , as well as the limitations of the current administrative process. It is essential to understand all elements of the school meals programs before considering alternative procedures that could reduce administrative burden and make it possible to provide nutritious meals to a greater number of the nation's schoolchildren.
From page 17...
... Certification errors CO: Approved Students -- Observed Participation MO: Meals Served -- Observed Under Traditional Approach Participation Response to Universal Free Meals MU: Meals Served -- Universal Free Meals (Unobserved) FIGURE 2-1 School meals process and distributions of enrolled students and FIG2-1.eps meals served across free, reduced-price, and full-price categories: Traditional approach and universal free meals.
From page 18...
... The first oval (and third item) in the figure, labeled "CO: Approved Students -- Observed," represents the distribution of enrolled students into categories of approved for free meals, approved for reduced-price meals, and eligible for full-price meals, in which the categories of approved for free or reduced-price meals are as determined by the actual operation of the certification process and maintained in school records.
From page 19...
... The third box (and fifth item) in the figure, "MU: Meals Served-Universal Free Meals (Unobserved)
From page 20...
... a runaway child who is receiving assistance from a program under the Runaway and Homeless Youth Act and is identified by the local educational liaison. With the passage of the Healthy, Hunger-Free Kids Act of 2010, foster children also are categorically eligible for free meals.
From page 21...
... Families of such students can establish their categorical eligibility by providing a SNAP, TANF, or FDPIR case number on their application for school meals.8 The application process begins just prior to and at the start of a school year (normally mid-July through early September) , when school districts send a letter to the parents of their students describing the school meals programs, inviting them to apply, and providing an application form.9 The application requests information about participation in SNAP or other assistance programs, family composition, and family income.
From page 22...
... 2010 42.5 8.4 49.1 2009 40.1 8.6 51.3 2008 37.9 8.6 53.5 2007 37.1 8.3 54.6 2006 37.8 8.4 53.8 2005 37.1 8.1 54.8 NOTE: Approval status for the school meals programs includes both the National School Lunch Program (NSLP) and the School Breakfast Program (SBP)
From page 23...
... As noted in a study by the National Research Council of the National Academy of Sciences, "results like this contributed to the Improper Payments Act of 2002, which requires that various federal agencies identify and reduce erroneous payments in their programs" (National Research C ouncil, 2009:14) .10 Subsequent research found that at least some of the difference between income eligibility estimated from the CPS and approval status under the school meals programs could be due to how income relative to poverty is measured (annual or monthly)
From page 24...
... More detailed results from the APEC study are discussed later in this chapter. Verification In addition to special studies, such as the APEC study, the accuracy of the certification process is examined through a requirement for school districts to verify a sample of NSLP applications annually.
From page 25...
... National Data Bank provided to the panel, July 5, 2011. Participation Any student attending a school that participates in the school meals programs may obtain a meal for free or at the reduced price, if so approved, or by paying the full price for the meal.
From page 26...
... National Data Bank provided to the panel, July 5, 2011. of enrolled students approved in that category shows consistently higher participation by students approved for free meals (81.9 percent in 20092010)
From page 27...
... ." This distribution reflects what would happen in the future if a district adopted free meals for all students through a new approach that used available data, such as those from the ACS, to establish claiming percentages13 for reimbursement from 13Claiming percentages are used in determining a school district's reimbursement for the school meals programs. In the traditional approach in the contiguous states in the 2011-2012 school year, a school district with less than 60 percent of students eligible for free or reduced
From page 28...
... The claiming percentages are the percentage of total meals (separate for lunch and breakfast) that are served to students eligible for free meals, the percentage served to students eligible for reduced-price meals, and the percentage served to students who must pay full price.
From page 29...
... SPECIAL PROVISIONS AND OPTIONS FOR OPERATING THE SCHOOL MEALS PROGRAMS As discussed in Chapter 1, schools, groups of schools, or entire school districts may choose to apply for one of four special provisions or options instead of following the traditional procedures for eligibility determination and meal counting. Typically, they apply for these provisions through the state.
From page 30...
... Provision 2 permits schools, groups of schools, and entire school districts to establish claiming percentages for federal reimbursement in accordance with information collected during a base period and to serve all meals at no charge for a 4-year period. The first year is the base year, during which the school provides all meals for free but collects applications, makes eligibility determinations, conducts verifications, and takes meal counts by type.16 During the next 3 years, the school performs no new eligibility determinations or verification checks and counts only the total number of reimbursable meals served each day.17 Reimbursement during these years is determined by multiplying the total count of reimbursable meals for a claiming month by the percentages of free, reduced-price, and full-price meals served during the corresponding month of the base year to estimate the number of meals served in each category.
From page 31...
... Reimbursement: BRR based on adjusted fraction identified for free meals, zero for reduced price, and for full price -- 1 minus the adjusted fraction for free times meals served in current month. Direct certification to be per formed at least every 4 years.
From page 32...
... The estimated percentage of full-price meals is 100 percent minus the estimated percentage of free meals.19 The reimbursement is the total number of meals served times the sum of the product of the percentage of free meals and the free meal reimbursement rate and the product of the percentage of full-price meals and the full-price meal reimbursement rate divided by 100. Schools or school districts are required to conduct direct certification every 4 years to reestablish eligibility and the percentage of identified students.
From page 33...
... The steps in the process for estimating claiming percentages include direct certification, followed by a survey of nondirectly certified students. The direct certification and household survey data showed that 79.6 percent of students attending schools with universal free meals were eligible for free or reduced-price meals in school year 2006-2007.
From page 34...
... During the first year of the AEO, the participating schools in a district would provide free meals to all students but collect applications, make eligibility determinations, conduct verifications, and count meals by category. The base year data used to determine reimbursement would include the impact on participation of providing free meals.
From page 35...
... Further, "when annually determining the eligibility of a CEO school to receive Title I funds and its Title I allocation, an LEA must assume that the percentage of economically disadvantaged students in the school is proportionate to the percentage of meals for which the CEO school is reimbursed for free meals by the USDA for the same school year." Provision 2 and 3 schools are to use the percentage of students certified as eligible for free or reduced-price meals during the base year for this purpose. For schools operating under the traditional approach, the percentages are derived annually from the school meals certification and verification process.
From page 36...
... Under the traditional procedures for operating the school meals programs (and under Provision 1) , federal financial assistance to school districts is calculated as the total number of reimbursable meals served to students approved for free, reduced-price, or full-price meals multiplied 25See http://frac.org/newsite/wp-content/uploads/2009/05/provision2.pdf.
From page 37...
... for reimbursable meals under the NSLP or SBP are Gt = R f Mtf + R r Mtr + R p Mtp Mtf r Mt r p Mt p = R f + R + R Mt M t Mt Mt = BRRt T Mt where · Gt is the federal government's outlay for reimbursable meals in month t, in dollars; · Rf is the reimbursement rate for free meals for this school year, in dollars (e.g., $2.77 for the NSLP in 2011-2012, if the school is not eligible for an increment) ; · Rr is the reimbursement rate for reduced-price meals for this school year, in dollars; · Rp is the reimbursement rate for full-price meals for this school year, in dollars; · Mtf is the total number of free meals served in month t; · Mtr is the total number of reduced-price meals served in month t; · Mtp is the total number of full-price meals served in month t; · Mt = Mtf + Mtr + Mtp is the total number of reimbursable meals served in month t; and · BRRtT is the blended reimbursement rate for the traditional approach (denoted by "T")
From page 38...
... The ratios in the first version of the equation above are the Provision 2 claiming rates, based on the percentage of meals served in each category in the base year. Like the BRR for the traditional approach, the BRR for Provision 2 varies from month to month.
From page 39...
... , as an estimate of the meals served in the current month. Under the Community Eligibility Option, reimbursement is based on the total number of meals served, the ratio of the number of identified students26 to the number of enrolled students in the base year (or a year since the base year)
From page 40...
... The reimbursement formula is Ef rE r pE p Gt survey = R f + R + R Mt E E E = BRR survey Mt where · Gtsurvey is the federal government's outlay established for the schools providing free meals to all students; · Mt is the total number of reimbursable meals served in month t; · Rf, Rr, and Rp are reimbursement rates as defined above;
From page 41...
... ; · Rf, Rr, and Rp are reimbursement rates as defined above; · Mt is the total number of reimbursable meals served in month t; · Ef/E is the estimated fraction of enrolled students who are eligible for free meals based on the ACS and other sources; · Er/E is the estimated fraction of enrolled students who are eligi ble for reduced-price meals based on the ACS and other sources; · Ep/E = 1 ­ Ef/E ­ Er/E is the estimated fraction of enrolled stu dents who are eligible for full-price meals based on the ACS and other sources; and · BRRAEO(1) is the BRR under the assumption that claiming percent ages are based on student eligibility fractions estimated using the ACS and other information.
From page 42...
... is the federal government's outlay for reimbursable meals served in month t in AEO schools in dollars, with the (2) indicat ing that this is the second version of the AEO considered by the panel, and it is based on estimated claiming percentages that account for both eligibility and participation; · Rf, Rr, and Rp are reimbursement rates as defined above; · Mt is the total number of reimbursable meals served in month t; · Cf is the claiming rate for free meals, an estimate of the fraction of reimbursable meals served to students eligible for free meals; 28FNS gave a hypothetical example of a school with 70 percent of students eligible for free meals, 10 percent eligible for reduced-price meals, and 20 percent eligible for full-price meals.
From page 43...
... .31 In this process, parents of students who are not directly certified need to apply in order for their children to receive the benefits of free or reduced-price meals. If a family that is eligible for these benefits does not apply and is not identified by direct certification, the students have been denied access to free or reduced-price meals to which they are entitled.32 30As shown in Chapter 5, meals served claiming percentages can be expressed in terms of the product of eligibility percentages and participation rates.
From page 44...
... A school must retain daily records of the number of meals served for each eligibility status by linking a reimbursable meal served to a student and then linking that student to his or her certified eligibility status. The school's daily records are compiled and submitted to the school district, and the school district submits them to the state.
From page 45...
... Roughly one-third of students approved for reduced-price meals should have been approved for free meals, and 25 percent should have had their applications denied. To quantify the potential effect of certification errors on the distribution of students by eligibility status when the traditional method is used, the APEC study compared the distribution of students based on the categories for which they had been approved with the distribution based on their true eligibility status, using the sample of students who had undergone the certification process and either had been certified for free or reduced-price meals or had their applications denied.36 The distribution based on approval status was 78 percent free, 17 percent reduced price, and 5 percent full price (U.S.
From page 46...
... ; and 4. the summation of counts of meals served over cashiers and days, transmission of the school's meal counts by category to the school district, the state, and the federal government for reimbursement (aggregation error)
From page 47...
... In subsequent base years, there is likely to be more error because after 4 years of not taking applications, parents and school district staff have become less familiar with the application and verification procedures and less skilled in carrying them out. In light of the ongoing provision of free meals, some parents may not understand why applications need to be submitted, and may not submit applications at all or take the time to complete them accurately.
From page 48...
... While the CEO may not keep up to date with changes in the economic status of the community, the school district has the option of conducting direct certification in any year and using the new results if they would lead to an increase in reimbursement.


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