Here are the top 4 questions we received from states regarding the Community Eligibility Provision:
1. Can any school, regardless of its Identified Student Percentage (ISP), be included in a group or does the site need to have a percentage above 40%?
Any school within an LEA may be included, regardless of the school's Identified Student Percentage. "The 40% threshold may be determined school-by-school, by a group of schools within the LEA, or in the aggregate for an entire LEA", writes the USDA*. As a result, there will be some schools below the 40% threshold as long as the group of schools meets the threshold.
Response: Yes, any school can be included in a group as long as the group as a whole meets the 40% threshold. It is important to note that if a school drops out mid-year and the LEA no longer meets the required 40% Identified Student Percentage threshold, the LEA is not eligible to participate on an LEA-wide basis. That said, the LEA can have individual schools or groups of schools within the LEA participate, the USDA explains. Because this would then be considered a "new group", it means that a new Identified Student Percentage would be calculated.
2. Does the Identified Student Percentage data have to be April 1st or can it be a time prior to April 1st if it is in the same school year?
Because of the variations in monthly updates in state and local systems, states may update their data before or after April 1, but the USDA explains that the Identified Student Percentage and student enrollment data must be representative of April 1st. The USDA adds that "Since regulations regarding direct certification at 245.6(b)(3)(ii) require direct certification matches with SNAP to be run three times each year the timing of one of these matches can easily be planned to represent April 1st".*
Response: Data can be entered in prior to or after April 1st, but must be representative of April 1st identified students and student enrollment.
3. If a site participates in only lunch or only breakfast currently, can they apply for CEP?
All sites must serve both free lunch and free breakfast to be considered eligible.
Response: No. USDA says that the Community Eligibility Provision applies to: "Any School participating in the National School Lunch Program (NSLP) and the School Breakfast Program (SBP) and meeting the eligibility criteria to elect the CEP may participate".*
4. Should a site round the number of its Identified Student Percentage?
The USDA states that "When determining the percentage of identified students you should not round. The percentage must be at least 40% to be eligible. A percentage of 39.98% does not meet the threshold".*
Response: A site cannot round its ISP number. The ISP percentage must be at least 40%. Remember that any site that has an ISP of 30-39% is only "potentially eligible".