In the 2021-22 school year, one in three schools participated in the Community Eligibility Provision, or CEP, which allows high-poverty schools and districts to serve free breakfast and lunch to all students without families filing applications, according to the Food & Research Action Center.
To be eligible for CEP, an entire school or district must have an "Identified Student Percentage" of 40% or above. That percentage is calculated by dividing the number of students eligible for free school meals by the total student enrollment.
Now, however, as districts and schools increasingly look toward providing universal free school meals, the data used to measure student poverty through free and reduced-price applications is at risk of disappearing.
Free and reduced-price meal data is used primarily, of course, to determine eligibility for school meals. But it's also used to track student outcomes for research and in some cases to help disburse state funding to schools and districts, said Crystal FitzSimons, director of school and out-of-school time programs at the Food & Research Action Center.
“As you move away from schools tracking it, the free and reduced-price measure becomes less useful,” FitzSimons said. “If a third of the schools are not collecting and certifying kids for free and reduced-price meals, then it’s different.”
In fact, more than half of schools nationwide are eligible for CEP, FitzSimons said. The Food & Research Action Center has been tracking the number of schools participating in CEP since 2014-15.
More schools are participating in the Community Eligibility Provision
Because there’s no CEP proxy for statewide universal school meal models, states like California that have adopted free meals for all are still collecting free and reduced-price meal data from non-CEP districts so the state can get federal reimbursement for those meals, FitzSimons said.
In addition to California, other states that adopted universal school meal policies include Maine, Nevada, Massachusetts and Vermont. In Colorado, the plan is on the November ballot as a statewide referendum.
So what other alternative poverty indicators are out there? Researchers have shared there’s not quite an ideal model yet, but possibilities include using direct certification, state income tax systems, or the U.S. Census to gauge family income.
At Evergreen School District in Montana, the K-8 district has participated in CEP for both its elementary and middle schools for nine years, said Superintendent Laurie Barron.
Though the 662-student district no longer collects free and reduced-price meal applications, it's still able to track the number of students who would qualify, through estimates provided by the Montana Office of Public Instruction, Barron said. Those estimates are then based on federal assistance programs students participate in, said Joan Jepsen, the district’s food services director.
Barron said she doesn’t believe CEP eligibility will hinder a district’s efforts to secure grant funding or provide services.
“Not having the specific applications or eligibility or number has not had a negative impact on us,” Barron said. “Even if we didn’t have a really good estimate, I don’t think it would have a negative impact because by nature of being eligible for CEP — that’s an indicator of economic need in your community.”
Overall, transitioning to CEP has been a positive experience for the Evergreen Schools community, she said. There’s less worry about “chasing paperwork” and collecting meal debt, too, Barron said.
In Oregon, the Tigard-Tualatin School District had participated in CEP before the COVID-19 pandemic in two of its Title I schools, said Superintendent Sue Rieke-Smith.
However, the 11,700-student district has since lost its CEP eligibility for those two schools because leaders couldn't get enough families to fill out the free and reduced-price meal applications again to meet the 40% threshold, she said.
Immigrant families not authorized to live in the country feared they might be “outed” if they filled out the paperwork, Rieke-Smith said. The fear grew out of Trump administration immigration policies that have since been reversed under President Joe Biden, she said.
“Unfortunately those issues stick within a community and it takes time to reeducate and help people understand ‘that no longer impacts you in a negative way, please fill these forms out,’” Rieke-Smith said.
But now, over 2,000 students have large unpaid meal balances, and a majority of those same students ask for second meals, Rieke-Smith said. Other students, meanwhile, have said they would prefer to go hungry so their parents aren’t mad that they have school meal debt.
“That’s the bigger concern,” Rieke-Smith said. “For me as a superintendent, also as a mother and a grandmother, it is an anathema to me that children would have to even say that — that they would have to basically lay their lives bare so that they can get fed. That’s ridiculous.”
And that’s ultimately why Rieke-Smith said the CEP threshold should be brought down to 25% or below, so more children can be fed.
Should that happen, though, there will need to be more alternative poverty indicators, she said. If a form is collected to gauge student poverty, policymakers should examine what that would look like, perhaps including insecurity measures related to food, housing, medical or transportation, Rieke-Smith said.