(This guest blog was authored by our friends at No Kid Hungry by Share Our Strength and published with permission. Please note this content does not necessarily represent the views or policies of ASBO International and its members, nor imply any endorsement by the association and its officer or affiliates.)
COVID’s Impact on School Meal Data and Title I Funding
By Tam Lynne Kelley and Emily Pia
June 21, 2021
The recent announcement from USDA that universal free school meals will continue through School Year 2021–22 is positive news for students, families, and schools. Yet, some school districts may have concerns about what this announcement means for other school programs and funding, since free and reduced-price meals eligibility data may not be available this year.
First Things First—As many school business professionals know, the Title I education funding formula for school districts does not use free and reduced-price school meals eligibility data. Rather, census poverty data determine the amount of Title I funding that a school district receives from the federal government. Districts should not be concerned that their Title I funding will be negatively impacted by serving free meals to all students this year, and by extension, not collecting free and reduced-price school meals applications.
While the total amount of federal Title I funding will not be impacted by free and reduced-price meals data (or lack thereof), each district must determine how to distribute Title I funding to individual schools within the district. Traditionally, many districts have relied on free and reduced-price school meals eligibility data to measure poverty, and Title I funding was allocated to schools with the greatest number of students eligible for free or reduced-price school meals. However, there are other options that districts can use, including data sources that are already available (as compared to the time-intensive collecting and processing of meal applications) and that include verified income and household data (as compared to the self-reported information collected on meal applications).
While using the following alternative data sources may be new to your district, thousands of schools, including Community Eligibility Provision (CEP) schools, are already using them. Click here to learn more about how CEP can help ensure that students in your district have access to healthy school meals at no cost, not just this year, but for the next four years.
Existing federal guidance from the U.S. Department of Education allows districts to use any of the following data alone, or in combination, to allocate Title I funding to schools within the district:
Students Directly Certified for Free or Reduced-Price School Meals (“Identified Students”)
- This is the most commonly used alternative to school meal data. This data is reliable, verified, and already available to schools. Historical data are also available and can be referenced to show trends.
- Known as “Identified Students,” this data set includes those students who are directly certified for free or reduced-price meals via the “direct certification” data-matching process with other means-tested programs.
- Identified students include those in households with the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), Food Distribution Program on Indian Reservations (FDPIR), and in some states, Medicaid. In addition, students identified as experiencing homelessness, in Head Start/Early Head Start, in foster care, migrant, or runaway are also included in this count.
- Please note that all school nutrition departments already have the lists of students in households receiving SNAP, TANF, FDPIR, and in some states, Medicaid, as they are required to conduct data-matching between these programs and student rosters at least three times per year.
Students Eligible for Medicaid
- Advantages of using Medicaid data include that more students are eligible for Medicaid, as compared to the programs typically included in the identified student count. For example, Medicaid participation data include students who do not meet the more restrictive citizenship requirements for SNAP. There is also less stigma surrounding participation in Medicaid, as compared to SNAP and TANF, which contributes to a more complete count of students.
- Districts may find that the number of students enrolled in Medicaid is comparable to the number of students eligible for free or reduced-price meals via the usual school meal application process. Therefore, transitioning to using Medicaid data to allocate Title I funding may be a relatively seamless process.
- Please note that districts may use Medicaid data for their Title I allocations, even if their state is not participating in the Medicaid direct certification option. (The Medicaid direct certification federal option allows for Medicaid participation data to be included in the identified student count along with SNAP, TANF, etc.)
- While Medicaid enrollment data already exist within your state’s Department of Health or other agency that administers Medicaid in your state, it may not be accessible to the school district without an agreement in place.
School-Age Children in Households Below the Federal Poverty Level, per the U.S. Census
- As noted above, this is the metric the federal government uses to determine the amount of Title I funding each school district receives.
- While census poverty data is reliable and inclusive of all families, data may not be available at the school level.
Students in Households Receiving Temporary Assistance for Needy Families (TANF)
- School nutrition departments already have the number of students in households receiving TANF, as they are required to conduct data-matching between TANF and student rosters at least three times per year. As a subset of the identified student population, students enrolled in TANF can be used to distribute Title I funding alone or in combination with other data metrics.
- Each state can set income thresholds for TANF eligibility, yet all students in families with TANF assistance have very low/no income. In fact, in many states, income limits are set at half of the federal poverty level.
Students Eligible for Free or Reduced-Price School Meals
- As noted previously, this option is the most commonly used metric for distributing Title I funding from the school district to individual schools.
- Free meals eligibility = Below 130% federal poverty level
- Reduced-price meals eligibility = Between 130% and 185% federal poverty level
- As part of this option, districts may use an alternative household income form as a substitute for free and reduced-price meals applications. (See question 77 of SP54-2016.) However, this data source option requires significant administrative costs, increases paperwork burden, and may cause confusion among families, given that income forms are typically tied to free and reduced-price meals eligibility, yet all students will receive meals for free this year.
Bottom Line—Existing guidance allows for multiple data sources to be used for distributing Title I funding that are easier and more reliable than traditional free and reduced-price meal eligibility data. If your district is interested in exploring more reliable and accurate measures of poverty and reducing paperwork and administrative burdens for your staff, consider using Medicaid and/or identified student data to distribute Title I funding instead.