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Recommended Meals Policy for Charter Schools

Public Benefits

Recommended Meals Policy for Charter Schools

On August 5, 2013, the following organizations recommend that the School Reform Commissions (SRC) adopt the following language governing school meals standards in all Charter School contracts: Public Citizens for Children and Youth (PCCY), Community Legal Services (CLS), the Coalition Against Hunger, Food Research and Action Center (FRAC).

Introduction

Longstanding research shows the tremendous health and academic benefits of school breakfast and lunch. Yet, wide disparities exist in school meals participation among charter schools, particularly in breakfast utilization. SY 2012-13 data from the Pennsylvania Department of Education (PDE), which administers the federal meals programs, shows that 79 of 84 current charters participated in the National School Lunch Program (NSLP), and significantly fewer – 68 – participate in the School Breakfast Program (SBP).[1] As such, there is a need for clear standards and oversight to insure maximum participation, as well as the sharing of basic information and best practices for the delivery of school meals. Our recommendations for a charter schools meals policy fall along broadly supported goals of improving access, ensuring equity and establishing accountability, so that school meals are utilized to their full potential to support student achievement and health.

Recommendations:

1. Participation in the National School Lunch Program and School Breakfast Program

All schools are required to participate in the National School Lunch Program and School Breakfast Program. Schools may contract with the Food Services Division of the Philadelphia School District, contract with another PDE-approved food service provider[2]or operate as a separate LEA with the approval and oversight of the Pennsylvania Department of Education’s Division of Food and Nutrition All schools should ensure that eligible students have immediate access to free or reduced-price meals upon enrollment, as quickly as possible and within five school days.

2. Direct Certification   

All schools are required to comply with federal law requiring Direct Certification, i.e. automatic eligibility for free school meals without an individual application, for children in households participating in the Supplemental Nutrition Assistance Program (SNAP).  In addition, all schools are required to directly certify children in households receiving Temporary Assistance for Needy Families (TANF) and, for so long as Pennsylvania is participating in the USDA pilot project for Direct Certification of students enrolled in Medicaid (also known as “Medical Assistance” or “MA”), schools must directly certify of all students enrolled in certain categories of Medicaid. Schools shall follow PDE guidance concerning best practices for directly certifying students. Currently, PDE advises that schools upload student data to COMPASS, which results in a higher match rate than downloading PDE data. This approach will help ensure the Direct Certification of as many students as possible.

3. Certification of Other Categorically Eligible Children

All schools should also certify without an application students who are categorically eligible for free school meals due to their status as homeless or runaway, migrant, in foster care or enrolled in a Head Start program. Schools may not require an application to certify such students and must obtain a list of these students from the appropriate district coordinator (i.e. the Homeless Education/McKinney-Vento coordinator, Migrant Education Coordinator, or Head Start Director).

4. Certification by Individual Household Application

Application materials and other communications with households concerning eligibility determinations must be provided in a language that parents and guardians can understand as required by federal law. Schools must make reasonable efforts to provide forms in the appropriate languages for Limited English Proficient households, including access to USDA Food and Nutrition Service prototype application translations (See: http://www.fns.usda.gov/cnd/Application/ translatedapps.html). Schools must ensure that all parents and guardians have access to, and assistance in completing, these applications.

5.  Increasing Availability of Universal Free Meals

Schools are strongly encouraged to pursue options that will allow them to offer universal free meals, thereby avoiding the paperwork, expense and obstacles of individual applications for free or reduced-price meals.

Currently, all schools contracting with the School District of Philadelphia’s Food Services Division[3]are eligible to offer free school breakfast to all students. In addition, schools that meet the required eligibility thresholds as determined by DFS may also be eligible to offer Universal Free Lunch.[4] Alternatively, schools with 65 percent or more FRP certified students are strongly encouraged to utilize one of the following options to offer breakfast and lunch at no charge to all students:

  • Community Eligibility Option: This new federal option will be available in SY 2014-2015 to any school that chooses to participate and that has 40 percent or more “identified students” certified for free meals without submitting a school meal application, which includes: children who are directly certified (through data matching) for free meals because they live in households that participate in the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), the Food Distribution Program on Indian Reservations (FDPIR), or are enrolled in Medicaid, as well as children who are automatically eligible for free school meals because of their status as being in foster care or Head Start, homeless or migrant. Schools must offer breakfast and lunch at no charge to all students and may not collect school meal applications. Reimbursements are determined by multiplying the percentage of “identified students” by 1.6 to determine the percent of meals eaten that will be reimbursed at the free rate, and the remaining meals are reimbursed at the paid rate.
  • Provisions 2: ,This is a federal option that allows schools to serve meals to all students at no charge. Schools may use Provision 2 to offer all students free breakfast, lunch, or both. For more information, see:  http://www.fns.usda.gov/cnd/breakfast/expansion/expansionstrategies.htm

6. Increasing Participation in the School Breakfast Program

All schools should aim to serve free or reduced-price meals to as many eligible children as possible in each school. Entities seeking to establish a new charter school must include a plan to provide meals and reach eligible students as part of its application to the School Reform Commission (SRC). Schools seeking charter renewal must also provide data on participation in school breakfast and lunch, as well as efforts to maximize participation.

The School Reform Commission shall issue guidance to all charter schools concerning participation in meals, including:

  • Participation rates in breakfast and lunch – and efforts to improve these rates annually if participation among free and reduced-price certified students is not strong– will be reviewed when a school’s charter is reviewed for renewal.
  • Schools should aim to achieve levels of participation of free and reduced-price certified students for lunch consistent with SDOP averages for schools serving the equivalent grade levels from the previous year’s annual average. The SRC shall direct the Division of Food Services to calculate the annual average daily participation (ADP) of free and reduced-price certified students for elementary, middle, and high schools to be utilized as benchmarks for lunch participation.
  • For breakfast, schools should aim to serve at least 70 percent of free and reduced-price certified students receiving lunch (for instance if a school is serving 70 percent of eligible students lunch, it would aim to reach 49 percent of eligible students with breakfast).
  • The SRC may require specific remedies in charter renewals if a school has failed to improve low breakfast or lunch participation levels during its previous charter contract period, such as the adoption of best practices  including breakfast in the classroom (BIC) in younger grades, and kiosk or “grab and go” alternatives for higher grades.

7. Parent/Guardian Notification  

At the beginning of the year, or when a new student enrolls during the school year, schools must provide the following information to parents or guardians, and also inform them and the public where this information is available online:

  • School meal delivery practices (times breakfast and lunch are served and method of service utilized)
  • Methods utilized to certify that school’s children for free and reduced-price meals (e.g. Universal Feeding, Direct Certification, Community Eligibility Option, applications)
  • Average daily participation for free and reduced-priced breakfast and lunch from the previous school year
  • For schools relying on paper applications, notification of where hard-copy and online paper applications are available, as well as whom parents can contact for assistance in filling out applications

Conclusion

These recommendations support the goals of improving and maximizing access to free and reduced-priced school meals, ensuring equity and establishing accountability, while also allowing individual schools flexibility to develop an individualized program.

Contact information:

Jonathan Stein, Community Legal Services, (215) 981-3742 jstein@clsphila.org

Kathy Fisher, Public Citizens for Children and Youth, 215-563-5848 x27, kathyfisher@pccy.org

Julie Zaebst, Coalition Against Hunger, 215-430-0555 x121, jzaebst@hungercoalition.org

Jessie Hewins, Food Research and Action Center, 202-986-2200 x3966, jhewins@frac.org

 

[1] Pennsylvania Department of Education Division of Food and Nutrition, Building Data Report For October 2012 Meals Served.

[2] Providers must be approved by PDE (see: http://www.education.state.pa.us/portal/server.pt/community/ foodnutrition_services/7483/contracting_with_a_food_service_management_company_%28fsmc%29/561495,

[3] Due to the high volume of meals and the efficiencies Food Services has achieved, it has been able to offer free breakfast to all students at all district schools for several years and plans to continue this practice.

[4] The School District of Philadelphia’s Division of Food Services will evaluate which of the various options (the current “Survey Method,” Community Eligibility, or others) is best to support the District’s Universal Feeding program.

Date: 
08/08/2013