Documenting Site Eligibility
This is part 3 of a series of presentations that provide an overview of planning and administering the Summer Food Service Program or SFSP. In this presentation, we will discuss documenting eligibility. Sponsors must be able to document that their sites are eligible to participate in the program. We will now discuss the different requirements for documenting site eligibility.
For open and restricted open sites, the two primary sources of data that may be used to determine whether the area that will be served as eligible our: school data or census data. Let's start with school data. In order for a site to be determined area eligible, using School data, the school data must indicate that the proposed meal site is located in a school attendance area where at least 50% of the children are eligible for free or reduced-price school meals. This data should not be based on school meal participation rates, rather it should be based on the percentage of children who qualify for free or reduced-price meals. Sponsors may use data from elementary middle or high schools as long as the site is located within the attendance area of the school. Once established eligibility is good for 5 years.
In school districts where busing or school choice policies are in place, if the site is located inside the area eligible school, sponsors may always rely on the National School Lunch Program data for that individual School. In school districts where busing or school choice policies are in place but school attendance areas are still defined, sites located both in schools or in other locations may be determined eligible based on the enrollment or attendance data obtained for either the school the children attend or the school the children would have attended were it not for the schools busing or school-choice policy. The same method for determining site eligibility must be used for all sites participating under a particular program sponsor to avoid duplicate counting.
Community Eligibility Provision or CEP serves as an alternative to collecting individual applications for free or reduced-price meals. CEP allows schools and local education agencies, with a high percentage of low-income children, to offer free meals to all students. Qualifying schools serve free lunch and breakfast through the National School Lunch Program and School Breakfast Program. Individual school data must be used to determine area eligibility for SFSP, even if schools are participating in CEP as part of a group of schools, or a school district, and claiming meals with a shared identified student percentage or ISP. If a school’s ISP is greater than or equal to 31.25, then the meal sites located in the attendance area of the school are eligible for 5 years.
Sponsors also may document that area eligibility of their proposed open or restricted open sites on the basis of census data. This is an alternate option to using school data, however if the school district does not have to find school attendance areas the use of school data is not permitted for non-school sites. In this case, Census data must be used to determine area eligibility for the National School Lunch Program and Summer Food Service Program.
To qualify as a closed enrolled site, at least 50% of the enrolled children must be from households that meet the income eligibility guidelines. Sponsors can document an enrolled sites eligibility by: obtaining lists of enrolled children for free or reduced-price meals from schools operating the NSLP or SBP, asking the parent or guardian of each enroll child to complete a household application, using area eligibility data for the location of the site, or using Census data when the site is located outside of an eligible area.
Sponsors that operate residential summer camps and non-residential day camps, offering both organized programming and a regularly scheduled food service, may participate in the SFSP. Non-residential day camps may participate only as sites under eligible sponsoring organizations and enrolled for-profit sites or for-profit camps are not eligible for participation in the SFSP. Unlike other types of sites, camps do not have to establish income eligibility at the 50% level. Instead, camps are reimbursed only for meals served to children who meet the income eligibility criteria for free or reduced-price school meals.
In order to determine eligibility for children, camp sponsors me use the household application or rely on lists of income-eligible children provided by the school system. However, state agencies may require camp sponsors to use the household application or a state agency equivalent form. SFSP sponsors of closed enrolled and campsites must collect and report income eligibility information to the state agency—household applications are current and valid for one year.
Sponsors may utilize household applications from other programs that base their eligibility on the same criteria as the SFSP but should contact the state agency to verify that the same threshold and definitions are used for both programs. For example, sponsors can use documentation of income-eligible Upward Bound participants provided and certified by an Upward Bound grantee to document the eligibility of closed enrolled site or residential or non-residential camps.
In an effort to provide consistent administration across program lines, to State agencies and SFSP sponsoring organization, sponsors of sites determine to the area eligible based upon school and Census data are only required to submit documentation every 5 years. Sponsors using other sources, including household applications, must document site eligibility annually.
If sponsors are unable to document the need of their area or site by using sources such as current year school data or recent Census data, they should consult with their state agency about the possibility of using other types of data to determine area eligibility to document site eligibility.
Children age 18 and under, may receive meals through SFSP. A person 19 years of age and over who has a mental or physical disability and who participates during the school year in a public or private non-profit school program, is also eligible to receive meals. Sponsors may determine and document participant eligibility in a number of ways. We will now discuss these options.
The household application is used to determine the income eligibility of enrolled children for all camps and foreclosed enrolled sites. The information collected on the household application includes household size and income or the case number for benefits received under another comparable federal assistance program. Any alternate forms developed by sponsors, must request the same information as is found on the USDA prototype household application forms and must be approved by the state agency before use. Eligibility based on household applications is valid for 12-months. Families must reapply and sponsors must read determine income eligibility annually.
Children enrolled in federal Head Start or Early Head Start programs are eligible for free meals in SFSP without further application. Sponsors may establish eligibility of all Head Start enrollees through documentation provided by the Head Start Program. Forms of acceptable documentation include: an approved Head Start application, a statement of Head Start enrollment, or a list of participants from a Head Start official. Applicant families also may indicate a child's participation in Head Start on the household application. Eligibility based on such documentation is valid for 12-months.
When SFSP sponsors have to obtain individual eligibility information, they can obtain a child's eligibility status from another Child Nutrition Program operator to expedite the certification process. Schools and other Child Nutrition Program operators may disclose aggregate information to the public without parental notification. This is allowed as long as an individual or group of children's eligibilities cannot be identified through release of the aggregate data or by means of deduction. There are, however, restrictions on the disclosure and use of information obtained from a household application as well as criminal penalties for improper release of information. If you have questions about the proper release of information, please contact the state agency for additional guidance.
Area eligibility may also be established by using documentation from other approved sources to demonstrate that 50% or more of the children in a defined area are eligible for free or reduced-price school meals. Eligibility determinations using approved alternative data also remain in effect for five years. Approved sources my include departments of welfare, zoning commissions, USDA’s Rural Development housing authorities, Housing and Urban Development (HUD) housing authorities, or local housing authorities. For example, if an SFSP site is located in a HUD housing authority development, and it does not qualify based on school or Census data, the site may be considered area eligible using HUD data if residents of the housing development meet income eligibility requirements that are equivalent to or more restrictive than the SFSP requirements.
Certain categories of children are automatically eligible for free meals and no income information is required. This is referred to as categorical eligibility. Children may be classified as categorically eligible for a period of 12-months through: participation in another comparable federal assistance program, documentation that the child is homeless, runaway or migrant, a foster child, or enrollment in a federally funded or state funded Head Start program or pre-kindergarten program.
Individuals participating in any of the following programs may be determined eligible: National Youth Sport Program, Upward Bound, Workforce Investment Act participation, Military Privatized Housing, Military Combat Pay, or Armed Forces Family Subsistence Supplemental Allowance. For additional information about eligibility documentation required for each of these programs, please contact your state agency.
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