Developing and Evaluating Methods for Using American Community Survey Data to Support the School Meals Programs: Interim Report (2010)

The National School Lunch Program (NSLP) and the School Breakfast Program (SBP) are federally assisted meal programs operating in public and nonprofit private schools and residential child care institutions. The programs seek to provide nutritionally balanced, low-cost or free lunches and breakfasts to students each school day. They are a key component of the nation’s food security safety net, serving millions of children who might otherwise not obtain adequate nutrition.

The Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA) administers both programs at the federal level. At the state level, both programs are usually administered by state education agencies, which operate the programs through agreements with local education agencies (LEAs), commonly known as school districts.¹

Determination of students’ eligibility for free or reduced-price meals on the basis of need has historically involved substantial paperwork and

administrative burden for schools and families. To ease the administrative burden and at the same time expand the reach of the meals programs, USDA regulations currently allow school districts to use alternative provisions for determining federal reimbursement for meals served in one or more schools in a district. Under two such alternative provisions, the district provides free meals to all students in the participating schools (supplementing federal funds with local funds) and, in exchange, takes applications from students’ families and conducts some other administrative activities at most once every 4 years.

With the 2005 inception by the U.S. Census Bureau of a major new continuous survey, the American Community Survey (ACS), which collects income and other relevant information on very large samples of families every month, FNS decided to investigate the feasibility of using data from the ACS or other sources in the administration of the school meals programs. FNS asked the National Academies’ Committee on National Statistics and Food and Nutrition Board to convene an expert panel to consider ways in which the burden could be further reduced for school districts that provide free meals to all students in participating schools by using available data to estimate the share of meal costs to be reimbursed by the federal government. This, the panel’s interim report, specifies the technical approach and work plan that the panel will follow in responding to its charge.

USDA has provided assistance to elementary and secondary schools for meals served to students for over 70 years, initially by providing food commodities and later by also reimbursing school districts for a share of the cost of meals served. The National School Lunch Act, signed by President Truman in 1946, officially authorized the NSLP, although funds had previously been appropriated for over a decade without specific legislative authority. The 1966 Child Nutrition Act expanded the program and added the SBP on a pilot basis; 1975 legislation made the SBP permanent; and 1998 legislation expanded the NSLP to include reimbursements for snacks served to students in after-school educational and enrichment programs.

Currently, the NSLP operates in over 101,000 public and nonprofit private schools and residential child care institutions. In fiscal year (FY) 2009, the program subsidized lunches to more than 31 million students each school day at an annual cost to the federal government of $9.8 billion. The SBP currently operates in more than 88,000 schools and institutions; in FY 2009, the program subsidized breakfasts to 11 million students each school day at an annual cost to the federal government of $2.6 billion.²

School lunches and breakfasts must meet the applicable recommendations of the 1995 Dietary Guidelines for Americans, which recommend that no more than 30 percent of an individual’s calories come from fat and less than 10 percent come from saturated fat. Regulations also establish a standard for school lunches and school breakfasts to provide one-third and one-fourth, respectively, of the recommended dietary reference intakes (formerly allowances) of protein, vitamin A, vitamin C, iron, calcium, and calories. Traditionally, schools used food-based menu planning, which required school meals to offer set numbers of servings from specific food groups, with minimum portion sizes that varied by age. For example, NSLP lunches were required to offer one serving of meat or meat alternatives (cheese, beans), at least one serving of grains or bread, two servings of different fruits and/or vegetables, and one serving of fluid milk. There is an alternative nutrient-based standard for school meals that allows schools greater flexibility in the types of foods offered, but it requires nutrient analysis of planned menus. An enhanced food-based system that calls for larger fruit and vegetable portions and more grains and breads is also available. School meals must meet federal nutrition requirements, but decisions about what specific foods to serve are made by local school food authorities.³

Any child at a participating school may purchase a meal through the NSLP or the SBP. Students from families with incomes at or below 130 percent of the U.S. Department of Health and Human Services poverty guideline for their family size or who participate in certain other assistance programs are eligible for free meals.⁴ Those with incomes greater than 130 percent of the poverty guideline and less than or equal to 185 percent of the poverty guideline are eligible for reduced-price meals. For reduced-price meals, students can be charged no more than 40 cents for lunch and no more than 30 cents for breakfast. Students from families with incomes over 185 percent of the poverty guideline pay a full price, although their meals are still subsidized to some extent. School districts set their own prices for full-price meals but must operate their meal services as nonprofit programs. Most of the support USDA provides to schools in the NSLP and the SBP comes in the form of a cash reimbursement for each meal served. As a result, schools must count and

report the number of qualified meals by eligibility category (free, reduced price, or full price).

To determine students’ eligibility for free or reduced-price meals each year, school districts must publicize the availability of free or reduced-price meals and interested families submit applications. School districts must also conduct verification studies of samples of applications to determine the accuracy of the information that was provided and the eligibility status based on that information. In addition, school districts, usually through their state agency, are required to work with other agencies to identify students who can be “directly certified”; that is, automatically eligible for free school meals because their families are enrolled in another income-assistance program, such as the Supplemental Nutrition Assistance Program (SNAP, formerly the Food Stamp Program), Temporary Assistance to Needy Families (TANF), or the Food Distribution Program on Indian Reservations (FDPIR).⁵

For many years, federal, state, and local officials have been concerned about the burden of eligibility determination, verification, and meal counting, not only in terms of the time and resources required, but also because it may discourage participation by families whose children would be eligible for free or reduced-price meals. One problem with the current process is the time required in the school cafeteria line to sort out each child’s eligibility status. Another issue has to do with the potential perceived stigma associated with participating in the program. While overt identification of students participating in the program is prohibited, an FNS study (U.S. Department of Agriculture, Food and Nutrition Service, 1994a) suggested that perceived stigma is a major factor in nonparticipation. It observed that perceived stigma is generally more of an issue with high school students than with elementary school students, with middle school students in a transition stage.

To reduce costs and expand participation, federal regulations issued in 1980 permitted individual schools to use one of two special provisions designed to reduce paperwork and administrative burden in the school meals program; in 1995, a third special provision was added. Provision 2 and Provision 3 require that schools offer free meals to all participating students in exchange for collecting applications from students’ families (and using direct certification) and counting meals served by category at most once every 4 years.⁶ Then for the duration of use of one of the

provisions, schools count the total meals served daily and claim reimbursement by category using the information from the last year in which applications were taken and meals were counted.⁷ In 2004, the Child Nutrition and WIC Reauthorization Act (Public Law 108-265) expanded the opportunity to use Provision 2 or Provision 3 to groups of schools or entire school districts.

While many school districts have adopted Provision 2 and fewer have adopted Provision 3,⁸ operation under the provisions can be challenging. Under these provisions, “claiming percentages” for reimbursement are established in a “base year,” during which schools take applications and conduct direct certification and count the number of meals served by category. During the following 3 or 4 years, schools offer meals at no cost to all students, count the total number of meals served, and are reimbursed based on the meal counts by category during the base year. At the end of 4 years, when it is time to establish a new base year, many schools have lost some of the institutional knowledge and procedures needed to process applications, and families are no longer accustomed to completing the application forms.

FNS would like to develop new methods for reducing paperwork and administrative burden on schools and families and make it easier for more low-income students to participate in the school meals programs. One possible approach is to develop estimates of students who are eligible for free and reduced-price meals from income data collected in the ACS and use these estimates as the basis for reimbursement under a provision similar to Provision 2 or Provision 3. For the purposes of this report, we refer to an approach that uses ACS-derived estimates as the basis for reimbursement as Provision 4. If such estimates could be developed reliably for attendance areas for schools, groups of schools, or entire districts, it might be possible to eliminate entirely the need for schools to determine eligibility on a case-by-case basis once every few years, and more schools might choose to provide free meals to all of their students.

In response to a request from the USDA Food and Nutrition Service, a panel of experts, convened by the Committee on National Statistics, is studying technical and operational issues in using the ACS to provide small-area estimates of students who are eligible for free and reduced-

price school lunches and breakfasts. The purpose of the estimates is to provide “claiming” percentages by which USDA would reimburse school districts for providing free meals to all students attending specified schools. From the panel charge:

Following this introduction, Chapter 2 provides background on the administration of the school meals programs. Chapter 3 describes current data sources, including the ACS and SAIPE, that may provide useful estimates of eligibility for free and reduced-price school meals to be used in a new Provision 4 for administering the programs. Chapter 4 provides a framework for examining school districts and introduces the selection of districts to serve as case studies. Chapter 5 describes methods the panel will consider for developing estimates of claiming percentages for free and reduced-price meals and adjusting those estimates so that they will better reflect the eligibility requirements of the school meals programs and improve their reliability for small school districts and school attendance areas. Chapter 5 also addresses issues in estimating school meals participation, particularly changes in participation that may be due to providing lunch or breakfast at no cost to all students, and in assessing the potential costs of the programs to school districts under a new Provision 4. The panel has chosen to be comprehensive in its description of methods to be

considered. As work progresses, we will focus on those methods with the greatest potential of responding to our charge within the time frame of our study. Chapter 6 discusses how alternative estimates will be assessed concerning their fitness for use. Chapter 7 addresses issues of operational feasibility. The report makes no recommendations or conclusions; its purpose is to present a well-specified approach to carrying out the charge.