Summary

The National School Lunch and School Breakfast Programs, administered by the Food and Nutrition Service (FNS) of the U.S. Department of Agriculture (USDA), are key components of the nation’s food security safety net, providing free or low-cost meals to millions of schoolchildren each day. To qualify their children each year for free or reduced-price meals, many families must submit applications that school officials distribute and review. To reduce this burden on families and schools and to encourage more children to partake of nutritious meals, USDA regulations allow school districts to operate their meals programs under special provisions that eliminate the application process and other administrative procedures in exchange for providing free meals to all students enrolled in one or more schools in a district. Because districts must use nonfederal funds to make up any difference between their costs and the reimbursement from USDA, the special provisions are most attractive for schools with high percentages of students eligible for free or reduced-price meals.

Under the most commonly adopted provisions, USDA reimburses districts for meals served on the basis of data collected through applications in a “base year.” After 3 or 4 years, unless districts can show that socioeconomic conditions have not improved, they must take applications again to establish new base-year data that reflect the changes in conditions. The need to reestablish a base year is challenging. After not taking applications for several years, schools can lose institutional knowledge and find it difficult to process applications, while families may



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Summary T he National School Lunch and School Breakfast Programs, admin- istered by the Food and Nutrition Service (FNS) of the U.S. Depart- ment of Agriculture (USDA), are key components of the nation's food security safety net, providing free or low-cost meals to millions of schoolchildren each day. To qualify their children each year for free or reduced-price meals, many families must submit applications that school officials distribute and review. To reduce this burden on families and schools and to encourage more children to partake of nutritious meals, USDA regulations allow school districts to operate their meals programs under special provisions that eliminate the application process and other administrative procedures in exchange for providing free meals to all stu- dents enrolled in one or more schools in a district. Because districts must use nonfederal funds to make up any difference between their costs and the reimbursement from USDA, the special provisions are most attractive for schools with high percentages of students eligible for free or reduced- price meals. Under the most commonly adopted provisions, USDA reimburses districts for meals served on the basis of data collected through applica- tions in a "base year." After 3 or 4 years, unless districts can show that socioeconomic conditions have not improved, they must take applica- tions again to establish new base-year data that reflect the changes in conditions. The need to reestablish a base year is challenging. After not taking applications for several years, schools can lose institutional knowl- edge and find it difficult to process applications, while families may 1

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2 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS resent completing what appears to be a new form when their children are already receiving free meals at school. As an alternative, a periodic survey of a sample of families with enrolled students could provide updated socioeconomic information for determining reimbursements, and would be less burdensome than annual applications. For most districts, however, collecting high-quality data at an affordable cost through a local survey could be a substantial challenge. A special provision that would incorporate new data reflecting changes in local conditions without requiring applications to be taken or a special survey to be conducted every few years would be attractive to school dis- tricts and families: it would further reduce burden and could potentially increase the numbers of students who partake of school meals by expand- ing their access to free meals. To this end, FNS asked the National Acad- emies' Committee on National Statistics and the Institute of Medicine's Food and Nutrition Board to convene a panel of experts to investigate the technical and operational feasibility of using data from the continuous American Community Survey (ACS) to estimate students eligible for free and reduced-price meals for schools and school districts. The ACS eligi- bility estimates would be used to develop "claiming percentages" that, if sufficiently accurate, would determine the USDA reimbursements to districts for schools that provided free meals to all students under a new special provision that eliminated the ongoing base-year requirements of current provisions. The ACS is a natural source of data for deriving such eligibility estimates. As the replacement for the long-form sample of the decen- nial census, the ACS is designed to produce relatively precise estimates throughout the nation for small geographic areas, such as school districts, by surveying large samples of households and accumulating data over periods of 1, 3, and 5 years, depending on an area's population. Since becoming fully operational in 2005 (2006 for residents of group quarters), the ACS samples each month about 240,000 housing unit addresses, a target that was increased to 295,000 in June 2011. No other national house- hold sample survey is nearly as large. The U.S. Census Bureau conducts the ACS and achieves high overall response rates of 97 to 98 percent. Collecting information on households and their members--including household composition, school attendance and educational attainment, income, participation in government assistance programs, and other characteristics--the ACS provides data for constructing estimates of total enrollment and students eligible for free and reduced-price meals for schools and school districts. The panel examined alternative procedures for constructing such estimates, provided the Census Bureau with a set of specifications, and evaluated the resulting estimates. The panel conducted this study in two phases. It first issued an

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SUMMARY 3 interim report (National Research Council, 2010), describing its planned approach for assessing the utility of ACS-based estimates for a special provision to expand access to free school meals. This, the panel's final report, presents the panel's findings and recommendations and concludes the second phase of the study. The bottom line is a glass half-empty and half-full story. The half-empty part is the panel's conclusion that there is no immediately obtainable and usable set of estimates from the ACS that would enable USDA to specify a new special provision eliminating periodic base-year applications in all of the schools or entire districts that want to provide free meals to all students. The glass half-full part is that the panel developed a set of procedures through which an assessment by a school district could lead USDA to approve the use of ACS-based claim- ing percentages for some or all of the district's schools. The panel's initial goal was to identify a universally applicable method for estimating ACS-based claiming percentages that could be used in any school district operating under a new special provision. The panel anticipated that one or more simple adjustments might be needed to account for consistent differences between ACS-based estimates and those from the traditional certification process of the school meals programs. However, the panel's comparison of ACS estimates with adminis- trative data for all school districts and for all schools in five case study districts revealed that the ACS generally understates the percentages of students eligible for free meals and overstates the percentages eligible for reduced-price and full-price meals, particularly in schools and districts with high percentages of students eligible for free and reduced-price meals. More important, the systematic differences observed vary sub- stantially across schools and districts. In Norfolk, Virginia, for example, the differences between ACS estimates and administrative data are small, whereas in Pajaro Valley, California, the differences are quite large. Several major factors appear to contribute to such systematic differ- ences in varying degrees in different places: underreporting of Supple- mental Nutrition Assistance Program (formerly Food Stamp Program) participation by ACS respondents, use of annual income in the ACS to determine eligibility rather than monthly income as in the application process, limitations of using ACS data to count migrant and other s tudents who do not live in traditional housing or do not live in the district all year, the presence of charter schools and other school choice opportunities that draw students from their neighborhood schools and the districts in which they reside, and errors in the certification process. The variation in differ- ences between ACS and administrative estimates illustrated by Norfolk and Pajaro Valley demonstrates that a one-size-fits-all approach to correct- ing for the effects of these and other factors will not work. Accordingly, the panel suggests a more tailored approach to using

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4 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS ACS estimates in a new ACS Eligibility Option (AEO). Essentially, an interested district would examine its annual ACS eligibility percentages to determine whether they were sufficiently close to the district's own certification percentages or, at least, differed in a consistent way from year to year. Should a district such as Norfolk, where the ACS eligibility percentages are consistently quite close to district-level data, determine that it was economically feasible to implement the AEO districtwide or for a group of schools, the district could apply for and USDA could approve the district's adoption of the AEO. In a district such as Norfolk, the AEO could be implemented with no correction or only a small correction for the differences between ACS and administrative estimates and with an adjustment to reflect the different expected participation rates of students in the free, reduced-price, and full-price categories when all students were offered free meals. A district where there were substantial differences between ACS eligi- bility percentages and district certification data would need several years of ACS and administrative data to demonstrate the stability of a correction for such systematic differences. If such stability were found, the district could apply for a version of the AEO that would correct for the differences by benchmarking the ACS estimates to the administrative data. The district could operate an "AEO base year" to provide sufficient data to establish the benchmarking correction and incorporate the effects of the anticipated increase in participation due to offering free meals to all students. For any district that adopted the AEO, the annual release of ACS estimates would allow the district's AEO reimbursement claiming percentages to be updated each year to reflect the changes in socioeconomic and demo- graphic conditions that are captured by the ACS. Nonetheless, districts could opt out at any time. Because consideration of the AEO raises complex issues and the resources available to address such issues are limited, school districts will undoubtedly encounter technical and other challenges in assessing whether to adopt the AEO and in implementing it if the assessment is favorable. Recognizing these challenges, the panel offers a set of recom- mendations to facilitate districts' assessment and implementation of the AEO and to potentially improve the accuracy of school meals program eligibility estimates based on the ACS. One such recommendation is that FNS provide technical assistance to states and districts, including the development and provision of a web-based "AEO Calculator" for use by districts in working with ACS estimates to assess and implement the AEO. The panel also recommends the designation and supplemental funding of early implementers of the AEO as demonstration sites and the commissioning of an independent

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SUMMARY 5 evaluation to enhance understanding of the effects of adopting the AEO, including, especially, the effects on participation and administrative costs. The panel's recommendations also are designed to facilitate imple- mentation of the AEO by removing specific barriers to its adoption. Because National School Lunch Program certification data are used to confer benefits for and administer other assistance and education pro- grams, some districts have been reluctant to adopt existing special provi- sions that eliminate--for at least several years--the certification process and, thereby, certification data. These needs of other programs might also be a barrier to adoption of the AEO, which permanently ends the certifica- tion process. Therefore, the panel recommends that FNS, the U.S. Depart- ment of Education, and other federal, state, and local agencies agree to allow school districts to use data other than traditional National School Lunch Program certification data for individual and aggregate reporting of economically disadvantaged students under the Elementary and Sec- ondary Education Act, as well as for other purposes. In considering the AEO, some districts may wish to adopt it in a sub- set of schools with especially high concentrations of students eligible for free or reduced-price meals rather than districtwide. For such districts, the panel recommends that FNS and the Census Bureau agree on protocols and schedules for the exchange of school attendance area boundary infor- mation and the dissemination of ACS estimates, and that FNS provide technical assistance for the preparation of the geographic information needed by the Census Bureau. Additional recommendations by the panel address activities to mon- itor and enhance the accuracy of the ACS eligibility estimates that would be used to implement the AEO. Specifically, the panel recommends collaboration among FNS, the U.S. Department of Education, and the broader education research community in monitoring the prevalence of school choice opportunities and evaluating the effects of such opportu- nities on the accuracy of ACS eligibility estimates; monitoring by FNS of the accuracy of ACS eligibility estimates, the accuracy of administra- tive certification estimates, and the accuracy and stability of differences between the ACS and administrative estimates; sponsorship of research to develop a statistical model that could be applied to all districts in adjusting for differences between ACS eligibility estimates and school meals program certification data; and collaboration between FNS and the Census Bureau to improve the methods for deriving ACS eligi- bility estimates, with a focus on methods for small-area model-based estimation. Although these recommendations and those pertaining to technical assistance and related activities are appropriate for FNS to pursue if it chooses to implement the AEO, the panel developed other recommen-

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6 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS dations that should be considered even if the AEO is not implemented. These recommendations address some of the challenges associated with survey and administrative data that the panel encountered in conducting its analyses. One set of recommendations entails research activities that could improve ACS estimates for all uses, particularly those that require esti- mating whether low-income individuals are eligible for benefits under various assistance programs, such as the school meals programs. In addi- tion to research to assess the quality of the panel's definition of "economic unit" for use in determining eligibility for free and reduced-price meals with the ACS, the panel recommends that the policy research community and the Census Bureau continue to investigate the causes of and solutions for not only the underreporting of income and program benefits, but also the differences in program eligibility estimates based on monthly and annual income. Another set of recommendations entails research and other activities by FNS, the Census Bureau, and the National Center for Education Statis- tics that would improve the quality and availability of data pertaining to the school meals programs. These recommendations include annual pro- duction and dissemination of district-level ACS estimates of total enroll- ment and percentages of students eligible for free and reduced-price meals according to the panel's specifications (as revised based on further research); improvements in the quality and comparability of administra- tive data on enrollment and certification in the school meals programs; improvements in the quality, comparability, and availability of adminis- trative data on participation in the school meals programs; and a feasi- bility assessment of developing a program for the periodic collection of data on the administrative costs of operating the school meals programs. This report presents and describes in detail the panel's analyses and findings; the AEO developed by the panel; and the panel's recommenda- tions for facilitating implementation of the AEO, improving the accuracy of ACS estimates of eligibility for the school meals programs, and enhanc- ing the quality and availability of survey and administrative data for a broad range of uses. If implemented, the AEO would provide an oppor- tunity to expand access to free meals for the nation's schoolchildren and reduce administrative burden on schools and families.