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5 A Plan for Implementing the AEO T he panel was convened to investigate the technical and operational feasibility of using data from the American Community Survey (ACS) to expand the availability of free school meals under a new special provision of the National School Lunch Program (NSLP) and School Breakfast Program (SBP). Under an ACS Eligibility Option (AEO), the ACS would provide estimates for the development of claiming per- centages for use by the U.S. Department of Agriculture (USDA) in reim- bursing school districts for the federal government's share of the costs of providing free school meals to all enrolled students in participating schools. Expanding the availability of free meals would likely lead to increased participation by students, which in turn could well lead to such desired outcomes as improved nutrition, health, and school performance. Another benefit of using the AEO would be sparing families and school districts the burden and costs of completing and processing annual application forms. In contrast, two existing special provisions, Provi- sions 2 and 3, require periodic administration of applications to provide the baseline for claiming percentages for the next 3-4 years (unless it can be demonstrated that economic conditions have not changed sub- stantially). The Community Eligibility Option (CEO), which is currently being pilot-tested in districts in three states, requires less paperwork than Provisions 2 and 3, but it requires direct certification (determination of eligibility on the basis of matching to lists of participants in other pro- grams for low-income families and children) at least every 4 years. The major disadvantage of the CEO is that it can be used only by districts or 151

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152 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS schools with 40 percent or more of enrolled students who are identified as eligible for free meals through direct certification or the use of local lists of categorically eligible students. According to the form FNS-742 data set for 2009-2010, only 3.5 percent of school districts would be eligible to adopt the CEO districtwide, although it is more widely applicable for schools or groups of schools. Because school districts must use nonfederal funds to make up any difference between their costs and the USDA reimbursement, Provisions 2 and 3, the CEO, and the AEO are likely to be most attractive to schools with high percentages of students eligible for free or reduced-price meals. Assuming for the sake of illustration that the AEO would appeal to school districts with 75 percent or more eligible students, then according to Table 3-1 in Chapter 3, the AEO might be attractive to as many as 1,291 districts.1 These districts are a relatively small percentage (10 percent) of the total number of districts nationwide, yet they enroll a larger percent- age of total students (13 percent). Table 5-1 shows that of the districts that reported operating under Provision 2 or 3, not in a base year, in the FNS-742 data set for 2009-2010, 296 (79 percent) had implemented the pro- vision districtwide. Of these districts, 69 percent had 75 percent or more of students certified for free or reduced-price meals, while the others were almost evenly split between those with 50 to 75 percent of students eli- gible for free or reduced-price meals and those with 50 percent or fewer of students eligible. Although this evidence supports the statement that the AEO may appeal to districts with free or reduced-price eligibility percent- ages greater than 75 percent, it also shows that there must be reasons why districts with smaller percentages of free- and reduced-price-eligible stu- dents may choose to participate. The panel observes further that because many districts with less than 75 percent eligible students districtwide include some schools that exceed the 75 percent cutoff, still more students could benefit from a universal free meals program should these districts adopt the AEO for a subset of their schools. The panel's original expectation regarding the AEO was based on the assumption that the U.S. Census Bureau would be able to estimate accurate ACS-based claiming percentages straightforwardly for every school district in the United States, and the Food and Nutrition Service (FNS) would allow districts to use the ACS-based estimates to claim reimbursements under a universal free meals option. With a universally applicable method providing accurate estimates, districts that wanted to adopt the AEO districtwide could proceed with confidence that the ACS estimates would be satisfactory. As with Provisions 2 and 3, districts could determine whether the benefits of implementation would outweigh the 1Some of these districts are likely to be participating in Provision 2 or 3 already.

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A PLAN FOR IMPLEMENTING THE AEO 153 TABLE 5-1 Districts Operating Under Provision 2 or 3 in 2009-2010, Not in a Base Year Percentage Free or Reduced Price Greater Than 50%, Less Than Less Than or Equal or Equal Greater to 50% to 75% Than 75% Total Districtwide Number 34 29 233 296 Percentage 11 10 79 Some Schools Number 43 61 31 135 Percentage 32 45 23 Total 77 90 264 431 Total Districts in United States 12,257 Percentage of Total Districts Under 4 Provision 2 or 3 SOURCE: Prepared by the panel. costs in their own situations. Should adoption of the AEO for a subset of schools be preferable to districtwide adoption, the district would have to complete an additional step of providing geographic boundaries for the applicable school attendance areas to the Census Bureau, which would prepare ACS estimates for those areas. As demonstrated in the preceding chapter, however, ACS estimates are not sufficiently accurate for use in a one-size-fits-all version of the AEO. The remainder of this chapter briefly summarizes the reasons why the panel's initial goal of a universal method could not be achieved and then provides a detailed description of a tailored approach to imple- menting the AEO for consideration by FNS. In the subset of districts that decides to investigate the AEO and for which accurate claiming percentages can be developed, it might still be possible to achieve the AEO's advantages of providing universal free meals and eliminating applications. The panel's recommendations for research and development in Chapter 6 are directed toward improvements in data and estimation methods that would enhance prospects for using the AEO more widely in the future.

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154 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS INITIAL GOAL VERSUS REALITY The panel's initial goal was to identify a universally applicable method for estimating ACS-based claiming percentages and, if sufficient data on school district costs and increased participation under a univer- sal free meals program could be obtained, to specify when it would be cost-beneficial for a school district to adopt the AEO for some or all of its schools. With regard to ACS-based claiming percentages, we anticipated that one or more simple adjustments might be needed to account for consistent differences between ACS eligibility estimates and administra- tive estimates derived from the application and certification processes conducted by districts. As noted earlier, the data the panel collected and the extensive analy- ses we undertook did not enable us to recommend a universally appli- cable method for implementing the AEO for the school meals programs. This conclusion should not be taken as a general indictment of the ACS, which was not designed specifically to support the school meals programs but as a multipurpose survey covering a variety of subject areas. More- over, the significant variations in school district characteristics, such as enrollment size, populations served, and organization (for example, open enrollment and charter schools) make it unlikely that any general-purpose survey could serve as the basis for a universally applicable new special provision. That being said, the quality of the ACS reporting of income and program participation could undoubtedly be improved, and our findings identify promising areas for research and development to that end (see Chapter 6). Systematic Differences The first, and most important, impediment to a universal, one-size- fits-all approach for the AEO is that in districts with more than 50 percent of students eligible for free or reduced-price meals, ACS direct estimates,2 when compared with administrative estimates for all such school districts and for all the schools in the panel's five case study districts, generally understate the percentage of students eligible for free meals and overstate the percentages eligible for reduced-price and full-price meals. This pat- tern of differences is especially pronounced in districts and schools with very high percentages (75 percent or more) of students eligible for free and reduced-price meals, which are precisely those districts most likely to be interested in the AEO if accurate claiming percentages could be 2For small districts, for which the gains in precision from model-based estimates are great- est, the systematic differences between model-based and administrative estimates are sub- stantially larger than the systematic differences between direct and administrative estimates.

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A PLAN FOR IMPLEMENTING THE AEO 155 developed. Moreover, the differences between administrative and ACS estimates of students eligible for free and reduced-price meals likely vary substantially among school districts. Consequently, despite exten- sive investigation, we were unable to develop a set of universally appli- cable adjustments to ACS-based estimates of students eligible for free and reduced-price meals that would achieve reasonable consistency with administrative estimates from the current certification process. As described in Chapter 4, many factors appear to underlie the differences between the ACS estimates and administrative data (including errors in those data), and the importance of each factor varies among districts. Sampling Variability In addition to the systematic differences between ACS eligibility esti- mates and administrative data, the ACS estimates exhibit sampling vari- ability, which could cause claiming percentages and reimbursements to fluctuate excessively from year to year. However, the panel found that while 1-year ACS estimates are more variable than the administrative estimates to which districts are accustomed, 3- and 5-year ACS estimates are less variable than administrative estimates for large districts. For typi- cal medium-sized districts, the ACS 3-year estimates have about the same variability as administrative estimates, and the 5-year estimates have less variability. For small districts with enrollments of at least 400 students, the 5-year ACS estimates would be somewhat more stable than administra- tive estimates; for smaller districts, however, the ACS estimates might be less stable than administrative estimates. Timeliness Bias and Overall Accuracy The 5-year ACS estimates are less variable--that is, more stable--over time than the 1-year and 3-year ACS estimates. However, because the 5-year estimates average the most recent data with older data over a 5-year period, the 5-year estimates are less responsive to real changes in socioeconomic conditions, such as those occurring during the recent "Great Recession," than the 1- and 3-year estimates. Likewise, the 3-year estimates are more stable but less responsive to changes than the 1-year estimates. School food authority directors who participated in the panel's work- shop (refer back to Chapter 3) indicated that the stability of claiming percentages from year to year was generally more important than their timeliness. The reason is that dramatic changes in claiming percentages due to sampling variability or a rapid improvement in economic condi- tions (or both) would leave a school district scrambling for funds if a large drop in federal reimbursements occurred. (Of course, changes in claiming percentages that increased reimbursements would benefit the district.)

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156 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS This concern leads to a preference for using ACS estimates based on more rather than fewer years of data even though the estimates would be less reflective of current economic conditions. This preference is reinforced by our finding that for medium-sized districts, 5-year estimates are likely to be more accurate than 3-year estimates when one takes into account error from both variability and timeliness bias. For large districts, both 3- and 5-year estimates are likely to be more accurate than 1-year estimates, although whether the 3- or 5-year estimates are more accurate is less clear. Based on these findings, we outline below how a school district might approach the stability-timeliness trade-off in evaluating the AEO. Calculation of Costs and Benefits Because of a lack of sufficient data, the panel was unable to develop universally applicable estimates of the expected additional costs due to offering free meals to all students versus the savings due to eliminating the application, certification, and verification processes and to economies in the meal-serving process (such as eliminating the need to count meals by eligibility category or to collect money). The data available to the panel suggest that the net costs would likely vary significantly among school districts. Also because of a lack of data, the panel was unable to develop uni- versally applicable estimates of the expected increase in participation among students in different eligibility categories (free, reduced-price, full-price) under a universal free meals program. Accurate estimates of participation by category are essential not only for estimating claiming percentages that accurately reflect changed participation patterns so the federal government appropriately reimburses school districts, but also for accurately calculating the net costs to school districts of implementing universal free meals. Our suggested approach for implementing the AEO accommodates the lack of data on changes in participation by using the same mechanism used for Provision 2--namely, using a base year during which all meals are served free, but applications are taken, verifications are conducted, and reimbursement is based on meal counts by category. The base-year participation rates will reflect any changes in participa- tion due to providing free meals to all students, and they can be used in conjunction with ACS eligibility estimates for establishing claiming percentages. Of course, a full cost-benefit calculation also needs to account for nonpecuniary benefits, such as an improved environment in the cafeteria due to elimination of stigma and improvements in diet quality that may ultimately lead to improvements in student health and school perfor- mance. There may also be nonpecuniary costs, such as possible dissatis- faction among some stakeholders because of perceived increased costs for

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A PLAN FOR IMPLEMENTING THE AEO 157 universal free meals. At the panel's workshop, some of the participants representing school districts indicated that they would probably consider only districtwide adoption of the AEO to reflect public opinion in their districts, while others would probably consider implementing the AEO only in some schools. All of these officials, however, emphasized that their district would need to "run the numbers" to determine whether the AEO was financially viable in terms of the district being able to cover the costs of the meals programs through federal reimbursements and other sources of funds while providing free meals to all students attending schools in which the AEO might be adopted. OVERVIEW OF THE PROPOSED AEO As noted above, the AEO proposed by the panel, like Provision 2, begins with a base year during which districts collect applications, con- duct verifications, and count meals but feed all students free of charge. Reimbursement in the base year makes use of meal counts by category, as in the traditional approach. ACS eligibility estimates and the district's own administrative data for a minimum of 4 years (including the base year) are used to compute benchmarked ACS claiming percentages that are used to determine reimbursements in future years, when all meals are free. The benchmarked ACS claiming percentages are updated annually when the new ACS data become available. The benchmarking approach proposed by the panel automatically adjusts for systematic differences between the ACS estimates and a dis- trict's administrative data. As discussed in Chapter 4, many of the reasons for these systematic differences relate to issues affecting the ACS esti- mates, particularly in high-poverty areas: underreporting of Supplemental Nutrition Assistance Program (SNAP, formerly the Food Stamp Program) benefits; use of annual rather than monthly income to determine eligibil- ity; omission of students who live in group quarters or nontraditional housing; differential inclusion of part-time residents, such as migrant workers, who live in traditional housing; and school choice. Benchmark- ing is likely to remove these causes of systematic errors. Because it is based on certification data, however, benchmarking can perpetuate the effects of certification error. That is, if certification error is present in a district's administrative data, it will continue to be present in AEO bench- marked estimates. Furthermore, all else being equal, the AEO will be more attractive to districts with higher levels of overcertification. 3 3Further research could be undertaken to develop an approach for adjusting administra- tive estimates to remove certification error. Prior to approval of a district's request to adopt the AEO, FNS might want to review the district's verification results and consider correc- tions to the district's benchmarking adjustments for certification error.

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158 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS This section provides an overview of the implementation of the AEO, beginning with the provision of ACS tabulations for school districts to use in deciding whether to adopt this new provision. The approach discussed here requires one or more interagency agreements between the Census Bureau, FNS, and possibly the National Center for Education Statistics (NCES) addressing schedules for activities, resources to be devoted to those activities, and other issues that ultimately will determine whether the panel's recommended methods and procedures are operationally fea- sible. FNS and states will need to provide technical assistance to school districts, including the AEO Calculator, a web-based tool or spreadsheet designed to perform all calculations proposed by the panel (described in further detail below). The AEO, like other special provisions for the school meals programs, would be offered as an option for districts. It would not be imposed uni- versally or on any particular district. Therefore, each district would have to make its own decision about whether to adopt the AEO. The decision a district makes and the effects of that decision will be independent of what other districts decide because the reimbursement of districts under the school meals programs is different from the allocation of funds under a program that has a fixed amount to allocate. In the latter case, one juris- diction's gain is another's loss, whereas in the school meals programs, one district's reimbursement does not affect that of any other district. To determine whether to adopt the AEO, a district would weigh the benefits and costs of this new special provision in its own socioeconomic and political context. For a school district to adopt the AEO, it must be confident that ACS- based claiming percentages will satisfy its own requirements for stabil- ity over time and for reimbursements large enough to cover costs when combined with other available funds. From a federal perspective, how- ever, reimbursements should not be excessive; to control total program costs, amounts should be consistent with eligibility and participation as established by law. The requirement that reimbursements be sufficient but not excessive implies, above all, that the estimated claiming percentages must be reasonably accurate for a district or subset of schools adopting the AEO. As described in more detail below, it will be important for FNS to monitor the accuracy of ACS eligibility estimates, the accuracy of administrative certification estimates, and the accuracy and stability of differences between ACS and administrative estimates. If FNS detects substantial changes, the causes and implications of such changes will need to be investigated.

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A PLAN FOR IMPLEMENTING THE AEO 159 Derivation and Provision of ACS Estimates at the School District Level Under the proposed AEO, FNS will arrange with the Census Bureau to provide annually for each school district in the country ACS direct estimates and the associated standard errors for the percentage of stu- dents in each eligibility category--free, reduced-price, and full-price-- prepared according to the panel's specifications (as updated based on fur- ther research). FNS should request that 1-year, 3-year, and 5-year school district-level estimates for all past ACS years, from 2005 through 2011, be made public in 2013, with new estimates being released annually there- after. Clear lines of communication and authority must be established among FNS, states, local authorities, and the Census Bureau if this new approach is to work effectively. Moreover, there are financial implications, probably for FNS, of commissioning a new set of services from the Census Bureau. The Census Bureau maintains up-to-date school district boundary information and already provides special tabulations of the ACS for school districts to NCES. The Census Bureau also provides estimates from its Small Area Income and Poverty Estimates (SAIPE) Program for all school districts included in its geographic database. Hence, it should be relatively straightforward for the Census Bureau to prepare estimates for school districts according to the panel's specifications.4 The AEO Calculator The panel envisions that FNS will provide the AEO Calculator, a web-based tool for districts to use in analyzing the feasibility of the AEO, calculating benchmarked ACS eligibility percentages, and calculating claiming percentages for use under the AEO. The AEO Calculator will enable separate analyses for the NSLP and the SBP, although bench- marked eligibility rates will be the same for both programs. Claiming percentages will be computed using the same eligibility percentages but program-specific participation data. The AEO Calculator also will enable districts currently operating under Provision 2 or 3 to determine whether it would be advantageous for them to switch to the AEO. The AEO Calcu- lator will make district-level ACS estimates available. Districts will need to enter their own certification and participation data, and the Calculator will guide them as to the data that are needed. Ideally, the Calculator will also be a useful tool for FNS and districts to use in communicating about 4Optimally, NCES and FNS would coordinate their tabulation requests, and both agencies would use the panel's specifications for eligibility estimates for school meals.

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160 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS the AEO. For example, a district might inform FNS through the Calculator that it was interested in participating in the AEO and provide FNS with all of the input and calculated output from the Calculator for approval and accountability purposes. District Assessment of ACS Estimates School districts will have to be comfortable with a decision to imple- ment the AEO because once a community has become accustomed to a universal free meals program with no application requirements, it will be difficult to retreat from that decision--a point made by the district officials participating in the panel's workshop based on their experience with Provision 2. To minimize financial uncertainty, districts must be able to envision new operating systems and accurately estimate changes in operating costs and participation.5 Many state and local financial systems do not appear to collect data at an appropriate level of detail to support the development of sound cost and savings estimates. Moreover, many districts appear to lack experience and expertise in large-scale systems change. These factors appear to make districts risk adverse and likely to persist in old ways of doing business. Since use of ACS estimates may be perceived as a more radical departure from the current application and certification processes than the existing special provisions, local hesitancy to adopt the AEO may be magnified. This possibility argues for outreach and technical assistance from the federal government. It also argues for a strong state agency role. Many districts reported to the panel that their state officials did not provide useful information or technical assistance regarding implementation of the existing special provisions. In some cases, states appeared to actively discourage their use. On the other hand, some states, such as Texas, have successfully promoted the use of special provisions and serve as a model in this regard. A district considering whether to implement the AEO would compare the impact of using the AEO relative to the current method. To this end, the district would enter multiple years of its own administrative data into the AEO Calculator. The AEO Calculator would produce benchmarked estimates--that is, estimates adjusted to reflect local circumstances, such as a large migrant population or other systematic differences between the ACS data and local administrative data. The district would assess the relationship among district administrative data, the ACS eligibility estimates, and ACS benchmarked estimates and determine whether the 5The panel found a paucity of consistent data on costs of administrative processes for school districts. Similarly, few data were available on the extent of changes in participation that result from providing free meals to all students.

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A PLAN FOR IMPLEMENTING THE AEO 161 ACS benchmarked estimates would satisfy its criteria for currency, accu- racy, and temporal stability if used to establish claiming percentages for reimbursement.6 If a district decided that the ACS benchmarked estimates were insuffi- ciently stable or too inaccurate, it might decide not to implement the AEO. If the district decided that the ACS benchmarked estimates appeared to be acceptable, it would apply to FNS or the state to initiate a base year for implementation of the AEO. After approval, the district could conduct a base year, providing free meals to all children but continuing to collect applications, conduct verifications, and count meals.7 During the base year, as in Provision 2, participation should increase as a result of mak- ing meals free to all students. These increases in participation would be accounted for in the AEO claiming percentages, although during the base year, reimbursements would be based on the traditional approach. The district would enter base-year data on certification percentages and par- ticipation by eligibility group into the AEO Calculator, which would have been updated by FNS with the latest ACS eligibility estimates. Bench- marked eligibility percentages, blended reimbursement rates (BRRs), and claiming percentages would then be produced. The district would verify that the benchmarked ACS BRRs were sufficiently stable and within an acceptable range for operating a universal free meals program. Should the district decide to go forward with the AEO, the bench- marking adjustments and participation rates derived during the base year would be used to produce updated benchmarked ACS eligibility estimates and claiming percentages in future years as new ACS data were released. After the initial base year, no additional base years would be required. Derivation and Release of ACS Estimates for School Attendance Areas Many districts have pockets of poverty within their borders. Thus an entire district may have less than 75 percent of students eligible for free or reduced-price meals, but selected schools within the district may have higher percentages of such students and may therefore be good candi- dates for a special provision whereby all meals are served free. The prob- lem in this situation is that less than districtwide implementation limits 6Districts should examine especially carefully the ACS estimates for 2010 and 2011 because they will reflect the effects of using the new ACS population controls based on the 2010 decennial census. If the calculated reimbursement rates for these years are substantially higher or lower than those for previous years, the district should consider waiting another year until 2012 ACS estimates are released, allowing the assessment of 3 years of reimburse- ment rates constructed from ACS estimates based on the new population controls. 7A district could conduct two base years if it did not yet have at least 3 years of consistent ACS and administrative data.

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192 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS Step 1: Calculate Benchmarked ACS Estimates For Provision 2 or 3 districts, the initial calculations in the benchmark- ing process are shown in Box 5-7. However, because these estimates are based on 4 years of ACS data, and there is no base year, the benchmarking adjustments are the final adjustments that will be used annually to update ACS estimates for use as claiming rates under the AEO. The benchmarking adjustments are different only in that they are based on the differences between the Provision 2 or 3 claiming percent- ages (rather than average certification percentages) and average ACS eligibility percentages. The benchmarking adjustments for a small district are shown in Box 5-7. For a medium district, the AEO Calculator will pro- duce two additional benchmarking adjustments: one for the 3-year esti- mates of the percentage of students eligible for free meals and one for the 3-year estimates of the percentage of students eligible for reduced-price BOX 5-7 Calculating ACS and Administrative Averages and Benchmarking Adjustments Provision 2 or 3 Districts Step 1a: Calculate averages of ACS estimates f SEk = the average percentage of students eligible for free meals, and r SEk = the average percentage of students eligible for reduced-price meals, where k = 1, 3, or 5, indicating whether the average pertains to 1-, 3-, or 5-year ACS estimates. Step 1b: Calculate benchmarking adjustments (illustrated for 5-year estimates) For a small district, there are two benchmarking adjustments: Bf5 = 100 Cp2/3 f - Ave SE5 f =b enchmarking adjustment for 5-year estimates of percentage of students eligible for free meals, and Br5 = 100 Crp2/3 - Ave SE5 r =b enchmarking adjustment for 5-year estimates of percentage of students eligible for reduced-price meals, f r where Cp2/3 and Cp2/3 are the claiming rates for free and reduced-price meals, respectively, under Provision 2 or 3. SOURCE: Prepared by the panel.

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A PLAN FOR IMPLEMENTING THE AEO 193 meals. For a large district, the AEO Calculator will produce two more benchmarking adjustments, which correspond to the 1-year estimates. The benchmarked ACS estimates shown in Box 5-8 reflect adjusted claiming percentages rather than eligibility percentages. For a small dis- trict, the AEO Calculator will produce eight such benchmarked estimates. The same approach will be used for benchmarking 3- and 1-year ACS estimates for medium and large districts. Box 5-9 illustrates the calculation of the BRRs based on the bench- marked ACS estimates for the past 4 years for a small district. In addition to the BRRs based on the benchmarked 5-year ACS estimates, a medium district will examine six BRRs based on the benchmarked 3-year esti- mates, and a large district will also examine eight BRRs based on the benchmarked 1-year estimates. BOX 5-8 Benchmarking of ACS Estimates Provision 2 or 3 Districts Step 1d: Calculate benchmarked ACS claiming percentages (illustrated for 5-year estimates) fB SC509 = SE509 f + Bf5 =benchmarked 2005-2009 estimate of the claiming percent- age for free meals, fB SC510 = SE510 f + Bf5 =benchmarked 2006-2010 estimate of the claiming percent- age for free meals, fB SC511 = SE511 f + Bf5 =benchmarked 2007-2011 estimate of the claiming percent- age for free meals, fB SC512 = SE512 f + Bf5 =benchmarked 2008-2012 estimate of the claiming percent- age for free meals, C509 = SE509 + B 5 = SrB r r benchmarked 2005-2009 estimate of the claiming percent- age for reduced-price meals, C510 = SE510 + B 5 = SrB r r benchmarked 2006-2010 estimate of the claiming percent- age for reduced-price meals, C511 = SE511 + B 5 = SrB r r benchmarked 2007-2011 estimate of the claiming percent- age for reduced-price meals, and C512 = SE512 + B 5 = SrB r r benchmarked 2008-2012 estimate of the claiming percent- age for reduced-price meals. SOURCE: Prepared by the panel.

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194 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS BOX 5-9 Calculating Blended Reimbursement Rates Based on Benchmarked ACS Claiming Percentages in Provision 2 or 3 Districts Step 1d: Calculate BRRs (illustrated with 5-year estimates) BRRC509 = [R0910f (SC509fB / 100) + R0910r (SC509rB / 100) + R0910p ((100 ­ SC509fB ­ SC509rB ) / 100)] = BRR based on the benchmarked 2005-2009 ACS claiming percentage, BRRC510 = [R1011f (SC510fB / 100) + R1011r (SC510rB / 100) + R1011p ((100 ­ SC510fB ­ SC510rB ) / 100)] = BRR based on the benchmarked 2006-2010 ACS claiming percentage, BRRC511 = [R1112f (SC511fB / 100) + R1112r (SC511rB / 100) + R1112p ((100 ­ SC511fB ­ SC511rB ) / 100)] = BRR based on the benchmarked 2007-2011 ACS claiming percentage, and BRRC512 = [R1213f (SC512fB / 100) + R1213r (SC512rB / 100) + R1213p ((100 ­ SC512fB ­ SC512rB ) / 100)] = BRR based on the benchmarked 2008-2012 ACS claiming percentage, where Rf, Rr, and Rp, respectively, are the district's per meal reimbursement rates for free, reduced-price and full-price meals (with subscripts referencing school years). SOURCE: Prepared by the panel. Step 2: Conduct an Assessment of the Use of Benchmarked ACS Estimates to Implement the AEO The district will examine the BRRs calculated in Step 1 to deter- mine whether they are sufficiently stable from year to year and within an acceptable range for operating the school meals programs. For this assessment, the AEO Calculator can multiply each BRR, which gives the average reimbursement per meal, by a recent monthly or annual figure for the total number of meals served to estimate the total reimbursement the district would have received based on the benchmarked ACS estimates. The district can also compare the BRRs based on benchmarked ACS esti- mates with BRRs based on the district's claiming percentages under Pro- vision 2 or 3, derived by the AEO Calculator using the BRR formulas in Box 5-9--the benchmarked ACS claiming percentages being replaced

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A PLAN FOR IMPLEMENTING THE AEO 195 by the Provision 2 or 3 claiming percentages. While small districts will examine the benchmarked 5-year estimates in their assessment, medium districts can also consider the benchmarked 3-year estimates, weighing the generally greater stability associated with 5-year estimates against the generally greater responsiveness to socioeconomic change associated with the 3-year estimates. Large districts can consider benchmarked 5- and 3-year estimates, as well as benchmarked 1-year estimates, which are generally the least stable but the most responsive to change. If a large district determines that the BRRs based on 1-year estimates fluctuate too much from year to year, it may find that the BRRs based on 3- or 5-year estimates are sufficiently stable. When conducting its assessment, a district should examine especially carefully the 1-year estimates for 2010, 2011, and 2012; the 3-year estimates for 2008-2010, 2009-2011, and 2010-2012; and the 5-year estimates for 2006- 2010, 2007-2011, and 2008-2012. These estimates will reflect the effects of using the new ACS population controls based on the 2010 decennial census. If the BRRs based on these estimates are substantially higher or lower than BRRs based on previous estimates, the district should con- sider waiting another year until the 2013, 2011-2013, and 2009-2013 ACS estimates are released, allowing the assessment of four BRRs constructed from benchmarked ACS estimates based on the new population controls. Step 3: Make a Decision About Adopting the AEO and Obtain Necessary Approvals Based on its assessment in Step 2, a district will decide whether to adopt the AEO. If a district concludes from its assessment that it will be financially viable to operate under the AEO using benchmarked ACS esti- mates and that BRRs are likely to be sufficiently stable, the district may want to adopt the AEO. If the BRRs fall outside an acceptable range or are excessively variable, the district can cease its consideration of the AEO or conduct further research to determine, for example, whether a different adjustment method would improve the estimates. A large district will have to determine whether it wishes to base its claiming rates on benchmarked 1-, 3-, or 5-year estimates, while a medium district will have to choose between benchmarked 3- and 5-year estimates as the basis for its claiming rates. If a district chooses to base its claiming rates on the k-year estimates, where k = 1, 3, or 5, its AEO claiming rates based on 2012 data will be calculated as shown in Box 5-10. These are the claiming rates that will be used during school year 2014-2015. To obtain approval for adopting the AEO, the district will have to comply with any regulations or other requirements imposed by FNS and state and local authorities.

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196 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS BOX 5-10 Calculation of AEO Claiming Rates for Use in 2014-2015 Provision 2 or 3 Districts C fAEO = ( SCk12 fB / 100 ) , CrAEO = ( SrB Ck12 / 100 ) , and AEO = 1 - C AEO - C AEO , Cp f r fB where SCk12 and SrB Ck12 are the benchmarked k-year estimates (k = 1, 3, or 5) from the most recent release of ACS estimates (assumed for this example to be the 2012, 2010-2012, or 2008-2012 estimates). SOURCE: Prepared by the panel. Step 4: Update Claiming Rates for Ongoing Operation of the AEO If a district's request for approval to adopt the AEO is granted, the district will update its claiming rates each year based on the most recently released ACS estimates as shown in Box 5-11. The benchmarking adjust- ments will be used indefinitely as long as the district operates under the AEO. The district will continuously assess whether the AEO is meeting the district's objectives. If it is not, the district can return to traditional operating procedures or Provision 2 or 3 at any time, subject to whatever conditions are specified by FNS or state or local authorities. Adjusting for Students Living in Nontraditional Housing19 As discussed in Chapter 4, one reason for discrepancies between ACS and administrative estimates is that the ACS estimates for school districts exclude students who do not live in traditional housing. However, home- less students and students living in migrant labor camps, for example, are likely known to school districts (which receive lists of such students), and they are categorically eligible for free meals. A school district that has a substantial number of such students and has data for at least 3 years should consider an adjustment to its ACS estimates. 19To adjust for seasonal fluctuations in the student population associated, for example, with the movement of migrant workers, districts can replace their October certification estimates with averages based on the entire school year.

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A PLAN FOR IMPLEMENTING THE AEO 197 BOX 5-11 Benchmarking Future ACS Estimates and Updating of AEO Claiming Rates Provision 2 or 3 Districts Assume that the district is using the k-year ACS estimates to establish claiming rates. Then the benchmarked ACS claiming percentages are fB SCkTT = SEkTT f + Bk f , and SCkTT = SEkTT + Bk , rB r r where TT is the last year in the reference period for the k-year estimates (e.g., f TT = 13 for the 5-year estimates for 2009-2013), and Bk and Brk are the bench- marking adjustments calculated in Step 1. AEO claiming rates are C fAEO = ( SCkTT fB / 100 ) , CrAEO = ( SrB CkTT / 100 ) , and AEO = 1 - C AEO - C AEO . Cp f r SOURCE: Prepared by the panel. In addition to certification rates and participation rates for at least 3 years, the district will need to have total enrollment (E) and the total number of students who live in nontraditional housing and are cate- gorically eligible for free meals (H) in each year. The adjustment will be applied to ACS eligibility estimates, before benchmarking, as illustrated in Box 5-12. The adjusted ACS estimates will then be used in all benchmark- ing equations instead of the unadjusted numbers. MONITORING BY FNS The accuracy of both ACS and administrative estimates may vary over time. ACS sample sizes may be cut. Continued improvements in direct certification may reduce certification error. Some changes in the quality of estimates may affect the accuracy and stability of AEO bench- marking adjustments for districts that are considering the AEO, as well as districts that have already adopted it. Thus, it is important that FNS track such changes, identify their causes, and assess their implications. These activities should be conducted for a broad sample of districts that are potential candidates for adopting the AEO but are not operating

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198 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS BOX 5-12 Adjustment of ACS Eligibility Percentages to Account for Students Who Live in Nontraditional Housing E = total enrollment, and H = total number of students who live in nontraditional housing and are categori- cally eligible for free meals. ACS eligibility estimates are adjusted as follows: f SEkTT (E - H) + H fA SEkYY = , E S r (E - H) rA SEkYY = EkTT , and E Sp (E - H) pA SEkYY = EkTT . E SOURCE: Prepared by the panel. under the AEO or any other special provision or option.20 Within this sample, separate analyses should be performed for high and very high FRPL districts (or for a more detailed categorization of districts) and for small, medium, and large districts. Because the districts in the sample are operating under traditional procedures, ACS eligibility estimates can be compared with administration certification estimates, as the panel has done in this report. FNS also should monitor the accuracy of ACS eligibility estimates for districts that have already adopted the AEO and are no longer certifying students. To facilitate such monitoring, the panel suggests that FNS allow districts that have adopted the AEO to continue working with state agen- cies to match district enrollment lists with lists of SNAP recipients, as is done for direct certification, and derive SNAP recipiency rates.21 Then, the relationships between these SNAP recipiency rates and ACS eligibility estimates can be analyzed to identify districts with substantial changes 20One limitation of this sample for learning about changes that might be affecting districts that have already adopted the AEO is that it will become more selective over time, consisting of proportionately more districts for which the AEO is not attractive. 21Temporary Assistance for Needy Families (TANF) and Food Distribution Program on Indian Reservations (FDPIR) lists can also be used if the district has previously used them for direct certification.

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A PLAN FOR IMPLEMENTING THE AEO 199 over time. Analyses can be conducted not only for the districts that have adopted the AEO but also for districts that are still potential candidates for doing so.22 SUMMARY The AEO may give school districts a new opportunity to provide free meals to all students. The AEO base year is essentially the same as a Pro- vision 2 base year. During this year, the district continues to take applica- tions, conduct verifications, and count meals served by category; however, all meals are served free. During the base year, the district is reimbursed based on meals served by category as in the traditional approach. The increase in participation due to offering free meals to all students can then be estimated and incorporated into claiming percentages. There are several key differences between the AEO and Provision 2. First, under the AEO, no additional base years are required because the ACS estimates released each year provide the means for updating claim- ing percentages in response to changing socioeconomic conditions. Even schools operating under Provision 2 or 3 may find the AEO attractive because it eliminates the requirement to conduct a base year every 4 years. Second, as just noted, districts need not rely on exactly the same claiming percentages every year under the AEO. Instead, with estimates provided annually by a highly credible and reliable source, the U.S. Census Bureau, districts can use the AEO Calculator to determine updated benchmarked eligibility percentages and claiming percentages that are then used in conjunction with the total number of meals served to determine monthly reimbursements. Third, if a school or district has high numbers of home- less students or migrant students living in nontraditional housing, the district also can adjust the ACS estimates to include those students. Adopting the AEO will not be burden-free for states and districts, although the tasks they will need to perform are completely different from those required by current administrative processes. If districts wish to implement the AEO for only a group of schools, for example, they must be able to provide accurate geographic boundary information on the attendance areas encompassed by that group of schools.23 Ideally, this information will be provided to the Census Bureau through FNS and will consist of a list of the census blocks that make up the school catchment areas of interest. Furthermore, a district may need to address limitations 22If a district is operating under the AEO in a subgroup of schools, the analysis can be conducted for that subgroup. 23Implementation districtwide will be easier in this regard because the Census Bureau maintains school district boundaries through its biennial School District Review Program.

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200 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS BOX 5-13 Other Uses of Data on Students Certified for Free and Reduced-Price Meals School meals program certification status is widely used to measure whether students are economically disadvantaged. One of the most significant uses is for Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA), as amended. Under ESEA section 1113, a local education agency (LEA) must rank its schools based on the percentage of economically disadvantaged students in each school to determine a school's eligibility for receiving Title I funds and to allocate funds to selected schools. To meet these requirements, an LEA must have school-level data on individual economically disadvantaged students. For many districts, in- formation from the National School Lunch Program is likely to be the best, and perhaps the only, source of data available to identify those students. Moreover, in the case of the priority for public school choice and eligibility for supplemental education services, the No Child Left Be- hind Act of 2001 (NCLB) specifically requires a district to use the same data it uses for making within-district Title I allocations: historically, most LEA's use school lunch data for that purpose.a In May 2011 the Department of Education issued guidance to state education officers on how to report the percentage of economically disadvantaged students and assess economic status for individual students under the new Community Eligibility Option (CEO). The guidance states that all students in a CEO school, just as in Provision 2 and 3 schools, are to be reported as economically disadvan- of the ACS. For example, the ACS does not represent all populations with equal accuracy. If a school or district has high numbers of homeless stu- dents or migrant students living in nontraditional housing, it will be in the district's interest to augment and refine its ACS estimates with supple- mentary information available at the local level. The accuracy of the ACS information also is affected by the degree to which open enrollment poli- cies, charter schools, and other school choice opportunities affect whether students attend schools outside their normal attendance areas. States and districts, perhaps in collaboration with FNS or other agencies, will need to determine whether such local attendance policies have an effect on the accuracy of ACS estimates and whether the proposed benchmarking pro- cedure corrects effectively for any errors. An individual district will also be able to monitor whether the number of students exercising the choice to leave the district is rising sharply. If the district has not yet adopted the AEO, certification data are available for use in comparing certification

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A PLAN FOR IMPLEMENTING THE AEO 201 taged for purposes of NCLB accountability reporting, implementing supplemental educational services, and identifying priority for school choice. When annually ascertaining the eligibility of a CEO school to receive Title I funding and determin- ing its Title I allocation, LEAs are instructed that the percentage of economically disadvantaged students is equal to the percentage of meals reimbursed at the free rate--that is, the product of the statutory multiplier specified in the Healthy, Hunger-Free Kids Act (initially 1.6) and the percentage of "identified" students in the school during either the base year or a more recent year (up to a maximum of 100 percent). Provision 2 and 3 schools use the number of free and reduced-price students identified in the base year divided by enrollment in that year. In our survey of Provision 2 and 3 districts (see Appendix E), the panel identi- fied other uses of free and reduced-price data in addition to Title I and NCLB. One commonly mentioned program is E-rate.b Districts also noted the need for individually identifiable data for grants and for waived and reduced textbook, activ- ity, and other fees for qualifying students. Typically, a family is asked to complete a waiver to allow sharing of individually identifiable eligibility information on free and reduced-price meal status (which otherwise is considered confidential) for purposes of obtaining waived and reduced fees and other benefits. aFrom Department of Education memorandum to State Education Officers from Commis- sioner of Education, Hanely, May 20, 2011. bThe Schools and Libraries Program of the Universal Service Fund, commonly known as E-Rate, is administered by the Universal Service Administrative Company under the direction of the Federal Communications Commission. It provides discounts to assist most schools and libraries in the United States in obtaining affordable telecommunications and Internet access. See http://www.universalservice.org/sl/about/overview-program.aspx. SOURCE: Prepared by the panel. percentages for students who have exercised choice opportunities and left the district with the certification percentages for students who have remained enrolled in district schools. If certification data are no longer available because the district has already adopted the AEO, the district will be able to match enrollment lists with SNAP records to derive SNAP recipiency rates, as described above. Then, the district will be able to compare SNAP recipiency rates for students who have left and those who remain. Such comparisons will reveal whether school choice opportunities are disproportionately attracting students from higher- or lower-income families and changing the composition of students who remain enrolled in the district in terms of their eligibility for free or reduced-price meals. 24 24The analyses described can be performed for the schools in which the AEO has been or might be adopted, rather than for the whole district.

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202 USING ACS DATA TO EXPAND ACCESS TO THE SCHOOL MEALS PROGRAMS The methodology proposed by the panel provides a district with esti- mates that it can use to fulfill other data requirements. Box 5-13 describes some of these uses. Benchmarked eligibility percentages, for example, can be used in place of aggregate certification percentages for purposes of ranking schools based on the percentages of economically disadvan- taged children. As with Provisions 2 and 3 and the Community Eligibility Option (CEO), for purposes of Title I reporting of progress of students toward meeting education goals by subgroup, all students attending an AEO school can be classified as economically disadvantaged. Other needs for data concerning the status of economically disadvantaged children can similarly be met with one of these two approaches.