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 percentage 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 provision 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 eligible 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 percentages greater than 75 percent, it also shows that there must be reasons why districts with smaller percentages of free- and reduced-price-eligible students 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

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1 Some of these districts are likely to be participating in Provision 2 or 3 already.



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