CEP Implementation Training for Food Service Directors SY 14-15

1. CEP Implementation Training for Food Service DirectorsSY 14-15 Kentucky Department of Education Division of School and Community Nutrition

2. Today’s Training • Recent Survey • Overview of CEP Concepts and Cycle • Review of KDE’s CEP Eligibility Criteria • Notification and Intent to Participate • CEP Pre-Operational and “Starting Up” Requirements • District Responsibilities • Claims and Reimbursement

3. Current CEP Survey Data 69 CEP sponsors with 377 feeding sites participating in SY 13-14 • 37 Sponsors responded to the March, 2014 survey. Survey Findings • 67.5% experienced an increase of 6% or higher for breakfast and 56.7% experienced an increase of 6% or higher for lunch. • 78.4% of the sponsors experienced an increase in the percentage of Direct Certification from their “Year Prior First Year” data since implementing CEP. • 78.4% reported that they have not modified their CEP groupings after their first year of CEP participation. • 81.1% reported that they have not had to use a la carte or contract sales to offset any losses.

4. Overview of CEP Concepts and Cycle

5. Overview of CEP Concepts • Benefit Issuance Document – April 1st Roster • Identified Student Percentage – DC student count divided by total enrollment • Edit Checks – Based on enrollment, not eligibility • FRAM Coordinator – Processes HIF forms • “Grouping”-adding DC and enrollment of different sites to qualify • “Mixed” District – where only some of the schools are on CEP and others are not • “Full CEP” – where all schools in the district participate in CEP • YPFY - Year Prior to the 1st Year (April data – guaranteed %)

6. CEP Cycle • The CEP program is on a 4 year cycle • If after the first year, you decide not to continue with the CEP, you do not reapply • Those who continue with CEP, the claiming percentage will be based on the higher of the YPFY data or the prior year April data (most current) • If you change groupings in the next school year, the cycle re-sets • You do not change claiming percentages month to month, but you still process DC

7. CEP Cycle, cont. Example of a cycle: You will never receive less than your YPFY percentage.

8. Kentucky’s CEP Eligibility Criteria • LEA reports April DC data per SCN data collection and reporting requirements. Deadline for reporting: April 15th • Schools would be required to have a minimum percentage (40%) of identified students, who are students certified for free meals through means to other than individual household applications (e.g., students directly certified through the SNAP, KTAP, Medicaid, and Foster Child monthly downloads) in the school year prior to implementing the CEP provision. • Participate in both SBP and NSLP and serve free lunches and breakfasts to all students.

9. Pre-Implementation Steps • Eligible LEA would notify SCN of intent to participate with CEP on behalf of single school, select group, or district wide by May 15th. Notify: Valerie Crouch, valerie.crouch@education.ky.govA consultant will be assigned to the district to assist with the application and approval process. • Please notify SCN by June 30th of each year of your intent to continue (or stop) participation in your application and agreement in CNIPS.

10. Pre-Implementation Steps 2. Submit documentation of School Board approval. (form provided) This documentation would confirm School Board approval and that the following would be implemented: • Cover with non-Federal funds any costs of providing free meals to all students that exceed the Federal reimbursement. • No household applications for free and reduced price meals would be collected because meal reimbursement would be based on claiming percentages derived from the identified student percentage. • IF LEA determines that it is necessary to collect socio-economic data to assist with the disbursement of other education-related funds, a FRAM coordinator would be appointed and such application process would be developed and managed totally separate from the School Nutrition Program, and not under the auspices of the National School Lunch Program. It is expected that the form/request for household information for non-Program purposes would clarify its purpose, and affirmatively state that receipt of school meal benefits would not be affected by a household’s decision to complete and return the form/request. Office of District Supports provides a form: http://education.ky.gov/districts/SHS/Pages/Community-Eligibility-Option-(CEO).aspx

11. Pre-Implementation Steps, cont. 3. LEA is required to update district’s NSLP Policy Statement and attachments, i.e., Meal Counting and Claiming. The meal counting and claiming procedures must identify any alternative point of service system, must clearly demonstrate that accurate meal counting practices are instituted, provide a description of the procedures that will be used to ensure that there are no second meals counted for reimbursement, provide a description of the internal controls that will be employed to monitor for problems in the meal counting system and provide a copy of any forms that will be used. 4. Submit updates to Policy Statement, complete Sponsor and Site Applications along with CEP Group Schedule in CNIPS and seek approval prior to implementation of Community Eligibility Provision prior to start of program year.

12. Pre-Implementation Steps, cont. 5. LEA must provide and maintain documentation of training on the meal counting and claiming procedures, required USDA civil rights training, and applicable HACCP procedures with all applicable staff. LEA needs to notify SCN of intent to participate with CEP by May 15th. While the decision to participate in CEP rests with the LEA, SCN is required to confirm the LEA’s eligibility and that the criterion has been met.

13. District’s Intent to Participate

14. Sponsor and Site Application • Mark CEP for each of these questions on the 2014-2015 sponsor application packet • Sponsor application • Site application • Lunch • Breakfast

15. Grouping Sites • Place CEP sites into groups for the following reasons: • CEP participation – allow an ineligible site to participate by grouping it with an eligible site • Sites >100% claiming percentage – if the claiming percentage (i.e., DC percentage X 1.6 multiplier) is greater than 100%, then group this site with another site (but be sure to look at the enrollment first) • District-wide Participation: place all sites under “Group 1” if you plan to have all sites in CEP.

16. Grouping Sites • No rules exist for grouping sites • Any school can be grouped with another but the resulting DC percentage must be 40% or greater for all grouped sites • Except for sites with >100% claiming reimbursement you will not obtain higher reimbursement for grouping sites versus not grouping them

17. Grouping Sites in CNIPS • Sponsors can visit the CNIPS training site and work with the CEP Group Schedule prior to completing in SY’s application and agreement. However, current April DC data would need updated to reflect SY 14/15. • CNIPS Training Site: https://cnipstest.education.ky.gov/training/Splash.aspx • Use same CNIPS ID and password • Call Brad to have password reset

18. Meal Counting and Claiming Policy and Procedures SCN has posted guidance on drafting Meal Counting and Claiming Policy and Procedures for CEP districts. Key Components: • Daily counts of the total number of lunches and breakfasts is required. No longer will need to track meals by Free, Reduced, and Paid categories. Edit checks to be completed daily that monitor total meals, average attendance factor, and enrollment. • SCN has developed a CEP meal count edit check form, should your POS not speak to the above criteria. Posted on SCN website. • Alternative POS identified and procedures outlined. The use of a tally sheet is only approved for breakfast meal service. Example of tally sheet can be found on SCN website.

19. CEP Implementation Requirements • Letter to Household (Optional) • Media Release • Internal Controls • Data Synchronization/DC Import • District Responsibilities

20. Letter to Households Household applications are not distributed to households of children in CEP participating schools. If you have any schools that are not participating in CEP, you are required to provide the traditional letter to households, household application and instructions to each of those households and certify applications as usual at those non-CEP sites. Letter to Household (Optional) USDA requires that CEP schools provide a notification of their participation in CEP, but USDA has also confirmed that the Media Release meets that requirement. If you wish to send home letters to the household about the program, you may do so. A sample letter to households for CEP schools is available on our website at: http://education.ky.gov/federal/SCN/Pages/Community-Eligibility-Option.aspx

21. CEP Media Releasehttp://education.ky.gov/federal/SCN/Pages/Community-Eligibility-Option.aspx • [Sponsor Name] • FOR IMMEDIATE RELEASE • [NAME OF SPONSOR] today announced an amendment to its policy for serving meals to students under the [National School Lunch / School Breakfast Programs] for the 2014-15 school year. All students will be served [lunch/breakfast] at no charge at the following sites: • [You may either list sites here or insert a chart of sites] • For additional information please contact: [Name of Sponsorship], Attention: [Name, Title], [Department/Division], [Address], [City, State ZIP], [Telephone Number], [E-mail Address]. • In accordance with Federal Law and U.S. Department of Agriculture policy, this institution is prohibited from discriminating on the basis of race, color, national origin, sex, age, or disability. • To file a complaint of discrimination, write USDA, Director, Office of Adjudication, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410 or call toll free (866) 632-9992 (Voice).  Individuals who are hearing impaired or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339; or (800) 845-6136 (Spanish). USDA is an equal opportunity provider and employer.

22. Internal Controls • Point of Service – No change in service procedures; Children should go through the line and be counted using a POS system or roster. • Tally Sheets are permitted for use only at Breakfast meal service. • Back-up rosters for system failures are still required.

23. Internal Controls, cont. Point of Service • Meal prices should be set at $0.00 for meals served at CEP schools. • The child’s eligibility status is not considered because percentages are applied to total meal counts for the claim. • Mixed districts may have issues with IC and their POS communications. You will need to work closely with your IT department to ensure systems are in synch.

24. Internal Controls, cont. • Sponsor must still conduct a review of the school’s Meal Counting and Claiming Procedure (On Site Review) by February 1 of each year. • Edit Checks must be completed daily to compare the number of meals served to the attendance adjusted enrollment. You can ask your POS provider to reset the “Edit Check Report” in your POS system to include only free and paid students (recommended)

25. Data Synchronization • Action Item Data synchronization must be adjusted depending on your CEP type Mixed CEP Districts All CEP Districts

26. DC Import Best practice: Import the DC file into both POS and Infinite Campus Advantage: DC can be extended to other students in the household in IC Step-by-step instructions are on the KDE SCN DC Download website -- in the help manual

27. District’s Implementation Responsibilities

28. Collecting SES Data FRAM Coordinators • Traditionally, other programs have obtained socioeconomic data from the NSLP for the purposes of funding and the waiving of student fees. • With the implementation of the CEP, those programs will no longer be able to obtain that information, and a new procedure is needed.

29. Collecting SES Data FRAM Coordinators • Under the KDE initiative, each district operating the CEP must appoint a FRAM Coordinator to obtain the socioeconomic status for students attending CEP schools using household income forms (HIFs). • No employee of Food Service (including part-time) may be appointed as the FRAM Coordinator.

30. Collecting SES Data Refer to FRAM and FSD workflow charts. What you can do… You may: • Process and upload DC into FRAM. • Process a NSLP application for a household that indicates both CEP and non-CEP students and extend eligibility to all household members. • Accept HIFs from FRAM Coordinators that indicate a non-DC student as homeless, migrant, or runaway (as these require investigation and could possibly be a missed DC). • Accept referrals from the FRAM Coordinator about potentially eligible participants of non-CEP schools for the NSLP.

31. HIF Form in Brief • KDE developed the household and income form (HIF) to collect socioeconomic status on students in CEP schools • Necessary for state and federal reporting purposes and to determine eligibility for educational benefits (e.g., FRYSC) • Very similar in design to NSLP household application

32. HIF Distribution • As a state developed form the HIF can be distributed prior to July 1 in the student registration packets • Prototype HIF on KDE’s CEP website: http://education.ky.gov/districts/shs/pages/community-eligibility-option-(ceo).aspx • Tips: • Use colored paper to differentiate HIF form vs. NLSP household application • Process HIF forms after July DC data has been imported and preferably after August DC data has been imported

33. HIF Data Processing Estimate Estimate of HIF form data processing time: Total student households Less DC households Less overtly paid students (default is paid) Less mixed households (mixed CEP only)* *Mixed households include CEP and non-CEP siblings; if the household completes an NSLP application then this can be shared with FRAM Coordinator

34. Food Service Director HIF Processing Responsibilities FRAM Coordinator

35. HIF Processing • A FRAM Coordinator must be appointed in the district to process HIF forms • Paid out of general revenue funds • Must not be the food service director or food service staff • HIF forms will be processed using Household Eligibility tool in IC or equivalent for non-public sponsors. • Students are assigned free, reduced, or paid meal status • Training will be provided to FRAM Coordinators by KDE’s District Support Services • FRAM Coordinator Resources: http://education.ky.gov/districts/shs/pages/community-eligibility-option-(ceo).aspx

36. FRAM Coordinator Training Division of District Support Services will train all FRAM Coordinators. Training dates June 26, 2014 GRECC Headquarters, Bowling Green, KY 9 am – 12 pm June 27, 2014 KDE Training Room, Capital Plaza Tower, Frankfort, KY 9 am – 12 pm June 30, 2014 KY Career Center, 412 Roy Campbell Drive, Hazard, KY 9 am – 12 pm For Registration information, contact: Cheri Meadows, Division of District Support, cheri.meadows@education.ky.gov Division of District Support Service’s CEP website: http://education.ky.gov/districts/SHS/Pages/Community-Eligibility-Option-%28CEO%29.aspx

37. Claims and Reimbursement The identified student percentage is used to determine reimbursements for both breakfast and lunch. This percentage multiplied by 1.6 is the free claiming percentage. The free claiming percentage is applied to the total number of breakfasts and the total number of lunches served to determine how many breakfasts and lunches are claimed at the free rate. The remaining meals are reimbursed at the paid rate.

38. Claims and Reimbursement • Monthly claims must be submitted for each site through CNIPS claims system. • CEP sites will only need to enter the total number of reimbursable meals served. The CNIPS system will apply your approved claiming percentages to that total number of meals to determine how many free and how many paid meals will be reimbursed. • Complete all site claims and submit as usual.

39. Questions and Answers • Questions regarding this web-ex can be submitted to the following email address: kyschoolnutrition@education.ky.gov Programmatic Delivery Section Consultants will respond and address all questions. Questions and answers will then be posted: http://education.ky.gov/federal/SCN/Pages/Community-Eligibility-Option.aspx

40. Have a Great Day! Valerie Crouch, SNS Administrative Section Supervisor Programmatic Delivery Section School and Community Nutrition Kentucky Department of Education 502 564-5625, ext. 4912 Programmatic Delivery Section Members: Jenny Fuller, ext. 4924 Katie Embree-Cleveland, ext. 4915 Jennifer Langfels, ext. 4939