Begin work on your student eligibility data as soon as school starts. It will not be needed until the filing of Form 471 in November or December, but it is time consuming. Student eligibility data may be obtained by using one of three measures:
- National School Lunch Program questionnaire
- Apply to the Department of Agriculture for Provision 1, 2, or 3 measures
- A survey of your own design that meets the criteria outlined below
Once you have determined which students in your school(s) meet the income eligibility guidelines for free or reduced lunch, you will use those numbers to determine your E-Rate discount. To determine the discount for a facility that has classrooms and a fixed student population, divide the number of students eligible for NSLP at the school by the total number of students at the school. Use this number and the urban or rural status of the school to look up the discount on the USAC discount matrix. If a site has a student population that varies from day-to-day or over time, use a “snapshot” of the student population. To determine a snapshot, choose a particular day and calculate the percentage of the student population in the classroom that is NSLP eligible and take that percentage to the discount matrix. Be sure to maintain documentation of your calculation.
In general, the discount for a non-instructional school facility is the Weighted Average Discount of the school district in which it is located.
This discount calculation will be needed when filling out Block 4 of your Form 471. You will need a discount calculation for each building you are applying for funding for.
NSLP Data Collection
Remember that your district is entitled to count eligible students, not merely the NSLP enrolled students. You may report higher numbers if you can justify them. Send your explanation of higher numbers in with your Item 21 attachment for your Form 471.
Ways to Increase Your Count of Eligible Students
- Sibling match: Increase your discount percentage by identifying eligible students at high and middle schools. Older students are reluctant to enroll in the National School Lunch Program resulting in an undercount. Identify them by matching participating siblings, usually elementary students, using addresses or phone numbers as well as family names. Keep the documentation of your matching system with your records.
- Participation in other federal programs: An eligibility list of students who qualify for Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Low Income Home Energy Assistance Program (LIHEAP), Migrant Education Program (MEP), Medicaid, food stamps, or tuition assistance is sent to each district with a school lunch program. These students also qualify and may be counted as eligible without any further paperwork. A Categorical Eligibility List of homeless, migrant, and runaway children also provides more names for your qualified list. Check that the children on these lists are not already included in your NSLP forms, as they can not be counted twice.
- Students who are in foster care as well as those who are wards of the state are eligible.
The district is entitled to combine numbers gathered by any of the above methods so long as no one student is double counted.
When NSLP data is either not available or does not give an accurate picture of school/community income, the most common way of determining student eligibility is the income survey. Information about income may be part of another collection of facts already gathered, such as scholarship applications or other forms used in schools, or it may be specifically collected for E-Rate purposes by using a survey. A school or district may not use the NSLP form as their survey. There are specific rules about using survey data that can help to increase the numbers gathered.
Surveys developed by an applicant must be based on the following guidelines:
- The survey must be sent to all families whose children attend the school
- The survey must, at a minimum, contain the following information:
- Name of family and students
- Size of the family
- Income level of the family
Income data (or eligibility data based on income) from a survey used to support a discount level for a funding request cannot be older than two years before the start of the funding year. For example, the data gathered from an income survey done in September 2007 can be used for funding requests for Funding Year 2008 and Funding Year 2009, but not for Funding Year 2010. Therefore, surveys must be done at least every other year. You should maintain a record of the data collected to assist in responding to PIA inquiries. Such records should be maintained for a period of five years after the last day of delivery of the discounted services.
Income data should be collected based on income received by the household during the month before the month in which the survey is conducted. However, a household can project its annual rate of income for the current year based on the income data that is available.
Information on the definition of income under NSLP, other income guidelines of the program, and the school meals eligibility manual can be obtained from the National School Lunch Program website.
Gathering Survey Data
Surveys are sent to households, not individual students. If a school has sent a survey to the households of all of its students and receives a return rate of at least 50%, it may use that data to project the percentage of eligibility of all students in the school.
For example, a school with 100 students sent a survey to the 100 households of those students, and 75 of those households returned the questionnaire. The school finds that the incomes of 25 of those 75 households are at or below the income eligibility guidelines for NSLP. Consequently, 33% (25/75) of the students from those households can be counted as eligible for NSLP. The school may then project/extrapolate from that sample to conclude that 33 percent of the total enrollment, or 33 of the 100 students in the school, can be counted as eligible for NSLP.
If 100% of households are not surveyed, or if less than 50% of households return your questionnaire, you may not project/extrapolate your eligibility. However, you may still use the returned forms as “questionnaires” to count the individual students listed on them.
Other Acceptable Mechanisms for Collecting Data
Collecting Data from Existing Sources
Schools may also use existing sources of data that measure levels of poverty, such as TANF or need-based tuition assistance programs. However, these measures are acceptable for E-Rate purposes only if the income eligibility guidelines are equal to or below the income eligibility guidelines for NSLP.
If a school has established that the household income of one of its students is at or below the IEGs for NSLP, the siblings of that student may also be counted as eligible for NSLP. For example, an elementary school has established, through a survey, that a student’s household income is at or below the IEGs for NSLP. That student’s household also has a brother and a sister who attend the local high school. The high school may use the status of the elementary school sibling to count his high school siblings as eligible for NSLP, without collecting its own data on that household.
Combining Data from Different Sources
Unless a school is able to use a projection based on a survey as described above, data used to support a particular discount level must be collected and verifiable on an individual student basis. However, data from multiple sources can be combined to complete the count of students eligible for NSLP.
For example, a school with 100 students sent a survey to the 100 households of these students, and 40 of those households returned the survey. The school finds the income of 20 of those 40 households, each of which has one student in the school, are at or below the income eligibility guidelines for NSLP. This rate of return (40%) is too low to allow a projection based on that survey. However, the school has also matched 10 students not represented in the survey responses with siblings who are eligible for NSLP, and the school has verified that 15 additional students not represented in the survey responses participate in a need-based tuition assistance program that requires the household income of participants to be below the income eligibility guidelines for NSLP. The school can combine the individual results from these three sources to conclude that 45% of the total enrollment, or 45 (20 + 10 + 15) of the 100 students in the school, are eligible for NSLP. The school must be able to verify that it has counted each eligible student only once.
Students from families that meet an income test based on the same income levels used in the National School Lunch Program may be included in your count of eligible students. A chart of income levels and family sizes for the next school year may be obtained at the National School Lunch Program website.
You may not use NSLP forms as survey instruments, nor should you attach your survey to distributed NSLP forms.
Organize your survey to collect information on entire families rather than students. Send a single survey to each family (or if it is more convenient to send surveys home with students, prepare to consolidate the returns back into family units. You must be able to identify specific children rather than anonymous groups in your records, though student names will be held in the strictest of confidence.
Surveys must be kept confidential and families should be assured that they will be held so, but they must be retained for 5 years (beyond the last date of service) to support any audit that may be done. It is more than likely that the Schools and Libraries Division will ask for a copy of the instrument you use for the survey and for a signed letter from a district authority attesting to the correctness of the results summary.
In actual data gathering, surveys included as part of another data collection effort seem to get the most results. Consider including surveys in school year registration procedures, in family back to school activities, or sent home along with federal impact cards.
If sending forms to 100% of families has not resulted in sufficient return, increase survey response numbers by choosing (or creating) an event that will bring a large number of parents to the school and have the superintendent or other administrator do a personal plea explaining why it is so important that these surveys be done. Hand out forms as people come in and collect them at the door before people leave. Ask your PTA officers to call a non-responsive household and make a personal plea for the return of the form. If you explain the money involved and compare it to the average fund raiser, perhaps your PTA will think of other ways to get surveys back. Sample surveys can be adapted to your own uses. Be sure to use the chart at the National School Lunch Program website to update the income guideline numbers on your form each year.
Miscellaneous Issues on Discounts
If you are using NSLP data to determine your discount, the SLD will have access to any school lunch numbers you have submitted. They will question any rise in these numbers, but will accept any additional numbers of eligible students, provided you can justify them with records of the above activities. Maintain these records for five years.
Discounts may be affected (either adversely or favorably) by whether a school district is considered to be a single or multiple site district. Those districts that may be able to make a choice of definition based on the number of programs housed in a single building or on a single campus should look at their discount numbers under both scenarios. Consult with E-Rate coordinator David Skogen about the classification of your district.
If you are building a new school, in order to receive funding for services received there during the construction year (e.g., internal connections, such as wiring and its installation) you may use the weighted district average as the school’s individual discount, since you do not have students assigned to the building yet to form its own count.
Send in an explanation for any numbers which vary as a part of Item 21 packet.
Building a Paper Trail
You need to retain these documents for eight years in case of an audit or review:
- NSLP data used to determine your discount calculations
- Any “snapshot” data used to determine eligibility of a facility
- Any survey used if NSLP data was not available or employed
- All surveys collected from households
- A spreadsheet containing students and their reason for eligibility if you augmented your NSLP and/or survey numbers with additional means of counting