Any school, group of schools, or school district which has 40 percent or more of students receiving a free or reduced-price lunch based on their status as an "identified student" qualified to receive benefits is eligible for the community free lunch program. Note the phrase "identified student." It's important.
A student who provides the school district with evidence that his family receives SNAP, or that he is a foster child, or that he meets a number of other qualifications is considered an "identified student" eligible for free lunch with no further application or qualification. Other students qualify through a written application. My understanding is that the overwhelming majority of free-reduced lunch participants qualify through the "identified student" provisions.
Participation in the following programs or students in these categories qualify as "identified students":
• Supplemental Nutrition Assistance Program (SNAP);
• Temporary Assistance to Needy Families (TANF);
• Food Distribution Program on Indian Reservations (FDPIR); and
• Medicaid (in States and LEAs participating in an FNS demonstration project to test the potential for direct certification with Medicaid). The term identified students would also include the following students, as defined in § 245.2:
• Homeless children as defined under section 725(2) of the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11434a(2));
• Runaway and homeless youth served by programs established under the Runaway and Homeless Youth Act (42 U.S.C. 5701);
• Migrant children as defined under section 1309 of the Elementary and Secondary Education Act of 1965 (20 U.S.C. 6399);
• Foster children certified through means other than a household application;
• Children enrolled in a Federally- funded Head Start Program or a comparable State funded Head Start Program or pre-kindergarten program;
• Children enrolled in an Even Start Program; and
• Non-applicant students approved by local education officials, such as a principal, based on available information.
Students not qualifying for free-reduced lunch under the above can still qualify using a paper application. However, these students are not to be treated as "identified students" in determining Community Eligibility.
The great unknown is how many subsidized-lunch students qualify automatically and how many qualify through application. And are there any who could have qualified automatically who submitted an application? If so, these recipients won't be counted as they should be.
Currently the Oxford School District has about 50 percent of its students on the free or reduced program, with the lowest participation being the high school with 39 percent and the highest Bramlett Elementary with 58 percent. Many high school students don't sign up for the program just because they are afraid other students will find out.
How the program works
Based on my reading, here's how the program works.
To participate, a school must have at least 40 percent "identified students," and wish to participate. Participating schools must agree to feed all students both breakfast and lunch at no cost.
Participating schools are paid the full free-lunch or breakfast price for 1.6 times the number of "identified students." So if Oxford were to come in just under the wire at 41 percent the program would provide full reimbursement for 65.6 percent of all lunches served. The remaining meals would be reimbursed at the paid level of about 35 cents per paid lunch served.
I would guess that Oxford currently receives a high reimbursement rate, in part because so many kids who aren't on the free lunch program bring their own from home. Thus it is likely that even though only about 50 percent of the students are eligible for free or reduced lunch, this group likely accounts for more than 60 percent of meals served, which gives the school a higher reimbursement rate.
I'm not going to get into the math of reimbursements, because it's a complex process with lots of variables. If eligible for the community program, Oxford is likely to be reimbursed about $2.10 for each lunch served, which is less than it currently receives through the current combination of government and private payment. I would make a wild guess that Lafayette could get a $2.30-$2.40 reimbursement, and Marshall County and Panola County can feed everyone and receive around $3.01 for every lunch served.
It should be noted that individual schools within each of these school districts could have a higher reimbursement rate; not every school has to participate. So a single school with a higher free-lunch rate might find it beneficial to provide free lunch to all under this program while other schools remain out of the program.
As I said, this is a good program for a lot of reasons. Among them is the fact that many students, particularly high school students, are eligible but don't sign up. And I happen to believe that there is a benefit to treating every student the same: If one gets a free lunch, all should get a free lunch.
Steps every school district should take right now
There is a June 30 deadline for eligible schools to sign up to participate in this program. Eligibility is determined by the percentages in place on April 1. I don't know if it's possible to go back and massage the April 1 numbers; I suspect that many school districts have not been diligent about getting all eligible students enrolled in the free-lunch program.1. Every school and school district should examine their free lunch numbers to see if they are near the 40 percent threshold. In the end some choices may have to be made concerning the grouping of schools, or making the program available to one school, but not all.
2. If a school or district is anywhere close to qualifying, it should do a sibling check, to make sure that one child from a household isn't receiving benefits while another isn't. Once one child is qualified all are qualified, even if one child doesn't return his form. This should be done already, but the possibility exists that a few might slip through the cracks.
3. Schools should audit those students in the free lunch program by application to make sure none were eligible for automatic enrollment, which would make them "identified students."
I'm not a big fan of massive government programs, but the free lunch program is about as effective as they come, even if some of the food the schools are required to serve isn't very tasty. But that's a battle for another day.
I will say that after looking at the numbers, the program really doesn't work for Oxford as a whole. It might work for Bramlett, which has a slightly higher subsidized-lunch rate. For the Lafayette County Schools the numbers work out a little better, but it will still cost the district money to provide every student with a free lunch; however there is a real benefit in providing each child with free meals, and the cost could well be worth it. For Panola County, Water Valley, Holly Springs, and Marshall County it's a no-brainer. It seems to me that these schools can provide a free lunch to every student at virtually no cost, and a failure to do so is educational malpractice.
On a statewide level, 71 percent of all students are on the free or reduced lunch program. Clearly most schools will be eligible to feed all students for free, if only the schools make the proper applications.
For many districts this program doesn't offer a "free lunch." In Oxford, for example, a large percentage of students bring their own lunch to school and are likely to continue to do so even if offered a free school lunch. For a school with this student dynamic to participate could be a financial disaster; Oxford would likely end up getting less money for each lunch served while serving few additional students.
But for most Mississippi schools this program is a godsend. I hope these school districts will take advantage of the opportunity to feed all of their students for free.
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