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Raising Your 2004, Year 8 E-rate Discounts
~ 2004-2005 National School Lunch Eligibility Guidelines Posted ~
Message Posted August 2, 2004

As you know, E-rate discounts are determined by two factors: whether your
district is located in a rural or urban county, and what percentage of your
students' families qualify for free or reduced lunches. If your school
doesn't participate in the NSLP program, or you feel that your NSLP
enrollment does not reflect the true poverty of the students in a particular
school, there are official mechanisms established by the FCC in which a
school can determine true eligibility, regardless of NSLP enrollment or
school participation in the program.

I encourage all schools to attempt to reach their true eligibility
percentage, rather than simply rely on enrollment figures. Some schools,
particularly high schools, have used surveys, sibling matches, or other
income-related programs to determine which students' families have income
guidelines that meet or exceed the NSLP thresholds -- with great success.
All of those methods are discussed below. Please note that if you use any
other information (surveys, etc) besides what is reported to PDE each
October, the SLD will ask you for additional information during your PIA
review. Normally, they request a copy of the survey, the number that were
mailed and number returned, and sometimes a statement from the principal,
food service director or superintendent requesting confirmation that the
survey was legitimate. It's not a high hurdle to leap, but be prepared for
it and keep careful records.

The 2004-2005 NSLP Income Guidelines have been released by US Department of
Agriculture and can be found at:
http://www.fns.usda.gov/cnd/governance/notices/iegs/IEGs04-05.pdf. Be
patient...sometimes it takes a while for this .pdf to appear.

The columns you should refer to are the Household Size, and the five columns
under Reduced Price Meals - 185%. The reason is because the income
requirements aren't as stringent for reduced price meals as they are for
free meals, so it is more advantageous to use the reduced meals income
levels. Also, be careful to just use the top of the chart, as the second
and third sections are for Alaska and Hawaii only.

CONDUCTING AN INCOME SURVEY
If you choose to do a survey, the following guidelines apply:

* The survey must be sent to all families whose children attend the school
(survey doesn't have to be sent to the whole district).

* The survey must attain a return rate of at least 50%. If a school has sent
a questionnaire to all of its families, and if it receives a return rate of
at least 50 percent of those questionnaires, it may use that data to project
the percentage of eligibility for E-rate purposes for all students in the
school. For example, a school with 100 students sent a questionnaire to the
100 homes of those students, and 75 of those families returned the
questionnaire. The school finds that the incomes of 25 of those 75 families
are at or below the IEG for NSLP. Consequently, 33 percent of the students
from those families are eligible for E-rate purposes. The school may then
project from that sample to conclude that 33 percent of the total
enrollment, or 33 of the 100 students in the school, are eligible for E-rate
purposes.

If a survey is sent, and the school does not receive a 50% return rate, but
finds additional students that are eligible for NSLP but aren't enrolled,
they can count those students in their discount calculation. For example,
if a school has 100 students, and 33 are enrolled in the NSLP, and the
school identifies an additional 10 students through a survey, they can now
say that 43 students are eligible for the NSLP.

* The survey must, at a minimum, contain the following information:
-- Address of family
-- Grade level of each child
-- Size of the family
-- Income level of the parents
The survey must assure confidentiality. (The names of the families are not
required.)

We've found the easiest way to construct the survey is to write a cover
letter explaining what the E-rate is, and the potential financial and
technological benefits the school will gain if a significant number of
surveys are returned. Then attach a second sheet containing the actual
survey. Instead of asking for the exact income of the family, it's easiest
to list the number of members of the family in one column, and then the
income guidelines for that family size. Then just ask them to circle the
number of people in their family, and indicate Yes or No as to whether their
income meets or exceeds that amount. If the answer is No, then all of the
students in that family can be counted as eligible for the NSLP.

Using volunteers to make calls encouraging families to return of surveys has
worked well in many districts.

FINDING ELIGIBLE STUDENTS THROUGH OTHER PROGRAMS
There are several other programs that have income guidelines that meet or
exceed the income eligibility guidelines for the National School Lunch
Program. If you know a student participates in one or more of the programs
listed below, you know that that family can be added to your NSLP
eligibility data set for E-rate purposes.
The programs are:
-- Medicaid
-- Food stamps
-- Supplementary Security Income (SSI)
-- Federal public housing assistance or Section 8 (a federal housing
assistance program administered by the Department of Housing and Urban
Development)
-- Low Income Home Energy Assistance Program
-- Participation in Temporary Assistance for Needy Families (TANF) is an
acceptable alternative measure of poverty ONLY IF the family income of
participants is at or below the IEG for NSLP.
Similarly, participation in need-based tuition assistance programs is
acceptable if the family income of participants is at or below the IEG for
NSLP.

USING EXISTING SOURCES
Schools may also use existing sources of data which measure levels of
poverty, such as surveys that may have been collected for other programs,
such as need-based tuition assistance programs. However, these measures are
acceptable for E-rate purposes only if the family income of participants is
at or below the IEG for NSLP.

CONDUCTING A SIBLING MATCH
The siblings of a student in a school that has established that the student’
s family income is at or below the IEG for NSLP may also be counted as
eligible for E-rate purposes by the respective schools the siblings attend.
For example, an elementary school has established, through a survey, that a
student’s family income is at or below the IEG for NSLP. That student 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 E-rate purposes, without collecting its own data on
that family.

UNACCEPTABLE ALTERNATIVE DISCOUNT MECHANISMS
The following alternative measures of poverty are NOT acceptable for
determining E-rate discounts. They rely on projections rather than on the
collection of actual data:

* Feeder school method. This method projects the number of low-income
students in a middle or high school based on the average poverty rate of the
elementary school(s) which "feeds" students to the middle or high school.
Sibling matches, however, are OK.

* Proportional method. This method projects the number of low-income
students in a school using an estimate of local poverty.

* Extrapolation from non-random samples. This method uses a non-random
sample of students chosen to derive the percentage of poverty in a school,
such as those families personally know by the principal ("Principal’s
method") or the families of students who apply for financial aid (a
non-random sample).

* Title 1 eligibility. This method uses eligibility for Title 1 funds as the
criterion for estimating the level of poverty in a particular school. Some
measures of poverty eligible under Title 1 are indirect estimates of
poverty, and do not necessarily equate to the measure of poverty for E-rate,
namely eligibility for NSLP.

As always, if you have any questions about conducting a survey or raising
your E-rate discounts please contact me at jtschell@comcast.net.

Julie Tritt Schell
jtschell@comcast.net

(717) 730.7133 (voice)
(717) 730.9060 (fax)

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