Impact of the Community Eligibility Provision (CEP) Program on E-rate Discount Calculations

April 30, 2014

Recently, Acting Secretary of Education, Carolyn Dumaresq sent a letter to all Pennsylvania superintendents and school administrators, explaining the benefits for schools choosing to opt into the Community Eligibility Provision (CEP) as an alternative to collecting annual NSLP forms. A copy of that letter and other CEP-related information can be found at: www.education.state.pa.us/cep. As you know, the E-rate program currently uses NSLP eligibility, or a federally approved alternative mechanism, as a measure of poverty when calculating discounts on services received under the E-rate program. Thus, schools are currently required to determine income eligibility from each family whose student attends the school in order to determine a school’s poverty level. The CEP program provides a new alternative to NSLP household applications for free and reduced price meals in high poverty local educational agencies as it does not require schools participating in CEP to obtain individual income eligibility applications from each student. Instead, it derives estimates of the NSLP eligible population from existing data from other income-based programs.

The FCC has provided formal guidance to USAC stating that E-rate rules do not yet permit the use of the CEP estimated NSLP eligibility data (presumably because it contains a 1.6 multiplier) and instead participating schools must use the NSLP eligibility data from the most recent year prior to opting into CEP. For example, if a school opts into CEP for the 2014 school year, the FY 2015 E-rate application would use the NSLP eligibility data from FY 2014 (which is based on the October 2013 data submitted to PDE).

Under CEP, LEAs do have the option of selecting only a subset of their schools to participate in CEP. In those cases, for the District’s FY 2015 E-rate application, the schools that opt into CEP would use the October 2013 PDE data, and the schools that have not opted into CEP would use the October 2014 data.

It is our understanding that when the PDE NSLP data is released in January 2015, it will show the CEP schools’ data using the 1.6 multiplier which cannot be used for E-rate discount calculation purposes. It is my intention to either provide a separate spreadsheet of the entities that have opted into CEP and what NSLP/enrollment data they should be using for their E-rate application, or, if time permits, integrate that data directly into the PDE NSLP file. Either way, we will try to make this as easy as possible for not only schools, but also the libraries and IUs that also use the schools’ NSLP data for their E-rate applications.

When this guidance was originally issued by the FCC in 2012 for states that first rolled out the CEP program, I believe it was a short-term measure designed to provide the Commission time to decide whether to allow schools to use the 1.6 multiplier when calculating E-rate discounts. The 2014 school year marks the first year that every state in the country can make CEP available to their schools and I, along with numerous other state E-rate Coordinators, have asked the FCC to provide updated guidance so schools won’t be forced to use old poverty data. I will let you know if the FCC issues any further statements or rules pertaining to CEP and E-rate.

What is CEP?
In order to qualify for CEP, a school, group of schools, or the entire district must have an Identified Student Percentage of 40% or more and must offer both breakfast and lunch daily. The Identified Student Percentage is composed of students that are eligible for free meals without the need for Household Application. LEAs/schools can obtain the identified student information through calculating students from lists of Direct Certification (DC), Homeless/Runaway, Migrant, Foster (through county office), Head Start, Even Start, etc. For more information, the Division of Food and Nutrition, Pennsylvania Department of Education’s website for the CEP, located at www.education.state.pa.us/cep, offers a variety of resources, including a spreadsheet that identifies potentially eligible schools based on direct certification numbers alone.

If you have any questions related to CEP, please contact Gina Wetten, Special Projects Manager in the PDE Division of Food and Nutrition at giwetten@pa.gov or 800.331.0129. If you have any questions related to how CEP will impact E-rate, please direct them to me at jtschell@comcast.net.

— Julie

Julie Tritt Schell
PA E-rate Coordinator

717-730-7133 – o
717-730-9060 – f
jtschell@comcast.net
www.e-ratepa.org
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