How Direct Certification Will Affect E-rate Discounts
Message Posted July 24, 2008

~ Program is Mandatory Beginning in 2008 ~

 

As you know, E-rate discounts are determined by the percentage of students that are eligible for free or reduced priced meals through the National School Lunch Program (NSLP).  Most schools use NSLP eligibility rates rather than try to extract true eligibility rates via an income survey or sibling match.  But because documented NSLP eligibility rates often are lower than true eligibility, schools receive a lower E-rate discount than they actually deserve. 

 

Several years ago, the US Department of Agriculture (the agency that administers NSLP) developed a process called Direct Certification which allows LEAs to directly qualify children into the NSLP whose families participate in Food Stamps or Temporary Assistance for Needy Families (TANF), without the family having to complete an application for free or reduced price school meals.

The Direct Certification program to this point has been optional, but beginning in 2008, it is mandatory for all schools -- public and private.  Each state determines how the program is implemented, and in Pennsylvania, there are two options that can be implemented.  School Districts can use either Option 1 or 2.  All other entities (charter schools, private schools, etc) must use Option 2.  

 

Option 1
1) The PA Department of Public Welfare (DPW) uploads a list of all families that are participating in Food Stamps/TANF to the COMPASS system by July 15.
2) LEAs must download the list of households from COMPASS associated with their LEA.  The LEA then matches the household names and addresses with students enrolled in their school(s). 
3) When a match is found, the LEA must mail a letter to the household informing them that their child(ren) qualifies for NSLP and will be automatically enrolled for free meals in the upcoming school year and that no further action is needed.  The district, however, must provide the family with an opportunity to "opt out" of NSLP if they so choose.  (A form letter is available in the PEARS system under 'PEARS Form Download' in the COMPASS section.)

Option 2
1) The school uploads their student enrollment list into the COMPASS system. 
2) COMPASS then matches that enrollment list against the DPW database for Food Stamp/TANF households and returns the school’s enrollment list via COMPASS indicating if there is an exact match or potential match for the student.  An exact match means first name, last name and date of birth match.  A potential match means last name matches, but date of birth or first name do not match, in which case the school needs to determine if it is a match.  (In many cases, it is a difference of schools using William vs. Bill; schools entering incorrect information in their databases for their student(s) (ex. wrong social security numbers, misspelling of name, typographical errors, etc.)

3) When a match is found, the school must mail a letter to the household informing them that their child(ren) qualifies for NSLP and will be automatically enrolled for free meals in the upcoming school year and that no further action is needed.  The district, however, must provide the family with an opportunity to "opt out" of NSLP if they so choose.  (A form letter is available in the PEARS system under 'PEARS Form Download' in the COMPASS section.)

 

As you can imagine, Direct Certification has the potential to greatly reduce the disparity between NSLP participation and NSLP eligibility, and provide LEAs with the E-rate discount that they deserve without having to go through the hassle of conducting an income survey or sibling match.  

For E-rate contacts, I encourage you to work with your Food Services Department to ensure that the District is complying with the now-mandatory Direct Certification process and to ensure that all eligible students are included in the NSLP count that is submitted to the State each October. 

If you have any questions about how Direct Certification will affect E-rate, please don't hesitate to contact me.  If you have questions about the Direct Certification program itself, please contact Pam Heimbach in PDE's Division of Food and Nutrition at pheimbach@state.pa.us or 717-783-3223.

-- Julie