AOE Requirements for Reporting Household Income
The most important fact to understand about the collection of household income is that is determines if a student is eligible for FRL. This is not the same thing as if they are actually receiving free or reduced lunch. If a student is eligible based on set income ranges, the student may also be eligible for other state programs that have nothing to do with lunch, such as free Internet access. It would be great if they would call this Household Income Eligibility and not FRL.
The following are excepts from the AOE that explains this requirement.
The AOE states in a memo to Superintendents and others on 8/22/2017 (from Laurie Colgan, Director, Child Nutrition Programs:)
The Student Census data collection requires that student eligibility to receive free and reduced
lunch be reported annually whether or not students receive lunch at school. Schools that no
longer participate in the National School Lunch Program (NSLP), and report Student Census
must still collect and report household income data.
PreK Programs, CEP & Provision 2 Schools, and schools not participating in National School
Lunch Program –Schools that are required to report Student Census data must collect and
report household income data which can be a challenge when schools:
- Do not participate in the National School Lunch Program (NSLP) or
- Do not distribute free and reduced price meal applications due to participation in the
Community Eligibility Provision (CEP) or Provision 2, or
- Have students participating in Pre-Kindergarten education programs (PreK) that do not
have access to meal programs.
Free and reduced priced lunch eligibility has been widely used as a determining factor for
eligibility and funding of a number of state and federal programs for families and schools.
Other programs depend on the household income data to determine things like a student’s
eligibility for services, a family’s eligibility for reduced internet service rates, the school’s e-rate,
and other criteria that are used in federal and state grant applications. Schools must report this
data for all enrolled students including PreK.
And specifically regarding CEP schools:
…Since USDA does not permit these schools to use the federal free and reduced price
meal application to determine household income, the AOE has prepared and provided the Household Income Form for public schools enrolling students to PreK Programs (public and
private providers), CEP and Provision 2 schools, and non-NSLP schools to use so that you may
collect household income information from those families and households whose children are
not on the Directly Certified List.
CEP Student Eligibility Data & Direct Certification – USDA’s Community Eligibility Provision
(CEP) changed the way schools must collect and report student-level eligibility for free and
reduced price school meals programs. The school’s eligibility to participate in CEP, as well as
the level of free reimbursement claimed, is based on the number of directly certified students
enrolled in the school, including PreK students that participate in the school meals program.
The school must continue to collect and identify directly certified students throughout the
school year in order to determine the accurate level of reimbursement for the next program
year. USDA guidance allows schools to adjust their claiming percentages which is based on the
current “Identified Student Percentage” reported in April as long as the student data has been
collected and verified; increases in the number of directly certified students allows the school(s)
to earn a higher percentage of free reimbursement for all meals served. In addition, these
schools must also distribute the household income form to collect data to report the eligibility
status of students not directly certified.
The AOE follows up in another memo to Business Managers, PreK Program Coordinators and Directors and copied to Superintendents on 9/17/2017.
One of the critical elements of the demographic data is whether or not students are eligible for
free and reduced lunch. This data is required whether or not the student is actually receiving
meals at the school to which they are enrolled.
The Agency also requires public school districts to collect and report household income data for
all students. For PreK or early education programs, especially for those in private educational
settings that do not participate in the Child & Adult Care Food Program, families must be
provided the household income form to collect this data.
They discover that some districts have been letting ACT 166 providers collect the Household Income Survey:
We have received notice that some school systems are requiring this data collection be done by
private providers. The Agency of Education does not recommend this as a data collection
method. Only individuals trained to adequately protect student privacy should collect this
sensitive information. School systems may consider these options if a student was enrolled
before you collected the data:
- If the child has older siblings in your schools system you may apply the status of the
older sibling to the younger sibling.
- Mail the household income form to families to return to your school.
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