CALPADS Update Flash #220

To:           Local Educational Agency (LEA) Representatives

From:      California Department of Education (CDE) –
                California Longitudinal Pupil Achievement Data System (CALPADS) Team

Date:       March 25, 2022

Subject:  CALPADS Update FLASH #220

National School Lunch Program Meal Application and Alternative Income Form Requirements for 2022−23

Background: California Universal Meals Program

Assembly Bill (AB) 130, the 2021−22 budget trailer bill for K-12 education, established the California Universal Meals Program. Under this program, beginning in school year 2022−23, county offices of education, public school districts, and charter schools serving students in grades K-12 are required to provide two free meals (breakfast and lunch) during each school day to students requesting a meal, regardless of students’ free or reduced-price meal (FRPM) eligibility, and regardless of whether or not the school is participating in the federal National School Lunch Program (NSLP) or School Breakfast Program (SBP).

The California Universal Meals Program is meant to supplement, not supplant, the federal school nutrition programs. As such, under the California Universal Meals Program, the CDE will reimburse eligible LEAs for the difference between the federal paid and reduced-price meal reimbursement and the free rate, as long as the LEA participates in both the NSLP and SBP. LEAs are required to serve meals that comply with the U.S. Department of Agriculture (USDA) meal standards and must abide by federal regulations and guidelines. Therefore, LEAs are still required to collect Meal applications or Alternative Income forms as described in the next section.

In addition, on or before June 30, 2022,LEAs participating in a federal meals program are required to apply to operate under a federal provision, such as the Community Eligibility Provision (CEP) or Provision 2, for any high poverty schools within the LEA. The definition of a high poverty school is updated to mean 40 percent or more of enrolled students who are directly certified, or identified as homeless, migrant, foster, or runaway.

Meal Application and Alternative Income Form Collection

Meal Application Collection

As a condition of participation in the NSLP/SBP, whether and how often schools are required to collect meal applications depends on the school’s provision status (non-provision, CEP, and Provision 2 or 3):

• Non-provision schools must collect meal applications annually.
• Schools operating under a CEP are prohibited from collecting meal applications because their eligibility for CEP is based on whether 40 percent or more of enrolled students are directly certified or categorically eligible based on their migrant, homeless, foster, or runaway status.
• Schools operating under Provision 2 or 3 are required to collect meal applications in a “base-year” and every time a new Provision cycle is established.

Alternative Income Form Collection

In California, LEAs are eligible to receive supplemental and concentration grants under the Local Control Funding Formula (LCFF), based on an “Unduplicated Pupil Count” (UPC) of targeted disadvantaged students, which includes students who are FRPM-eligible. Since CEP schools are prohibited from collecting meal applications that determine FRPM eligibility, the Alternative Income form was created as a way for CEP schools to collect income data for LCFF purposes. Therefore, CEP schools desiring to receive funding under the LCFF grants must collect Alternative Income forms to capture FRPM-eligible students who are not directly certified or categorically eligible, so that they can be included in their LEA’s UPC. CEP schools may collect these forms annually, or during an LCFF-base year which must be re-established at least every three years (i.e., in the year following the base-year plus an three additional years).

Provision 2 or 3 schools may also establish an LCFF-base year (which may be the same as their provision-base year), and then collect Alternative Income forms from new or incoming transfer students during non-base years in order to include those students in the UPC.

CEP and Provision 2 or 3 schools that have established an LCFF-base year may:

• Use that eligibility status for students in each of the following school years until they re-establish their base year.
• Collect forms once from new or incoming transfer students during non-base years in order to include those students in the UPC. Alternative Income forms must then be collected from all students when the base-year is being re-established.

Since the authority to establish an LCFF-base year is provided to schools operating NSLP/SBP under a provision (CEP or Provision 2 or 3), schools not participating in NSLP/SBP must collect Alternative Income forms annually.

Summary of What LEAs Should Collect

The following table summarizes what LEAs are required to collect beginning in 2022−23 based on their status:

Submitting Data to CALPADS for the UPC

In order for CDE to capture students for inclusion in the UPC, LEAs must annually submit an FRPM program record (Education program code 181 – Free Meal Program, or 182 – Reduced-Price Meal Program), with a start date in the current year for each student identified as FRPM-eligible based on an approved meals application or Alternative Income form. Furthermore, to be included in the UPC and reflected in Certification report 1.17 – FRPM/English Learner/Foster - Count, students must be enrolled in a school in the LEA on Census Day (first Wednesday in October), and have an open FRPM record with a start date before Census Day through October 31 of the same year.

In order to be included in the UPC, even CEP and Provision 2 or 3 schools, which only collect meal applications or Alternative Income forms in a base-year, must send up an FRPM record for each student identified as FRPM-eligible in the base year, and in each of the subsequent years. Schools must annually submit that same FRPM status for the student (as long as they remain continuously enrolled in the school) with a new annual start date until a new base-year is re-established. These schools may also submit an FRPM record for new or incoming transfer students during non-base years in order to include those students in the UPC. To be included in the UPC and reflected in Certification report 1.17, these students must also be enrolled in a school in the LEA on Census Day, and have an open FRPM record with a start date before Census Day through October 31 of the same year.

Addressing Challenges to Collecting the Meal Applications and Alternative Income Forms

In light of the new California Universal Meals Program, the CDE recognizes that LEAs will find it challenging to collect meal applications or Alternative Income forms, since families know that all students may receive free meals without submitting any applications or forms. As part of an overall strategy, to get families to submit these applications/forms, LEAs should develop a communications plan led by district leadership that informs parents and students of the critical importance of turning in meal applications and Alternative Income forms. LEAs can emphasize that completion of these forms may bring significant additional funds to the school site, as well as qualify students for individual benefits such as college application waivers, Advanced Placement (AP) and International Baccalaureate (IB) testing fee waivers, and Pandemic-Electronic Benefits Transfer (P-EBT) benefits. Addressing the change in this messaging is critical.

Addressing Challenges to Collecting Alternative Income Forms

Alternative Income form prototypes can be found on the CDE LCFF Frequently Asked Questions web page at: https://www.cde.ca.gov/fg/aa/lc/lcfffaq.asp#PROV2and3. The 2022−23 Income Eligibility Guidelines (IEG) can be found here: https://www.cde.ca.gov/ls/nu/rs/scales2223.asp. LEAs can use the guidelines to update the form they choose to use.

During the past two years, many LEAs have operated under the Seamless Summer Option which enabled LEAs to serve meals to all students without the submission of applications. This necessitated all schools to collect the Alternative Income form for LCFF purposes. During this time, LEAs found that collecting the Alternative Income form during the registration process was an effective way to get needed income data for LCFF. Therefore, to facilitate the collection of Alternative Income forms, the CDE will allow LEAs to collect this form for the next school year (for example, school year 2022−23), during preceding spring, in order that LEAs may incorporate its submission as part of the spring registration process, provided the USDA income eligibility guidelines are available. Since the forms reflect students’ income status for the next school year, FRPM records must be submitted to CALPADS each year in the school where the student is enrolled and with an overlapping program record with a start date of July 1, 2022 or after, even if the student’s eligibility was determined during the registration prior to July 1, 2022.

As in past years, Alternative Income forms may be distributed and collected online, and electronic signatures are acceptable. LEAs may also complete an Alternative Income form on behalf of a student’s household by collecting the required information over the telephone provided the LEA documents: 1) the date, time, and name of the student’s adult household member spoken to, and 2) the date, time, name, and signature of the LEA staff member collecting the information.

Meal Applications

The California Universal Meals Program is premised on LEAs continuing to receive federal reimbursement under NSLP/SBP. Therefore, it is critical that LEAs continue to collect meal applications in order to receive federal reimbursement for meals. Since parents know that their students will receive free meals regardless of whether they turn in a meal application, it is important that messaging is consistent and is part of an overall communications plan that highlights the importance of turning in meal applications because it brings additional funding to the school site, and may qualify students for other individual benefits such as fee waivers and P-EBT benefits.

Unlike the new flexibility provided for collecting Alternative Income forms, non-provision schools and provision 2/3 schools collecting meal applications in their base year, must continue to abide by NSLP/SBP regulations, including collecting meal applications in the same school year in which they apply. This means, for the 2022−23 school year, meal applications must be collected on or after July 1, 2022. 

LEAs who have been successful in collecting meal applications have also found that direct outreach to families is effective. Understanding that this is a resource-intensive effort, since students who are directly certified or categorically eligible do not require a meal application for federal meal reimbursement or LCFF, LEAs may also consider focusing outreach efforts on families who are not directly certified or categorically eligible for FRPM.

Additional Resources

CDE Provisions: Claiming Alternatives web page at https://www.cde.ca.gov/ls/nu/sn/provisions.asp

CDE Community Eligibility Provision web page at https://www.cde.ca.gov/ls/nu/sn/cep.asp

CDE School Nutrition Programs Forms web page at https://www.cde.ca.gov/ls/nu/sn/fm.asp

CDE Universal Meals Program Questions and Answers listserv at https://www.cde.ca.gov/ls/nu/univmealsqandapart2.asp
[NOTE (as of March 2023): The preceding link is no longer valid. Visit the CDE Universal Meals Frequently Asked Questions web page at https://www.cde.ca.gov/ls/nu/univmealsfaq.asp for relevant information.]

CDE LCFF Frequently Asked Questions web page at https://www.cde.ca.gov/fg/aa/lc/lcfffaq.asp#PROV2and3