Schools and Libraries

Step 5: Alternative Discount Mechanisms Fact Sheet

The primary measure for determining E-rate discounts is the percentage of students eligible for free and reduced lunches under the National School Lunch Program (NSLP), calculated by individual school. Students from households whose income is at or below 185% of the federal poverty guideline are eligible for the NSLP.

The FCC's rationale for using NSLP data is as follows:
"[T]he national school lunch program determines students' eligibility for free or reduced-price lunches based on family income, which is a more accurate measure of a school's level of need than a model that considers general community income."

- FCC 97-157 ¶ 509


Income Eligibility Guidelines for NSLP eligibility are available on the web page of the United States Department of Agriculture Child Nutrition Programs by following the links for "National School Lunch Program" and "Income Eligibility Guidelines."

The FCC also sanctions other mechanisms to determine a school's level of need, as long as those mechanisms are based on – or do not exceed – the same measure of poverty used by NSLP:

"[A] school may use either an actual count of students eligible for the national school lunch program or federally-approved alternative mechanisms to determine the level of poverty for purposes of the universal service discount program...

"[S]chools that choose not to use an actual count of students eligible for the national school lunch program may use only the federally-approved alternative mechanisms contained in Title I of the Improving America's School Act, which equate one measure of poverty with another."

- FCC 97-157 ¶ 510

SURVEYS

A school may design a survey that provides the necessary information that measures a family's level of need. A sample survey is available in the training materials on this website. Applicants cannot use National School Lunch Application forms as surveys. Surveys must be based on the following guidelines:

  • The survey must be sent to all families whose children attend the school.
  • The survey must, at a minimum, contain the following information:
  • Name of family and students
  • Size of the family
  • Income level of the family

Income data (or eligibility data based on income) from a survey used to support a discount
level for a funding request cannot be older than two years before the start of the funding year. For example, the data gathered from an income survey done in September 2005 can be used for funding requests for Funding Year 2006 and Funding Year 2007, but not for Funding Year 2008. Therefore, surveys must be done at least every other year.

Survey retention documentation

Applicants should maintain a record of the survey documentation collected to assist in responding to PIA inquiries. Such records should be maintained for a period of five years after the last day of delivery of the discounted services.

Collecting income data on a survey

Consistent with NSLP eligibility guidance, income data (or eligibility data based on income) used to support the discount level for a funding request should be collected based on income received by the household during the month before the month in which the survey is conducted. However, the monthly income of a household containing one or more seasonal workers, self-employed workers, or other workers whose income varies from month to month may not accurately represent the actual circumstances of the household. Such a household can project its annual rate of income for the current year based on the income data that is available.

NOTE: In general, income data gathered for NSLP is annualized based on the monthly household income from the month preceding the month in which the application is submitted; applications are distributed at the beginning of the school year. The income data gathered is used to determine eligibility for the twelve-month school year (July 1 to the following June 30) in which the survey is conducted.

Information on the definition of income under NSLP, other income guidelines of the program, and the "Eligibility Guidance for School Meals Manual" can be obtained from the website of the National School Lunch Program.

Collecting data on acceptable alternative measures of poverty on a survey

Participation in one or more of the following programs is currently acceptable as an alternative to NSLP eligibility. Questions on eligibility for these programs can also be included in a survey:

  • 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 not an acceptable alternative measure of poverty since the participation guidelines are not always equal to or below the level of the Income Eligibility Guidelines (IEGs) for NSLP. Participation in need-based tuition assistance programs is acceptable only if the household income of participants is at or below the IEGs for NSLP.

Projections based on surveys If a school has sent a survey to the households of all of its students, 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 NSLP for all students in the school. For example, a school with 100 students sent a survey to the 100 households of those students, and 75 of those households returned the questionnaire. The school finds that the incomes of 25 of those 75 households are at or below the IEGs for NSLP. Consequently, 33 percent (25 / 75 * 100) of the students from those households can be counted as eligible for NSLP. 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, can be counted as eligible for NSLP.

OTHER ACCEPTABLE MECHANISMS FOR COLLECTING DATA

Collecting data from existing sources

Schools may also use existing sources of data that measure levels of poverty, such as TANF or need-based tuition assistance programs. However, these measures are acceptable for E-rate purposes only if the income eligibility guidelines are equal to or below the IEGs for NSLP.

Matching siblings

If a school has established that the household income of one of its students is at or below the IEGs for NSLP, the siblings of that student may also be counted as eligible for NSLP. For example, an elementary school has established, through a survey, that a student's household income is at or below the IEGs for NSLP. That student's household also 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 NSLP, without collecting its own data on that household.

Combining data from different sources

Unless a school is able to use a projection based on a survey as described above, data used to support a particular discount level must be collected and verifiable on an individual student basis. However, data from multiple sources can be combined to complete the count of students eligible for NSLP. For example, a school with 100 students sent a survey to the 100 households of these students, and 40 of those households returned the survey. The school finds the income of 20 of those 40 households, each of which has one student in the school, are at or below the IEGs for NSLP. This rate of return (40%) is too low to allow a projection based on that survey. However, the school has also matched 10 students not represented in the survey responses with siblings who are eligible for NSLP, and the school has verified that 15 additional students not represented in the survey responses participate in a need-based tuition assistance program that requires the household income of participants to be below the IEGs for NSLP. The school can combine the individual results from these three sources to conclude that 45% of the total enrollment, or 45 (20+10+15) of the 100 students in the school, are eligible for NSLP. The school must be able to verify that it has counted each eligible student only once.

Provision 1, Provision 2 or Provision 3 schools

The National School Lunch Act incorporates three alternative provisions to the normal requirements for annual determinations of eligibility for free and reduced price school meals. For schools that meet the requirements of one of these provisions, annual notification of program availability and certification of children eligible for free meals may be reduced to once every two consecutive school years or less. USAC defers to these reporting requirements and does not require more documentation than is required under these provisions.

Schools participating in one of these three provisions can use the percentage of students eligible for free and reduced lunches acceptable under that provision to determine the discount they enter on their Form 471. However, such schools must be able to produce the documentation required under that provision if requested. Specifically, a Provision 2 or Provision 3 school must have copies of its site application, approval letter from its state to participate in that provision, base year statistics, and the state letter approving an extension (if applicable).

Special provisions for schools in Puerto Rico and the U.S. Virgin Islands

The Code of Federal Regulations contains special provisions for determining NSLP eligibility for schools in Puerto Rico and the U.S. Virgin Islands. All students in these territories are provided with a free lunch regardless of actual income. However, a survey must be conducted to determine the socio-economic level of the territory and the applicable reimbursement rate for the NSLP, and it is that reimbursement rate that determines the E-rate discount. USAC will work with the relevant territorial agencies to determine the eligibility numbers approved by the U.S. Department of Agriculture for each territory. This determination is applicable to public schools and libraries. Nonpublic schools are not automatically eligible to receive the same discount rate.

UNACCEPTABLE MECHANISMS

The following alternative measures of poverty are NOT acceptable for determining E-rate discounts:

  • 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) that "feeds" students to the middle or high school.
  • 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.

 


Last modified on 11/30/2011