Arkansas Department of Education Updated E-Rate Guidance for Schools Electing Community Eligibility Provision

Memo Information

Memo Number
FIN-15-058
Memo Date
12/5/2014
Memo Type
Regulatory
Section
Fiscal & Administrative Services
Regulatory Authority
§USDA Memo SP 08-2015, Federal Communications Commission FCC 14-99, FCC DA12-1196
Response Required
NO
Attention
Co-op Directors; Elementary Principals; Middle School Principals; High School Principals; Superintendents; Child Nutrition Directors

Contact Information

Memo Text

The purpose of this memo is notify local program operators of the National School Lunch Program (NSLP) of recently updated rules issued by the Federal Communications Commission (FCC) regarding the calculation of discount rates under the E-Rate program for schools electing to participate in the Community Eligibility Provision (CEP). Typically, school districts have calculated E-Rate discount rates based on each school’s percentage of free/reduced price eligible students.  Districts, individual schools or any combination of schools electing to participate in the CEP do not take meal applications to determine percentage of free/reduced price meal benefits.  In July, 2014, the FCC adopted new rules for the E-Rate program, including rules specifying how school districts with CEP schools should calculate their discount rates beginning in School Year 2015-2016.  It is important to note that there is no impact on the current school year 2014-15, for which E-Rate discounts have already been calculated under FCC’s previous interim guidance (FCC DA12-1196, July 31, 2012)(attached). FCC requires school districts with schools electing to participate in CEP that apply for E-Rate discounts to use the same multiplier issued by the United States Department of Agriculture (USDA) to calculate meal claiming percentages under CEP.  Schools electing to participate in CEP will use their Identified Student Percentage (ISP) multiplied by the USDA CEP multiplier (currently 1.6) for the purposes of determining the number of free and reduced price eligible students.  This is the same formula that schools electing CEP use to calculate meal claiming percentages.  Student eligibility may not exceed 100% for any purposes related to E-Rate or any other school meal program.  USDA is permitted to change the multiplier to a number between 1.2 and 1.6 but has no plans to do so at this time. E-Rate discounts remain valid for the entire four-year CEP cycle.  If a school’s ISP decreases in subsequent years, the school may continue to use the original percentage for the remainder of the four year cycle.  If the ISP increases in the four year cycle, the school may choose to use the higher percentage for E-Rate purposes. Anytime a school participating in CEP begins a new four year cycle or chooses to apply a new meal claiming percentage, the school district must also re-calculate its student eligibility for E-Rate and use that data in the next funding year.  For example, a schools ISP increases in year two of the four year cycle and the school chooses to apply the new higher percentage to meal claiming percentage – new ISP x 1.6 = meal claiming %.  For E-Rate purposes, the school must also re-calculate its student eligibility using the new meal claiming percentage. FCC’s published E-Rate rules and guidance of July 23, 2014 on procedures for schools electing CEP is attached and may be accessed at the following URL:  https://apps.fcc.gov/edocs_public/attachmatch/FCC-14-99A1.pdf.  Refer to paragraphs 225-229 for CEP.  USDA Memo SP 08-2015 is attached may be accessed at the following URL:  http://www.fns.usda.gov/sites/default/files/cn/SP08-2015os.pdf. E-rate questions may be directed to Cory Biggs at 501-682-0459. CEP and Child Nutrition Program questions may be directed to Patricia Winders at 501-324-9502.