Rationale for Continued Collection of Household Income Information from Families in SY22-23
Q1. Why does the Agency of Education still ask families to complete forms to provide household income when school meals will be free to all in SY22-23?
Household income data are used to determine which schools and students are eligible for many educational programs and benefits that are tied to need, in addition to qualifying students for free or reduced-price school meals. Such data also are needed to comply with mandated reporting that accompanies the approximately $123 million in federal education funding the state receives each year.
The primary purpose of the school meals application (hereafter known as the Free or Reduced-Price Meals or FRL application) is to determine a student’s eligibility for free or reduced-price school meals and a student’s school or community’s eligibility for additional meals funding (e.g., Open Summer Meals Sites, preference on Equipment Grants, etc.). Just as importantly though, household income information that is collected through FRL applications and Household Income (HIF) forms also is used to determine schools’ and communities’ eligibility for many important educational programs and benefits. For example, these data are used to determine which schools are eligible to receive a share of the approximately $41 million in federal Title I funds the state receives annually to support schools’ educational programs. These data also are used to determine which schools may operate their Title I programs as Schoolwide Programs that benefit every student, as opposed to having to target specific students for additional supports. Such data also are used to determine many other school-level programs and benefits including determining which schools:
- May operate federally funded summer and afterschool programs,
- Will receive additional funding for broadband access,
- Are eligible to apply for state Community Schools grants, and
- May receive additional federal Individuals with Disabilities Act (IDEA) special education funding.
The data from individual forms also are used to determine the eligibility of individual students for benefits such as:
- The federal Affordable Connectivity Program
- Waivers of SAT and other testing fees
- Waivers of college application fees
- Comcast discounts
- VSAC stipends for Dual Enrollment and Early College
Finally, like every state, the Agency of Education is required, as a condition of the approximately 123 million in federal education funding it receives annually, to report on the academic performance of low-income students in comparison to all students, to improve equity. The data provided in the FRL and HIF forms is the best measure of individual students’ income status to which the Agency of Education currently has access.
Q2. Why is completing FRL applications and HIF forms a priority in SY22-23?
The necessity and urgency to collect FRL applications and HIF forms is particularly significant in SY22-23 because in 2022, the Vermont legislature enacted a universal meals law which will be in effect in SY22-23. This follows several years of universal school meals made possible by federal COVID waivers. Due to both factors, family’s incentives to provide household income information, and their understanding of why it is still necessary to do so, will be significantly reduced in SY22-23 since school meals will continue to be free for all students.
It is essential that the Agency of Education have a complete picture of the relative poverty within each school and district in order to fairly distribute educational benefits and program supports. Furthermore, the more students are determined eligible for free or reduced-price meals by completing applications/forms, the greater the amount of federal funding for school meals the state can draw down, reducing the cost to Vermont taxpayers. Schools and districts are asked to do all that they can to ensure that the appropriate applications/forms are completed so that their students and schools will have access to the maximum federal and state educational funding and so that universal meals can continue to be funded in future years. The AOE has provided template materials, including a letter to households, newsletter copy and social media graphics to assist with this outreach effort.
Q3. Why can’t the AOE get household income information from another source such as taxes?
The AOE has explored a number of alternatives sources of household income information. However, none, including state and federal tax information, provides the information required for federal reporting or educational program eligibility purposes.For example, many families do not file income taxes, and tax forms do not count sources of household income such as income from public benefit programs or earnings of non-related household members which are required to be included in household income as defined by the federal rules governing education and meals programs.
The AOE will continue to explore alternative ways of collecting household income information without having to ask families to complete applications/forms. The AOE also continues to advocate with the US Departments of Education and Agriculture and with Congress to come up with a nationwide metric for poverty that does not rely on individual families providing household income information through forms.
FRL Applications versus HIF Forms
Q4. What is the difference between the FRL application and HIF forms?
The FRL application was created by the USDA and by federal law may only be used to determine eligibility for free or reduced-price school meals. However, once the information is collected for meals eligibility purposes, it may then be used for other educational purposes. When FRL forms may not be used, families are asked to use a state-created HIF form which collects the same household income information, which still is needed for the educational (non-meals) eligibility purposes discussed in Q1.
For a number of years now, many Vermont’s schools have been eligible to operate universal meals pricing programs through USDA options for higher poverty schools called Community Eligibility Provision and Provision 2. Per federal law, such schools may no longer collect FRL applications because they are not needed to determine meals eligibility. (Provision 2 schools collect FRL applications in their first or “base” year but not in years 2-4 of each 4-year cycle.) In place of FRL applications in CEP and Provision 2 schools after the base year, families are asked to complete a state-created HIF which collects the same income information. This is the same process that is followed in other states.
Q5. Who should complete the FRL applications or HIF forms?
In order to provide the household information needed for the educational purposes outlined in Question [x] above, families that have students attending public schools (as well as those with children attending independent schools or prekindergarten programs if those schools or programs participate in USDA school meals programs) will be requested by their schools to complete either the FRL application or HIF form, regardless of whether their children intend to eat school meals or to apply for benefits such as Early College tuition waivers. While it is not required that they do so under state or federal law, they will be helping their school and community to access needed resources by doing so.
Q6. Who in our schools/LEAs should be responsible for collecting FRL applications and HIF forms?
If FRL applications are needed for the school meals program because the school is in their first, or base year, of Provision 2, FRL applications may continue to be collected by the same individuals who have done so in the past, and this work may be supported by Child Nutrition funds. However, if the school is operating CEP, Years 2-4 of Provision 2, or not operating a school meals program, FRL applications may not be used. In cases where FRL applications may not be used, the HIF should be used instead. USDA regulations do not allow Child Nutrition funds to be used to send out the HIF, or to pay staff to process these forms, as the HIF is not used to determine eligibility for any school meals program. It is up to the LEA to determine who is responsible for the collection of HIF forms within their schools.
Q7. Do we need to audit a percentage of HIF forms and if so, who is responsible for this?
Auditing of a sample of household-provided data is necessary for data quality and equity purposes. USDA regulations require an audit of 3% of FRL forms submitted by families in each school each year through the verification process. This work is done by staff paid with Child Nutrition funds. Unlike the FRL applications, there currently is no audit requirement for the HIF forms and there will not be such a requirement for SY22-23. However, recently enacted state legislation gives the AOE authority to audit HIF data beginning in SY23-24 and flexibility to determine how such auditing will occur. The AOE is committed to developing a process that will be the least onerous possible for both families and schools/LEAs.
Poverty Data Collection and Submission Instructions for CEP Schools for SY22-23
Q8. How should CEP schools collect data on students’ household income status in SY22-23?
Schools operating CEP may not collect free and reduced-price meal applications per federal regulation. To gather the school and student-level household income data needed for the purposes described in Q1 above, the school should collect the Household Income Form (HIF). Funds from the non-profit school food service account may not be used to pay for collection and processing of the Household Income Form, as it is not needed for the child nutrition programs.
Q9. How should CEP schools submit data on students’ household income status in SY22-23?
LEAs should continue to use the code set they have been using for the DC04, DC05, and DC06 data collections:
01 – Eligible for free breakfast or lunch (means student’s household income is at or below 130% of federal poverty level based on an FRL application or HIF form or student is directly certified for free meals)
02 – Eligible for reduced-price breakfast or lunch (means student’s household income is at or below 185% of federal poverty level based on an FRL application or HIF form)
09 – Declined free breakfast or lunch (means student is eligible for free school meals based on direct certification but declined them)
96 – Not eligible for free breakfast or lunch (means student is not eligible for free school meals based on direct certification and either student’s household income exceeds 185% of poverty based on an FRL application or HIF form or family did not complete an FRL application or HIF form)
Students reported as 01, 02, or 09 are considered “low-income” for educational purposes. This student-level coding is what is aggregated to generate school and LEA low-income percentages that are used for educational program and benefit eligibility purposes.
Poverty Data Collection and Submission Instructions for P2 Schools for SY22-23
Q10. How should Provision 2 schools collect data on students’ household income status in SY22-23?
Provision 2 operates in four-year cycles. During Year 1, or the “Base Year”, of Provision 2, schools must attempt to collect FRL applications from each student to establish their base USDA reimbursement claiming percentages (free, reduced, and paid) which apply for the remaining three years of their cycle. Most Vermont schools operating Provision 2 in SY22-23 will be in their base year and therefore, will need to collect FRL applications in SY22-23.
Because they are not needed in years 2-4, schools operating Provision 2 in years 2-4 may not collect free and reduced meal applications per federal regulation. To gather the school and student-level household income data needed for the purposes described in Question [x] above, schools in Provision 2 years 2 to 4 should collect the Household Income Form (HIF). Funds from the non-profit school food service account may not be used to pay for collection and processing of the Household Income Form, as it is not needed for the child nutrition programs.
In Fall 2022, because of recently enacted federal waivers, free and reduced-price eligibility from School Years 19-20, 20-21 and 21-22 will carry over for the first 30 operating days, unless a more recent application has been submitted. Usually, the thirtieth operating day occurs in mid-October. This should lessen the impact of universal meals on low-income data reported in SY22-23. However, the FRL applications and HIF forms collected in SY22-23 will affect SY 23-24 carry over numbers.
Q11. How should Provision 2 schools submit data on students’ household income status in SY22-23?
Follow instructions for submitting household income data in CEP schools in SY22-23 (Q8).
Poverty Data Collection and Submission Instructions for Independent Schools and PreK Programs
Q12. How should independent schools and PreK programs participating in the Universal Meals Supplement collect data on students' household income status in SY22-23?
Independent schools and prekindergarten programs participating in the Universal Meals Supplement program as a site under a public SFA will operate either CEP, if eligible, or Provision 2 in SY22-23. In addition, non-profit state-approved independent schools operating as their own SFAs that wish to receive the Universal Meals Supplement also must operate either CEP, if eligible, or Provision 2. (For further information on which independent schools are eligible for the Universal Meals Supplement, please see the July 5 memo from Secretary French Implementation of Act 151 - Universal Meals for School Year 22-23. Independent schools and prekindergarten programs should follow the instructions above for collecting household income data that pertain to the type of meals program they will be operating in SY22-23 (i.e., CEP vs. Provision 2, see Q8 and Q10). They will submit their household income information in the Independent School Census using the usual coding (see Q8).
Q13. How should independent schools and PreK programs not participating in the Universal Meals Supplement collect data on students' household income status in SY22-23?
Independent schools and prekindergarten programs that will not participate in the Universal Meals Supplement but will continue to provide school meals will operate their “normal” NSLP programs. As such, they will collect FRL applications as usual and will submit their household income information in the Independent School Census using the usual coding (see Q8).
Q14. How should Independent Schools and PreK Programs that choose not to participate in the NSLP program collect data on students' household income status in SY22-23?
Independent schools and prekindergarten programs that choose not to participate in the NSLP program at all should collect household income for required data submission in the Independent School Census via the Household Income Form. They should not use the USDA FRL application because this application is only allowed to be used under federal law for the purpose of determining eligibility for free or reduced-price meals under the NSLP. They should submit their household income information in the Independent School Census using the usual coding (see Q8).
Oct. 1 vs. Oct. 31 Low-income (or “FRL”) Data Collections
Q15. Why does the AOE require two separate October data collections involving low-income or (“FRL” numbers)? What are the differences between the 10/1 and 10/31 data collections?
We acknowledge that the two collections appear redundant and the different poverty numbers generated may be confusing. However, each collection responds to different federal and state statutory requirements and has different purposes.
Per US Department of Education and state regulations, AOE must determine October 1st Student Census data, including students’ household income status as of this date. These data are collected by the AOE’s Data Management and Analysis Division (DMAD) through the DC06 and are used for many school and student eligibility and accountability purposes as described above in question [x].
Per US Department of Agriculture regulations, AOE Child Nutrition Programs (CNP) must collect a separate free and reduced percentage as of the last operating day of Oct of each year. These data are collected through the online CNP application and claims management system in something called the “Site Enrollment Data Collection.” For that report, CNP must determine the status of all the students who have access to school meals; we ask only for the total number of free, reduced, and paid status students. CNP publishes the FRL rates collected from this report each year on our website (the Child Nutrition Free and Reduced Eligibility Report).
Q16. Why are our Oct. 1 and Oct. 31 FRL numbers different?
Both the Oct.1 and Oct. 31 reports are based on the number of individual students who qualify for free and reduced-price meals compared to your enrollment. However, prior year free and reduced meal eligibility carries over for the first 30 operating days of the school year unless the household submits a new application during that time period. The 30th operating day generally falls in mid-October. Therefore, the October 1st (DC06) numbers include all of the children who qualified in the prior year, plus students who qualified in July-September, whereas the October 31st numbers (CN) only include children who became newly eligible in July-September. This means in practice that the October 1 FRL numbers (DC06) are usually a little higher than the October 31st numbers (child nutrition).
Q17. Should preschool students be included in either report?
For the Oct. 1 DCO6 collection, preschoolers should be included. However, per federal statue, AOE DMAD removes preschoolers from the Oct. 1 FRL and enrollment numbers for purposes of determining Title I eligibility and allocations through the Title I Targeting and Ranking process. For the Oct. 31 CNP collection, if a school’s preschool students have access to breakfast or lunch, then they should be included in the Oct. 31report - and the school’s meals program should be collecting FRL applications or HIF forms from those students as appropriate (see questions related to poverty data collection and reporting instructions for CEP and Provision 2 schools in SY22-23). If they don’t have access to the school meals program, you would exclude those students from your report.
Options for Determining School-Level Poverty for Purposes of Title I
Q18. What options do LEAs have for Title I Targeting & Ranking and determinations of eligibility to operate Schoolwide Title I programs if they are concerned that their low-income percentages may not be accurate, based on a low rate of return of FRL applications or HIF forms?
Because they are not allowed to collect FRL applications, schools operating their meals programs under CEP rules may use either the low-income percentages that are generated based on their DC06 data submission or their Identified Student Percentage (ISP) x a multiplier of 1.6, whichever they determine is more advantageous for them. All other schools must use the data generated by their DC06 submission.
For the past two years because of COVID disruptions in schools’ which impacted LEAs’ ability to collect FRL applications and HIF forms, the federal government has allowed LEAs to use either of the two prior years or the current year’s DC06 data for purposes of Title I Targeting & Ranking and determinations of eligibility to operate Schoolwide Title I programs, whichever they believe is most accurate. Schools and LEAs have already completed their SY22-23 determinations of eligibility to operate Title I programs and SWP program eligibilities using this flexibility. We do not expect the federal government will continue to offer this flexibility for FY24.
In anticipation of potential impacts on Title I eligibilities in SY23-24, we encourage schools and LEAs to do all that they can to ensure households complete the FRL applications and/or HIF forms, as appropriate, so that their students and schools will have access to the maximum federal and state educational funding. The AOE has provided template materials, including a letter to households, newsletter copy and social media graphics to assist with this effort.
If you have additional questions not included in this FAQ, please contact Anne Bordonaro at anne.bordonaro@vermont.gov.