A new federal program will offer free breakfast and lunch to all students in high-poverty schools, not just those whose families meet the government’s income bar, and some Colorado school districts are signing up.

But many other districts — including Denver, Aurora and Jeffco — are giving the “Community Eligibility Provision” a pass for now, fearing that it won’t be financially viable, could jeopardize funding for at-risk students or is simply too untested in Colorado.

Community Eligibility, also known as CEP, represents a policy shift from student-specific meal benefits to school-wide and, in some cases, district-wide benefits. The goal is to increase access to school meals, with the hope of reducing hunger and some of the issues that go along with it, such as spotty attendance or discipline problems.

Six other states and the District of Columbia have piloted the program over the last three years. The first three to try it–Michigan, Kentucky and Illinois–saw big increases in school meal participation, 25 percent for breakfast and 13 percent for lunch.

Alamosa, which already offers universal free breakfast, may see similar increases in its lunch program next year when administrators implement the CEP program in all three schools.

Joni Bilderbeck, the district’s director of food service, believes it will help ease the burden on working families who struggle financially but who just miss being eligible for free or reduced-price meals. She became more acutely aware of just how tenuous some families’ financial footing is after she recently hammered out next year’s salaries for her own staff.

“It’s just pathetic,” she said. “I’m thinking, ‘God, how do people survive?’”

Julie Griffith, program specialist in the Office of School Nutrition at the Colorado Department of Education, said she’s received a lot of positive feedback about CEP.

“It’s just a totally different way operating,” said Griffith. “It’s trying to make things easier for the families.”

But Griffith said she’s also fielded a lot of questions about how the program could affect districts’ revenue. That’s a concern echoed by Theresa Hafner, executive director of Enterprise Management for Denver Public Schools, who said she plans to wait to see how the program rolls out in other districts before deciding to adopt it.

“I don’t think many of us are going to [sign on] yet because we want to see how it works,” Hafner said.

A different yardstick for eligibility

Under CEP, which was established by the Healthy and Hunger Free Kids Act of 2010, parents will no longer have to fill out “Free/Reduced Price Meal” applications or pre-pay for school meals. Instead, any child in a CEP school gets free breakfast and lunch — no questions asked.

With about a month until the June 30 deadline for applying to CEP, it’s unclear how many districts will opt to try it out.

Twenty districts, most of them small and rural, are eligible to put the program into place districtwide, but many more districts are eligible to implement it at select schools. Aside from Alamosa, officials in Pueblo District 60, Harrison and Centennial have said they will pursue the program.

Schools or entire districts are eligible for the CEP program for four years if 40 percent or more of their students are “directly certified,” which means they are identified as low-income because they receive certain types of government benefits such as SNAP (formerly known as the food stamp program), or are classified as homeless, migrant or in foster care.

Free/reduced rates vs. "direct certification" rates in 15 districtsA district’s direct certification number represents a subset of those students who qualify for free meals based on the traditional application. For example, 73 percent of Alamosa students currently qualify for free or reduced-price meals but only 42 percent are directly certified based on CEP criteria.

In Aurora, 11 schools are eligible for CEP, but after crunching the numbers, Nutrition Services Director Mona Martinez-Brosh recommended against participating.

“We weren’t seeing the numbers work out,” she said. “We were afraid we would lose money.”

As in most school districts, Aurora’s food service department is expected to be financially self-sufficient. Martinez-Brosh said she and other food service directors in the state worked on CEP calculations together and concluded that a district would need direct certification rates around 50 percent to break even. Most of her eligible schools were closer to 40 percent.

Although Aurora won’t join the CEP program, many district students already enjoy universal free breakfast. The program is in place at 16 schools this year, with 17 more scheduled to add it over the next two years as Colorado’s “Breakfast After the Bell” law takes effect. The district, which has a free and reduced-price meal rate of 68 percent, doesn’t offer universal free lunch.

Some poor districts not eligible

Sometimes the gap between the directly certified percentage and the free and reduced percentage is so large that even districts generally recognized as having lots of poor students somehow don’t meet the 40 percent threshold, either districtwide or for individual schools.

That’s the case for Adams 14, where 83 percent of students qualify for free or reduced meals, but only 27 percent met CEP criteria.

“We were kind of amazed that we don’t have the qualifiers we thought we did,” said Jim Rowan, director of nutrition services. “We may not have people using government services to the extent that they qualify.”

Another factor may be that Colorado’s CEP program doesn’t directly certify children whose families receive “Temporary Aid to Needy Families” or TANF, as other states who’ve piloted the program do. Griffith said CDE is working with Colorado TANF to include that benefit in the direct certification process in the future.

Practically speaking, though, it doesn’t make much difference for Adams 14 students that the district isn’t eligible for CEP, since free breakfast and lunch are already available to all students. Rowan said this is possible because the federal reimbursement he gets for providing free or discounted meals to low-income students is enough to cover the cost of meals for students who would normally pay. The district has offered universal free meals for about five years.

No end of forms

While parents at Community Eligibility schools will no longer have to fill out applications for free or discounted lunches, they’ll probably be asked to fill out a similar form called a “Family Economic Data Survey.” That’s because districts are still obligated under state law to provide information on their low-income populations if they want to receive special funding for at-risk students.

“Unfortunately, the state does need some kind of paper trail,” said Scott Abbey, a member of CDE’s audit team.

For some districts, the move toward Community Eligibility hinges on a successful switch to the Family Economic Data Survey. Officials in Pueblo 60 hope to try CEP at 27 of 32 schools, but must first successfully embed the survey in the district’s new electronic registration process. The district is testing the system this week.

“Once we know that that works, that’s probably the final element,” said Jill Kidd, director of nutrition services.

Although the data survey form doesn’t look much different than the free-and-reduced meal application, the two have different requirements. For example, under federal law food service departments cannot pay for the processing of the data surveys as they do for the applications. Instead, those costs must be shifted to other departments.

While students will still get free meals under CEP even if their parents don’t fill out the data surveys, districts have a vested interest in making sure the surveys are completed. Without accurate data, they risk losing money. In Pueblo, state at-risk funding totals nearly $12 million for the district’s nearly 6,000 at-risk students.

“I certainly wouldn’t impact the general fund to make my job easier,” said Kidd.

She’s hopeful that with reminders and outreach to parents, the surveys will be completed and there won’t be a negative budget impact. Still, she’s aware that concerns about at-risk funding and the complexities of the data survey are on the minds of colleagues in other districts. She recounted how an informal poll among several other food service directors recently revealed that Pueblo wasn’t going to have much company in its pursuit of CEP.

She said the message from her colleagues was “Go ahead Jill, you can be a trailblazer.”

Correction: An earlier version of this article incorrectly stated the name of the “Community Eligibility Provision” and the June 30 application deadline. It also incorrectly stated that the Family Economic Data Survey is a one-per-child form rather than a one-per-family form.