USDA PROPOSED ELIMINATION OF THE SCHOOL DISTRICT`S

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USDA PROPOSED ELIMINATION OF THE
SCHOOL DISTRICT’S UNIVERSAL FEEDING PROGRAM
FACT SHEET AND TALKING POINTS
10/22/2008
FACTS:
 In a letter dated August 12, 2008, James Harmon, Regional Director,
Special Nutrition Programs, USDA, informed Pa. Department of
Education’s (PDE) Vonda Fekete, State Director for the Child
Nutrition Programs that the USDA intends to terminate the Universal
Feeding Pilot Program (the “Paperwork Reduction Pilot”) that has
operated in the School District of Philadelphia (SDOP) since 1991.
 In cooperation with the USDA’s Food and Nutrition Service, the
District began the Universal Feeding Program in 1991 in order to
develop a more streamlined alternative method for counting and
claiming meals served under the National School Breakfast and
School Lunch Programs.
 In essence, the program utilizes a third-party socioeconomic study to
determine school-wide eligibility for participation in the Breakfast and
Lunch programs. This is done in lieu of requiring separate
Application for Meal Benefits from each household.
 Prior to 1991, individual Application for Meal Benefits were sent to
parents and households to enroll students in the meal program. Once
completed, parents submitted the application to the School District,
who in turn would determine through various forms of data and a
multitude of criteria, whether an individual child or household would
be eligible to receive meals for free or at a reduced cost if the family
met the necessary eligibility guidelines.
 Under the Universal Feeding Program, the process of determining
eligibility was re-engineered and streamlined. Rather than rely on
individual determination of applicants, a comprehensive
socioeconomic study is used to determine overall eligibility for
students. This method eliminated cumbersome paperwork and
USDA PROPOSED ELIMINATION OF THE
SCHOOL DISTRICT’S UNIVERSAL FEEDING PROGRAM
FACT SHEET AND TALKING POINTS
10/21/2008
administrative layers for parents and for the School District to ensure
that every child is able to receive meals at no cost.
 The District recently invested $550,000 to conduct a new socioeconomic study, carried out by The Reinvestment Fund, in order to
establish updated eligibility percentages for free and reduced price
meals that went into effect with the 2007-08 school year.
 The USDA agreed to allow the District to use its current socioeconomic study data to determine eligibility through the 2009-10
school year.
 The August 12, 2008 USDA letter informed the District that
beginning in September 2010 (the 2010-011 school year), the District
will be required to return to the standard household application system
for counting and claiming meals.
 The District has more than 167,000 students in schools it operates
throughout the city, not including charter schools. Currently, the
District serves an average of 50,000 breakfasts and 115,000 lunches
every school day.
 If the Universal Feeding program is eliminated, thousands of
Philadelphia students will have to submit an Application for Meal
Benefits in order to continue to receive free and /or reduced price
breakfast and lunch. If this happens, the District will work hard to
make sure NO students are impacted. However, the risk that certain
children will not receive important nutritional services will be much
greater than it has been under the Universal feeding program.
 The School District’s Office of Food Services estimates that about
67,000 of the 120,000 students currently eligible under the guidelines
established by the socio-economic study would be required to fill out
the Application for Meal Benefits in order to receive meals for free or
at a reduced cost during the 2010-11 school year. The remaining
students (about 53,000) will automatically be eligible to receive a
lunch and/or breakfast at no cost because they are already known to be
in families receiving food stamps and/or Temporary Assistance to
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USDA PROPOSED ELIMINATION OF THE
SCHOOL DISTRICT’S UNIVERSAL FEEDING PROGRAM
FACT SHEET AND TALKING POINTS
10/21/2008
Needy Families (TANF) benefits. This process is called “Direct
Certification.”
Talking Points:
 The District is disappointed with the decision by the USDA. We will
continue to fight to reverse the decision because we believe it replaces
an efficient and streamlined process and policy with an inefficient and
ineffective process that costs more money to implement, and runs a
greater risk of denying essential nutritional services to eligible
Philadelphia children. At the same time, however, we are creating
contingency plans for this situation to ensure that our children’s needs
will be met.
 On September 26, 2008 PDE sent a letter of appeal to the USDA
requesting reconsideration of the decision to discontinue the Universal
Feeding program. In a letter dated October 20, 2008 the USDA
notified PDE that the appeal has been rejected.
 SDOP sees three major problems with the USDA’s recent decision:
Problem #1: Eliminating Universal Feeding will have a negative
impact on kids in Philadelphia.
 If the USDA’s decision goes into effect beginning September 2010,
this is likely to have a negative impact on students, District Food
Services operations, and the School District as a whole.
 Thousands of households within the District have not had to complete
an Application for Meal Benefits for nearly 17 years. This is an entire
cycle of students from kindergarten through twelfth grade.
 During those 17 years, all students in the Universal Feeding sites have
eaten at no cost and, as a result, more students are eating a
nutritionally balanced meal, which is the foundation for preparing a
child to learn.
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USDA PROPOSED ELIMINATION OF THE
SCHOOL DISTRICT’S UNIVERSAL FEEDING PROGRAM
FACT SHEET AND TALKING POINTS
10/21/2008
 Only the District’s neediest schools participate in the Universal
Feeding program—200 of the District’s more than 280 schools.
 In the first year of the Universal Feeding pilot the district realized a 14
percent increase in lunch participation in elementary schools, a 45
percent increase in middle schools and 180 percent increase in high
schools. Overall breakfast participation increased by 26 percent. The
application process would negate the positive effects of the pilot
especially at the middle and high school levels.
Problem #2: Expected reduction in the Free and Reduced
Breakfast/Lunch program eligibility could adversely impact
Philadelphia’s ability to receive funding for other federal and
state programs
 A decrease in the free and reduced price eligibility percentages will
have widespread impact since School District eligibility for other
grant funding is often based on the number of low income students in
the District, which is determined by proxy by utilizing National
School Breakfast/Lunch Program data. Therefore, a decrease in
eligibility percentages will cause the School District to lose millions
of dollars in other state and federal grant funding.
 For example, Federal E-rate funding for School District educational
technology is tied directly to the free and reduced cost meal eligibility
percentages.
 Title 1 funding is distributed to buildings within the school district
based upon the number of low-income students.
Problem # 3: Changing the application process will increase
bureaucratic delays, increase paperwork and unnecessarily complicate
the eligibility process.
 The original name of the Universal Feeding pilot was the “Paperwork
Reduction Pilot” aimed at streamlining a paper-intensive and
prolonged process.
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USDA PROPOSED ELIMINATION OF THE
SCHOOL DISTRICT’S UNIVERSAL FEEDING PROGRAM
FACT SHEET AND TALKING POINTS
10/21/2008
 Given the District’s experience with the old household application
system, it is highly likely that requiring the District to once again
collect individual household applications may result in thousands of
eligible children not receiving a meal because of the added layers of
bureaucracy that accompany such an eligibility process.
 The District would incur significant direct and indirect cost in training
over two hundred principals or designees to the Application for Meal
Benefits process. In addition, a new generation of parents would for
the first time be introduced to the old process, adding confusion and
additional costs.
 Under the streamlined process, the eligibility data collected by the
2006-07 socio-economic study is valid for four years. Elimination of
the program will necessitate redistribution of funds, currently used to
enhance existing programs, to offset increased cost associated with
meal benefit application process.
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