Assessing the “Survey Method” to Establishing Student Eligibility for School Meals  in Child Nutrition Reauthorization - April 29, 2010

Compiled by Rachel Meeks, Greater Philadelphia Coalition Against Hunger, Kathy Fisher, Public Citizens for Children and Youth, and Jonathan Stein, Community Legal Services

ARGUMENTS FOR THE SURVEY METHOD

1)  The survey is statistically the most accurate way to count the number of low-income children entitled to free/reduced price school meals.  Successful models should get preserved, not only as an option for Philadelphia and other school districts that may wish to use it for school meals, but also because its value as an alternative that could be used in other means-tested benefits programs. The survey model is an effective means of reducing paperwork and easing individual eligibility hurdles that should not be discarded.

2)  The survey has a 20 year history of success, qualifying 67,000 Philadelphia school children for free meals, substantially increasing enrollment percentages for lunches and breakfasts, and saving millions in costs over time. While other proposed measures of “community eligibility” in the Senate CNR bill are worth exploration, they are untried, and need substantial future improvements.  If the only method proposed, “provision 4” (using direct certification) fails, schools would have to wait another five years for the opportunity to amend federal legislation. 

3)  SNAP (Food Stamps) remains difficult to access, especially in households with mixed immigration status, limited English proficiency, working parents, and/or income that results in a very small SNAP benefit.  A community eligibility provision that relies solely on SNAP enrollments could result in our most vulnerable children missing out on food assistance twice – missing out on SNAP benefits AND universal school meals. 

Example: According to the 2006-2007 Survey by The Reinvestment Fund, Penrose Elementary School in Southwest Philadelphia had 38% of students directly certified (under the proposed 40% “paperless” threshold). Yet, it had 76% of children eligible for free/reduced meals based on the survey, thus currently qualifying the school as universal service. Lesser SNAP uptake does not mean families are not poor and children do not need meals.

4)  Because the survey counts the number of poor children attending a particular school with a high degree of accuracy, it is used for distribution of other critical poverty-related federal funds (e.g. Title I funding).

RESPONSES TO CRITICISMS OF THE SURVEY METHOD

1)  The COB score for the survey is not known and its cost may compete with other provisions getting into the final CNR bill.

Response: Legislation can limit the survey option to a specific number of jurisdictions (e.g. 20 largest school districts or any district with over 150,000 students).

2)  Philadelphia’s School District may determine that the proposed provision 4 (direct certification & multiplier of 1.6) may be more advantageous than continuing the survey method.

Response: The multiplier can fall after the first year to 1.3, and remains subject to discretionary USDA adjusting. Excluding the successful survey method now will make it more difficult to revert back to the survey if Provision 4 proves less successful than planned. 

Response: Regardless of the Philadelphia School District’s decision, the survey should be protected to offer all school districts the option, and flexibility to employ it. It is an effective means of reaching eligible children.

3)  Advocates can press to increase SNAP enrollments to maintain universal service without preservation of the survey. Only 10-20 schools may be under 40% direct certified.

Response:  SNAP eligibility is significantly more difficult to apply for/receive than school meals, and there may be some schools where families are very poor but still ineligible for SNAP benefits. Many families also churn on and off the program. Sole reliance on enrollment in SNAP is not the only long-term, reliable solution to maintaining universal service in all high-need schools.  

4)  Sens. Casey and Specter seeking a floor amendment would use political capital and force a vote that might lose, diminishing the chance of other improvements to the bill (such as fixing the multiplier at 1.6 instead of a variable rate). 

Response:  If we get a low CBO score on the survey with limitations on the number of jurisdictions that can use it, Sens. Casey or Specter can ask Sen. Lincoln for a Managers Amendment that wouldn’t require a vote. Other states like Ohio (Sen. Brown) and Illinois (Sen. Durbin) with very low direct cert. take-up can be supportive of options like survey method.

Response: An alternative approach would be to have Senator Specter offer a floor amendment to include the survey method, while Senator Casey as a member of the Agriculture Committee works to ensure the strongest Direct Certification provision possible.  

5)  It is not “fair” that Philadelphia has enjoyed a special provision and/or Philadelphia is getting higher reimbursement rates than they deserve. 

Response: The way to correct any perceived “unfairness” is to offer the Philadelphia model to more jurisdictions. Reimbursements have been proper and USDA approved. See Ira Goldstein memo on scientific/statistical rigor and accuracy of Philadelphia’s 2006-07 survey.

6) Other cities don’t have Dr. Goldstein’s or other expertise, or the money to do a survey. USDA does not want different surveys in use or to be pressured to accept lower standards of survey results because a school district paid for the survey upfront. 

Response: Limiting the number of jurisdictions that can use the survey would help with USDA’s concerns regarding workload. Any new district using the survey will have a good reason to believe they can meet established targets. If, for some reason, they don’t meet targets, they could be allowed to use paper application data from the previous year to enroll in another paperless provision (Provision 2 or 4). 

7)  Even if the survey method is successfully preserved, USDA may continue to resent its use and force school districts to spend lots of money to accomplish a very high (70-80%) response rate. 

Response:  This concern backs up the argument for multiple paperless, community eligibility options.  School districts will have the option to use direct certification to accomplish their goals. Senior Obama appointments to USDA – as well as future administrations – have yet to hear directly about the accuracy of the survey here, and adequacy of response rates and methodology.  Fear of potential USDA’s resentment should not keep this successful model from being a legitimate option.