Updated Guidance on Implementing ESEA Programs Without Complete NSLP Data

The Department of Education released an updated fact sheet on implementing ESEA programs without complete National School Lunch Program (NSLP) data from SY20-21 and SY21-22. The guidance provides some additional options for state education agencies (SEAs) and local education agencies (LEAs) to calculate eligibility and allocations that are usually based on NSLP data.

Most notable for district leaders are alternate measures to use for Title I allocations within LEAs. To the extent that NSLP data from SY20-21 and SY21-22 are not available, for SY22-23 LEAs may use:

• Medicaid or TANF data or a composite of data from these two sources from SY20-21 for SY21-22 within-LEA allocations or from SY21-22 for SY22-23 within-LEA allocations;
• The best available NSLP data, which may be from SY19-20;
• NSLP data from SY20-21 or SY21-22 that may be accessible (e.g., counts of children identified through direct certification, which may be adjusted by 1.6 for within LEA allocations to account for the lack of household applications);
• A combination of the best available NSLP data from SYs 19-20, 20-21, and 21-22;
• A composite of the NSLP, Medicaid, and TANF data listed in the previous bullets; or
• Data from a poverty survey conducted by the SEA or LEA that replicate NSLP, Medicaid, or TANF data.

The guidance also includes other measures that SEAs may use to calculate children from low-income families for the Rural and Low-Income School Program, Title I and II allocations for specials LEAs, Title I allocations for small LEAs and reporting and accountability.  

Additionally, the document clarifies that under waivers issued by USDA for school year 2021-2022, the At-Risk Afterschool Meals Component of Child and Adult Care Food Program may operate simultaneously with the SSO during the regular school year.