Authorizers May Need to Remind Schools of Important December 31 Funding Deadline

A combination of this year’s Average Daily Attendance (ADA) “hold harmless” and the extension of the federal waiver to allow the summer meal program through June 30, 2021, may pose a funding pitfall for unwary public schools, including charter schools. Authorizers may want to make certain that their authorized schools are aware of a December 31, 2020 deadline for collecting data they will need to qualify for supplemental and concentration grant funding.

The situation is explained in the November 17 letter below from the California Department of Education (CDE). The state’s ADA “hold harmless” does not apply to the unduplicated pupil percentage, which drives supplemental and concentration grant funding based on the Unduplicated Pupil Count (UPC). Depending on enrollment, especially of free and reduced-price meal (FPRM)-eligible students, these funds can be a  significant portion of a school’s revenue.

• CDE Nov. 17, 2020 letter: “2020-21 Requirements for Collecting Free and Reduced-Price Meal Eligibility Data Used to Determine Supplemental and Concentration Grant Funding”

The attachment to the CDE letter includes a link to CDE’s Local Control Funding Formula (LCFF) online FAQs page, which provides a variety of alternative household income form prototypes for schools to use in lieu of the forms most schools are not now collecting because meals under the summer program are free. The forms include translations into various languages. They can be distributed and collected online, and electronic signatures are acceptable.

• CDE LCFF FAQs, with alternative forms

Due to the extension of the summer meal program, many school agencies are finding it difficult gather the necessary documentation to determine FRPM eligibility as families may be less motivated to complete and submit forms when doing so is not necessary for their children to qualify for FPRM. in addition, time is tight, especially with the holidays upon us. Fortunately, the attachment to CDE’s letter also indicates that schools are allowed to collect income information from families by phone:

• In 2020–21, LEAs may complete an alternative household income form on behalf of a student’s household by collecting the required information over the telephone provided the LEA documents 1) the date, time, and name of the student’s adult household member spoken to, and 2) the date, time, name, and signature of the LEA staff member collecting the information.

Food service staff also may assist in the distribution and collection of the alternative household income forms, provided that time spent on this activity is not charged to food service funds.

The CDE letter was sent to charter school administrators in addition to county and district superintendents, but authorizers that have not already done so may want to verify that their schools have documented eligible students or are on track to do so by December 31.

The eligibility data must be maintained for audit purposes, and schools may want to consider asking their auditor to review in advance this and any forms or processes to be relied upon.

Even if schools that are behind at this point need to incur added expenses to collect this data over the holidays, they may calculate that the amount of funds at stake could well justify the expense.

If you have questions, please contact CCAP Executive Director Tom Hutton at tom.hutton@calauthorizers.org