Superintendent’s Memo #104-14

State seal, Commonwealth of Virginia

Department of Education

April 25, 2014

TO:  Division Superintendents

FROM:  Patricia I. Wright, Superintendent of Public Instruction

SUBJECT:  Identification of the Economically Disadvantaged Subgroup for Title I Accountability Under the Community Eligibility Provision

Superintendent’s Memorandum Number 066-14, Community Eligibility Provision (CEP): Guidance and Procedures for School Year 2014-2015, dated March 21, 2014, provides information on the Community Eligibility Provision (CEP), which provides eligible divisions and schools with high percentages of low-income children the option to offer free school meals to all children in those schools.  Under CEP, identified students are defined as students certified for free meals through means other than individual household applications including: 1) students who are directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF); and 2) homeless, runaways, migrant youth, Head Start, Even Start and foster children approved by means other than a meal application.

Each state and division that receives funding under Title I must assess and report annually on the extent to which the subgroup of economically disadvantaged students is making progress toward meeting the state’s academic achievement standards.  The U.S. Department of Education guidance on CEP, Community Eligibility Provision and Selected Requirements Under Title I, Part A, includes two options from which states may choose to identify students in CEP schools in the economically disadvantaged subgroup for reporting and accountability purposes:

Option 1: A state may include only students identified through direct certification in the economically disadvantaged subgroup.

Option 2: A state may base reporting and accountability on all students in a Community Eligibility school, meaning the economically disadvantaged subgroup would be the same as the “all students” subgroup, or 100% of the student enrollment.

Beginning with accountability results for the 2015-2016 school year, based on assessments administered in the 2014-2015 school year, Virginia will implement Option 1, the use of direct certification data for the identification of the economically disadvantaged subgroup, for accountability purposes in all CEP schools.  This option directly aligns with Virginia’s existing federal accountability design.  Annual measurable objectives (AMOs), as described in Virginia’s ESEA flexibility plan, are intended to increase subgroup accountability for the purpose of providing targeted interventions to groups of students most in need of support.  Option 1 allows the state, divisions, and schools to continue to focus on the most underperforming groups of students while maintaining transparency in reporting and accountability.  Because schools participating in the CEP program are prohibited from distributing and collecting individual household applications to determine free- or reduced-lunch status, these schools must use direct certification or the other data sources identified above to identify a student as economically disadvantaged for reporting and accountability purposes beginning in the 2014-2015 school year.  

Schools not participating in CEP will continue to use traditional methods for the identification of the economically disadvantaged subgroup for accountability purposes as allowed under Title I and that comply with the data elements outlined in the Student Record Collection (for example, student eligibility for Free/Reduced Meals, students receiving TANF, and students eligible for Medicaid).

The Virginia Department of Education will provide additional guidance on the impact of CEP on the identification of Title I schools and accountability during future technical assistance opportunities. 
Questions about the identification of the economically disadvantaged subgroup in participating CEP schools should be directed to Veronica Tate, director, Office of Program Administration and Accountability, at (804) 225-2869 or, or to Dr. Lynn Sodat, Title I coordinator, at (804) 371-2934 or