Alaska State Library > E-rate

Begin work on your student eligibility data as soon as school starts. It will not be needed until the filing of the Form 471 in November or December, but it is time consuming. Student Eligibility data may be obtained by using one of the 3 measures:

1. National School Lunch Program questionnaire,
2. A survey of your own design that meets the criteria outlined below, or
3. Apply to the Dept of Agriculture for Provision 1, 2 or 3 measures

Once you have determined which students in your school(s) meet the income eligibility guidelines for free or reduced lunch you will use those numbers to determine your E-rate discount. To determine the discount for a facility that has classrooms and a fixed student population, divide the number of students eligible for NSLP at the school by the total number of students at the school. Use this number and the urban or rural status of the school to look up the discount on the discount (link below). If a site has a student population that varies from day-to-day or over time, use a "snapshot" of the student population. To determine a snapshot, choose a particular day and calculate the percentage of the student population in the classroom that is NSLP-eligible and take that percentage to the discount matrix. Be sure to maintain documentation of your calculation.

With the exception of the Anchorage School District, all schools and districts within Alaska are considered rural when using the USAC discount matrix to calculate your discount. To determine the discount for a school facility that has classrooms and a fixed student population, divide the number of students eligible for NSLP at the school by the total number of students at the school. Use this number and the urban or rural status of the school to look up the discount on the USAC discount matrix, which can be found at: http://www.universalservice.org/sl/applicants/step05/discount-matrix.aspx

In general, the discount for a non-instructional school facility is the Weighted Average Discount of the school district in which it is located.

This discount calculation will be needed when filling out Block 4 of your form 471. You will need a discount calculation for each building you are applying for funding for.

NSLP data collection

If your school has a National School Lunch Program, those statistics are available to the SLD on the EED website (see link to NSLP data at left). You should consider the numbers turned in to State EED Child Nutrition as the minimum number for discount setting purposes. Remember that your district is entitled to count eligible students, not merely the NSLP enrolled students. You may report higher numbers if you can justify them. Send your explanation of higher numbers in with your Item 21 attachment for your 471.

Ways to increase your count of eligible students

• Sibling match: Increase your discount percentage by identifying eligible students at high and middle schools. Older students are reluctant to enroll in the National School Lunch Program resulting in an undercount. Identify them by matching participating siblings, usually elementary students, using addresses or phone numbers as well as family names. Keep the documentation of your matching system with your records.
• Participation in other Federal Programs: A Direct Eligibility List of students who qualify for Aid for Dependent Children benefits or the equivalent Alaskan programs, Migrant Education, TANF and ASSAP; for food stamps; for Supplemental Security Income (SSI); for Medicaid; for Low Income Home Energy Assistance Program; or tuition assistance is sent to each district with a school lunch program. These students also qualify and may be counted as eligible without any further paperwork. A Categorical Eligibility List of homeless, migrant, and runaway children also provides more names for your qualified list. Check to be the children on these lists are not already included in your NSLP forms, as they can not be counted twice.
• Students who are in foster care as well as those who are wards of the state because they are in the Juvenile Justice program are eligible.

The district is entitled to combine numbers gathered by any of the above methods so long as no one is double counted.

Surveys

The most common way of determining student eligibility when NSLP data is either not available or does not give an accurate picture of school/community income is the income survey. Information about income may be part of another collection of facts already gathered, such as scholarship applications or other forms used in schools, or it may be specifically collected for E-Rate purposes by using a survey. A school or district may NOT use the NSLP form as their survey. There are specific rules about using survey data that can help to increase the numbers gathered.

Surveys developed by an applicant must be based on the following guidelines:

• The survey must be sent to all families whose children attend the school.
• The survey must, at a minimum, contain the following information:
  • Name of family and students
  • Size of the family
  • Income level of the family

Income data (or eligibility data based on income) from a survey used to support a discount level for a funding request cannot be older than two years before the start of the funding year. For example, the data gathered from an income survey done in September 2007 can be used for funding requests for Funding Year 2008 and Funding Year 2009, but not for Funding Year 2010. Therefore, surveys must be done at least every other year. You should maintain a record of the survey documentation collected to assist in responding to PIA inquiries. Such records should be maintained for a period of five years after the last day of delivery of the discounted services.

Income data should be collected based on income received by the household during the month before the month in which the survey is conducted. However, a household can project its annual rate of income for the current year based on the income data that is available.

Information on the definition of income under NSLP, other income guidelines of the program, and the "Eligibility Guidance for School Meals Manual" can be obtained from the National School lunch program website.

Gathering survey data

Surveys are sent to HOUSEHOLDS, not individual students. If a school has sent a survey to the households of all of its students, and if it receives a return rate of at least 50 percent of those questionnaires, it may use that data to project the percentage of eligibility of all students in the school. For example, a school with 100 students sent a survey to the 100 households of those students, and 75 of those households returned the questionnaire. The school finds that the incomes of 25 of those 75 households are at or below the income eligibility guidelines for NSLP. Consequently, 33 percent (25/75) of the students from those households can be counted as eligible for NSLP. The school may then project/extrapolate from that sample to conclude that 33 percent of the total enrollment, or 33 of the 100 students in the school, can be counted as eligible for NSLP.

If less than 50 percent of your households return your questionnaire, you may not project/extrapolate your eligibility. You may only report the actual numbers represented on your questionnaire.

Other Acceptable Mechanisms for Collecting Data

Collecting data from existing sources

Schools may also use existing sources of data that measure levels of poverty, such as TANF or need-based tuition assistance programs. However, these measures are acceptable for E-rate purposes only if the income eligibility guidelines are equal to or below the income eligibility guidelines for NSLP.

Matching siblings

If a school has established that the household income of one of its students is at or below for NSLP, the siblings of that student may also be counted as eligible for NSLP. For example, an elementary school has established, through a survey, that a student's household income is at or below the IEGs for NSLP. That student's household also has a brother and a sister who attend the local high school. The high school may use the status of the elementary school sibling to count his high school siblings as eligible for NSLP, without collecting its own data on that household.

Combining data from different sources

Unless a school is able to use a projection based on a survey as described above, data used to support a particular discount level must be collected and verifiable on an individual student basis. However, data from multiple sources can be combined to complete the count of students eligible for NSLP. For example, a school with 100 students sent a survey to the 100 households of these students, and 40 of those households returned the survey. The school finds the income of 20 of those 40 households, each of which has one student in the school, are at or below the income eligibility guidelines for NSLP. This rate of return (40%) is too low to allow a projection based on that survey. However, the school has also matched 10 students not represented in the survey responses with siblings who are eligible for NSLP, and the school has verified that 15 additional students not represented in the survey responses participate in a need-based tuition assistance program that requires the household income of participants to be below the income eligibility guidelines for NSLP. The school can combine the individual results from these three sources to conclude that 45% of the total enrollment, or 45 (20+10+15) of the 100 students in the school, are eligible for NSLP. The school must be able to verify that it has counted each eligible student only once.

Students from families that meet an income test based on the same income levels used in the National School Lunch Program may be included in your count of eligible students. A chart of income levels and family sizes for the next school year may be obtained at The National School Lunch Program website. Be sure to use the income levels marked as Alaskan (which are more generous than most other locations). and use the Reduced Lunch levels rather than the Free Lunch levels.

You may NOT use NSLP forms as survey instruments, nor should you attach your survey to distributed NSLP forms.

Organize your survey to collect information on the entire families, rather than by students. Send a single survey to each family (or if it is more convenient to send surveys home with students, prepare to consolidate the returns back into family units. You must be able to identify specific children rather than anonymous groups in your records, though student names will be held in the strictest of confidence.

Surveys must be kept confidential and families should be assured that they will be held so, but they must be retained for 5 years (beyond the last date of service) to support any audit that may be done. It is more than likely that the Schools and Libraries Division will ask for a copy of the instrument you use for the survey and for a signed letter from a district authority attesting to the correctness of the results summary.

In actual data gathering, surveys included as part of another data collection effort seem to get the most results. Consider including surveys in school year registration procedures, or in family back-to-school activities, or sent home along with federal impact cards.

If sending forms to 100% of families has not resulted in sufficient return, increase survey response numbers by choosing (or creating) an event that will bring a large number of parents to the school and have the superintendent or other administrator do a personal plea explaining why it is so important that these surveys be done. Hand out forms as people come in and collect them at the door before people leave. Ask your PTA officers to call a non-responsive household and make a personal plea for the return of the form. If you explain the money involved and compare it to the average fund raiser, perhaps your PTA will think of other ways to get surveys back. Sample surveys can be adapted to your own uses. Be sure to use the Dept. of Agriculture site (above) to update the income guideline numbers on your form each year.

Miscellaneous issues on discounts

The SLD will have access to any school lunch numbers you have turned in to the State EED Dept. if you are using NSLP data to determine your discount. They will question any rise in those numbers, but will accept any additional numbers of eligible students, provided so long as you can justify them with records of the above activities. (Maintain these records for 5 years.)

If 100% of families are not surveyed or if you fail to get at least a 50% return, you may still use the returned forms as "questionnaires" to count the individual students listed on them. However, you cannot use those counted students to interpolate your numbers onto students who did not answer the survey.

Discounts may be affected (either adversely or favorably) by whether a school district is considered to be a single or multiple site district. Those districts that may be able to make a choice of definition based on the number of programs housed in a single building or on a single campus should look at their discount numbers under both scenarios. Consult with Eddy Jeans of the State EED Department (907-465-8679) about the state's classification of your district. The SLD will accept the state's classification.

Because of the legal structure of CHARTER SCHOOLS in Alaska, districts with charter schools should treat them just as every other school site in figuring discounts.

If you are building a new school, in order to receive funding for services received there during the construction year and for Internal Connections such as wiring and its installation, you may use the weighted district average as the school's individual discount, since you do not have students assigned to the building yet to form its own count.

Send in an explanation for any numbers which vary from the numbers on the EED site as a part of Item 21 packet.

Building a Paper Trail

You need to retain these documents for eight years in case of audit or review:

• NSLP data reported to the State of Alaska which you used to determine your discount calculations.
• A spreadsheet containing students and their reason for eligibility if you augmented your NSLP numbers with alternative efforts.
• Any “snapshot” data used to determine eligibility of a facility
• Any survey used if NSLP data was not available or employed.
• All surveys collected by households
• A spreadsheet containing students and their reason for eligibility if you augmented your survey numbers with additional means of counting.