How Schools are Identified for Title I
Process
Title I status is determined annually. Each year, the district must put all of its schools in rank order from highest to lowest based on poverty measures. Any school with a poverty measure 75% or higher is automatically designated as a Title I school. After identifying schools with 75% poverty or higher, MCPS must decide how many additional schools will be served using TItle I funds.
The number of schools who will be served is based on the amount of Title I funding MCPS receives. The amount of funding fluctuates each year based on changes in enrollment and other economic factors like census poverty data. Schools enter or exit Title I status each year based on changes in their poverty percentage, where they fall in rank order, and the number of schools that can be served through the district’s Title I allocation.
Poverty Measures
Traditionally, Free and Reduced-priced Meals (FARMS) application data has been used as the poverty measure to identify Title I schools. For school year 2024-2025, a school’s poverty data is calculated one of two ways, depending on the school’s Community Eligibility Provision (CEP) status.
- Poverty calculated using direct certification data: A multiplier of 1.6 is applied to the number of students with direct certification as of October 31, 2023, and then is divided by September 30, 2023, enrollment to determine its percent of poverty. This formula is applied to the CEP schools.
- Poverty calculated using Free and Reduced-priced Meals data: A non-CEP school uses the number of children qualifying for free or reduced-price meals as of October 31, 2023, and then is divided by September 30, 2023, enrollment to determine its percent of poverty. This formula is applied to non-CEP schools.
Find out more about the Community Eligibility Provision and a list of schools who operate under this provision here.
Direct Certification means that students automatically qualify for free meals based on their household’s participation in the Supplemental Nutrition Assistance Program (SNAP), Temporary Cash Assistance (TCA) program, or are identified as Foster Free, Head Start Free, or Medicaid Free.
Frequently Asked Questions
- Title I Eligibility and Determinations
- Free And Reduced-price Meals Systems (FARMS)
- Community Eligibility Provision (CEP)
Title I Eligibility and Determinations
Question: What are the Title I eligibility requirements?
Answer: Title I eligibility is determined based on a school’s poverty data. Each LEA is required to rank all of its school attendance areas according to their percentage of public school children from families with low income. The district must put all of its schools in rank order from highest to lowest based on their percentage of poverty. Any school with 75% or higher must be served using Title I funds.
Question: What data is used to determine Title I designation?
Answer: Traditionally, Free and Reduced-priced Meals (FARMS) application data has been used as the poverty measure to identify Title I schools. For school year 2024-2025, a school’s poverty data is calculated one of two ways, depending on the school’s Community Eligibility Provision (CEP) status.
Poverty calculated using direct certification data: A multiplier of 1.6 is applied to the number of students with direct certification as of October 31, 2023, and then is divided by September 30, 2023, enrollment to determine its percent of poverty. This formula is applied to the CEP schools.
Poverty calculated using Free and Reduced-priced Meals data: A non-CEP school uses the number of children qualifying for free or reduced-price meals as of October 31, 2023, and then is divided by September 30, 2023, enrollment to determine its percent of poverty. This formula is applied to non-CEP schools.
Find out more about the Community Eligibility Provision and a list of schools who operate under this provision here.
Direct Certification means that students automatically qualify for free meals based on their household’s participation in the Supplemental Nutrition Assistance Program (SNAP), Temporary Cash Assistance (TCA) program, or are identified as Foster Free, Head Start Free, or Medicaid Free.
Question: How are Title I schools selected?
Answer: To identify Title I schools, all schools are put in rank order, from highest to lowest, based on the poverty measures. Any school with a poverty percentage 75% or higher is automatically designated as a Title I school. After identifying schools with 75% poverty or higher, the LEA must decide how many additional schools will be served using Title I funds. To do so, careful consideration has to be given to the anticipated district-level Title I allocation and the distribution of poverty percentages.
Question: What additional supports are provided to Title I schools?
Answer: Aside from the school level allocation, in MCPS Title I district-level funds are used to provide additional supports and programming for Title I schools including:
- Expansion of Head Start and Pre-K from half day to full day in selected Title I schools
- Extended Learning Opportunities Summer Adventures in Learning (ELO SAIL): summer programming for students enrolled in Title I schools
- Primary Talent Development in elementary schools: A program designed nurture talent and increase opportunities for enrichment and rigor in our youngest learners
Question: Do schools have to qualify for Title I status each year?
Answer: Yes, Title I designation is an annual process.
Question: What happens if a school loses their Title I status?
Answer: Since at least 2016, when a school transitioned from a Title I school to a Focus school, MCPS always gave each of those schools an additional 1.0 FTE classroom teacher above what the formula provided.
Question: If a school has a regional program that draws students from outside of the attendance zone, can those students be excluded to determine Title I status?
Answer: The poverty percentage to rank order schools is based on total school enrollment as of September 30th of the prior year.
Free and Reduced-price Meals Systems
Question: What is FARMS?
Answer: Students at non-CEP schools must individually qualify for free and reduced-price meals. The Free and Reduced-price Meal Systems (FARMS) is how MCPS qualifies individual students to receive free or reduced-price meals at school. Eligibility is determined annually each school year starting July 1st. Students are able to carry over prior year eligibility until a new determination is made for 30 operating days into the new school year.
Question: How do students qualify for FARMS?
Answer: A student is automatically directly certified for free meals if they are in a household that participates in the Supplemental Nutrition Assistance Program (SNAP); Temporary Assistance for Needy Families (TANF); Medicaid-Free; or if they are identified as in the Head Start program, foster, migrant, runaway, or homeless.
A student can also qualify for free or reduced-priced meals at non-CEP schools by completing a FARMS application, which is based on household size and income. Applications are available online in multiple languages as well as in each school front office.
Students enrolled in Head Start are directly certified and are able to receive free meals without any further action. Students enrolled in pre kindergarten or preschool education programs (PEP) that are not directly certified through another program should complete FARMS applications.
Question: If our assigned school collects FARMS applications, do I have to fill one out for each student?
Answer: No. Use one application for all students in your household.
Question: Can I complete an application online?
Answer: Yes. Families are encouraged to complete an online application instead of a paper application. It asks the same questions as the paper application but is also translated in multiple languages and allows for faster processing. Applications are approved by the Division of Food and Nutrition Services (DFNS) if they meet the federal income eligibility requirements.
Question: If a student was approved for free or reduced meals last year, do families need to fill out a new application the following year?
Answer: Yes. Applications are for the current school year and carry over through September 30th of the following year. If families are not directly certified, the application will need to be submitted each year to verify income requirements to determine qualification for free or reduced meals.
Question: What is official FARMS data?
Answer: Official FARMS data for non-CEP schools reflects the number and percentage of students that qualify for free or reduced-price meals as of October 31st each year. This includes both direct certification data and students approved through applications.
Community Eligibility Provision
Question: What is CEP?
Answer: CEP designation ensures all students at an enrolled school are able to receive free breakfast and lunch regardless of their individual meal eligibility. The Community Eligibility Provision (CEP) is an option in the school nutrition programs that allows schools in high-poverty areas to offer breakfast and lunch at no cost to all students enrolled in a school, ensuring access to nutrition, resulting in students being prepared to learn. This is a provision made available through the United States Department of Agriculture (USDA).
Question: What are the benefits of CEP?
Answer: The benefits of CEP are far-reaching and include free breakfast and lunch to all enrolled students, removing stigma or shaming associated with being identified as receiving free or reduced-price meals, reducing administrative burden on families to complete FARMS applications, ensuring students in CEP schools no longer accrue negative balances on their student meal accounts, and that students in CEP schools are eligible for discounts provided to students qualifying for FARMS (such as enrollment in community activities).
Question: How is CEP calculated?
Answer: To be eligible to operate CEP, a school or group of schools must have an Identified Student Percentage (ISP) of 25% or greater. The ISP is the percentage of students automatically certified for free meals due to their participation in certain federal benefits programs such as Medicaid, Supplemental Nutrition Assistance Program (SNAP), and Temporary Cash Assistance. Students in these programs are identified through a process known as direct certification. To calculate ISP, a school must count all of the students who are categorically eligible for free school meals and divide by total student enrollment. Because the ISP does not account for low-income students who are not participating in programs like SNAP, a 1.6 multiplier is applied to the ISP to determine the reimbursement rate for meals served, and to serve as a more accurate calculation for the percentage of low-income students in our schools.
Question: What does the Individual School Percentage (ISP) mean?
Answer: Once schools have the 1.6 multiplier applied to their direct certification rate, the ISP is established. This ISP determines the rate at which meals are reimbursed. If a school has an ISP of 80%, this means that while 100% of students have access to free meals, only 80% of the meals are reimbursed at the free federal reimbursement rate.
Question: Do families in CEP schools need to submit FARMS applications?
Answer: No. MCPS is not allowed to accept or process FARMS applications from families at CEP schools. All students enrolled in schools participating in CEP can receive free breakfast and lunch.
Question: How long is a school in CEP?
Answer: Once adopted, a school may remain in CEP for up to four school years without having to re-qualify, providing continuity of nutrition support to students and families. MCPS will determine schools participating in CEP annually by June 30th for the following school year.
Question: Why did MCPS start participating in CEP in the 2023-24 school year?
Answer: Schools are eligible for CEP based on the percentage of students directly certified for free meals. In 2022, the state of Maryland added Medicaid to the list of programs able to directly certify a student for free meals. This resulted in direct certification rates for many MCPS schools increasing dramatically, becoming newly eligible for CEP.
School meals were free from March 2020 through the end of the 2021-22 school year. Starting in the 2022-23 school students would have to be eligible for FARMS or pay for school meals. MCPS identified a need to continue free school meals, and through pandemic relief funding, was able to continue in 25 schools. Those funds have been exhausted, yet the need remains.
Due to Medicaid being added to direct certification, new eligibility in CEP allowed MCPS to expand free school meals, a recommendation in the Montgomery County Strategic Plan to End Childhood Hunger. MCPS adopted CEP in 58 MCPS schools in the 2023-24 school year and will continue to assess which schools participate annually.
Question: How does MCPS choose which schools will participate in CEP?
Answer: Federal regulations require school districts to use April 1st direct certification data to determine school eligibility for CEP, and that CEP elections are made by June 30th annually. Each year, DFNS evaluates April 1st direct certification data to determine which schools can be included in CEP while maximizing federal reimbursements to MCPS. The list of CEP schools is recommended to the MCPS superintendent and the Board of Education before finalizing each year.
Question: How were the schools participating in CEP for the 2024-2025 school year determined?
Answer: MCPS followed the process described above, and ranked schools in order of their population of directly certified students. With a desire to increase the number of schools providing free meals through CEP, MCPS identified the ability to expand CEP from 58 to 60 schools. The 60 schools with the highest direct certification rates were elected into CEP for the 2024-2025 school year. This included adding seven new schools into CEP, and four schools transitioning out of CEP.
Question: Does MCPS have to participate in CEP?
Answer: No, MCPS does not have to participate in CEP. However, in order to provide free meals to all enrolled students at an MCPS school, MCPS must utilize CEP. Providing free meals supports Montgomery County Strategic Plan to End Childhood Hunger which includes strategies to address childhood food insecurity which includes the expansion of free school meals.
Question: How do FARMS and CEP impact Title I?
Answer: The chart below shows the federally allowable methods to use poverty metrics in determining Title I eligibility.
Historically, the percent of students qualifying for FARMS (including those directly certified and those qualifying from income-based applications) has been used as the poverty metric to inform Title I eligibility.
CEP schools do not collect FARMS applications and instead may use the percent of directly certified students to determine the poverty metric to inform Title I eligibility. To account for the number of students who would qualify for FARMS based on income applications, options allow for the use of a federally designated 1.6 multiplier. Districts can multiply the percent of directly certified students by the 1.6 multiplier to estimate the FARMS percentage if income based applications were used.
Question: How long will the CEP multiplier of 1.6 remain in place?
Answer: The multiplier rate is tied to economic indicators. USDA has the authority to establish multipliers between 1.3 and 1.6. The 1.6 multiplier will be used for the entire time a school is in CEP, only to be updated per USDA guidance or federal regulatory updates.
Question: Are pre kindergarten and Head Start students included in the number of identified students for CEP?
Answer: Head Start students are included in the number of identified students for CEP. Students enrolled in pre kindergarten are not included in the count of directly certified students. Pre kindergarten students at non-CEP schools should complete FARMS applications.
Question: How does CEP affect Title I funding?
Answer: CEP will not impact the total amount of Title I funding received at the district level. It may impact the distribution percentages for funding received at individual school levels for schools that fall into poverty levels lower than 75%.