blogger Layla Bonnot is a research intern at the Thomas B. Fordham Institute.

Is the number of free and reduced-price lunch
participants an accurate proxy for the number of poor kids in America’s schools? New Jersey’s acting education
commissioner, Chris Cerf, isn’t so sure. A recent article in The Star-Ledger highlights Cerf’s two concerns: first, that the
self-reported basis of Free and Reduced Lunch Program (FRLP) participation
makes the count prone to errors and—potentially—fraud, and second, that this
number alone might not be a reliable proxy for the number of students living in

Mr. Cerf, I wouldn’t throw out school lunches quite yet—maybe just add a few other ingredients into the mix.
Photo by U.S. Department of Agriculture.

The issue of fraud in the lunch room pops up every couple of years. Detailed audits
have shown that some students who should receive benefits do not, some parents or
schools make honest mistakes on the application, and yes, there are some
instances of fraud. Given our current situation of squeezed budgets and a
National School Lunch Program that cost $9.7 billion in FY 10 and relies on
self-reported income, those small instances of fraud can really add up (A 2009 2007 Mathematica study estimated the cost of errors close to $1 billion). It
would be impractical, very time-consuming, and costly to audit every applicant
in every district, but per USDA guidance, state chiefs can request that each
district audit three percent of its participants whose incomes border the FRLP
qualification level.

Requiring income verification from each participant
would clamp down on fraud. This is already a requirement for SNAP recipients (whose children are auto-enrolled in the FRLP),
but would increase the burden of the program for school districts—both in terms
of time and money. Instead, the most promising solutions for improving accuracy
seem to be quite simple: a streamlined application, additional training for
those who process applications, clear consequences for fraud, and actual
enforcement of those consequences. The optics of prosecuting parents for
seeking help feeding their kids are as troubling as recent cases of mothers
being arrested for “stealing” educational services, of course, and there is
real danger that parents could be punished for an honest mistake such as not
understanding the form or being bad at arithmetic.

The fraught nature of using FRLP participation
as a measure of poverty is also a recurring issue in the news. David N. Bass’ piece
in Education Next makes the point
that using
FRLP to drive education funding leads to over-reporting by schools to ensure
additional funding from the district, state, and federal levels. The Shanker
Institute’s Matt Di Carlo and others argue that
the measure is too limiting, fails to shows degrees
of poverty on either side of the qualification line, and should include other
out-of-school factors.

In fact, while the Garden State’s funding system
uses the FRLP count as its only measure of poverty, many other states either use it along
with a combination of other factors or do not use it at all, relying instead on
U.S. census data or enrollment in the Temporary Assistance
for Needy Families
(TANF) program. Using TANF or census data alone is
problematic; TANF’s income requirement is much lower than FRLP and would
identify a lower number of people in poverty than the free lunch program, while
census bureau data is updated infrequently.

A compromise might be for New Jersey to look
into a using a poverty formula (see the ‘Highly
Impacted Schools Program
’ in Utah) that gives weight to a number of factors,
such as the number of ELL, special education, and FRLP participants, to give an
overall measure of how much money should reach a given school for its entire
student population. Respectfully, Mr. Cerf, I wouldn’t throw out school lunches
quite yet—maybe just add a few other ingredients into the mix

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