How to determine school poverty rates for Title I allocations

Officials are conducting outreach to potentially eligible families to identify as many children who are eligible
By: | November 2, 2020
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The extension of the USDA free meals program through the end of SY 2020-21 was met with overall relief by educators and stakeholders nationwide.

However, some are concerned that they will see a drop in applications for the school nutrition programs that some districts use to determine Title I allocations for schools or attendance areas.

For example, school officials in Mesa Public Schools in Arizona, are concerned that their application rates for free and reduced-price lunches are down, and the Title I, Part A allocations for schools will be affected.

The district uses those applications to rank and serve eligible Title I schools, and a drop in the number of applications could lead to a drop in funding levels for eligible schools in the district.


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Officials are conducting outreach to potentially eligible families to identify as many children who are eligible as possible.

Districts that use other eligible data are prepared for the potential drop in free and reduced-price meal applications.

Denise Ling, director of federal and state programming and intervention for the Berkeley CountySchool District in South Carolina, said until two years ago, when the district received the Community Eligibility Provision for several schools, her district relied on free and reduced-price lunch applications to determine Title I, Part A allocations to schools.

CEP allowed access to free meals for all students at eligible schools, a shift that caused Ling to “dig pretty deep” to determine data needed to rank and serve Title I students.

“I had been doing this job as federal programs administrator for over 20 years and had always used free and reduced lunch application counts from schools,” Ling said. “At that point, I no longer had a consistent data point for all of my schools, so I started looking at what people were doing in other districts and other states, and a lot of folks were using what’s called the ‘Pupils in Poverty’ count.”

The count includes students who are eligible for different federal programs, including students who are enrolled in Medicaid or are in the Supplemental Nutrition Assistance Programs, as well as the number from military families, students who are experiencing homelessness, and students in foster care, among others.

“I went to the superintendent and talked about this other consistent data point because we could pull it out of our PowerSchool program, [which is] our student information systems program,” Ling said. “We moved to that count for all of our students.”


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While Ling said she is not worried about the free and reduced-price lunch count in her district, “the one that probably does worry me is that certain populations are not as prone to registering for those types of [assistance] programs as others. I believe there will be a proportion of not only our students, but other students that will be somewhat transient during COVID-19.”

Measures of poverty for Title I, Part A

ESEA Section 1113(a)(5) allows local educational agencies to select one of five measures of poverty to determine the percentage of eligible children from low-income families that reside in their attendance areas. They are:

  1. Census counts of children from families below the poverty level. This is the same data the U.S. Education Department uses to allocate Title I, Part A funds to districts.
  2. Counts of children who are eligible for free and reduced-price meals.
  3. Counts of children whose families receive assistance under the federal Temporary Assistance for Needy Families program.
  4. Counts of children eligible for Medicaid.
  5. A combination of two or more of the preceding data sources.

An LEA must use the same measure or measures of poverty to identify eligible school attendance areas, rank schools by poverty level, and determine a per-pupil allocation for each area.

Charles Hendrix covers education funding and other Title I issues for TitleIAdmin.com, a DA sister publication.