About the Schools and Libraries Program
Alternative Discount Mechanisms Fact Sheet
1. Primary measure for E-rate
The primary measure for determining E-rate discounts is the percentage of students eligible for free and reduced lunches under the National School Lunch Program, calculated by individual school. Students from family units whose income is at or below 185% of the federal poverty guideline are eligible for the NSLP.
The FCC’s rationale for using NSLP data is as follows:
"[T]he national school lunch program determines students’ eligibility for free or reduced-price lunches based on family income, which is a more accurate measure of a school’s level of need than a model that considers general community income."
A chart defining the Income Eligibility Guidelines (IEG) for NSLP eligibility for the current year (07/01/2000 – 06/30-2001) is available by clicking here.
The FCC also sanctions other mechanisms to determine a school’s level of need, as long as those mechanisms are based on — or do not exceed — the same measure of poverty used by NSLP:
"[A] school may use either an actual count of students eligible for the national school lunch program or federally-approved alternative mechanisms to determine the level of poverty for purposes of the universal service discount program…
"[S]chools that choose not to use an actual count of students eligible for the national school lunch program may use only the federally-approved alternative mechanisms contained in Title I of the Improving America’s School Act, which equate one measure of poverty with another."
These federally-approved alternative mechanisms use data comparable to NSLP data which are:
(1) [c]ollected through alternative means such as a survey; or
(2) [f]rom existing sources such AFDC or tuition scholarship programs."
If a school chooses to do a survey, the following guidelines apply:
The survey must assure confidentiality. (The names of the families are not required.)
The following measures of poverty are currently acceptable alternatives to NSLP eligibility:
Participation in Temporary Assistance for Needy Families (TANF) is an acceptable alternative measure of poverty ONLY IF the family income of participants is at or below the IEG for NSLP. Similarly, participation in need-based tuition assistance programs is acceptable if the family income of participants is at or below the IEG for NSLP.
Schools may also use existing sources of data which 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 family income of participants is at or below the IEG for NSLP.
The siblings of a student in a school that has established that the student’s family income is at or below the IEG for NSLP may also be counted as eligible for E-rate purposes by the respective schools the siblings attend. For example, an elementary school has established, through a survey, that a student’s family income is at or below the IEG for NSLP. That student 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 E-rate purposes, without collecting its own data on that family.
If a school has sent a questionnaire to all of its families, 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 for E-rate purposes for all students in the school. For example, a school with 100 students sent a questionnaire to the 100 homes of those students, and 75 of those families returned the questionnaire. The school finds that the incomes of 25 of those 75 families are at or below the IEG for NSLP. Consequently, 33 percent of the students from those families are eligible for E-rate purposes. The school may then project from that sample to conclude that 33 percent of the total enrollment, or 33 of the 100 students in the school, are eligible for E-rate purposes.
The following alternative measures of poverty are NOT acceptable for determining E-rate discounts. They rely on projections rather than on the collection of actual data:
Content Last Modified: January 3, 2005
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