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The federally funded ARP-EANS program will soon make $181 million worth of COVID-19 related emergency assistance and services available to qualifying California nonprofit private schools.

Learn more about the ARP-EANS program, find links to support materials, and launch your school’s online application from the California Department of Education’s “Emergency Assistance to Non-Public Schools Program” web page.

A major difference between the first round of EANS funding and ARP-EANS (‘ARP’ stands for “American Recovery Plan,” the underlying legislation that enacted the program) is that ARP-EANS requires no less than 20 percent of a private school’s total enrollment to be comprised of “low-income students.” (Different threshold percentages may apply in other states.)

On December 6, 2021, the California Department of Education (CDE) released a “for information only” copy of its ARP-EANS request for information (RFA) document which identified four sources of data applicant schools may use to count “low-income students.” They are:

  • Available free or reduced-priced lunch data as derived from students who are eligible to receive free and reduced-price meals (FRPM) based on applying for the National School Lunch Program (NSLP) or who are determined to meet the same income-eligibility criteria as the NSLP through their local school as well as students who are automatically eligible for free meals based on their foster, migrant, or homeless status, or because they were directly certified (Title 7, Code of Federal Regulations, Section 245.6) as being eligible for free meals pursuant to all applicable State and federal requirements.

  • Scholarship or financial assistance data, limited to students who are from families at or below 185 percent of the federal poverty level.

  • E-Rate Data: an alternative method that allows schools to collect and determine low income counts without participating in the NSLP.

  • Comparable poverty data from another source, such as proportionality. (Use of proportionality requires the NPS to apply the low-income percentage of each participating Title I public school attendance area to the number of the NPS’ private school children who reside in that school attendance area to derive the number of private school children from low-income families.) (Emphasis ours.)

All data used to determine the number and percentage of “low-income students” is to be drawn from the 2019-20 school year.

The method of proportionality offers prospective ARP-EANS applicants a streamlined method for determining whether at least 20 percent of a private school’s total enrollment is comprised of “low-income students,” and does so in a way that is consistent with program guidelines. Employing the method of proportionality spares private schools from the challenge of attempting to gather, organize, and analyze a substantial body of information from school families during the course of the Winter Break. (The “window” for the submission of ARP-EANS applications runs from December 13, 2021 to 5:00 p.m. on January 3, 2022. These dates were not of the CDE’s choosing. Federal guidance requires states to make applications available within 30 days after a state receives its ARP-EANS allocation. It’s an unfortunate coincidence that the application period largely coincides with the Winter Break.)

Before proceeding, it’s important for readers to understand that ‘low-income student’ (for purposes of determining ARP-EANS eligibility) refers to a pupil hailing from a family whose combined income does not exceed 185 percent of the federal poverty level. This is the income level that is used to determine eligibility for participation in various federal programs, including the Free and Reduced Price Meals program (FRPM).

Conveniently, the CDE compiles FRPM eligibility information for every public school in the state. If you look at the percentage figures appearing in Column “V” of this CDE table (select the “FRPM School-Level Data” tab), you will see the percentage of pupils in a given public school that are eligible for participation in FRPM. Because FRPM eligibility requires total family income to be no greater than 185 percent of the federal poverty level, this figure also provides a comparable percentage of “low-income” public school students that can be used to derive the corresponding number of private school students. This is where proportionality comes into play.

According to a CDE guidance document titled, “ARP EANS Request for Application Webinar Q&A from December 8, 2021,” which was released on December 13, 2021, “proportionality data” is to be “calculated as the number of students enrolled in a NPS who reside in a Title I school attendance area multiplied by the percentage of public school students in that same attendance area who are from low-income families.” (‘NPS’ stands for “Non-public school,” i.e., a private school.)

To furnish a practical example of how the method of proportionality can be used to determine the percentage of “low-income students” in a private school wishing to make application for ARP-EANS assistance and services, imagine the existence of a fictitious nonprofit private school called “The CAPSO School.” Further imagine that the “The CAPSO School” is located in Encino, California, and that it offers instruction in grades K-8. Let’s also assume that the school enrolls a total of 200 students.

To meet the 20 percent “low-income student” threshold required for participation in ARP-EANS, “The CAPSO School” must enroll no fewer than 40 “low-income students.”

To employ the method of proportionality, administrators at “The CAPSO School” will need to know the grade-relevant public school attendance area in which each of its students resides. (It’s a good idea for every private school to include this information in its digitized enrollment roster.) Schools not currently in possession of such information can use this handy online search tool from to add public school attendance area information to their rosters. Just enter a student’s home address in the search box, select either “Elementary,” “Middle,” or “High” under “School Grade,” and click “Search.” If in doubt, check to make sure the public school offers instruction at the grade level in which the private school student was enrolled during the 2019-20 school year. (The above-referenced CDE table shows “low grade” and “high grade” information in columns “P” and “Q.”)

Note: is a commercial website and CAPSO makes no claims as to the accuracy of the information it provides. Some public school districts provide utilities enabling users to enter addresses in order to identify corresponding public school attendance areas. If, for example, you reside within the boundaries of the Los Angeles Unified School District, you can use this public school identifier. Here’s one for Glendale Unified. Orange CountySacramento (City)San Diego UnifiedSan FranciscoSanta Clara. (Readers can search for similar utilities provided by their public school district of residence.)

Returning to our example, imagine that of all students enrolled in “The CAPSO School,” 20 students enrolled in any of grades K-5 resided within the attendance area of Emelita St. Elementary School. The first thing we will want to know about this school is whether it receives Title I funding. If it doesn’t, we can’t include it in our calculations using the method of proportionality.

Happily, this CDE table lists all public schools that were recipients of Title I, Part A funding in the 2019-20 school year. A quick search reveals that “Emelita Street Elementary” appears in the table. We’re good to go!

Returning to the previous table, the information appearing in “Column V” shows that 63.8 percent of Emelita Street Elementary students were eligible for FRPM in 2019-20, meaning that they are “low-income students.” That percentage can now be applied to the 20 “CAPSO School” students residing in Emelita Street Elementary School’s attendance area: 20 X .638 = 12.76. Applying the method of proportionality, we can now say that 12 “CAPSO School” students have met the “low-income student” criterion.

Let’s assume that 24 “CAPSO School” pupils live within the attendance boundaries of Newcastle Elementary.

Did that school receive Title I funding in 2019-20? Yes! Its FRPM-eligible percentage is 89.5 percent. Let’s go ahead and apply the proportionality formula:

24 X .895 = 21.48

We can now add another 21 “low-income students” to “The CAPSO School’s” count.

Next, say that a total of 42 “CAPSO School” students who, in 2019-20, were enrolled in grades 6-8, resided within the attendance area of the Gaspar De Portola Charter Middle School. Did that school receive Title I funding in 2019-20? Check! What was it’s percentage of FRPM-eligible/”low-income students?” 51.7 percent. You should know the routine by now!:

42 X .517 = 21.7

The three public schools we have used in our example have enabled us to estimate that there are 54 “low-income students” enrolled in “The CAPSO School.” We have met the minimum 20 percent threshold requirement.

Let’s imagine that the remaining 114 “CAPSO School” students all reside within the attendance area of the Lanai Road Elementary School. Was this school a recipient of Title I funds in 2019-20? No! Lanai Road Elementary doesn’t appear in the CDE table of Title I recipient schools. Even though the school shows a FRPM-eligible/”low-income student” figure of 8.1 percent, the method of proportionality may not be applied to this school. In our fictitious example, it wouldn’t matter. “The CAPSO School” would have met the 20 percent “low-income student” threshold using the method of proportionality.

Important: Schools making successful application for ARP-EANS services and assistance must maintain the sources of data used to count “low-income students” for a period of at least five years. If your school plans to apply the method of proportionality to count “low-income students,” you will need to maintain the following:

  • Names, addresses, ages, grade levels, and public school attendance areas for students enrolled during the 2019-20 school year;

  • A copy of  the CDE’s “Unduplicated Student Poverty – Free or Reduced-Price Meals Data 2019–20” spreadsheet, which contains 2019-20  FRPM/”Low-Income Student” information for public schools;

  • A copy of the CDE’s “Title I, Part A Recipients” spreadsheet, showing which public schools received Title I, Part A funds in 2019-20; and,

  • The calculations used to determine that at least 20 percent of all students enrolled in the applicant private school in 2019-20 were “low-income students.”

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