Our review of the California Charter Schools and how the nutritional needs of their students are being met, revealed the following:
In investigating how the nutritional needs of charter school students are being met, so that the Legislature can make future decisions regarding the health and education of California's children, we were hampered by a lack of data. Specifically, we found that data from California Department of Education (Education) databases are not sufficiently reliable to determine the exact number of California charter schools participating in the federal School Breakfast Program (breakfast program) or the National School Lunch Program (lunch program). Moreover, the data are not sufficiently reliable to identify the number of students at either traditional or charter schools who qualify for or participate in these programs.
Under the Charter Schools Act of 1992, teachers, parents, students, and community members are encouraged to establish and maintain charter schools that operate independently from the existing school district structure. Although charter schools operate independently, they are part of the public school system and can serve students in kindergarten through grade 12. Charter schools are exempt from many of the laws that apply to school districts. In particular, they are exempt from the law that requires schools to provide each needy student with one nutritionally adequate free or reduced-price meal during each school day. Further, as is true for school districts, participation by charter schools in both the breakfast and lunch programs is voluntary.
The breakfast and lunch programs are federally assisted meal programs operating in public and nonprofit private schools. School districts and independent schools that choose to take part in the breakfast and lunch programs get a cash subsidy from the U.S. Department of Agriculture (USDA) for each meal they serve. In return, they must serve meals that meet federal requirements and offer free or reduced-price meals to eligible children.
The data from Education are not sufficiently reliable to determine the exact number of charter schools and their students participating in the breakfast and lunch programs. For example, Education's Consolidated Application Data System (ConApp database), a paperless system, has three data fields that are relevant to our audit. These fields are designed to capture the number of students enrolled at a given school, the number of those enrolled students who are eligible to receive free meals, and the number of those enrolled students who are eligible to receive reduced-price meals. However, Education lacks an internal control process, such as a systematic review of the local educational agencies' and direct-funded charter schools' supporting documentation, to ensure the accuracy of these three data fields. In addition, Education does not require all direct-funded charter schools to submit their information using the ConApp database.
Education's Nutrition Services Division uses its Child Nutrition Information and Payment System (CNIPS) database for school food authorities to submit and track the status of their applications and reimbursement claims for the meals the schools under their jurisdiction serve to students under the breakfast and lunch programs. A school food authority is defined as an entity that is responsible for the administration of one or more schools and has the legal authority to operate a breakfast or lunch program or is approved by the USDA's Food Nutrition Service to operate a breakfast or lunch program. For example, a school district or a county office of education may operate as a school food authority. In addition, certain entities, such as residential care facilities, may be approved by the USDA to operate a program. The school food authority must submit to Education an application for any school in which it desires to operate a breakfast or lunch program and a policy statement regarding free and reduced-price meals. The school food authority must include in its application information related to its food safety inspections, verification reports, and annual audits, as well as a site application for each school it sponsors.
Education performs reviews of a sample of the schools under the jurisdiction of the school food authorities each year, in accordance with federal regulations, to ensure that the requirements of the lunch program are being met. However, its reviews do not include a procedure for verifying the accuracy of the county-district-school (CDS) code or the site type reflected on the schools' site applications. Therefore, Education is unable to accurately identify all charter schools participating in the breakfast and lunch programs. We found errors related to the CDS codes and the site type. Specifically, three charter schools with CDS codes in the CNIPS database did not match the CDS codes in Education's Charter Schools Database, and eight charter schools had no CDS codes in the CNIPS database. Also, two charter schools participating in the breakfast and lunch programs were misidentified on the school food authorities' applications—one as a private school and one as a county office of education.
In addition, the CNIPS database has data fields for the school food authorities to enter the number of students approved for free and reduced-price meals at each site under their jurisdiction. However, Education allows the school food authorities to combine the information for their sites before entering it into the CNIPS database. Therefore, although Education can report the total number of students for each school food authority, it cannot differentiate between charter school students and students from traditional schools who are participating in the breakfast or lunch program.
Despite the limitations of Education's data, we were able to identify 815 charter schools active in California as of April 2010.1 According to the data, 451 were participating in the breakfast or lunch program and an additional 151 were providing instruction to their students outside the classroom, either online or independently, and thus do not provide meals. We surveyed the remaining 213 charter schools to identify those that provide an alternative meal program and those that do not provide meals to their students. Of the 133 responses we received, 46 charter schools stated that they offer their students an alternative meal program, 39 stated that they do not provide meals to their students, 41 stated that they were in fact participating in the programs, and four stated that they provide instruction based outside the classroom. In addition, three charter schools stated that they do not provide meals to students or participate in the breakfast and lunch programs because their students are age 18 or older and are not eligible to participate in the programs.
The 46 charter schools responding to the survey that provide an alternative meal program have varying methods of providing meals, ranges of meal costs, and reasons for offering an alternative meal program. Most of these schools either have their staff prepare and deliver the meals or hire contractors to do so. The students at these charter schools paid between 50 cents and $5 for their meals. In addition, the primary reason cited by 15, or 33 percent, of these schools for having an alternative meal program is to allow them to provide what they described as fresher, healthier food choices to their students than the breakfast or lunch program provides. Some of these charter schools stated that they provide meals that meet or exceed the USDA's nutritional standards. Generally, these charter schools believe that the nutritional needs of their students, including low-income students, are being met.
As mentioned previously, state law does not require charter schools to provide each needy student with one nutritionally adequate free or reduced-price meal during each school day. The 39 charter schools that do not provide meals to their students gave various reasons for not participating in the breakfast and lunch programs and not providing an alternative meal. The primary reason was lack of a kitchen, cafeteria, or other facility to prepare and deliver meals to their students. Another reason commonly cited was a lack of funding and staffing to operate an alternative meal program or participate in the breakfast and lunch programs. Generally, however, these charter schools believe that the nutritional needs of their students, including their low-income students, are being met. Many of the schools stated that their students bring lunch from home. We also found that some of these charter schools inform parents via handbooks that can be found on their Web sites that they do not provide meals. Thus, when parents choose to pack their children's lunch and schools make parents aware of the fact that they do not provide meals, it becomes the parents' responsibility to ensure that their children's nutritional needs are met.
To ensure the reliability of the ConApp database fields related to the number of students enrolled at the school level, the number of those enrolled students who are eligible to receive free meals, and the number of those enrolled students who are eligible to receive reduced-price meals, Education should establish an internal control process such as a systematic review of a sample of the local educational agencies' and direct-funded charter schools' supporting documentation.
To ensure the accuracy of the CNIPS database, Education should:
Education generally agreed with our recommendations. However, Education did not address fully one recommendation aimed at ensuring the accuracy of its CNIPS database and it is considering the actions it will take regarding two other recommendations.
1 The number of active charter schools was obtained from Education's Charter Schools Database. However, we could not test the information in the database against source documents. Further, we found that the Charter Schools Division does not conduct audits or perform reviews of the information stored in the database. Therefore, we concluded that the information from the database was of undetermined reliability to reach an audit conclusion related to the number of active charter schools in California. We present this information because there was no better source from which to obtain this information.