Comment on FR Doc # 2011-14926

The Equality Lunch Meal Pricing has good intention but is flawed. Forcing districts to increase paid meal prices will either cause parents to lie and claim free eligibility or brown bag more meals (will happen after 3 or 4 continual price increases). Also allowing district to make up the lost revenue from not increasing meal prices from district general funds is a farce because districts will simply raise their non-direct charges on us, then send the necessary funds back to us and not pay anything from their funds. The meal pricing requirement is highly unfair to districts that manage their finances well. Our district will reach the state/fed limit of 3 months operating expenses fund balance, so why should we be forced to increase meal prices if we have the funds to cover increased costs? The solution to this should be based on a formula that takes various factors into consideration. First is a regional paid meal price base on free & reduce percentage ranges and current average meal price. Ranges could be: 0-20%; 21-40%; 41-55%; 56-70%; 71-85% and 86-99%. The requirement to increase should be based whether the district is at the regional percentage. A low f&r district should have less restrictions to raise their prices because they are less dependent on free reimbursement so their prices are more market driven. The high f&r districts are the ones who are subsidizing meal prices. The latest requirement based on CPI & food cost and rounding totally is unfair. How is it that a district like Alief ISD in the Houston that is high f&r and only charges $.75 for a paid meal can avoid not increasing at the minimum rate of $.05 because they are under $1.59 and we at $1.60 have to go up $.05 (CPI/rounding req) makes sense if the $.10 across the board rule in the law is not being implemented? If you have exceptions then it needs to be fair. If we go up $.10 this year and the minimum in $.05 and next year its $.05 again, then we should NOT have to go up next year.