The invisible poor

As I mentioned in passing last week, the Board of Ed is getting a presentation tomorrow from the administration on a change--as far as I can tell, it's a change? not a proposed one? they can do this unilaterally?--to the way percentage of low income is calculated for schools in Massachusetts. The Globe has an article on it today.
Currently, most districts calculate low income based on free and reduced lunch numbers. Those numbers come from the forms parents send in--which yes, are audited--as well as cross-reference from other state programs. Those are : the Supplemental Nutrition Assistance Program (SNAP); the Transitional Assistance for Families with Dependent Children (TAFDC); the Department of Children and Families’ (DCF) foster care program; and MassHealth (Medicaid).  Community eligibility instead uses just the information from the other programs AND, if you're a district that uses it, all students, regardless of income, receive free lunch.
Thus, CEP districts are full free lunch districts. Boston started doing this in 2013.

You may remember, when this happened, we had some discussion about why Worcester was choosing not to do it, and, to be honest, most of that hasn't really changed.

You'll find DESE's discussion of the change here. Let me say up front that I genuinely believe that their motivation is good: they want to feed more kids, and, by making lunch universal, the hope is that any lingering stigma associated with getting school lunch will be removed.

However:
This automatically decreases the number of kids being measured as in poverty. There are kids who legitimately receive free lunch now who are not receiving any of these other benefits: maybe their parents don't want to ask for help, or lack paperwork, or don't have the time to apply. There are lots of reasons why kids might have one sort of qualification and not the other. Yes, they'll have lunch now, but they won't be counted otherwise.
The memo attempts to argue that this is simply another measure--even using a new term, "economically disadvantaged"--and cautions in bold against comparing measurements:

 It is important for users of this data to understand that enrollment percentages and achievement data for “economically disadvantaged” students cannot be directly compared to “low income” data in prior years. 

And what is the first thing the Globe did?

More broadly, the data raise questions about whether some schools should be performing at higher levels if indeed they have fewer poor students than previously thought.

No, it does not. We don't have fewer poor kids; we're just counting fewer of them.

So what, beyond the above sort of nonsense (of which I am quite certain we'll see lots more), is the problem?

• This automatically cuts the foundation budget for any district with low income kids (which I believe would be all of them). There is a low income increment as part of the foundation budget; fewer kids = smaller budget. Now, DESE immediately pivots to the Foundation Budget Review Commission taking this up as part of their work. As the only mention I've heard at their meetings on this issue was a single one by the Commissioner in passing, that's...optimistic. Also, the low income increment needed to be increased, anyway, as it wasn't covering anything close to what it was supposed to; something tells me that it isn't going to be increased by both the amount it should be PLUS the amount we'll lose through the new calculation. 
• We get an airy "will provide guidance" on other grants, which is not reassuring when you're talking about cutting our eligibility.
• No one seems to be addressing federal reimbursement rate for lunches, which, at least when we last talked about this in Worcester, didn't address the real costs of the program.
• We're losing decades of comparable data on rates of poverty. You can like or not like the current way of measuring, but at least the data set was cross-comparable. Call me cold-blooded, but having a consistent measurement of how many kids are poor matters. 

 I'm concerned, to put it lightly.