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In March 2010 an Interagency Technical Working Group released guidelines on thresholds and resources for a Supplemental Poverty Measure (SPM), recommending that thresholds include in-kind benefits that are accounted for in resources; however, only limited in-kind benefit information is available in the Consumer Expenditure Survey (CE), the data source upon which the thresholds are based. To reflect reported rates of participation, data from the Current Population Survey (CPS), the basis of the SPM resource measure, are used to model imputations to the CE for participation in the national school lunch program and WIC. Thresholds based on the CPS Program Participation Method, presented in this paper, are produced for 2009 and compared to thresholds based on an earlier CE Eligibility Method.