In March 2010 an Interagency Technical Working Group (ITWG) released guidelines on thresholds and resources for a Supplemental Poverty Measure (SPM). The ITWG recommended 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. For example, the CE collects information on rental housing that is subsidized and market rents so that rent subsidies can be imputed. Also, the CE collects information on food expenditures that implicitly include the cash value of benefits from the Supplemental Nutrition Assistance Program (SNAP) but no information on other food programs. In earlier work, Garner (2010a,c,d) imputed in‐kind rates and benefits for the National School Lunch Program (NSLP) and Women, Infants, and Children Program (WIC) using eligibility guidelines (CE Eligibility Method) and consumer unit characteristics data from the CE. To better 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 NSLP and WIC (CPS Program Participation Method) in this study. Data for five years, referring to 2005 to 2009, are used for the imputations. CPS‐based imputed participation rates for NSLP and WIC are used along with U.S. Department of Agriculture information to assign benefit levels to the CE. Thresholds based on the CPS Program Participation Method are produced for 2009 and compared to thresholds based on the CE Eligibility Method. Preliminary results reveal that the two sets of thresholds ‐‐ based on the CPS Program Participation method and the CE Eligibility method and defined for owners with mortgages, owners without mortgages and renters ‐‐ are not statistically significantly different from each other. In contrast, when housing tenure thresholds are compared to each other within each method group, statistically significant differences arise. No poverty rates using these thresholds are produced.