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Universal Free School Meals

Ensuring that All Children Are Able to Learn

By Madeleine Levin & Jessie Hewins

As a society we expect—and demand—that schools provide every student with the resources necessary for learning—books, a desk, a qualified teacher, a safe learning environment. Of course, the most basic and fundamental resource that every child needs in order to learn is nourishment for the brain and body—an adequate and healthy diet that supports learning and keeps the child healthy. Children who are hungry cannot learn. They cannot concentrate. They are more likely to be absent and tardy. They get “hunger headaches.” And they often have a hard time behaving in class. All of the federal, state, and local dollars spent in the United States on education are wasted if classrooms have hungry students.

Understanding the impact of nutrition on academic achievement, many school officials across the country mandate that all their students go to the cafeteria to eat breakfast on standardized test days. However, many do not make the same effort to ensure that all their students have the nutrition they need in order to learn every instructional day—those critical days when the students are learning the information they need to do well on the test, and in school generally. The School Breakfast and National School Lunch Programs provide federal funding to public and private nonprofit schools so that low-income children have access to a nutritious breakfast to start the school day and be ready to learn and a nutritious lunch so that they can remain focused and continue learning throughout the day.1


There are strategies, however, to offer school meals for free to all students in a school, especially a predominantly low-income school. These strategies eliminate many barriers to participation, including stigma: many low-income students choose not to participate so they are not labeled “poor” by their peers—a problem that particularly inhibits breakfast participation because, in most schools, low-income students must arrive early to eat in the cafeteria while other children choose to socialize in the hallways or on the playground before class. Also, many struggling families with incomes just above the cutoff line for free school meals cannot pay the meal fees charged by the schools. More student participation in the programs supports stronger, more financially viable school nutrition programs and often supports healthier, more appealing school meals.

A growing number of schools are offering all of their students free breakfast—or both breakfast and lunch—to encourage participation. Now a new federal provision, called “community eligibility,” makes it easier for high-poverty schools to offer free breakfast and lunch to all students and eliminates the administrative work associated with identifying and tracking each child’s eligibility for free or reduced-price school meals. Community eligibility has been phased in over the last three years in 11 states and will become available nationwide at the start of the 2014–2015 school year. This new provision presents a tremendous opportunity to expand access to school meals in the nation’s most vulnerable communities, and there are several key steps that can facilitate and encourage widespread adoption of community eligibility in 2014–2015 and subsequent school years.

School Meal Participation: Impact, Eligibility, and Barriers

The school nutrition programs offer students two meals that meet federal nutrition standards each school day, helping ensure that students are able to start their school day ready to learn and can continue learning into the afternoon.2 Research shows not only that a nourished child is a better learner but also that the child is a better test-taker and participant in school—more likely to be at school, arrive on time, behave, and be attentive in class.3 Hungry children have been found to have lower math scores and be more likely to repeat a grade.4 Hungry teens are more likely to be suspended from school and more likely not to get along with other children.5

The nutrient-rich foods provided through the school meal programs also can help reduce participants’ risk of obesity. A nationally representative study found that school breakfast participation was associated with a significantly lower body mass index (BMI, an indicator of excess body fat).6 Furthermore, school meal participants are less likely to have nutrient inadequacies and more likely to consume fruit, vegetables, and milk at breakfast and lunch.7 These positive effects from participation in the school meal programs will only increase as schools continue to improve nutrition quality and further restrict less healthy snack foods that students may purchase in school buildings as a result of the Healthy, Hunger-Free Kids Act of 2010.8 There is a growing body of evidence that when school meals are offered at no charge to all children in a school, the resulting increased participation magnifies these benefits, especially for low-income children. Many of these positive effects are particularly pronounced in the School Breakfast Program, which is vastly underutilized, with only 52 percent of the low-income students who eat school lunch each day also receiving a school breakfast.9

Research shows not only that a nourished child is a better learner but also that the child is a better test-taker and participant in school.

Research findings on the link between free school meals and food security paint a compelling case for increasing access to these meals. When schools offer all children breakfast at no charge, schools decrease food insecurity and create a playing field where all children have the same opportunity to start their school day well nourished.10 Schools that offer universal free meals have higher breakfast participation, especially when breakfast is served in the classroom, resulting in more students consuming a nutritionally substantive breakfast.11

Eligibility for Free and Reduced-Price School Meals.
All public schools, nonprofit private schools, and Residential Child Care Institutions can participate in the federally funded National School Lunch and School Breakfast Programs. Local education agencies (school districts) must apply to their state child nutrition agency (typically the department of education) in order to institute a program. All students in these schools may participate in the programs. However, household income determines whether they receive free, reduced-price or “paid” meals. Children from families with incomes at or below 130 percent of the federal poverty level receive free school meals—they may not be charged at all.12 Children from families with incomes between 130 percent and 185 percent of the poverty level receive school meals at a reduced-price—the student pays a share of the cost (no more than 40 cents per lunch and 30 cents per breakfast), while the federal government pays for the rest. All other participating students, officially designated as receiving “paid” meals, pay most of the cost of their meals, although schools receive a small federal reimbursement for these meals.

Most children are certified for free or reduced-price school meals via individual household applications collected by the school district. However, children from households that receive Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF) cash assistance, or Food Distribution Program on Indian Reservations (FDPIR) benefits, as well as foster youth, migrant, homeless, or runaway youth, and Head Start participants, are “categorically eligible” (automatically eligible) for free school meals without the need for an application.13 School districts are required to “directly certify” children in SNAP participant households for free school meals through data matching of SNAP records with school enrollment lists, and the districts have the option of directly certifying children in TANF and FDPIR households as well.

Barriers to School Meal Participation. Millions of children rely on school meals each day, but many more are eligible yet not participating. The school meal administrative processes create access barriers for children whose families either do not successfully apply, or who are removed from the rolls for failure to respond to requests for additional information. For children who make it through this process and are found eligible for reduced-price meals, the copayment fees create a barrier to eating breakfast or lunch. For children just above 185 percent of the poverty level, the full fees for school meals can be an even greater hurdle to participation. This income-based system marks the school meals programs themselves as only for “poor children,” creating a stigma among students who do not want to be identified as low-income through their participation. While schools are supposed to make status invisible, low-income children often can be inadvertently identified by point-of-sale processes and even by what meal they choose.

Most families must complete school meal applications, which can be confusing for them and burdensome for schools to collect and process. For families with limited English proficiency, there are additional access challenges created by lack of translation assistance or a lack of forms and information in their primary language.14 These problems are compounded when these families’ applications are chosen for further income verification and additional correspondence is sent home, often only in English, creating the risk that the child will lose access to free meals if the family fails to respond.

The income verification process causes eligible children to lose benefits. After processing applications and certifying eligible students, school districts must select 3 percent of applications, or up to 3,000, approved for free or reduced-price school meals for income verification, and school districts must choose “error-prone” applications from households with reported incomes near the cutoffs.15 Applicants selected for verification must submit proof of the amount, frequency, and source of their reported income.16 School districts are required to make at least one attempt to follow up with all households not responding to the initial verification request. If a household fails to respond, school meals benefits are automatically terminated.17

The primary cause for children initially certified for free or reduced-price meals to have their benefits terminated is failure to respond to verification requests. In the latest study of verification rates, nationally 32 percent of households initially certified for free or reduced-price meals selected for income verification in the 2008–2009 school year did not respond.18 In districts of 20,000 students or more, the nonresponse rate swelled to 46 percent.19 As a result, all of these households were automatically cut off from free or reduced-price school meals. Studies focusing on large urban school districts have reported even more troubling rates of termination due to nonresponse. In a pilot study of verification processes in large metropolitan districts, the U.S. Department of Agriculture (USDA) found that, among households selected for verification, 50 percent did not respond and had their benefits terminated. Upon independent verification of income for the nonresponding households initially certified for free meals, however, the study found that 51 percent were in fact eligible for free meals and 26 percent were eligible for reduced-price meals.20

Schools that offer universal free meals have higher breakfast participation, especially when breakfast is served in the classroom.

The problems of the means test continue after application verification and into the cafeteria. As a result of the income-based eligibility, schools must adhere to a complex reimbursement system that requires documentation of each meal served by child and eligibility category. As students move through the cafeteria line, school nutrition staff members must ensure that students have selected all the components of a reimbursable meal under the federal nutrition guidelines, collect fees for paid or reduced-price meals, and record that meal in the point-of-sale system—all without identifying students as “low-income.” These systems involve a wide array of practices, such as personal identification numbers or student identification numbers being entered by students into a pad, finger imaging of students, or cash payments entered by staff members at the “point of sale.” As a result, cafeteria lines often move slowly, as children wait for their peers to be properly entered into handwritten or computer documentation systems. These lines discourage participation in the school meal programs, especially among older students and cut into already too-short periods to eat. Research into the gap between eligibility and participation for free and reduced-price eligible students in the school lunch program found that older students were less likely to participate and cited long lines as one of the primary reasons for nonparticipation.21

The fees that schools charge also limit participation. For families between 130 percent and 185 percent of the federal poverty level, the modest fees charged for reduced-price school meals can be an insurmountable obstacle to participation, particularly for families with more than one child.22 For families just over the 185 percent mark, paying the full price for meals is often financially out of reach.23 Children in these fee categories typically must have positive account balances with the school district or cash in hand before they can receive a meal, although some districts do allow families to owe a small amount of money to the district and still receive meals. Often this is accompanied by an “alternate meal policy,” where children who have reached the maximum allowable overdue account balance are given something like a cold cheese sandwich instead of the hot lunch. This can be an upsetting and even humiliating experience for children when they reach the end of the lunch line only to find that they are not allowed to keep the meal they have selected.

Now is the time to expand universal free school meals to thousands of high-poverty schools by realizing the potential of the community eligibility provision.

Stigma has long been identified as a significant barrier to participation in antihunger and antipoverty programs. The National School Lunch Act was amended in 1970 to prohibit the overt identification of children who receive free or reduced-price school meals.24 Over the years, improved technology has supported cafeteria systems that limit the identification of students eligible for free or reduced-price school meals, but many schools still use outdated methods, such as tokens or student rosters. These practices have contributed to the stigmatization of school meals and caused low-income students, especially teens, not to participate in order to avoid feelings of shame in front of their peers.25

The problem of stigma persists in most school buildings, even those that have instituted good procedures in their lunch program, due to the presence of foods sold outside the meal program. These foods–known as competitive foods–include a la carte foods sold in the cafeteria alongside the reimbursable meal. In some cases, there is a different line in the cafeteria for a la carte foods, and this separates children eating free or reduced-price meals from their higher-income peers or leads children to spend money they do not have. Even when there is a single line, the food on students’ trays clearly marks whether they have received the subsidized meal or purchased their food.26


Increasing Access Through Universal Free Meals

Universal free school meal programs offer a solution to many of the barriers that impede participation. There are several options created in federal law to permit schools to offer free meals to all students and incorporate administrative simplifications, which enable high-poverty schools to stop collecting fees from students and still cover their costs with the federal reimbursements.27 Across the country, there are thousands of schools with high rates of student eligibility for free and reduced-price meals where universal free meals can and have become the norm. Administrative savings can be considerable for these schools because, under standard school meals eligibility determination, they must devote extensive resources to identifying the small numbers of children who do not qualify for free or reduced-price meals.

The economics in the cafeteria improve as well. Under the traditional model, school nutrition staff members must not only determine the eligibility of each student but also count and claim for reimbursement each meal served by fee category and collect fees from students eligible for paid and reduced-price meals. When schools offer universal free meals through the available federal options, however, cafeteria staff members are required only to keep track of total meal counts each day and do not collect fees from students. School nutrition staff members are additionally relieved of the often daunting task of collecting unpaid fees from families when students cannot pay for their meal. Few schools allow children to go hungry and often absorb the expense of at least some of these uncollected meal fees.28 Moreover, when school meals are offered to all students at no charge, this becomes the “default” for all children and helps eliminate stigma. Offering universal free breakfast streamlines and complements the implementation of alternative service models where students eat breakfast in the classroom after the start of the school day; this has proven to be the most effective means of increasing school breakfast participation.

In addition to administrative savings from offering universal free meals, schools can capture increased savings through economies of scale as more children participate and the school nutrition budget grows. As programs increase participation, they can achieve greater labor efficiencies that actually lower their cost per meal, and programs can lower food costs per child as well through improved negotiating power for better pricing as a result of larger purchases.29 These cost savings can then be reinvested in the school meal programs in a number of ways that benefit children. Schools have been able to increase the nutrition quality of meals because they can afford to purchase healthier meal components that are often more expensive, or schools conduct additional training for school nutrition staff members to prepare more meals from scratch. Realizing these cost savings is particularly crucial at this moment, as the Healthy, Hunger-Free Kids Act of 2010 provides for extensive improvements on nutrition that school nutrition professionals have been working diligently to incorporate into their menus since the 2011–2012 school year. While that law provides for an additional six cents per child per lunch to help offset the cost of these much-needed updates, schools have struggled to stretch already tight budgets to include more whole grains, lean proteins, fruit, and vegetables. Moreover, unlike for lunch, no additional funding was provided to make similar nutrition improvements for school breakfast. Taking advantage of efficiencies and economies of scale inherent in serving universal free meals can help schools reach more low-income children with two more nutritious meals each day.

Community Eligibility: A New Solution. A case for the expansion of universal free school meal programs in high-poverty schools is strong, and the Healthy, Hunger-Free Kids Act of 2010 created an opportunity to expand these programs greatly through the new community eligibility provision.30 While federal options for universal free meals in schools with high levels of low-income children have been available since the 1980s (discussed below), community eligibility goes further than previous options to streamline administrative requirements for school districts by eliminating the school meal application process entirely. Community eligibility is being phased in over four years. Illinois, Kentucky, and Michigan implemented the provision in the 2011–2012 school year; the District of Columbia, New York, Ohio, and West Virginia did so in the 2012–2013 school year; and Georgia, Florida, Maryland, and Massachusetts implemented the provision in the 2013–2014 school year.31 The provision will be available to districts and schools in all states in the 2014–2015 school year.

Benefits of Community Eligibility. Under community eligibility, administrative savings are maximized—compared to other universal options—as the application process is eliminated entirely. Community eligibility schools instead offer breakfast and lunch at no charge to all children, and reimbursement amounts are determined by a simple formula based on the number of “identified students”—children eligible for free school meals that are already identified by other means than an individual household application (e.g., direct certification of children in SNAP households). The purpose of community eligibility is to increase access to school meals for low-income children, and, in the first two years of implementation, schools using the provision have done just that. Illinois, Kentucky, and Michigan schools that have been participating in community eligibility for two years have increased average daily participation in the National School Lunch Program by 13 percent and average daily participation in the School Breakfast Program by 25 percent.32 As a result of the successful implementation in some schools in the phase-in states, more and more schools in those states have come into the program. In the three states where community eligibility has been available for two years, the number of schools participating nearly doubled in the second year, increasing from 665 schools in the 2011–2012 school year to 1,240 schools in the 2012–2013 school year.33

Reliance on Identified Student Percentage and Direct Certification. The funding that community eligibility schools receive is based upon the number of “identified students” who are certified for free school meals by means other than an individual household application.34 Most of these children are directly certified through data matching because their households receive SNAP, TANF, or FDPIR and, in some states and areas, Medicaid benefits.35 Identified students also include children who are automatically eligible for free meals because they are homeless, migrant, enrolled in Head Start, or in foster care.

Any school or district with 40 percent or more identified students can participate in community eligibility, and school districts may choose to have individual schools, certain groups of schools (that reach the 40 percent requirement combined), or all schools in the district implement the provision.36 To establish the reimbursement amount for meals served, the district’s, the school’s, or the group of schools’ identified student percentage is multiplied by 1.6 to determine the percentage of meals reimbursed at the federal free reimbursement rate.37 The remaining meals are reimbursed at the lower “paid” reimbursement rate.38 For example, if a district has an identified student percentage of 55 percent and chooses to implement community eligibility districtwide, 88 percent of meals (55 percent identified students multiplied by 1.6) would be reimbursed at the free rate, and 12 percent of meals served would be reimbursed at the paid rate. As another example, if a school with 65 percent identified students implements community eligibility, then 100 percent of meals would be reimbursed at the free rate (65 percent identified students x 1.6 = 104, but free meal reimbursement is capped at 100 percent).

A number of factors contribute to higher participation in school lunch and corresponding low participation in school breakfast.

The free-meal-claiming percentage, based upon the identified student numbers, is basically intended to serve as a proxy for the number of children who would have been eligible for free and reduced-price meals under the traditional methods of certification. Schools and districts that have implemented community eligibility represent some of the most vulnerable communities across the country including urban districts such as Boston, Chicago, and Detroit, as well as rural areas of Kentucky and West Virginia. Generally schools and districts that would meet the 40 percent identified student threshold to use community eligibility serve communities where more than 65 percent of students would qualify for free and reduced-price school meals under traditional means of certifying children for school meal benefits.

For most schools utilizing community eligibility, a majority of identified students are directly certified through data matching with the state agency administering SNAP and TANF benefits and, in some cases, Medicaid. Increasing the effectiveness of these systems to identify all school-age children in households participating in these programs is a critical component to maximize the reimbursement rate under community eligibility. Furthermore, increasing enrollment in SNAP and these other safety-net programs can be mutually reinforcing with increasing access to free school meals for low-income children. Community eligibility schools would benefit from higher SNAP, TANF, and, in some areas, Medicaid, participation rates in their communities, as this would result in an increased number of identified students and more meals reimbursed at the free rate. Children in households enrolled in other safety-net programs would gain access to two nutritious meals at school, reducing financial strain on low-income families. A number of school districts have recognized the value of coordinating outreach for SNAP and other programs among students’ families since ensuring that students’ basic needs are met benefits the individual students as well as the school environment. For example, in Chicago, the district employs outreach staff members to educate families about available assistance programs and encourage and assist in enrollment.

Moreover, reliance on the number of identified students, as opposed to separate household school meal applications, improves certification accuracy in the school meals programs overall. Direct certification through data matching is a highly accurate means of identifying children eligible for free school meals because households have already undergone a significant income verification process to receive SNAP or other benefits.39 With household school meal applications eliminated, there is less room for human error in computing income that can cause some children to be certified in the wrong fee category. In many states that have invested in developing a strong direct certification system, virtually all low-income children in SNAP households are certified for free school meals, thereby boosting the efficiency and accuracy of certifications among all students.40

Other Options for Offering Universal Free School Meals. Since long before the availability of community eligibility, schools have been offering meals at no charge to all students by utilizing special-needs provisions (e.g., Provisions 1, 2, and 3) designed to increase participation in high-poverty schools.41 The most common method used by schools is Provision 2, which allows schools to offer either breakfast or lunch or both, free to all students while obtaining some administrative cost savings to offset the meal fees that would have been collected from students eligible for reduced-price or paid meals.42 Similar to community eligibility, Provision 2 schools can realize cost savings from reduced administrative work through bypassing the traditional application process. Under Provision 2, however, schools are not able to eliminate applications completely. Instead Provision 2 schools offer meals at no charge to all students but must collect school meal applications and count and claim meals by fee category during year 1, called the “base year,” of the multiyear cycle.43 For at least the next three school years, schools do not have to make individual eligibility determinations or collect school meal applications—they are required only to track total meal counts.44 Reimbursements for these meals then are based on participation rates from the base year—schools are reimbursed for meals served each month based on the proportion of free, reduced-price, and paid meals served in the corresponding month during the base year.45

At the end of the four-year cycle, the state child nutrition agency may extend the same base year claiming percentage to another four-year cycle if the income level of the school’s population remains steady.46 But eventually the school district must establish a new base year through another full application process, which can prove particularly challenging in districts and schools that have been utilizing Provision 2 for an extended period—families and school nutrition staff members have become accustomed to not having to fill out school meal applications, making the application process more difficult when a new base year is required.

Although many districts using Provision 2 will switch to community eligibility in order to eliminate school meal applications completely, Provision 2 likely will remain an option for some uniquely situated districts and schools. Community eligibility requires universal free meals offered at both lunch and breakfast; schools may use Provision 2 to offer just breakfast (or lunch) at no charge, while continuing to collect applications and charging fees for the other meal. In communities with high levels of income-eligible families but low SNAP utilization, and therefore lower than expected identified student numbers, Provision 2 may be more cost-effective.

Schools and districts may choose to offer universal free meals through other more informal means as well. Through policies commonly referred to as “nonpricing,” schools simply operate their school meal programs under the traditional model, including collecting and processing school meal applications and counting and claiming meals by fee categories, but schools do not charge students for meals—or for one meal—regardless of their eligibility status. Most often used to offer breakfast at no charge, nonpricing does not require preapproval from the state child nutrition agency and can be an effective option for schools to offer universal free meals without altering administrative processes for parents or school nutrition staff members.

As an intermediate step to offering universal free meals, some states and school districts have opted to eliminate the copayment fee for reduced-price meals and offer breakfast or lunch or both, free to all students certified for reduced-price meals in addition to the students certified for free meals. Reduced-price school meal participation has traditionally lagged behind that of free school meal participation—for many of the reasons discussed and primarily due to the burden that even a modest copayment fee can be for low-income families, especially those with more than one school-age child. Eliminating the reduced-price copayment fee removes this financial barrier, increases participation among these children, and helps low-income families stretch limited budgets.


Underutilization of the School Breakfast Program. Offering universal free school meals is particularly effective as a strategy to increase participation in the School Breakfast Program, which is underutilized to a significantly greater degree than lunch. Despite steady growth over the past 20 years, just over half of all low-income children who participate in school lunch participate in school breakfast.47 School lunch programs have traditionally maintained high utilization rates, reaching 20.9 million free and reduced-price certified children each day in the 2012–2013 school year, while just 10.8 million participated in school breakfast.48 A number of factors contribute to higher participation in school lunch and corresponding low participation in school breakfast. Lunchtime is an established part of the school schedule, and in most schools most students eat in the cafeteria, making participation convenient and accessible. School breakfast, however, is often served in the cafeteria before the school day begins, and this can be difficult due to rushed morning family schedules, late buses, and long school security lines. Moreover, if students arrive in school early, they may choose to socialize with friends or avoid the cafeteria because of the stigma that school breakfast is perceived to be “only for the poor kids.”

The most effective strategies for increasing school breakfast participation not only offer universal free breakfast but also move breakfast out of the cafeteria and make it part of the regular school day schedule. Children eat breakfast in their classroom with their peers after the school bell rings. The breakfasts are delivered to the classroom at the start of the school day, or students pick up a bagged meal at convenient points of sale in the school building to take to their classroom. Middle and high schools also have had success with “second-chance breakfast,” in which students are able to pick up breakfast after first period. These models work best when implemented with universal free meal provisions, such as community eligibility; the universal free meal provisions make counting the meals being served and getting reimbursed easier for schools since the schools do not have to track which children participate. When all students are offered breakfast free of charge, stigma is eliminated. And when breakfast is served at the start of the school day, participation is convenient for all students. Several large districts, including Dallas, Detroit, Houston, Los Angeles, and Newark, have implemented such programs districtwide, demonstrating the efficacy of these strategies to increase breakfast participation. The District of Columbia and some states, such as Colorado and New Mexico, have mandated that high-poverty schools implement these strategies as well.49

A Call to Action

Now is the time to expand universal free school meals to thousands of high-poverty schools by realizing the potential of the community eligibility provision. Advocates have a unique opportunity to work with communities and with local and state education agencies to ensure the maximum possible impact for low-income children, their families, and communities. To facilitate and encourage adoption of community eligibility, any barriers to school participation must be hurdled particularly with regard to eliminating school meal applications, as a number of states rely on data from school meal applications for other programs unrelated to school meals. The experience of the 11 phase-in states can be instructive on how to accommodate schools wanting to take advantage of community eligibility and therefore no longer collecting income data as part of the school nutrition program. Various approaches among the states have worked. The following steps will help ensure that high-poverty schools do not miss the opportunity to adopt universal free school meals:

1. Encourage Eligible School Districts to Adopt Community Eligibility.

The first step is to develop a list of schools that may be eligible to implement community eligibility. Each state school nutrition agency is required to publish a list of schools that are eligible for the following year by May 1 of each year. In advance of this, or as a proxy, advocates can reach out to schools—including schools that are already offering universal free meals through the other provisions—with 75 percent or more free and reduced-price student populations. Schools may not be aware of this new provision and have questions about how they would be reimbursed for meals and how it would affect the operations of the school nutrition program and other programs that rely on data from school meal applications. Advocates can help school officials understand community eligibility by sending a letter to the school district or by giving presentations on community eligibility to school officials.50 The USDA and the state agencies from the phase-in states have developed helpful resources available on their websites to aid schools in determining if community eligibility would be financially viable. The Food Research and Action Center and the Center on Budget and Policy Priorities have created a variety of resources to assist advocates in their outreach and education efforts, including a report on community eligibility implementation and progress in the phase in states, as well as a series of webinars, PowerPoint presentations, and an implementation guide.51

2. Work with the State Education Agency, Education Advocates, and Other Stakeholders to Modify Nonnutrition Programs that Rely on School Meal Applications.

In many states, programs unrelated to the school meal programs utilize school meal eligibility data as a proxy for determining the number of low-income children in a school or district, generally to provide additional aid for low-income children. The perceived need for these data should not stand in the way of allowing schools to offer universal free meals. At the federal level, the U.S. Department of Education and the USDA worked together to resolve the policy issues of eliminating the school meal applications, and stakeholders in the phase-in states have been able to work collaboratively to identify solutions to policy barriers at the state level. For the state, advocates can help set up an advisory group of representatives from key stakeholders, including the state child nutrition agency, the state department of education, Title I funding, E-rate, accountability and assessment offices, all of which might be affected by the elimination of free and reduced-price school meal application data.

3. Support Efforts to Improve Data Matching to Enroll Categorically Eligible Children Automatically.

Strong data matching systems will result in more schools qualifying for community eligibility and increase each school’s federal reimbursement (by raising the free claiming percentage) under community eligibility. States should use all available mechanisms to identify students who are in foster care or Head Start, homeless, migrant, or living in households that receive SNAP benefits, TANF cash assistance, FDPIR benefits, or Medicaid in certain states and areas.52 Schools can also increase the number of identified students by ensuring that all potentially eligible families in their community are aware of and have applied for SNAP benefits—and are then directly certified through data matching.

4. Explain Community Eligibility to Families and the General School Community.

Communicate the advantages of universal free meals to families and the general school community.53 Building local support for community eligibility can make the difference between limited and robust implementation. School districts typically make final decisions at school board meetings where the public can testify to support informed decision making.

5. Work with the Media to Promote Community Eligibility.

Advocates can publish letters to the editor and op-ed items in local papers, conduct outreach to press outlets to pitch stories to local reporters, and speak about the importance of adopting community eligibility at local forums and coalition meetings.54 Social media also can be utilized to help spread the word and build excitement.

6. Engage a broad base of allies to support community eligibility.

Pulling in likely and unlikely allies from education, community health, and faith based groups, among others, can help to build strong community support and momentum for offering universal free meals through community eligibility. Community members, along with parents and the school community, can leverage their networks and resources to help with outreach and can encourage schools to learn more about community eligibility. Advocates and organizations that work to enroll families in other means-tested programs also can be potential allies due to mutually reinforcing incentives to increase access to SNAP and TANF, and school meals.

As families continue to struggle against stagnant wages, diminishing government supports, and rising costs of living, they need school meal programs more and more to help stretch their limited resources and ensure that their children can succeed in school. By making school meals free for all students and an integral part of the learning environment, schools support healthier students, better academic outcomes, and the elimination of childhood hunger.

Madeleine Levin

Senior Policy Analyst, School Breakfast

and Lunch Program

Jessie Hewins

Child Nutrition Policy Analyst

Food Research and Action Center
1200 18th Street NW Suite 400 
Washington, DC 20036 

202.986.2200 ext.3004

202.986.2200 ext. 3966

2 Schools that qualify for the At-Risk Afterschool Meal Program based on Child and Adult Care Food Program regulations can serve an additional meal with federal funding. This program, however, is not a part of the community eligibility provision and not discussed here.

3 J. Michael Murphy, Breakfast and Learning: An Updated Review, 3 Journal of Current Nutrition and Food Science 3–36 (2007).

4 Katherine Alaimo et al., Food Insufficiency and American School-Aged Children’s Cognitive, Academic and Psychosocial Development, 108 Pediatrics 44 (2001).

5 Id.

6 Philip M. Gleason & Allison H. Dodd, School Breakfast Program but Not School Lunch Program Participation Is Associated with Lower Body Mass Index, 109 Journal of the American Dietetic Association S118–S128 (2009).

7 Melissa A. Clark & Mary Kay Fox, Nutritional Quality of the Diets of U.S. Public School Children and the Role of the School Meal Programs, 109 Journal of the American Dietetic Association S51 (2009).

8 See National School Lunch Program and School Breakfast Program: Nutrition Standards for All Foods Sold in School as Required by the Healthy, Hungry-Free Kids Act of 2010, 78 Fed. Reg. 39068 (June 28, 2013).

10 Judith S. Bartfeld & Hong-Min Ahn, The School Breakfast Program Strengthens Household Food Security Among Low-Income Households with Elementary School Children, 141 Journal of Nutrition 470 (2011).

11 Mary Kay Crepinsek et al., Dietary Effects of Universal-Free School Breakfast: Finding from the Evaluation of the School Breakfast Program Pilot Project, 106 Journal American Dietetic Association 1799 (2006).

13 For more information on certifying low-income children for school meals, see Zoe Neuberger & Tina Fritz Namian, Center on Budget and Policy Priorities, Enrolling All Children in a Household for Free School Meals (June 16, 2010).

19 Id.

25 Jodi Reddan et al., Children’s Perceived Benefits and Barriers in Relation to Eating Breakfast in Schools With or Without Universal School Breakfast, 34 Journal of Nutrition Education and Behavior 47–52 (2002).

26 Karen Stein, Erasing the Stigma of Subsidized School Meals, 108 Journal of the American Dietetic Association 1980–83 (2008).

28 Janet Poppendieck, Free for All: Fixing School Food in America 219 (2010).

33 Id.

34 Healthy, Hunger-Free Kids Act of 2010, Pub. L. No. 111-296, 124 Stat. 3183 (2010) (according to law, “identified students” refers to all children who are certified for free school meals and are not subject to verification).

35 Under the Healthy, Hunger-Free Kids Act of 2010, the U.S. Department of Agriculture is conducting demonstrations that add Medicaid to the list of programs used to certify students directly for free school meals. Direct certification of children participating in Medicaid is currently available statewide in Kentucky and Pennsylvania and in selected school districts in Florida, Illinois, Massachusetts, and New York. Additional states will be included for the 2014–2015 school year.

38 Id.

40 Id. at 12.

43 Id.

44 Id.

45 Id.

46 Id.

47 Hewins & Burke, supra note 9, at 5.

48 Id.

49 See Colo. Rev. Stat. § 22-82.8 (2013); D.C. Code §§ 38-821.01 et seq. (2010); N.M. Stat. Ann. § 22-13-13.2 (2011).

50 A sample letter to a school district and a sample introductory presentation are available at Food Research and Action Center, Community Eligibility (2010).

51 For introductory materials for school districts, see Food Research and Action Center, Community Eligibility: An Amazing New Opportunity (Nov. 2013).

52 See supra note 35. For a full discussion of strategies, see Neuberger & Namian, supra note 13.

53 For introductory materials for school districts, see Food Research and Action Center, supra note 51.

54 A model op-ed item is available at Food Research and Action Center, Community Eligibility (2010).

Louisiana Appleseed

Public schools across Louisiana can now provide free meals to all students under the School Breakfast and National School Lunch Programs through Provision 2—and soon through community eligibility—thanks to the advocacy work of Louisiana Appleseed. The organization took action after learning that Louisiana schools were unable to utilize universal free school meal programs without forgoing significant state education funding for at-risk students—effectively barring schools from offering universal free meals. Louisiana Appleseed and its community partners worked with the Louisiana Department of Education to amend the policy by which it determines for other programs the count of low-income children in schools wanting to eliminate school meal applications as part of their universal free meals programs. The updated policy ensures that schools opting for programs such as Provision 2 and community eligibility will continue to receive vital state education funding while also providing free meals to their students.

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