A Closer Look at How SNAP Benefit Changes Could Negatively Impact School Age Children

In September 2019, BPC submitted comments on the USDA proposed rule to revise categorical eligibility in SNAP. The proposed rule would no longer allow states to make recipients of the TANF benefits automatically eligible for the program.

Our comments urged USDA to analyze and document the impact of the proposed rule on children’s access to school meals. While SNAP eligibility directly certifies students receive free school meals, USDA did not include the potential impact of the loss in SNAP eligibility on school meal participation in the proposed rule’s Regulatory Impact Analysis.  BPC recognizes the importance of access to nutritious meals for school-aged children as a critical determinant of long-term health and an influential factor in their academic success.  

On October 15, 2019, USDA released an informational analysis on the impacts of the proposed rule on children who participate in the National School Lunch Program and School Breakfast Program. The analysis revealed that 982,000 students would no longer be directly certified for free school meals, almost double the original estimate of 500,000. One of USDA’s objectives for implementing the proposed rule is to cut down on program abuse and to ensure that those who are truly in need receive assistance. However, it seems that in practice this rule would achieve just the opposite. BPC submitted supplemental comments on November 1, 2019 expressing additional concerns with the rule and its impact on school meals. We were also surprised that USDA allowed just 14 days for comments after the informational analysis was released, compared to the typical 60 or 90-day comment period.  

Currently, direct certification allows children in households who receive SNAP benefits to be automatically eligible for free lunch. USDA’s informational analysis shows that 96% of students would remain eligible to receive free or reduced-price school meals, if families submit an application. Since eligibility would largely remain consistent, USDA would not be cutting back on program abuse but instead creating an administrative barrier for families that fall within federally recognized poverty thresholds. 

Nearly half (45%) of the 982,000 students at risk of losing access would need to apply to receive the free meals they previously received with no application. It is highly likely that participation would decrease because of the new application requirement. The remaining 51% of students would be moved from free lunch to reduced-price lunch. Currently, students who receive reduced-price lunch pay a maximum of 30 cents for breakfast and 40 cents for lunch. However, the cost can become burdensome and, in some cases, lead to school meal debt for low-income families. 

Across the nation, 75% of school districts have unpaid school meal fees. This debt will likely increase if low-income families are moved from free to reduced-price meals under the proposed rule. School meal debt can also directly affect students as children are often singled out for not being able to pay for their meals. This is a concerning practice commonly known as school lunch shaming.  

Requiring applications would also create a delay in processing eligibility which could result in students accumulating school meal debt and experiencing the bullying and embarrassment of lunch shaming.

USDA estimates that the proposed rule will result in federal savings of $90 million per year beginning in FY2021 or $270 million over five years. A substantial portion of the rule’s estimated cost savings would come from eligible students dropping out of the program because of the new application barrier. These cost savings do not address USDA’s goal of eliminating program fraud since 96% of students will continue to remain eligible. It does, however, create a significant barrier for low-income families to access food assistance.  

The cost savings estimate provided in the new informational analysis also does not include the additional costs for states to process all the applications or funds for education and outreach needed to get the 684,000 households to apply for the school meals programs. Since no application was required previously, states will have to develop and execute plans for education and outreach to ensure that families are aware of and can complete the application. On October 16, 2019, the Subcommittee on Civil Rights and Human Services of the House Committee on Education and Labor held a hearing with Deputy Under Secretary for Food, Nutrition & Consumer Services Brandon Lipps on the proposed rule and its impacts on school meals. Committee members expressed disappointment that USDA does not have a plan in place to assist states with the roll out of the proposed application process. Ultimately, the proposed rule shifts costs from the federal government to states and from food assistance to administrative burden. 

The evidence from USDA’s analysis confirms that children across the country are at risk of losing access to consistent and healthy meals under this proposed rule. BPC values bipartisan solutions that improve access and better health outcomes.  We urge USDA to reconsider this proposed new rule given the negative impact it will have on school meals and our nation’s children.