Free school meal access has become increasingly intertwined with federal social safety net programs—including the Supplemental Nutrition Assistance Program (SNAP)—to reduce duplicative paperwork for schools. The changes to SNAP that House Republicans have proposed would have downstream effects on free school meal access.

New Urban Institute analysis finds that within a sample of 37 states and the District of Columbia, an estimated 832,000 students might need to revert to school meal applications, something that has always been associated with stigma and has become less common because of the rise in universal free meal programs such as the Community Eligibility Provision (CEP) in the wake of the pandemic. Moreover, at least 18 million students nationwide are enrolled in schools that could be subject to increased costs that could threaten their access to the popular CEP if the proposed changes to SNAP take effect. Although individual students would remain income eligible for free school meals, the changes to SNAP could leave fewer students automatically enrolled for these meals, especially if students enrolled in both SNAP and Medicaid were to lose both benefits. Further, reduced participation rates in SNAP and Medicaid could increase school meal costs in schools, districts, and states, especially in the eight states with statewide universal free meal policies. This could lead to the rollback of universal school meals in some cases.

Current Reconciliation Proposals Could Limit Free Meals for Individuals and Make Offering Universal School Meals More Costly

Free school meal access and SNAP, though different policies, are inherently tied together. Students living in households participating in SNAP are directly certified for school meals, meaning their families do not have to fill out meal applications because their school records are administratively matched. Further, a student household’s SNAP participation is counted toward a school or district’s CEP threshold, which enables the school or district to offer free school meals to all students. Any decrease in SNAP participation among school-age children, and thus direct certification numbers, could affect individual student eligibility and could increase the cost of providing universal school meals for most CEP schools.

In addition to SNAP, 44 states include Medicaid in their list of programs to directly certify students for free meals, but successful matching rates vary by state. Previous research finds that approximately 75 percent of children receiving SNAP benefits are also enrolled in Medicaid. Given the uncertainties around the current Medicaid proposals set forth by House Republicans, it is unclear whether students who lose SNAP based on the current SNAP proposals would also lose Medicaid. But if SNAP proposals were to pass and student participation rates in Medicaid were to remain unchanged, we can assume that approximately 75 percent of the students losing SNAP would remain directly certified via Medicaid. I plan to provide further and additional analysis incorporating Medicaid data in a longer version of this analysis.

The proposed changes to SNAP—including stricter work requirements for households with children 7 or older—would lead to fewer directly certified students. The proposal also increases administrative costs and shifts a portion of benefit costs to states. Because states are required to maintain a balanced budget, any cost increases could lead to additional eligibility restrictions and potentially lower benefit amounts for households.

How Many Students Could Lose Access to SNAP?

To calculate the number of students who could lose access to SNAP and therefore direct certification status, I used data from the US Department of Agriculture’s Food and Nutrition Service and Mathematica’s 2023 SNAP Quality Control database. For each of the three proposed changes, I make the following assumptions:

1. Households with children 7 and older who are not currently meeting the proposed work requirements would lose SNAP eligibility. Previous research finds that 3 percent of school-age children who have a parent who loses eligibility would lose SNAP benefits under this proposal, so I decrease the number of school-age children participating in SNAP who have a parent who loses eligibility by 3 percent.
2. In response to increased cost shares, I assume that states would eliminate Broad-Based Categorical Eligibility, meaning all school-age children in households with incomes above 130 percent of the federal poverty level would lose access to SNAP and potentially their direct certification status.
3. In response to increased cost shares, I assume states would reduce SNAP benefits in proportion to their increased administrative and benefit costs. I also assume that households qualifying for a new, lower benefit amount of $22 would no longer participate.

I estimate the following:

• 1.4 million school-age children would lose access to SNAP if all three proposals pass
• 96,458 school-age children would lose access if the time and work requirements pass
• 1.3 million school-age children would lose access if Broad-Based Categorical Eligibility were eliminated
• 127,790 school-age children would lose access if the benefit cost share were enacted

How Many Students Could Lose Access to Free School Meals?

To calculate the number of students and schools at risk of losing free meal access, I use 2023–24 school-level meal eligibility data from the Common Core of Data via Urban’s Education Data Portal and data from the Food Research & Action Center’s Community Eligibility Provision database, as well as the state-level estimates calculated from the SNAP Quality Control data. These estimates depend on the availability of direct certification data for all students in each state.

I differentiate between schools that offer universal free meals via CEP and schools that serve free meals to individually eligible students, as well as states with universal free meal policies. I find that at least 18.3 million students could lose access to free meals either via individual certification or through their school or state’s participation in universal free meal programs.

These estimates do not account for student participation in Medicaid or other programs, which can also determine certification for free school meals. If child participation rates in Medicaid were to remain unchanged, the number of students that would no longer qualify for meals via direct certification would be appreciably lower than estimates provided here and would result in smaller direct certification rate decreases for CEP schools, affecting fewer students.

• At least 832,000 students would no longer qualify for free school meals through direct certification of SNAP eligibility and would have to fill out a meal application form.
• At least 907,425 students in states without statewide universal free meal policies would have school-level direct certification rates below 25 percent, meaning their schools would no longer be eligible to participate in universal free meals via CEP.
• At least 7.2 million students in states without statewide universal free meal policies are enrolled in schools that would have to cover increased meal costs, as schools with direct certification rates between 25.0 and 62.5 percent are not reimbursed for 100 percent of meals served at the federal rate. These schools would have to determine whether continuation of CEP is financially viable.
• Up to 9.9 million students are enrolled in the eight states that use federal school meal programs to operate statewide universal free meals for all (i.e., California, Colorado, Maine, Massachusetts, Michigan, Minnesota, New Mexico, and Vermont). Decreases in SNAP participation and therefore direct certification rates, similar to schools, will increase costs for the states and could put universal free meals at risk.

How Would Changes Affect Student Achievement?

Research shows that providing free meals for all students helps students feel safer and that school is a welcoming place, leading to higher student achievement and better student discipline. Though income-eligible students in schools that fall below the CEP threshold would not lose access to free and reduced-price meals, other students would have to fill out eligibility forms, which can carry a stigma and could lead to fewer students applying for free meals. As a result, food-insecure students might go without, especially older students, among whom stigma can be perceived at higher levels. These proposed changes would indeed have implications for SNAP households across the nation and for school-age children’s access to free school meals. Policymakers will have to weigh the effects of the proposed eligibility and financial changes to SNAP (and Medicaid) against the downstream implications for student access to school food.