Brief The States That Need It Most Might Not Enroll in Statewide Free Meals
Emily Gutierrez
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President Biden’s proposed Build Back Better agenda would allow states to provide free school meals to all students, but the proposed reimbursement structure might discourage some states where child poverty is highest from enrolling.

Build Back Better proposes to expand the Community Eligibility Provision (CEP) of the National School Lunch Program to the state level. Statewide expansion of CEP would allow states to be reimbursed in full or in part for universal free school meals, but because of the way low-income students are counted under CEP, the states most in need are not always the ones that would receive the largest reimbursement. States would be better positioned to widely address student hunger if the proposed bill included more inclusive ways to count eligible students and changes to the reimbursement structure that more directly reflected child poverty.

Key Context

The reimbursement calculation for CEP is based on the identified student percentage (ISP)—that is, the number of students directly certified as eligible for free meals based on their household’s participation in certain safety net programs plus students identified as homeless, runaway, or in foster care. Criteria for inclusion in the ISP vary by state. Under the proposed CEP expansion, states with ISPs of at least 40 percent would be fully reimbursed, while states with ISPs below 40 percent would be partially reimbursed.

But because of states’ varying rules around participation in social safety net programs, ISP and child poverty rates are only loosely correlated.

Key Numbers

  • Of the 27 states that report direct certification rates (which are a close estimate of ISPs), only 4 would be eligible for full reimbursement of statewide free meals. In 11 of those 27 states, more than 20 percent of children live in poverty.
  • Twenty-four percent of children in Alabama live in poverty, but the state’s direct certification rate is only 33.9 percent. This means Alabama would be only partially reimbursed for free meals if it chose to participate at the state level.
  • Meanwhile, Florida has a direct certification rate of 41.3 percent and would be eligible for full reimbursement, though its child poverty rate is nearly 5 percentage points lower than Florida’s.


This disconnect between child poverty rates and direct certification rates (and therefore ISPs) is likely to create a disconnect between the states that enroll in statewide free meals and those that most need statewide free meals. Though places like Florida; Washington, DC; and West Virginia—with direct certification rates above 40 percent—would have incentives to adopt the proposed structure, states such as Alabama with higher child poverty rates but direct certification rates below 40 percent would be responsible for covering any gaps between reimbursements and the cost of producing meals, and may be less likely to enroll.

Previous versions of the Build Back Better framework had proposed to add Medicaid to the list of directly certified programs for all states—it is currently used in only some states—which would help make ISPs more reflective of a state’s child poverty rates. Beyond this, the disconnect between ISP and child poverty could be solved by using a different metric, such as census-related poverty rates, rather than ISPs, and a different reimbursement multiplier.

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Additional Resources

Research Areas Education
Tags Hunger and food assistance K-12 education
Policy Centers Center on Education Data and Policy