Two million families with children could lose access to the Supplemental Nutrition Assistance Program (SNAP) under the administration’s proposed changes to broad-based categorical eligibility (BBCE), and the ripple effects could be felt throughout schools, districts, and states.

In a brief released last week, Urban Institute researchers Elaine Waxman and Nathan Joo note that proposed changes to BBCE, which gives states flexibility to expand access to SNAP benefits by increasing income limits and removing or relaxing asset limits, would result in 2 million people in families with children losing access to benefits. As they write, this has important implications for children’s short- and long-term outcomes.

Along with losing access to SNAP, these children, many of whom are from families earning slightly more than 130 percent of the federal poverty level but facing significant expenses, could also lose access to free school lunches.

Which students get free or reduced-price lunch?

A little background: schools formerly used paper forms and family outreach to determine which students were eligible for free or reduced-price lunches (FRPL). But a 2010 policy known as the Community Eligibility Provision (CEP) allowed states to count whole schools or districts as FRPL-eligible if 40 percent of the student body could be “directly certified” as low-income based on participation in another public benefit program.

Though some states use additional programs for direct certification, every state uses SNAP. Qualify for SNAP, and you qualify for FRPL. If 40 percent of a school’s students receive SNAP benefits, every student at that school receives FRPL. Direct certification was a more efficient way to find students in need, and CEP expanded the reach of the National School Lunch Program.

If BBCE is eliminated, the administration has estimated (PDF) that 500,000 students could lose automatic eligibility for free lunch. If 500,000 students lose their certification, it’s a safe bet that some schools would lose access to CEP, causing even more children to potentially lose access to free or reduced-price meals. States could return to determining eligibility through paper forms, but that would pose a significant administrative and financial burden to schools.

Implications beyond school lunch

There’s another complication, as researcher Erica Greenberg detailed in a brief last year: as paper FRPL forms have fallen by the wayside, the number of students directly certified as low-income is increasingly used in accountability and funding systems. Eligibility for federal Title I funds is reserved for schools or districts serving high shares of low-income students.

Allowing 2 million families with children to fall off the SNAP registers could result in fewer students being identified as low-income, leading schools and districts to potentially lose access to this critical funding stream. (If you want to see how different states use SNAP and other programs for funding or accountability purposes, you can explore Urban’s new tracker.)  

Direct certification is not without its flaws, and it can miss important populations, particularly immigrant families. But it is important for distributing school funding and free meals to the students most in need, and SNAP is the one program used nationwide for direct certification. Eliminating BBCE could cut students and schools off from critical assistance.