FRAC Chat

Published August 26, 2026

For more than a decade, high-poverty schools across the country have been able to offer free breakfast and lunch to all students through the Community Eligibility Provision (CEP), reducing stigma and making it easier for children to access the nutrition they need to learn and thrive. Since becoming available nationwide in the 2014–2015 school year, CEP adoption has expanded dramatically, reaching over 27 million students in the 2025–2026 school year, and has become a cornerstone strategy for reducing childhood hunger. A new study by FRAC and the Urban Institute, Expanding the Reach and Impact of School Meals: How and Why Do Changes to the Community Eligibility Provision Affect Adoption?, examines over a decade of CEP implementation and sheds light on what drives schools to participate.  

To better understand how CEP is working, we analyzed which schools participate, who they serve, and how participation has changed over time in states that do not subsidize CEP either through specific CEP state policy (Oregon and Washington) or through Healthy School Meals for All, offering a free school breakfast and lunch to all students regardless of their household income (California, Colorado, Maine, Massachusetts, Michigan, Minnesota, New Mexico, New York, and Vermont). We compared participating and nonparticipating schools based on student demographics, geography, and poverty levels, and examined how changes to CEP’s participation threshold, as well as Medicaid direct certification, influenced CEP adoption. We also tracked schools’ long-term participation patterns, and evaluated how CEP affects school district finances, including revenues and expenditures. Finally, we explored whether these impacts differ across urban, suburban, town, and rural communities. 

The report reveals that: 

• CEP participation is concentrated in higher-poverty, urban schools. Participating schools typically have higher identified student percentages (ISPs). ISP is the share of students who are automatically eligible for free school meals without having to submit a school meals application.1 The higher the school’s ISP, the more federal reimbursement CEP schools receive, therefore making CEP more financially feasible. In addition to having higher ISPs, our research found that CEP schools are more often located in urban areas and serve larger shares of Black and Hispanic students than eligible nonparticipating schools. 

• CEP participation is highly stable among high ISP schools. Most schools that adopt CEP remain in the program over time, with schools that have higher ISP rates — above 60 percent — tending to participate longer. In fact, only 11 percent of CEP schools dropped the program across the years studied. Those that discontinued CEP tended to have lower ISPs.  

• Expanding eligibility increased access, but not large uptake. In 2023, the U.S. Department of Agriculture (USDA) lowered the CEP eligibility threshold from 40 percent ISP to 25 percent ISP. While this change made thousands of additional schools eligible, only about 7 percent of newly eligible schools in non-Healthy School Meals for All and non-CEP subsidy states adopted the program in the policy’s first full year, 2024–2025. 

• Medicaid direct certification supports participation. Direct certification has streamlined access to free school meals by automatically enrolling eligible children, reducing paperwork for families, and easing administrative burdens for schools. It also serves as the basis for determining CEP eligibility and federal reimbursement. Introduced in the Healthy, Hunger-Free Kids Act of 2010, the USDA’s Direct Certification with Medicaid for Free and Reduced-Price Meals demonstration project allows participating states to match Medicaid and household income records with school enrollment lists to identify children as eligible for free or reduced-price meals. Children who are directly certified for free meals using Medicaid and household income data are counted towards a school’s ISP. As of the 2026–2027 school year, 44 states are participating in Medicaid direct certification. Our research found that states using Medicaid direct certification saw higher ISP rates and increased CEP participation, as more schools qualified for and adopted the program. 

• CEP strengthens school meal program finances. Federal reimbursement for CEP schools is calculated by multiplying a school or school district’s ISP by 1.6 to determine the share of meals that will be reimbursed at the federal free rate, with the remainder of meals reimbursed at the lower federal paid rate. Schools with ISPs equal to or greater than 62.5 percent receive the higher, federal free rate for 100 percent of the meals served (62.5 x 1.6 = 100). Schools with lower ISPs receive less federal funding to implement CEP. Since CEP schools do not charge students for meals, they do not collect fees or payments from students who previously paid for meals. We found that districts adopting CEP generally experienced growth in federal reimbursements that exceeded the revenue they would have collected from paid and reduced-price meals. 

• Financial impacts vary by district type. While CEP shifted funding from local to federal sources across urban, suburban, town, and rural districts, the size of revenue and expenditure changes differed by locale, with rural districts typically experiencing smaller effects. 

CEP Roadblocks 

This research shows that CEP is working, but too many eligible schools still face barriers that make participation difficult. Schools with higher levels of federal reimbursement are better positioned to implement and sustain CEP, while schools closer to the eligibility threshold — especially those with ISPs below 40 percent — struggle to cover the cost of serving all students free meals on federal reimbursements alone. Those challenges will grow as https://frac.org/hr-1cuts to the Supplemental Nutrition Assistance Program continue to take effect. When children lose access to SNAP, schools’ ISPs fall, reducing federal meal reimbursements and making CEP harder to sustain. As a result, some schools may be forced to drop CEP and no longer offer meals to all students at no charge. That would mean an increase in hunger in classrooms and the return of stigma in the cafeteria. It would also mean more administrative work for families and schools. 

Supporting CEP and School Meals 

Thankfully, Congress has the power to reverse the SNAP cuts and invest in school meal programs. Join FRAC as we urge Congress to pass the Universal School Meals Program Act, which would create a nationwide Healthy School Meals for All policy, and ensure that every student in every state has access to the nutrition they need to succeed in the classroom and throughout their school day. 

For a deeper look at the data, join FRAC’s webinar, The Reach and Impact of CEP: Insights from a Decade+ of Implementation, on Thursday, Sept. 3 at 3 p.m. ET.