Updated October 21, 2019

By Crystal FitzSimons, Director of School and Out-of-School Time Programs, and Ellen Vollinger, Legal/Food Stamp Director

The Trump administration recently proposed a rule to gut states’ option to use broad-based categorical eligibility (Cat El) for the Supplemental Nutrition Assistance Program (SNAP).  If adopted, the rule would eliminate SNAP benefits for 3.1 million people, and a newly released USDA analysis found that it would jeopardize nearly one million children’s access to free school breakfast and lunch. When USDA issued its new analysis of the impact of the proposed rule on access to free school breakfast and lunch, it re-opened the comment period until November 1st.

Broad-based categorical eligibility allows more families that get services funded by the Temporary Assistance for Needy Families (TANF) program to qualify for SNAP benefits if their net incomes are at or below 100 percent of the federal poverty line.

Among those harmed by the proposed rule would be school children. This blog describes the important role that SNAP plays in linking children to free school meals when their families are struggling and are in need of nutrition assistance. It explains how the proposed change would undercut that link and how it would impact food assistance for many school children living in low-income households.

What is the relationship between SNAP and school meals?
Children who live in households that receive SNAP benefits are directly certified (automatically eligible) to receive free school meals.

How does the link to SNAP streamline and improve households’ access to free school meals?
Children who are not automatically eligible for free school meals must submit a school meal application demonstrating that their household’s gross income is at or below 130 percent of the federal poverty line. Those with household incomes between 130 and 185 percent of the federal poverty line are certified to receive reduced-price school meals and can be charged a maximum of 30 cents per breakfast and 40 cents per lunch. Those whose household incomes are above 185 percent of the poverty line do not qualify for subsidized school meals and are generally charged the majority of the school meal’s cost.

In contrast, SNAP benefit eligibility involves gross income and net income limits. In states taking the SNAP Cat El option, some households who have gross incomes between 130 percent and 200 percent of the federal poverty line, but whose high costs for other basics, such as shelter, utilities, and child care, render their net incomes at or below 100 percent of the federal poverty line, still qualify for a SNAP benefit. In turn, the children in those SNAP households are directly certified for free school meals without additional red tape for them or the school. The U.S. Department of Agriculture (USDA) estimates that 1.7 million individuals would fail to meet the gross income test that the proposed rule would set. USDA’s newly-released analysis of the proposed rule found that, of the one million children no longer automatically eligible for free school meals, the majority would no longer qualify for free school meals: 497,000 children would only qualify for reduced-price meals and to receive them their families would have to navigate the school meal application process, and 40,000 would not be eligible for free or reduced-price school meals.

The broad-based categorical eligibility option also allows states to eliminate the outdated and administratively complicated SNAP asset tests. Most states have done so. USDA estimates that 1.4 million individuals would lose SNAP eligibility due to the proposed rule’s reimposition of the federal asset limit in all states. USDA’s analysis finds that 445,000 would still be eligible for free school meals. Because they are no longer automatically eligible for free school meals, they (like the students who would become eligible for reduced-price school meals) would have to navigate the school meal application process.

How are TANF families impacted?
Children who receive TANF cash benefits are eligible for free school meals. TANF-funded cash benefits, however, represent only a small percentage of TANF expenditures. The broad-based categorical eligibility option gives states flexibility to get SNAP to more households that do not receive TANF cash payments, but do get TANF-funded in-kind services. The proposed SNAP rule change would undercut the Cat El option for most households that receive TANF-funded in-kind services, but not cash. USDA estimates that the proposed rule would eliminate SNAP benefits for 7.4 percent of SNAP households with children.

Who are the children that would lose free school meals?
They come from working poor families and families with grandparents. They come from families who are struggling to put food on the table, but do not meet SNAP’s gross income test that requires the household income to be at or below 130 percent of the federal poverty line or its asset test; therefore, they would not be allowed to qualify for a SNAP benefit even if their net income is at or below 100 percent of the federal poverty line. A family of three’s annual net household income must be less than $21,330 to receive benefits. A family struggling with this low net income needs nutrition assistance through SNAP and free school meals.

How will the proposed rule impact the Community Eligibility Provision?
Community eligibility is a hugely successful option that allows over 28,500 high-poverty schools to offer free breakfast and lunch to their students. In order to qualify, at least 40 percent of the students must be certified for free school meals without an application (called identified students). Identified students are a subset of the low-income students in a school, since additional students would be certified for free or reduced-price school meals through the application process. Once a school is eligible, its reimbursement is determined by its percentage of identified students: that percentage is multiplied by 1.6 to account for the additional students who would be certified through the application process. The vast majority of identified students are certified for school meals through SNAP. Reducing the number of children who are certified through SNAP will result in fewer schools qualifying for community eligibility, and schools that qualify for community eligibility may find that the option is less financially viable because the federal reimbursement will be lower.

What will happen to school lunch debt?
Already 75 percent of school districts are dealing with unpaid school meals fees, according to the School Nutrition Association’s report, The State of School Nutrition 2018. Moving struggling families out of free school meals likely will result in more unpaid school meals fees for schools to contend with. And in the districts that do not provide meals to children who do not have money in their school meals account, children will be sitting in classrooms hungry.

How important are school meals?
The nutritious breakfasts and lunches that low-income children receive at school help combat childhood hunger, while playing an important role in improving academic achievement and test scores, and reducing absenteeism, tardiness, and discipline referrals.

What does it mean to lose SNAP benefits and free school meals?
Children will be hungry at home and school. Since childhood hunger is linked to academic struggles, difficulties focusing and concentrating, mental health disorders, and increased behavioral referrals, many schools would struggle to meet the educational, health, and mental health needs of the nearly one million students who lose SNAP benefits and whose access to school meals is jeopardized if the proposed rule were to go into effect.

Take a stand against the Trump administration’s proposed rule by submitting a comment.

Click to Tweet: A new Trump admin. proposed rule would take away SNAP from 3M+ people, and put 500K+ children at risk of losing free #SchoolMeals. @fractweets experts explain what reduced access to SNAP and school meals means for our country: bit.ly/33kQBZH #HandsOffSNAP #FRACChat