75 percent of school districts have outstanding “lunch debt” racked up by students who couldn’t pay for meals. In large districts, that number can approach $1 million. At the end of the school year, when that debt comes due, kids with outstanding balances are denied opportunities to participate in activities, prevented from graduating, or forced to watch school cafeteria staff throw their food away. Pennsylvania’s Wyoming Valley West School District even threatened to place children owing as little as $10 for school lunch into foster care.
Now, a new Trump administration rule could make paying for lunch even harder for thousands of students. Via changes to a rule known as “categorical eligibility,” the Trump administration is trying to undermine access to the Supplemental Nutrition Assistance Program (SNAP). This program is commonly used as a basis for certifying kids for free and reduced lunch. That could increase the number of kids going hungry at home and struggling to pay for lunch at school.
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Under categorical eligibility, households that qualify for certain cash benefits, including Temporary Assistance for Needy Families (TANF) and General Assistance, are treated as “categorically eligible” for SNAP. Since they have already met the income and asset tests set by the state for the other program, they do not need to endure a separate eligibility determination to qualify for SNAP.
43 states have introduced a form of this known as “broad-based categorical eligibility,” which allows people to qualify for SNAP if they are eligible for certain non-cash benefits and services funded by TANF, such as child care assistance and work supports, along with Medicaid in some states. Since many states allow households with incomes up to 200 percent of the poverty line ($50,200 per year for a family of four) to receive these benefits, this method of qualifying people for SNAP creates a gradual phase out of benefits as family incomes increase. Without broad-based categorical eligibility, anyone earning more than 130 percent of the poverty line ($32,630 per year for a family of four) could lose their SNAP benefits.
In short, broad-based categorical eligibility improves access to SNAP — and would be radically altered by the new rule that the USDA will open for public comment tomorrow. Under the rule, only people receiving “substantial” benefits valued at $50 or more would be eligible, and only if they utilized work supports, child care vouchers, and subsidized employment.
The USDA estimates these changes could strip SNAP from 3.1 million people in 1.7 million households. A 2019 report estimated that similar changes could threaten access to school nutrition programs for 265,000 children who get free and reduced lunch due to their SNAP enrollment. But in a June 22 phone briefing with the House Committee on Education and Labor, the USDA admitted this number could approach 500,000.
Children in 2.9 million households experienced food insecurity in 2017. And while child poverty rates are falling, 41 percent of children remain low-income and have difficulty paying in the cafeteria — one reason the U.S. has a free and reduced lunch program. During the 2018-2019 school year, 22 million students a day ate free and reduced lunch across the United States. Nearly all U.S. public and nonprofit private schools participate in the federal school nutrition program, which compensates schools on a sliding scale for every meal served.
Eligibility for free and reduced school meals can be based on an application submitted by the student. But foster and migrant youth, runaways, and children in families with benefits like SNAP (and in some cases Medicaid) are automatically qualified for free meals. They can be identified through direct certification, a federally-required process that compares school enrollment records to records maintained by local benefits agencies. Children who qualify for SNAP via broad-based categorical eligibility may not be eligible for school lunch otherwise, say advocates. The USDA disputes this claim, saying children who lose SNAP would still be eligible by applying directly, though according to the agency’s own guidelines, this might not necessarily be true, and this would increase the administrative burden on schools.
Losing school lunch has serious implications for low-income children counting on year-round nutritional supports. Even the relatively low cost of school lunch, which typically costs less than $3 at full price, can be too much for children living on the margins. Hungry children have difficulty focusing and don’t perform as well in school. They can also experience behavioral problems that disrupt their educations as well as that of other students. Research also shows growing up with nutritional deprivation can cause developmental delays and lasting physical effects.
Fewer children eating meals is a problem for the school, as well, because school nutrition is already underfunded. The government compensates schools by meal served, not by child; if children aren’t receiving meals, the district will not receive state and federal funds. Reduced funds limit the school’s or district’s purchasing power, making it harder to negotiate affordable prices to keep meal costs down. At the same time, labor costs for school cafeterias will remain relatively consistent, forcing districts to pay for food preparation, administration, and other services with reduced budgets. Dropping children from the free lunch roll will have negative effects on district finances — which, as lunch debt shaming shows, are already precarious in some districts.
SNAP is designed to secure access to safe, wholesome food for people who have difficulty affording it on their own, and if the new rule becomes reality, affected children will lose the benefits paying for food at home as well as the eligibility for food at school at the same time. Some may go hungry, while others may begin to rack up school lunch debt, one carton of milk at a time. The affordability problem won’t vanish when the SNAP benefits do, and hunger will follow children from kitchen to classroom.
Editor’s note: This article has been updated (July 29 2019) with updated numbers regarding the estimate of how many children will be dropped from the free and reduced lunch program.