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It’s no wonder why: As child hunger rose at alarming rates in 2020, the U.S. Department of Agriculture (USDA) issued waivers to allow schools to distribute all meals free of charge. Schools struggling with tight budgets and supply chain issues no longer had to spend time and resources on paperwork to determine eligibility for free or discounted meals. Meals for all meant the threat of lunch shaming was eliminated. And as a result, many lawmakers expressed enthusiasm for the cause and even introduced bills to make the changes permanent. Legislators in California and Maine passed laws guaranteeing free meals for all students, and many others are considering similar legislation or have extended free meals through the current school year.

However, as two major federal policy milestones for child hunger and nutrition approach, it no longer seems politically possible to guarantee free meals for all students in all states, primarily due to Republican opposition. Meanwhile, the USDA’s waivers are expiring, and in most states, kids are going back to school with old systems of applications and payment back in place.

So, while advocacy groups are still pushing for universal school meals in reports and comments submitted ahead of the upcoming White House Conference on Hunger, Nutrition, and Health, they are also lining up to support smaller policy tweaks that seem more possible, especially as part of the long-awaited Child Nutrition Reauthorization (CNR).

“At this moment in time, it seems very unlikely that Congress will pass federal legislation providing free meals to all kids,” said Lisa Davis, senior vice president of Share Our Strength, the organization behind the influential No Kid Hungry campaign. “But I think it’s important to be creative and remember that there are a lot of different roads to Rome. There are a lot of ways to expand the availability of free meals to kids—at the state level and even at the federal level, in a more targeted way.”

As the 2022–2023 school year kicks off, Davis believes the conversation is more important than ever. “Families are still hurting, and yet many of those supports that kept us from having a devastating food security crisis at the height of the pandemic are gone or going away,” she said. “Given the challenges facing school meal programs and the challenges facing families, it’s crucial that our nation continues to invest in the proven programs and policies that keep kids fed.”

Eliminating the Application Process

One of those expansions involves introducing additional ways to eliminate the application process. In order to qualify for free or reduced price meals, many families have to submit paperwork with income information. School nutrition directors have long reported that the process of soliciting and processing that paperwork is costly and time consuming. In recent listening sessions, many directors anticipated that getting families to submit paperwork will be harder than ever this school year, since no one has had to do so for the past two years.

But there’s another process to determine kids’ eligibility for free meals: direct certification. Children who come from families who are enrolled in the Supplemental Nutrition Assistance Program (SNAP), for example, automatically get certified, since the income eligibility criteria are similar.

Anti-hunger groups like the Food Research and Action Center (FRAC) have long pushed for improving and expanding direct certification. “We’re finding this really needs to be a priority,” said Clarissa Hayes, the deputy director of school and out-of-school time programs at FRAC.

To that end, Hayes and others are supportive of a provision in the current CNR draft that would increase the number of states directly certifying children in families using Medicaid.

Some states have already piloted the change for varying lengths of time, and results suggest that many more students would automatically qualify for free meals. One 2015 USDA analysis that looked at the potential impact in six pilot states found that the direct certification rate in those states would likely increase by 12 percent if Medicaid were included.

It also determined that, because the income requirements for school meals and Medicaid are different and vary state by state, only half of those students from low-income families would have qualified for free meals if their families had to apply. Texas began directly certifying students from families on Medicaid in 2017, and a state report found that between the 2017 and 2020 school years, the number of students directly certified for free meals increased by 48 percent, resulting in 376,000 fewer applications for schools to process.

“It’s a no-brainer,” said Dariush Mozzafarian, dean of the Friedman School of Nutrition Science and Policy at Tufts University, who is currently leading a task force related to the White House Conference on Hunger, Nutrition, and Health and who co-authored a recent journal article on priorities for the 2022 CNR. “There absolutely needs to be better coordination across federal investments to address health and equity, whether that’s Medicaid and the school lunch program, or Medicaid and SNAP, or Medicaid and WIC—all of those things should be coordinated better.”

The Community Eligibility Provision

Created during the last CNR, CEP allows schools or districts that serve a high percentage of low-income students to opt to serve free meals to all students instead of requiring applications. Schools are then reimbursed for meals using a different formula.

The reason direct certification matters here is that the threshold at which schools are eligible to choose CEP is based on the percentage of students—currently 40 percent or more—directly certified for free meals. So if more students are certified, more schools will potentially qualify to operate under CEP.

In 2014, about 14,000 schools chose to use CEP. By 2020, that number more than doubled to 33,000 schools. But more than 30 percent of eligible schools still don’t choose the program.

In a qualitative study of Maryland CEP schools published in 2021, many school food operators said one challenge to participating is that if a school’s number of direct-certified students is right at the threshold or drops, the school is reimbursed for fewer meals at the highest rate, and making it work financially becomes challenging.

Proposed changes in the CNR draft would attempt to address that issue by not only lowering the threshold at which schools are eligible to participate—to 25 percent—but, importantly, by increasing per-meal reimbursements for schools that participate in CEP. In other words, the aim is to alter the program so that it makes more financial sense for schools struggling with tight budgets to opt in.

Aside from potential financial constraints, participants in the Maryland study shared that overall, CEP allowed them to feed more children, reduced the administrative burden on staff, and alleviated family stresses around school meal payment and debt. “Since we had this program, the kids are very happy. We’re happy, too, because we won’t be hearing the kids say, ‘I don’t have no money and can’t pay my lunch,’” according to one cafeteria manager quoted in the report.

“I think it has been positive for [cafeteria staff],” another food service director shared. “No one likes to be put in a position when you’re taking meals away from students. That’s pretty demoralizing as a worker.”

In addition to these provisions, which have broad support among anti-hunger groups, another promising change involves making permanent a pandemic-related summer EBT program that provides funds for students missing summer meals. But Davis at Share Our Strength said the fact that schools currently have to serve summer meals on site, when kids aren’t in classes, is another big barrier, because it requires travel that most families can’t or won’t do.

“During the pandemic, schools and community organizations were able to allow families to pick up several days’ worth of meals in one shot, and many programs delivered meals to kids. The number of summer meals served doubled and even tripled in some places, so we know that flexibility works,” said Davis.

Diane Pratt-Heavner, the director of media relations for the School Nutrition Association, which represents school meal operators, also expressed hope that negotiations around CNR could lead lawmakers to raise the proposed overall 10-cent reimbursement increase per meal.

“We are grateful for any increase we can get, but we’re concerned that it won’t be enough,” she said, referring to challenges cited in SNA’s latest national survey of people working in school cafeterias, such as high food costs and persistent supply chain issues. “We’re going to have to keep an eye on the financial situation schools are facing this year.”

In the end, Pratt-Heavner and most of the advocates pushing to expand school meal access are willing to accept incremental changes but haven’t lost sight of free meals for all students.

“[Universal school meals] will always be the long-term goal, and I think the public, Congress, and USDA are going to see how difficult the transition is back to this application process and the tiered payment system,” Pratt-Heavner said. “It’s going to be tough for families who for the last two years have benefited from knowing their kids would be well-fed at school.”

But she notes that in the meantime, “If we can get more kids who we know are eligible for free or reduced priced meals to be automatically brought into the system [through other tweaks to current policy], we’re going to have fewer kids going without.”