American Families Plan Could Substantially Reduce Children’s Food Hardship
When schools closed in the spring of 2020 due to COVID-19, federal policymakers enacted new laws to enable the nation’s child nutrition programs for lower-income schoolchildren to shift their focus: from mainly offering meals to large groups of children at school, to providing both meals for pick-up and grocery benefits to help low-income families prepare meals for their children at home. These changes laid the groundwork for strengthening child nutrition programs on a permanent basis so that they do more to prevent food insecurity among children.
President Biden’s American Families Plan would build on those successful changes so that when the COVID-19 crisis ends and child nutrition programs once again operate under their regular rules, child food insecurity will not return to its pre-pandemic norm. In combination with the American Families Plan’s other proposals, its proposed changes to the child nutrition programs could transform the way we provide nutrition assistance to the nation’s low-income schoolchildren.
The Biden plan includes three important provisions, each explained in a separate section below, to reduce food hardship among schoolchildren and help their families make ends meet.
- Provide Summer Electronic Benefits Transfer (EBT) nationwide every summer. To prevent the usual summertime increase in children’s food hardship, the plan would make summer grocery benefits available nationwide every summer to replace the school meals that children miss when school is out.
- Expand community eligibility. To bring free meals to all students in more schools in low-income communities, the plan would make it easier for schools serving large numbers of low-income children to offer meals at no charge under the federal Community Eligibility Provision — an option that improves student health and academic performance while reducing paperwork for schools.
- Expand direct certification. To make it easier to enroll low-income students for free or reduced-price meals regardless of where they attend school, the plan would let more states rely on Medicaid or Supplemental Security Income (SSI) data rather than require families to fill out duplicative applications.
The elevated number of children facing food hardship during COVID-19 highlighted a long-standing problem. The American Families Plan child nutrition proposals would help ensure that school-age children get enough nutritious food every day of the year.The elevated number of children facing food hardship during COVID-19 highlighted a long-standing problem. Too many children face periods of food hardship as they grow up, which can have lasting negative consequences for their health and development. Studies link food insecurity among children with reduced intake of some key nutrients, health problems, behavioral issues, and mental health conditions. These problems, in turn, can lower children’s test scores, their likelihood of graduating from high school, and their later earnings. Moreover, parents struggling to meet basic needs often report high levels of stress, which can have serious consequences for their children’s emotional and behavioral outcomes. Addressing food insecurity can mitigate these negative consequences.
The Pandemic Transformed the Child Nutrition Programs
As the number of households having trouble putting food on the table rose sharply over the past year due to COVID-19’s far-reaching health and economic impacts, especially for families with children and Black and Latino households, policymakers turned to a proven approach to alleviating children’s food hardship: providing grocery benefits to families to replace meals missed at school and child care. Policymakers also allowed schools to offer meals for pick-up or on site without forcing them to process applications or follow other program rules that would be risky or burdensome during a pandemic.
As part of COVID-19-related relief legislation over the last year, policymakers created the Pandemic EBT (P-EBT) program, under which states give families that are receiving free or reduced-price school meals the value of missed breakfasts and lunches via a benefit card that’s similar to what Supplemental Nutrition Assistance Program (SNAP, formerly food stamp) beneficiaries use. Policymakers also let the U.S. Department of Agriculture (USDA) waive child nutrition program rules so that school districts could provide meals to children when schools were closed or combining in-person instruction with remote learning. As a result, policymakers transformed how our child nutrition programs provide benefits to low-income families from providing meals in group settings at schools, child care programs, and summer activities to providing both meals at pick-up sites and grocery benefits that families can use to buy food to prepare at home.
When schools can reopen safely, many aspects of child nutrition programs will likely return to their pre-pandemic norm, but important improvements that President Biden has proposed in his American Families Plan would enable the programs to do more to prevent food hardship among school-age children.
While the number of households reporting in Census Bureau data that they had trouble getting enough to eat has declined in recent weeks as federal relief measures reached low-income families, it still far exceeds pre-pandemic levels. Black and Latino households are likelier to report difficulty getting enough to eat; data from the Census Bureau’s Household Pulse Survey collected in mid-April showed that 1 in 5 children in Black households and about 1 in 4 children in Latino households live in households in which children didn’t eat enough in the last week because the household couldn’t afford it — more than twice the rate for white children.
With the Biden proposals, policymakers have an opportunity to build on how they transformed child nutrition programs during the pandemic so that, in the future, these programs work more effectively, in combination with SNAP, to prevent food hardship among school-age children.
Provide Summertime EBT Nationwide Every Summer
For roughly 50 years, the federal Summer Food Service Program has been the backbone of the nation’s efforts to feed children while school is out. With a design akin to the school meal programs, it provides free meals to children in a group setting, usually combined with summer education or enrichment programs in low-income neighborhoods.
Due to limited funding for summer enrichment programs, as well as transportation barriers that families face, however, only 1 in 7 of the low-income children who rely on free or reduced-price meals during the school year typically receive such meals over the summer. As a result, children’s food hardship generally rises during the summer. Because even short periods of food insecurity can affect children’s learning in both the short and long term, the summertime gap in nutrition assistance has been a long-standing concern of educators, nutrition experts, community organizations, and others in the field. There is significant evidence that student skills can diminish during summers, and that this slide may be greater for children in high-poverty settings. In combination with the evidence that children’s food insecurity rises in the summer and can impair learning, increasing children’s access to healthy food during the summer may play a meaningful role in positioning them for ongoing educational success.
To address the large share of low-income children who do not receive free meals over the summer, policymakers launched a Summer Electronic Benefits Transfer (Summer EBT) demonstration program in 2011 to see whether grocery benefits would provide nutrition assistance more effectively to low-income children. And, in fact, supplemental grocery benefits measurably decreased food hardship and improved the quality of children’s diets. Despite its success, policymakers have provided only limited funding for this demonstration, enabling only a few states to offer it each year.
When COVID-19 hit, policymakers established the P-EBT program, modeled on the Summer EBT demonstration, to provide grocery benefits to replace meals that children are missing at school and child care because of school closures and remote learning. During the spring of 2020, state human services, education, and school nutrition staff worked together to implement the new program, which was ultimately offered by every state, Washington D.C., Puerto Rico, and the Virgin Islands.
The P-EBT program provides benefits on SNAP or similar EBT cards, which families can redeem at grocery stores. Children approved for free or reduced-price school meals are eligible, along with some children under 6 in households that are receiving SNAP this school year.
Under the American Rescue Plan, policymakers extended P-EBT through the summer. As a result, for the first time this coming summer, all low-income children will be eligible for grocery benefits to replace school meals while schools are closed for the summer. All states will be able to provide roughly $375 in grocery benefits for each low-income child for the summer so that families can prepare meals at home.
If every state participates, USDA reports, nearly 30 million low-income school-age children and another 4 million younger low-income children will qualify for assistance this summer. States with an approved P-EBT plan for the 2021-22 school year will be able to offer benefits during the summer of 2022 as well.
The American Families Plan includes $25 billion over the next decade to make Summer EBT benefits available nationwide in future summers. This important investment, in combination with additional investments that would make it easier for community organizations to offer summer programs with meals so that children benefit from the enrichment activities as well as the meals, could eliminate the long-standing increase in summer food hardship for low-income school children.
Expand Community Eligibility
Over the last decade, the Community Eligibility Provision of federal law, which was enacted with bipartisan support, has helped transform the school meals programs in high-poverty schools. It lets schools offer breakfast and lunch at no charge to all students in those schools and eliminates the need for schools to collect and process school meal applications, thereby increasing participation, reducing paperwork for parents, and reducing administrative work for schools. It also reduces the stigma that students sometimes associate with eating school meals and eliminates the meal fees that school districts struggle to collect from families. Community eligibility is associated with a range of positive outcomes for students, including better academic performance, lower student suspension rates, and more students with a healthy body mass index, a growing body of research shows.
School administrators, teachers, school nutrition professionals, parents, and community leaders in high-poverty communities value this simplified way to make free meals available to low-income children. As a result, the number of schools offering community eligibility has grown each year since it became available nationwide in 2014. For the 2019-20 school year, more than 14.9 million children in more than 30,600 schools and more than 5,000 school districts received meals at no charge through community eligibility — or, more than 1 in 4 elementary and secondary students nationwide.
To be eligible for community eligibility, a school, group of schools, or school district must serve breakfasts and lunches at no charge to all students and must have at least 40 percent of its students certified for free school meals other than through a school meal application. These students are termed “identified students” because they have been identified by other programs as automatically eligible for free school meals. Identified students include those who live in households that receive SNAP, Temporary Assistance for Needy Families (TANF) cash assistance, or Food Distribution Program on Indian Reservations (FDPIR) benefits; Medicaid in some states; and children who are homeless, in foster care, migrant, or in Head Start. The identified student percentage does not fully reflect the school or district poverty level, however, because more low-income children would be certified for free or reduced-price meals through an application.
Even though all students receive meals at no charge, the district is reimbursed by the federal government for only some of the meals at the “free” reimbursement rate, which is the highest rate. School districts must cover any costs that are associated with serving meals at no charge to all students and that exceed the federal reimbursement under a formula that’s based on the “identified student” percentage.
Federal reimbursements for schools that qualify for community eligibility are based on their poverty level. Schools with a larger share of identified students receive the highest federal reimbursement for a larger share of the meals served, increasing their federal funding. To determine the federal reimbursement, community eligibility increases the percentage of identified students by a “multiplier” of 1.6 to account for the additional students within the school who would have been certified for free school meals through a school meal application. Schools at the lowest level of eligibility, with identified student percentages of 40 percent, have only 64 percent of their meals reimbursed at the free rate, and they are reimbursed at a much lower rate for the other 36 percent of their meals. The reimbursement level increases as the identified student percentage increases. Schools in which 62.5 percent of the students are identified students receive the free reimbursement rate for all meals.
Because the federal reimbursement sometimes falls short of covering schools’ full costs for serving meals to all students, many eligible schools choose not to participate, leading some of their students to miss out on free school meals. For the 2019-20 school year, more than 3,700 eligible school districts and more than 13,700 eligible schools did not adopt community eligibility.
The American Families Plan proposes to increase the multiplier part of the reimbursement formula — which plays a key role in determining the level of federal reimbursements to schools for the costs of providing meals — from its current 1.6 to a new 1.9 in middle and high schools and 2.5 in elementary schools. All elementary schools that are now eligible for community eligibility would be reimbursed at the free rate for all meals served, making it feasible for all currently eligible schools. (The 40 percent or more of identified students would be multiplied by 2.5, resulting in 100 percent of the meals reimbursed at the free rate.)
In addition, a larger share of middle and high schools would be reimbursed at the free rate for all meals served, and all eligible middle and high schools would have at least 76 percent of their meals reimbursed at the free rate (because 40 percent multiplied by 1.9 results in 76 percent of meals reimbursed at the free rate). Middle and high schools with an identified student percentage of 53 percent or more would be reimbursed at the free rate for all meals served. Thus, increasing the multiplier would (1) enable more high-poverty schools that qualify for community eligibility to offer it, and (2) enable participating schools and districts to build more financially sustainable school nutrition programs over the long term.
At the same time, the American Families Plan proposes to make additional elementary schools eligible by enabling schools in which 25 percent or more of the students are identified students to participate, down from the current 40 percent. For these schools, the federal government would provide reimbursements at the free rate for between 62.5 percent and 100 percent of their meals, depending on their identified student percentage.
The multiplier used to determine federal reimbursements was originally established based on analyses showing that for every ten students directly certified in high-poverty schools, about six more students were approved for free or reduced-price meals based on an application. The goal was to provide schools that adopted community eligibility with roughly the same amount of federal funding they would receive if they accepted applications. In exchange for a simpler program and the economies of scale that come with higher participation, the schools would forgo student meal fees.
Now, with a decade of experience with community eligibility, federal policymakers should raise the reimbursement multiplier for several reasons. First, for some schools, the share of students who are identified by other programs as automatically eligible for free school meals understates poverty among students. That might be true, for instance, for schools in counties or states with relatively low SNAP participation by eligible families, and rural schools in which families may be reluctant to apply for benefits for fear that other community members will learn that they have done so. Second, school districts with higher expenses for producing meals would find the reimbursements more closely aligned to their actual costs. Rural school districts, in particular, would greatly benefit from increasing the reimbursement multiplier because they often have higher expenses due to increased transportation costs, limited food purchasing options, and smaller economies of scale. Finally, apart from the analytics of the multiplier, the evidence shows that increasing access to free school meals in schools that serve large numbers of low-income children improves their health and educational prospects. Expanding community eligibility is an important tool for achieving that goal.
The American Families Plan’s proposals would enable a much wider group of schools to offer meals at no charge to all students when COVID-19-related waivers expire. (For the costs of expanding community eligibility, see the next section.) By expanding community eligibility, policymakers can target a greater investment in universal free meals to schools serving large numbers of low-income children.
Adopting Community Eligibility This Summer
Would Benefit High-Poverty Schools for the Next Four Years
Over the last year, while many more schools have become eligible for community eligibility, or eligible for higher federal reimbursements under it, some school districts have not applied for community eligibility because it would not affect their funding or operations for this school year or the next one.a That’s because, during COVID-19, policymakers implemented waivers of many school meals program rules to allow schools to serve meals safely to students attending school in person, and to allow schools to offer meals to students learning remotely. Under the waivers, any school may offer meals at no charge to all students without processing applications for both the 2020-21 and 2021-22 school years. School districts can lock in higher reimbursement rates for continuing to offer meals at no charge to all students over the next four years by applying for community eligibility before the September 30, 2021 deadline.b
a For more information on the advantages of adopting community eligibility now, see https://frac.org/blog/kicking-off-community-eligibility-election-season.
b USDA’s guidance on adopting community eligibility for the 2021-22 school year is available at https://fns-prod.azureedge.net/sites/default/files/resource-files/COVID19NationWideWaiver82s.pdf.
Expand Direct Certification
To ensure that families who are most likely to face food hardship have access to free school meals, policymakers have enabled certain categories of children to be enrolled for free school meals automatically through an electronic data-matching process called direct certification. States or school districts match the names of children living in households that receive certain federal benefits (the most common of which is SNAP) with school enrollment records. Such students are approved for free school meals automatically, so that their families do not have to complete a school meals application. In addition to enrolling children who might not otherwise receive free meals, direct certification eliminates the burden on families of having to complete application and verification processes for benefits when the state already has data establishing their eligibility.
Since direct certification became available nationwide in 1989, federal policymakers have taken numerous steps to improve the process because direct certification improves access to school meals, reduces the administrative burden of operating the school meals programs, and improves enrollment accuracy by relying on income data that has been rigorously assessed by another program. Currently, school districts must directly certify children in households that receive SNAP. School districts also can conduct data matching to directly certify children receiving TANF cash assistance or FDPIR benefits and children in foster care. In addition, school districts can directly certify children who are homeless, runaway, migrant, or in Head Start based on documentation from relevant officials.
Due to a demonstration project launched in the 2010 Healthy, Hunger-Free Kids Act, children who are receiving Medicaid and in families with income below 185 percent of the federal poverty line may be directly certified in some states. The share of students certified for free school meals rose as a result of using Medicaid data, a USDA study showed. While some children identified through direct certification with Medicaid were previously certified for free school meals through an application, the study showed, the use of Medicaid data for direct certification reached students who would not otherwise have received free meals. These results demonstrate a promising increase in direct certification rates as well as a substantial decrease in the applications that school districts need to process and verify.
The American Families Plan proposes to expand the use of Medicaid data for direct certification. By letting all states directly certify low-income children who are enrolled in Medicaid for free school meals, policymakers could build on the demonstration to simplify enrollment for more children who are eligible for free meals.
The American Families Plan also proposes to allow, for the first time, the use of SSI program data for direct certification, which would cover disabled children in very low-income families. SSI provides federal income support to low-income families that are caring for children with disabilities. Children must meet stringent criteria to receive SSI benefits. Though 11 million children have special health care needs, few meet SSI’s strict eligibility standards — either because their disabling conditions aren’t severe enough or because their families’ income and savings exceed the program’s low limits. Directly certifying these children would help ensure that they eat nutritious meals when they can attend school and would eliminate the need for families that already face higher costs, more demands on their time, and more insecurity to complete school meal applications.
Efforts to expand community eligibility focus on improving access to free meals in schools in low-income communities. Expanding direct certification would benefit low-income students wherever they attend school by allowing them to benefit from direct certification’s simplified enrollment process. Expanding the data sources available for direct certification also would make it easier for schools to identify their low-income students and, thus, it would qualify more schools for community eligibility or would qualify eligible schools for a higher reimbursement rate under it.
The American Families Plan invests about $18 billion over ten years to expand both community eligibility (as per the previous section) and direct certification — which, together, the Administration estimates, would provide free school meals to more than 9 million additional children. Together, these proposals would substantially improve the access of low-income children across the country to free or reduced-price school meals, while strengthening program integrity and simplifying program administration.
The American Families Plan’s child nutrition proposals could usher in a new era in which food hardship is much rarer among school-age children than before COVID-19, reducing the risk of long-term adverse consequences associated with even short periods of food insecurity during childhood. By providing grocery benefits to all low-income children every summer, allowing many more schools serving large numbers of low-income children to offer meals free to all students, and making it easier to enroll low-income students for free or reduced-price school meals regardless of where they attend school, the proposals could help ensure that school-age children get enough nutritious food every day of the year.
 The White House, “Fact Sheet: The American Families Plan,” April 28, 2021, https://www.whitehouse.gov/briefing-room/statements-releases/2021/04/28/fact-sheet-the-american-families-plan/.
 Sharon Parrott, “Parrott: President’s Recovery Agenda Is an Ambitious Plan to Tackle Big Problems,” Center on Budget and Policy Priorities, April 28, 2021, https://www.cbpp.org/press/statements/parrott-presidents-recovery-agenda-is-an-ambitious-plan-to-tackle-big-problems.
 Brynne Keith-Jennings, Catlin Nchako, and Joseph Llobrera, “Number of Families Struggling to Afford Food Rose Steeply in Pandemic and Remains High, Especially Among Children and Households of Color,” Center on Budget and Policy Priorities, April 27, 2021, https://www.cbpp.org/research/food-assistance/number-of-families-struggling-to-afford-food-rose-steeply-in-pandemic-and and Claire Zippel and Arloc Sherman, “Bolstering Family Income Is Essential to Helping Children Emerge Successfully From the Current Crisis,” Center on Budget and Policy Priorities, updated February 25, 2021, https://www.cbpp.org/research/poverty-and-inequality/bolstering-family-income-is-essential-to-helping-children-emerge.
 Federal policymakers have enacted several relief packages since March 2020 to help families put food on the table and meet other needs, including the Families First Coronavirus Response Act of March 2020, the government spending bill of October 2020, the relief package enacted in December 2020, and the American Rescue Plan of March 2021. For a discussion of the specific food assistance provisions included in each piece of legislation, see “States Are Using Much-Needed Temporary Flexibility in SNAP to Respond to COVID-19 Challenges,” Center on Budget and Policy Priorities, updated May 11, 2021, https://www.cbpp.org/research/food-assistance/states-are-using-much-needed-temporary-flexibility-in-snap-to-respond-to. For descriptions of the waivers that apply to the school meal programs, see https://www.fns.usda.gov/programs/fns-disaster-assistance/fns-responds-covid-19/child-nutrition-covid-19-waivers.
 Center on Budget and Policy Priorities, “Tracking the COVID-19 Recession’s Effects on Food, Housing, and Employment Hardships,” updated May 20, 2021, https://www.cbpp.org/research/poverty-and-inequality/tracking-the-covid-19-recessions-effects-on-food-housing-and.
 Center on Budget and Policy Priorities analysis of USDA administrative data available at https://www.fns.usda.gov/sites/default/files/data-files/keydata-january-2021.xlsx.
 Jin Huang, Ellen Barnidge, and Youngmi Kim, “Children Receiving Free or Reduced-Price School Lunch Have Higher Food Insufficiency Rates in Summer,” Journal of Nutrition, Vol. 145, Issue 9, September 2015, https://pubmed.ncbi.nlm.nih.gov/26203095/#:~:text=For%20households%20participating%20in%20the,the%20year%20at%20nearly%202%25.
 Keith-Jennings, Nchako, and Llobrera, op. cit.
 David M. Quinn and Morgan Polikoff, “Summer learning loss: What is it, and what can we do about it?” Brookings Institution, September 14, 2017, https://www.brookings.edu/research/summer-learning-loss-what-is-it-and-what-can-we-do-about-it/.
 Megan Kuhfeld, ”Summer learning loss: What we know and what we’re learning,” NWEA, July 16, 2018, https://www.nwea.org/blog/2018/summer-learning-loss-what-we-know-what-were-learning/ and Karl L. Alexander, Doris R. Entwisle, and Linda Steffel Olson, “Lasting consequences of the summer learning gap,” American Sociological Review, Vol. 72, No. 2, April 2007, pp. 167-180.
 Ann M. Collins et al., “Summer Electronic Benefit Transfer for Children (SEBTC) Demonstration: Summary Report,” Abt Associates & Mathematica Policy Research, May 2016, https://fns-prod.azureedge.net/sites/default/files/ops/sebtcfinalreport.pdf.
 USDA, “Summer Electronic Benefit Transfer for Children (SEBTC),” November 8, 2013, https://www.fns.usda.gov/ops/summer-electronic-benefit-transfer-children-sebtc.
 Center on Budget and Policy Priorities, “CBPP/FRAC P-EBT Documentation Project Shows How States Implemented a New Program to Provide Food Benefits to Up to 30 Million Low-Income School Children,” www.cbpp.org/pebt.
 P.L. 117-2 § 1108.
 USDA, “USDA to Provide Critical Nutrition Assistance to 30M+ Kids Over the Summer,” April 26, 2021, https://www.usda.gov/media/press-releases/2021/04/26/usda-provide-critical-nutrition-assistance-30m-kids-over-summer.
 USDA has also estimated how many children will qualify and the amount of assistance that could flow to each state. See “Pandemic EBT – Summer 2021,” https://fns-prod.azureedge.net/sites/default/files/resource-files/21-04-24-p-ebt-final.pdf.
 Kristin Blagg, Macy Rainer, and Elaine Waxman, “How Restricting Categorical Eligibility for SNAP Affects Access to Free School Meals,” Urban Institute, October 2019, https://www.urban.org/sites/default/files/publication/101280/how_restricting_categorical_eligibility_for_snap_affects_access_to_free_school_meals_0.pdf and Amelie A. Hecht, Keshia M. Pollack Porter, and Lindsey Turner, “Impact of The Community Eligibility Provision of the Healthy, Hunger-Free Kids Act on Student Nutrition, Behavior, and Academic Outcomes: 2011-2019,” American Journal of Public Health, Vol 110, No. 9, September 2020, https://ajph.aphapublications.org/doi/full/10.2105/AJPH.2020.305743.
 Crystal FitzSimons, Alison Maurice, and Melissa Osbourne, “Community Eligibility: The Key to Hunger-Free Schools, School Year 2019-2020,” Food Research & Action Center, May 2020, https://frac.org/wp-content/uploads/CEP-Report-2020.pdf.
 National Center for Education Statistics, “Digest of Education Statistics,” https://nces.ed.gov/programs/digest/d19/tables/dt19_105.20.asp.
 See 42 U.S.C. § 1759a(11)(a)(1)(F).
 White House/USDA Nutrition Stakeholders Briefing, April 29, 2021.
 Christopher W. Logan et al., “School Nutrition and Meal Cost Study—Volume 3: School Meal Costs and Revenues,” Abt Associates for Food and Nutrition Service, USDA, April 2019, https://fns-prod.azureedge.net/sites/default/files/resource-files/SNMCS-Volume3.pdf.
 For a discussion of the history of direct certification and policy changes over the years, see “Direct Certification Improves Low-Income Student Access to School Meals: An Updated Guide to Direct Certification,” Food Research & Action Center, November 2018, https://frac.org/wp-content/uploads/direct-cert-improves-low-income-school-meal-access.pdf.
 Lara Hulsey et al., “Direct Certification with Medicaid for Free and Reduced-Price Meals (DCM-F/RP) Denomination, Year 1,” USDA, Food and Nutrition Service, August 2019, https://fns-prod.azureedge.net/sites/default/files/resource-files/Evaluation-DCM_Year1.pdf.
 Center on Budget and Policy Priorities, “Supplemental Security Income,” January 29, 2018, https://www.cbpp.org/research/social-security/supplemental-security-income-ssi.
 Kathleen Romig, “SSI: A Lifeline for Children with Disabilities,” Center on Budget and Policy Priorities, May 11, 2017, https://www.cbpp.org/research/social-security/ssi-a-lifeline-for-children-with-disabilities.