What’s Inside? (Table of Contents)

  • Summary
  • What is the Community Eligibility Provision?
  • Who Benefits From the Community Eligibility Provision?
  • Why does this Rule Change Matter?
  • How Can I Learn More and Take Action?


On March 23, 2023, the United States Department of Agriculture Food and Nutrition Service (USDA) proposed a rule change to dramatically expand child access to school meals. They propose to lower the threshold that schools have to meet to qualify for the Community Eligibility Provision (CEP), a federal program that enables eligible schools to serve free meals to all students. Currently, schools can qualify for the program if they have an Identified Student Population (ISP, definition below) of 40%. USDA wants to lower the threshold to qualify for CEP from 40% to 25%. This change will greatly increase the number of schools that are eligible for the program and increase the number of students benefiting from healthy school meals. 

National Farm to School Network is a champion of this rule change. We urge our partners to submit comments to the USDA in support of expanding access to CEP.

Comments are due May 8, 2023. Continue reading for more information on the proposed change, why it is important, and how to take action. 

What is the Community Eligibility Provision?

When did CEP start?

Who benefits from this program?

  • One in three schools participated in CEP in the 2021-22 school year, according to a report by the Food Research and Action Center. This amounts to over 33,000 schools, which represent 16.2 million students, or nearly a quarter (22%) of all children under 18 in the US. Most eligible schools (74.3%) participate in CEP.

Who can qualify for CEP?

  • To be eligible to operate CEP, a school within a district must have an Identified Student Percentage (ISP) of 40% or higher. Schools can also form groups to increase their ISP and maximize federal funding. 

What is an Identified Student Percentage?

  • The “identified student percentage” (ISP) is calculated by dividing the total number of identified students by the total number of enrolled students. “Identified students” are students who are categorically eligible for free meals without the need for a household income application. For example, students are considered categorically eligible if they are enrolled in Head Start or Early Head Start, the Supplemental Nutrition Assistance Program (SNAP, formerly known as food stamps), and other similar federal assistance programs, or are homeless, migrant, runaway, or are in foster care. Additionally, the USDA began a pilot program in 14 states to directly certify students if they are enrolled in Medicaid. 

How are schools funded through CEP?

  • Schools are reimbursed using a formula that multiplies Identified Student Population by 1.6. This number will give schools the percentage of meals they serve that are fully reimbursed by the federal government. For example, a school with an ISP of 56% will be federally reimbursed for 93% of the meals they serve. The remainder of funding would have to come from non-federal sources. A school with an ISP of 63% will be reimbursed for all meals they serve by the federal government. So among schools that participate in CEP, those with higher ISPs will be reimbursed for a higher percentage of meals served. 

Who Benefits from the Community Eligibility Provision?

During the COVID-19 pandemic, the federal government made all school meals temporarily free to students. The nation was able to see first-hand the difference this support made in communities. Providing healthy school meals for all through CEP provides similar benefits throughout the school community, backed up by a robust and growing body of research evidence. NFSN has created a 3-page list of talking points that stem from this research in the context of this proposed rule change. 

It benefits students:

  • It promotes equity. More students have access to healthy school meals, regardless of income.
  • Without cash registers, there are shorter lunch lines and more time to eat lunch.
  • There is no stigma associated with eating school lunch.
  • We know hungry students can’t learn. School meals for all improve student outcomes by ensuring kids can stay focused in the classroom.

It benefits parents:

  • Parents experience less stress when they don’t need to worry about preparing school lunches or paying for meals at school 

It benefits school nutrition professionals.

  • There is less administrative burden for schools, which do not have to process school meal applications if they participate in CEP. 
  • There are fewer reporting requirements for schools, which previously had to track each meal by payment category (such as free, reduced-price, or paid meals).
  • Schools no longer have to act as debt collectors. They do not need to call parents to make up for unpaid meals. This has become a growing problem, especially after the COVID-19 pandemic.
  • The lunch line is faster, without the need to collect payment from students.
  • Reduced administrative burden means that more time can be spent on scratch cooking and purchasing local ingredients.

Why does this Rule Change Matter?

It will increase the number of students benefiting from healthy school meals.

More schools can participate: This rule change will lower the threshold to participate in CEP from 40% to 25%, meaning that many more schools (and more students) will be able to benefit from this program. According to Food Research and Action Center, this change will expand CEP to reach an additional 9 million students in 20,000 more schools that would now be eligible for the program. Some states even require schools to participate in all federal food assistance programs in which they qualify, which ensures more schools will benefit from CEP.

Student meal participation increases with universal access: Meal participation increases when students have access to healthy school meals. 

It will make statewide universal meal policies more appealing to state governments. 

National Farm to School Network has launched the Who’s At the Table? School Meals campaign to promote state-level universal meals policies that align with our community values. This proposed rule would support states that have implemented universal meals and make universal meals policies more appealing to state governments looking to establish universal meals. 

Most universal meals policies require their state governments to cover the difference between the regular price of the meal and any federal funding support for school meals. For example, if a meal costs $3, and the federal government already provides $1 in reimbursement for that meal, currently the state government would provide the remaining $2. This ultimately makes school meals free to all public school students.

Even in states with universal free meals policies, schools are experiencing challenges with collecting income eligibility forms needed to obtain the maximum amount of funding available from federal sources. Lowering the CEP eligibility threshold would allow more schools to participate in CEP, allowing for a more streamlined paperwork process for schools in these states, and reducing the overall cost of a program. This proposed rule change may be the catalyst for more states to adopt healthy school meals for all.

How Can I Learn More and Take Action?

To Learn More:

To Get Involved:

Are you ready to make a comment of your own?