In 2025, H.R. 1 codified several changes to the Supplemental Nutrition Assistance Program (SNAP) and Medicaid, and Congress has recently considered a regulation that would eliminate SNAP’s Broad Based Categorical Eligibility (BBCE) policy. These past and potential changes would result in increased cost-shares for states and the loss of automatic certification for students eligible for school meal programs and will have consequences for states’ and schools’ ability to operate free school meal programs and, as such, will have consequences for students attending these schools.
Why This Matters
For more than a decade, schools have used students’ participation in social safety net programs, such as SNAP and Medicaid, to “directly certify” students for free and reduced-price meals—that is, automatically enroll them in free school meals or count that student toward eligibility thresholds for universal meal programs. This system reduces the paperwork that families must fill out and spares students the stigma associated with meal applications.
According to the most recent data, 28 million students attend schools with universal free school meal programs. In addition to the proposed elimination of BBCE, H.R. 1 prohibits refugees from accessing SNAP or Medicaid, which will also lower direct certification numbers. Both changes will increase the costs of school meal programs at a time when state budgets are already tightening.
What I Found
In this essay, I estimate the potential effects of eliminating BBCE, as well as the effects of the enacted legislation.
I find the following:
- 1.3 million students would lose SNAP benefits if BBCE were eliminated.
- 264,000 of these students would lose direct certification, and potentially have to fill out meal applications.
- 106,000 refugee and asylee children have lost SNAP benefits and direct certification.
- States could face
- $2.6 billion in increased administrative SNAP costs
- $11.1 billion in SNAP benefit costs
- Decreased direct certification counts and tightening state budgets could threaten universal free meal access for
- 28 million students that attend a universal free meal school
- 12.9 million students in universal free meal states
- 15.3 million students in non–universal free meal states
- 28 million students that attend a universal free meal school
Given state-by-state differences in universal school meal policies, the number of students who may lose access to free meals because of lower direct certification numbers varies widely by state.
Source: Author’s analysis of fiscal year 2023 data from the SNAP Quality Control database from the US Department of Agriculture’s Food and Nutrition Service and Mathematica and 2023 American Community Survey via IPUMS. See “National School Lunch and School Breakfast Program Demonstration Projects to Evaluate Direct Certification with Medicaid,” US Department of Agriculture, Food and Nutrition Service, last updated March 30, 2026, https://www.fns.usda.gov/cn/direct-certification-medicaid-demonstration-project.
Previous research finds that beyond increasing test scores and graduation rates, universal school meal programs improve food security and student health outcomes—including reductions in body mass index and blood pressure—while enhancing school climate and reducing disciplinary incidents. Thus, all students may suffer academically and developmentally when a school can no longer offer universal free meals.
How I Did It
I calculate the number of school-age children who could lose access to SNAP using data from the US Department of Agriculture’s Food and Nutrition Service and Mathematica’s 2023 SNAP Quality Control database. Because many students are also identified for direct certification through their household’s participation in Medicaid, I use 2023 American Community Survey data to identify the percentage of non-Medicaid-enrolled, SNAP-enrolled children in each state. I use 2024–25 school-level meal eligibility data from the Common Core of Data via the Urban Institute’s Education Data Portal and data from the Food Research & Action Center’s Community Eligibility Provision database to estimate the number of students enrolled in universal free meal schools and states.
