Impact of The Community Eligibility Provision of the Healthy, Hunger-Free Kids Act on Student Nutrition, Behavior, and Academic Outcomes: 2011–2019

Abstract

The Community Eligibility Provision (CEP) allows high-poverty schools participating in US Department of Agriculture meal programs to offer universal free breakfast and lunch. Authorized as part of the Healthy, Hunger-Free Kids Act of 2010, CEP became available to eligible schools nationwide in 2014.

Emerging evidence suggests that schools that provide universal free meals experience positive impacts on student nutrition, behavior, and academic performance. In particular, schools benefit from increased meal participation rates. There is mixed evidence of impacts on test scores and attendance, and limited but promising results showing improvements in weight outcomes, on-time grade promotion rates, disciplinary referrals, and food security.

In this article, we summarize the growing evidence base and suggest policy approaches to increase the use of CEP by eligible schools.

One in 7 US children lives in a food-insecure household (i.e., a household with limited or uncertain access to adequate food).¹ Food insecurity among children has a deleterious effect on physical and psychosocial health, cognitive function, and academic performance.^2–5 Children in food-insecure households are more likely to be hospitalized and develop chronic conditions such as diabetes, and are less likely to meet developmental milestones and succeed in school.^6–8 Annual costs to the health care and education systems associated with food insecurity among families with young children are estimated at more than $1.2 billion.⁹ Federal nutrition assistance programs administered by the US Department of Agriculture (USDA) aim to support tens of millions of children in the United States each year. Research has consistently demonstrated the benefits of 2 of these programs—the School Breakfast Program and the National School Lunch Program—for reducing childhood food insecurity.^10–12

The US Congress is currently discussing Child Nutrition Reauthorization, which is the process of revising the statutes that authorize the federal child nutrition assistance programs. The last reauthorization process occurred in 2010 through the Healthy, Hunger-Free Kids Act.¹³ In addition to reauthorizing funding for child nutrition programs, the law created the Community Eligibility Provision (CEP), a school meal-funding option that allows schools or districts in high-poverty areas to serve free breakfast and lunch to all students.¹³ CEP is an alternative to the traditional USDA reimbursement model through which meal pricing is determined annually for each student on the basis of household income. CEP was designed to increase access to nutritious food for low-income children, decrease stigma associated with participating in school meals, and reduce administrative burden for schools by eliminating the need to process meal applications and track students’ meal charges.

Previous research has explored the impacts of universal free meal (UFM) programs other than CEP, including municipal free meals initiatives and the USDA’s prior UFM options, Provisions 1, 2, and 3, whose eligibility cutoffs and lengths of cycle are different from those of CEP.^14–21 Among 8 previous studies of UFM,^14–21 all but 1 focused on universal free breakfast only; the remaining study focused on universal free lunch only.¹⁵ These studies have consistently found improvements in student meal participation but revealed mixed impacts on academic achievement and attendance. In the years since CEP became available, accumulating evidence indicates that CEP has positive impacts on a range of student nutrition, academic, and behavior outcomes, including some outcomes not previously studied in the UFM literature, such as disciplinary referrals.

Despite promising findings of the benefits of UFM programs, proposals have circulated in the US Congress that would weaken CEP and render participation financially infeasible for thousands of schools serving millions of low-income children. In this article, we provide a primer on CEP, synthesize literature that has assessed the impact of UFM on student outcomes with an emphasis on the recent literature on CEP, and argue that policy changes that strengthen—rather than erode—CEP are warranted to promote the health and educational attainment of the nation’s children. This article is timely because it is anticipated that Child Nutrition Reauthorization will pass in 2020 or 2021.

THE COMMUNITY ELIGIBILITY PROVISION

Nearly half of all US public school children are eligible for free or reduced-price meals.²² However, despite elevated prevalence of food insecurity among such students, rates of student participation in USDA school meals programs are low: in 2015, only 43% of students eligible for free or reduced-priced meals participated in breakfast and 81% participated in lunch.²² Barriers to student meal participation include stigma, lack of outreach to eligible students, and confusion among parents regarding eligibility.^23,24 CEP was designed to address such barriers by allowing high-poverty schools to provide universal free breakfast and lunch. Schools or districts can opt into CEP if 40% or more of students are identified as “categorically eligible” for free meals using existing administrative data, such as participation in the Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families. CEP was rolled out over a 3-year period in 10 states and the District of Columbia, and it then became available nationwide to eligible schools at the beginning of school year (SY) 2014–2015. In that first year, 14 214 schools adopted CEP.²⁵ By SY 2018–2019, adoption had doubled to 28 614 schools (64.6% of those eligible).²⁵

How Does Reimbursement Work?

Instead of collecting annual meal applications with household income information from each student, schools adopting CEP are reimbursed using a formula based on the percentage of students categorically eligible for free meals (the “identified student percentage,” or ISP). A school’s ISP is multiplied by 1.6 to calculate the percentage of meals reimbursed at the “free” rate (in SY 2019–2020, on average, $3.41 for lunch and $1.84 for breakfast), and the remainder are reimbursed at the lower “paid” rate (in SY 2019–2020, on average, $0.32 for lunch and $0.31 for breakfast).²⁶ For example, a school with an ISP of 50% would be reimbursed at the USDA’s “free” rate for 80% of meals served (50% ISP × 1.6), and at the “paid” rate for the remaining 20% of meals.

Which Eligible Schools Adopt the Provision?

Among eligible districts, adjusted odds of CEP participation are higher for districts that are located in rural compared with suburban areas, in the Southeast compared with the Northeast, and in states where CEP has been available longer (i.e., states that participated in CEP prior to the national rollout).²⁷ School ISP is also strongly associated with adoption: in SY 2018–2019, CEP adoption rates were 22.3%, 65.5% and 80.4%, respectively, among schools with ISPs of 40% to 49%, 50% to 59%, and 60% or higher.²⁵ Documented barriers to CEP adoption among eligible schools include concerns about how adoption would affect food service reimbursement, and state and federal education funding through programs such as Title I.²⁸

EFFECTS OF UNIVERSAL FREE MEAL PROGRAMS

Studies representing a wide range of geographies and grade levels have reported promising outcomes following UFM adoption. Studies focused on the impacts of CEP are detailed in Appendix A (available as a supplement to the online version of this article at http://www.ajph.org). Most studies employ strong analytic methods, including difference-in-difference and instrumental variable approaches, that allow for causal inference. In Appendix A, we describe the study design used in each study, and in this section we note where noncausal study designs were used.

Student Nutrition Impacts

Research suggests that UFM programs achieve their primary goal of increasing meal participation. A review of universal free breakfast program evaluations through 2004 found consistent evidence of increased breakfast participation.²⁰ Since then, additional studies using strong causal research designs have provided further evidence of increased meal participation linked with UFM.^14–18 Adding to the existing literature on UFM programs, 4 studies have evaluated the impact of CEP on breakfast and lunch participation across grade levels, and all detected significant increases.^28–31 Two studies focused on multiple states participating in CEP prior to nationwide rollout,^28,30 and 2 examined specific states after nationwide rollout (California²⁹ and Pennsylvania³¹). Increases in participation ranged from 3.5 to 37.8 percentage points for breakfast and 3.5 to 11.8 percentage points for lunch; some variation in findings was due to different student subgroups studied. Analytic rigor and design of these studies also differed: the California and Pennsylvania studies compared participation rates in CEP adopting and nonadopting eligible schools 1 year after adoption, whereas 1 national study used propensity score matching to develop sets of adopting and nonadopting schools for comparison and the other leveraged the staggered rollout of CEP to compare early and late adopting states. Gains in meal participation occurred among students previously eligible for free and reduced-price meals, as well as those previously above the eligibility cutoff. Taken together, these studies suggest that UFM programs significantly increase program reach for the School Breakfast Program and the National School Lunch Program.

Critics of CEP feared that students at participating schools would “double-dip”—both bringing their lunch from home and eating the school meal, leading to higher caloric intake and increases in obesity. On the contrary, of the 3 studies that have assessed weight outcomes in the context of UFM, 2 found no impact of UFM on weight and 1 found a beneficial effect. An analysis of a randomized universal free breakfast pilot program in elementary schools found no impact on 24-hour nutritional intake or weight.¹⁶ Among middle school students participating in UFM programs in New York City, there was no change in body mass index or healthy weight, but there were improved weight outcomes among students not previously eligible for free meals.¹⁵ In Georgia, CEP adoption led to a 1 percentage point decrease in body mass index averaged across grade levels.³² Further, evidence suggests that revised nutrition standards issued by the USDA in SY 2012–2013 have led to a significant improvement in the nutritional quality of school meals, and that meals served in schools are of significantly higher nutritional quality than those brought by children from home.²² Therefore, students switching to school meals instead of home-packed meals may experience improvements in nutritional outcomes.

Finally, 3 studies have considered the relationship between UFM and food security or hunger. In Boston, Massachusetts, Kleinman et al. found that a universal free breakfast program led to lower rates of student hunger.¹⁹ In Maryland, surveys of families in 5 matched CEP participating schools and eligible nonparticipating schools showed that adjusted odds of living in a food-insecure household were twice as great for students at nonparticipating schools.³³ Additionally, a simulation study of the impact of CEP on families’ food purchasing power and food insecurity found that in 2014, by increasing purchasing power, CEP may have allowed 3.2% of food-insecure children and their families (693 411 families) to move to full food security.³⁴ Although neither study on CEP used longitudinal data and findings were not causal, they do suggest that CEP adoption may be linked to improved household food security.

Student Academic Performance Impacts

Six previous studies have explored the impact of UFM programs other than CEP on test scores and have found different effects by academic subject and age group. Five of these studies focused on universal breakfast programs; 3 found no change in test scores^16–18 and 2 found some improvements.^19,21 A final study examined universal free lunch in middle schools and found improvements in reading and math test scores.¹⁵ Among studies focusing specifically on test scores and CEP, 2 detected improvement in test scores for some subjects and age groups and the third detected no change.³⁵ Notably, the study that found no change included only data from 1 year after implementation. Gains detected in the other 2 CEP studies are similar in magnitude to those observed in the UFM studies. In South Carolina, Gordanier et al. detected a significant increase (0.06 standard deviations) in elementary school math scores, but no change in elementary school reading scores or middle school scores.³⁶ In a national evaluation, Ruffini found that across grade levels, reading scores did not change but math scores increased 0.02 standard deviations in districts with the largest shares of students becoming eligible for free meals.³⁰ After scaling by the share of newly eligible students, access to free meals increased math performance by 0.05 standard deviations. Although these gains are relatively small, they are similar in magnitude to those seen when families receive other forms of income support, such as the earned income tax credit.³⁰

To date, only 1 study has explored the impact of UFM on on-time grade promotion rates. In that study, Kho found that by the second year of CEP adoption in Tennessee, students at participating schools were 0.6 percentage points more likely to be promoted to the next grade on time.³⁵

Evidence on the impact of UFM on attendance rates is mixed. Six studies examined the impact of universal breakfast on attendance; 3 found no change,^16–18 2 found improvements across the study sample,^19,21 and 1 found improvements only among certain racial and socioeconomic subgroups.¹⁴ Three studies examined this question in the context of CEP and found similarly inconclusive results; 1 found positive effects among elementary schoolers,³⁷ 1 found positive effects among elementary but not middle schoolers,³⁶ and the third found small but negative effects across grade levels.³⁵ In Wisconsin elementary schools, Bartfeld et al. found that participation in CEP led to a 3.5 percentage point reduction in students with low attendance, particularly among economically disadvantaged children.³⁷ In South Carolina, Gordanier et al. found that CEP participation led to a reduction in absences equivalent to one fifth of a day per student for elementary school students, but it had no effect on attendance in middle schools.³⁶ In Tennessee, Kho detected an increase in absences equivalent to half a day per student across grade levels due to CEP.³⁵

Student Behavior Impacts

Two studies have examined the impact of UFM programs—specifically, CEP—on student disciplinary referrals, and both found positive effects. In a national evaluation, Gordon and Ruffini found that CEP participation reduced suspension rates among White elementary school males by 1 percentage point, but their study lacked statistical precision to estimate changes for other groups by race or grade level.³⁸ In Tennessee, by the third year after CEP adoption, Kho found that disciplinary referrals decreased 2.3 percentage points averaged across grade levels, with the greatest reductions among high school students.³⁵

SUMMARY OF THE EVIDENCE

There is strong evidence of benefits of UFM for meal participation rates; promising evidence for benefits for weight outcomes, food security, disciplinary referrals, and on-time grade promotion; and mixed evidence of impacts for test scores and attendance. Although the studies evaluating the impact of CEP discussed in the previous section reflect early stages of policy implementation (primarily assessing outcomes 1 to 3 years after adoption), most use strong causal methods to produce credible results and are corroborated by other studies with findings in the same direction. It is persuasive that these studies have identified positive effects so soon after policy implementation given that outcomes such as weight reflect the cumulative effect of years of exposure and take time to change. Research on CEP has shown that benefits accrue both to students previously eligible and ineligible for free or reduced-price meals, indicating that families may have needed meal assistance despite earning above the cutoff. This finding is important because as many as 15% of marginally food secure and 10% of food-insecure students do not qualify for free or reduced-price meals on the basis of household income.³⁹

STRATEGIES TO STRENGTHEN THE PROVISION

Considering the emerging evidence of UFM’s benefits for a range of student nutrition, behavior, and academic outcomes, federal and state policymakers should consider strategies to strengthen CEP and promote adoption by eligible schools. We recommend several policy approaches.

1. Increase the federal reimbursement multiplier for CEP schools. The total amount of meal reimbursement that a school receives is tied directly to its ISP; thus, ISP is a strong predictor of CEP adoption.^27,29,40 With the ISP multiplier currently capped at 1.6, only schools with ISPs of 62.5% or above are fully reimbursed for all meals served; schools with ISPs between 40% and 62.5% must cover the gap in reimbursement themselves. An increase of the multiplier to 1.8 would enable full reimbursement for schools with ISPs above 55.5%. This federal policy change could increase the likelihood of CEP adoption for an estimated additional 2100 new schools and extend meal access to more than 1 million children.⁴⁰

2. Continue to allow “grouped” schools with ISPs of 40% or above to participate in CEP. Currently, schools can opt into CEP individually, as part of a group of schools or as part of a district, as long as their pooled ISP is greater than 40%. This allows a district to adopt CEP for all schools in the district, even if some schools are slightly below the 40% ISP mark. For example, a district with 10 schools where ISPs range from 30% (near eligible) to 80% (very high poverty) and a district aggregate ISP of 65% could adopt CEP districtwide. Grouping schools simplifies administration and often helps districts save money: they can reduce their administrative overhead by eliminating the infrastructure needed to process meal applications and can achieve economies of scale through increased purchasing and production volumes. Districtwide adoption can also reduce confusion among parents that may occur when students move from a participating school to a nonparticipating school within the district, or when 1 sibling attends a participating school and another does not. The 2020 budget proposed by the White House suggested limiting CEP participation to schools with an ISP of 40% or above. This would prevent districts from including schools with lower ISPs in grouped or districtwide adoption. The ability to pool ISPs and include these schools as part of grouped or districtwide implementation is a key consideration for decision-makers⁴¹; curtailing the opportunity for districtwide implementation would eliminate these benefits and may result in fewer eligible schools participating.

3. Strengthen state direct certification systems. ISP is a top predictor of CEP participation; therefore, strategies that improve identification of categorically eligible students and boost ISPs could lead more schools to adopt CEP.^27,29,40 In SY 2016–2017, states failed to certify, on average, 8% of children directly eligible for free meals.⁴² Direct certification systems could be improved with increased state and federal funding, including through resumption of the Direct Certification Improvement Grant program, which is currently frozen. Additionally, the ability to use income data available in Medicaid administrative records for direct certification should be extended to all states. In states that were authorized to use Medicaid data as part of the Direct Certification With Medicaid for Free and Reduced-Price Meals Demonstration Program, direct certification rates increased significantly; in the 4 states new to the program in 2016, students directly certified for free meals increased between 2.5 and 8.0 percentage points in the first year.⁴³

4. Revise federal policies that limit participation in other public benefit programs. ISPs reflect the proportion of students within a school who are identified as directly eligible for free meals on the basis of existing administrative data, such as participation in SNAP and Temporary Assistance for Needy Families. Federal policies that lead to lower participation in these benefit programs, including the Categorical Eligibility for SNAP proposed rule⁴⁴ or the Inadmissible on Public Charge Grounds final rule,⁴⁵ may lead to lower ISPs and thus lower CEP adoption. Estimates suggest that the Categorical Eligibility for SNAP proposed rule would cause ISPs to drop below 40% (the CEP eligibility cutoff) at schools that collectively serve 142 000 students, and ISPs to drop below 62.5% (the level at which schools are fully reimbursed for all meals served) at schools that serve an additional 1.05 million students.⁴⁶ These policies should be revised to avoid negatively affecting school meal access.

KEY TAKEAWAYS

There is growing evidence that CEP produces important benefits for children’s health and academic performance. Investment yields long-term benefits: outcomes such as food security and school attendance during childhood are predictive of health and productivity into adulthood.^8,47 Further, CEP has become an increasingly appealing solution to schools seeking to address unpaid meal debt and eliminate meal shaming, a practice that has recently garnered considerable negative media attention. The US Congress should consider these benefits to students, schools, and society, and identify opportunities to strengthen CEP through Child Nutrition Reauthorization and beyond.