Policy Blog: Impact of SNAP Eligibility Changes on School Meal Access and the Community Eligibility Provision

By Morgan Flood, Policy Research Specialist

The Pennsylvania Department of Human Services estimates that changes to SNAP eligibility made in the July 2025 budget reconciliation bill will result in more than 140,000 individuals across the state, including almost 22,000 residents of the Central Pennsylvania Food Bank’s service territory, losing grocery benefits that help them make ends meet. Another 310,000 Pennsylvanians are projected to lose Medicaid coverage. Beyond the devastating direct impact these cuts will cause, however, there will also be downstream effects that could cause Pennsylvania’s most vulnerable families to lose access to critical nutrition programs for children.

Foremost among these impacts is the potential risk to Pennsylvania schools offering free school meals to all students under the Community Eligibility Provision (CEP) of the National School Lunch Program. Under ordinary circumstances, schools operating the school meal programs must collect and process income-eligibility paperwork from households interested in receiving free lunch in order to determine if they fall below the eligibility threshold; in Pennsylvania, students under 185% FPL qualify for free lunch and all students may receive free breakfast without the need for an application thanks to a statewide initiative. However, CEP allows high-poverty schools and school districts to provide free meals, including lunch, to all students without the need for applications, which significantly reduces administrative burden for both schools and families.

Beyond simplifying the process of receiving free school lunch and reducing stigma, research also shows that universal school meal provision is associated with improved English and math scores as well as higher attendance and lower suspension rates. Pennsylvania offers universal free school breakfast to all students through a statewide initiative that started in 2022 and has fueled significant participation growth. CEP also helps the Commonwealth make the state-level breakfast program financially sustainable by leveraging federal dollars to their fullest extent.

Schools and school districts may elect CEP if they are able to prove that at least 25% of their students are categorically eligible for free or reduced-price lunch. Children may become categorically eligible via a number of pathways, including participation in SNAP or Medicaid as well as students with homeless, runaway, migrant, or Head Start status.  In Pennsylvania, students participating in SNAP and Medicaid are directly certified as eligible for free meals, further simplifying both their individual experiences and the process of electing CEP for school food authorities. It is important to note that schools and districts may elect CEP as individual buildings or by using a grouped or district average ISP, depending on which is more financially sustainable for them, expanding access to the program in districts where eligibility is unevenly distributed among schools and simplifying the school meal experience for families, who need not worry about school meal provision being universal in some school buildings but not others.

Many schools and districts do not elect CEP until they have determined that at least 62.5% of their students are eligible via one or more of these pathways at either a building or district level, as this is the point at which federal reimbursement for meals is equivalent to if every child in the school were eligible for free lunch; as of 2024, about half of Pennsylvania CEP schools or school districts were receiving reimbursement at a 100% free rate. Schools and districts that elect CEP below this threshold must find additional funding elsewhere in their budgets to fully fund meal service, though many find that this is an investment well worth making given its positive impact on student outcomes. Of the schools with reimbursement rates below 100%, three fifths are at or above 80% free reimbursement rate.

Because the SNAP and Medicaid eligibility changes will reduce participation in these programs, they will likely also reduce CEP participation, especially among schools that are close to or below the 62.5% identified student percentage (ISP) threshold. These potential drops in ISP resulting from SNAP and Medicaid cuts could have tremendous impact on Pennsylvania’s schools and students who benefit from universal school meals through CEP.

Statewide, 923 of the 1,467 (62.9%) schools currently participating in CEP have identified student percentages at or below 70%; more than 488,000 students attend these schools. Of these, 238 schools serving over 110,0000 students are in Central Pennsylvania. These schools are at particular risk of seeing negative impact on their ability to continue to offer CEP due to decreases in Medicaid and SNAP enrollment either newly forcing them to find additional funding for school meals to make up the difference in reimbursement or creating larger gaps in reimbursement, given their proximity to the 62.5% break-even threshold. For some schools, changes in ISP due to SNAP and Medicaid changes could potentially force them to drop the program entirely.

However, there is opportunity to act to extend CEP in schools across the Commonwealth. USDA and PDE guidance around CEP states that schools and school districts may ‘lock in’ their CEP status for up to four years using a base year of data reflecting student eligibility as of April 1 of the given year. This means that data reflective of the 2025-2026 school year may be used to establish CEP eligibility through school year 2030-2031. Because school meal eligibility determinations are made on an annual basis, this data will reflect eligibility prior to the full impact of the SNAP and Medicaid cuts taking effect. Schools currently implementing CEP should look into renewing their determination for this reason and could collaborate with local food banks or other nonprofits to conduct SNAP outreach to reach all eligible households. Community members and other stakeholders who are interested in supporting universal school meals can help by contacting their school board and encouraging them to learn more about the program.