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SNAP Categorical Eligibility & School Meals

By August 17, 2020October 15th, 2020No Comments

The comment period has ended. Thank you to all who submitted comments. We will post updates to the proposed rule as they become available.

Proposed Changes to SNAP Could Leave 1 Million Children Without Access to Free School Meals

The United States Department of Agriculture (USDA) recently proposed a rule to gut states’ option to use broad-based categorical eligibility (Cat El) for the Supplemental Nutrition Assistance Program (SNAP). If adopted, the rule would eliminate SNAP benefits for 3.1 million people. A newly released USDA analysis found that it would jeopardize nearly one million children’s access to free school breakfast and lunch. Due to this new data, USDA has reopened the public comment period for Categorical Eligibility in the Supplemental Nutrition Assistance Program starting October 18, and ONLY for a period of 14 days ending on Friday, November 1.

Children who live in households that receive SNAP benefits are directly certified (automatically eligible) to receive free school breakfast and lunch. While the initial estimate showed that the rule could jeopardize more than 500,000 children’s access to free school meals, the new USDA analysis states that as many as 982,000 children could be impacted, with 445,000 needing to submit applications to be eligible for free meals, 497,000 children moving from free to reduced-price meals, and 40,000 completely losing eligibility for both free and reduced-price school meals. This means the majority of families impacted will face burdensome paperwork that that is a significant barrier to families and leads to eligible children losing access to critical source of daily nutrition.

If this rule is enacted, children will be hungry at home and at school. Since childhood hunger is linked to academic struggles, difficulties focusing and concentrating, mental health disorders, and increased behavioral referrals, many schools would struggle to meet the educational, health, and mental health needs of the students who lose SNAP benefits and as a result, access to free school meals.

We need your help.

Submit a comment on this proposed rule. We need USDA to understand the profound impact this will have on New York State children, families, and schools.

Tell the USDA that this rule will:

  • Leave more children hungry at home and at school
  • Create more red tape for struggling working families to access free school meals
  • Allow fewer schools to use Community Eligibility Provision to provide free meals to all students
  • Place increased administrative burden on schools by taking away the ability to streamline and improve access to school meals for working families
  • Increase costs for NYS to cover the reduced-price co-payment for the half of the impacted children who will lose free school meal eligibility

This extended comment period applies only to comments on the new data analysis around school meals. If comments include information that is not reflective of the impact on school meals, they will not be accepted by USDA.

We need you, your volunteers, clients and others to submit individual comments in opposition to the rule. Feel free to use any of the digital comment platform options below that work best for your organization. Comments need not be technical or lengthy. But it is important that comments are unique or else identical comments (submitted using a template) can be counted as a single comment.

Comments must be received by USDA on or before November 1, 2019.

Submit your comments at FRAC
Submit your comments at Feeding America

Background information:

The USDA recently proposed rules to gut states’ option to use broad-based categorical eligibility (Cat El) for the Supplemental Nutrition Assistance Program (SNAP). New York State uses the SNAP Cat El option to allow households who have gross incomes between 130% and 200% of the federal poverty line – but whose high costs for other basics, such as shelter, utilities, and child care, render their net incomes at or below 100% of the federal poverty line – to qualify for a SNAP benefit. New York State also uses broad-based categorical eligibility option to eliminate the outdated and administratively complicated SNAP asset tests.

For additional context about broad-based categorical eligibility and school meals, visit FRAC’s webpage.

Please be sure to limit your comments to the scope of the impact to school meals, not on the original proposed rule change. The new comment period is only addressing this specific area, other comments will be disregarded.

Additional Resources

From FRAC:

From Hunger Solutions New York:

Background on how Cat El works in NYS:

The Rule’s Impacts


132,500 New Yorkers

in families with children lose SNAP benefits.
(Mathematica, 2019)

Proposed changes to the income test

39,000 children

lose automatic eligibility for free school meals.


982,000 children

are no longer directly certified for free school meals based on SNAP participation.

Proposed changes to the income test

497,000 children

lose access to free school meals and move to reduced price meals, but only if their parents can navigate the school meal application process.

40,000 children

lose all eligibility for both free and reduced-priced school meals.

Proposed re-imposition of the asset test

445,000 children

would still be eligible for free school meals, but only if their parents can navigate the school meal application process.