Comments from Richard Besser, MD, on Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program

Potential Impacts on Participants in School Lunch and School Breakfast Program

    • November 1, 2019

The following comments were submitted by Richard Besser, MD, Robert Wood Johnson Foundation (RWJF) President and CEO, on the United States Department of Agriculture’s (USDA) notice of proposed rule: Revision of Categorical Eligibility in the Supplemental Nutrition Assistance Program—Potential Impacts on Participants in the National School Lunch Program and School Breakfast Program.

In our original comments, we expressed the strong belief that the proposed rule be withdrawn because it would “make it harder for families to reduce financial hardship and become food secure.” We came to this conclusion due to:

  • USDA’s original analysis, which found that the proposal would push about nine percent of SNAP participants—more than three million people off the program entirely
  • A Mathematica analysis showing that more than 40 percent of the 1.9 million SNAP households slated to lose benefits live in poverty, while more than one-third have children 
  • An Urban Institute research brief finding that for more than two million participants in SNAP households with children, the resulting benefit loss would be approximately $240 per month per household, or about $165 million annually

The Department’s latest informational analysis with respect to the negative repercussions to school meals confirms and strengthens our original conclusion that this rule would do significant harm—not just in communities, but in school cafeterias and classrooms as well. The proposal would needlessly jeopardize students’ access to school meals that can improve their health and help them succeed in the classroom, especially in high-poverty schools that may lose the ability to serve free meals to all students.   

Impact of Proposed Changes on School Meals

When the proposed rule was issued two months ago, the Department estimated that eliminating broad-based categorical eligibility (BBCE) would cause approximately 500,000 children to no longer be directly certified for free school meals based on SNAP participation. Its latest analysis reveals the actual number to be up to 982,000. Of those, 40,000 children would lose eligibility for free or reduced-price meals entirely; 445,000 would have to apply to maintain access for free school meals; and 497,000 would only qualify for reduced-price meals. The rule would thus make it significantly harder for children from low-income families who already struggle with food insecurity to afford and access school meals.   

Losing access to school meals means students are denied a variety of benefits associated with those meals that can improve their health and performance in the classroom. Those benefits include: food security, access to healthy food, academic achievement and childhood obesity prevention.  

Food security. Many children consume up to half of their daily calories at school; for some children, school breakfast or lunch might be their only meals in a given day. For children from low-income families, school meals are an especially critical source of affordable, healthy foods; 51 percent of U.S. children now qualify for free and reduced-price school meals. Nearly three-quarters of children who eat school lunch qualify for free or reduced-price meals. 

Access to healthy food. The Healthy, Hunger-Free Kids Act of 2010 (HHFKA), the most recent iteration of the Child Nutrition Act, updated nutrition standards for school meals programs for the first time in 15 years to reflect the latest nutrition science. A 2019 USDA study that gathered data from more than 1,200 schools nationwide found the updated standards for school meals have had “a positive and significant influence on nutrition quality.” Specifically, the evaluation found that the nutritional quality of school breakfasts and lunch increased by more than 40 percent between school years 2009–2010 and 2014­–2015, with student participation rates in meal programs highest in schools that served the healthiest meals.

Academic achievement. Studies show that eating a regular breakfast, including breakfast at school, has cognitive benefits, including a mainly positive effect on on-task behavior in the classroom and children’s academic performance.

Childhood obesity prevention. Harvard researchers estimate the 2012 nutrition standards will prevent more than two million cases of childhood obesity and save up to $792 million in health care-related costs over 10 years.

The rule would also have repercussions for students attending schools that qualify for the Community Eligibility Provision (CEP), which allows high-poverty schools to serve free meals to all students. More than 13.6 million children in more than 28,000 schools benefited from CEP during the 2018–2019 school year.  

New research from the Urban Institute sheds new light on how this rule could impact schools that currently qualify for CEP. More than one million students could see their schools lose full reimbursement for serving free school meals, potentially putting their CEP status at risk. This could cost those schools more than $167 million in school lunch funding. Moreover, an additional 142,000 students could see their schools lose eligibility for CEP entirely. Under that circumstance, those schools would no longer be able to provide free school meals to all students—which reduces student meal debt, ends stigma, and extends the benefits of healthy meals to everyone—but only to those directly certified as low-income.


SNAP has a long and successful history of providing temporary assistance in order to lower food insecurity and lift families out of poverty. Nearly half of the 36 million SNAP participants in the United States are children; ensuring children have access to adequate, nutritious foods—especially during the school day—is among the most important responsibilities of the adults who care for them and of a wealthy society.

The proposed rule represents an abdication of those responsibilities. USDA’s own research and the nonpartisan studies we cite in our current and previous comments are stark warnings that this proposal would cause significant harm to children and families already struggling with food insecurity. We strongly urge the Department to withdraw its proposal. 


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