Issue: Each school day, millions of U.S. children receive

free or reduced-price meals provided through the National

School Lunch Program (NSLP). Recent studies have indicated that many students who are not eligible for free or

reduced-price NSLP meals are receiving the meals. How

large is this certification error problem? Would stricter certification procedures deter many eligible students from

participating?

Background: Nutritionally balanced NSLP meals are

available in almost all public and many private schools.

Any child at a participating school may purchase a lunch

through the NSLP. Children from families with incomes at

or below 130 percent of the poverty level are eligible for

free lunches. Children from families with incomes

between 130 percent and 185 percent of the poverty level

are eligible for reduced-price lunches, for which no more

than 40 cents may be charged. Over half of the 25 million

NSLP lunches served on an average school day in 2001

were given to children free or at a reduced price.

To properly target benefits, NSLP administrators must

ascertain who is eligible. This entails identifying children

from households within the two targeted income categories. The certification process requires a balance

between minimizing the number of eligible students not

receiving benefits (undercoverage) and minimizing the

number of ineligible students receiving benefits (certification error).

Current regulations allow children to be certified for free

or reduced-price meals in two ways. Direct certification,

used in nearly two-thirds of school districts, allows school

officials to certify children based on documentation from

State or local welfare offices indicating that a child’s

household participates in the Food Stamp Program, the

Temporary Assistance for Needy Families (TANF), or the

Food Distribution Program on Indian Reservations. School

districts can also certify children based on an application

submitted by the child’s parent or guardian. Applicants

can either document that they receive assistance from one

of the three programs or report their current monthly

income and household size.

School districts are required to verify a small percentage

of the approved applications each school year and, if warranted, take action with regard to receipt of free or

reduced-price lunches. School districts are not required to

verify the eligibility of directly certified children.

Findings: Interim results from an Economic Research

Service-funded study on the use of direct certification and

its impact on error rates estimate that 61 percent of school

districts used direct certification in 2001, about the same

as in 1996. While the share of districts using direct certification is stable, the direct certification method has

changed. In 1996, nearly half of school districts used a

nonmatching method in which the State or district sent a

letter to all families with children on the welfare rolls. The

parent or child had to file the letter with the school to

obtain free meals. The matching method, in which the

State or school district matches children in the district

schools with the welfare rolls, was used by slightly more

than half of the districts. Matched families are either sent a

letter that they must file with the children’s school to

obtain free meals (active consent) or the children are automatically made eligible for free meals (passive consent).

Nearly all school districts that used matching in 1996 used

passive consent. By 2001, “matching” and “active consent” were used by more school districts. Complaints from

parents who did not want their children certified appear to

have been one of the motivating factors for the increased

use of active consent.

Reasons cited most often by the remaining districts for not

using direct certification included: (1) satisfaction with

United States

Department of

Agriculture

Economic 

Research

Service

Food Assistance and Nutrition Research Report Number 34-4 July 2003

WIC School

meals

CACPF General

Certifying Eligibility in the

National School Lunch

Program

Food Assistance Research Brief

Craig Gundersen, cggunder@ers.usda.gov, (202) 694-5425

Rosanna Mentzer Morrison, rosanna@ers.usda.gov,(202) 694-5411 

Linda M. Ghelfi, lghelfi@ers.usda.gov,(202) 694-5437
2 Economic Research Service / USDA

Certifying and Verifying Eligibility in the National School Lunch Program / FANRR-34-4

their current procedures; (2) too few eligible students to

make direct certification cost-effective; and (3) lack of

staff to perform the work required for direct certification.

The ERS study also collected information on the verification of application-approved students. Of the small samples subjected to verification, about 70 percent were found

to be eligible. The remaining 30 percent were deemed

ineligible. This error rate should be construed as an upper

limit, however. Children were deemed ineligible for two

primary reasons—their family incomes were found to be

too high (40 percent) or their families did not respond to

the verification request (56 percent). Families with high

incomes are clearly ineligible at verification, even if they

had been eligible at application. Nonresponders may or

may not be ineligible. A study by USDA’s Food and

Nutrition Service (FNS) of income verification during the

1986-87 school year found that more than half of nonresponders would have remained eligible for the free or

reduced-price meals their children had been receiving.

Another 8 percent would have been eligible for increased

benefits—having their children’s meals reimbursed at the

free rather than the reduced-price rate.

In related research, a pilot project conducted by FNS

examined the eligibility of directly certified children in

seven school districts. The project found that 88 percent of

directly certified children were still receiving benefits

from the qualifying programs at the time of verification,

and, hence, remained eligible for free meals. Of the 12

percent no longer receiving benefits from the qualifying

programs, over half completed an application form and

qualified for free or reduced-price meals based on low

family income.

At the other end of the spectrum are eligible children who

are not certified or do not participate even after certification. This undercoverage issue was addressed by two FNSfunded studies in the early 1990s. The School Nutrition

Dietary Assessment Study found that between 16 percent

and 25 percent of income-eligible children were not certified for free or reduced-price meals in 1992. Among those

certified, 80 percent of those certified for free meals and

70 percent of those certified for reduced-priced meals participated on a typical day. The School Lunch Eligible NonParticipants Study used case studies to assess the reasons

for parents not applying and for children not participating.

Half of parents who did not apply believed they were not

income eligible, 20 percent cited stigma, 10 percent cited

their children’s preferences not to eat school lunches, and

10 percent cited administrative problems with applying.

Children who did not participate cited dislikes for some or

all of the foods served. Along with disliking some of the

foods, high school students also cited stigma as a reason

not to participate. 

Summary: These studies suggest that some children from

higher income homes are certified for free or reducedprice lunches in error, and some children from low-income

homes are not receiving the free or reduced-price lunches

for which they qualify. 

Direct certification appears to reduce certification error and

respondent burden. But it is also a factor is determining

the pool of children certified by application. With direct

certification used by two-thirds of all school districts and

most frequently by larger, poorer districts, the poorest

children tend to qualify through that method, leaving children in families with incomes closer to the NSLP income

thresholds to be certified by application. If stricter certification procedures were instituted, certification error would

be reduced, but nonresponse by eligible households to

income verification requests could increase undercoverage.

Information Sources:

Burghardt, J., et al., The School Nutrition Dietary Assessment Study:

School Food Service, Meals Offered, and Dietary Intakes, report by

Mathematica Policy Research, Inc., for USDA, FNS, Office of Analysis

and Evaluation, October 1993.

Glantz, F., et al., School Lunch Eligible Non-Participants, report by Abt

Associates Inc., for USDA, FNS, Office of Analysis and Evaluation,

December 1994.

Gleason, Philip, et al., Direct Certification and Its Impact on Errors in

the National School Lunch Program: Data Collection and Descriptive

Report. Interim report by Mathematica Policy Research, Inc., for

USDA, ERS. 2002.

St. Pierre, Robert G. and Michael J. Puma, Study of Income Verification

in the National School Lunch Program: Executive Summary, report by

Abt Associates Inc., for USDA, FNS, Office of Analysis and

Evaluation, 1990.

U.S. Department of Agriculture, Food and Nutrition Service, National

School Lunch Program Application/Verification Pilot Project: Report

on First Year Experience. Special Nutrition Programs, Report No. CN02-AV, 2002.

Additional information is available at:

http://www.ers.usda.gov/Briefing/childnutrition

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