FOOD INSECURITY

Better Information 

Could Help Eligible 

College Students 

Access Federal Food 

Assistance Benefits

Report to Congressional Requesters

December 2018

GAO-19-95

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-19-95, a report to 

congressional requesters

December 2018

FOOD INSECURITY 

Better Information Could Help Eligible College 

Students Access Federal Food Assistance Benefits

What GAO Found

There is limited information about the national prevalence of food insecurity 

among college students. GAO reviewed 31 studies that identified a wide range of 

food insecurity rates among the students studied, but the studies did not provide

national estimates. College students at risk of food insecurity may be eligible for 

benefits from the Food and Nutrition Service’s (FNS) Supplemental Nutrition 

Assistance Program (SNAP). However, GAO’s analysis of Department of 

Education (Education) data shows that almost 2 million at-risk students who

were potentially eligible for SNAP did not report receiving benefits in 2016. 

According to GAO’s analysis, having a low income is the most common risk 

factor for food insecurity among college students. Among low-income students,

most have one additional risk factor associated with food insecurity, such as

being a first-generation student or a single parent.

The 14 selected colleges that GAO contacted were addressing student food 

insecurity in a number of ways. For example, all 14 were providing free food to 

students through on-campus food pantries, and most were offering emergency 

funds to help students pay for living expenses that might otherwise force them to 

choose between buying food or staying in school. Many of these colleges had

centralized student services to better address their students’ basic needs and 

provide other support, such as screening students for potential eligibility and 

helping them apply for federal benefit programs like SNAP.

Selected Colleges’ Initiatives to Address Student Food Insecurity 

Federal student aid generally does not cover all college costs for low-income 

students, and college students may have limited access to federal food 

assistance programs such as SNAP because of program eligibility restrictions. 

Some state SNAP agencies reported that they are taking steps to help students 

access SNAP by conducting outreach to colleges and developing guidance.

Nevertheless, at 9 of the 14 colleges GAO contacted, some college officials and 

students said that they were unfamiliar with or did not fully understand SNAP’s 

student eligibility rules. Some college officials said that they would like 

information from FNS to better explain SNAP student rules, but FNS has not 

made such information easily accessible on its website. Further, college officials 

and state SNAP agencies noted that FNS does not share examples of actions

taken by other states to help eligible students access SNAP. Clarification of

SNAP student eligibility rules and enhanced information sharing about state

efforts could help ensure that potentially eligible college students can access 

federal food assistance programs. 

View GAO-19-95. For more information, 

contact Kathryn Larin at (202) 512-7215 or 

larink@gao.gov.

Why GAO Did This Study

Increasing evidence indicates that 

some college students are 

experiencing food insecurity, which can 

negatively impact their academic 

success. However, college students 

are only eligible for SNAP in certain

cases. Given the substantial federal 

investment in higher education and the 

risk posed if students do not complete 

their degrees, GAO was asked to 

review food insecurity among college 

students. 

This report examines (1) what is known 

about the extent of food insecurity 

among college students and their use 

of SNAP; (2) how selected colleges are 

addressing student food insecurity; and 

(3) the extent to which federal

programs assist students experiencing

food insecurity. GAO reviewed relevant 

federal laws and agency documents 

and studies on student food insecurity; 

analyzed 2016 federal student data

(the most recent available), and visited

four states, selected based on actions 

taken to address student food 

insecurity, geographic diversity, and 

other factors. GAO interviewed

researchers; officials from Education, 

FNS national and regional offices; and 

officials at 14 colleges, including 

students at 8 of these colleges. GAO 

also emailed all state SNAP agencies 

about their efforts related to students.

What GAO Recommends

GAO recommends that FNS (1) 

improve student eligibility information 

on its website and (2) share 

information on state SNAP agencies’ 

approaches to help eligible students.

FNS partially concurred, and plans to 

review its information. GAO continues 

to believe additional action is 

warranted, as discussed in the report.
Page i GAO-19-95 College Student Food Insecurity

Letter 1

Background 4

Information about the Prevalence of Food Insecurity among 

College Students Nationally is Limited and Many Potentially 

Eligible, At-Risk Students Do Not Receive SNAP 11

Selected Colleges Are Using a Range of Approaches to Address 

Student Food Insecurity 20

While SNAP Can Supplement Other Federal Aid for Some LowIncome Students, FNS Does Not Share Key Information to Help 

States Better Leverage SNAP to Assist Students 28

Conclusions 39

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 40

Appendix I: Objectives, Scope, and Methodology 42

Appendix II: GAO Contact and Staff Acknowledgments 57

Tables

Table 1: Prevalence of Risk Factors Associated with Food 

Insecurity among Low-Income U.S. College 

Undergraduate Students, by College Type in 2016 16

Table 2: Prevalence of Risk Factors Associated with Food 

Insecurity among Low-Income U.S. College 

Undergraduate Students in 2016 17

Table 3: Studies Included in GAO’s Review That Estimate College 

Student Food Insecurity 44

Table 4: Risk Factors Identified by GAO Associated with Food 

Insecurity Among College Students 48

Table 5. Selected Risk Factors and Corresponding Variables in 

the 2016 National Postsecondary Student Aid Study Data 

Set 50

Table 6: Supplemental Nutrition Assistance Program (SNAP) 

Eligibility Exemptions for College Students and 

Corresponding Variables in the 2016 National 

Postsecondary Student Aid Study Data Set 52

Table 7: List of 2- and 4-year Selected Colleges that GAO 

Contacted, by State 55

Contents
Page ii GAO-19-95 College Student Food Insecurity

Figures

Figure 1: Percentages and Characteristics of Traditional and 

Nontraditional College Students in 2016 7

Figure 2: Supplemental Nutrition Assistance Program (SNAP) 

Participation among Low-Income College Students AtRisk of Food Insecurity in 2016 19

Figure 3: Initiatives by Selected Colleges to Address Student Food 

Insecurity 21

Figure 4: Pictures of Food Pantries from GAO Site Visits to 

Selected Colleges 24

Abbreviations

Education U.S. Department of Education

E&T Employment and Training

FAFSA Free Application for Federal Student Aid

FNS Food and Nutrition Service

NPSAS National Postsecondary Student Aid Study

SNAP Supplemental Nutrition Assistance Program

USDA U.S. Department of Agriculture

This is a work of the U.S. government and is not subject to copyright protection in the 

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-19-95 College Student Food Insecurity

441 G St. N.W.

Washington, DC 20548

December 21, 2018

The Honorable Debbie Stabenow

Ranking Member

Committee on Agriculture, Nutrition, and Forestry

United States Senate

The Honorable Patty Murray

Ranking Member

Committee on Health, Education, Labor & Pensions

United States Senate

The Honorable Edward J. Markey

United States Senate

The Honorable Elizabeth Warren

United States Senate

In fiscal year 2017, the federal government spent over $122 billion in 

grants, loans, and work-study funds through federal student aid programs

to help make college accessible to students.1 This substantial federal 

investment in higher education is at risk if college students drop out 

because they cannot afford basic necessities like food. The federal 

government also spent $98 billion in fiscal year 2017 on nutrition 

assistance programs, including $68 billion on the Supplemental Nutrition 

Assistance Program (SNAP), the nation’s largest nutrition assistance 

program, to combat food insecurity. College students enrolled at least half 

time, however, are generally not eligible for SNAP benefits unless they 

fall into certain categories designed to more narrowly target students in 

need of assistance. According to some studies, college students who 

experience food insecurity, which the U.S. Department of Agriculture 

(USDA) defines as the condition of limited or uncertain access to 

adequate food, may also experience decreased academic performance, 

symptoms of depression and anxiety, and other negative mental health 

 1

For this report, we define federal student aid programs as financial aid programs 

authorized under Title IV of the Higher Education Act of 1965, as amended, Pub. L. No. 

89-329, Title IV, 79 Stat. 1219 (codified at 20 U.S.C. § 1001 et seq.). These include the 

William D. Ford Federal Direct Loan, the Federal Pell Grant, and the Federal Work-Study 

programs. 

Letter
Page 2 GAO-19-95 College Student Food Insecurity

indicators.2 In light of the potential obstacles to college students’

academic success posed by lack of access to adequate food, you asked 

us to review the issue of food insecurity among college students.

This report examines: (1) what is known about the extent of food 

insecurity among college students and their use of SNAP; (2) how 

selected colleges are addressing student food insecurity; and (3) the 

extent to which federal programs assist college students experiencing 

food insecurity.

To determine what is known about the extent of food insecurity among 

college students, we conducted an in-depth review of studies. To be 

included, studies had to: (1) be based on research conducted in and 

published in the United States; (2) be published after 2007; and (3) 

contain original, direct estimates of food insecurity rates among college 

students. We identified 35 studies that met these criteria, but 

subsequently eliminated 4 of these from our in-depth review due to 

concerns about their methodological limitations. We reviewed and 

summarized the remaining 31 studies.

We also analyzed National Postsecondary Student Aid Study (NPSAS) 

data from the 2015-2016 academic year, the most recent year available, 

to estimate the prevalence of risk factors for food insecurity among 

college students. Nationally representative survey data that would support 

direct estimates of the prevalence of food insecurity among college 

students do not currently exist. However, the National Center for 

Education Statistics at the Department of Education (Education) regularly 

collects NPSAS data, which contain nationally representative, detailed 

 2

See Suzanna M. Martinez, Edward A. Frongillo, Cindy Leung, and Lorrene Ritchie, “No 

Food for Thought: Food Insecurity is Related to Poor Mental Health and Lower Academic 

Performance among Students in California’s Public University System,” Journal of Health 

Psychology (June 25, 2018), accessed at 

http://journals.sagepub.com/doi/abs/10.1177/1359105318783028; Maya E. Maroto, 

Anastasia Snelling, and Henry Linck, “Food Insecurity among Community College 

Students: Prevalence and Association with Grade Point Average,” Community College 

Journal of Research and Practice, vol. 39, no. 6 (2015); Megan M. Patton-López, Daniel 

F. López-Cevallos, Doris I. Cancel-Tirado, and Leticia Vazquez, “Prevalence and 

Correlates of Food Insecurity among Students Attending a Midsize Rural University in 

Oregon,” Journal of Nutrition Education and Behavior, vol. 46, no. 3 (2014); Meg 

Bruening, Stephanie Brennhofer, Irene van Woerden, Michael Todd, and Melissa Laska, 

“Factors Related to the High Rates of Food Insecurity among Diverse, Urban College 

Freshmen,” Journal of the Academy of Nutrition and Dietetics, vol. 116, no. 9 (2016).
Page 3 GAO-19-95 College Student Food Insecurity

demographic and financial data about college students.3 We assessed 

the reliability of the NPSAS data by reviewing existing information about

the data and the system that produced them and by interviewing agency 

officials knowledgeable about the data. As a result, we determined that 

the data were sufficiently reliable for the purposes of this report. We 

identified risk factors associated with food insecurity through a literature 

review and through interviews with academic researchers, college 

officials, state and federal officials, and relevant policy organizations. We 

also analyzed NPSAS data to estimate SNAP participation among 

potentially eligible students.

To understand how selected colleges address student food insecurity, we 

conducted site visits in California, Kentucky, Massachusetts, and 

Michigan. We selected a geographically diverse group of states where 

colleges or state SNAP agencies were actively addressing food insecurity 

among college students. In selecting these states, we reviewed literature 

and asked researchers we interviewed about colleges and states that 

were actively addressing food insecurity on campus. In each state, we 

met with administrators, faculty, and students at selected 2- and 4-year 

public colleges and with officials from the state agencies that administer 

the SNAP program and other relevant organizations. Overall, we 

contacted 14 colleges—seven 2-year and seven 4-year colleges—that 

were actively addressing food insecurity among their students.4 We also 

interviewed researchers and staff at policy organizations knowledgeable 

about SNAP and college student food insecurity.

To assess the extent to which federal programs assist college students 

experiencing food insecurity, we reviewed relevant federal laws, 

regulations, and agency guidance and program documents. We emailed 

the 51 state SNAP agency directors (all 50 states and the District of 

Columbia) to ask whether their state agency is taking any action to 

address college student food insecurity and received responses from 50 

 3

NPSAS data are based on a nationally representative sample of college students. Data 

are collected from multiple sources, including school records and government databases, 

as well as student interviews. 

4

We visited 12 colleges as a part of our site visits and conducted telephone interviews with 

officials at 2 colleges in other states.
Page 4 GAO-19-95 College Student Food Insecurity

of them.5 We interviewed state SNAP agency directors in our site visit 

states of California, Kentucky, Massachusetts, and Michigan, as well as in 

Washington because of its innovative partnerships with colleges. We also 

interviewed USDA Food and Nutrition Service (FNS) officials at the 

national office as well as at four of the seven FNS regional offices.6 We 

compared FNS’s communication and information sharing activities 

against federal internal control standards. Further details on our 

methodology are available in appendix I.

We conducted this performance audit from July 2017 to December 2018 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The federal government, states, colleges, students and their families all 

play important roles in financing higher education costs.7 Under Title IV of 

the Higher Education Act of 1965, as amended, the federal government 

offers students at all types of colleges financial assistance to help pay for 

their education, such as through the William D. Ford Federal Direct Loan 

(Federal Direct Loan), the Federal Pell Grant (Pell Grant), and the 

Federal Work-Study programs. Some of this aid is targeted toward 

students based on their financial need. For example, Education provided 

almost $27 billion in Pell Grants to low-income students in fiscal year 

2017. States also provide funding to public colleges through state 

appropriations for operating expenses and grant programs that provide 

financial aid directly to students based on financial need, merit, or a 

combination of both. Despite the substantial federal expenditure in higher

 5

Michigan’s state SNAP agency did not respond to our email. However, we interviewed 

the Michigan state SNAP agency director during the course of our review and 

incorporated the state’s actions to address student food insecurity into our report, as 

appropriate.

6

We interviewed the four FNS regional offices that are responsible for oversight of our site 

visit states.

7

For purposes of this report, “colleges” include 2- and 4-year degree-granting institutions 

as well as those that provide technical training in certificate programs of shorter duration. 

Unless otherwise noted, “college students” refers to undergraduates enrolled in one of 

these institutions.

Background
Page 5 GAO-19-95 College Student Food Insecurity

education, rising college costs have outpaced federal and state grant aid 

and, over time, have led to an increasing share of the cost being borne by 

students and their families. For example, over the past 30 years, the 

average in-state net price for a full-time undergraduate student at a public 

4-year college—after taking into account all grant aid and education tax 

benefits—has nearly doubled, from about $8,000 in 1990-1991 to nearly 

$15,000 in 2017-2018. At public 2-year colleges, the net price for full-time 

students increased over the same time period from about $6,800 to 

$8,000.8

To plan for the cost of college, students and their families must consider 

the full cost of attendance, which includes not only tuition and fees, but 

also room and board and other miscellaneous expenses.9 The federal 

government requires colleges to estimate and distribute information on 

the full cost of attendance to prospective and enrolled students. The 

amount of need-based federal aid a student is eligible for is based, in 

part, upon the school’s estimated cost of attendance.

National data show that, over the past several decades, an increasing 

percentage of students from low-income households are enrolling in 

college. According to NPSAS data, the percentage of all undergraduates 

who had a household income at or below 130 percent of the federal 

poverty line increased from 28 percent in 1996 to 39 percent in 2016.10 In 

addition, the percentage of college students receiving a Pell Grant has 

nearly doubled over roughly the same time period. For example, in 1999-

2000, approximately 23 percent of college students received a Pell Grant, 

 8

Net price is the cost of college per student after all financial aid and education tax 

benefits are taken into account. This figure includes tuition, fees, room, and board (the 

cost of food). To increase transparency about college costs and help students make 

informed decisions about which college they can afford, the federal government requires 

all colleges that are authorized to disburse federal financial aid to annually publish on their 

website a net price calculator. These figures are collected and published in Sandy Baum, 

Jennifer Ma, Matea Pender, and Meredith Welch, Trends in Student Aid 2017 (New York: 

The College Board, October 2017).

9

Room costs include an allowance for living expenses for students who do not live on 

campus. Miscellaneous expenses may include allowances for books, supplies, 

transportation, loan fees, and, if applicable, dependent care.

10These results are within a +/-1 percentage point margin of error. U.S. Department of 

Education, National Center for Education Statistics, 1995-1996 National Postsecondary 

Student Aid Study (NPSAS:96); and 2015-2016 National Postsecondary Student Aid 

Study (NPSAS:16). 

Changes in College 

Student Demographics
Page 6 GAO-19-95 College Student Food Insecurity

and in 2016, this figure was about 40 percent.11 Some researchers have 

suggested that reductions in federal and state funding of higher education 

relative to the increasing cost of college have coupled with these student 

demographics to increase the share of college costs borne by students, 

which can reduce the amount students have to support their basic needs, 

such as food and housing.12

A traditional college student is generally considered to be someone who 

is enrolled in college full time immediately after graduating from high 

school, is financially dependent on his or her parents, and either does not 

work during the school year or works part time.13 However, these 

students represent a minority of students enrolled in college today. 

According to NPSAS data, about half of all undergraduate students 

enrolled in college in 2016 were considered financially independent from 

their parents. About 22 percent had dependent children themselves, and 

14 percent were single parents. The average college student in 2016 was 

26 years old and first enrolled at age 21. Sixty-four percent of college 

students in 2016 worked at least part time while enrolled, and a quarter 

worked full time. See figure 1 for the percentages of traditional and 

nontraditional students in 2016 and for Education’s list of traditional and 

nontraditional student characteristics.

 11U.S. Department of Education, National Center for Education Statistics, Trends in Pell 

Grant Receipt and the Characteristics of Pell Grant Recipients: Selected Years, 1999-

2000 to 2011-2012, NCES 2015-601 (Washington, D.C.: September 2015); and 2015-

2016 National Postsecondary Student Aid Study (NPSAS:16).

12See, for example, Amy Ellen Duke-Benfield, Bolstering Non-Traditional Student 

Success: A Comprehensive Student Aid System Using Financial Aid, Public Benefits, and 

Refundable Tax Credits (Washington, D.C.: Center for Law and Social Policy, December 

2015); Sara Goldrick-Rab, Katharine Broton, and Daniel Eisenberg, Hungry to Learn: 

Addressing Food and Housing Insecurity among Undergraduates (Madison: Wisconsin 

HOPE Lab, December 2015); Sara Goldrick-Rab, Jed Richardson, and Anthony 

Hernandez, Hungry and Homeless in College: Results from a National Study of Basic 

Needs Insecurity in Higher Education (Madison: Wisconsin HOPE Lab, March 2017).

13U.S. Department of Education, National Center for Education Statistics, Findings from 

the Condition of Education, 2002: Nontraditional Undergraduates, NCES 2002–012 

(Washington, D.C.: 2002).
Page 7 GAO-19-95 College Student Food Insecurity

Figure 1: Percentages and Characteristics of Traditional and Nontraditional College 

Students in 2016

Note: Categories of traditional and nontraditional students are based on the Department of 

Education’s definition. All results are within a +/-2 percentage point margin of error.

FNS oversees the states’ administration of SNAP, the main federal 

benefit program to address food insecurity for low-income households. In 

fiscal year 2017, the program provided benefits to about 42 million 

individuals in more than 20 million households. The purpose of the SNAP 

program is to safeguard the health and well-being of the nation’s 

population by providing a monthly cash benefit to raise the purchasing 

power and nutrition level of low-income households. FNS is responsible 

for establishing program regulations and ensuring that state officials 

administer SNAP in compliance with program rules. Officials in seven 

FNS regional offices assist officials from the FNS national office in this 

oversight work. FNS shares information and policy guidance with state 

SNAP agencies in part through its regional offices, the FNS website, and 

annual conferences. The states, or in some cases counties within a state, 

administer SNAP by determining whether households meet the program’s 

eligibility requirements, calculating monthly benefits for qualified 

households, issuing benefits to participants on an electronic benefits 

transfer card, and investigating and prosecuting recipient fraud. States 

Federal Food Assistance 

Programs Available to 

College Students
Page 8 GAO-19-95 College Student Food Insecurity

are also allowed to establish some state-specific modifications in how 

they administer SNAP policy.14

Beyond SNAP, the Special Supplemental Nutrition Program for Women, 

Infants, and Children (WIC) is another federal food assistance program 

available to eligible college students who are pregnant or postpartum.15

FNS also oversees the WIC program, which is administered by state and 

local agencies through approximately 10,000 clinic sites.

SNAP eligibility is largely based on a household’s income and certain 

other characteristics.16 However, in 1980 federal law restricted college 

students who are enrolled at least half time from receiving SNAP 

benefits.17 This law generally prevents traditional college students—who

may appear to have a low income while attending college but receive 

 14SNAP’s statutes, regulations, and waivers provide state SNAP agencies with various 

policy options. State SNAP agencies use this flexibility to adapt their programs to meet the 

needs of eligible, low‐income households in their states. See U.S. Department of 

Agriculture, Food and Nutrition Service, Supplemental Nutrition Assistance Program, State 

Options Report, 14th Edition (Washington, D.C.: May 31, 2018).

15WIC is designed to improve the health and nutritional well-being of pregnant and 

postpartum women, infants, and young children by providing nutritious supplemental 

foods, nutrition education, and referrals to health and social service programs. Pregnant 

and postpartum women and children up to age 5 are eligible if they are found to be at 

nutritional risk and have incomes below a certain threshold. WIC participants typically 

receive food benefits in the form of vouchers or coupons that they redeem at authorized 

retail vendors to obtain, at no cost, certain approved foods, including infant formula. 

16In general, SNAP defines a household as persons living together who purchase food 

and prepare meals together for home consumption. Some people who live together are 

included in the same household even if they purchase and prepare meals separately, 

such as spouses and children under 22 living with their parents. Some federal program 

benefits are included as income when determining a household’s SNAP eligibility, while a 

household may deduct certain expenses from the income used to calculate their eligibility 

for SNAP, such as those for dependent care if the care enables a household member to 

work or enroll in training or education.

17Food Stamp Act Amendments of 1980, Pub. L. No. 96-249, Title I, § 139, 94 Stat. 357, 

370. The statutory language restricts access to SNAP benefits for individuals enrolled half 

time or more in an institution of higher education. 7 U.S.C. § 2015(e). An individual is 

considered to be enrolled in an institution of higher education if the individual is enrolled in 

a business, technical, trade, or vocational school that normally requires a high school 

diploma or equivalency certificate for enrollment in the curriculum or if the individual is 

enrolled in a regular curriculum at a college or university that offers degree programs

regardless of whether a high school diploma is required. For the purposes of discussing 

student access to SNAP benefits in this report, we will refer to these individuals as college 

students. 

College Student Eligibility 

for SNAP
Page 9 GAO-19-95 College Student Food Insecurity

financial support from their parents—from receiving SNAP benefits. 

Federal law establishes several exemptions to this restriction so that 

college students who are enrolled at least half time and have a legitimate 

need can access SNAP.18 For example, assuming that they meet all other 

SNAP eligibility criteria, a full-time college student may be exempt from 

the college student restriction if they are:

• younger than age 18 or age 50 or older;

• a parent caring for a child under age 6;

• a parent caring for a child aged 6 to 11 who is unable to obtain 

childcare to attend school and work;

• a single parent caring for a child under 12 years old and enrolled full 

time;

• working a minimum of 20 hours per week at paid employment;

• participating in a state- or federally-financed work-study program;

• receiving Temporary Assistance for Needy Families (TANF) 

benefits;19

• not physically or mentally fit (e.g., have a disability);20 or

• enrolled in certain programs for the purpose of employment and 

training.21

FNS officials told us that states have flexibility regarding which programs 

may qualify a student for the exemption pertaining to enrollment in certain 

programs for the purpose of employment and training. These programs 

must be operated by a state or local government, target low-income 

households, and increase participants’ employability. State SNAP 

agencies have discretion to determine which programs in their state 

 18Throughout this report we refer to these as student eligibility exemptions. Students who 

meet one of these student eligibility exemptions do not automatically qualify for SNAP—

they must still apply for SNAP and meet the household income and asset limits, among 

other eligibility criteria, to be determined eligible to receive SNAP benefits.

19TANF is a block grant to states to help meet the needs of low-income families. The 

program emphasizes work and time-limited cash assistance and gives states wide 

discretion on how to use TANF funds, including for various noncash services. 

20For ease of reference, in this report we use the term “disability” to refer to this student 

eligibility exemption.

217 U.S.C. § 2015(e)(3). 
Page 10 GAO-19-95 College Student Food Insecurity

qualify.22 These employment and training programs may be operated at 

community colleges, among other community partners.

FNS officials said that in 2014 the agency expanded its focus on SNAP 

Employment & Training (E&T) program services, which are intended to 

help individuals in SNAP households acquire skills, training, and work 

experience that will increase their ability to obtain regular employment 

that will ultimately lead to greater self-sufficiency and reduce their reliance 

on SNAP.23 State agencies have flexibility in designing SNAP E&T 

program services, and FNS encourages states to enter into partnerships 

with established providers, including community colleges, to deliver SNAP 

E&T program services.24 For example, a SNAP recipient could train to 

become a Certified Nursing Assistant at a community college as part of a 

state’s SNAP E&T program. In addition to providing employment and 

training services, state SNAP E&T programs are required to provide 

participants with necessary supportive services, such as transportation, 

childcare, and textbooks.

 227 C.F.R. § 273.5(b)(11)(iv). The law also states that programs must be at least 

equivalent to a state SNAP Employment and Training (E&T) program service.

23We recently reported on the performance of the SNAP E&T Program. See GAO, 

Supplemental Nutrition Assistance Program: More Complete and Accurate Information 

Needed on Employment and Training Programs, GAO-19-56 (Washington, D.C.: Nov. 20, 

2018).

24A provision in the 2014 Farm Bill clarified that SNAP E&T program services must meet 

the criteria for a career or technical education program outlined in the Carl D. Perkins 

Career and Technical Education Act (Perkins Act). For the purposes of the Perkins Act, a 

career or technical education program is defined at 20 U.S.C. § 2302.
Page 11 GAO-19-95 College Student Food Insecurity

Our review of 31 studies provided some information regarding food 

insecurity among college students, but all of the studies have limitations 

and none provide estimates of food insecurity for this population in 

general.25 Estimates of food insecurity among college students included 

in the studies we reviewed ranged from 9 percent to well over 50 percent, 

with 22 of these of 31 studies estimating food insecurity rates of over 30 

percent.

26 These results reflect the studies’ different samples and 

methods, and the estimates from the studies included in our review are 

not generalizable to the college student population as a whole. None of 

these studies are based on a sufficiently large or diverse random sample 

of college students to constitute a representative study. The studies 

addressed the difficulty of sampling the college student population in 

different ways, including by extrapolating from household data, surveying 

students in a particular degree program or on a particular campus, or 

targeting particular, non-random sub-groups of the college student 

population. Most of the studies were also conducted on only one campus, 

 25We included studies that had been published in U.S. journals from January 2007 through 

August 2018, covered college students in the United States, and contained original, direct 

estimates of food insecurity among college students. 

26USDA has developed three questionnaires containing 6, 10, and 18 questions, 

respectively, to measure household food insecurity. All but three of the studies in our 

review adapted the questions from either the 6-, 10-, or 18-question USDA questionnaire 

to measure food insecurity among individual students. Depending on how many questions 

respondents answer affirmatively, they were designated as being either food secure, 

having low food security, or having very low food security. Those with either low or very 

low food security were termed “food insecure.” 

Information about the 

Prevalence of Food 

Insecurity among 

College Students 

Nationally is Limited 

and Many Potentially 

Eligible, At-Risk 

Students Do Not 

Receive SNAP

Studies Identify a Range 

of Food Insecurity Rates 

among Respondents, but 

Results Cannot Be 

Generalized to All 

Students
Page 12 GAO-19-95 College Student Food Insecurity

although some studies gathered data from more than one campus.27

Despite the limitations, these studies as a whole help shed some light on 

the range of food insecurity that exists among some groups of college 

students.

Of the 31 studies we reviewed, 2 used nationally representative 

household data sets, the Current Population Survey and the Survey of 

Income and Program Participation.28 The study that used the Current 

Population Survey data from 2011-2015 found that an estimated:

• 11 percent of households with a student in a 4-year college 

experienced food insecurity,

• 14 percent of households with a student in vocational/technical 

education experienced food insecurity, and

• 17 percent of households with a student in a community college 

experienced food insecurity.29

These national household surveys assess the food security of households 

with a college student member, but they do not directly survey college 

students and only measure food security at the household, and not the 

individual, level. For example, these household data may not capture a 

 27Of the 31 studies included in our review, 8 had survey respondents from multiple college 

campuses or across university systems.

28The Current Population Survey, sponsored jointly by the U.S. Census Bureau and the 

U.S. Bureau of Labor Statistics, is the primary source of labor force statistics for the 

population of the United States. Since 1995, the Current Population Survey has included a 

Food Security Supplement (FSS) that has collected information on the food security, food 

program participation, and food expenditures of U.S. households. FSS survey questions 

ask about the household as a whole and not about individuals within the household. The 

Survey of Income and Program Participation, sponsored by the U.S. Census Bureau, is 

the federal government’s premier source of information for U.S. household income and 

program participation. The Survey of Income and Program Participation collects data for 

many topics, including: economic well-being, family dynamics, education, assets, health 

insurance, childcare, and food security.

29The authors found that the incidence of food insecurity for each of these groups was 

significantly different (at the .05 level) from the incidence of food insecurity for all adults 

not in that group. See Kristin Blagg, Craig Gundersen, Diane Whitmore Schanzenbach, 

and James P. Ziliak, Assessing Food Insecurity on Campus: A National Look at Food 

Insecurity among America’s College Students (Washington, D.C.: The Urban Institute, 

August 2017).
Page 13 GAO-19-95 College Student Food Insecurity

college student’s food insecurity in situations where the student member 

of the household does not live at home for most of the year.30

The remaining 29 studies we reviewed collectively surveyed college 

students on approximately 200 campuses across multiple states, 

including two large state university systems, and produced a wide range 

of estimates of food insecurity. In most cases, the results can be 

characterized as applying only to the respondents of the survey.31 The 29 

studies based on campus surveys provide a range of food insecurity rates 

among respondents, from 9 percent to over 50 percent.

• For example, a study first published in 2017 found that 15 percent of 

student respondents at one 4-year college experienced food 

insecurity, with an additional 16 percent of student respondents at that 

college estimated to be at-risk for food insecurity.32

• Two recent surveys of college systems in California found that 40 

percent of respondents from University of California campuses and 42 

percent of respondents from California State University campuses 

experienced food insecurity.33

Estimates of food insecurity rates in the studies we reviewed tended to be 

higher at 2-year than at 4-year colleges. Four studies examined only 2-

year college students and three of these studies estimated food insecurity 

 30Additionally, while these surveys are nationally representative overall, the number of 

households with college students in these surveys is relatively small, which limits the 

precision of these estimates.

31The inability to generalize beyond survey respondents occurs in these cases because 

even when a survey is sent to all students or to a random sample of students, the students 

who choose to respond may be non-random. For example, students with a particular 

interest in food insecurity or who want to report their own food insecurity may opt to 

participate in these surveys at higher rates than other students. As a result, the 

respondents may not fully represent the population sampled. Additionally, the response 

rates in many of the surveys used in the studies we reviewed were very low—in some 

cases 10 percent or below. 

32See Devon C. Payne-Sturges, Allison Tjaden, Kimberly M. Caldeira, Kathryn B. Vincent, 

and Amelia M. Arria, “Student Hunger on Campus: Food Insecurity among College 

Students and Implications for Academic Institutions,” American Journal of Health 

Promotion, vol. 32, no. 2 (2018).

33See R.M. Crutchfield and J. Maguire, “California State University Office of the Chancellor 

Study of Student Basic Needs,” retrieved from http://www.calstate.edu/basicneeds; and 

Suzanna M. Martinez, Karen Webb, Edward A. Frongillo, and Lorrene D. Ritchie, “Food 

Insecurity in California’s Public University System: What Are the Risk Factors?,” Journal of 

Hunger and Environmental Nutrition, vol. 13, no. 1 (2017).
Page 14 GAO-19-95 College Student Food Insecurity

rates among respondents at 2-year colleges to be 40 percent or higher. 

Three studies looked at both 2-year and 4-year colleges and estimated 

food insecurity to be higher among students at 2-year colleges. For 

example, a large, multi-college study conducted in 2017 found that during 

the 30 days preceding the survey, 42 percent of community college 

students who responded and 36 percent of students at 4-year colleges 

who responded indicated they were food insecure.34 Further, the two 

studies that used national household data sets found that households 

with community college and vocational education student members had 

higher food insecurity levels than households with students at 4-year 

colleges.35

We identified and analyzed the prevalence of risk factors associated with 

food insecurity among students through our review of peer-reviewed 

publications on food insecurity and through interviews with academic 

researchers, college officials, state and federal officials, and officials from 

relevant policy organizations.36 In the studies we reviewed and in our 

interviews with researchers, having a low income was consistently 

identified as a key risk factor for food insecurity. The other risk factors we 

included in our analysis are: being a first-generation college student, 

 34Sara Goldrick-Rab, Jed Richardson, Joel Schneider, Anthony Hernandez, and Clare 

Cady, Still Hungry and Homeless in College (Madison: Wisconsin HOPE Lab, April 2018).

35See Blagg, Gundersen, Schanzenbach, and Ziliak, Assessing Food Insecurity on 

Campus. See also K. Broton, “The Evolution of Poverty in Higher Education: Material 

Hardship, Academic Success, and Policy Perspectives” (Ph.D. diss., University of 

Wisconsin-Madison, 2017).

36We focused on risk factors associated with food insecurity because nationally 

representative data on food insecurity among college students do not exist. The risk 

factors we identified can be grouped into several broad categories: low-income indicators, 

housing issues, skills/resiliency factors, demographic characteristics, and “other 

stressors.” For example, the academic studies we reviewed consistently identified having 

a low-income as a correlate of food insecurity. Our analysis focused on potential risk

factors that had a corresponding variable in the 2016 NPSAS data set. We defined low 

income as a household income at or below 130 percent of the federal poverty line 

because this is the income threshold for SNAP benefits for households that do not include

a member who is 60 years of age or older or disabled. For more information on how we 

identified risk factors associated with food insecurity, see appendix I. 

Federal Data Show Most 

Low-Income Students Had 

Multiple Risk Factors 

Associated with Food 

Insecurity in 2016
Page 15 GAO-19-95 College Student Food Insecurity

receiving SNAP, being a single parent, being disabled, being homeless or 

at risk of homelessness, and being a former foster youth.37

In our analysis, we focused on students with a household income at or 

below 130 percent of the federal poverty line, which represents 39 

percent of all undergraduates.38 While having a low income is itself the 

most common risk factor for food insecurity among college students, our 

analysis found that the majority of low-income students also experience 

additional risk factors for food insecurity. The three most common risk 

factors for food insecurity among low-income students were being a firstgeneration college student; receiving SNAP (receiving SNAP can be 

considered a risk factor in that it may reduce, but not entirely eliminate, 

food insecurity); and being a single parent. Of the approximately 7.3 

million low-income students, 31 percent were first-generation college 

students, 31 percent reported receiving SNAP, and 25 percent were 

single parents.39 The prevalence of risk factors among low-income 

students was lower at 4-year colleges compared to other colleges. For 

example, about 21 percent of low-income 4-year college students were 

single parents in 2016 compared to about 42 percent of low-income 

students in less than 2-year programs. Low-income individuals enrolled in 

less than 2-year programs had the highest prevalence for almost all risk 

factors (see table 1).40

 37Receiving SNAP is a risk factor for food insecurity because while receiving SNAP 

benefits addresses food insecurity to some extent, studies show SNAP recipients still 

have higher food insecurity rates than the general population. For example, one study 

found that receiving SNAP for 6 months only reduced food insecurity by about 13 percent. 

In other words, receiving SNAP benefits may reduce food insecurity without completely 

eliminating it. See, for example, James Mabli, Jim Ohls, Lisa Dragoset, Laura Castner, 

and Betsy Santos, Measuring the Effect of Supplemental Nutrition Assistance Program 

(SNAP) Participation on Food Security, a report prepared by Mathematica Policy 

Research at the request of the U.S. Department of Agriculture, Food and Nutrition Service 

(August 2013).

38This analysis excludes foreign and international students.

39Risk factors associated with food insecurity frequently co-occur. Our analysis found the 

majority of low-income students who received SNAP also have one or more additional risk 

factors. Including SNAP receipt as a risk factor in our analysis did not substantially affect 

the total number of at-risk students.

40Our analysis does not estimate rates of food insecurity among students with these 

characteristics because the NPSAS does not include data on food insecurity. Instead, our 

analysis highlights low-income students who have at least one other risk factor associated 

with food insecurity. Education officials said they are planning to incorporate food 

insecurity questions into the next NPSAS data collection in 2020. See appendix I for 

information about how we selected and operationalized these risk factors.
Page 16 GAO-19-95 College Student Food Insecurity

Table 1: Prevalence of Risk Factors Associated with Food Insecurity among Low-Income U.S. College Undergraduate 

Students, by College Type in 2016

Total

4-year 

schools

2-year 

schools

Less than

2-year schools

Risk 

factor

Number of 

students

Percent of 

low- income 

students 

Number of 

students

Percent of 

low-income 

students

Number of 

students

Percent of 

low- income 

students

Number of 

students

Percent of 

low- income 

students

First 

generationa 2,299,206 31% 1,015,263 28% 1,188,889 34% 95,053 35%

Receiving 

SNAPb 2,257,121 31% 1,024,774 29% 1,128,133 33% 104,214 38%

Single parent 1,815,655 25% 756,885 21% 943,168 27% 115,602 42%

Disabledc 1,591,962 22% 757,267 21% 773,159 22% 61,536 22%

Homeless or 

at risk of 

homeless

1,109,714 15% 504,397 14% 548,235 16% 57,082 21%

Former foster 

youthd 788,866 11% 391,819 11% 371,419 11% 25,628 9%

Total Lowincome 

studentse

7,339,571 100% 3,597,419 100% 3,466,862 100% 275,291 100%

Source: GAO analysis of 2016 National Postsecondary Student Aid Study Data | GAO-19-95

Notes: All results are within a +/-5.5 percentage point margin of error. Percentages do not sum to 100 

percent because students may have more than one risk factor.

a

Being a first generation college student is determined based on whether the student reported that 

his/her parents attended college.

b

Receipt of Supplemental Nutrition Assistance Program (SNAP) benefits is self-reported and not 

cross-checked with Food Nutrition Service (FNS) enrollment data.

c

Students self-report their disability status; this is not based on a federal disability determination.

d

The variable we used as a proxy for having been a former foster youth is indicated by being an 

orphan or ward of the court.

e

Low income is defined as having a household income level at or below 130 percent of the federal 

poverty level.

Twenty-nine percent of all U.S. undergraduates had a low income and 

experienced at least one additional risk factor for food insecurity, 

according to our analysis of 2016 NPSAS data—14 percent had a low 

income and one other risk factor and 15 percent had a low income and 

two or more additional risk factors associated with food insecurity (see 

table 2). Risk factors associated with food insecurity are more prevalent 

among low-income students than among the general student population, 

with 75 percent of low-income students experiencing one or more 

additional risk factors. Students at 2-year colleges and those in less than 

2-year programs were also more likely to have multiple risk factors.
Page 17 GAO-19-95 College Student Food Insecurity

Table 2: Prevalence of Risk Factors Associated with Food Insecurity among Low-Income U.S. College Undergraduate 

Students in 2016

Number of 

risk factors

Number of 

low-income 

undergraduates

Percent of all 

undergraduates

Percent of low-income 

undergraduates

Low-income and 0 

additional 

risk factors

1,858,253 10%

29% of U.S. 

undergraduates are 

low-income and 

have 1 or more 

additional risk 

factors for food 

insecurity

25%

75% of lowincome 

undergraduates 

have 1 or more 

additional risk 

factors for food 

insecurity

Low-income and 1 

additional 

risk factor

2,586,454 14% 35%

Low-income and 2 or 

more additional risk 

factors

2,894,864 15% 39%

Total low-income 

undergraduates

7,339,571 39% 100%

Source: GAO analysis of 2016 National Postsecondary Student Aid Study Data | GAO-19-95

Notes: All results are within a +/-1 percentage point margin of error. Sums have been rounded to the 

nearest whole percentage point. We included the following risk factors associated with food insecurity 

in addition to having a low income: being a first-generation college student, receiving Supplemental 

Nutrition Assistance Program (SNAP) benefits, being a single parent, being disabled, being homeless 

or at risk of homelessness, and being a former foster youth.
Page 18 GAO-19-95 College Student Food Insecurity

In our analysis of SNAP participation among students, we focused on 

low-income students with at least one additional risk factor for food 

insecurity because these students would likely meet the income threshold 

for SNAP eligibility and have an additional risk factor that could put them 

in need of food assistance.41 Our analysis of 2016 NPSAS data identified 

about 5.5 million low-income students with at least one additional risk 

factor for food insecurity and found that about 59 percent of these 

students (3.3 million) reported being enrolled at least half time and 

meeting a SNAP student eligibility exemption. About 1.8 million of these 

low-income students with an additional risk factor reported meeting a 

student exemption and also that they were not receiving SNAP 

benefits.42 In other words, among potentially SNAP eligible low-income 

students with at least one additional factor for food insecurity, 57 percent 

did not report participating in SNAP in 2016 (see fig. 2).43

 41We identified potentially eligible students based on characteristics we identified in the 

NPSAS data, specifically, whether they had an income at or below 130 percent of the 

federal poverty level and reported meeting one of the student exemptions we were able to 

capture in our analysis. Our analysis was not able to perfectly capture all the student 

eligibility exemptions. Some of the limitations of our analysis may have led to fewer 

students appearing to meet an eligibility exemption (specifically the exemption related to 

participation in other employment and training programs, for which there is no 

corresponding NPSAS variable), while others may have led to more students appearing to 

meet an eligibility exemption (specifically the exemptions related to disability and the 

availability of childcare, for which the NPSAS variable does not perfectly align with the 

SNAP student exemptions). A student who meets a SNAP exemption must still submit a 

SNAP application with household income and asset information; then the state SNAP 

agency reviews the application, interviews the applicant to gather additional relevant 

information, and determines eligibility for SNAP benefits. See appendix I for more 

information on how we identified students who potentially met a SNAP eligibility exemption 

using NPSAS data.

42The student or their parents report receipt of SNAP benefits on the Free Application for 

Federal Student Aid. Students are asked about their receipt of SNAP benefits again during 

the interview portion of the NPSAS. Most students we identified as not receiving SNAP 

were financially independent and could likely apply for SNAP as their own household; 

dependent students who are potentially eligible can only receive SNAP as part of their 

parents’ household.

43The total SNAP participation rate among potentially eligible students with one additional 

risk factor was 43 percent. According to FNS, in fiscal year 2016, the national SNAP 

participation rate among all eligible persons was about 85 percent. See Karen 

Cunnyngham, Trends in Supplemental Nutrition Assistance Program Participation Rates: 

Fiscal Year 2010 to Fiscal Year 2016, a report prepared at the request of the U.S. 

Department of Agriculture, Food and Nutrition Service (Washington, D.C.: Mathematica 

Policy Research, July 2018).

Fifty-Seven Percent of 

Potentially Eligible LowIncome Students with 

Food Insecurity Risk 

Factors in 2016 Did Not 

Participate in SNAP
Page 19 GAO-19-95 College Student Food Insecurity

Figure 2: Supplemental Nutrition Assistance Program (SNAP) Participation among Low-Income College Students At-Risk of 

Food Insecurity in 2016

Notes: All results are within a +/-2 percentage point margin of error. We identified students potentially 

eligible for SNAP based on characteristics we identified in the NPSAS data related to SNAP 

eligibility—specifically, whether they had an income at or below 130 percent of the federal poverty 

level and reported one of the characteristics we identified that correspond to the student exemptions 

we were able to capture in our analysis. Some of the limitations of our analysis may have led to fewer 

students appearing to meet an eligibility exemption (specifically the exemption related to participation 

in other employment and training programs, for which there is no corresponding NPSAS variable), 

while others may have led to more students appearing to meet an eligibility exemption (specifically 

the exemptions related to disability and the availability of childcare, for which the NPSAS variable 

does not perfectly align with the SNAP student exemption). We did not make any legal determination 

about actual SNAP eligibility for any individual. Risk factors associated with food insecurity include 

being disabled, homeless or housing insecure, a former foster youth, a single parent, the firstgeneration in a student’s family to attend college, and receiving SNAP benefits. Participation in SNAP 

is self-reported through the Free Application for Federal Student Aid and these data are used in the 

NPSAS.

a

Students who did not meet an eligibility exemption but reported receiving SNAP (1) may be receiving 

SNAP as members of their parents’ household, (2) may have attended college less than half time and 

therefore were not subject to the student SNAP restrictions, or (3) may have met one of the student 

exemptions we were unable to capture in our analysis.
Page 20 GAO-19-95 College Student Food Insecurity

About one-quarter of the 5.5 million low-income students with at least one 

additional risk factor for food insecurity did not meet any of the student 

exemptions we could identify in the NPSAS data and reported that they 

did not receive SNAP benefits.44 These students would likely be ineligible 

to participate in SNAP unless they begin meeting one of the student 

eligibility exemptions in the future, such as working 20 hours per week.

The 14 selected colleges we contacted are addressing student food 

insecurity in three main ways: by educating faculty, staff, and students; by 

providing students free food and emergency assistance; and by 

centralizing and coordinating their student services and helping students 

apply for federal and state benefits. Officials at 9 of these colleges said 

that they viewed student food insecurity as part of students’ increasing 

inability to meet their basic needs as a result of the decreasing 

affordability of higher education or the high cost of living. This sentiment 

was echoed by selected students we spoke with during discussion groups 

(see text box). 

 44In addition, 15 percent of low-income college students with one additional risk factor for 

food insecurity did not appear to meet one of the student exemptions, based on our 

analysis, but reported they received SNAP in 2016. This may be because they received 

SNAP through their parents’ household, were enrolled less than half time and therefore 

not subject to student SNAP restrictions, or met one of the student exemptions we were 

unable to capture in our analysis. For example, the NPSAS data set does not contain data 

for the student eligibility exemption “enrolled in certain programs aimed at employment,” 

such as the Workforce Innovation and Opportunity Act or Temporary Assistance for Needy 

Families employment and training programs. As a result, we may overestimate the 

number of students who did not meet an eligibility exemption.

Selected Colleges 

Are Using a Range of 

Approaches to 

Address Student 

Food Insecurity
Page 21 GAO-19-95 College Student Food Insecurity

All of the colleges we contacted have implemented on-campus initiatives 

to combat students’ food insecurity with the goal of improving their 

student outcomes, such as retention, completion, and loan repayment 

rates. As one community college official told us: “We have come to realize 

that we can’t address retention and completion without addressing 

students’ basic needs.” See figure 3 for the range of initiatives the 14 

colleges we contacted were taking to address food insecurity among 

college students on their campuses.

Figure 3: Initiatives by Selected Colleges to Address Student Food Insecurity
Page 22 GAO-19-95 College Student Food Insecurity

Educating the campus community. Officials at several of the selected 

colleges told us that many administrators, faculty, staff, and students on 

their campus are unaware that students experience food insecurity, which 

hinders their college’s efforts to address the issue (see text box). At all 14 

colleges we contacted, officials said they are educating their campus 

community about available resources, both on campus and off, to 

address student food insecurity.

All of the 14 colleges we contacted also educate their students about the 

resources available to address food insecurity in a variety of ways, such 

as by providing information during student orientations, on flyers and 

pamphlets, or through social media and text messages. Eight of the 14 

colleges we contacted hold trainings or distribute information to faculty 

and staff about the on-campus and community resources available to 

students. Nine of these colleges have created supplemental or for-credit 

courses on topics such as financial literacy or cooking and nutrition. For 

example, one college we visited runs a workshop for first-year students 

on writing a spending plan and a food budget. At several of the selected 

colleges, faculty members include blurbs about basic needs-related 

resources, such as campus food pantries, in their syllabi.

Providing food and emergency financial assistance. All of the 14 

colleges we contacted address student food insecurity by providing 

students free food and most provide students emergency financial 

assistance. Nationwide, the College and University Food Bank Alliance 

has reported that at least 656 colleges have or were developing food 

pantries as of September 2018.45 Each of the 14 colleges we contacted 

had a food pantry, with 7 having started their pantry in the past 5 years. 

 45This is the number of college food pantries registered as members with the College and 

University Food Bank Alliance and does not include college food pantries that are not 

members. 
Page 23 GAO-19-95 College Student Food Insecurity

According to college officials, individual faculty and staff members are 

often first to identify food insecurity as a campus concern and provide 

food to students. For example, officials at several of the colleges we 

contacted traced the origins of their college’s food pantry to a drawer of 

food a faculty or staff member kept in their office for students, or to a 

professor who brought jars of peanut butter or bagels for any student who 

wanted one.

The college food pantries we visited varied in terms of their size and 

location, which can depend upon the space available on campus.46 For 

example, some pantries we visited consisted of only a couple of shelves 

of non-perishable items, while others spanned multiple rooms containing 

refrigerators and freezers. Directors at four of the selected food pantries 

said that student need was great enough to support expanding the food 

pantry, but that they had been unable to expand because space on 

campus is at a premium (see text box). 

Several pantries also had separate sections providing students personal 

health items and clothing and offered auxiliary services, such as 

information about cooking, food budgeting, or SNAP enrollment (see fig. 4 

for pictures of some of the college food pantries at selected colleges).

 46The food pantries we visited received funding from a variety of sources, including from 

their college’s budget, faculty, staff, and student donations, grants from community food 

banks, or endowments created by college donors.
Page 24 GAO-19-95 College Student Food Insecurity

Figure 4: Pictures of Food Pantries from GAO Site Visits to Selected Colleges 

Officials at 11 of the selected colleges we contacted said that a major 

barrier they face is overcoming the stigma some students associate with 

accepting help for their basic needs, such as using the food pantry (see 

text box). Concern about this stigma led at least 3 of the colleges we 

contacted to place their food pantry in a less-public area of campus to 

address students’ privacy concerns. In contrast, 3 other colleges we 

contacted centrally located their food pantry to advertise its existence and 

normalize its use. One college president we spoke with said that “until 

[the college] normalized [the food pantry] and pulled it to the center of 

campus, it was underutilized,” and stated that moving the food pantry to 

the center of campus quadrupled its use.

Officials at 9 of the 14 colleges we contacted reported that their campus 

food pantry had seen an increased number of users over time as the 
Page 25 GAO-19-95 College Student Food Insecurity

student body became aware of this resource. One student we spoke with 

said that his college’s food pantry was his only source of food, while 

another estimated that the food pantry allowed him to save about $100 

per month on food.

Officials at 10 of the 14 selected colleges we contacted told us they 

partner with national organizations or campus dining services or both to 

try to respond to the needs of students who might be experiencing food 

insecurity. For instance, public colleges in California receive state funding 

to incentivize them to address student food insecurity in a variety of ways, 

including by establishing campus food pantries, providing information to 

students about SNAP benefits, and establishing meal point donation 

programs.47 Two California colleges we contacted were working with a 

national organization to set up a meal point donation program. One 

college in another state we visited included in their contract with their 

private dining services vendor funding for several initiatives, such as a 

campus-wide survey of student food insecurity, on-campus farmer’s 

markets, and a learning kitchen that teaches students hands-on cooking 

skills. Additionally, 2 of the colleges we contacted are working to have 

SNAP benefits accepted at campus markets.

Beyond providing students with free food, officials at 12 of the 14 colleges 

we contacted said that their college makes emergency cash assistance 

available to students through small loans, grants, or grocery store or gas 

station gift cards. These emergency funds are intended to help students 

pay bills for one-time financial emergencies, such as buying groceries or 

paying for a car repair or a utility bill. One community college we visited 

directly ties this assistance to its retention efforts, providing a one-time 

amount of up to $500 for students judged to have sufficient need and who 

are likely to remain in school if the bill is paid.

Centralizing and coordinating student services and access to 

benefits. Officials at many of the colleges we contacted told us they have 

centralized their student support and financial aid services, among others, 

and several have introduced a case management approach to better 

collaborate across departments and more efficiently and holistically 

address their students’ basic needs (see text box). Of the 14 colleges we 

contacted, 8 had centralized some or all of their student services. For 

example, one community college we visited has co-located many of its 

 47Cal. Educ. Code § 66027.8(d).
Page 26 GAO-19-95 College Student Food Insecurity

student services—including its financial aid, academic counseling, payroll, 

food pantry, veterans’ services, and women’s resource center, among 

others—around a central hub of the student union. Students visiting this 

central hub may be assigned a caseworker to connect them with the oncampus, community, state, and federal benefits for which they are 

eligible. Officials at a few of the colleges we contacted said that centrally 

locating student services also helped faculty and staff by providing a 

single point of contact to refer students. One official said that she tells 

faculty and peer mentors: “If you see a student in any kind of distress at 

all—mental health, hunger, homelessness, anything—send them to us.”

She added that it is too much to ask faculty to figure out which office or 

official to send students to for specific concerns.

Officials at 8 of the 14 colleges we contacted told us their campus has 

established a coordinated benefits access program or is actively 

screening students for potential eligibility for, and helping them enroll in, 

federal and state benefit programs like SNAP, WIC, Medicaid, and the 

Earned Income Tax Credit.48 For example, one community college we 

contacted had a staff member build a statistical model to analyze the 

college’s existing data on first-time students, such as data on students’

household income, demographics, and course enrollment, to identify 

students at risk of not returning to college and to provide these students, 

their professors, and their faculty advisors with information about oncampus resources. Officials at one college we visited told us the campus 

 48Medicaid is a joint federal and state program that provides health coverage to millions of 

Americans, including some low-income individuals, families and children, pregnant 

women, the elderly, and people with disabilities. The Earned Income Tax Credit is a 

federal benefit for low- to moderate-income workers. 
Page 27 GAO-19-95 College Student Food Insecurity

hosts weekly clinics with county SNAP eligibility analysts to screen 

students for SNAP eligibility and help them apply for benefits. At a 

community college system we visited, the administration told us they were 

working with the state SNAP agency to identify which students were 

receiving SNAP benefits and they plan to send targeted information on 

SNAP to those potentially eligible students not receiving benefits.

Officials at three of the colleges we contacted said that their college was 

purchasing software that creates a centralized portal where faculty and 

staff can share information about a student’s situation with student 

support providers so they can better provide help. For example, at a 

college we visited that is using such software, officials said that a

professor might note in the centralized portal that an at-risk student was 

either failing or not attending a class, and that student would be flagged in 

the portal to notify academic advisors, counselors, and other college staff 

who can direct the student to the on-campus resources they may need, 

such as the food pantry or help in completing a SNAP application.
Page 28 GAO-19-95 College Student Food Insecurity

Federal grant aid is available to help low-income college students and 

their families pay for college, but for many students, the maximum 

amount of grant aid available to them does not cover all of the costs 

associated with attending college.49 Officials from many of the 

organizations we interviewed said that the federal Pell Grant Program for 

low-income college students was a major source of financial support for 

these students, but that it does not cover the full cost of college 

attendance for many students, and particularly for those at 4-year 

colleges or in areas with high costs of living.50 Most low-income students 

also work while attending college.51 Despite this, several college officials 

 49Most states also have need- and merit-based student aid programs. 

50For 2018-2019, the maximum annual federal Pell Grant award is $6,095. 

51According to 2015-2016 NPSAS data, 60 percent of low-income students had a job while 

enrolled in college. 

While SNAP Can 

Supplement Other 

Federal Aid for Some 

Low-Income 

Students, FNS Does 

Not Share Key 

Information to Help 

States Better 

Leverage SNAP to 

Assist Students

Federal Programs Are 

Limited in the Extent to 

Which They Can Address 

the Needs of College 

Students Experiencing 

Food Insecurity

Federal Student Aid Generally 

Does Not Cover All College 

Costs for Low-Income 

Students
Page 29 GAO-19-95 College Student Food Insecurity

we interviewed told us that the gap between the amount of financial aid 

available and what it costs to attend college is continuing to grow. One 

financial aid director told us that students used to be able to pay for 

groceries or rent with some of their financial aid “refund” money (that is, 

financial aid funds refunded to a student after tuition, fees, and other 

school charges are paid, which can be used to pay for other education 

and living expenses); however, he said students rarely receive a refund 

any more. According to data from Education’s National Center for 

Education Statistics, the average Pell Grant used to cover more of the 

cost of college than it does today. For example, about 40 years ago—

soon after the Pell Grant Program was established—the average award 

covered about 50 percent of the average cost of in-state tuition, fees, 

room, and board at public 2-year colleges, and 39 percent at public 4-

year colleges. Today, the average Pell Grant award amount covers just 

37 percent of these costs at public 2-year colleges, and 19 percent at 

public 4-year colleges.52 Federal Work-Study Program employment 

opportunities may be available to qualifying students, but several officials 

we interviewed noted that funding for this program is extremely limited, 

especially at community colleges where there are more students at risk of 

food insecurity.53

When grant funds and student earnings are insufficient to cover the full 

cost of college, students can take out federal student loans to make up 

the difference. Officials at a national association of community colleges 

and at a few colleges we visited told us that low-income students often 

use federal loans to help them pay for basic living expenses—such as 

food or rent. While these loans can be helpful for some students who 

need additional funds to support themselves while in college, officials at a 

few community colleges also cautioned that loans may not be the best 

choice for all students, and may worsen the financial position of already 

vulnerable students. For example, at one 4-year college we visited, the 

financial aid director said that many of their students have reached their 

 52These figures are based on data from the U.S. Department of Education, National 

Center for Education Statistics and Federal Pell Grant Program End of Year reports. See 

National Center for Education Statistics, Digest of Education Statistics, Table 330.10 and 

Pell Grant End of Year reports at https://www2.ed.gov/finaid/prof/resources/data/pelldata.html.

53The Federal Work-Study Program allows students to earn up to their awarded amount 

by working at an on-campus job or certain off-campus jobs. Students who participate in 

the Federal Work-Study Program would meet one of the student SNAP exemptions. A few 

officials told us that because funds for each campus are limited and awarded to students 

on a first come, first served basis, many students are unable to participate.
Page 30 GAO-19-95 College Student Food Insecurity

maximum federal lifetime loan limit (see text box for an example).54 He 

also noted that graduates have, on average, $25,000 of student loan 

debt. He said his college has historically trained its students for public 

sector careers, e.g., teachers or counselors, and he worries that salaries 

in these professions will not allow graduates to repay this amount of 

student loans.55

Given the limitations of federal student aid funding, officials from several 

organizations we interviewed spoke about the importance of leveraging 

other federal benefits, such as food assistance programs, to help address 

the needs of college students experiencing food insecurity. According to 

research on the effect of SNAP benefits, these benefits can provide some 

help to students, although they may not completely eliminate their food 

insecurity.56 However, college students have limited access to several key 

federal food assistance programs that could help address some of their 

needs. For example, several college officials we spoke with noted that 

many low-income students received federally subsidized free or reduced 

price lunch while in elementary and secondary school, but a comparable 

program does not exist for college students, even though many face the 

same level of need. In addition, many college students are prohibited 

from receiving federal SNAP benefits because of restrictions on student 

eligibility. Several college officials told us that when students are unable 

to meet one of the student exemptions for SNAP benefits, they will try to 

 54In 2018, the aggregate lifetime Federal Direct Loan limit for dependent undergraduate 

students was $31,000. For independent undergraduate students, it was $57,500.

55Graduates who enter public service careers full time with qualifying employers are 

eligible for forgiveness for part of their federal student loan debt after meeting certain other 

requirements. GAO found that many borrowers are confused about this program and we 

recommended that Education do more to ensure students understand which employers 

qualify for the program. See GAO, Public Service Loan Forgiveness: Education Needs to 

Provide Better Information for the Loan Servicer and Borrowers, GAO-18-547 

(Washington, D.C.: Sept. 5, 2018).

56See, for example, Mabli, Ohls, Dragoset, Castner, and Santos, Measuring the Effect.

College Students Have Limited 

Access to Federal Food 

Assistance Programs
Page 31 GAO-19-95 College Student Food Insecurity

connect them to community resources or to the on-campus food pantry, 

but a few characterized these as short-term solutions to their students’

problems. We also heard from officials at several colleges that students 

who are pregnant or postpartum may qualify for the WIC program, which 

provides food assistance to mothers with infants and young children; 

however, this program serves only a small minority of college students 

who may be experiencing food insecurity.

About one-third of state SNAP agencies reported they were taking actions 

to inform college students about SNAP and help them access SNAP 

benefits.57 These state SNAP agencies reported assisting college 

students in various ways, including by developing guidance or training for 

state and college officials on student eligibility rules, by conducting 

outreach at local colleges, or by providing students with options to qualify 

for a SNAP student exemption by participating in employment and 

training services.

Eleven state SNAP agencies reported clarifying policy on college student 

eligibility to SNAP staff who determine eligibility for benefits or providing 

training to third-party partners to increase awareness of students’

potential eligibility for SNAP. For example, in 2015 and 2017 California’s 

state SNAP agency issued policy letters to its county offices clarifying 

college student eligibility rules and expanding the list of college programs 

that qualify a student for an exemption under the employment and training 

provision.58 Minnesota’s state SNAP agency reported that it conducts 

technical assistance training on student eligibility issues for its 

caseworkers twice a year.

 57We emailed the SNAP directors of all 50 states and the District of Columbia to ask what, 

if any, actions their state agency was taking to address college student food insecurity. 

Fifty of the 51 state SNAP agencies responded to our email for a 98 percent response 

rate. About a quarter of states that responded to our email indicated that they had 

implemented a state option related to averaging student work hours on a monthly basis 

instead of requiring 20 hours per week to qualify for a student exemption. For the 

purposes of our analysis, we did not include this as a state action because it is an 

approach to implementing an existing student exemption. This email inquiry was 

conducted in March and April 2018 and may not include all state actions that have 

occurred since April 2018.

58In California and in nine other states, counties separately administer the SNAP program 

on behalf of the state SNAP agency. 

Some State SNAP 

Agencies Are Assisting 

Potentially Eligible 

Students to Access SNAP 

Benefits

Several States Are Clarifying 

Student Rules and Conducting 

Training and Outreach about 

SNAP Student Eligibility
Page 32 GAO-19-95 College Student Food Insecurity

State SNAP agencies also reported partnering with colleges to increase 

awareness of potential student SNAP eligibility or to reduce the burden of 

the application process for students. For example, Missouri’s state SNAP 

agency reported that it recently began a partnership with the state’s 

community college association to increase students’ awareness of their 

potential eligibility for SNAP. To reduce the burden students face in 

applying for SNAP benefits, Rhode Island’s state SNAP agency reported 

that its outreach partner holds regular “office hours” at state community 

college campuses to answer questions about SNAP, screen students for 

potential eligibility, and assist with application completion. Officials from 

California’s state SNAP agency stated that its county SNAP agencies 

periodically hold SNAP enrollment clinics on college campuses. At one 

time, a community college in California had a county SNAP staff member 

located on campus to assist their students with benefit applications.

Finally, two of the states we visited partially fund their state higher 

education grants for low-income college students with some of their 

federal TANF block grant dollars.59 Because these grant recipients 

receive TANF benefits, they are eligible for the corresponding SNAP 

student exemption. For example, the California state SNAP agency 

issued guidance in February 2017 to all of its county offices to explain 

that this SNAP student exemption applies to any student who receives 

the state’s higher-education grant for low-income students.60 In 

Massachusetts, the state SNAP agency issued similar guidance in August 

2017 to state SNAP staff who determine eligibility for benefits.61

 59States may use federal TANF block grant funds on a wide range of benefits and 

services, including to support work, education, and training programs. 

60California Health and Human Services Agency, Department of Social Services, CalFresh 

Student Eligibility, All County Letter No. 17-05 (Sacramento: February 2017).

61Massachusetts Executive Office of Health and Human Services, Department of 

Transitional Assistance, SNAP – Student Eligibility Updates, Online Guide Transmittal 

2017-52 (Boston: August 2017).
Page 33 GAO-19-95 College Student Food Insecurity

Some state SNAP agencies are taking steps related to the exemption for 

students who are enrolled in certain employment and training programs, 

which can be offered at 2-year colleges and other community-based 

organizations.

62 Seven states reported taking steps to designate specific 

programs at their community colleges to qualify as employment and 

training programs to make it easier for students and SNAP staff who 

determine eligibility for benefits to identify students who could meet this 

exemption. In these states, according to the SNAP agency, they have 

determined that certain programs at community colleges qualify enrolled 

students for one of the student SNAP exemptions because they are 

programs for low-income households, aimed at employment, and run by a 

state or local government.63

According to FNS, state SNAP agencies have the authority to decide 

which programs would qualify enrolled students for this exemption, and 

several states have identified qualifying programs at community colleges 

in their state.64 Students in these designated community college programs 

who attend at least half time and do not meet one of the other student 

exemptions can be eligible for SNAP under this provision if they meet all 

other eligibility criteria. In 2010, Massachusetts’ state SNAP agency 

began using a dedicated form that provides community college students 

in these state-designated employment and training programs support for 

their SNAP application. According to officials at the state SNAP agency, 

this form has helped to streamline the application process for both 

students and state SNAP agency staff who determine eligibility for 

benefits.

Other states are developing opportunities for students to meet the 

employment and training exemption through partnerships with the states’

SNAP Employment & Training (E&T) programs. Twenty-four state SNAP 

 62Many of the student SNAP exemptions are relatively easy for a state SNAP staff 

member who determines eligibility for benefits to verify, for example, being a single parent 

of a child under age 12 or participating in the Federal Work-Study Program. One student 

exemption—related to participation in employment and training programs—is less 

straightforward because states must review the components of each program and 

independently determine if it qualifies as such a program under FNS rules. FNS officials 

told us state SNAP agencies are not required to report information on how many states 

take these approaches or how many students qualify for SNAP through the employment 

and training student exemption. 

63See 7 U.S.C. § 2015(e)(3)(D); see also 7 C.F.R. § 273.5(b)(11)(iv). 

64These programs must meet the requirements detailed at 7 C.F.R. § 273.5(b)(11)(iv).

Some States Are Implementing 

Approaches that Provide 

Additional Employment and 

Training Options for Certain 

Students
Page 34 GAO-19-95 College Student Food Insecurity

agencies reported that they have implemented a third-party partnership 

with at least one community college to deliver SNAP E&T program 

services on campus.65 Under these state SNAP E&T program 

partnerships, the state SNAP agency works with community colleges to 

enroll SNAP recipients in programs that are designed to increase the 

employability of the participant. One FNS official told us that state SNAP 

E&T programs were an ideal way to provide college students who qualify 

for SNAP benefits with additional services and support, such as 

counseling or transportation assistance, and that they can help students 

persist in their community college program and ultimately improve their 

self-sufficiency.66

According to FNS, state agencies can enroll individuals in these SNAP 

E&T programs in one of two ways. A SNAP recipient may enroll in the 

designated community college training program affiliated with the state’s 

SNAP E&T program, which allows them to continue receiving SNAP 

benefits even if they attend the program more than half time. Or, the 

community college partner can refer individuals already enrolled at the 

college to the state SNAP agency to determine if they are eligible for state 

SNAP E&T program services—a process known as a “reverse referral.” In 

the case of a reverse referral, individuals who are enrolled in certain 

training programs and who are experiencing food insecurity may be able 

to qualify for a student exemption to receive SNAP, as well as additional 

services through state SNAP E&T programs.67 According to Washington’s 

state SNAP agency, SNAP E&T programs operate at all 34 community 

colleges in the state, and have served approximately 20,000 students 

each fiscal year since 2015. A senior program official at Washington’s 

state SNAP agency told us that the vast majority of incoming community 

college students in Washington are screened for potential eligibility and 

reverse referral into the state’s SNAP E&T program services.

 65FNS-reported data as of fiscal year 2018. SNAP E&T programs can also partner with 

other community-based organizations to deliver services. 

66According to FNS, state SNAP E&T programs are a secondary payer for students who 

are enrolled in college programs. For example, if a student is determined to be eligible for 

a Pell Grant or other federal financial aid, these funds must be used first to pay for tuition. 

Once other funding sources have been exhausted, state SNAP E&T program funds may 

be used for any outstanding tuition and fees.

67Students who are referred to state SNAP E&T programs and qualify for a student SNAP 

exemption must meet other financial and non-financial eligibility criteria to receive benefits.
Page 35 GAO-19-95 College Student Food Insecurity

At 9 of the 14 colleges we contacted, some officials and students we 

spoke with indicated that they either did not know about or found it difficult 

to understand the SNAP student rules. For example, in a student 

discussion group at one community college, some students said they 

were uncertain about how SNAP student rules applied to them when they 

lived with their parents but received no financial support or food from 

them. Officials at another college told us that many students are not even 

aware of or do not realize that the SNAP student rules apply to them. In a 

student discussion group we held at another college, some students told 

us that they had been unaware that they may be eligible for SNAP until 

they spoke to someone at their college. Further, we found college officials 

may also have difficulty understanding SNAP student rules—for example, 

officials at one college said that they believed that college students are 

not eligible for SNAP. College officials can be an important source of 

information for students regarding SNAP, but this can create barriers to 

access if college officials do not have the correct information. For 

example, at one college we visited, two students said they were 

misinformed by officials at their college or their state SNAP agency about 

their potential eligibility for SNAP.

Officials we met with at three colleges said that they would like 

information from FNS about college student eligibility rules so they can 

help educate and enroll students in SNAP, but FNS has not developed 

such targeted information to distribute to colleges and students. Officials 

at one college said they requested information from FNS to distribute to 

students, but the general SNAP eligibility brochure FNS provided did not 

reference college student eligibility requirements.68 A senior FNS official 

said developing printed materials expressly explaining the college student 

eligibility requirements is primarily a state agency responsibility, and that 

information about this topic was available on the FNS website. However, 

we found that the information specifically related to college student 

eligibility requirements on the FNS website was not easy to find. For 

example, the main webpage of FNS’s SNAP eligibility website lists the 

special circumstances under which certain specific populations may be 

SNAP eligible, but it does not include college students nor does it link to 

 68Officials at two FNS regional offices told us they were aware of a few colleges in their 

regions that had developed SNAP materials to distribute to students, but these materials 

were locally developed and disseminated only at certain colleges.

College and State Officials 

Reported That FNS Does 

Not Share Key Information 

That Could Help Them 

Assist Students 

Experiencing Food 

Insecurity
Page 36 GAO-19-95 College Student Food Insecurity

the webpage listing the student exemptions.69 Further, the webpage 

containing information on SNAP for college students restates the list of 

student exemptions from the regulations, using legal and technical 

language that is not always easy to understand. For example, the 

webpage states that students “may be able to get SNAP benefits if 

otherwise eligible, and they ‘get public assistance benefits under a Title 

IV-A program of the Social Security Act.’” Many college officials and 

students may not realize this refers to TANF benefits. In addition, the 

website does not list being “not physically or mentally fit” (e.g., having a 

disability) as one of the ways to qualify for a student exemption, nor does 

it provide information relevant to how students may qualify for an 

exemption because they are assigned to or placed in certain employment 

and training programs.

A senior official from the FNS national office said that college student 

eligibility and the student exemptions were among the most complicated 

SNAP policies to explain and that they frequently receive questions from 

the general public about how the rules apply to certain students in certain 

situations. This official said that because the student SNAP rules are so 

difficult to navigate, FNS responds to these individual questions and 

circumstances as they arise, rather than developing materials that could 

apply broadly to every situation, and that state SNAP agencies are 

primarily responsible for assisting students. Officials at all four FNS 

regional offices we spoke with said materials explaining the student rules 

tailored to colleges and college students would prove useful to states and 

colleges in their regions. While developing clear written materials about a 

complicated policy is challenging, Standards for Internal Control in the 

Federal Government states that agencies should communicate key 

information to their internal and external stakeholders.70 Further, a core 

activity of the SNAP program is to work with its partners to ensure that 

those eligible for nutrition assistance can make informed decisions about 

applying for the program.71 The lack of clear and easily accessible 

 69According to federally developed web usability guidelines, important information should 

be available within two or three clicks of the homepage. We found the SNAP for Students 

webpage was not linked to the SNAP Eligibility webpage, and only found the SNAP for 

Students webpage by conducting a keyword search on the FNS website. See Department 

of Health and Human Services, The Research-based Web Design and Usability 

Guidelines, Enlarged/Expanded Edition, (Washington, D.C.: August 2006). 

70GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014).

71The SNAP program’s other core activity is to improve program administration and 

ensure program integrity. 
Page 37 GAO-19-95 College Student Food Insecurity

information on student SNAP eligibility requirements can make it difficult 

for potentially eligible students to make informed choices about applying 

for SNAP, and for colleges to develop their own materials to help 

potentially eligible students apply for SNAP. As a result, students could 

miss opportunities to obtain the additional support they may need to stay 

in college and graduate.

In addition, we found that some state SNAP agencies had limited 

information about approaches that they could take to help potentially 

eligible college students who may qualify for a student exemption. 

Specifically, officials at four of the five state SNAP agencies and at three 

of the four FNS regional offices that we spoke with said that it is not 

entirely clear to them under which circumstances college students may be 

eligible for a student exemption if they are enrolled in a qualifying 

employment and training program run by a community college. State 

SNAP agency officials in four of the five states, as well as officials in three 

of the four FNS regional offices, told us that they would like more 

information from FNS about how to implement the approach some state 

SNAP agencies are taking to help college students who may qualify for 

an employment and training exemption access SNAP. One state SNAP 

agency official said that she believes that the lack of guidance and 

leadership from FNS on this issue leaves many state SNAP agencies 

operating with uncertainty, and, as a result, many of them do not take any 

actions to identify those college students who may qualify for an 

employment and training exemption under SNAP rules.

Several of the FNS regional office officials we interviewed agreed that the 

FNS national office was uniquely positioned to collect and share

information about potential approaches that states are using to implement 

the student exemption for employment and training programs so that 

other states could also consider using such approaches to assist lowincome college students who may qualify. Officials at one FNS regional 

office said that an FAQ-type document on college student eligibility 

scenarios would be helpful. At the same time, a few FNS regional office 

officials said that the national office is cautious about developing 

information for all states when each state’s SNAP program operates 

slightly differently.72 According to FNS national office officials, FNS issued 

the most recent document discussing general SNAP eligibility for students 

 72As previously noted, state SNAP agencies have flexibility to adapt their programs to 

meet the needs of eligible, low‐income households in their states.
Page 38 GAO-19-95 College Student Food Insecurity

in August 2010. This document explained that certain employment and 

training services provided by a state or local government may qualify a 

student for a SNAP student exemption. In November 2016, six federal 

agencies including USDA (on behalf of FNS) released an interagency 

letter, Aligning Federal Supports and Program Delivery for College 

Access and Completion, that includes information from FNS related to 

general student eligibility for SNAP.73

However, neither of these documents included specific strategies or 

examples of approaches states have used or can use to help potentially 

eligible college students access SNAP benefits. Standards for Internal 

Control in the Federal Government states that agency management 

should internally communicate the necessary information to achieve the 

program’s objectives.74 In addition, part of the role of the FNS national 

office is to work with its partners, including its regional offices and the 

state SNAP agencies, to improve program administration and ensure 

access to benefits for eligible individuals. FNS officials told us FNS has 

several existing mechanisms for information sharing with the regional 

offices and the state SNAP agencies, including policy memos, webinars, 

and annual conferences. However, a senior FNS official told us that she 

was not aware of any plans to share additional information with state 

SNAP agencies or regional offices on this topic, noting that college 

students are a relatively small population compared to other SNAP 

recipients. As a result, state SNAP agencies may not be aware of 

approaches other states have used that they could take to assist college 

students experiencing food insecurity in accessing SNAP benefits, and 

FNS may not be fulfilling its role to ensure program access for college 

students who are eligible.

In addition to noting how complicated the college student SNAP eligibility 

rules are, most state higher education and SNAP policy organization 

officials we interviewed remarked that the student exemptions can make it 

challenging for many students who are food insecure to obtain SNAP 

benefits that could help them succeed in college. Specifically, a few 

researchers and state higher education officials said the eligibility 

restrictions were instituted when college students were generally from 

 73See Aligning Federal Supports and Program Delivery for College Access and 

Completion (Washington, D.C.: Nov. 15, 2016). According to an Education official, this 

interagency letter was the product of the federal College Access and Completion 

Interagency Working Group. 

74GAO-14-704G.
Page 39 GAO-19-95 College Student Food Insecurity

higher-income households, whereas many students enrolled in college 

today are from low-income households. Several higher education officials 

and one researcher noted that when a student qualifies for a student 

exemption by working 20 hours a week, it can have a detrimental impact 

on college completion. For example, research has shown that full-time 

college students who work more than 15 hours a week or who reduce 

their college course load and attend part time in order to increase their 

work hours are less likely to complete their degree or educational 

program.75

At the same time, FNS officials and officials at one state SNAP agency 

stressed the importance of having proper controls in place to prevent 

certain students from improperly receiving benefits. A senior FNS official 

noted that the college student restrictions were established to prohibit 

traditional college students who are supported by their parents from 

receiving SNAP benefits. This official said that the student eligibility rules 

should ensure that middle-class and wealthy students do not access 

SNAP while attending college. Further, officials at a few organizations 

and one state SNAP agency we interviewed expressed support for some 

of the student exemptions, such as the exemption for college students 

who work 20 hours per week.

76

The federal government invests billions of dollars annually in higher 

education through grants and loans to low-income students. Partially as a 

result of this investment, a college education is accessible to more lowincome Americans than ever before. Despite this federal support, many 

low-income college students struggle to meet their basic needs, including 

 75See, for example, Robert Bozick, “Making It Through the First Year of College: The Role 

of Students’ Economic Resources, Employment, and Living Arrangements,” Sociology of 

Education, vol. 8, no. 3 (2007); and Sarah Blanchard Kyte, Who Does Work Work For? 

Understanding Equity in Working Learner College and Career Success, (Iowa City, IA: 

ACT Center for Equity in Learning, July 2017). Officials at all state SNAP agencies, along 

with several college and state higher education policy officials, as well as a few students 

that we interviewed also noted that if college students were allowed to count unpaid 

internships or similar volunteer work in their field of study to qualify for the student 

exemption by working 20 hours per week, it could help support their academic and future 

career success.

76Many federal means-tested benefits programs require some low-income recipients to 

work in order to receive benefits. For more information, see our prior work on federal 

means-tested benefits programs, GAO, Federal Low-Income Programs: Eligibility and 

Benefits Differ for Selected Programs Due to Complex and Varied Rules, GAO-17-558 

(Washington, D.C.: June 29, 2017).

Conclusions
Page 40 GAO-19-95 College Student Food Insecurity

obtaining the food that they need, and may drop out of college as a result. 

SNAP can be an important source of support for low-income students, 

although it may not completely ameliorate food insecurity. However, 

because the SNAP eligibility requirements for college students can be 

difficult for students and colleges to understand, students may be 

unaware of or misinformed about their potential eligibility for SNAP. FNS 

has not made information that clearly explains student SNAP eligibility 

requirements easily accessible to students and college officials and, as a 

result, students experiencing food insecurity may remain unaware that 

they could be eligible for SNAP.

In addition, some states are exercising existing state flexibilities to help 

students experiencing food insecurity to access SNAP, but FNS does not 

actively share this information among state SNAP agencies. By collecting 

and sharing information on approaches taken by state SNAP agencies 

active in this area, FNS could potentially help state SNAP agencies 

identify ways to help eligible students who are experiencing food 

insecurity. Better supporting these students will also help the Department 

of Agriculture and the Department of Education meet their respective 

goals and make good use of the substantial federal investment in higher 

education while improving the health and nutrition of individuals 

experiencing food insecurity.

We are making the following two recommendations to FNS:

The Administrator of FNS should make information on their website 

regarding student SNAP eligibility requirements easier to understand and 

more accessible, as a resource for colleges and state SNAP agencies. 

(Recommendation 1) 

The Administrator of FNS should coordinate with its regional offices to 

collect and review information about existing SNAP flexibilities and 

examples of approaches state SNAP agencies are taking to assist eligible 

college students to access SNAP benefits, and share such information 

with state SNAP agencies. (Recommendation 2)

We provided a draft of this report to the Department of Agriculture and the 

Department of Education for review and comment. The Department of 

Education provided technical comments, which we incorporated into the 

report as appropriate. On November 28, 2018, and December 7, 2018, 

the Directors of the FNS SNAP Program Development Division and Office 

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
Page 41 GAO-19-95 College Student Food Insecurity

of Employment and Training met with us to provide the agency’s 

comments orally. At the December 7, 2018 meeting, FNS officials told us 

they partially concur with our recommendations and believe that FNS has 

sufficient guidance in place for states to provide further information to 

colleges. However, the agency agrees with the intent of GAO’s 

recommendations and plans to review its existing guidance to determine 

if any improvements are warranted. We continue to believe that additional 

action is necessary to address our recommendations. While reviewing its 

existing information would be helpful, we believe that changes to FNS’s

existing information are also needed to improve the clarity and 

accessibility of information about SNAP student eligibility requirements on 

FNS’s website, and that FNS needs to work with its regional offices to 

identify and share additional information about state approaches to assist 

eligible college students with access to SNAP benefits. In response to 

FNS officials’ comments, we also clarified both recommendations to focus 

more on actions that fall under the responsibility of the FNS National 

Office. FNS also provided technical comments, which we incorporated 

into the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

Secretaries of Agriculture, Education, appropriate congressional 

committees, and other interested parties. In addition, the report will be 

available at no charge on the GAO website at http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or larink@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix II.

Kathryn Larin

Director, Education, Workforce,

And Income Security
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-19-95 College Student Food Insecurity

This report examines (1) what is known about the extent of food insecurity 

among college students and their use of the Supplemental Nutrition 

Assistance Program (SNAP); (2) how selected colleges are addressing 

student food insecurity; and (3) the extent to which federal programs 

assist college students experiencing food insecurity. This appendix 

provides details of the data sources used to answer these questions, the 

analyses we conducted, and any limitations to our analysis.

Overview

We used multiple methodologies to conduct this review. We conducted a 

review of academic studies based on original research to determine what 

is known about food insecurity among college students. We assessed the 

quality of these studies by evaluating their research methods and 

determined that the studies we included in our review were sufficiently 

reliable for our use. To describe the prevalence of risk factors for food 

insecurity among college students, we used data on student 

characteristics from the nationally representative National Postsecondary 

Student Aid Study (NPSAS). We assessed the reliability of NPSAS data 

by reviewing existing information about the data and the system that 

produced them and by interviewing agency officials knowledgeable about 

the data. We determined that the data were sufficiently reliable for the 

purposes of describing the prevalence of risk factors for food insecurity 

among college students and students’ participation in SNAP.

To understand how selected colleges address student food insecurity, we 

conducted four state site visits (California, Kentucky, Massachusetts, and 

Michigan) selected based on whether colleges and/or state government 

agencies were taking steps to address food insecurity among students,

and geographic diversity, among other criteria. In each state, we visited 

public colleges and universities, where we met with college officials, 

students, and researchers. We also interviewed state higher education 

and SNAP officials, as well as experts from relevant policy organizations. 

To assess federal efforts, we identified federal programs that may assist 

college students in need of food, interviewed officials from Education and 

USDA, and reviewed relevant federal laws, regulations, and agency 

guidance and program documents, as well as federal internal controls 

standards applicable to these programs.

Review of Studies

To understand what is currently known about the extent of food insecurity 

among college students, we conducted an in-depth review of studies. Our 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-19-95 College Student Food Insecurity

preliminary search in Scopus identified a recent systematic literature 

review on food insecurity on college campuses.1 Upon reviewing the 

article’s scope and methodology, we chose to update rather than 

duplicate their efforts. We expanded the original search terms to include 

“higher education” and “postsecondary” among others, and searched two 

additional research databases (ProQuest and Scopus) in addition to the 

original list of sources (MEDLINE, PSYCHINFO, and Web of Science). 

We identified peer-reviewed journal articles and other published research 

through this search. Through news reports on food insecurity and 

interviews with researchers, we also identified studies published up to 

August 31, 2018 that may not have been included in our initial review. We 

included studies in our review if they met the following criteria: (1) were 

based on research conducted and published in the United States; (2) 

were published since 2007; and (3) contained original, direct estimates of 

food insecurity rates among college students.

We identified a total of 35 studies that met these criteria and conducted 

an initial review to determine if the studies met generally accepted social 

science standards and were appropriate for our purpose to provide 

information on the prevalence of food insecurity among college students. 

We eliminated some studies if we determined that the methods were not 

appropriate or rigorous—specifically, we concluded that we could not 

report the results of four studies due to research design limitations. For 

instance, some studies did not fully disclose their methods, had small 

sample sizes, used data based on low survey response rates, or did not 

attempt to correct for or address potential biases in their methodology. 

For studies included in this report, we performed an initial in-depth review 

of the findings and methods, and a GAO methodologist performed a 

second review to confirm our reported analysis of the findings. As a 

result, we determined 31 studies to be of sufficient quality and we 

summarized the findings of these 31 studies in our report (see table 3).

 1

Meg Bruening, Katy Argo, Devon Payne-Sturges, and Melissa N. Laska, “The Struggle is 

Real: A Systematic Review of Food Insecurity on Postsecondary Education Campuses,” 

Journal of the Academy of Nutrition and Dietetics, vol. 117, no. 11 (2017).
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-19-95 College Student Food Insecurity

Table 3: Studies Included in GAO’s Review That Estimate College Student Food Insecurity

Title Authors

Year of 

publication

1 Food Insecurity Prevalence among College Students at the 

University of Hawai’i at Mānoa

Chaparro , M. Pia, Sahar S. Zaghloul , 

Peter Holck, Joannie Dobbs

2009

2 Examining the Role of Financial Factors, Resources and Skills in 

Predicting Food Security Status among College Students

Gains, Alisha, Clifford A. Robb, Linda L 

Knol, Stephanie Sickler 

2014

3 Prevalence and Correlates of Food Insecurity among Students 

Attending a Midsize Rural University in Oregon

Patton-Lopez , Megan M., Daniel F. 

Lopez-Cevallos, Doris I. Cancel-Tirado, 

Leticia Vazquez 

2014

4 Hungry to Learn: Addressing Food and Housing Insecurity Among 

Undergraduates.

Goldrick-Rab, Sara, Katharine Broton, 

Daniel Eisenberg

2015

5 Food Insecurity Among Community College Students: Prevalence 

and Association With Grade Point Average

Maroto, Maya E., Anastasia Snelling, 

Henry Linck

2015

6 The Relationship Between Food Security, Housing Stability, and 

School Performance Among College Students in an Urban 

University

Silva, Meghan R., Whitney L. Kleinert, 

A. Victoria Sheppard, Kathryn A. 

Cantrell, Darren J. Freeman-Coppadge, 

Elena Tsoy, Tangela Roberts, and 

Melissa Pearrow

2015

7 Factors Related to the High Rates of Food Insecurity among 

Diverse, Urban College Freshmen

Bruening, Meg, Stephanie Brennhofer, 

Irene van Woerden, Michael Todd, 

Melissa Laska

2016

8 Prevalence of Food Insecurity Among College Students at 

Southeast Missouri State University

Hillmer, Amelia 2016

9 Predictors of College-Student Food Security and Fruit and 

Vegetable Intake Differ by Housing Type

Mirabitur, Erica, Karen E. Peterson, 

Colleen Rathz, Stacey Matlen , Nicole 

Kasper

2016

10 The Prevalence of Food Security and Insecurity Among Illinois 

University Students

Morris, Loran Mary, Sylvia Smith, 

Jeremy Davis, Dawn Bloyd Null 

2016

11 A Household-Based Food Security Survey of Western New York 

College Students to Determine Its Prevalence

Bentley, Bradley J. 2017

12 Assessing Food Insecurity on Campus Blagg, Kristin, Diane Whitmore 

Schanzenbach, Craig Gundersen, 

James P. Ziliak

2017

13 The Evolution of Poverty in Higher Education:

Material Hardship, Academic Success, and Policy Perspectives

Broton, Katharine M. 2017

14 The Relationship Between Food Insecurity and Academic 

Performance Among San Jose State University Students

Dudley, Bethany 2017

15 Hungry and Homeless in College: Results from a National Study of 

Basic Needs Insecurity in Higher Education

Goldrick-Rab, Sara, Jed Richardson, 

Anthony Hernandez

2017

16 Fostering Success: Understanding the Experience of Foster Youth 

Undergraduates

Kinarsky, Alana. R. 2017

17 Food Insecurity Among College Students: Exploring the Predictors 

of Food Assistance Resource Use

King, Jennifer A. 2017
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-19-95 College Student Food Insecurity

Title Authors

Year of 

publication

18 Food Insecurity, Self-rated Health, and Obesity among College 

Students

Knol, Linda L., Cliff A., Robb, Erin 

M.McKinley, Mary Wood

2017

19 Food Insecurity in California’s Public University System: What are 

the risk factors?

Martinez, Suzanna M., Karen Webb, 

Edward A. Frongillo, Lorrene D. Ritchie

2017

20 A High Prevalence of Food Insecurity Among University Students 

in Appalachia Reflects a Need for Educational Interventions and 

Policy Advocacy.

McArthur, Laura Helena, Lanae Ball, 

Ariel C. Danek, Donald Holbert

2017

21 Prevalence and Predictors of Social Work Student 

Food Insecurity

Miles, Rhen, Bowen McBeath, 

Stephanie Brockett, Paul Sorenson

2017

22 Student Hunger on Campus: Food Insecurity Among College 

Students and Implications for Academic Institutions

Payne-Sturges, Devon C., Allison 

Tjaden, Kimberly M, Caldeira, ,Kathryn 

B. Vincent, Amelia M. Arria

2017

23 Hungry to Learn: the Prevalence and Effects of food Insecurity on 

Health Behaviors and Outcomes over Time among a Diverse 

Sample of University Freshmen 

Bruening, Meg, Irene van Woerden, 

Michael Todd, and Melissa N. Laska.

2018

24 Study of Student Basic Needs Crutchfield, Rashida, Jennifer Maguire 2018

25 Why are Hungry College Students Not Seeking Help? Predictors 

of and Barriers to using an on-Campus Food Pantry.

El Zein, Aseel, Anne E. Mathews, Lisa 

House, and Karla P. Shelnutt.

2018

26 Food Insecurity and Hunger: Quiet Public Health Problems on 

Campus

Forman, Michele R., Lauren D Mangini, 

Yong-Quan Dong, Ladia M Hernandez, 

Karen L Fingerman

2018

27 Still Hungry and Homeless in College Goldrick-Rab, Sara, Jed Richardson, 

Joel Schneider, 

Anthony Hernandez Clare Cady

2018

28 Food Insecurity and Behavioral Characteristics for Academic 

Success in Young Adults Attending an Appalachian University

Hagedorn, Rebecca L., and Melissa D. 

Olfert

2018

29 Food Insecurity and Academic Disruption among 

College Students. 

Phillips, Erica, Anne McDaniel, and 

Alicia Croft.

2018

30 Relationship between Diet and Mental Health in a Young Adult 

Appalachian College Population. 

Wattick, Rachel A., Rebecca L. 

Hagedorn, and Melissa D. Olfert.

2018

31 Experiences With “Acute” Food Insecurity Among

College Students

Wood, J.Luke, Frank Harris III 2018

Source: Studies GAO reviewed. | GAO-19-95

Note: We selected studies for inclusion based on the following criteria: (1) based on research 

conducted and published in the United States; (2) published after 2007; and (3) contains original, 

direct estimates of food insecurity rates among college students. While we determined that these 31 

studies were appropriate for our purpose to provide some information regarding food insecurity 

among college students, all of the studies have methodological limitations and none provide 

estimates of food insecurity for the college student population in general.

While these 31 studies are of sufficient quality to provide information on 

what is known about food insecurity among college students, the 

generalizability of their findings require significant caveats. Most of the 

survey results in these studies are not generalizable to a population larger 

than their sample size, meaning that the findings apply only to the 
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-19-95 College Student Food Insecurity

respondents of the survey. None of the studies in our review conducted 

non-response bias analyses or attempted to address potential selection 

bias in the sample. Despite these limitations, the studies collectively offer 

assessments of food insecurity conducted on over 200 campuses in more 

than 30 states, at both 2- and 4-year schools, and all but three of the 

studies used adapted versions of the USDA food insecurity measure.

NPSAS Data Analysis

We analyzed data from the Department of Education’s (Education) 

National Postsecondary Student Aid Study (NPSAS). Because no federal 

datasets contain food insecurity data specifically about college students, 

we chose to analyze NPSAS data for the prevalence of risk factors 

associated with food insecurity.2 Additionally, we used some summary 

statistics from frequencies presented in the 2016 NPSAS data codebook.

NPSAS data contain nationally representative, detailed demographic and 

financial aid data for college students enrolled in less than 2-year, 2-year, 

4-year, and graduate postsecondary programs. These data come from 

institutional records, government databases, and interviews with students. 

Because the NPSAS data are based on probability samples, estimates 

are calculated using the appropriate sample weights provided which 

reflect the sample design. Each of these samples follows a probability 

procedure based on random selection, and they represent only one of a 

large number of samples that could have been drawn. Since each sample 

could have provided different estimates, we express our confidence in the 

precision of our particular sample’s results as a 95 percent confidence 

interval. This is the interval that would contain the actual population value 

for 95 percent of the samples we could have drawn. Unless otherwise 

noted, all percentage estimates from the NPSAS data analysis have 95 

percent confidence intervals within plus or minus 5 percentage points of 

the percent estimate, and other numerical estimates have confidence 

intervals within plus or minus 5 percent of the estimate itself. We 

compared 95 percent confidence intervals to identify statistically 

significant differences between specific estimates and the comparison 

groups. The information provided in the NPSAS data, particularly those 

 2

Federal data sets that collect data on food insecurity measure food insecurity at a 

household level, which is limited for estimating food insecurity among college students. 

Likewise, no federal education datasets currently contain food insecurity data for individual 

students. Department of Education officials told us they are planning to include a series of 

questions measuring student food insecurity in the next NPSAS data collection in 2020.
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-19-95 College Student Food Insecurity

from the interview portion of the study, are self-reported and not all of the 

data are based on federal determinations or cross-verified with outside

sources. For example, students self-report their disability status, their 

hours worked, and so on. Such self-reported data are subject to several 

sources of nonsampling error, including the inability to obtain information 

about all sample cases; difficulties of definition; differences in the 

interpretation of questions; respondents’ inability or unwillingness to 

provide correct information; and errors made in collecting, recording, 

coding, and processing data. These nonsampling errors can influence the 

accuracy of information presented in the report, although the magnitude 

of their effect is not known.

Identification of Risk Factors for Food Insecurity

In order to identify risk factors associated with food insecurity among 

college students, we reviewed published articles and reports on the topic 

of food insecurity and interviewed researchers, college and state officials, 

and officials at relevant policy organizations. We present the list of risk 

factors for food insecurity we considered in table 4. Not all of the risk 

factors we identified have a corresponding NPSAS variable. For example, 

NPSAS does not ask respondents about unmet medical needs or 

childhood food insecurity. Additionally some of the risk factors overlapped 

and were thus not included in our analysis. For example, the NPSAS 

dataset contains multiple variables pertaining to student and student 

household income, such as household income, financial aid, and receipt 

of public benefits. Many indicators of low-income status likely overlap 

(e.g., being eligible for a Pell Grant and receiving other financial aid), and 

many students who have one indicator will likely have others.
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-19-95 College Student Food Insecurity

Table 4: Risk Factors Identified by GAO Associated with Food Insecurity Among College Students

Risk factor selected for GAO analysis Description

Disability Several studies and an expert in one interview mentioned having a disability as a 

correlate for food insecurity; also it is one of the exemptions for Supplemental Nutrition 

Assistance Program (SNAP) eligibility. Disability is a stressor that may partially overlap 

with the low-income variable, but adds a unique dimension of risk for food insecurity. 

First-generation student Mentioned in several studies as a correlate of food insecurity; may partially overlap with 

the low-income variable. 

Former foster youth Former foster youth are more likely to be low income, housing insecure, and food 

insecure than other types of students. 

Homelessness/housing insecurity Several studies mention homelessness/housing insecurity as a strong correlate of food 

insecurity. Particularly in high-cost areas, this may be an indicator of food insecurity risk 

even among students who are not technically low income. 

Low income Multiple studies and experts in multiple interviews mention that having a low income is 

associated with an increased risk of food insecurity.

Single parent status Single parent status likely overlaps with low-income status to some degree; it is also 

indicative of a unique stressor that may increase food insecurity risk (it is also one of the 

student exemptions for SNAP eligibility).

Receiving SNAP Receipt of SNAP benefits is positively associated with food insecurity. While receiving 

SNAP mitigates food insecurity, SNAP recipients still have higher food insecurity rates 

than the general population. 

Risk factors considered but not 

included in analysis

Reason excluded

(Lack) of access to credit card No corresponding National Postsecondary Student Aid Study (NPSAS) variable.

Age or year in school Some studies identify different years in school or different age groups as having different 

risks for food insecurity, but which year is at higher risk varies from study to study. 

Exogenous shock (e.g., death of family 

member, income loss, natural disaster, 

etc.)

No corresponding NPSAS variable.

Familial financial support/expected family 

contribution

Experts mentioned lack of family financial support as a strong correlate of food insecurity 

and a proxy for financial need. It is also indicative of the level of support a student’s family 

can provide to assist a student experiencing food insecurity. However, this factor is likely 

highly correlated with low-income status.

Food prep skills/other skills No corresponding NPSAS variable

Household receipt of Free and Reduced 

Price Lunch in High School

Research has found that household receipt of Free or Reduced Price Lunch is positively 

associated with food insecurity. However, this variable broadly overlaps with low-income 

status. 

Living arrangements, such as on- or offcampus housing and whether food 

provision is included in on-campus 

housing

This factor may be correlated with food insecurity and is potentially related to 

homelessness/housing insecurity; however, homelessness is a stronger 

correlate/indicator of food insecurity risk. 

Hours worked per week Two studies found that the number of hours worked per week is positively correlated with 

food insecurity. However, working a greater number of hours while in college is likely 

correlated with having a low-income. 
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-19-95 College Student Food Insecurity

Risk factors considered but not 

included in analysis

Reason excluded

Independent student status Independent student status may be a proxy for having a low income or lacking family 

resources. Other variables may more directly indicate low-income status. 

Loan use May be a proxy for having a low income, but is also very broad as many non-low-income 

students also take out student loans. 

Race/Ethnicity Several studies have found that non-whites and certain ethnicities have higher risk of food 

insecurity. Race is generally considered a marker of other underlying risk factors more 

strongly associated with food insecurity, including being low-income. Because of this, we 

did not include race as a risk factor in our analysis. 

Receipt of or eligibility for Pell Grants or

financial aid broadly speaking

Several studies have found that unmet financial need and Pell Grant receipt are both 

indicators of overall need and are positively associated with food insecurity. The federal 

government determines Pell Grant eligibility based on income as reported on the Free 

Application for Federal Student Aid (FAFSA). However, this risk factor largely overlaps 

with having a low income.

Sex/Gender The research results are unclear on the relationship between gender and food insecurity. 

Type of institution attended (2-year vs. 4-

year, for profit, etc.).

Several studies have found that community and vocational and technical college students 

have higher food insecurity rates than students at 4-year colleges. We report the results 

of our analysis by college type, but do not consider college type a risk factor itself. 

Undocumented/international students No corresponding NPSAS variable for undocumented students, and few variables 

available for documented international students.

Unmet medical needs No corresponding NPSAS variable.

Source: GAO analysis. | GAO-19-95

Notes: GAO compiled this list of risk factors associated with food insecurity among college students 

based on whether the risk factor was mentioned in research or mentioned during interviews with 

researchers, college officials, state and federal officials, and relevant policy organizations.

Although this is not an exhaustive list of risk factors, individuals who 

experience one of the following seven characteristics may be at risk of 

food insecurity: being disabled, homeless or housing insecure, being a 

former foster youth, receiving SNAP benefits, being a single parent, and 

being the first-generation in a student’s family to attend college.3 Table 5 

shows how we compared these risk factors with corresponding variables 

from the 2016 NPSAS data.

 3

Participation in SNAP is correlated with both having a low-income and with food 

insecurity; studies show SNAP recipients are more food insecure than the general 

population even though they receive SNAP benefits. This is partially because food 

insecure people choose to participate in SNAP and partially because receiving SNAP 

does not completely ameliorate food insecurity. According to research by USDA, 

participating in SNAP for 6 months was associated with a decrease in food insecurity of 

12.7 percentage points. See James Mabli, Jim Ohls, Lisa Dragoset, Laura Castner, and 

Betsy Santos, Measuring the Effect of Supplemental Nutrition Assistance Program 

(SNAP) Participation on Food Security, a report prepared by Mathematica Policy 

Research at the request of the U.S. Department of Agriculture, Food and Nutrition Service 

(Washington, D.C.: August 2013).
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-19-95 College Student Food Insecurity

Table 5. Selected Risk Factors and Corresponding Variables in the 2016 National Postsecondary Student Aid Study Data Set

Risk factor

NPSAS 

variable name Description

Disabilitya DISABIL2 Indicates student has some type of disability or condition. 

Homeless/housing 

insecure

HOMELESS2 Includes some students who were determined by a professional to be homeless (via the 

Free Application for Federal Student Aid or FAFSA), but predominantly measures studentdetermined “risk of homelessness.” This is not a direct measure of homelessness.

Former foster 

youth

ORPHAN2 Indicates student is an orphan, ward of court, emancipated minor, or in legal guardianship.

Receiving SNAPb FEDBENA Indicates whether any member of the student’s household received Food Stamp (SNAP) 

Benefits during the 2013 or 2014 calendar year. 

Single parent 

status

SINGLPAR Identifies independent students who were single parents/caretakers during the 2015-2016 

academic year.

Low-Income PCTPOV Indicates total 2014 income as a percentage of the federal poverty level thresholds for 

2014. For our purposes, low income is defined as having a household income level at or 

below 130 percent of the federal poverty level.

First generation 

student

PAREDUC Indicates the highest level of education achieved by a parent, stepparent, or guardian of 

the student. Per previous Department of Education studies, we define first generation as 

college students whose parents’ maximum educational attainment was a high school 

diploma or less. Note that students who did not know their parent’s highest education were 

not counted as first generation students.

Source: GAO analysis. | GAO-19-95.

a

The data are self-reported. The student may not be eligible for or receiving federal disability benefits.

b

The data are reported by the student and their family on the FAFSA or during the student interview. 

National level, individual SNAP enrollment data are not available to verify this variable, as states 

provide aggregate statistics to FNS.

Because our analysis does not include some of the risk factors for food 

insecurity listed in table 4, our findings may underestimate the number of 

college students who have a risk factor for food insecurity. For example, 

we heard in some of our interviews with researchers and in our 

discussions with students that being an undocumented or an international 

student was a risk factor for food insecurity. Such students are generally 

ineligible for federal financial aid and are restricted in the type of other 

federal aid they can receive. Undocumented students are also more likely 

than other students to be poor. However, NPSAS does not contain 

detailed data about undocumented or international students, so we could 

not include this risk factor for food insecurity in our analysis. The risk 

factors for food insecurity we included in our analysis may also be 

correlated with one another and can co-occur. For example, youth who 

were formerly in foster care are more likely than other youth to be low-
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-19-95 College Student Food Insecurity

income.4 Indeed, the prevalence of additional risk factors for food 

insecurity is higher among low-income than wealthier students. We did 

not analyze the extent to which some risk factors are more strongly 

associated with food insecurity than others or attempt to rank or weight 

the relative importance of risk factors.

Student SNAP Eligibility

To calculate potential student SNAP eligibility, we first calculated the 

number of students who might qualify for SNAP based upon having a 

household income at or below 130 percent of the federal poverty line, 

which is the standard income requirement for households that do not 

include a member who is 60 years of age or older or disabled to qualify 

for SNAP benefits. Next, we analyzed NPSAS variables to identify those 

that corresponded with SNAP student eligibility rules. We deemed all 

students who met the income requirements, were enrolled in school at 

least half time, and met one of the student eligibility exemptions we were 

able to identify in the data as potentially eligible for SNAP.

However, our analysis has limitations and does not precisely identify all 

students who are SNAP eligible. The 2016 NPSAS data set contains 

several variables that match up closely with certain student eligibility 

exemptions. For example, the exemptions related to age, having young 

dependents, working 20 hours per week, and receiving certain federal 

benefits have corresponding NPSAS variables (see table 6). For two of 

the exemptions, we used variables from the NPSAS data set that do not 

perfectly correspond to the statute but were the closest available proxies 

in the data. For the eligibility exemption that covers parents caring for a 

child 6-11 years old who are unable to obtain childcare to attend school 

and work, we identified students who have a child 6-11 years old and 

indicate they have no paid childcare. However, some individuals may 

have unpaid childcare, such as family members, and be able to work and 

attend school despite not having paid childcare, meaning they would not 

meet this SNAP student eligibility exemption. For the disability exemption, 

we used the NPSAS variable based on an interview question that asks 

students if they have a mental or physical disability. However, because of 

different definitions, the NPSAS disability variable may include students 

 4

Most foster and homeless youth have incomes within the lowest income quartile of all 

college-enrolled youth. See GAO, Higher Education: Actions Needed to Improve Access 

to Federal Financial Assistance for Homeless and Foster Youth, GAO-16-343 

(Washington, D.C.: May 19, 2016). 
Appendix I: Objectives, Scope, and 

Methodology

Page 52 GAO-19-95 College Student Food Insecurity

with disabilities who would not qualify for the SNAP student exemption 

related to disability. Specifically, to qualify for this SNAP student 

exemption, the student must not be “physically or mentally fit,”, while the 

NPSAS interview question asks students if they have some type of 

disability or condition, including a long-lasting condition such as serious 

difficulty hearing; blindness or serious difficulty seeing; difficulty 

concentrating, remembering or making decisions, a serious learning 

disability, depression, or Attention Deficit Hyperactivity Disorder; or 

serious difficulty walking or climbing stairs. As a result, we may 

overestimate the number of students who would qualify for the student 

exemption related to having a disability or caring for a child age 6-11. 

Lastly, NPSAS does not contain a variable to capture the student 

eligibility exemption related to enrollment in certain programs aimed at 

employment, such as the Workforce Innovation and Opportunity Act or 

Temporary Assistance for Needy Families employment and training 

programs. Therefore, we could not identify any students who met this 

eligibility exemption for SNAP and may have therefore underestimated 

the number of students who were potentially eligible for SNAP.

Table 6: Supplemental Nutrition Assistance Program (SNAP) Eligibility Exemptions for College Students and Corresponding 

Variables in the 2016 National Postsecondary Student Aid Study Data Set

College student 

SNAP exemption

NPSAS 

variable 

Variable description 

and limitations

Under age 18 or age 50 or older AGE Provides the student’s age as of 12/31/2015.

Parent caring for a child under age 6 DEPCHILD, 

DEPYNG

DEPCHILD identifies students who dependents who are children; 

DEPYNG provides the age of the student’s youngest child during the 

2015-16 academic year.

Parent caring for a child 6-11 years 

old who is unable to obtain child care 

to attend school and work

DEPCHILD, 

DEPYNG, 

DEPCARE

DEPCARE indicates whether the student had dependent children in paid 

childcare during the 2015-16 academic year. Students who have a child 

between 6 and 11 and indicate they do not have paid childcare were 

identified as meeting this condition. However, some individuals may have 

unpaid childcare that allows them to work and attend school, which these 

variables do not capture.

Single parent caring for a child under 

12 years old and enrolled full-time

SINGLPAR, 

DEPYNG, 

ATTEND2

The student’s single parent status, age of their youngest child, and 

whether they are enrolled full time.

Working a minimum of 20 hours per 

week

JOBHOUR Based on the following student interview question asked of each job the 

student has held while enrolled, “How many hours per week have you 

usually worked [for this employer] while you have attended school?” 

Excludes work study hours.

Receiving any Federal Work-Study 

funds 

TFEDWRK Total amount of federal work study awarded for the 2015-2016 academic 

year.

Receiving Temporary Assistance for 

Needy Families (TANF) benefits 

FEDBEND Whether any member of the student’s household received Temporary Aid 

for Needy Families (TANF) benefits during the 2013 or 2014 calendar 

year.
Appendix I: Objectives, Scope, and 

Methodology

Page 53 GAO-19-95 College Student Food Insecurity

College student 

SNAP exemption

NPSAS 

variable 

Variable description 

and limitations

Not physically or mentally fit (e.g., 

have a disability)

DISABIL2 Student has self-reported some type of disability or condition; not based 

on a federal disability determination.

Enrolled in certain programs aimed at 

employment, including TANF work 

programs, Workforce Innovation and 

Opportunity Act Title I programs, and 

others

N/A No corresponding NPSAS Variables

Source: GAO analysis and 2016 National Postsecondary Student Aid Study Documentation. | GAO-19-95.

Additionally, SNAP eligibility for college students depends not only on 

income and meeting a student exemption, but also on other 

determinations such as the level of the individual’s financial assets, 

including savings and any state policy waivers that may apply to the 

individual’s eligibility. Given that our analysis relied on self-reported 

information, and did not capture all aspects of student SNAP eligibility, we 

did not make any legal determinations about whether individuals were 

eligible for SNAP, and therefore our analysis can be characterized as 

providing only a rough estimate of those students who may potentially be 

eligible for SNAP benefits.

State Site Visits

To understand how selected colleges address student food insecurity, we 

conducted four state site visits (California, Kentucky, Massachusetts, and 

Michigan). We selected these states based on the following criteria:

• Mentioned in interviews with researchers or government officials as 

being a state that is: actively addressing college food insecurity, or 

has at least one public college that is taking action to address food 

insecurity among college students (number of mentions).

• School or state program on hunger or food insecurity featured in 

research papers or policy briefs (number of mentions).

• FNS data on food insecurity rates in the state, to indicate whether 

food insecurity among college students might also be a problem (rank 

by state).

• FNS data on SNAP enrollment and participation in the state, to 

indicate the level of SNAP usage in the state (rank by state).

• FNS information regarding the number of SNAP waivers a state has 

received, as a proxy for SNAP policy activity in the state (rank by 

state).
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-19-95 College Student Food Insecurity

We also sought geographic diversity in our site visit states. To achieve 

this, we created summary rank ordering of states based upon our criteria, 

then, from those states that ranked in the top 15, we selected one state 

from the Northeast, South, Midwest, and West census regions. Some of 

our criteria were purely qualitative in nature, such as information from 

interviews, research papers, and policy briefs regarding states and 

colleges with promising practices. Our site visit selection focused 

specifically on states and colleges with documented activity addressing 

college student food insecurity, and is therefore biased toward those that 

had taken action to address college student food insecurity. Our selection 

strategy did not capture situations where there was high food insecurity 

among students but the college or state was taking no action to address 

it, nor did we seek to identify or visit locations where food insecurity had 

not been identified as a problem. In addition to our site visits, we 

conducted interviews with officials from one college in Texas and one 

college in Ohio to learn about specific campus food insecurity initiatives in 

these states.

In each site visit state, we visited several colleges that were taking action 

to address food insecurity among their student populations, selected 

based on recommendations from researchers and college officials. We 

also considered geographic proximity when selecting colleges to visit. 

Overall, we spoke with officials representing 14 2- and 4-year public 

colleges (12 in-person and 2 telephone interviews).5 In each of our site 

visit states, we visited at least one large public university and one 

community college. See table 7 for a list of the 2- and 4-year colleges we 

interviewed in each state. 

 5

In addition, we met with one private college during the course of our study. We met with 

this 4-year private work college to learn about their unique approach to meeting their 

students’ basic needs. This college is not included in our summary of actions taken by 

colleges because it fell outside of our report’s focus on public 2- and 4-year colleges.
Appendix I: Objectives, Scope, and 

Methodology

Page 55 GAO-19-95 College Student Food Insecurity

Table 7: List of 2- and 4-year Selected Colleges that GAO Contacted, by State

State

2-year colleges 

interviewed

4-year colleges 

interviewed

California Skyline College California State University, Sacramento

University of California, Berkeley

Kentucky Maysville Community and Technical College Eastern Kentucky University

University of Kentucky

Massachusetts Bunker Hill Community College University of Massachusetts, Boston

Michigan Mott Community College

Washtenaw Community College

Eastern Michigan University

University of Michigan, Dearborn

Ohio Cuyahoga Community College

Texas Amarillo College

Total 7 7

Source: GAO. | GAO-19-95

At colleges, we asked members of the leadership team, financial aid 

officers, student affairs administrators, and other staff members questions 

about how they recognize, measure, and address college student food 

insecurity. We also conducted discussion groups with students at seven 

colleges we visited and asked about their experiences with food insecurity 

and federal assistance programs, such as SNAP. Students were invited 

by college officials to participate in these meetings. In each state we 

visited, we also met with officials from the state agencies that administer 

SNAP and any state governmental agencies, such as those overseeing 

higher education or involved in addressing food insecurity among college 

students. Lastly, in each site visit state, we identified and interviewed staff 

members at policy organizations, such as legal policy institutes or hunger 

advocacy groups, involved in efforts to address food insecurity among 

college students.

Assessing Federal Efforts to Address Food Insecurity

We assessed the extent to which federal programs assist college 

students experiencing food insecurity by reviewing relevant federal laws, 

regulations, and agency guidance and program documents related to 

specific SNAP requirements for college students and we interviewed FNS 

national office officials, including representatives of the Divisions of SNAP 

Program Development, Employment and Training, and Retailer Policy. 

We also interviewed FNS regional office officials in four of the seven FNS 

regions about their experiences working with the FNS national office and 
Appendix I: Objectives, Scope, and 

Methodology

Page 56 GAO-19-95 College Student Food Insecurity

with state SNAP agencies in their regions to address college student food 

insecurity and access to SNAP.

We also sent an email to all 51 state SNAP agency directors (all 50 states 

plus the District of Columbia) to ask about any actions their state has 

taken to address college student food insecurity. We received responses 

from 50 of the 51 state SNAP agencies, for a 98 percent response rate.6

This email inquiry was conducted in March and April 2018 and may not 

include all state actions that have occurred since April 2018. 

We conducted in-depth interviews with officials at five state SNAP

agencies and asked about any specific policies or actions their agencies 

have taken to address college student food insecurity or to assist 

potentially eligible college students to access SNAP. We conducted these 

interviews in person with state SNAP agencies during our four state site 

visits, and interviewed the Washington state SNAP agency by phone.7

We conducted this performance audit from July 2017 to December 2018 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

 6

The Michigan state SNAP agency did not respond to our email. However, we interviewed 

the Michigan state SNAP agency director during the course of our review and 

incorporated the state’s actions into our report, as appropriate.

7

We interviewed the Washington state SNAP agency director because of Washington’s 

extensive SNAP Employment & Training Program partnerships with colleges. 
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 57 GAO-19-95 College Student Food Insecurity

Kathryn Larin, (202) 512-7215 or larink@gao.gov

In addition to the contact named above, Michelle L. St. Pierre (Assistant 

Director), Nora Boretti (Analyst-In-Charge), Jessica K. Rider, and 

Stephen C. Yoder made significant contributions to this report. Also 

contributing to this report were Holly A. Dye, Barbara J. El Osta, Sarah C. 

Gilliland, Alison E. Grantham, Gina M. Hoover, Saida B. Hussain, Sheila 

R. McCoy, John W. Mingus Jr., Mimi Nguyen, Monica P. Savoy, Benjamin 

A. Sinoff, Almeta Spencer, Rachel R. Stoiko, Elaine L. Vaurio, and David 

A. Watsula.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(102202)
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