School Meals and Other Child Nutrition Programs: Background and Funding

Source: Expenditures are from USDA-FNS, "Child Nutrition Tables," April 11, 2025, https://www.fns.usda.gov/pd/child-nutrition-tables.

Notes: Graph displays actual spending except for the inflation-adjusted total, which was calculated by CRS using the Food Away From Home series of the Consumer Price Index for All Urban Consumers (CPI-U) (not seasonally adjusted) from the U.S. Bureau of Labor Statistics. Graph includes commodity costs but excludes other types of child nutrition program spending, such as FFVP, state administrative expenses, and discretionary grants. COVID-19 response policies affected spending in FY2020-FY2023 (discussed in the "Child Nutrition Program Operations During the COVID-19 Pandemic" text box). NSLP = National School Lunch Program, SBP = School Breakfast Program, CACFP = Child and Adult Care Food Program, SFSP = Summer Food Service Program, FFVP = Fresh Fruit and Vegetable Program, SMP = Special Milk Program.

National School Lunch Program (NSLP) and School Breakfast Program (SBP)

NSLP and SBP (the school meals programs) provide federal support for meals served in more than 90,000 public and private elementary and secondary schools nationwide.⁵⁸ They also support meals served in a smaller number of residential child care institutions.⁵⁹ Schools receive federal aid in the form of cash reimbursements for every meal they serve that meets federal nutritional requirements (limited to one breakfast and lunch per child daily). The largest subsidies are provided for free and reduced-price meals served to eligible students based on income eligibility and categorical eligibility rules (discussed below). Schools also receive a certain amount of commodity assistance per lunch served (discussed previously). Schools participating in NSLP have the option of providing afterschool snacks through the program, and schools participating in NSLP or SBP have the option of providing summer meals and snacks through the Seamless Summer Option (discussed in the "After-School Meals and Snacks" and "Seamless Summer Option" sections).

Schools are not required by federal law to participate in NSLP or SBP; however, some states require schools to have a school lunch and/or breakfast program, and some require schools to operate such programs through NSLP and/or SBP. Schools that do not participate in the federal school meals programs may still operate locally funded meal programs.⁶⁰ Some states also provide state funding for the school meals programs, including nine states (as of the cover date of this report) that have authorized funding to provide free meals to all students.⁶¹ As of school year 2023-2024, approximately 60% of NSLP schools operated universal school meal programs using a state or federal policy option.⁶²

The Healthy, Hunger-Free Kids Act of 2010 (HHFKA; P.L. 111-296) made several changes to the school meals programs. Among those changes was a requirement that USDA update the nutrition standards for school meals and create new nutritional requirements for foods sold in NSLP and SBP schools within a certain timeframe. The law also created the Community Eligibility Provision, through which eligible schools can provide free meals to all students. These changes are discussed further within this section.

NSLP and SBP are two separate programs, and schools can choose to operate one and not the other.⁶³ The programs are discussed together in this report because they share many of the same requirements. Differences between the programs are noted where applicable. Student participation in SBP tends to be lower than in NSLP for several reasons, including the traditionally required early arrival by students in order to receive a meal before school starts.

This section discusses topics specific to the school meals programs. Other food service topics relevant to child nutrition programs more broadly (e.g., the farm to school program) are discussed in the "Other Child Nutrition Activities" section.

Administration

Locally, the school meals programs are usually administered by school districts. Statute and regulations designate school food authorities as the local authorities in charge of operating the school meal programs; typically, these are food service departments within school districts.⁶⁴ Local educational agencies—the broader school district or school board—also play a role in administering the school meal programs.⁶⁵ This report sometimes uses the term school district to refer informally to the local administrative entities in the school meals programs.

In general, school food authorities handle food service operations and accounting responsibilities, such as food procurement, preparation, and service and tracking meals for reimbursement, while local educational agencies handle administrative duties, such as processing applications and certifying children for free and reduced-price school meals.

At the state level, the school meals programs are most often administered by state departments of education.⁶⁶ State administrative agencies are responsible for distributing federal reimbursements to school food authorities and overseeing school districts' administration of the school meal programs, including by conducting administrative reviews of school districts.⁶⁷

At the federal level, FNS provides ongoing guidance and technical assistance to state agencies and school food authorities through seven regional offices. FNS also provides oversight of state agencies, including by conducting management evaluations.⁶⁸

Figure 4 depicts the federal, state, and local roles in administering the school meals programs.

Figure 4. Federal, State, and Local Roles in the School Meals Programs

Source: CRS, based on current law and regulations.

Eligibility and Reimbursement

The school meals programs do not exclusively serve low-income children. Any student in an NSLP or SBP participating school may purchase a school meal; however, children must meet program eligibility rules in order to receive a free or reduced-price meal.

In most schools (excluding schools that participate in the Community Eligibility Provision or other special options), children are certified for free or reduced-price school meals through one of two pathways (shown in Figure 5):

• Household application (based on income eligibility or categorical eligibility, meaning that the child participates in another qualifying program or has a certain qualifying status); and
• Direct certification (automatic enrollment in free meals for categorically eligible children without additional means testing [with the exception of Medicaid, in which case income data are considered and children may be enrolled in free or reduced-price meals]).

If children are certified for free meals, the school food authority receives the free meal reimbursement for those meals. If children are certified for reduced-price meals, the school food authority receives a slightly lower reimbursement. School food authorities also receive a much smaller paid-rate reimbursement for meals served to children who pay for "full price" meals. School food authorities must follow federal guidelines in setting the price of paid meals.⁶⁹

Certain schools follow different eligibility and reimbursement procedures because they participate in the Community Eligibility Provision or other special options (discussed below in the "Special Options" section).

Figure 5. Certification Pathways for Free and Reduced-Price School Meals Household Application and Direct Certification Processes

Source: CRS adaptation of figure from U.S. Government Accountability Office (GAO), School Meals Programs: USDA Has Enhanced Controls, but Additional Verification Could Help Ensure Legitimate Program Access, GAO-14-262, May 2014, p. 13. Notes: Graphic does not depict direct certification of children for reduced-price meals through Medicaid in demonstration states or practices used in Community Eligibility Provision (CEP) schools and other schools using special options. FPG = federal poverty guidelines; SNAP = Supplemental Nutrition Assistance Program.

Income Eligibility

Children are eligible for free or reduced-price meals if their household's income falls within the following ranges:

• Free meals: household income at or below 130% of the federal poverty guidelines.⁷⁰
• Reduced-price meals (charges of no more than 40 cents per lunch and 30 cents per breakfast): household income above 130% and less than or equal to 185% of the federal poverty guidelines.⁷¹

These thresholds are based on the annual federal poverty guidelines established by the U.S. Department of Health and Human Services, and are updated annually for inflation. FNS publishes the corresponding income limits by household size for free and reduced-price meals in the Federal Register on an annual basis.⁷² Table 3 provides an example of the income limits for free and reduced-price meals for a household of four.

To become income eligible for school meals, a parent or guardian must complete a paper or online application that includes the income of each household member, the household size, and other information.⁷³ Household income is defined as total gross income (before taxes or deductions), including earnings and wages, certain public assistance benefits (such as unemployment compensation, social security benefits, and child support payments), and retirement and pension income.⁷⁴ Households are asked to provide current weekly, biweekly, twice monthly, or monthly income, which school district officials compare to the federal poverty guidelines to determine eligibility for free meals, reduced-price meals, or neither.⁷⁵ Households only need to fill out one application if they have multiple children in the same school district.

Categorical Eligibility

As an alternative to income eligibility, children can become eligible for free school meals if they fall into a certain category (called categorical eligibility). Per statute, children are automatically eligible for free lunches and breakfasts (without consideration of household income) if they are

• in a household receiving benefits through the following programs:
• SNAP (Supplemental Nutrition Assistance Program);
• FDPIR (Food Distribution Program on Indian Reservations, a program that operates in lieu of SNAP on some Indian reservations); or
• TANF (Temporary Assistance for Needy Families);
• enrolled in Head Start;
• in foster care;
• a migrant;
• a runaway; or
• homeless.⁷⁶

Categorical eligibility for free meals may be determined via a household application (households provide a case number on the application) or through direct certification (discussed in the next section). The vast majority of categorically eligible children are certified for free meals through direct certification.⁷⁷

Categorical eligibility for free school meals with SNAP and TANF began in the 1980s (then, the Food Stamp and Aid to Families with Dependent Children programs, respectively).⁷⁸ Categorical eligibility enabled schools to make use of other programs' more in-depth certification processes and reduced the number of applications that families had to fill out.⁷⁹ Other programs and categories were added over time.

Direct Certification

Direct certification is a process through which state agencies and school districts automatically certify children for free meals based on documentation of the child's status in a program or category without the need for a household application.⁸⁰ States are required to conduct direct certification with SNAP and have the option of conducting direct certification with the other programs and categories that convey categorical eligibility.

For SNAP and other federal programs, the direct certification process typically involves state agencies (e.g., state SNAP and state educational agencies) cross-checking program rolls.⁸¹ A list of matched children is sent to the school district, which certifies children for free meals without the need for a household application.⁸² For foster, homeless, migrant, and runaway children, direct certification typically involves school district communication with a local or state official who can provide documentation of the child's status in one of these categories.⁸³

The 2004 child nutrition reauthorization act (P.L. 108-265) required states to conduct direct certification with SNAP, with nationwide implementation taking effect in school year 2008-2009. As of school year 2018-2019 (the most recent data available), USDA reported that 98% of children in SNAP households were directly certified for free school meals.⁸⁴

The HHFKA made further policy changes to expand direct certification. One of those changes was the initiation of a demonstration project to test direct certification with Medicaid (see the text box below). The law also funded performance incentive grants for high-performing states and authorized corrective action plans for low-performing states in direct certification activities.⁸⁵

Verification of Eligibility

Each fall, districts are required to verify a sample of approved household applications on file, with a focus on applications close to the eligibility threshold ("error-prone" applications).⁹¹ School districts may also conduct verification of questionable applications. Verification is not required for children who are directly certified for free or reduced-price meals. (Note that districts participating in Provisions 1, 2, and 3 [see the "Provisions 1, 2, and 3" section] must meet verification requirements for the years in which they administer household applications.)

Many districts employ direct verification (matching data from other low-income programs) to conduct their verification activities, but if data cannot be verified in this way, schools must contact households to verify the information provided on the application. A child's eligibility status may stay the same or change (e.g., from free meals to reduced-price meals or loss of eligibility) as a result of verification of household income, or if the household does not respond to verification outreach (in which case eligibility would be lost, though that decision can be appealed).

Reimbursement

School food authorities must keep track of the daily number of meals they serve in each category (free, reduced-price, and paid) that meet federal nutrition requirements. School food authorities then submit claims for reimbursement to the state agency, which submits the claims to FNS. Approved reimbursements are distributed to school food authorities by the state agency, usually on a monthly basis. Per statute, reimbursement rates are adjusted for inflation annually.⁹² Table 4 shows NSLP and SBP reimbursement rates for school year 2024-2025. (Note that school food authorities also receive a per-lunch commodity reimbursement, discussed previously under "Commodity Assistance".)

The law provides a higher reimbursement rate for meals meeting certain criteria. For example, school food authorities that are compliant with the updated federal nutrition standards for school meals (nearly all school food authorities as of school year 2023-2024⁹³) receive an additional 9 cents per lunch.⁹⁴ School food authorities also receive an additional 2 cents per lunch if they serve 60% or more of their lunches at a free or reduced price.⁹⁵ For breakfasts, school food authorities receive higher reimbursements for free and reduced-price meals (an additional 47 cents per breakfast) if they serve 40% or more lunches at a free or reduced price (referred to as severe need schools).⁹⁶

Once school food authorities receive the cash reimbursements, they can use the funds to support almost any aspect of the school food service operation. However, federal cash reimbursements must go into a nonprofit school food service account that is subject to federal regulations.⁹⁷ Payments for non-program foods (e.g., vending machine sales) must also accrue to the nonprofit school food service account.⁹⁸

FNS periodically studies the costs of producing a reimbursable meal. In April 2019, FNS released a School Nutrition and Meal Cost Study, which found that the average reported cost of producing a reimbursable lunch was $3.81 in school year 2014-2015 (reported costs were defined as those charged to the school food service account).⁹⁹ This exceeded the average federal cash reimbursement ($3.32) for lunches in school year 2014-2015. When unreported costs were included (costs outside of the food service account; for example, labor costs associated with processing applications), the cost of producing the average reimbursable lunch was $6.02. As noted previously, children's payments and state and local funds may also cover meal costs.

Special Options

Community Eligibility Provision (CEP)

The HHFKA authorized the Community Eligibility Provision (CEP), an option that allows eligible schools, groups of schools, and school districts to offer free meals to all enrolled students.¹⁰⁰ To participate in CEP, the school(s) must have an identified student percentage (ISP) of at least 25% (USDA lowered the eligibility threshold from 40% to 25% as of school year 2023-2024).¹⁰¹ The ISP is the percentage of students in the school(s) who are certified for free meals without a household application (i.e., who are directly certified for free meals through SNAP or another program/category).¹⁰² In addition, the school(s) must operate both NSLP and SBP in order to participate in CEP, and they must opt-in to CEP.

Based on the statutory parameters, FNS piloted CEP in various states over three school years, and expanded the option nationwide in school year 2014-2015. Eligible schools, groups of schools, and entire school districts may participate; if participation is as a group, the ISP is calculated on a group basis. Local educational agencies have until June 30 of each year to notify USDA of the schools in their jurisdiction that will participate in CEP.¹⁰³ According to a database maintained by the Food Research and Action Center (a research and advocacy organization), approximately 47,766 schools participated in CEP in school year 2023-2024, up from 40,235 schools in school year 2022-2023.¹⁰⁴ Figure 6 displays the estimated proportion of CEP schools out of all NSLP schools since school year 2014-2015 (the first year of nationwide implementation).

Figure 6. CEP Schools as a Proportion of NSLP Schools, School Years 2014-2015 to 2023-2024

Source: CRS-calculated proportions using USDA FNS-742 administrative data for FY2015-FY2024. Notes: Includes CEP schools in states operating universal free meal policies. CEP percentages not shown for school years 2020-2021 and 2021-2022, during which the vast majority of schools operated under COVID-19 response policies that enabled them to receive reimbursement for free meals served to all students. Therefore, CEP participation in these years is not relevant. In addition, NSLP participation is lower in school year 2020-2021 than a typical year because many school food authorities chose to operate the summer meals programs instead of NSLP as a result of pandemic response policies (discussed further in the "Child Nutrition Program Operations During the COVID-19 Pandemic" text box).

Though CEP schools serve free meals to all students, they are not reimbursed at the free rate for every meal served. Instead, the law provides a funding formula: the ISP is multiplied by a factor of 1.6 to estimate the proportion of students who would be eligible for free or reduced-price meals had they been certified via application.¹⁰⁵ The result is the percentage of meals served that will be reimbursed at the free-meal rate, with the remainder reimbursed at the much lower paid-meal rate. For example, if a CEP school has an ISP of 40%, then 64% of its meals served would be reimbursed at the free-meal rate and 36% would be reimbursed at the paid-meal rate. Schools that identify 62.5% or more students as eligible for free meals receive the free-meal reimbursement for all meals served (62.5% multiplied by 1.6 equals 100%). Figure 7 provides a visual representation of the CEP reimbursement formula for participating schools, groups of schools, and school districts.

CEP participating schools must recalculate their ISP at least once every four years, but they can choose to do so more frequently if desired.¹⁰⁶ While eligibility determinations occur every four years, schools can drop out of CEP at any time.¹⁰⁷

CEP is intended to reduce paperwork for families and schools and enable schools to provide more free meals. However, the option may or may not be financially beneficial for schools depending on their proportion of identified students.

Figure 7. Community Eligibility Provision (CEP) Reimbursement Formula

Source: Graphic created by CRS based on current law. Notes: The Identified Student Percentage (ISP) is the percentage of enrolled children who are certified for free meals without a household application. The ISP is multiplied by 1.6 to calculate the proportion of meals reimbursed at the free rate; the remainder of meals are reimbursed at the lower paid rate. For free and paid reimbursement rates in school year 2024-2025, see Table 4.

Provisions 1, 2, and 3

Schools, groups of schools, and school districts can also use Provisions 1, 2, and 3 to establish alternative certification and reimbursement procedures. These options are intended to reduce paperwork for school administrators and families.¹⁰⁸ The options predate CEP, and unlike CEP, they still require some household applications. A school's decision to participate in a special option may depend on financial considerations. There were 4,471 schools operating Provisions 1, 2, or 3 in school year 2023-2024.¹⁰⁹

Provision 1 allows schools with high proportions (80% or more) of students eligible for free and reduced-price meals to make free meal eligibility determinations that remain in effect for two school years. This reduces the number of applications they have to process (though they still have to process reduced-price meal applications annually).¹¹⁰

Provision 2 and Provision 3 are open to all schools. Similar to CEP, schools, groups of schools, or school districts must agree to provide free meals (lunches or lunches/breakfasts) to all students in order to participate in Provision 2 or Provision 3. Under Provision 2, schools are reimbursed over a four-year period by applying the proportion of meals served at a free/reduced-price/paid rate during the first year to total meals served in subsequent years. Eligibility determinations in the first year are based on direct certification and household applications (a difference from CEP). Under Provision 3, schools are similarly required to make eligibility determinations in the first year of a four-year period. However, in this case, schools receive the same level of federal assistance over the next three years, which is adjusted for enrollment and inflation (there are no separate payments for free/reduced-price/paid meals).¹¹¹

Nutrition Standards and Food Service

Nutrition Standards for School Meals

Nutritional requirements for school meals have changed throughout the history of the school meals programs.¹¹² The most recent child nutrition reauthorization, the HHFKA in 2010, required USDA to update the nutrition standards for school meals within 18 months of the law's enactment based on recommendations from the Food and Nutrition Board at the National Academies of Sciences, Engineering, and Medicine.¹¹³ The law also provided a "performance-based" bonus reimbursement of 6 cents per lunch (adjusted annually for inflation) for school food authorities certified as compliant with the updated standards (the rate is 9 cents in school year 2024-2025) (which nearly all school food authorities receive, as discussed in the "Reimbursement" section).¹¹⁴

USDA published the updated nutrition standards for school meals in 2012.¹¹⁵ They were based on the 2010 Dietary Guidelines for Americans (per an existing statutory requirement) as well as the recommendations from the National Academies of Sciences, Engineering, and Medicine.¹¹⁶ The standards required increased servings of fruits, vegetables, whole grains, and meats/meat alternates in lunches and breakfasts. They also restricted milk to unflavored low-fat (1%) and flavored and unflavored fat-free varieties, set limits on calories and sodium in school meals, and prohibited trans fats in school meals, among other changes. Separate from the final rule, USDA also implemented a requirement in the HHFKA that schools make water available to children during meal service in the cafeteria.¹¹⁷

The revised nutrition standards largely took effect in school year 2012-2013 for lunches and in school year 2013-2014 for breakfasts. A few requirements phased in over multiple school years.¹¹⁸ Some schools experienced difficulty implementing the new standards.¹¹⁹ Subsequent changes to the whole grain, sodium, and milk requirements were made through appropriations acts and USDA rulemaking.¹²⁰ In April 2024, USDA finalized a rule that made changes to milk, sodium, and whole grain standards and instituted a new limit on added sugars in school meals, among other policies.¹²¹

States and school districts are allowed to implement additional nutritional requirements for school meals, as long as they meet the federal standards.¹²²

Table 5 provides an overview of the federal nutrition standards for school lunches.

Nutrition Standards for Competitive Foods

The HHFKA also required USDA to develop nutrition standards for other foods sold in NSLP- and SBP-participating schools on campus during the school day. These foods are known as competitive foods (i.e., foods sold in competition with school meals). Competitive foods include foods and drinks sold in vending machines, a la carte lines, snack bars and concession stands, and school fundraisers. These foods do not receive a federal reimbursement. The HHFKA required USDA to publish proposed nutrition standards for competitive foods within one year of the law's enactment and align the standards with the most recent Dietary Guidelines for Americans.

Relying on recommendations made by the National Academies of Sciences, Engineering, and Medicine, FNS promulgated a proposed rule in April 2013 and then an interim final rule in June 2013, which went into effect in school year 2014-2015.¹²³ The interim final rule created nutrition standards for all non-meal foods and beverages that are sold during the school day (defined as midnight until 30 minutes after dismissal). The final rule, published in July 2016, maintained the interim final rules with minor changes.¹²⁴ Under the final standards, competitive foods must have certain primary ingredients, meet whole-grain requirements, and comply with calorie, sugar, sodium, and fat limits, among other criteria. Schools are also limited to a list of specific beverages they may sell (with larger portion sizes and caffeine allowed in high schools).¹²⁵ The April 2024 final rule (discussed previously) further limited added sugars in milks sold as competitive beverages and exempted bean/hummus dips from fat limits.¹²⁶

Fundraisers held outside of the school day and fundraisers in which the food sold is clearly not intended for consumption on campus during the school day are not subject to the competitive food nutrition standards. In addition, the law and the final rule provided states with discretion to exempt infrequent fundraisers selling foods or beverages that do not meet the nutrition standards.

The federal standards are minimum standards, and states and school districts are permitted to issue more stringent policies. Many districts already had local competitive food standards in place prior to the HHFKA because of the 2004 child nutrition reauthorization law (P.L. 108-265), which required local educational agencies to implement local school wellness policies (discussed in the next section) that included nutritional guidelines for foods sold in schools.

Local School Wellness Policies

Local educational agencies participating in the school meals programs are required to have a local school wellness policy, which sets nutrition and health-related goals and guidelines for schools within the jurisdiction.¹²⁷ Local school wellness policies must include goals related to nutrition and physical activity, nutrition standards for school foods that meet or exceed federal nutrition standards, and an implementation plan, among other content. Local educational agencies must provide opportunities for input from parents, students, school nutrition professionals, physical education teachers, school health professionals, school administrators, and the general public in developing and updating local school wellness policies.

Food Procurement and Preparation

The majority of foods used in the school meal programs are purchased by school food authorities using federal cash reimbursements or other funds. School food authorities also receive USDA Foods (as discussed previously). School food authorities must comply with federal procurement rules when purchasing foods for the school meals programs.¹²⁸ In addition, there is a "Buy American" requirement in statute that requires schools participating in the school meal programs to purchase domestic commodities and products "to the maximum extent practicable."¹²⁹ Purchases may include local foods, as long as they comply with federal, state, and local procurement regulations.¹³⁰

Many school food authorities purchase and prepare their own meals, either at a centralized district kitchen or onsite at individual schools.¹³¹ Alternatively, school food authorities may contract with a private food service management company to contract out procurement and/or meal preparation.¹³² The contracted company must comply with all school meal regulations and the school food authority must retain general control over the operation of the school meals programs, including financial oversight and compliance with nutrition standards.¹³³

Meal Times and Settings

In general, lunches and breakfasts are intended to be consumed onsite during the school day.¹³⁴ Surveys have found that schools typically provide roughly 20 minutes for breakfast and 25-30 minutes for lunch.¹³⁵

Under SBP, students were traditionally required to arrive early for breakfast and eat it in the cafeteria. However, in recent years, schools and states have increasingly adopted alternative models of breakfast service such as breakfast in the classroom, grab-and-go carts, and breakfast during morning breaks. Anti-hunger advocacy groups have encouraged the adoption of new models of breakfast service as a way to increase SBP participation.¹³⁶ According to a 2018 survey by the School Nutrition Association (SNA), a membership and advocacy organization, more than half of surveyed school districts offered both a traditional cafeteria line and alternative modes of breakfast service, while 43% of schools offered a cafeteria line only. Common alternatives were grab-and-go stations (particularly in middle and high schools) and breakfast in the classroom (particularly in elementary schools).¹³⁷

School Meal Equipment Assistance Grants

At different points in the school meals programs' history, specific funds have been provided for cafeteria equipment purchases (per-meal reimbursements may also cover equipment costs). Since FY2013, annual appropriations acts have provided funding for school meal equipment assistance grants to help schools prepare meals that comply with updated nutrition standards, improve food safety, and support the establishment, maintenance, or expansion of school breakfast programs ($10 million was provided for FY2024, down from $30 million in FY2023).¹³⁸ These grants are awarded by FNS to state agencies, which distribute funds to school food authorities on a competitive basis.¹³⁹

Child and Adult Care Food Program (CACFP)

CACFP provides federal reimbursements for meals and snacks served in approximately 135,000 child care centers, day care homes, and adult day care centers nationwide in a typical year (see Table 6 for participation by type of institution).¹⁴⁰ Reimbursements are generally provided for meals and snacks served to children ages 12 and under and chronically disabled and elderly adults.¹⁴¹ CACFP also supports free meals and snacks for children ages 18 and under in emergency shelters and afterschool programs in low-income areas (discussed in the "After-School Meals and Snacks" section).¹⁴²

In general, CACFP provides cash reimbursements for up to two meals and one snack or one meal and two snacks per participant daily (a meal may be a breakfast, lunch, or supper).¹⁴³ A smaller share of federal aid takes the form of commodity assistance or cash in lieu of commodities and funds for administrative costs (discussed previously).¹⁴⁴ The eligibility and funding rules of CACFP differ for centers (facilities or institutions) and day care homes (private homes). Day care homes must be overseen by sponsoring organizations, which handle the financial and administrative functions of the program for local providers. Centers have the option of operating independently or under a sponsor.

Both centers and day care homes must comply with government-established standards for other child care programs and meet federal CACFP nutrition standards.¹⁴⁵

Administration

At the local level, sponsor organizations administer CACFP for all participating day care homes and centers that elect to have a sponsor. Sponsors are responsible for conducting audits of providers, distributing federal reimbursements, and in some instances, preparing and distributing meals.¹⁴⁶ They can be public or nonprofit institutions or, in some cases, for-profit institutions.¹⁴⁷ Centers that choose to handle their own administrative responsibilities are referred to as independent centers.

Unlike centers, day care homes are required to have a sponsor organization. Sponsors receive monthly federal administrative payments based on the number of homes for which they are responsible (sponsors, on average, have more than 100 day care homes under their supervision).¹⁴⁸ They may also receive a portion of the per-meal reimbursement if they have an agreement with the day care home to prepare meals.¹⁴⁹ If a center opts to have a sponsor, the sponsor may retain a portion of the per-meal reimbursements for its administrative expenses.¹⁵⁰

In CACFP, the state administering agency is typically the state department of education or department of health and/or human services.¹⁵¹ The state agency distributes federal funds and conducts reviews of CACFP sponsor organizations and independent centers.¹⁵²

Similar to the school meals programs, FNS provides oversight of state agencies and issues guidance and regulations to states and providers.

Eligibility and Reimbursement

CACFP Centers

The following institutions are eligible to participate as centers in CACFP:

• public or private nonprofit (tax exempt) organizations providing nonresidential child care or adult day care (including school food authorities and Head Start centers),¹⁵³
• private for-profit organizations providing nonresidential child care or adult day care that enroll a certain proportion of low-income participants,¹⁵⁴ and
• emergency shelters for homeless families.¹⁵⁵

Adult day care centers and outside school hour centers fall under the first two categories, but they are subject to specific federal regulations.¹⁵⁶

Income eligibility rules for CACFP centers are the same as the school meals programs: participants in households at or below 130% of the poverty line qualify for free meals and snacks and those between 130% and 185% of the poverty line qualify for reduced-price meals and snacks (a charge of no more than 40 cents for a lunch or supper, 30 cents for a breakfast, and 15 cents for a snack).¹⁵⁷ CACFP centers also use similar categorical eligibility criteria, including participation in Head Start, foster child status, and household participation in SNAP, FDPIR, or TANF assistance. Adults are categorically eligible if they participate in SNAP, FDPIR, Supplemental Security Income (SSI), or Medicaid.¹⁵⁸ Eligibility is determined through paper applications or, in some states, direct certification-like processes.

For CACFP centers, the reimbursement rates for breakfasts and lunches/suppers are the same as the SBP breakfast reimbursement rate and NSLP lunch reimbursement rate, respectively.¹⁵⁹ The largest subsidies are provided for free and reduced-price meals and snacks, while paid meals receive a lower reimbursement.¹⁶⁰ Unlike the school meals programs, CACFP allows centers certain flexibilities for tracking meal counts and submitting claims for reimbursement.¹⁶¹

Compared to school meals, CACFP centers are also less likely to collect meal payments from participants and more likely to incorporate meal costs into tuition. Centers are not required to adjust tuition and fees to account for CACFP funding. Centers are also allowed to charge families separately for meals and snacks, as long as there are no charges for children who qualify for free meals and limited charges for those who qualify for reduced-price meals.¹⁶²

CACFP Day Care Homes

Day care homes are private homes that provide nonresidential child care services. In general, any day care home that meets local, state, or federal child care standards may participate in CACFP.

Unlike centers, day care homes generally do not make eligibility determinations and receive the same reimbursement rate for every meal served. Day care homes located in a low-income area or with a low-income provider receive a higher, Tier I reimbursement rate (shown in Table 7). To receive the Tier I rate, the home must be located in an area in which at least 50% of children are eligible for free or reduced-price meals or be operated by a provider whose household income level meets the free or reduced-price income standards.¹⁶³ Day care homes that do not qualify for Tier I rates receive Tier II (lower) rates. However, Tier II providers may seek the higher Tier I subsidies for individual low-income children for whom household income information is collected and verified.

Like centers, CACFP-participating day care homes may incorporate meal costs into tuition. Unlike centers, federal rules prohibit any separate meal charges.¹⁶⁴

Nutrition Standards and Food Service

Nutrition Standards

In addition to nutrition standards for school foods, the HHFKA required the Secretary of Agriculture to update CACFP's meal patterns. USDA's final rule, effective October 1, 2017, revised the meal patterns for meals and snacks served in centers and day care homes.¹⁶⁵ It also aligned nutrition standards for meals served to preschool-aged children through NSLP and SBP.

For infants (under 12 months of age), the new meal patterns eliminated juice, encouraged breastfeeding, and set guidelines for the introduction of solid foods, among other changes. For children ages one and older and adult participants, the new meal patterns increased whole grains, fruits, and vegetables, limited milk to certain varieties¹⁶⁶, limited sugar in cereals and yogurts¹⁶⁷, and prohibited deep-fried foods. They also required that potable water be available to children throughout the day.

Procurement and Meal Service

CACFP institutions may purchase their own foods and prepare their own meals, or they may contract with a school or a food service management company that prepares meals for them. In either case, institutions must comply with federal, state, and local procurement regulations.¹⁶⁸ As noted previously, CACFP institutions also receive a certain amount of USDA Foods.

Meals must comply with state or local health, safety, and sanitation requirements for storing, preparing, and serving food, and institutions must acquire annual food safety inspections. Family-style meal service (where children can serve themselves from shared bowls or platters) is encouraged in CACFP.¹⁶⁹

Summer Food

The SFSP and the Seamless Summer Option (SSO) provide federal reimbursements for summer meals.¹⁷⁰ SFSP is open to school food authorities, local public agencies, and private nonprofit organizations, while SSO is specifically for school food authorities, allowing them to continue operating under certain NSLP/SBP requirements into the summer. The programs share many of the same requirements, including a requirement that children consume meals onsite—known as the "congregate feeding" requirement—except in rural areas (discussed further below).¹⁷¹ Summer food benefits for households with school-age children are also available through the Summer EBT program, which was permanently authorized by the FY2023 Consolidated Appropriations Act (P.L. 117-328).

During the COVID-19 pandemic, the summer meals programs were used during the school year to facilitate free meal service (not discussed in this section).¹⁷²

Summer Food Service Program (SFSP)

The SFSP provides federal aid to school food authorities and other local public and nonprofit organizations that serve meals and snacks to children during the summer months.¹⁷³ Federal aid is provided in the form of per-meal cash reimbursements and a smaller amount of commodity foods and administrative funds (discussed previously). The program serves roughly 2.8 million children at around 36,000 meal sites each summer.¹⁷⁴

Similar to CACFP, SFSP is administered at the local level by sponsor organizations that operate the program at one or more meal sites (the physical location where food is served and eaten). All SFSP meal sites are required to have a sponsor. Sponsors may operate meal sites at a variety of locations, including schools, recreation centers, parks, churches, and public libraries.

Unlike the other child nutrition programs, SFSP participation is generally limited (with the exception of camps and certain rural areas) to meal sites that serve children from "areas in which poor economic conditions exist"—defined as areas or sites in which at least 50% of children are eligible for free and reduced-price school meals (discussed further below).¹⁷⁵

Administration

The following public and private nonprofit institutions are eligible to participate in SFSP as sponsors:

• nonprofit organizations,
• school food authorities,
• state and local governments (including tribal governments),
• public or nonprofit summer camps (overnight and day camps), and
• public or nonprofit colleges and universities participating in the National Youth Sports Program.¹⁷⁶

Figure 8 displays the proportion of summer meal sponsors by institution type as of summer 2018.

Figure 8. Summer Meal Sponsors by Type, 2018 Estimated Percentage of Sponsors in SFSP and SSO by Organization Type

Source: USDA-FNS, USDA Summer Meals Study Volume 2. Sponsor and Site Operational Characteristics, prepared by Westat, October 2021, pp. 3-4 to 3-7, https://www.fns.usda.gov/cn/usda-summer-meals-study. Note: Numbers may not sum to 100% due to rounding.

Eligible sponsors must also provide year-round services to the community, with limited exceptions.¹⁷⁷ In addition, all sponsors except camps must "conduct a regularly scheduled food service for children from areas in which poor economic conditions exist" (discussed further in the next section).¹⁷⁸

According to statute, when selecting sponsors, states must give priority to school food authorities, public and nonprofit organizations that have demonstrated successful program performance in a prior year, new public sponsors, and new nonprofit sponsors (in that order). States must also prioritize sponsors located in rural areas.¹⁷⁹

Sponsors are responsible for selecting meal sites, distributing meals to sites, and monitoring sites.¹⁸⁰ Officials at meal sites are responsible for distributing meals to children, monitoring the food service, and keeping track of meals served for reimbursement. At times, a sponsor may also be a site (for example, camps are both sponsors and meal sites).

State administering agencies (often state departments of education) approve sponsors, distribute federal funds, and conduct reviews of sponsors and sites.¹⁸¹ State agencies receive SFSP funds for administrative costs in addition to general child nutrition program administrative funds (discussed previously in the "Administrative Funds" section).

FNS distributes funds and commodities to state agencies, oversees states' implementation of SFSP, and provides guidance and technical assistance to states and participating institutions.

Eligibility and Reimbursement

SFSP's eligibility and reimbursement rules differ for different types of areas and meal sites.

Rural areas: As a result of the FY2023 Consolidated Appropriations Act (P.L. 117-328), sponsors may provide free meals for off-site consumption (i.e., pick-up or delivery) to children in rural areas¹⁸² if (1) the area is also considered low-income (defined as at least 50% of children qualifying for free or reduced-price school meals)¹⁸³ or (2) the individual child qualifies for free or reduced-price school meals.¹⁸⁴ Sponsors may receive reimbursement for up to two meals, or one meal and one snack, per child daily (however, sponsors may seek state approval to distribute up to 10 days' worth of meals at a time). This policy became effective in summer 2023. According to USDA, more than 1,000 sponsors established nearly 4,000 non-congregate rural points-of-service in summer 2024.¹⁸⁵

Open sites are meal sites that are open to all children in the community.¹⁸⁶ Open sites are the most common type of site, comprising an estimated 83% of summer meal sites in summer 2018 (the most recent year of data).¹⁸⁷ In order to participate in SFSP, open sites must be located in an area in which at least 50% of the children would be eligible for free or reduced-price school meals as demonstrated through school data, Census data, or other approved data sources.¹⁸⁸ Meals must be served free to all children at these sites, and the sponsor of the site receives reimbursement for every meal served (up to two meals or one meal and one snack per child daily).

Closed enrolled sites are meal sites (other than camps) that only serve enrolled children. In order for the site to participate in SFSP, closed enrolled sites must establish that at least 50% of children qualify for free or reduced-price school meals based on area eligibility data or individual eligibility information for enrolled children.¹⁸⁹ Like open sites, meals are served free to all children and the sponsor receives reimbursement for every meal served (up to two meals or one meal and one snack per child daily).

Camps include residential and day camps that provide organized programs for enrolled children. Unlike open and closed enrolled sites, camps do not have to demonstrate that a certain percentage of children meet the free and reduced-price eligibility standards in order to participate in SFSP. Instead, eligibility works like NSLP and SBP: camps make eligibility determinations using similar income and categorical eligibility criteria for free and reduced-price meals. However, unlike the school meals programs, camps receive the same reimbursement rate for free and reduced-price meals. Camps may receive reimbursement for up to three meals or two meals and one snack per eligible child daily. Camps are not required to serve meals for free to all children, and there is no paid reimbursement provided for full-price meals.

Migrant sites must demonstrate that they predominantly serve migrant children as certified by a migrant organization or a sponsor. They follow the same eligibility and reimbursement rules as open sites, except that they may receive reimbursement for up to three meals or two meals and one snack per child daily.

SFSP reimbursement rates (inflation-adjusted rates displayed in Table 8) are based on a statutory formula that takes into account operating costs (e.g., food, storage, and labor costs) and administrative costs.¹⁹⁰ While such factors are taken into account in calculating the rates, once sponsors receive the funds they can use them for any allowable program cost. Higher reimbursements are provided for sponsors of rural meal sites and "self-preparation" sites (meal sites in which a sponsor rather than a vendor prepares food).

Nutrition Standards

Meals and snacks served through SFSP must meet federal nutrition standards. In contrast to the child nutrition programs discussed thus far, SFSP's nutrition standards are not required to align with the Dietary Guidelines for Americans, but are "prescribed by the Secretary on the basis of tested nutritional research."¹⁹¹ Program regulations outline the nutrition standards for breakfasts, lunches/suppers, and snacks.¹⁹² The standards prescribe minimum servings of fruits and vegetables, meats/meat alternatives, breads/bread alternatives, and milk. Unlike school meals and CACFP, there are no limits on calories, saturated fats, and milk varieties in SFSP. Participating school food authorities may instead choose to use the NSLP and/or SBP nutrition standards for SFSP.¹⁹³

Meal Service

As noted, children are required to consume meals onsite in SFSP, unless they receive meals under the rural non-congregate feeding policy. There are also requirements around the timing of congregate meals in SFSP, including at least one hour between meals.¹⁹⁴ Like the other child nutrition programs, SFSP sponsors must comply with local or state health and sanitation requirements.

Seamless Summer Option (SSO)

School food authorities may participate in SFSP, or they can choose to offer summer meals through SSO. SSO allows school food authorities to continue operating under certain NSLP/SBP requirements into the summer.¹⁹⁵ For example, it allows them to use the school meals programs' nutrition standards, administrative review process, and reimbursement rates (see Table 4 for NSLP/SBP reimbursement rates). Other requirements are the same as SFSP, including rural area and site eligibility rules.¹⁹⁶ School food authorities are the only eligible sponsor in SSO, but they can operate the program at a variety of meal sites (e.g., parks, recreation centers, libraries) and through meal delivery and other offsite feeding mechanisms in rural areas.¹⁹⁷

The school lunch and breakfast reimbursement rates used in SSO are lower than SFSP's reimbursement rates. However, school food authorities participating in SSO also receive the NSLP commodity reimbursement (discussed in the "Commodity Assistance" section). School food authorities may also have a reduced administrative burden under SSO. A 2018 study by USDA found that three-quarters of sponsors operated SFSP and one-quarter operated SSO.¹⁹⁸

Summer EBT

Following a more than decade-long demonstration (discussed below), the Summer EBT program was permanently authorized by the FY2023 Consolidated Appropriations Act (P.L. 117-328), which gave all states and territories and some ITOs the option to operate Summer EBT starting in summer 2024. According to the law, participating jurisdictions are to distribute federal funds to eligible households—in an amount of $40 per child per summer month (adjusted annually for inflation)—which households can redeem at SNAP-authorized retailers for groceries. Children who receive free or reduced-price meals during the school year are automatically enrolled in the program (though families may opt out). States participating in the program must also establish an application process—using the same eligibility criteria as free or reduced-price school meals—for other children.

P.L. 117-328 establishes separate program options for ITOs participating in WIC (some of whom previously operated the Summer EBT demonstration through WIC), territories that do not operate SNAP (American Samoa, Puerto Rico, and the Northern Mariana Islands), and children who attend year-round schools.

The law requires grantees to cover at least half of administrative costs and authorizes federal funding to cover the other half.

In summer 2024, 37 states, DC, five territories, and two ITOs operated Summer EBT.¹⁹⁹ Federal funding totaled approximately $2.5 billion for benefits and $250 million for administrative costs.²⁰⁰ USDA also made an additional $100 million available in discretionary funding under the Consolidated Appropriations Act, 2024 (P.L. 118-42) for noncompetitive technology grants for implementation of Summer EBT (not subject to the administrative match requirement).²⁰¹

Special Milk Program (SMP)

SMP provides funding for milk served in approximately 1,600 schools, child care institutions, summer camps, and other institutions.²⁰⁸ Generally, schools and other participating institutions may not participate in another child nutrition meal service program along with SMP. However, schools may administer SMP for pre-kindergartners and kindergartners who are in part-day sessions and do not have access to the school meals programs.²⁰⁹

In SMP, participating institutions provide milk to children for free and/or at a subsidized paid price. Institutions are reimbursed differently based on whether they decide to provide milk for free to all children, sell milk to all children, or combine these options (provide free milk to eligible children and sell milk to other children) (see Table 9). If institutions choose the combined option, they must establish eligibility rules for free milk.²¹⁰

USDA updated the nutritional requirements for milk served in SMP alongside changes to the CACFP nutrition standards.²¹¹ The final rule, which took effect on October 1, 2017, required unflavored whole milk for one-year-olds, unflavored low-fat (1%) or unflavored fat-free milk for children ages 2-5, and unflavored low-fat (1%) or flavored/unflavored fat-free milk for children ages six and older (subsequent rules have allowed flavored low-fat milk for the six-and-older age group).²¹² The regulations also allowed for reimbursement of non-dairy milk substitutes in cases of medical or special dietary needs.

After-School Meals and Snacks

CACFP and NSLP both provide federal support for snacks and meals served during after-school programs.²¹³ The CACFP At-Risk Afterschool component provides reimbursement for up to one snack and one meal (usually supper) per child daily, whereas the NSLP Afterschool Snack option provides reimbursement for snacks only. Reimbursement rates for CACFP At-Risk Afterschool meals/snacks and NSLP afterschool snacks are the same as CACFP reimbursement rates (listed in Table 7).

CACFP At-Risk Afterschool Meals and Snacks

The CACFP At-Risk Afterschool component was authorized as a demonstration project in 1994 (P.L. 103-448), expanded over time, and made available to all states by the HHFKA.²¹⁴ At-Risk Afterschool meal providers include the same types of institutions that are eligible to become CACFP centers (see the institutional eligibility rules in the "CACFP Centers" section); however, they do not need to operate the child/day care component of CACFP in order to operate the At-Risk Afterschool component. Additionally, At-Risk Afterschool providers must be located in the attendance area of a school in which at least 50% of children are eligible for free or reduced-price school meals.²¹⁵ The afterschool program must also have "an educational or enrichment purpose."²¹⁶ Unlike the traditional CACFP, which is available to children ages 12 and under, the At-Risk Afterschool component allows participation through age 18.

Participating institutions receive reimbursement for up to one snack and one meal (e.g., supper) per child daily, and meals and snacks are provided for free to all children. Meals and snacks must meet federal nutrition standards.²¹⁷ Institutions may operate the At-Risk Afterschool program in the after-school hours and on weekends, holidays, and breaks during the school year.

In FY2024, the CACFP At-Risk Afterschool component served a daily average of 2.7 million children.²¹⁸

NSLP Afterschool Snacks

The NSLP Afterschool Snack option was authorized in the 1998 child nutrition reauthorization act (P.L. 105-336). It allows NSLP-participating schools to receive federal reimbursement for one snack per child daily in eligible afterschool programs during the school year.²¹⁹ According to USDA guidance, eligible afterschool programs must provide "organized, regularly scheduled activities in a structured and supervised environment," including an educational or enrichment activity.²²⁰

Schools that choose to operate the NSLP Afterschool Snack component may do so in one of two ways: (1) like the CACFP At-Risk Afterschool component, if at least 50% of students in the school are eligible for free and reduced-price meals, the schools may provide free snacks to all children, or (2) if this criterion is not met, the schools may offer free, reduced-price, or full price snacks, based on household income eligibility (like the school meals programs). Historically, the vast majority of snacks provided through this program have been provided under the first option.²²¹ Snacks served through the NSLP Afterschool Snack component must comply with federal nutrition standards.²²²

The NSLP Afterschool Snack component serves 1.3 million snacks on average daily.²²³

Fresh Fruit and Vegetable Program (FFVP)

FFVP provides formula grants to states to fund fresh fruit and vegetable snacks in selected elementary schools.²²⁴ Under a statutory formula, about half the funding is distributed equally to each state and the remainder is allocated by state population. States must prioritize funding for schools with high proportions of students who are eligible for free or reduced-price meals. Schools must participate in NSLP in order to receive a FFVP grant. States set annual per-student grant amounts (between $50 and $75). Schools may provide fresh fruit and vegetable snacks to students at any time of day outside of the breakfast or lunch service.²²⁵ Schools offer snacks to all children in attendance (regardless of family income).

As noted previously, FFVP's funding structure differs from the other child nutrition programs. FFVP is funded by a mandatory transfer of funds from Section 32 of the Act of August 24, 1935. The authorizing law provided $150 million for school year 2011-2012, which is adjusted annually for inflation.²²⁶ For FY2025, FNS allocated approximately $232 million (including carryover funds) for FFVP to states.²²⁷

FFVP has been amended over time both by farm bills and by child nutrition reauthorization bills. FFVP was created by the 2002 farm bill (P.L. 107-171) as a pilot project. The 2004 child nutrition reauthorization act (P.L. 108-265) made the program permanent and provided funding for a limited number of states and Indian reservations. The 2008 farm bill (P.L. 110-246) expanded FFVP's mandatory funding through Section 32 and enabled all states to participate in the program. The 2014 farm bill (P.L. 113-79) essentially made no changes to FFVP but provided $5 million for a demonstration project to test offering frozen, canned, and dried fruits and vegetables in the program. Four states (Alaska, Delaware, Kansas, and Maine) participated in the pilot in school year 2014-2015 and an evaluation was published in 2017.²²⁸

Other Child Nutrition Activities

Federal child nutrition laws authorize, and child nutrition funding supports, several additional initiatives and activities, such as studies and evaluations, training and technical assistance, technology improvements, and food safety initiatives.²²⁹ Selected initiatives and activities are discussed below.

Farm to School Program

The farm to school program, which includes grants to organizations, technical assistance, and research, was authorized by the HHFKA in 2010.²³⁰ It expanded upon FNS's existing farm to school efforts, defined broadly as "efforts that bring regionally and locally produced foods into school cafeterias," with a focus on enhancing child nutrition.²³¹ The goals of these efforts include increasing fruit and vegetable consumption among students, supporting local farmers and rural communities, and providing nutrition and agriculture education. The farm to school program has mandatory funding of $5 million, which has been supplemented with discretionary funds in recent years.²³²

One component of the farm to school program is farm to school grants, which are awarded by FNS on a competitive basis to schools, nonprofit entities, and agricultural producers and processors for the purpose of establishing programs that improve schools' access to locally produced foods. They may be used for training, supporting operations, planning, purchasing equipment, developing school gardens, nutrition education, developing partnerships, and other activities.²³³ In FY2024, FNS awarded $14.3 million to 154 grantees, which were projected to serve more than 3,000 schools and 1.2 million students.²³⁴

In FY2022, FNS used American Rescue Plan Act of 2021 (P.L. 117-2) funding to provide an additional $60 million in non-competitive farm to school program funding to states for use over a four-year period. FNS distributed the funding using a formula based on states' NSLP participation.²³⁵

Institute of Child Nutrition

The Institute of Child Nutrition (ICN) provides technical assistance, instruction, and materials for nutrition and food service professionals and other local administrators of child nutrition programs on a variety of topics. The institute receives $5 million a year in mandatory funding appropriated in statute.²³⁶ It has also received additional discretionary funding in recent fiscal years.²³⁷ The institute is currently located at the University of Mississippi.

Team Nutrition

The Team Nutrition initiative supports federally and state-developed nutrition education and promotion initiatives. This includes grants for state agencies to develop programs to improve school meal quality, such as by training school nutrition professionals. From 2004 to 2018, Team Nutrition also included the HealthierUS Schools Challenge, which was a voluntary certification initiative designed to recognize schools that create a healthy school environment through the promotion of nutrition and physical activity.²³⁸

Healthy Meals Incentives Initiative

In 2022, USDA (during the Biden Administration) announced it would use $100 million in COVID-19 response funding under the Consolidated Appropriations Act, 2021 (P.L. 116-260) to implement a Healthy Meals Incentives Initiative.²³⁹ The initiative includes (1) grants for small and/or rural school food authorities to invest in staffing, training, and kitchen improvements, among other changes intended to improve nutrition in school meals;²⁴⁰ (2) School Food System Transformation Challenge grants to "stimulate innovation ... in the K-12 school food marketplace" through collaborative projects between school districts, food producers, suppliers, distributors, and/or community partners;²⁴¹ (3) nonmonetary recognition awards for school food authorities that have made significant improvements to nutrition in school meals;²⁴² and (4) summits for grant recipients to share best practices.

FNS contracted with four entities (Boise State University, the Chef Ann Foundation, Full Plates Full Potential, and the Illinois Public Health Institute) to carry out the School Food System Transformation Challenge grants and with Action for Healthy Kids to carry out the other three components of the initiative.²⁴³

Food Safety

Foods served in any child nutrition program must comply with state or local health, safety, and sanitation standards for food storage, preparation, and service. Schools participating in the school meals programs must obtain food safety inspections by a state or local government agency at least twice a year.²⁴⁴ There are also food safety inspections for USDA Foods.²⁴⁵ FNS also receives annual funding to carry out food safety training for state and local program operators.²⁴⁶

FNS Activities

Approximately $120 million was provided in FY2024 for FNS activities including technology, research, training and technical assistance, and payment oversight.²⁴⁷ This funding supports, for example, computer systems such as the USDA Foods ordering and purchasing application, FNS technical assistance, and guidance to states in implementing corrective actions to payment errors.²⁴⁸

Further Information

CRS reports:

• CRS In Focus IF10266, Child Nutrition Reauthorization (CNR): An Overview
• CRS In Focus IF11633, Summer Food for Children: An Overview of Federal Aid
• CRS Report R46681, USDA Nutrition Assistance Programs: Response to the COVID-19 Pandemic
• CRS Report R46888, Amending Eligibility Rules for Free and Reduced-Price School Meals: Background and Policy Options
• CRS Report R46371, Serving Free School Meals through the Community Eligibility Provision (CEP): Background and Participation
• CRS Report R47199, The School Foodservice Workforce: Characteristics and Labor Market Outcomes
• CRS Report R42353, Domestic Food Assistance: Summary of Programs
• CRS Report R45486, Child Nutrition Programs: Issues in the 115th Congress
• CRS Report R44373, Tracking Child Nutrition Reauthorization in the 114th Congress: An Overview
• CRS Report R41354, Child Nutrition and WIC Reauthorization: P.L. 111-296 (summarizes the Healthy, Hunger-Free Kids Act of 2010)
• CRS In Focus IF12193, Farm and Food Support Under USDA's Section 32 Account
• CRS Report RL33299, Child Nutrition and WIC Legislation in the 108th and 109th Congresses (summarizes the Child Nutrition and WIC Reauthorization Act of 2004)

Other resources:

• USDA-FNS website: https://www.fns.usda.gov
• The USDA-FNS page of the Federal Register: https://www.federalregister.gov/agencies/food-and-nutrition-service
• USDA-FNS Congressional Budget Justifications: https://www.usda.gov/about-usda/general-information/staff-offices/office-budget-and-program-analysis/congressional-justifications

Appendix A. A Brief History of Federal Child Nutrition Programs

This section provides a high-level summary of the federal child nutrition programs from their inceptions through 2010, when the most recent child nutrition reauthorization law was enacted.²⁴⁹

The Emergence of School Lunches and the National School Lunch Program

When the first federal aid for school lunches was provided in the 1930s, local school lunch programs were already operational in many cities and localities across the United States.²⁵⁰ Many of these early lunch programs were started by charitable women's organizations at the turn of the century in an effort to feed hungry children. Over time, they transitioned to school boards and school districts. These programs received a combination of private, local, and state funding.²⁵¹

The federal government became involved in school lunch programs during the Great Depression both as a way to feed hungry children and support the farm economy. Initially, federal aid was provided in the form of cafeteria equipment and labor. In 1932, the Reconstruction Finance Corporation began providing loans to states and school districts to cover the cost of cafeteria space and equipment for school lunch programs.²⁵² In 1935, the Works Progress Administration, a New Deal agency, began sponsoring women's employment in school lunchrooms. Federal food support for school lunches began that same year, when Section 32 of the Act of August 24, 1935 (P.L. 74-320) was enacted. The act provided 30% of customs receipts to USDA to purchase surplus commodities from farmers impacted by the depression. These commodities were donated through various outlets for domestic consumption, including school lunch programs.

With commodity aid came the first federal regulations for school lunch programs. USDA required recipient organizations, through their agreements with state agencies, to operate school lunch programs on a nonprofit basis, maintain any existing local funding for school lunches, keep records of foods received, serve meals free to poor children, and ensure that such children would not be identified to their peers, among other requirements.²⁵³

The availability of federal aid contributed to a rapid increase in the number of school lunch programs. However, in 1943, federal commodity aid declined as Section 32 surplus commodities were diverted to feed U.S. armed forces in World War II. In addition, federal support for lunchroom labor disappeared with the elimination of the Works Progress Administration.²⁵⁴ In the midst of declining aid, Congress provided the first cash assistance—$50 million in Section 32 funds—for "a school milk and lunch program" in the 1944 Department of Agriculture Appropriation Act (P.L. 78-129). The introduction of cash assistance marked a shift in the lunch program.²⁵⁵ For the first time, schools could purchase their own foods in addition to receiving federally purchased commodities.

Annual appropriations acts continued cash support for school lunches until 1946, when the National School Lunch Act (P.L. 79-396) was enacted. Signed into law on June 4, 1946, by President Truman, the National School Lunch Act permanently authorized appropriations of "such sums as may be necessary" for the National School Lunch Program. (The act would later be renamed the "Richard B. Russell National School Lunch Act," recognizing Senator Russell's role in the passage of the legislation and his earlier support for the school lunch program within New Deal programs and during his tenure as the Chairman of the Agriculture Appropriations subcommittee.²⁵⁶) The law required participating schools to serve lunches for free or at a reduced price to students who were deemed by local school authorities as unable to pay the full cost of a lunch. Funds were to be distributed to states based on the number of school-aged children in the state and the state's need, as measured by per-capita income, and states were to match federal funds dollar-for-dollar. States were to distribute funding on a monthly basis to schools based on the number of meals served that met "minimum nutritional requirements prescribed by the Secretary on the basis of tested, nutritional research" (P.L. 79-396).²⁵⁷ Cash assistance could not be used for cafeteria equipment, and separate funds were authorized for this purpose ($10 million annually); however, Congress subsequently prohibited appropriations for equipment assistance from FY1948 to FY1967.²⁵⁸

NSLP remained relatively unchanged from 1946 to 1960. However, during this timeframe, concerns emerged over the funding formula. One concern was that the formula prioritized funding for schools with large numbers of school-aged children rather than actual participants in the program. There was also concern that schools with high proportions of needy children received the same amount of aid as those with wealthier families, even though they had to serve a larger number of meals for free or at a reduced-price.²⁵⁹ In 1962, P.L. 87-823 changed the funding formula to be based on the number of school lunches served in the state in the preceding school year instead of the number of school-aged children. The law also authorized additional "special assistance" for state-selected schools in poor economic areas (however, special assistance was not funded until 1966).²⁶⁰

Other notable changes to NSLP occurred in the 1970s. In 1970, P.L. 91-248 extended special assistance to all schools participating in NSLP.²⁶¹ The law also reduced the state matching requirement and established the first national eligibility guidelines for free and reduced-price meals at 100% of the federal poverty level (later in the decade increased to 125% for free lunches and 195% for reduced-price lunches). In 1971, another significant change occurred with the enactment of P.L. 92-153, which guaranteed states a certain level of federal cash assistance by specifying average per-meal reimbursement rates for free, reduced-price, and paid lunches.²⁶²

The Addition of Other Child Nutrition Programs

In the 1960s, federal child nutrition efforts expanded beyond school lunches.²⁶³ On October 11, 1966, the Child Nutrition Act of 1966 (P.L. 89-642) was enacted.²⁶⁴ It formally authorized the Special Milk Program (SMP) and authorized the School Breakfast Program (SBP) as a pilot program. The SMP was based on predecessor USDA school milk programs that had operated since the 1940s.²⁶⁵ SBP was a newer concept that USDA had piloted in the 1965-1966 school year.²⁶⁶ In a House Agriculture Committee hearing on the Child Nutrition Act, then-Secretary of Agriculture Orville L. Freeman testified that

These proposals will permit us to begin a comprehensive effort to broaden child nutrition programs in this country. They are based on what we have learned in 20 years of administration of the National School Lunch Act, and they reflect a careful assessment of gaps which now exist in the nutritional needs of children in this country.²⁶⁷

The SMP provided reimbursements for milk in schools, nonprofit child care centers, summer camps, and other nonprofit institutions. At the time, schools and institutions could participate in both SMP and NSLP. Meanwhile, SBP was authorized for two fiscal years and required states to prioritize funds for "schools drawing attendance from areas in which poor economic conditions exist and to those schools to which a substantial proportion of the children enrolled must travel long distances daily" (P.L. 89-642).²⁶⁸ (Congress later expanded priority to include "schools in which there is a special need for improving the nutrition and dietary practices of children of working mothers and children from low-income families" (P.L. 92-32).) The Child Nutrition Act of 1966 also gave the Secretary the authority to provide higher reimbursements to schools with "severe need." Like NSLP, the law specified that breakfasts "meet minimum nutritional requirements prescribed by the Secretary on the basis of tested nutritional research," and be served for free or at a reduced price to children unable to pay the full price of a meal, as determined by local school authorities (P.L. 89-642).

In 1968, child nutrition efforts were further expanded with the authorization of the Special Food Service Program for Children (SFSPC), a pilot program to fund meals in summer and child care settings (P.L. 90-302). SFSPC provided the first federal assistance for summer meals for children and the first dedicated assistance for meals served in child care settings.²⁶⁹ Similar to SBP, SFSPC was targeted to areas with poor economic conditions and a high number of working mothers.

In 1975, the program was split into the separate Child Care Food Program (CCFP) and the Summer Food Service Program (SFSP) (P.L. 94-105). CCFP was open to public and nonprofit institutions that met child care licensing or other official child care standards, while SFSP retained a focus on institutions in low-income areas.²⁷⁰ Meals were provided for free to all children at SFSP sites, whereas CCFP conducted free and reduced-price eligibility determinations like NSLP.

1980 to 2010

The long-standing growth of child nutrition programs was contrasted with budget cuts in the early 1980s, which were part of larger efforts to reduce federal domestic spending.²⁷¹ The Omnibus Reconciliation Act of 1980 (P.L. 96-499) reduced FY1981 funding for child nutrition programs by approximately $400 million (9%) of the child nutrition budget.²⁷² The law achieved savings by lowering reimbursement rates in the programs and eliminating commodity assistance for breakfast, among other changes.²⁷³ Larger spending cuts followed with the Omnibus Reconciliation Act of 1981, which made changes that collectively cut $1.4 billion (25%) of the child nutrition budget (Title VIII of P.L. 97-35).²⁷⁴ Many of the policy changes made by the law remain in place today. For example, the law restricted eligibility from 195% of poverty to 185% of poverty for reduced-price meals and set eligibility at 130% for free meals in the NSLP, SBP, and CCFP. It also raised allowable charges for reduced-price lunches from 20 cents to 40 cents and for reduced-price breakfasts from 10 cents to 30 cents.²⁷⁵ In a major change to SMP, the law excluded schools/institutions that participated in another child nutrition meals program from participating in SMP—cutting SMP's budget by 77%.²⁷⁶ In CCFP, the law restricted participation from children ages 18 and under to children ages 12 and under, and reduced the maximum number of reimbursable meals from three meals and two snacks per child daily to two meals and one snack per child daily. The law also eliminated equipment assistance for school meals.

Child nutrition programs were subsequently excluded from budget deficit reduction measures in the late 1980s and 1990s, and new policies led to the expansion of the programs during this timeframe.²⁷⁷ For example, amendments to the programs in these years authorized start-up grants for school breakfast programs, expanded CCFP to adult day care centers (and renamed it(?) the Child and Adult Care Food Program, or CACFP), and provided new funding for afterschool snacks through NSLP and CACFP.²⁷⁸ But what had potentially the longest-term impact on expansion was a policy change intended to reduce paperwork in the school meals programs: automatic (categorical) eligibility for free meals for children in food stamp (now SNAP) and Aid to Families with Dependent Children (now TANF) households, which was enacted in 1986—and direct certification of such children for free meals without household applications, which was enacted in 1989.²⁷⁹

Other policies in the late 1980s and 1990s focused on improving program integrity. The 1989 child nutrition reauthorization (P.L. 101-147) required USDA to create a standardized process through which states would review school food authorities' administration of NSLP and SBP (known as administrative reviews).²⁸⁰ In CACFP, following USDA Office of the Inspector General (OIG) audits in the 1990s that found instances of abuse and mismanagement, the Agricultural Risk Protection Act of 2000 (P.L. 106-224) made a number of changes aimed at improving program integrity in CACFP.²⁸¹ The act required CACFP sponsors to conduct more frequent and unannounced site visits of sponsored centers and homes, restricted nonprofit institutions' eligibility to those with tax-exempt status, and excluded institutions deemed ineligible to participate in any other public program based on violations of program requirements. Other legislation was aimed at improving program integrity in the school meals programs.

Program integrity continued to be a focus in the 2004 child nutrition reauthorization (P.L. 108-265), which made changes to school food authorities' verification of household applications for free and reduced-price meals. Specifically, the law set a sample size of applications that schools must review, established a focus on "error-prone" applications (applications near the income eligibility thresholds), and authorized direct (automatic) household application verification processes.²⁸² In addition, the law required states to conduct additional administrative reviews of school food authorities with a high level of administrative error or risk of error.²⁸³

The 2004 child nutrition reauthorization also continued the expansion of free school meals to new categories of children. Specifically, the law extended categorical eligibility and direct certification for free school meals to homeless children, migrant children, and children served under the Runaway and Homeless Youth Act.

The most recent child nutrition reauthorization as of the cover date of this report was the Healthy, Hunger-Free Kids Act of 2010 (HHFKA; P.L. 111-296). The HHFKA continued the expansion of school meals in a few ways. It made foster children categorically eligible for free school meals, and allowed direct certification of such children. It also included a pilot project for direct certification (but not categorical eligibility) of children in Medicaid households for free and reduced-price meals based on an income test. In addition, the HHFKA created the Community Eligibility Provision (CEP), through which eligible schools can provide free meals to all students.

As discussed in this report, the HHFKA also made changes to nutritional requirements in the school meals programs and CACFP. Specifically, the law required USDA to update the nutrition standards for school meals within a certain timeframe and align the standards with the Dietary Guidelines for Americans (per an existing statutory requirement).²⁸⁴ The law also required USDA to issue new nutrition standards regulating all foods sold on school campuses during the school day ("competitive foods"). (Previous standards applied only to competitive foods sold during meal service.) In addition, the HHFKA required USDA to update the nutrition standards for CACFP meals and snacks within a certain timeframe and align them with the Dietary Guidelines for Americans.²⁸⁵