Schools, states, and researchers use federal data on students’ eligibility for free and reduced-price meals (FRPM) as a proxy for how many students live in households with relatively low incomes. Policymakers then use this proxy to allocate state funding and for accountability purposes, while researchers use it to study certain policies’ effects on students from economically disadvantaged backgrounds.
But recent changes to the national school lunch program, pandemic disruptions, and growing variation in how states report FRPM data have weakened FRPM eligibility as a proxy for student economic need.
Further, changes to the Supplemental Nutrition Assistance Program and Medicaid made in the One Big Beautiful Bill Act could make FRPM even less reliable as a proxy measure, as free school meal access has become increasingly intertwined with social safety net programs.
To get a more accurate read of individual student economic need, state policymakers can move to measures independent of FRPM data, such as state income tax data or an index based on Census Bureau data that captures students’ residential neighborhood characteristics. Researchers looking to evaluate policy changes can consider using new proxy measures, such as the Urban Institute’s Model Estimates of Poverty in Schools (MEPS 2.0), for school-level analyses that are across states or over time.
Changes to the national school lunch program and pandemic disruptions made it more difficult for schools to collect and report accurate data
Schools report the share of students with low incomes to state and federal governments using two types of data:
- total FRPM data, which capture students from households with incomes up to 185 percent of the federal poverty level
- direct certification data, which reflect students who were automatically certified for FRPM via their participation in social safety net programs
But the share of K–12 students eligible for FRPM has increased substantially in the past 15 years, even as overall poverty rates among children have decreased. In 2024, about 72 percent of school meals served were FRPM, compared with 63 percent in 2009.
Some of the growing challenges in reporting student need are linked to the expansion of free school meal programs.
The Healthy, Hunger-Free Kids Act of 2010 introduced the Community Eligibility Provision, which provides universal free meals for students in schools with higher shares of students eligible for free meals. The Community Eligibility Provision aimed to reduce the administrative burden of collecting FRPM forms, eliminate the stigma of receiving a free meal, and provide meals for students who are eligible but unidentified by the school. These universal free school meals have been associated with a range of positive academic, behavioral, and health outcomes for students, including those ineligible for free meals based on their family’s income.
But because Community Eligibility Provision schools don’t collect traditional meal applications, some schools misreport the number of students eligible for free meals to the US Department of Education, beginning in the pilot years of the provision (2011–12 through 2013–14).
Child Nutrition Program waivers, which provided more than 3 billion lunches to children during the first pandemic school year, exacerbated FRPM reporting issues from July 2020 through September 2022, when all schools were able to provide meals to all children at no cost. It became even more difficult for schools to collect forms when students were learning remotely and all children were already receiving meals for free.
FRPM data no longer capture student economic need consistently across schools and over time
Data from US Department of Education’s Common Core of Data (CCD) and the American Community Survey (ACS) demonstrate a growing divergence between students’ eligibility for FRPM as reported by schools and poverty estimates for children enrolled in public schools. Starting in 2016 –17, states could report to CCD either the total number of students eligible for FRPM, the total number of students who were directly certified, or a combination of the two.
Among 16 states that consistently reported the total number of students eligible for FRPM up to 2024, ACS poverty shares declined by 8 percentage points from 2010 to 2024, while FRPM eligibility increased by 8 percentage points.
By 2024, FRPM eligibility exceeded ACS poverty estimates by roughly 25 percentage points, versus 9 points in 2010.
Further, the availability of FRPM eligibility data has declined, because for about a decade, states have had the option to report direct certification numbers alongside or instead of total FRPM data.
From 2010 to 2015, roughly 90 to 95 percent of schools reported FRPM data to the CCD, as it was the only option available. When states were given flexibility in reporting either total FRPM or direct certification in 2016–17, FRPM reporting declined.
Then, during the first pandemic school year, child nutrition waivers reduced reliance on household applications, further driving down FRPM reporting.
By 2024, approximately three-quarters of schools reported FRPM data, while roughly half reported direct certification data.
In 2024, fewer than half of states reported both metrics for 85 percent or more of schools. Five states reported direct certification only for most schools, and 15 reported FRPM data only.
What measures can policymakers and researchers use to better assess student economic need?
To get a more accurate read of individual students’ economic needs, policymakers could look to student poverty measures that rely less on federal school lunch and social safety net changes. New measures of poverty are particularly valuable if they are consistent across states and over time.
Instead of FRPM or direct certification data, policymakers can work together with researchers to explore alternative measurements for student economic need:
- Use students’ residential neighborhood characteristics to create an “at-risk” index. The American Community Survey’s data on socio-economic characteristics can be matched to students’ residential neighborhood. States could define which socio-economic characteristics make up those at risk and identify tiers of need within the index. Colorado, Texas, and Maryland have already incorporated similar census measures.
- Link students to their households’ reported tax income through state tax data, as New Mexico does. This option, however, is limited to states with state income tax data.
Researchers can also:
- Harness statistical proxy measures, such as MEPS 2.0, for school-level analyses of student poverty across states and over time.
- Use the Census Bureau’s Small Area Income and Poverty Estimates data for district-level analyses, keeping in mind that this would measure poverty for all students living in a geographic school district rather than just public school children.
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