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As CEP Participation Changes, Is Your District Ready for What Comes Next?

Falling SNAP enrollment is changing the CEP math for districts across the country. Here’s how to prepare your team, your families, and your meal application process.

When USDA lowered the Community Eligibility Provision’s identified student percentage (ISP) threshold from 40% to 25% in 2023, more schools gained the option to provide breakfast and lunch at no cost to all students. For districts and families, that created a meaningful opportunity to expand meal access and simplify school nutrition operations.

Why the CEP Math is Changing
But qualifying for CEP and making it financially sustainable are two different considerations. The eligibility threshold decreased, while the reimbursement multiplier remained at 1.6—the maximum federal law allows and a figure only Congress can change. At a 25% ISP, for example, only 40% of meals are reimbursed at the federal free rate; the remaining 60% receive the lower paid rate, even though every student eats at no charge.

In 2026, declining SNAP enrollment has added another layer of complexity. States including Florida, Texas, Kentucky, Arizona, and others have announced changes to universal free meal programs amid falling assistance enrollment and shifting student demographics. Because direct certification draws on SNAP and, in many states, Medicaid data, enrollment changes in those programs can affect a school’s identified student percentage—and, ultimately, its CEP eligibility or financial viability. Circumstances vary by district.

The 25% eligibility threshold has not changed. However, as districts approach the end of their four-year CEP cycles, updated identified student percentages can change the reimbursement available for the next cycle. For schools electing or renewing CEP, the ISP is based on data as of April 1, so the snapshot that shapes the 2027–28 school year is April 1, 2027. Schools whose ISP falls below 25% but stays at or above 15% in year four may qualify for a one-year grace period. Some districts may continue CEP districtwide, others may keep it at selected schools, and others may return to collecting meal applications.
Families May Still Qualify, Even Without Direct Certification

For schools returning to standard meal eligibility procedures, one message is especially important: a student who is not directly certified may still qualify for free or reduced-price meals through a household application based on income and household size. Families should not assume that losing SNAP or Medicaid benefits, or not receiving an automatic eligibility notification, means they can’t receive meal assistance.


For a household of four, the 2026–27 income guidelines allow families earning $42,900 or less per year to qualify for free meals, and $61,050 or less for reduced-price meals.


After years without meal applications, families may need clear instructions about what has changed, who should apply, and where to find help. Without that preparation, eligible families may miss assistance, staff may face a rush of questions, and districts could see unpaid meal balances grow. Software can support the process, but successful outreach requires people, communication, and follow-through.

Start Planning Before the Transition
Now is the time to evaluate your district’s application process and the software supporting it. Bring nutrition services, technology, business office staff, school offices, and communications teams into the conversation. Together, consider:

  1. Can parents easily find and complete an online meal application?

  2. How will staff manage direct certification alongside income-based applications?

  3. If CEP participation differs by school, how will families receive the correct instructions

  4. Where needed, how will CEP schools collect separate household income surveys? These support other funding or reporting needs; they don’t determine whether students receive free meals under CEP.

  5. Who will train staff, answer family questions, and follow up on incomplete applications?
Choosing software is a group effort. Evaluating your options early gives your team time to confirm workflows, prepare staff, and communicate with families before the next school year begins.
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Sources
  • USDA Food and Nutrition Service, Community Eligibility Provision final rule, September 2023.
  • Education Week, “Some Schools Stop Free Meals for All as SNAP Enrollment Falls,” August 2026.
  • NPR, “As millions of kids lose SNAP food benefits, free school meals are also at risk,” September 2026.
  • USDA Child Nutrition Programs Income Eligibility Guidelines, 2026–27.

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