Changes in Free/Reduced-Priced Lunch as a Measure of Student Poverty

October 26, 2015

By Dan Forsberg

Measuring the impact of poverty or low-income status on educational outcomes is vital for the creation and evaluation of education policy. Historically, student eligibility for free/reduced-price lunch (FRL) served as a proxy for individual student/family income status. However, due to the recent expansion of the National School Lunch Program’s Community Eligibility Provision (CEP), FRL is no longer an accurate measure of student income status. This education update provides an evaluation of FRL as a measure of student poverty and discusses alternative measures of student poverty for the purpose of data analysis and policy evaluation.

The National School Lunch Program and Free/Reduced-Price Lunch (FRL)

The National School Lunch Program (NSLP) is a federally-administered meal program through the U.S. Department of Agriculture (USDA) Food and Nutrition Service operating in over 100,000 public, non‐profit private schools, and residential child care institutions. In 2013, NSLP provided low‐cost or free lunches to nearly 31 million children.[1] In participating schools, eligibility is determined by family income, as shown in the following table

Table 1: FRL Eligibility

Free Lunch

Reduced-Price Lunch

Full-Price Lunch

Family Income as  % of Poverty Level:

Annual Family Income Less Than 130%

Annual Family Income Between 130% and 185%

Annual Family Income Greater Than 185%

Family Income in Dollars*:

Annual Family Income Less Than $32,737

Annual Family Income Between $32,737 and $44,862

Annual family Income  Greater Than $44,862

Source: Retrieved October 25, 2015, from

*Family Income measured in 2015 dollars, as reported by the Center for Medicaid and CHIP services.
Source: Retrieved October 25, 2015, from  

FRL eligibility status is often included in research as an indicator of poverty.  Currently, FRL status is included in several accountability measures in Georgia.  For example, the Georgia Department of Education’s (GaDOE) College and Career Ready Performance Index (CCRPI) serves as the statewide accountability measure for public schools.[2]  In the “Challenge Points” component of this index, schools earn points for strong performance of economically disadvantaged students, as measured by FRL status.  The Georgia State Charter Schools Commission (SCSC) also includes FRL status in the value-added model used to analyze state charter school performance.[3]

Understanding the Need for Alternative Poverty Measures

In order to qualify for the free/reduced-price lunch program, parents/legal guardians are required to report family income by submitting an NSLP application. However, following the introduction of the Community Eligibility Provision (CEP) in Georgia during the 2013-2014 school year, schools with at least a minimum of 40% directly certified students (defined below) can opt to provide free meals for all of their students each school year.[4] CEP can also be applied to schools at the district-level, as well as to groups of schools within a district. For example, a school with 0% directly certified students is eligible for CEP if the school is part of a district with at least 40% directly certified students. After qualifying for CEP, schools are no longer required to collect NSLP parent/guardian applications.[5] As a result, the FRL designation at the student level is not collected in CEP schools. 

Table 2: Definition of Directly Certified

As measured under the CEP, directly certified students fall into at least one of the following categories:

  1. Lives in a family unit receiving Supplemental Nutrition Assistance Program (SNAP) food stamp benefits,
  2. Lives in a family unit receiving Temporary Assistance for Needy Families (TANF) benefits, or
  3. Identified as homeless[6], unaccompanied youth[7], foster[8], or migrant.[9]

Many state agencies, including the Georgia Department of Education (GaDOE) and the Governor’s Office of Student Achievement (GOSA), still report the percentage of students that qualify for free/reduced-price lunch at the school-, district-, and state-levels.  Because the agencies do not have FRL information at the student level for CEP schools, CEP schools are reported as having 100% FRL students. As a result, many CEP schools appear to have a greater percentage of economically disadvantaged students than is actually the case. 

For example, in the school district below, 40% of students are directly certified in 2013-2014, and the district has opted to be a CEP school district in 2014-2015.  Because the district collected NSLP applications and direct certification data in 2013-2014, it provided a count of students who qualified for free/reduced-price lunch for that school year. 

Table 3: Reported Percentage of FRL Students in Example District in 2013-2014

% Directly Certified

% FRL in 2013-2014

% FRL in 2014-2015, under CEP

School A




School B




School C








However, after the district opted into the CEP, it no longer collected NSLP applications in the 2014-2015 school year.  As a result, each school in the district is reported to have 100% economically disadvantaged students. 

Alternative Measures

As more schools participate in CEP, the overrepresentation of FRL students at the school level will intensify. According to GaDOE, 587 schools, or roughly 30%, of Georgia public schools are CEP schools, and 72 of 180 districts have at least one CEP school.[10]

Given that FRL is no longer a reliable measure of economically disadvantaged students, there is a need for an alternative measure of student poverty that provides an accurate representation of student poverty at all levels: student, school, district, and state.  Unfortunately, many measures of student poverty are not available at the student level or would require significant burden on schools to collect the information.  For example, the US Census Bureau produces Small Area Income & Poverty Estimates (SAIPE), which measure the percentage of children in a school district that are living in poverty.[11]  However, this measure is not available on the school-level, which makes the incorporation into school-level accountability measures, such as the CCRPI,  not feasible.  Further, SAIPE estimates measure the students who live in the district whether or not they attend a public school in the district. Another alternative is to gather data directly from parents and students, such as household income or the highest level of parental education. However, this option would require significant effort for state and local school districts to collect this information.

One option that holds promise is the use of the percentage of students who are “directly certified.”  Some advantages and challenges of using directly certified student data to measure student poverty are included below: [12]

  • Direct certification provides an apples-to-apples comparison of poverty status in all schools and districts because it does not over-identify students CEP schools. As such, this measure would provide consistent estimates of poverty in school accountability measures, such as GaDOE CCRPI and Beating the Odds analysis.
  • GaDOE already receives CEP eligibility data from the Department of Human Services for School Nutrition purposes. As such, districts are already familiar with it and gathering these data does not create additional administrative burden.
  • Significantly fewer students qualify for direct certification than FRL.  In 2013-2014 school year, 62.5% of Georgia public school students qualified for FRL, while 34.8% were directly certified.[13]
  • Students whose families do not submit applications for SNAP or TANF are counted in direct certification even though they would otherwise be identified as low-income.  However, this is also true of FRL in non-CEP schools because students must turn in the NSLP application in order to qualify.
  • Cross-state comparisons are difficult because TANF and SNAP have different standards for eligibility and acceptance across states.[14]


Due to the increasing number of CEP schools, the use of free/reduced-price lunch is no longer a viable measure of individual-level student poverty.  GOSA is working with GaDOE to identify an alternative measure that meets the needs of Georgia students. The use of directly certified students may be the most plausible alternative for research, policy evaluation, and accountability purposes.



[1] Source:



[2] For more information on the value-added model and state charter school accountability, visit the SCSC website.



[3] For more information on the CCRPI, visit the GaDOE website.



[4] The CEP was authorized in 2010 and phased in over a period of three years.  It was implemented for the first time in Georgia in 2013-2014 and is available nationwide beginning July 1, 2014.  



[5] In fact, reducing administrative burden by eliminating these NSLP forms is touted as a benefit of the CEP. Retrieved from the USDA Food and Nutrition Service October 26, 2015.



[6] The Runaway and Homeless Youth Act (RHYA) defines homeless youth as individuals who are “ less than 21 years of age for whom it is not possible to live in a safe environment with a relative; and who has no other safe alternative living arrangement.” Click here for more information.

[7] The Free Application of Federal Student Aid (FAFSA) defines unaccompanied youth as “a student less than 21 years of age [who] is not living in the physical custody of his/her parent or guardian.” 

[8] The Internal Revenue Service (IRS) defines a foster child as “an individual who is placed with a foster family home by an authorized placement agency or by judgment, decree, or other order of any court of competent jurisdiction. Click here for more information.

[9] The National Center for Homeless Education defines a migrant child as “an child under 21 years of age who works, or whose parents work, in the agriculture, dairy, or fishing industry and who has made a qualifying move in search of work within the previous 36 months.” Click here for more information.

[10] To view these numbers, click  on the link for the Excel spreadsheets at the bottom of this page:….

[11] For more information, click here.

[12] For further reading, a report on measuring student poverty written by the National Center for Educational Statistics entitled “The Forum Guide to Alternative Measures of Socioeconomic Status in Education Data Systems” can be downloaded on their website. Click here for more information.

[13] FRL percentage is from GOSA Report Card.  Direct certification data provided by GaDOE

[14] Click here to see differences in TANF and SNAP Eligibility by state