November 13, 2026
Written by Tara Thomas, AESA Senior Government Affairs Manager
This week, the Department of Agriculture (USDA) issued a proposed rule to limit broad-based categorical eligibility, which allows states to streamline applications for the Supplemental Nutrition Assistance Program (SNAP) based on enrollment in other means-tested programs.
USDA estimates that this rule would result in 3.2 million households losing access to SNAP benefits, which would also reduce direct certification for school meals. USDA estimates that 1.78 million children would no longer be categorically eligible (i.e., directly certified) for free or reduced-priced meals as a result of this rule. Although roughly 97% of these students are estimated to retain eligibility, districts would have to rely on Free and Reduced-Priced Meal (FRPM) applications to recapture families—increasing the administrative burden on schools to ensure the impacted students remain enrolled in the program.
A decline in direct certification data will also impact districts’ ability to participate in the Community Eligibility Provision (CEP), a federal program that allows high poverty schools to serve meals for all students at no cost. Direct certification data determines both eligibility and reimbursement rates for districts, so a decline could mean districts lose access to this option.
This proposed rule is in addition to the SNAP changes that Congress passed as part of H.R. 1, the One Big, Beautiful Bill Act of 2025. The Center on Budget and Policy Priorities estimates that 2 million children have already lost access to SNAP as a result of these changes. As a result, some school districts have already reported a withdrawal from CEP. This rule, if finalized, would exacerbate this issue by further reducing enrollment in SNAP and decreasing the number of students who are directly certified.