POLICY BRIEF
November 2024

School Meal Participation Before and After State and Federal
Policy Changes in Arizona
Shreya Raval, MS, Sarah Martinelli, MS, RDN, Punam Ohri-Vachaspati, PhD, RD
College of Health Solutions, Arizona State University

KEY FINDINGS

•

In Arizona, the policy to eliminate reduced-price
co-pays for school meals was implemented in
January 2023. Subsequently, two additional federal
policies were implemented to improve access to
school meals: Medicaid Direct Certification in
August 2023, and Community Eligibility Program
(CEP) expansion in January 2024.

•

On average, 1.4 million additional free breakfast
and lunch meals were served per month when the
state and federal policies were implemented. In a
similar comparison, the average daily participation
rate in school lunches increased by 8%.

•

Initially, the average daily participation rate for
reduced-price lunches showed a notable increase
after the Arizona policy to eliminate the reducedprice co-pay for families was implemented,
highlighting the impact of the policy.

•

Subsequently, after the implementation of
Medicaid Direct Certification and CEP expansion
polices, average meals served in the reducedprice category dropped, while the number of
meals served in free category continued to grow.
The reduction in reduced-price category can be
attributed to more students becoming eligible for
free meals because of the federal policies, thereby
reducing the cost to the state as more meals were
covered by federal reimbursement.

•

The combination of state and federal policies
has increased access to healthy school meals
for Arizona students. While additional federal
policies (Medicaid Direct Certification and CEP
expansion) provide free meals to more Arizona
students, state funds are necessary to support
students in the reduced-price meal category,
specifically those attending schools that do not
participate in the CEP program.

INTRODUCTION
In Arizona, the National School Lunch Program
(NSLP) and the School Breakfast Program (SBP) provide
nutritionally balanced low- or no-cost meals to 550,000
and 250,000 students, respectively, each day.1 School
meals are funded primarily through the United States
Department of Agriculture (USDA) using the “threetiered system”, where families must submit income
applications each year and based on those applications
students from the lowest income families (below 130%
of the federal poverty line (FPL)) receive meals for free,
those from families with incomes between 130-185% of
the FPL receive meals at a reduced-price, while others
pay full price for the meals at subsidized rates (Box
1). Schools get reimbursement for meals based on the
number of breakfasts and lunches served in each of the
three categories.

Box 1

School Year 2024– 25 USDA Income Eligibility
Guidelines for the Three-tiered System for a
Family of Four
•

Free meals: Annual income < $40,560 (no cost to
families)

•

Reduced-price meals: Annual income $40,561 $57,720 (families pay $0.40 for lunch and $0.30 for
breakfast)

•

Paid meals: Annual income >57,720 (families pay
full price for breakfast and lunch, meal prices are set
at the district level, average cost for breakfast and
lunch are $1.75 and $3.00, respectively)

POLICY BRIEF

|

NOVEMBER 2024

|1|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

Since 2014, schools across the nation have had the
opportunity to participate in the USDA’s Community
Eligibility Provision (CEP), another federally funded
program, which allows schools serving a high proportion
of low-income students to offer no-cost meals to all
enrolled students. Schools participating in CEP do not
need to collect individual income applications from
families or track individual student eligibility in the
cafeteria, saving time for both families and school staff.

The objective of this study, conducted by the ASU
Food Policy and Environment Research Group, was to
examine the impacts of the state policy to cover family
co-pays for reduced-price meals and the two federal level
policy changes (1) Medicaid Direct Certification and (2)
CEP expansion on school meal participation in Arizona.

In March of 2020, at the start of the COVID-19 pandemic,
the USDA issued a series of waivers2 to make it easier for
students to access school meals during school closures.
One key waiver created a temporary federal Healthy
School Meals for All (HSM4A) program, also referred
to as Universal Free Meals (UFM) program, that allowed
schools to serve all students meals at no charge without
collecting individual income applications. However, at
the end of the federal public health emergency in the
fall of 2022, the federal HSM4A program ended and
schools in most states returned to the three-tiered system
or CEP.

To examine the impact of state and federal policy
implementation on school meal participation, data were
collected starting in August 2022, when the federal
HSM4A program ended, through May 2024. Based on
the timeline of policy implementation, the study was
divided into four distinct time periods (T1-T4) outlined
in Box 2.

Since 2022, drawing on the successful implementation
of HSM4A during the pandemic, there have been
several policy interventions aimed at improving access
to school meals. A handful of states allocated funds to
supplement federal school meal funding to keep meals
free for all students. While Arizona did not implement
a HSM4A program, starting in January 2023, the
state expanded access to free school meals to students
eligible for reduced-price meals by eliminating their
co-pays ($0.30 for breakfast and $0.40 for lunch) using
federal pandemic relief funds.3 This policy was extended
through June 2025 with support from the Arizona state
budget.4
Starting in the fall of 2023, Arizona capitalized on a
federal program known as the USDA Medicaid Direct
Certification Demonstration Project,5 a pilot program
that allows schools to categorically qualify students
for free meals if their families participate in the state
Medicaid program. Finally, during the 2023–24 school
year, the USDA announced changes to CEP6 that
allowed more schools to participate in the program.i
Since this change in CEP policy was announced during
the school year, after the typical application deadlines for
schools had passed, schools were allowed to enroll into
CEP mid-year.

METHODS

Our analysis included all public, private and charter
schools in Arizona that operated NSLP (n=1,771). Data
on CEP participation status, total meals served (breakfast
and lunch) across all categories (free, reduced-price,
and paid), students’ eligibility for each category, and
school operational days were sourced from the Arizona
Department of Education.

Box 2

Study Time Periods and Policies Implemented
•

T1: Aug– Dec 2022: Post-COVID, three-tiered
system in place

•

T2: Jan– May 2023: Arizona reduced-price co-pay
policy implemented

•

T3: Aug– Dec 2023: Arizona policy with Medicaid
Direct Certification

•

T4: Jan– May 2024: Arizona policy with Medicaid
Direct Certification and CEP expansion/mid-year
enrollment

POLICY BRIEF

|

NOVEMBER 2024

|2|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

To analyze the impact of policies on school meal
participation, two outcome measures were used to
describe school meal participation 1) average daily
participation (ADP) rate and 2) average number of total
meals served per month.
ADP for a specific meal category (free, reduced price,
paid) was calculated by dividing the total number of
meals served in that category during a given time period
by the number of operational school days in the same
period. Next, ADP rate for a specific category (free,
reduced price, paid) was calculated by dividing the ADP
for that category by the number of eligible students in
the specific category and multiplying by 100. ADP rate is
interpreted as the proportion of students in a particular
eligibility category participating in school meals. For
example, an ADP rate for the free NSLP meal category
of 70 means that on average 70% of the students eligible
for free meals participate in NSLP. An example of the
ADP Rate calculation for the free category is provided
in Box 3.
Average number of total meals served per month was
calculated by dividing the total number of meals served
during a study time period by five (each time period
captured data spanning a five-month period).

To assess the policy impacts on school meal participation,
we compared the outcome measures (ADP rate and
average number of total meals served per month)
two ways: 1) separately across all four time periods
representing different policy implementation phases
and 2) by comparing the “pre-policy period” (T1) when
Arizona schools returned to pre-pandemic three-tiered
or CEP funding models with the “post-policy period”
(T2 – T4), which included the implementation of the
three policies: (a) the sate reduced-price co-pay policy, (b)
the federal Medicaid Direct Certification, and (c) CEP
expansion/mid-year enrollment.

Box 3

Calculation of ADP rate for free meals
category
•

ADP (Free) = Total number of free meals served
Number of operational school days

•

ADP Rate (Free) = ADP (Free) *100
Number of students eligible for free meals

RESULTS
The impact of state and federal policy implementation on Community Eligibility Provision
participation in Arizona schools
Total number of schools participating in CEP increased across the four study periods
Figure 1: Total Number of CEP Schools in
Arizona Across All Study Periods
750

456

462

482

T1

T2

T3

Figure 1 presents the number of CEP-participating
schools in Arizona across the four study periods. At
T4, there was a 64% increase in the number of CEPparticipating schools compared to T1, increasing
from 456 to 750 schools statewide. The large jump
in CEP participation at T4 corresponds with the
implementation of the CEP expansion/mid-year
enrollment policies.

T4

Note:
T1: Aug–Dec 2022: Post-COVID, three-tiered system in place
T2: Jan–May 2023: Arizona reduced-price co-pay policy implemented
T3: Aug–Dec 2023: Arizona policy with Medicaid Direct Certification
T4: Jan–May 2024: Arizona policy with Medicaid Direct Certification and CEP
expansion/mid-year enrollment

POLICY BRIEF

|

NOVEMBER 2024

|3|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

The impact of state and federal policy implementation on average daily participation (ADP)
rates in Arizona schools
ADP rate for both breakfast and lunch increased for most eligibility categories in response to state and
federal policy implementation.

Figure 2: Average Daily Participation (ADP) Rate Across All Study Periods
By Student Eligibility Category (%)
Breakfast
70

63

62

63

63

62

62

60

57

60

Lunch

57

56

54

52

ADP Rate (%)

50
40

32

33

33

30

37

35

33
25

28

27

37

37

29

29

30

31

T1

T2

T3

T4

24

20

17

18

T1

T2

18

14

10
0

T1

T2

T3

T4

Free Meals

T1

T2

T3

T4

Reduced-Price Meals

T3

T4

Paid Meals

All Students

Note:
T1: Aug–Dec 2022: Post-COVID, three-tiered system in place
T2: Jan–May 2023: Arizona reduced-price co-pay policy implemented
T3: Aug–Dec 2023: Arizona policy with Medicaid Direct Certification
T4: Jan–May 2024: Arizona policy with Medicaid Direct Certification and CEP expansion/mid-year enrollment

The ADP rate for the reduced-price category for
breakfast increased from 25% at T1 to 28% at T2. This
shows that 12% more students eligible for reducedprice meals participated in the school breakfast program
after the implementation of the policy that removed the
reduced-price co-pay for families in Arizona. Similarly, a
9% increase in ADP rate was observed for school lunch
participation – from 57% at T1 to 62% at T2 (Figure 2).
ADP rates for students eligible for free meals increased
slightly from T1 to T2 but then remained stable
throughout with about 63% of students eligible for free
meals participating in school lunch and 33% participating
in school breakfast.

Overall, average daily lunch participation increased
by about 10% between T1 (52%) and T4 (57%), while
breakfast participation increased by 7%, from 29%
in T1 to 31% in T4. This increasing trend in overall
participation rate can be attributed to the increase in
student eligibility for free meals after the implementation
of state and federal policies, and a higher proportion of
students in the free meal category participating in school
meals compared to other categories. There was a slight
decline in the breakfast participation rate among the
reduced-price and paid categories at T4, but it remained
steady in the free meal category as well as in the overall
participation category.

POLICY BRIEF

|

NOVEMBER 2024

|4|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

Figure 3a: Average Daily Participation (ADP)
Rate in Breakfast Before and After State and
Federal Policy Changes (%)
Student Eligibility Status

Pre-Policy

Post-Policy
32
33

Free Meals
25
26

Reduced-Price Meals
17
17

Paid Meals

29
30

All Students
ADPRate Breakfast (%)

Figure 3b: Average Daily Participation
(ADP) Rate in Lunch Before and After State
and Federal Policy Changes (%)
Student Eligibility Status

Pre-Policy

Post-Policy
62
63

Free Meals
57

Reduced-Price Meals
Paid Meals

61

35
37
52

All Students

56

ADPRate Lunch (%)

Figures 3a and 3b present ADP rates pre-policy at T1 and post-policy across T2-T4. ADP rates increased for the
free meals and reduced-price meal categories as well as for all students post-policy, indicating that more students
participated in school lunch and school breakfast programs in the post-policy period.
The largest increase (7%) was observed in the reduced-price lunch category, from 57% to 61%, bringing the
participation rate in this category close to that for the free meals category for lunch participation. Pre-policy the
ADP rate for lunch for students eligible for reduced-price meals was lower compared to that for the free meals
category (57% vs 62%), but the difference narrowed post-policy (61% vs 63%) when the co-pays were eliminated.
Overall, for all students, compared to pre-policy, student participation in breakfast went up by 3% (from 29% to 30%)
and lunch by 8% post-policy (from 52% to 56%).

POLICY BRIEF

|

NOVEMBER 2024

|5|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

The impact of state and federal policy implementation on the average number of total number of
meals served per month in Arizona schools.
The total number of free meals served per month increased with an additional 1.4 million free meals
served each month following the implementation of state and federal policies. The number of meals
served in the reduced-price and paid categories decreased post-policy

Figure 4: Average Number of Total Meals Served Per Month Across All Study
Periods By Student Eligibility Category (In Million)

14.0

Breakfasts

12.0

Lunches

Meals Served (In Million)

10.0

6.0

8.9

9.0

9.2

3.8

4.1

4.1

4.3

T1

T2

T3

T4

8.4

8.0

5.4

5.7

6.3

6.9

4.0
2.0
0.0

2.9

T1

3.1

T2

3.3

T3
Free Meals

3.7

T4

2.4

2.4

2.2

1.9

0.7
0.3

0.8
0.3

0.6
0.2

0.4
0.2

0.7

0.7

0.6

0.5

T1

T2

T3

T4

T1

T2

T3

T4

Reduced-Price Meals

Paid Meals

All Students

Note:
T1: Aug–Dec 2022: Post-COVID, three-tiered system in place
T2: Jan–May 2023: Arizona reduced-price co-pay policy implemented
T3: Aug–Dec 2023: Arizona policy with Medicaid Direct Certification
T4: Jan–May 2024: Arizona policy with Medicaid Direct Certification and CEP expansion/mid-year enrollment

Figure 4 shows the average number of total meals served per month by the eligibility category across all four study
periods. The average number of free meals served per month increased steadily for breakfast and lunch across
the study periods. Free breakfasts rose from 2.9 million in T1 to 3.7 million in T4, a 28% increase. Similar to the
increase in free breakfasts, free lunches also increased by 28%, increasing from 5.4 million per month at T1 to 6.9
million per month at T4.
Lunches served across all student eligibility categories also grew, increasing from 8.4 million per month at T1 to 9.2
million at T4, a 10% increase. Overall, breakfasts served per month across all student eligibility categories increased
from 3.8 million at T1 to 4.3 million at T4, a 13% increase.

POLICY BRIEF

|

NOVEMBER 2024

|6|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

Meanwhile, meals served in the reduced-price and paid categories held steady in T1 and T2 but declined in T3 and
dropped further in T4. This reduction in meals for the reduced-price and paid categories during T3 and T4 reflects
the impact of Medicaid Direct Certification in T3 and CEP expansion in T4. Both federal policies led to more
students becoming eligible for free meals, thereby reducing the number of students to be served in the reduced-price
and paid categories.

Figure 5a: Average Number of Breakfasts
Served Per Month Before and After State and
Federal Policy Change(In Millions)

Student Eligibility Status

Pre-Policy

Post-Policy

Free Meals
Reduced-Price Meals
Paid Meals

2.87

3.34

0.28
0.24
0.7
0.59

All Students

3.84
4.18

Breakfast served (In Million)

Figure 5b: Average Number of Lunches
Served Per Month Before and After State and
Federal Policy Change (In Millions)

Student Eligibility Status

Pre-Policy

Post-Policy

Free Meals
Reduced-Price Meals
Paid Meals

5.37

6.29

0.68
0.58
2.4
2.17

All Students

8.45
9.04

Lunch served (In Million)

Figures 5a and 5b present the average number of total meals served pre- and post-policy implementation. The
average number of total free breakfasts and lunches served per month increased by 16% and 17% respectively.
Before the policy change, 2.87 million breakfasts and 5.37 million lunches were served. In the post-policy period, the
number of free breakfasts and lunches went up to 3.34 million and 6.29 million, respectively.

POLICY BRIEF

|

NOVEMBER 2024

|7|

School Meal Participation Before and After State and Federal Policy Changes in Arizona

Across all eligibility categories, breakfasts increased from
3.84 million to 4.18 million per month, a 9% increase.
Similarly, the number of lunches served per month across
all eligibility categories increased by 7%, increasing from
8.45 million to 9.04 million.
Together, 12.29 million breakfasts and lunches were
served pre-policy and post-policy this number went up
by nearly 1 million breakfasts and lunches, for a total
of 13.22 million meals served each month. Post-policy,
the number of breakfasts and lunches served for free
went up by 1.4 million per month. As expected, given
the introduction of federal policies that increased the
number of students eligible for free meals (Medicaid
Direct Certification and CEP expansion), the average
number of total breakfasts and lunches served in the
reduced-price and paid categories dropped.

REFERENCES
1.
2.
3.

4.

5.

6.

CONCLUSION

Child Nutrition Tables | Food and Nutrition Service. Accessed
November 1, 2024. https://www.fns.usda.gov/pd/child-nutritiontables
Child Nutrition Programs: COVID-19 Waivers by State | Food and
Nutrition Service. Accessed August 10, 2024. https://www.fns.usda.
gov/disaster/pandemic/covid-19/cn-waivers-flexibilities
Kunichoff Y. Arizona to invest $6.75 million to expand free
school meals. The Arizona Republic. Accessed August 11,
2024. https://www.azcentral.com/story/news/local/arizonaeducation/2022/12/16/arizona-to-invest-6-75-million-to-expandfree-school-meals/69729309007/
Eligible students to continue receiving free meals at start of school
year. ABC15 Arizona in Phoenix (KNXV). July 16, 2024. Accessed
November 1, 2024. https://www.abc15.com/news/local-news/
eligible-students-to-continue-receiving-free-meals-at-start-of-schoolyear
Applications Now Open for States to Streamline Access to Free,
Reduced-price School Meals | Food and Nutrition Service. Accessed
November 1, 2024. https://www.fns.usda.gov/stakeholdernotification/cn/direct-certification-rfa
CEP Final Rule Summary | Food and Nutrition Service. Accessed
November 1, 2024. https://www.fns.usda.gov/cn/cep-final-rulesummary

Since its launch in 2014, schools with ISP (identified student percentage, or the
proportion of students categorically eligible for free meals) of 40% or above had
been eligible to participate in CEP. Starting in SY 2023-24, schools with ISP of
25% and over were eligible to participate in CEP.
i

The combination of state and federal policies has
increased access to healthy school meals for Arizona
students. While the recently implemented federal policies
(Medicaid Direct Certification and CEP expansion)
provide free meals to more Arizona students, state funds
are necessary to support students in the reduced-price
meals, specifically those attending schools that do not
participate in the CEP program.

This research was made possible with support from the Arizona Food Bank Network.

POLICY BRIEF

|

NOVEMBER 2024

|8|