Arizona Students Are Back in School. Hundreds of Schools Could Lose Access to Free Meals. 

Arizona students have returned to classrooms, where access to healthy breakfast and lunch helps them stay focused, engaged and ready to learn. But hundreds of Arizona schools face a growing threat to free meals for every student — and it isn’t coming from just one policy change. 

In Arizona, a school’s ability to adopt the Community Eligibility Provision (CEP) is not only threatened by the steep decline in SNAP enrollment in state and looming Medicaid cuts, but Congressional Republicans have previously proposed raising the threshold for a school adopting CEP to provide school meals from 25% to 60%.  

Together, these policies create a double squeeze: One raises the bar, while the other makes it harder for schools to reach it. If the CEP threshold was raised from 25% to 60%, then nearly 145,000 Arizona students attending almost 300 schools could lose access to universal free school meals. And even if Congress never acts, schools are already losing ground because fewer students are being directly certified through SNAP and Medicaid.  

During the 2024-2025 School Year, 1,029 Arizona schools adopted CEP, serving free meals to more than 487,000 students. The program cuts paperwork, eliminates stigma, and helps ensure children can focus on learning instead of hunger. 

What is CEP — and why does it matter? 

CEP allows schools serving large numbers of students from low-income households to provide free breakfast and lunch to every student without requiring families to fill out meal applications.  

During the 2024-2025 School Year, 1,029 Arizona schools adopted CEP, serving free meals to more than 487,000 students. The program cuts paperwork, eliminates stigma, and helps ensure children can focus on learning instead of hunger.  

CEP faces pressure from 2 directions  

The federal reconciliation package made historic cuts to SNAP and Medicaid. Those cuts matter for school meals because CEP eligibility is based on a school’s Identified Student Percentage (ISP), the share of students automatically certified for free meals through programs like SNAP, Temporary Assistance for Needy Families (TANF), and Medicaid.  

As families lose SNAP and Medicaid coverage, fewer students may be directly certified for free school meals. 

Arizona’s recent SNAP participation losses demonstrate the potential scale of the problem. Every county in the state has lost at least a third of its child SNAP participants since July 2025, with Maricopa County losing more than half its child participants at the peak in April.  

To illustrate the potential impact of SNAP losses on CEP eligibility, we modeled a 33% decline in each school’s ISP, matching the statewide decline in child SNAP participation. Under that scenario, setting aside other ways in which a student may directly qualify for school meals, 181 Arizona schools currently at or above 25% ISP threshold would fall below it. 

Schools could lose CEP eligibility or the opportunity to ever adopt it, without any changes to federal CEP rules because the pool of students directly certified through SNAP, Medicaid and other qualifying programs would shrink. 

A separate congressional proposal from last year would have more than doubled CEP’s minimum ISP requirement, from 25% to 60%, a change that would strip free school meals from tens of thousands of schools nationwide.  

While this proposal is not yet law, it could potentially resurface quickly and without little warning. If enacted, it would compound the direct-certification losses that schools could experience because of cuts to SNAP and Medicaid. Arizona families cannot afford to dismiss that possibility as hypothetical. 

As the school year begins, Arizona cannot afford to wait and see 

To understand what the 60% eligibility threshold would mean for Arizona, we analyzed school-level CEP data from Arizona Department of Education and the Food Research & Action Center's Community Eligibility Database. The results show the proposal would reach every corner of the state.   

• 297 Arizona schools currently participating in CEP would lose eligibility outright — that's nearly 3 in 10 schools in the state currently using CEP. 

• 106 school districts would have at least one school affected. 

• 14 out of 15 Arizona counties would have at least one school lose access to CEP. 

• Rural counties would be hit hardest relative to their size: Maricopa County has the largest number of affected schools, but Yavapai County would lose the largest share of its CEP schools among counties with a meaningful number of participating schools. More than three-fourths of its participating schools — 24 of 31 — would lose eligibility. 

Schools would have to decide whether they can afford to continue providing free meals to every student or return to a system of meal applications, individual eligibility determinations, and unpaid meal debt. 

The impact doesn’t stop with schools already using CEP. 

Another 404 Arizona schools, serving 260,922 students, currently qualify for CEP under today’s rules but are not yet participating. Under the proposed 60% threshold, those schools would permanently lose the option to adopt CEP. 

What that costs a family  

The new school year already brings added expenses for supplies, clothing, transportation, child care and other necessities. Losing free school meals would add another significant cost to family budgets that are already stretched thin.  

The Center for American Progress estimates that a family with two children who lose access to free school meals would spend an additional $1,890 per year purchasing meals at school — or more than $2,214 per year packing lunches at home.  

That’s a real hit to a family budget, particularly as many of the same households confront high grocery prices, cuts to SNAP and a broader affordability crisis.  

The Center for American Progress estimates that a family with two children who lose access to free school meals would spend an additional $1,890 per year purchasing meals at school — or more than $2,214 per year packing lunches at home.  

Consequences extend beyond the cafeteria  

As teachers and students establish routines for a successful school year, hunger, paperwork and meal debt should not be additional barriers to learning. 

CEP wears two hats: it’s a nutrition program and an administrative one. When a school loses access to CEP:  

• Families go back to filing out meal applications every year.  

• Schools take on the cost and staff time of processing those applications and tracking who qualifies. 

• Some eligible children inevitably fall through the cracks, not because they stopped qualifying, but because a form didn’t get filled out, or a deadline was missed.  

• Stigma comes back into the cafeteria, as students receiving free meals may once again feel singled out or embarrassed. 

Research has consistently shown that universal school meals increase participation, reduce administrative burdens, and remove the stigma that can discourage students from eating school meals. Losing CEP means losing those benefits as well. 

Arizona families deserve better  

Arizona has worked to expand access to healthy school meals because the research is consistent: Well-fed students attend school more regularly, perform better academically, and have better long-term health outcomes.  

Dramatically increasing the CEP eligibility threshold while SNAP and Medicaid cuts are already making it harder for schools to qualify is a dangerous combination. It threatens to undo years of progress — not because Arizona schools have changed, but because the rules are changing around them. 

Arizona students are beginning a new school year right now. Whether they can eat breakfast and lunch at school should not depend on shifting federal rules or whether their families successfully navigate increasingly difficult benefit systems. 

Every student deserves the chance to focus on learning instead of wondering whether they’ll have lunch. Congress should be strengthening that promise, not putting it further out of reach.  

Analysis based on the Food Research & Action Center’s Community Eligibility Database, 2024-2025 school year, matched the Arizona Department of Education’s Active LEAs and Schools file to assign each school a county and charter/traditional-district status. FRAC’s January 2025 reporting on the 60% threshold proposal drew on 2023-2024 school year data available at the time; this analysis uses FRAC’s now-updated 2024-2025 database, which is why Arizona’s totals here differ slightly from FRAC’s earlier published figures. The 60% ISP threshold scenario applies FRAC’s reported school-level ISP directly; it does not account for LEAs regrouping schools to preserve eligibility collectively.