National School Lunch Program
High-priority program
Program level Payment Integrity results
Sponsoring agency: Department of Agriculture
The National School Lunch Program (NSLP) is a federally assisted meal program operating in public and nonprofit private schools and residential child care institutions. It reimburses participating schools and institutions for the cost of providing meals to eligible children. NSLP overpayments are primarily due to errors in determining children's eligibility for program benefits. Errors in counting and claiming meals for federal reimbursement is a secondary source of over payment. The most significant barrier to prevention is the decentralized nature of the program. Certifying children for benefits and counting meals for reimbursement are handled independently by tens of thousands of schools and school districts.
View on Federal Program InventoryPROGRAM METRICS
$19,914 M
in FY 2025 outlays, with a
93.0%
payment accuracy rate
-
Improper payment estimates over time
View as:
Chart toggle amounts:Proper paymentsOverpaymentUnderpaymentTechnically improperUnknown
Payment Integrity results
-
FY 2025 improper payment estimates
Chart legend and breakdown
Payment accuracy rate
Improper payment rate
Unknown payment rate
Sampling & estimation methodology details
Sampling timeframe:
07/2017 - 06/2018
Confidence interval:
There is no confidence level associated with the estimate
Margin of error:
+/-0.0
Causes
National School Lunch Program (NSLP) and School Breakfast Program (SBP) improper payments stemming from failure to access data in the Financial category relate to errors that occur when claims for reimbursement are prepared prior to submission to the State Agency (SA). Meal counts from individual points of service are consolidated at individual schools. Meal counts from individual schools are submitted to School Food Authorities (SFAs), which are then consolidated again before a claim for reimbursement is submitted from SFAs to SAs. Aggregation error occurs when incorrect meal counts are recorded, transmitted, or aggregated at any level (school, SFAs). SAs then report aggregated claims data to the Food and Nutrition Service (FNS). Improper payments with a Financial sub root cause can also stem from the SFA’s lack of access to accurate household income data. Families self-report household income on applications that are submitted to local school districts, and districts use that information to determine eligibility for free or reduced-price meals. Self-reported household income in combination with household size determines eligibility for program benefits based on annual Income Eligibility Guidelines.
-Household Size-
Like household income, household size is self-reported on school meal applications. Applications are submitted to local school districts, and districts use that information, combined with household income, to determine household eligibility for school meals, based on annual Income Eligibility Guidelines.
-Receiving Benefits from Other Sources-
NSLP and SBP eligibility can also be determined based on receipt of other benefits. Households self-report information on benefits received from other sources on school meals applications. Some benefits received from other sources can confer categorical eligibility for free meals. In other cases, program staff must use self-reported income, including benefits received from other sources, to determine program eligibility based on annual Income Eligibility Guidelines.
| Overpayment root cause | Overpayment amount |
|---|---|
| Amount of overpayments within the agency's control | $0.0 M |
| Amount of overpayments outside the agency's control | $1,035.17 M |
| Amount of overpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist | $0.0 M |
| Amount of overpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment | $0.0 M |
| Amount of overpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment | $1,035.17 M |
| Underpayment root cause | Underpayment amount |
|---|---|
| Amount of underpayments | $354.43 M |
| The amount of underpayments that occurred because the data/information needed to validate payment accuracy prior to making a payment does not exist | $0.0 M |
| The amount of underpayments that occurred because of an inability to access the data/information needed to validate payment accuracy prior to making a payment | $0.0 M |
| The amount of underpayments that occurred because of a failure to access data/information needed to validate payment accuracy prior to making a payment | $354.43 M |
| The amount of improper payments that were paid to the right recipient for the correct amount but were considered technically improper because of failure to follow statute or regulation | $0.0 M |
| The amount that could either be proper or improper but the agency is unable to determine whether it was proper or improper as a result of insufficient or lack of documentation | $0.0 M |
Prevention
Community Eligibility Provision (CEP) Assistance:
The Food and Nutrition Service (FNS) provides technical assistance for states wanting to adopt CEP. FNS has also developed a series of resources for states, school districts, and schools on CEP including introductory webinars, written materials, and trainings. FNS research shows that through eliminating applications, CEP schools have lower certification error and improper payments relative to non-CEP schools. The CEP threshold decrease occurred in October of 2023 and FNS continues to provide assistance on CEP adoption.
Progress on Access, Participation, Eligibility, and Certification IV (APEC):
FNS is engaged in research related to integrity in the National School Lunch Program (NSLP) and School Breakfast Program (SBP). The fourth APEC Study completed data collection in School Year (SY) 2023-2024 and the contractor is preparing the data for FNS. With this update to the APEC study series, FNS will be able to use a new baseline estimate for improper payments in NSLP and SBP, improving the projected error rates by starting with a more recent starting point. The study also includes a component that examines integrity features of online applications. From this sub study, FNS aims to gain clarity on quality of data collected in online applications used by students and families who apply for free and reduced-price meals. FNS expects to publish the study in July 2026.
Direct Certification with Medicaid (DC-M):
DC-M allows state child nutrition agencies to partner with their Medicaid state agencies to certify children without application for free or reduced-price school meal benefits. This process reduces certification error, and by extension, improper payments. Six states opted into the FNS DC-M demonstration project for SY 2024-
2025, including Idaho, Maine, New Jersey, North Dakota, Rhode Island, and most recently Arkansas. This brings the total number of states participating to 44.
-Automation-
Non-competitive Technology Innovation Grants (nTIGs):
In FY 2025, FNS released $28 million in nTIG funds for child nutrition state agencies to improve information technology (IT) systems. FNS works with grant recipients who are using nTIG funds to develop, improve, and maintain child nutrition IT systems. FNS expects that the overall improvement of IT systems by nTIG recipients administering NSLP will improve the state agency's ability to train, monitor, provide technical assistance, and complete corrective actions.
Encourage state agency adoption of FNS -developed data validation service (DVS):
FNS modified its process of reviewing state agency management of the NSLP/SBP to encourage adoption of an FNS-developed tool to reduce error in the reporting of NSLP/SBP administrative data. The tool, the DVS, is an application programming interface (API) that states can include in their platforms for collecting data from their school districts. The DVS provides real-time edit checks and error messages to school districts as they submit data to their states.
FY 2025 Child Nutrition State Agency Conference:
This conference served as a forum for information exchange across states on topics including but not limited to enhancing program integrity. A general session was specifically dedicated to program integrity, and it covered topics like improper payment measurement and fraud investigations. The conference provided the opportunity for state and local agencies to participate in technical training, share best practices or lessons learned, and expand program knowledge.
The Food and Nutrition Service (FNS) has established through the Access, Participation, Eligibility, and Certification (APEC) studies that replacing an application-based certification system with a direct certification system (which includes the direct certification-based Community Eligibility Provision (CEP)) is very effective at reducing certification error. That same research (APEC) does not point to other major deficiencies in the current structure of the program that are driving error.
The research supports the measured approach that FNS is taking in corrective action plans: continued incremental investments aimed at refining and strengthening direct certification (through non-competitive Technology Innovation Grants (nTIGs), Direct Certification with Medicaid (DC-M) and CEP technical assistance, sharing best practices at state agency conferences, etc.). Those incremental investments are the right approach for an error rate that is shrinking because FNS understands the root causes and has been investing in the right strategies for years. APEC does not point to other root causes that would call for a significant change in the current approach or a major new investment in an entirely different set of remedies.
Due to the periodic nature of improper payment estimation of the National School Lunch Program and School Breakfast Program, FNS places priority on updating the APEC study series as a corrective action. While other corrective actions target improper payment reduction in a more direct manner, FNS is unable to quantify the effects of these actions without a new baseline. As such, collecting and analyzing newer data in APEC IV is essential for assessing the adequacy of current and past actions, as well as informing FNS for new potential future corrective actions.
| Payment type | Mitigation strategies taken | Mitigation strategies planned |
|---|---|---|
| Overpayments | Automation, Change Process | Automation, Change Process |
| Underpayments | Automation, Change Process | Automation, Change Process |
| Eligibility element/information needed | Description of the eligbility element/information |
|---|---|
| Financial | The financial position or status of a beneficiary, recipient, or their family |
| Household | Number of family members in a household |
| Receiving Benefits from Other Sources | Beneficiary or recipient is receiving benefits from an additional source |
Additional information
Reduction target
6.52 %The Food and Nutrition Service (FNS) has a comprehensive system of internal controls that include State Agency (SA)-led Administrative Reviews (ARs)of sponsors, FNS-led Management Evaluations (MEs) of SAs, and various meal claim validation checks conducted by sponsors, SAs and FNS. FNS, the states, and sponsors developed these controls over many years. FNS periodically evaluates and adjusts its AR and ME processes in response to evolving risk in the programs. FNS believes that these controls, a combination of on-site reviews, off-site reviews of documentation, and automated edits checks, are the right tools to identify program error that leads to improper payments. These are resource-intensive processes. However, FNS believes that the agency, the SAs, and sponsors have adequate human capital and information system resources to carry them out effectively. Federal reimbursement for state administrative expenses (SAE), federal grants for state technology projects (Technology Innovation Grants or TIGs), and the federal budget for child nutrition payment accuracy, among other resources, fund these systems and oversight activities.
-Training and Technical Assistance-
The 2026 USDA Budget Explanatory Notes for the Food and Nutrition Service (FNS) assumes $53,212,000 for Training and Technical Assistance. Effective and continual training and technical assistance are necessary to help states properly administer the Child Nutrition Programs and to ensure states are equipped to identify and prevent fraud and abuse. The increase is due to inflation. The decrease in full-time equivalent (FTEs) is focused on restructuring the workforce and seeking efficiencies in operations.
-Child Nutrition Studies-
The Budget for FNS assumes $21,918,000 to conduct a variety of studies, evaluations, and related activities that respond to the needs of policy makers and managers and help ensure that nutrition assistance programs achieve their goals effectively, which include improving public health, and nutrition. This program line supports the critical evaluations needed for the Child Nutrition Programs, including the Federal staff needed to oversee this vital work. The increase is due to inflation. The decrease in FTEs is focused on restructuring the workforce and seeking efficiencies in operations.
-Child Nutrition Payment Accuracy-
The Budget for FNS assumes $16,189,000 to support the FNS's robust Federal oversight, monitoring, and technical assistance, which are essential to the identification, prevention and resolution of erroneous payments. The increase is due to inflation. The decrease in FTEs is focused on restructuring the workforce and seeking efficiencies in operations.
Program sponsors and operators have binding agreements with the administering State Agencies (SAs) to operate Food and Nutrition Service (FNS) the National School Lunch Program (NSLP) according to all program rules. SAs have binding agreements with FNS to administer the Federal programs in accordance with applicable regulations, guidance, and instructions. FNS has a robust review process that includes state-level review of local program operators and FNS-level reviews of SAs to ensure program integrity in the NSLP. Additionally, at the federal level, senior executives are held responsible for program oversight and integrity via the annual strategic planning process and performance system.