Project 2025 Targets School Meals: Attacking Community Eligibility and the USDA Safety Net
Project 2025 proposes restricting the Community Eligibility Provision (CEP) that lets high-poverty schools serve universal free meals, rolling back SNAP work-requirement protections, and slashing the Thrifty Food Plan—all under the guise of 'integrity' and 'original purpose.' These cuts would strip nutrition from millions of the same children the Department of Education dismantlement and Title I erosion would leave unsupported.
Project 2025's education chapter devotes pages to USDA nutrition programs because the authors understand what public school champions know: you cannot educate a hungry child. The Heritage Foundation's 2019 claim that CEP 'doubled' or 'tripled' the share of middle- and upper-income students receiving free meals is misleading. CEP requires that at least 40% of students in a school or district be 'directly certified' for free or reduced-price meals through SNAP, TANF, or other means-tested programs—meaning the school already serves a high-poverty population. The provision does not give free meals to wealthy students in affluent schools; it ends the bureaucratic stigma of collecting meal applications in schools where most kids already qualify. The Trump-era rule that would have restricted CEP grouping—allowing clusters of schools to jointly reach the 40% threshold—was finalized but blocked by a court and then abandoned by the Biden administration. Project 2025 revives that attack.
The same ideological drive to shrink the federal role in nutrition aligns with the push to abolish the Department of Education. If Congress eliminates the Department, Title I funds for high-poverty schools, IDEA special-education enforcement, and civil-rights investigations move to agencies that lack expertise or capacity. Students who rely on school meals as their most reliable source of nutrition—roughly 30 million children, over 20 million of whom eat free or reduced-price lunch daily—would lose a second safety net. Food service, as EPI notes, is the one budget line where low-income districts often spend more than wealthy ones precisely because they serve more students who need it. Attacking CEP and SNAP does not save money; it transfers costs to emergency rooms, behavioral-health systems, and a less productive workforce.
The humanitarian alternative
Congress should expand the Community Eligibility Provision by lowering the threshold from 40% to 25% of directly certified students, allowing all schools to participate without group restrictions. This would simplify administration, reduce stigma, and ensure that no child in a high-poverty school goes hungry. USDA should simultaneously issue guidance encouraging states to adopt direct certification with Medicaid data, which would increase participation among eligible families. The goal should be universal school meals, not a return to means-testing that singles out low-income children.
Rollback path — how this gets undone
This action has already been implemented. These are the concrete levers that could reverse it.
- Department of Education dismantlement ordered via executive order Future administration could rescind EO; Congress could statutorily re-establish Department functions. Pending litigation may enjoin.
- SNAP work requirements rule (Trump-era, blocked) Rule was already enjoined and not defended by Biden; not in effect.
Original source — excerpted
project2025 Project 2025 ch. 11: Department of Education (pp 333-335)"— 300 — Mandate for Leadership: The Conservative Promise the more than 40 million food stamp beneficiaries, the Trump rule would have applied only to 688,000 individuals in fiscal year 2021.63 The Trump reform was scheduled to go into effect, but a D.C. district court federal judge enjoined the rule.64 The USDA filed an appeal in late December 2020,65 but the Biden Administration withdrew from defending the challenge, and the rule was never implemented.66 Beyond the able-bodied work requirement, FNS should implement better regulation to clarify options for states to implement the general work requirement. This requirement is an option states can apply to work- capable beneficiaries aged 16 to 59. If beneficiaries’ work hours are below 30 hours a week, states can implement the general work requirements to oblige beneficiaries to register for work or participate in SNAP Employment and Training or workfare assigned by the state SNAP agency.67 Increased clarity for states would include items like states being required to offer employment and training spots for those that request them—not simply budgeting for every currently enrolled able-bodied adult. l Reform broad-base…"