PolicyBrief
H.R. 5128
119th CongressSep 4th 2025
Feed Hungry Kids Act
IN COMMITTEE

This act sets the Identified Student Percentage threshold for federal nutrition programs at 25 percent for school years beginning on or after July 1, 2025.

Laura Gillen
D

Laura Gillen

Representative

NY-4

LEGISLATION

School Lunch Metric Gets Fixed at 25%: How a Technical Change Could Affect Cafeteria Funding in 2025

The aptly named Feed Hungry Kids Act is kicking off with a highly technical, but important, procedural change regarding how schools qualify for certain federal nutrition programs. Essentially, the bill takes a metric known as the “Identified Student Percentage” (ISP)—which helps determine if a school can offer free meals to all students without collecting individual applications—and fixes the minimum threshold.

Starting with the school year that begins on or after July 1, 2025, the ISP threshold is officially set at 25 percent. This replaces the current language in the Richard B. Russell National School Lunch Act and means that schools will need at least 25% of their students to be directly certified for free meals (meaning they already receive benefits like SNAP or TANF) to use this specific funding calculation method (Sec. 2).

The ISP Explained: Cutting Through the Paperwork

For those of us who haven't dealt with school district budgeting, the ISP is a big deal because it’s the gateway to the Community Eligibility Provision (CEP). When a school qualifies for CEP, it can offer free breakfast and lunch to all students, regardless of their family income, without the administrative headache of processing thousands of individual free and reduced-price meal applications. This saves parents time and makes sure kids get fed without the stigma of needing a free meal.

This bill doesn't change the CEP program itself, but it standardizes a key entry point. By setting the threshold at a fixed 25%, the bill aims to create a clear, consistent benchmark across the board. For school administrators, this clarity is a win, simplifying planning and reducing confusion about annual eligibility requirements. It means less time spent deciphering complex federal rules and more time focusing on getting food to kids.

Who Feels the Change?

The real-world impact of fixing the ISP at 25% is primarily felt by schools that currently use a slightly different, perhaps lower, threshold to calculate their eligibility. While the 25% mark is relatively modest, any fixed number means that districts sitting just below that line might suddenly find themselves ineligible for the simplified funding process come July 2025.

Imagine a smaller, high-poverty school that currently qualifies for CEP because their ISP calculation was slightly more favorable under the old rules, maybe sitting at 23%. Under this new fixed rule, that school might lose the ability to offer universal free meals and would have to revert back to collecting and processing individual applications. This creates extra work for the school office and could lead to some kids missing out on meals if their parents miss the application deadline. The goal is standardization, but the practical challenge is ensuring that this technical fix doesn't unintentionally push schools off the simplified program, increasing administrative burden where it's needed least.