Reviewing Free-Lunch Student Counts Used as the Basis for At-Risk Funding [July 2025]

The Rundown with Kansas Legislative Division of Post Audit

The Rundown with Kansas Legislative Division of Post Audit
Reviewing Free-Lunch Student Counts Used as the Basis for At-Risk Funding [July 2025]
Jul 21, 2025

The federal government reimburses school districts for meals they serve to students through the National School Lunch Program. Students receive a free or reduced-price lunch through the National School Lunch Program if they meet 1 of several criteria including participating in certain federal programs, being a migrant student, and having household income of 130% or less than the federal poverty line. In Kansas, the state provides at-risk funding to school districts based on the number of students who are eligible for a free lunch and meet a few other criteria.

We chose a random and projectable sample of students who qualified for a free lunch in the 2023-24 school year to verify their eligibility for the free lunch program. We estimated that 54% to 72% of all Kansas students who qualified for free lunches because they submitted a National School Lunch Program application were likely ineligible in the 2023-24 school year. However, only about 16% of all students who qualified for a free lunch qualified by submitting an application. For most of the remainder of students we were not able to verify their eligibility because their eligibility was determined by the Department for Children and Families, the Kansas Department of Health and Environment, or by their school district. Because of time and data constraints, we could not determine whether those agencies and districts correctly determine student eligibility. As a result, we could not assess the overall accuracy of the free lunch count.

Federal rules significantly limit school districts' and KSDE's ability to verify the eligibility of students who receive a free lunch. As a result, the free lunch program is at high risk of fraud, waste, and abuse.