How can we get every eligible child into the school meal system?

Even among the households who meet the £7,400 per annum income threshold for entitlement to Free School Meals, an estimated one in ten children are not registered and therefore unable to receive the hot lunch to which they are entitled.

A recent analysis paper by Feeding Britain, written by Andrew Forsey and Prof Greta Defeyter, suggests that at least 220,000 children are missing out. At 190 school days per year, and £2.58 school meal allowance per day, that is worth up to £490 per child per year of lost value for the families

But that’s not all. Not even half of it in fact. At present, Free School Meal eligibility is used as a proxy for child poverty, passporting additional access to other support such as the Holiday Activities and Food Programme, or additional vouchers or cash payment support from local authorities through the Household Support Fund, for example. For schools, it also unlocks pupil premium that is used to provide additional learning support, subsidise costs of trips, uniform, before and after school clubs or additional equipment. That is worth an additional £1480 per year for a primary school child or £1050 for secondary age pupils. Greta Defeyter and her colleagues used COLLECT data and calculated that the combined cost to families and schools of under-registration in 2021-22 exceeded £23 million in the North East region alone.

It goes beyond that too, as Free School Meal eligibility also gets used as a reference point for all sorts of other metrics around health and attainment, and social mobility including higher education admissions. 

So there's a lot more at stake than simply a plate of food at lunchtime.

Cost of complexity

There is in fact increasing debate about whether Free School Meals eligibility is good enough to be deployed as a proxy for child poverty. That's not least because an estimated 900,000 children living in poverty are still not eligible under the current £7,400 threshold for Free School Meals in England, according to the Child Poverty Action Group, whilst transitional protections during Universal Credit roll out that were introduced alongside the eligilbility threshold in 2018 make the picture more complex still. A recent paper from the Education Policy Institute took a hard look at the data on the national pupil database and concluded that Free School Meals were a very unreliable proxy for targeting additional support. In short, it’s a mess!

For now though, it is is the system we have. And the big question is, with so much at stake, why are so many children missing out on the entitlement that is rightfully theirs?

It is under Section 512 of the Education Act 1996 that there a duty on maintained schools, academies and free schools to provide Free School Meals “to pupils of all ages that meet the criteria.” However, for a child to receive a free school meal, a subsequent clause states that a claim must be made to the local authority.

Making access easier

There are multiple reasons why families don’t make such applications – lack of awareness of eligibility, language barriers, distrust or fear of having other benefits removed, the complexity of administrative systems, feelings of stigma or shame can all play a role.

A huge amount is at stake, as multiple local authorities have found out by engaging in what has been termed the “Sheffield model” of opt-out automatic registration. In this initiative, the local authority uses existing welfare data to identify families that are not registered for free school meals. Families were informed that the council would apply for free school meals on their behalf, unless they chose to opt out. From 2016 to 2022, Sheffield managed to enrol an additional 6,403 children onto Free School Meals, with an estimated additional pupil premium value of £3.8 million.

Since then, the Fix our Food programme of researchers led by the University of York with Bremner & Co and the Food Foundation have been working collaboratively with councils across the UK to set up, deliver and evaluate auto-enrolment processes. 77 councils across England have already participated, with an average of over 1,000 pupils registered, bringing in an additional £1 million in pupil premium per local authority. In County Durham, a trial auto-enrolment programme resulted in 1,500 primary and 1,000 secondary pupils starting to receive free school meals.

The auto-enrolment work by local authorities has also raised important questions about whether the current process for Free School Meals application supports schools and local authorities to deliver on their duties under both the Education Act and the Equalities Act.  Lambeth successfully enrolled 580 children into Free School Meals following their auto-enrolment initiative. When they analysed the socio-economic background of newly registered families, 79% were from black and minoritised ethnic communities, 50% did not have English as a first language, and 89% were from lone parent households.

From local to national

However, whilst councils have shown the benefit of an automated registration process, doing this local authority by local authority is time consuming and inefficient. Councils have been dissuaded from undertaking the exercise not just because of the administrative workload, but also because obtaining data sharing agreements is fraught with fears of legal challenge.  As one local authority representative said, “The process … was beset by legal issues around data sharing. We were sent around in circles … it shouldn’t be that a local authority is having to go through this process against government departments – it costs money and takes significant time and resources.”

Another downside of the localized approach is that children do not always live in the same local authority as the school they attend. This makes it very difficult for the local authorities to identify eligible children. Multiple London boroughs are now working together to try to deliver a pan-London approach, with support from the Greater London Authority, in order to get over these barriers.

However, ultimately what is needed is a national policy solution. National auto-enrolment in workplace pensions was a game changer, lifting participation from 55% in 2012 to 88% in 2021. Why not the same for free school meal entitlement?

Legally, there are routes to amend and/or clarify guidance around Section 512 of the legislation requiring a child or their parent to apply for a Free School Meal - and instead to place the duty squarely back on the state, local authorities and schools to identify and provide meals to all eligible children. Technically, that would require data sharing agreements between DfE, DWP and local authorities to make it happen. Given that Universal Credit was intended to create a one-stop shop in bringing benefits together, there could be space in the Universal Credit application form to consent to data being used for registration for Free School Meals, where eligible.

Hope for change in 2025?

The Children’s Wellbeing and Schools Bill is already introducing free primary school breakfast clubs, and during committee stage, amendments were put forward supported by both Labour MP Dr Simon Opher and the Liberal Democrat spokesperson on children and families Munira Wilson MP.

Following scrutiny of the Bill, the influential Education Select Committee, chaired by Helen Hayes MP has also swung behind the case for auto-enrolment, saying “We consider that the arguments for auto-enrolment in free school meals for those children currently eligible are conclusive. In the interests of alleviating hunger in schools and improving health and educational outcomes for the poorest children, auto-enrolment must be brought in without delay”.  Members of the Committee have now sponsored an amendment to the Bill to remove the requirement in the Education Act for a child to have to make a claim for free school meals.

However, the issue has also risen up the political agenda due to a Private Members’ Bill sponsored by Peter Lamb, the MP for Crawley. His bill includes important clauses not just to provide a meal to every qualifying child, but also requiring the Secretary of State to “provide local education authorities, schools, and any other relevant departments or agencies with the powers necessary to obtain, process and exchange the information necessary for the carrying out” of identification of children eligible for free school meals.  For parents, it also retains the right to opt out.

Will the Government opt in or out?

The Government is facing increasing calls to expand eligibility for free school meals – not least via our work in our Say Yes to School Food For All Campaign, and the wider work of the School Food Review urging policy makers to get behind the Superpowers of School Food.

In the face of that, the calls for auto-enrolment – simply ensuring children receive the benefits they’re already legitimately entitled to – feel like a modest ask for the government to accede to. It is even aligned with the current government drive to reduce unnecessary administration and harness the power of data to deliver impact, not to mention putting power back into the hands of local government.  The Government could at the very least create the space for this debate by supporting Peter Lamb's Private Members' Bill to move to the next stage of the legislative process. Alternatively it can engage with amending the Children’s Wellbeing and Schools Bill as it moves through report stage in parliament, and be included in the Government’s Child Poverty Taskforce report.

Whatever the mechanism, moving auto-enrolment forward feels like a corner piece in the complex school food for all jigsaw – easiest to find first and put into place, and hopefully a helpful starting point for building the wider picture.