Public or nonprofit private schools of high school grade or under and public or nonprofit private residential child care institutions may or may not participate in the NSLP. School districts and independent schools that choose to take part in the NSLP get minimal cash subsidies and donated commodities from the USDA for each meal they serve. In return, they must serve lunches that meet Federal requirements, and they must offer free or reduced-price lunches to eligible children. School food authorities can also be reimbursed for snacks served to children through age 18 in after-school educational or enrichment programs.

Participation issues
In the late 1990s, NSLP officials determined in a "Study of Direct Certification in the National School Lunch Program" that the paper application process for NSLP certification was inefficient and potentially excluded participants from the program (Jackson, Gleason, Hall and Strauss, 2000). This study showed that direct certification provided the most advantageous way to identify eligible participants in the NSLP by allowing schools to use documentation from local or state welfare agencies to verify eligibility for the program. Although a lack of cooperation between the NSLP and some welfare agencies was identified, direct certification was shown to significantly improve the number of eligible participants in the Food & Nutrition Service's (FNS) study of direct certification. In 2008, Philip Gleason, Senior Researcher for the Mathematica Policy Research, wrote a paper also validating that direct certification clearly expands access for children to the NSLP.

In addition to student access to the NSLP, the integrity of the NSLP has come under fire for excessively validating students who are not eligible for the program. As a result, a recent three-year study by the USDA FNS (Gleason, 2008) found that 77.5 percent of NSLP applicants were correctly certified. However, 15 percent were certified as eligible when they did not qualify, while another 7.5 percent were denied benefits when they actually were eligible to participate. While the amount of erroneous NSLP payments during the 2005-2006 school year was relatively small in terms of overall percentages for the program, these overpayments totaled more than $759 million, a very significant amount considering that rising costs are an issue (Ponza, 2007). However, more current research by Molly Dahl identifies the cost of ineligible participants as a problem that continues to plague the NSLP (2011). With an estimated overpayment of $1.5 billion to FSA in 2011, her research shows that ineligible participants undeniably added to the cost of the program.

David Bass asserts that the problem is not simply an innocent one, but involves a calculated effort by many to commit fraud (2010). He argues that "State governments dole out benefits according to free and reduced-price lunch percentages. Because of financial benefits, local school districts have a clear incentive to register as many students in the NSLP as possible." While the NSLP has a verification process built into it, only up to 3 percent of applications can be verified for the accuracy of reported income. Bass found that some school districts who wanted to verify higher percentages of applications were threatened with legal action from the federal government. In fact, Bass identified one district alone that found 70 percent of the applications they verified were incorrect and resulted in reduced or eliminated benefits to the participant.

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