A pupil is only eligible to receive a free school meal when they meet the eligibility criteria, a claim for the meal has been made on their behalf, and their eligibility has been verified by their school or the local authority. Parents and guardians are required to complete an application form via their local authority or school to register a child for FSM.
Schools have ultimate responsibility to check the eligibility of the applicant and enrol them. However, many schools choose to work with their local authority to carry out these checks. All local authorities have access to the Department of Education (DfE’s) Eligibility Checking System (ECS), which allows local authorities to quickly check data held by the Department for Work and Pensions, the Home Office and HMRC to establish eligibility for free school meals and other early education entitlements.
In 2013, the DfE estimated that around 14 per cent of pupils entitled to FSM were not claiming them. The DfE does not routinely collect information on the number of pupils that are entitled to FSM but do not make a claim. It is therefore largely unknown how many children are currently not receiving the benefit and corresponding pupil premium funding.
Pupil Premium is awarded to schools to provide additional support for disadvantaged children. Pupil Premium is only provided for children registered to claim free school meals. Pupil Premium is awarded for 6 years, and follows the child when they move school, even if the FSM entitlement only lasts a short while. Schools therefore lose out on funding when families do not enrol eligible children for FSM. Particularly, if the child does not want a meal or is already receiving a meal under another scheme, families are unlikely to sign up for something they see no visible benefit from.
Since the implementation of Universal Infant Free School Meals (UIFSM) in 2014, many schools suffered a financial loss in terms of Pupil Premium funding as parents did not feel the need to apply for a free meal based on their household income when one was already provided. Section 106 of the Children and Families Act 2014 makes provision for free school meals to be provided for all pupils in Reception, Year 1 and Year 2. This duty took effect from September 2014 and is applicable for maintained schools, academies and free schools.
In London, the Mayor has funded universal free school meal provision in London primary schools for the 2023 to 2024 and 2024 to 2025 academic years. Parents whose children already qualify for FSM under the national offer are being advised to continue applying for FSM to secure Pupil Premium. However, there’s a risk that fewer parents will register if their child is already being provided with a meal through the local scheme, meaning schools will lose out on funding.
Local free school meals offers
Despite significant budget pressures, several councils have made the decision to provide a universal offer of free school meals for primary school pupils in their areas.
For example, since 2013 Southwark Council have run a free healthy school meals programme universally provided for all primary school students in Key Stage 2, to tackle food poverty and childhood obesity. This supplements the central government-funded, means-tested free school meals and universal infant free school meals. 38 per cent of children in Southwark live in poverty, yet many whose families earn above the £7,400 a year threshold would not be eligible for free school meals under the national offer.
Research by the University of Essex, which studied the impact of universal primary free school meal provision in Southwark, Tower Hamlets, Newham and Islington, found that the schemes have helped to reduce the prevalence of childhood obesity (by 9.3 per cent among Reception children and 5.6 percent among Year 6 children on average) and help families cope with the cost of living, saving them £37 per child per month on average.
Another example is a case study by Brighton and Hove on encouraging healthy food options in canteens, cafes and restaurants.
Free school meals and longer-term approaches to addressing poverty
While initiatives such as free school meals and the healthy start scheme have a vital part to play in helping families and children to access nutritious food, they must be supported by a long-term, integrated approach to addressing poverty and disadvantage. The most effective routes out of poverty depend on ensuring that people can access secure, well paid employment, affordable housing and inclusive financial support and services.
An adequately resourced national and local safety net is essential to supporting low-income households, and those who cannot work, to live well and access nutritious food. It is the LGA’s view that the national benefit system should provide the principal safety net for all low income households.
The LGA continues to work closely with DWP, councils, voluntary and community sector partners and others to press for a more sustainable local welfare safety net.
There are a number of measures that Government should consider to address these challenges and reduce the number of people facing food insecurity. We are calling on the Government to expand access to, and the value of, healthy start vouchers and expand the eligibility criteria for free school meals to encompass all children and young people of school age who are in food poverty. Alongside this, Government must introduce automatic enrolment for free school meals.
Evidence suggests that these measures could deliver long-term socio-economic benefits and contribute towards our shared objectives of tackling inequality, reducing the pressure on health services and closing the attainment gap between disadvantaged children and their peers.
Local auto-award approaches
Local authorities are increasingly introducing local approaches to improve the take-up of FSM and proactively register eligible children. These approaches broadly fall into two categories – ‘opt-in’ and ‘opt-out’.
Opt-out approaches
Sheffield City Council first introduced the ‘opt-out’ model in 2016. This has now been replicated by many councils across the country.
FixOurFood has created a toolkit for councils to help set up the delivery of auto-enrolment for FSM. FixOurFood is also running an action-orientated research programme to support and evaluate the implementation of auto-enrolment approaches within local authorities, primarily in Yorkshire – but the programme is open to councils nationwide. This is a UKRI funded project led by researchers at York University.
The ‘Sheffield Model’ uses the following process:
- Use data from Revenues & Benefits to identify families that have claimed Housing Benefit (HB) and/or Council Tax Support (CTS), and who have children but have not applied for free school meals.
- Every August, they write to all Housing Benefit/ Council Tax Support claimants who have dependents under school leaver age (2 to 19) and potentially meet the criteria for FSM (and are not already claiming for FSM).
- The letter advises that to ensure parents are claiming everything they are entitled to; the council will use their name, DOB and NI number from their Housing Benefit/Council Tax Support application to check their eligibility for free school meals.
- Parents are given three weeks to object to the use of their information.
- If after three weeks no objections have been received, the council will use the personal data to check a child’s eligibility for FSM on the ECS, and if eligible, enrol them.
- These children are immediately awarded FSM.
- Pupil Premium funding is awarded to schools based on how many children were enrolled for FSM on the previous years’ school census for pupils from Reception to Year 11.
The approach itself is relatively uncomplicated however it does involve a number of different teams working together (Revenues and Benefits, Education, Information Governance). London LAs undertaking the process have been users of Policy in Practice’s Low Income Family Tracker and have utilised it to extract households that appear to be eligible and not claiming.
Opt – in approaches
Other local authorities have implemented ‘opt-in’ approaches, which involve adding tick boxes (written or verbal) to the application process (forms or in-person/ telephone scripts) for local benefits. This includes Council Tax Support, Discretionary Housing Payments, grants from local welfare assistance schemes and/or the Household Support Fund, and any other relevant points of contact between families and the local authority.
In 2022, Feeding Britain, held a number of meetings with DfE and scoped out a pilot exercise to implement this approach. 20 local authorities in their network were involved in the pilot. The pilot is not DfE funded.
The DfE's key requirement for the pilot was that auto-enrolment could only take place upon parents' request or consent being given (and recorded) for their data to be used in this way. Local authorities have used the following text on relevant forms and/or application processes:
“I request that the local authority uses this information to process my application for free school meals.”
or
"I agree to the local authority using this information to process my application for free school meals."
Once permission has been gained from parents/guardians ticking that box or submitting that form, and eligibility has been established, local authorities are then able to complete the process of registering children in that household for their free school meal (and Pupil Premium) entitlement.