Food Insecurity: Better Information Could Help Eligible College Students Access Federal Food Assistance Benefits

Increasing evidence indicates that some college students are experiencing food insecurity, which can negatively impact their academic success. However, college students are only eligible for SNAP in certain cases. Given the substantial federal investment in higher education and the risk posed if students do not complete their degrees, GAO was asked to review food insecurity among college students.

This report examines (1) what is known about the extent of food insecurity among college students and their use of SNAP; (2) how selected colleges are addressing student food insecurity; and (3) the extent to which federal programs assist students experiencing food insecurity. GAO reviewed relevant federal laws and agency documents and studies on student food insecurity; analyzed 2016 federal student data (the most recent available), and visited four states, selected based on actions taken to address student food insecurity, geographic diversity, and other factors. GAO interviewed researchers; officials from Education, FNS national and regional offices; and officials at 14 colleges, including students at 8 of these colleges. GAO also emailed all state SNAP agencies about their efforts related to students.

There is limited information about the national prevalence of food insecurity among college students. GAO reviewed 31 studies that identified a wide range of food insecurity rates among the students studied, but the studies did not provide national estimates. College students at risk of food insecurity may be eligible for benefits from the Food and Nutrition Service's (FNS) Supplemental Nutrition Assistance Program (SNAP). However, GAO's analysis of Department of Education (Education) data shows that almost 2 million at-risk students who were potentially eligible for SNAP did not report receiving benefits in 2016. According to GAO's analysis, having a low income is the most common risk factor for food insecurity among college students. Among low-income students, most have one additional risk factor associated with food insecurity, such as being a first-generation student or a single parent.

The 14 selected colleges that GAO contacted were addressing student food insecurity in a number of ways. For example, all 14 were providing free food to students through on-campus food pantries, and most were offering emergency funds to help students pay for living expenses that might otherwise force them to choose between buying food or staying in school. Many of these colleges had centralized student services to better address their students' basic needs and provide other support, such as screening students for potential eligibility and helping them apply for federal benefit programs like SNAP.

Federal student aid generally does not cover all college costs for low-income students, and college students may have limited access to federal food assistance programs such as SNAP because of program eligibility restrictions. Some state SNAP agencies reported that they are taking steps to help students access SNAP by conducting outreach to colleges and developing guidance. Nevertheless, at 9 of the 14 colleges GAO contacted, some college officials and students said that they were unfamiliar with or did not fully understand SNAP's student eligibility rules. Some college officials said that they would like information from FNS to better explain SNAP student rules, but FNS has not made such information easily accessible on its website. Further, college officials and state SNAP agencies noted that FNS does not share examples of actions taken by other states to help eligible students access SNAP. Clarification of SNAP student eligibility rules and enhanced information sharing about state efforts could help ensure that potentially eligible college students can access federal food assistance programs.

GAO recommends that FNS (1) improve student eligibility information on its website and (2) share information on state SNAP agencies' approaches to help eligible students. FNS partially concurred, and plans to review its information. GAO continues to believe additional action is warranted, as discussed in the report.

In fiscal year 2017, the federal government spent over $122 billion in  grants, loans, and work-study funds through federal student aid programs  to help make college accessible to students. This substantial federal  investment in higher education is at risk if college students drop out  because they cannot afford basic necessities like food. The federal  government also spent $98 billion in fiscal year 2017 on nutrition  assistance programs, including $68 billion on the Supplemental Nutrition  Assistance Program (SNAP), the nation’s largest nutrition assistance  program, to combat food insecurity. College students enrolled at least half  time, however, are generally not eligible for SNAP benefits unless they  fall into certain categories designed to more narrowly target students in  need of assistance. According to some studies, college students who  experience food insecurity, which the U.S. Department of Agriculture  (USDA) defines as the condition of limited or uncertain access to  adequate food, may also experience decreased academic performance,  symptoms of depression and anxiety, and other negative mental health  indicators. In light of the potential obstacles to college students’  academic success posed by lack of access to adequate food, you asked  us to review the issue of food insecurity among college students.

This report examines: (1) what is known about the extent of food  insecurity among college students and their use of SNAP; (2) how  selected colleges are addressing student food insecurity; and (3) the  extent to which federal programs assist college students experiencing  food insecurity.

To determine what is known about the extent of food insecurity among  college students, we conducted an in-depth review of studies. To be  included, studies had to: (1) be based on research conducted in and  published in the United States; (2) be published after 2007; and (3)  contain original, direct estimates of food insecurity rates among college  students. We identified 35 studies that met these criteria, but  subsequently eliminated 4 of these from our in-depth review due to  concerns about their methodological limitations. We reviewed and  summarized the remaining 31 studies.

We also analyzed National Postsecondary Student Aid Study (NPSAS)  data from the 2015-2016 academic year, the most recent year available,  to estimate the prevalence of risk factors for food insecurity among  college students. Nationally representative survey data that would support  direct estimates of the prevalence of food insecurity among college  students do not currently exist. However, the National Center for  Education Statistics at the Department of Education (Education) regularly  collects NPSAS data, which contain nationally representative, detailed  demographic and financial data about college students. We assessed  the reliability of the NPSAS data by reviewing existing information about  the data and the system that produced them and by interviewing agency  officials knowledgeable about the data. As a result, we determined that  the data were sufficiently reliable for the purposes of this report. We  identified risk factors associated with food insecurity through a literature  review and through interviews with academic researchers, college  officials, state and federal officials, and relevant policy organizations. We  also analyzed NPSAS data to estimate SNAP participation among  potentially eligible students.

To understand how selected colleges address student food insecurity, we  conducted site visits in California, Kentucky, Massachusetts, and  Michigan. We selected a geographically diverse group of states where  colleges or state SNAP agencies were actively addressing food insecurity  among college students. In selecting these states, we reviewed literature  and asked researchers we interviewed about colleges and states that  were actively addressing food insecurity on campus. In each state, we  met with administrators, faculty, and students at selected 2- and 4-year  public colleges and with officials from the state agencies that administer  the SNAP program and other relevant organizations. Overall, we  contacted 14 colleges—seven 2-year and seven 4-year colleges—that  were actively addressing food insecurity among their students. We also  interviewed researchers and staff at policy organizations knowledgeable  about SNAP and college student food insecurity.

To assess the extent to which federal programs assist college students  experiencing food insecurity, we reviewed relevant federal laws,  regulations, and agency guidance and program documents. We emailed  the 51 state SNAP agency directors (all 50 states and the District of  Columbia) to ask whether their state agency is taking any action to  address college student food insecurity and received responses from 50  of them. We interviewed state SNAP agency directors in our site visit  states of California, Kentucky, Massachusetts, and Michigan, as well as in  Washington because of its innovative partnerships with colleges. We also  interviewed USDA Food and Nutrition Service (FNS) officials at the  national office as well as at four of the seven FNS regional offices. We  compared FNS’s communication and information sharing activities  against federal internal control standards. Further details on our  methodology are available in appendix I.

We conducted this performance audit from July 2017 to December 2018  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

The federal government, states, colleges, students and their families all  play important roles in financing higher education costs. Under Title IV of  the Higher Education Act of 1965, as amended, the federal government  offers students at all types of colleges financial assistance to help pay for  their education, such as through the William D. Ford Federal Direct Loan  (Federal Direct Loan), the Federal Pell Grant (Pell Grant), and the  Federal Work-Study programs. Some of this aid is targeted toward  students based on their financial need. For example, Education provided  almost $27 billion in Pell Grants to low-income students in fiscal year  2017. States also provide funding to public colleges through state  appropriations for operating expenses and grant programs that provide  financial aid directly to students based on financial need, merit, or a  combination of both. Despite the substantial federal expenditure in higher  education, rising college costs have outpaced federal and state grant aid  and, over time, have led to an increasing share of the cost being borne by  students and their families. For example, over the past 30 years, the  average in-state net price for a full-time undergraduate student at a public  4-year college—after taking into account all grant aid and education tax  benefits—has nearly doubled, from about $8,000 in 1990-1991 to nearly  $15,000 in 2017-2018. At public 2-year colleges, the net price for full-time  students increased over the same time period from about $6,800 to  $8,000.

To plan for the cost of college, students and their families must consider  the full cost of attendance, which includes not only tuition and fees, but  also room and board and other miscellaneous expenses. The federal  government requires colleges to estimate and distribute information on  the full cost of attendance to prospective and enrolled students. The  amount of need-based federal aid a student is eligible for is based, in  part, upon the school’s estimated cost of attendance.

National data show that, over the past several decades, an increasing  percentage of students from low-income households are enrolling in  college. According to NPSAS data, the percentage of all undergraduates  who had a household income at or below 130 percent of the federal  poverty line increased from 28 percent in 1996 to 39 percent in 2016. In  addition, the percentage of college students receiving a Pell Grant has  nearly doubled over roughly the same time period. For example, in 1999- 2000, approximately 23 percent of college students received a Pell Grant,  and in 2016, this figure was about 40 percent. Some researchers have  suggested that reductions in federal and state funding of higher education  relative to the increasing cost of college have coupled with these student  demographics to increase the share of college costs borne by students,  which can reduce the amount students have to support their basic needs,  such as food and housing.

A traditional college student is generally considered to be someone who  is enrolled in college full time immediately after graduating from high  school, is financially dependent on his or her parents, and either does not  work during the school year or works part time. However, these  students represent a minority of students enrolled in college today.  According to NPSAS data, about half of all undergraduate students  enrolled in college in 2016 were considered financially independent from  their parents. About 22 percent had dependent children themselves, and  14 percent were single parents. The average college student in 2016 was  26 years old and first enrolled at age 21. Sixty-four percent of college  students in 2016 worked at least part time while enrolled, and a quarter  worked full time. See figure 1 for the percentages of traditional and  nontraditional students in 2016 and for Education’s list of traditional and  nontraditional student characteristics.

Federal Food Assistance Programs Available to College Students

FNS oversees the states’ administration of SNAP, the main federal  benefit program to address food insecurity for low-income households. In  fiscal year 2017, the program provided benefits to about 42 million  individuals in more than 20 million households. The purpose of the SNAP  program is to safeguard the health and well-being of the nation’s  population by providing a monthly cash benefit to raise the purchasing  power and nutrition level of low-income households. FNS is responsible  for establishing program regulations and ensuring that state officials  administer SNAP in compliance with program rules. Officials in seven  FNS regional offices assist officials from the FNS national office in this  oversight work. FNS shares information and policy guidance with state  SNAP agencies in part through its regional offices, the FNS website, and  annual conferences. The states, or in some cases counties within a state,  administer SNAP by determining whether households meet the program’s  eligibility requirements, calculating monthly benefits for qualified  households, issuing benefits to participants on an electronic benefits  transfer card, and investigating and prosecuting recipient fraud. States  are also allowed to establish some state-specific modifications in how  they administer SNAP policy.

Beyond SNAP, the Special Supplemental Nutrition Program for Women,  Infants, and Children (WIC) is another federal food assistance program  available to eligible college students who are pregnant or postpartum.  FNS also oversees the WIC program, which is administered by state and  local agencies through approximately 10,000 clinic sites.

SNAP eligibility is largely based on a household’s income and certain  other characteristics. However, in 1980 federal law restricted college  students who are enrolled at least half time from receiving SNAP  benefits. This law generally prevents traditional college students—who  may appear to have a low income while attending college but receive  financial support from their parents—from receiving SNAP benefits.  Federal law establishes several exemptions to this restriction so that  college students who are enrolled at least half time and have a legitimate  need can access SNAP. For example, assuming that they meet all other  SNAP eligibility criteria, a full-time college student may be exempt from  the college student restriction if they are:  younger than age 18 or age 50 or older; a parent caring for a child under age 6; a parent caring for a child aged 6 to 11 who is unable to obtain  childcare to attend school and work; a single parent caring for a child under 12 years old and enrolled full working a minimum of 20 hours per week at paid employment; participating in a state- or federally-financed work-study program;  receiving Temporary Assistance for Needy Families (TANF)  benefits; not physically or mentally fit (e.g., have a disability); or enrolled in certain programs for the purpose of employment and  training.

FNS officials told us that states have flexibility regarding which programs  may qualify a student for the exemption pertaining to enrollment in certain  programs for the purpose of employment and training. These programs  must be operated by a state or local government, target low-income  households, and increase participants’ employability. State SNAP  agencies have discretion to determine which programs in their state  qualify. These employment and training programs may be operated at  community colleges, among other community partners.

FNS officials said that in 2014 the agency expanded its focus on SNAP  Employment & Training (E&T) program services, which are intended to  help individuals in SNAP households acquire skills, training, and work  experience that will increase their ability to obtain regular employment  that will ultimately lead to greater self-sufficiency and reduce their reliance  on SNAP. State agencies have flexibility in designing SNAP E&T  program services, and FNS encourages states to enter into partnerships  with established providers, including community colleges, to deliver SNAP  E&T program services. For example, a SNAP recipient could train to  become a Certified Nursing Assistant at a community college as part of a  state’s SNAP E&T program. In addition to providing employment and  training services, state SNAP E&T programs are required to provide  participants with necessary supportive services, such as transportation,  childcare, and textbooks.

Information about the Prevalence of Food Insecurity among College Students Nationally is Limited and Many Potentially Eligible, At-Risk Students Do Not Receive SNAP

Studies Identify a Range of Food Insecurity Rates among Respondents, but Results Cannot Be Generalized to All Students

Our review of 31 studies provided some information regarding food  insecurity among college students, but all of the studies have limitations  and none provide estimates of food insecurity for this population in  general. Estimates of food insecurity among college students included  in the studies we reviewed ranged from 9 percent to well over 50 percent,  with 22 of these of 31 studies estimating food insecurity rates of over 30  percent. These results reflect the studies’ different samples and  methods, and the estimates from the studies included in our review are  not generalizable to the college student population as a whole. None of  these studies are based on a sufficiently large or diverse random sample  of college students to constitute a representative study. The studies  addressed the difficulty of sampling the college student population in  different ways, including by extrapolating from household data, surveying  students in a particular degree program or on a particular campus, or  targeting particular, non-random sub-groups of the college student  population. Most of the studies were also conducted on only one campus, although some studies gathered data from more than one campus.  Despite the limitations, these studies as a whole help shed some light on  the range of food insecurity that exists among some groups of college  students.

Of the 31 studies we reviewed, 2 used nationally representative  household data sets, the Current Population Survey and the Survey of  Income and Program Participation. The study that used the Current  Population Survey data from 2011-2015 found that an estimated:

11 percent of households with a student in a 4-year college

14 percent of households with a student in vocational/technical  education experienced food insecurity, and

17 percent of households with a student in a community college  experienced food insecurity.

These national household surveys assess the food security of households  with a college student member, but they do not directly survey college  students and only measure food security at the household, and not the  individual, level. For example, these household data may not capture a  college student’s food insecurity in situations where the student member  of the household does not live at home for most of the year.

The remaining 29 studies we reviewed collectively surveyed college  students on approximately 200 campuses across multiple states,  including two large state university systems, and produced a wide range  of estimates of food insecurity. In most cases, the results can be  characterized as applying only to the respondents of the survey. The 29  studies based on campus surveys provide a range of food insecurity rates  among respondents, from 9 percent to over 50 percent.

For example, a study first published in 2017 found that 15 percent of  student respondents at one 4-year college experienced food  insecurity, with an additional 16 percent of student respondents at that  college estimated to be at-risk for food insecurity.

Two recent surveys of college systems in California found that 40  percent of respondents from University of California campuses and 42  percent of respondents from California State University campuses  experienced food insecurity.

Estimates of food insecurity rates in the studies we reviewed tended to be  higher at 2-year than at 4-year colleges. Four studies examined only 2- year college students and three of these studies estimated food insecurity  rates among respondents at 2-year colleges to be 40 percent or higher.  Three studies looked at both 2-year and 4-year colleges and estimated  food insecurity to be higher among students at 2-year colleges. For  example, a large, multi-college study conducted in 2017 found that during  the 30 days preceding the survey, 42 percent of community college  students who responded and 36 percent of students at 4-year colleges  who responded indicated they were food insecure. Further, the two  studies that used national household data sets found that households  with community college and vocational education student members had  higher food insecurity levels than households with students at 4-year  colleges.

Federal Data Show Most Low-Income Students Had Multiple Risk Factors Associated with Food Insecurity in 2016

We identified and analyzed the prevalence of risk factors associated with  food insecurity among students through our review of peer-reviewed  publications on food insecurity and through interviews with academic  researchers, college officials, state and federal officials, and officials from  relevant policy organizations. In the studies we reviewed and in our  interviews with researchers, having a low income was consistently  identified as a key risk factor for food insecurity. The other risk factors we  included in our analysis are: being a first-generation college student,  receiving SNAP, being a single parent, being disabled, being homeless or  at risk of homelessness, and being a former foster youth.

In our analysis, we focused on students with a household income at or  below 130 percent of the federal poverty line, which represents 39  percent of all undergraduates. While having a low income is itself the  most common risk factor for food insecurity among college students, our  analysis found that the majority of low-income students also experience  additional risk factors for food insecurity. The three most common risk  factors for food insecurity among low-income students were being a first- generation college student; receiving SNAP (receiving SNAP can be  considered a risk factor in that it may reduce, but not entirely eliminate,  food insecurity); and being a single parent. Of the approximately 7.3  million low-income students, 31 percent were first-generation college  students, 31 percent reported receiving SNAP, and 25 percent were  single parents. The prevalence of risk factors among low-income  students was lower at 4-year colleges compared to other colleges. For  example, about 21 percent of low-income 4-year college students were  single parents in 2016 compared to about 42 percent of low-income  students in less than 2-year programs. Low-income individuals enrolled in  less than 2-year programs had the highest prevalence for almost all risk  factors (see table 1).

Twenty-nine percent of all U.S. undergraduates had a low income and  experienced at least one additional risk factor for food insecurity,  according to our analysis of 2016 NPSAS data—14 percent had a low  income and one other risk factor and 15 percent had a low income and  two or more additional risk factors associated with food insecurity (see  table 2). Risk factors associated with food insecurity are more prevalent  among low-income students than among the general student population,  with 75 percent of low-income students experiencing one or more  additional risk factors. Students at 2-year colleges and those in less than  2-year programs were also more likely to have multiple risk factors.

Fifty-Seven Percent of Potentially Eligible Low- Income Students with Food Insecurity Risk Factors in 2016 Did Not Participate in SNAP

In our analysis of SNAP participation among students, we focused on  low-income students with at least one additional risk factor for food  insecurity because these students would likely meet the income threshold  for SNAP eligibility and have an additional risk factor that could put them  in need of food assistance. Our analysis of 2016 NPSAS data identified  about 5.5 million low-income students with at least one additional risk  factor for food insecurity and found that about 59 percent of these  students (3.3 million) reported being enrolled at least half time and  meeting a SNAP student eligibility exemption. About 1.8 million of these  low-income students with an additional risk factor reported meeting a  student exemption and also that they were not receiving SNAP  benefits. In other words, among potentially SNAP eligible low-income  students with at least one additional factor for food insecurity, 57 percent  did not report participating in SNAP in 2016 (see fig. 2).

About one-quarter of the 5.5 million low-income students with at least one  additional risk factor for food insecurity did not meet any of the student  exemptions we could identify in the NPSAS data and reported that they  did not receive SNAP benefits. These students would likely be ineligible  to participate in SNAP unless they begin meeting one of the student  eligibility exemptions in the future, such as working 20 hours per week.

Selected Colleges Are Using a Range of Approaches to Address Student Food Insecurity

The 14 selected colleges we contacted are addressing student food  insecurity in three main ways: by educating faculty, staff, and students; by  providing students free food and emergency assistance; and by  centralizing and coordinating their student services and helping students  apply for federal and state benefits. Officials at 9 of these colleges said  that they viewed student food insecurity as part of students’ increasing  inability to meet their basic needs as a result of the decreasing  affordability of higher education or the high cost of living. This sentiment  was echoed by selected students we spoke with during discussion groups  (see text box).

All of the colleges we contacted have implemented on-campus initiatives  to combat students’ food insecurity with the goal of improving their  student outcomes, such as retention, completion, and loan repayment  rates. As one community college official told us: “We have come to realize  that we can’t address retention and completion without addressing  students’ basic needs.” See figure 3 for the range of initiatives the 14  colleges we contacted were taking to address food insecurity among  college students on their campuses.

Educating the campus community. Officials at several of the selected  colleges told us that many administrators, faculty, staff, and students on  their campus are unaware that students experience food insecurity, which  hinders their college’s efforts to address the issue (see text box). At all 14  colleges we contacted, officials said they are educating their campus  community about available resources, both on campus and off, to  address student food insecurity.

All of the 14 colleges we contacted also educate their students about the  resources available to address food insecurity in a variety of ways, such  as by providing information during student orientations, on flyers and  pamphlets, or through social media and text messages. Eight of the 14  colleges we contacted hold trainings or distribute information to faculty  and staff about the on-campus and community resources available to  students. Nine of these colleges have created supplemental or for-credit  courses on topics such as financial literacy or cooking and nutrition. For  example, one college we visited runs a workshop for first-year students  on writing a spending plan and a food budget. At several of the selected  colleges, faculty members include blurbs about basic needs-related  resources, such as campus food pantries, in their syllabi.

Providing food and emergency financial assistance. All of the 14  colleges we contacted address student food insecurity by providing  students free food and most provide students emergency financial  assistance. Nationwide, the College and University Food Bank Alliance  has reported that at least 656 colleges have or were developing food  pantries as of September 2018. Each of the 14 colleges we contacted  had a food pantry, with 7 having started their pantry in the past 5 years.

According to college officials, individual faculty and staff members are  often first to identify food insecurity as a campus concern and provide  food to students. For example, officials at several of the colleges we  contacted traced the origins of their college’s food pantry to a drawer of  food a faculty or staff member kept in their office for students, or to a  professor who brought jars of peanut butter or bagels for any student who  wanted one.

The college food pantries we visited varied in terms of their size and  location, which can depend upon the space available on campus. For  example, some pantries we visited consisted of only a couple of shelves  of non-perishable items, while others spanned multiple rooms containing  refrigerators and freezers. Directors at four of the selected food pantries  said that student need was great enough to support expanding the food  pantry, but that they had been unable to expand because space on  campus is at a premium (see text box).

Several pantries also had separate sections providing students personal  health items and clothing and offered auxiliary services, such as  information about cooking, food budgeting, or SNAP enrollment (see fig. 4  for pictures of some of the college food pantries at selected colleges).

Officials at 11 of the selected colleges we contacted said that a major  barrier they face is overcoming the stigma some students associate with  accepting help for their basic needs, such as using the food pantry (see  text box). Concern about this stigma led at least 3 of the colleges we  contacted to place their food pantry in a less-public area of campus to  address students’ privacy concerns. In contrast, 3 other colleges we  contacted centrally located their food pantry to advertise its existence and  normalize its use. One college president we spoke with said that “until   normalized  and pulled it to the center of  campus, it was underutilized,” and stated that moving the food pantry to  the center of campus quadrupled its use.

Officials at 9 of the 14 colleges we contacted reported that their campus  food pantry had seen an increased number of users over time as the  student body became aware of this resource. One student we spoke with  said that his college’s food pantry was his only source of food, while  another estimated that the food pantry allowed him to save about $100  per month on food.

Officials at 10 of the 14 selected colleges we contacted told us they  partner with national organizations or campus dining services or both to  try to respond to the needs of students who might be experiencing food  insecurity. For instance, public colleges in California receive state funding  to incentivize them to address student food insecurity in a variety of ways,  including by establishing campus food pantries, providing information to  students about SNAP benefits, and establishing meal point donation  programs. Two California colleges we contacted were working with a  national organization to set up a meal point donation program. One  college in another state we visited included in their contract with their  private dining services vendor funding for several initiatives, such as a  campus-wide survey of student food insecurity, on-campus farmer’s  markets, and a learning kitchen that teaches students hands-on cooking  skills. Additionally, 2 of the colleges we contacted are working to have  SNAP benefits accepted at campus markets.

Beyond providing students with free food, officials at 12 of the 14 colleges  we contacted said that their college makes emergency cash assistance  available to students through small loans, grants, or grocery store or gas  station gift cards. These emergency funds are intended to help students  pay bills for one-time financial emergencies, such as buying groceries or  paying for a car repair or a utility bill. One community college we visited  directly ties this assistance to its retention efforts, providing a one-time  amount of up to $500 for students judged to have sufficient need and who  are likely to remain in school if the bill is paid.

Centralizing and coordinating student services and access to  benefits. Officials at many of the colleges we contacted told us they have  centralized their student support and financial aid services, among others,  and several have introduced a case management approach to better  collaborate across departments and more efficiently and holistically  address their students’ basic needs (see text box). Of the 14 colleges we  contacted, 8 had centralized some or all of their student services. For  example, one community college we visited has co-located many of its  student services—including its financial aid, academic counseling, payroll,  food pantry, veterans’ services, and women’s resource center, among  others—around a central hub of the student union. Students visiting this  central hub may be assigned a caseworker to connect them with the on- campus, community, state, and federal benefits for which they are  eligible. Officials at a few of the colleges we contacted said that centrally  locating student services also helped faculty and staff by providing a  single point of contact to refer students. One official said that she tells  faculty and peer mentors: “If you see a student in any kind of distress at  all—mental health, hunger, homelessness, anything—send them to us.”  She added that it is too much to ask faculty to figure out which office or  official to send students to for specific concerns.

Officials at 8 of the 14 colleges we contacted told us their campus has  established a coordinated benefits access program or is actively  screening students for potential eligibility for, and helping them enroll in,  federal and state benefit programs like SNAP, WIC, Medicaid, and the  Earned Income Tax Credit. For example, one community college we  contacted had a staff member build a statistical model to analyze the  college’s existing data on first-time students, such as data on students’  household income, demographics, and course enrollment, to identify  students at risk of not returning to college and to provide these students,  their professors, and their faculty advisors with information about on- campus resources. Officials at one college we visited told us the campus  hosts weekly clinics with county SNAP eligibility analysts to screen  students for SNAP eligibility and help them apply for benefits. At a  community college system we visited, the administration told us they were  working with the state SNAP agency to identify which students were  receiving SNAP benefits and they plan to send targeted information on  SNAP to those potentially eligible students not receiving benefits.

Officials at three of the colleges we contacted said that their college was  purchasing software that creates a centralized portal where faculty and  staff can share information about a student’s situation with student  support providers so they can better provide help. For example, at a  college we visited that is using such software, officials said that a  professor might note in the centralized portal that an at-risk student was  either failing or not attending a class, and that student would be flagged in  the portal to notify academic advisors, counselors, and other college staff  who can direct the student to the on-campus resources they may need,  such as the food pantry or help in completing a SNAP application.

While SNAP Can Supplement Other Federal Aid for Some Low-Income Students, FNS Does Not Share Key Information to Help States Better Leverage SNAP to Assist Students

Federal Programs Are Limited in the Extent to Which They Can Address the Needs of College Students Experiencing Food Insecurity

Federal Student Aid Generally Does Not Cover All College Costs for Low-Income Students

Federal grant aid is available to help low-income college students and  their families pay for college, but for many students, the maximum  amount of grant aid available to them does not cover all of the costs  associated with attending college. Officials from many of the  organizations we interviewed said that the federal Pell Grant Program for  low-income college students was a major source of financial support for  these students, but that it does not cover the full cost of college  attendance for many students, and particularly for those at 4-year  colleges or in areas with high costs of living. Most low-income students  also work while attending college. Despite this, several college officials we interviewed told us that the gap between the amount of financial aid  available and what it costs to attend college is continuing to grow. One  financial aid director told us that students used to be able to pay for  groceries or rent with some of their financial aid “refund” money (that is,  financial aid funds refunded to a student after tuition, fees, and other  school charges are paid, which can be used to pay for other education  and living expenses); however, he said students rarely receive a refund  any more. According to data from Education’s National Center for  Education Statistics, the average Pell Grant used to cover more of the  cost of college than it does today. For example, about 40 years ago— soon after the Pell Grant Program was established—the average award  covered about 50 percent of the average cost of in-state tuition, fees,  room, and board at public 2-year colleges, and 39 percent at public 4- year colleges. Today, the average Pell Grant award amount covers just  37 percent of these costs at public 2-year colleges, and 19 percent at  public 4-year colleges. Federal Work-Study Program employment  opportunities may be available to qualifying students, but several officials  we interviewed noted that funding for this program is extremely limited,  especially at community colleges where there are more students at risk of  food insecurity.

When grant funds and student earnings are insufficient to cover the full  cost of college, students can take out federal student loans to make up  the difference. Officials at a national association of community colleges  and at a few colleges we visited told us that low-income students often  use federal loans to help them pay for basic living expenses—such as  food or rent. While these loans can be helpful for some students who  need additional funds to support themselves while in college, officials at a  few community colleges also cautioned that loans may not be the best  choice for all students, and may worsen the financial position of already  vulnerable students. For example, at one 4-year college we visited, the  financial aid director said that many of their students have reached their maximum federal lifetime loan limit (see text box for an example). He  also noted that graduates have, on average, $25,000 of student loan  debt. He said his college has historically trained its students for public  sector careers, e.g., teachers or counselors, and he worries that salaries  in these professions will not allow graduates to repay this amount of  student loans.

College Students Have Limited Access to Federal Food Assistance Programs

Given the limitations of federal student aid funding, officials from several  organizations we interviewed spoke about the importance of leveraging  other federal benefits, such as food assistance programs, to help address  the needs of college students experiencing food insecurity. According to  research on the effect of SNAP benefits, these benefits can provide some  help to students, although they may not completely eliminate their food  insecurity. However, college students have limited access to several key  federal food assistance programs that could help address some of their  needs. For example, several college officials we spoke with noted that  many low-income students received federally subsidized free or reduced  price lunch while in elementary and secondary school, but a comparable  program does not exist for college students, even though many face the  same level of need. In addition, many college students are prohibited  from receiving federal SNAP benefits because of restrictions on student  eligibility. Several college officials told us that when students are unable  to meet one of the student exemptions for SNAP benefits, they will try to  connect them to community resources or to the on-campus food pantry,  but a few characterized these as short-term solutions to their students’  problems. We also heard from officials at several colleges that students  who are pregnant or postpartum may qualify for the WIC program, which  provides food assistance to mothers with infants and young children;  however, this program serves only a small minority of college students  who may be experiencing food insecurity.

Some State SNAP Agencies Are Assisting Potentially Eligible Students to Access SNAP Benefits

About one-third of state SNAP agencies reported they were taking actions  to inform college students about SNAP and help them access SNAP  benefits. These state SNAP agencies reported assisting college  students in various ways, including by developing guidance or training for  state and college officials on student eligibility rules, by conducting  outreach at local colleges, or by providing students with options to qualify  for a SNAP student exemption by participating in employment and  training services.

Several States Are Clarifying Student Rules and Conducting Training and Outreach about SNAP Student Eligibility

Eleven state SNAP agencies reported clarifying policy on college student  eligibility to SNAP staff who determine eligibility for benefits or providing  training to third-party partners to increase awareness of students’  potential eligibility for SNAP. For example, in 2015 and 2017 California’s  state SNAP agency issued policy letters to its county offices clarifying  college student eligibility rules and expanding the list of college programs  that qualify a student for an exemption under the employment and training  provision. Minnesota’s state SNAP agency reported that it conducts  technical assistance training on student eligibility issues for its  caseworkers twice a year.

State SNAP agencies also reported partnering with colleges to increase  awareness of potential student SNAP eligibility or to reduce the burden of  the application process for students. For example, Missouri’s state SNAP  agency reported that it recently began a partnership with the state’s  community college association to increase students’ awareness of their  potential eligibility for SNAP. To reduce the burden students face in  applying for SNAP benefits, Rhode Island’s state SNAP agency reported  that its outreach partner holds regular “office hours” at state community  college campuses to answer questions about SNAP, screen students for  potential eligibility, and assist with application completion. Officials from  California’s state SNAP agency stated that its county SNAP agencies  periodically hold SNAP enrollment clinics on college campuses. At one  time, a community college in California had a county SNAP staff member  located on campus to assist their students with benefit applications.

Finally, two of the states we visited partially fund their state higher  education grants for low-income college students with some of their  federal TANF block grant dollars. Because these grant recipients  receive TANF benefits, they are eligible for the corresponding SNAP  student exemption. For example, the California state SNAP agency  issued guidance in February 2017 to all of its county offices to explain  that this SNAP student exemption applies to any student who receives  the state’s higher-education grant for low-income students. In  Massachusetts, the state SNAP agency issued similar guidance in August  2017 to state SNAP staff who determine eligibility for benefits.

Some States Are Implementing Approaches that Provide Additional Employment and Training Options for Certain Students

Some state SNAP agencies are taking steps related to the exemption for  students who are enrolled in certain employment and training programs,  which can be offered at 2-year colleges and other community-based  organizations. Seven states reported taking steps to designate specific  programs at their community colleges to qualify as employment and  training programs to make it easier for students and SNAP staff who  determine eligibility for benefits to identify students who could meet this  exemption. In these states, according to the SNAP agency, they have  determined that certain programs at community colleges qualify enrolled  students for one of the student SNAP exemptions because they are  programs for low-income households, aimed at employment, and run by a  state or local government.

According to FNS, state SNAP agencies have the authority to decide  which programs would qualify enrolled students for this exemption, and  several states have identified qualifying programs at community colleges  in their state. Students in these designated community college programs  who attend at least half time and do not meet one of the other student  exemptions can be eligible for SNAP under this provision if they meet all  other eligibility criteria. In 2010, Massachusetts’ state SNAP agency  began using a dedicated form that provides community college students  in these state-designated employment and training programs support for  their SNAP application. According to officials at the state SNAP agency,  this form has helped to streamline the application process for both  students and state SNAP agency staff who determine eligibility for  benefits.

Other states are developing opportunities for students to meet the  employment and training exemption through partnerships with the states’  SNAP Employment & Training (E&T) programs. Twenty-four state SNAP  agencies reported that they have implemented a third-party partnership  with at least one community college to deliver SNAP E&T program  services on campus. Under these state SNAP E&T program  partnerships, the state SNAP agency works with community colleges to  enroll SNAP recipients in programs that are designed to increase the  employability of the participant. One FNS official told us that state SNAP  E&T programs were an ideal way to provide college students who qualify  for SNAP benefits with additional services and support, such as  counseling or transportation assistance, and that they can help students  persist in their community college program and ultimately improve their  self-sufficiency.

According to FNS, state agencies can enroll individuals in these SNAP  E&T programs in one of two ways. A SNAP recipient may enroll in the  designated community college training program affiliated with the state’s  SNAP E&T program, which allows them to continue receiving SNAP  benefits even if they attend the program more than half time. Or, the  community college partner can refer individuals already enrolled at the  college to the state SNAP agency to determine if they are eligible for state  SNAP E&T program services—a process known as a “reverse referral.” In  the case of a reverse referral, individuals who are enrolled in certain  training programs and who are experiencing food insecurity may be able  to qualify for a student exemption to receive SNAP, as well as additional  services through state SNAP E&T programs. According to Washington’s  state SNAP agency, SNAP E&T programs operate at all 34 community  colleges in the state, and have served approximately 20,000 students  each fiscal year since 2015. A senior program official at Washington’s  state SNAP agency told us that the vast majority of incoming community  college students in Washington are screened for potential eligibility and  reverse referral into the state’s SNAP E&T program services.

College and State Officials Reported That FNS Does Not Share Key Information That Could Help Them Assist Students Experiencing Food Insecurity

At 9 of the 14 colleges we contacted, some officials and students we  spoke with indicated that they either did not know about or found it difficult  to understand the SNAP student rules. For example, in a student  discussion group at one community college, some students said they  were uncertain about how SNAP student rules applied to them when they  lived with their parents but received no financial support or food from  them. Officials at another college told us that many students are not even  aware of or do not realize that the SNAP student rules apply to them. In a  student discussion group we held at another college, some students told  us that they had been unaware that they may be eligible for SNAP until  they spoke to someone at their college. Further, we found college officials  may also have difficulty understanding SNAP student rules—for example,  officials at one college said that they believed that college students are  not eligible for SNAP. College officials can be an important source of  information for students regarding SNAP, but this can create barriers to  access if college officials do not have the correct information. For  example, at one college we visited, two students said they were  misinformed by officials at their college or their state SNAP agency about  their potential eligibility for SNAP.

Officials we met with at three colleges said that they would like  information from FNS about college student eligibility rules so they can  help educate and enroll students in SNAP, but FNS has not developed  such targeted information to distribute to colleges and students. Officials  at one college said they requested information from FNS to distribute to  students, but the general SNAP eligibility brochure FNS provided did not  reference college student eligibility requirements. A senior FNS official  said developing printed materials expressly explaining the college student  eligibility requirements is primarily a state agency responsibility, and that  information about this topic was available on the FNS website. However,  we found that the information specifically related to college student  eligibility requirements on the FNS website was not easy to find. For  example, the main webpage of FNS’s SNAP eligibility website lists the  special circumstances under which certain specific populations may be  SNAP eligible, but it does not include college students nor does it link to  the webpage listing the student exemptions. Further, the webpage  containing information on SNAP for college students restates the list of  student exemptions from the regulations, using legal and technical  language that is not always easy to understand. For example, the  webpage states that students “may be able to get SNAP benefits if  otherwise eligible, and they ‘get public assistance benefits under a Title  IV-A program of the Social Security Act.’” Many college officials and  students may not realize this refers to TANF benefits. In addition, the  website does not list being “not physically or mentally fit” (e.g., having a  disability) as one of the ways to qualify for a student exemption, nor does  it provide information relevant to how students may qualify for an  exemption because they are assigned to or placed in certain employment  and training programs.

A senior official from the FNS national office said that college student  eligibility and the student exemptions were among the most complicated  SNAP policies to explain and that they frequently receive questions from  the general public about how the rules apply to certain students in certain  situations. This official said that because the student SNAP rules are so  difficult to navigate, FNS responds to these individual questions and  circumstances as they arise, rather than developing materials that could  apply broadly to every situation, and that state SNAP agencies are  primarily responsible for assisting students. Officials at all four FNS  regional offices we spoke with said materials explaining the student rules  tailored to colleges and college students would prove useful to states and  colleges in their regions. While developing clear written materials about a  complicated policy is challenging, Standards for Internal Control in the  Federal Government states that agencies should communicate key  information to their internal and external stakeholders. Further, a core  activity of the SNAP program is to work with its partners to ensure that  those eligible for nutrition assistance can make informed decisions about  applying for the program. The lack of clear and easily accessible information on student SNAP eligibility requirements can make it difficult  for potentially eligible students to make informed choices about applying  for SNAP, and for colleges to develop their own materials to help  potentially eligible students apply for SNAP. As a result, students could  miss opportunities to obtain the additional support they may need to stay  in college and graduate.

In addition, we found that some state SNAP agencies had limited  information about approaches that they could take to help potentially  eligible college students who may qualify for a student exemption.  Specifically, officials at four of the five state SNAP agencies and at three  of the four FNS regional offices that we spoke with said that it is not  entirely clear to them under which circumstances college students may be  eligible for a student exemption if they are enrolled in a qualifying  employment and training program run by a community college. State  SNAP agency officials in four of the five states, as well as officials in three  of the four FNS regional offices, told us that they would like more  information from FNS about how to implement the approach some state  SNAP agencies are taking to help college students who may qualify for  an employment and training exemption access SNAP. One state SNAP  agency official said that she believes that the lack of guidance and  leadership from FNS on this issue leaves many state SNAP agencies  operating with uncertainty, and, as a result, many of them do not take any  actions to identify those college students who may qualify for an  employment and training exemption under SNAP rules.

Several of the FNS regional office officials we interviewed agreed that the  FNS national office was uniquely positioned to collect and share  information about potential approaches that states are using to implement  the student exemption for employment and training programs so that  other states could also consider using such approaches to assist low- income college students who may qualify. Officials at one FNS regional  office said that an FAQ-type document on college student eligibility  scenarios would be helpful. At the same time, a few FNS regional office  officials said that the national office is cautious about developing  information for all states when each state’s SNAP program operates  slightly differently. According to FNS national office officials, FNS issued  the most recent document discussing general SNAP eligibility for students  in August 2010. This document explained that certain employment and  training services provided by a state or local government may qualify a  student for a SNAP student exemption. In November 2016, six federal  agencies including USDA (on behalf of FNS) released an interagency  letter, Aligning Federal Supports and Program Delivery for College  Access and Completion, that includes information from FNS related to  general student eligibility for SNAP.

However, neither of these documents included specific strategies or  examples of approaches states have used or can use to help potentially  eligible college students access SNAP benefits. Standards for Internal  Control in the Federal Government states that agency management  should internally communicate the necessary information to achieve the  program’s objectives. In addition, part of the role of the FNS national  office is to work with its partners, including its regional offices and the  state SNAP agencies, to improve program administration and ensure  access to benefits for eligible individuals. FNS officials told us FNS has  several existing mechanisms for information sharing with the regional  offices and the state SNAP agencies, including policy memos, webinars,  and annual conferences. However, a senior FNS official told us that she  was not aware of any plans to share additional information with state  SNAP agencies or regional offices on this topic, noting that college  students are a relatively small population compared to other SNAP  recipients. As a result, state SNAP agencies may not be aware of  approaches other states have used that they could take to assist college  students experiencing food insecurity in accessing SNAP benefits, and  FNS may not be fulfilling its role to ensure program access for college  students who are eligible.

In addition to noting how complicated the college student SNAP eligibility  rules are, most state higher education and SNAP policy organization  officials we interviewed remarked that the student exemptions can make it  challenging for many students who are food insecure to obtain SNAP  benefits that could help them succeed in college. Specifically, a few  researchers and state higher education officials said the eligibility  restrictions were instituted when college students were generally from higher-income households, whereas many students enrolled in college  today are from low-income households. Several higher education officials  and one researcher noted that when a student qualifies for a student  exemption by working 20 hours a week, it can have a detrimental impact  on college completion. For example, research has shown that full-time  college students who work more than 15 hours a week or who reduce  their college course load and attend part time in order to increase their  work hours are less likely to complete their degree or educational  program.

At the same time, FNS officials and officials at one state SNAP agency  stressed the importance of having proper controls in place to prevent  certain students from improperly receiving benefits. A senior FNS official  noted that the college student restrictions were established to prohibit  traditional college students who are supported by their parents from  receiving SNAP benefits. This official said that the student eligibility rules  should ensure that middle-class and wealthy students do not access  SNAP while attending college. Further, officials at a few organizations  and one state SNAP agency we interviewed expressed support for some  of the student exemptions, such as the exemption for college students  who work 20 hours per week.

The federal government invests billions of dollars annually in higher  education through grants and loans to low-income students. Partially as a  result of this investment, a college education is accessible to more low- income Americans than ever before. Despite this federal support, many  low-income college students struggle to meet their basic needs, including  obtaining the food that they need, and may drop out of college as a result.  SNAP can be an important source of support for low-income students,  although it may not completely ameliorate food insecurity. However,  because the SNAP eligibility requirements for college students can be  difficult for students and colleges to understand, students may be  unaware of or misinformed about their potential eligibility for SNAP. FNS  has not made information that clearly explains student SNAP eligibility  requirements easily accessible to students and college officials and, as a  result, students experiencing food insecurity may remain unaware that  they could be eligible for SNAP.

In addition, some states are exercising existing state flexibilities to help  students experiencing food insecurity to access SNAP, but FNS does not  actively share this information among state SNAP agencies. By collecting  and sharing information on approaches taken by state SNAP agencies  active in this area, FNS could potentially help state SNAP agencies  identify ways to help eligible students who are experiencing food  insecurity. Better supporting these students will also help the Department  of Agriculture and the Department of Education meet their respective  goals and make good use of the substantial federal investment in higher  education while improving the health and nutrition of individuals  experiencing food insecurity.

We are making the following two recommendations to FNS:  The Administrator of FNS should make information on their website  regarding student SNAP eligibility requirements easier to understand and  more accessible, as a resource for colleges and state SNAP agencies.  (Recommendation 1)

The Administrator of FNS should coordinate with its regional offices to  collect and review information about existing SNAP flexibilities and  examples of approaches state SNAP agencies are taking to assist eligible  college students to access SNAP benefits, and share such information  with state SNAP agencies. (Recommendation 2)

We provided a draft of this report to the Department of Agriculture and the  Department of Education for review and comment. The Department of  Education provided technical comments, which we incorporated into the  report as appropriate. On November 28, 2018, and December 7, 2018,  the Directors of the FNS SNAP Program Development Division and Office  of Employment and Training met with us to provide the agency’s  comments orally. At the December 7, 2018 meeting, FNS officials told us  they partially concur with our recommendations and believe that FNS has  sufficient guidance in place for states to provide further information to  colleges. However, the agency agrees with the intent of GAO’s  recommendations and plans to review its existing guidance to determine  if any improvements are warranted. We continue to believe that additional  action is necessary to address our recommendations. While reviewing its  existing information would be helpful, we believe that changes to FNS’s  existing information are also needed to improve the clarity and  accessibility of information about SNAP student eligibility requirements on  FNS’s website, and that FNS needs to work with its regional offices to  identify and share additional information about state approaches to assist  eligible college students with access to SNAP benefits. In response to  FNS officials’ comments, we also clarified both recommendations to focus  more on actions that fall under the responsibility of the FNS National  Office. FNS also provided technical comments, which we incorporated  into the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies of this report to the  Secretaries of Agriculture, Education, appropriate congressional  committees, and other interested parties. In addition, the report will be  available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-7215 or larink@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made key contributions to this report are  listed in appendix II.

Appendix I: Objectives, Scope, and Methodology

This report examines (1) what is known about the extent of food insecurity  among college students and their use of the Supplemental Nutrition  Assistance Program (SNAP); (2) how selected colleges are addressing  student food insecurity; and (3) the extent to which federal programs  assist college students experiencing food insecurity. This appendix  provides details of the data sources used to answer these questions, the  analyses we conducted, and any limitations to our analysis.

We used multiple methodologies to conduct this review. We conducted a  review of academic studies based on original research to determine what  is known about food insecurity among college students. We assessed the  quality of these studies by evaluating their research methods and  determined that the studies we included in our review were sufficiently  reliable for our use. To describe the prevalence of risk factors for food  insecurity among college students, we used data on student  characteristics from the nationally representative National Postsecondary  Student Aid Study (NPSAS). We assessed the reliability of NPSAS data  by reviewing existing information about the data and the system that  produced them and by interviewing agency officials knowledgeable about  the data. We determined that the data were sufficiently reliable for the  purposes of describing the prevalence of risk factors for food insecurity  among college students and students’ participation in SNAP.

To understand how selected colleges address student food insecurity, we  conducted four state site visits (California, Kentucky, Massachusetts, and  Michigan) selected based on whether colleges and/or state government  agencies were taking steps to address food insecurity among students,  and geographic diversity, among other criteria. In each state, we visited  public colleges and universities, where we met with college officials,  students, and researchers. We also interviewed state higher education  and SNAP officials, as well as experts from relevant policy organizations.  To assess federal efforts, we identified federal programs that may assist  college students in need of food, interviewed officials from Education and  USDA, and reviewed relevant federal laws, regulations, and agency  guidance and program documents, as well as federal internal controls  standards applicable to these programs.

To understand what is currently known about the extent of food insecurity  among college students, we conducted an in-depth review of studies. Our  preliminary search in Scopus identified a recent systematic literature  review on food insecurity on college campuses. Upon reviewing the  article’s scope and methodology, we chose to update rather than  duplicate their efforts. We expanded the original search terms to include  “higher education” and “postsecondary” among others, and searched two  additional research databases (ProQuest and Scopus) in addition to the  original list of sources (MEDLINE, PSYCHINFO, and Web of Science).  We identified peer-reviewed journal articles and other published research  through this search. Through news reports on food insecurity and  interviews with researchers, we also identified studies published up to  August 31, 2018 that may not have been included in our initial review. We  included studies in our review if they met the following criteria: (1) were  based on research conducted and published in the United States; (2)  were published since 2007; and (3) contained original, direct estimates of  food insecurity rates among college students.

We identified a total of 35 studies that met these criteria and conducted  an initial review to determine if the studies met generally accepted social  science standards and were appropriate for our purpose to provide  information on the prevalence of food insecurity among college students.  We eliminated some studies if we determined that the methods were not  appropriate or rigorous—specifically, we concluded that we could not  report the results of four studies due to research design limitations. For  instance, some studies did not fully disclose their methods, had small  sample sizes, used data based on low survey response rates, or did not  attempt to correct for or address potential biases in their methodology.  For studies included in this report, we performed an initial in-depth review  of the findings and methods, and a GAO methodologist performed a  second review to confirm our reported analysis of the findings. As a  result, we determined 31 studies to be of sufficient quality and we  summarized the findings of these 31 studies in our report (see table 3).

While these 31 studies are of sufficient quality to provide information on  what is known about food insecurity among college students, the  generalizability of their findings require significant caveats. Most of the  survey results in these studies are not generalizable to a population larger  than their sample size, meaning that the findings apply only to the  respondents of the survey. None of the studies in our review conducted  non-response bias analyses or attempted to address potential selection  bias in the sample. Despite these limitations, the studies collectively offer  assessments of food insecurity conducted on over 200 campuses in more  than 30 states, at both 2- and 4-year schools, and all but three of the  studies used adapted versions of the USDA food insecurity measure.

We analyzed data from the Department of Education’s (Education)  National Postsecondary Student Aid Study (NPSAS). Because no federal  datasets contain food insecurity data specifically about college students,  we chose to analyze NPSAS data for the prevalence of risk factors  associated with food insecurity. Additionally, we used some summary  statistics from frequencies presented in the 2016 NPSAS data codebook.

NPSAS data contain nationally representative, detailed demographic and  financial aid data for college students enrolled in less than 2-year, 2-year,  4-year, and graduate postsecondary programs. These data come from  institutional records, government databases, and interviews with students.  Because the NPSAS data are based on probability samples, estimates  are calculated using the appropriate sample weights provided which  reflect the sample design. Each of these samples follows a probability  procedure based on random selection, and they represent only one of a  large number of samples that could have been drawn. Since each sample  could have provided different estimates, we express our confidence in the  precision of our particular sample’s results as a 95 percent confidence  interval. This is the interval that would contain the actual population value  for 95 percent of the samples we could have drawn. Unless otherwise  noted, all percentage estimates from the NPSAS data analysis have 95  percent confidence intervals within plus or minus 5 percentage points of  the percent estimate, and other numerical estimates have confidence  intervals within plus or minus 5 percent of the estimate itself. We  compared 95 percent confidence intervals to identify statistically  significant differences between specific estimates and the comparison  groups. The information provided in the NPSAS data, particularly those  from the interview portion of the study, are self-reported and not all of the  data are based on federal determinations or cross-verified with outside  sources. For example, students self-report their disability status, their  hours worked, and so on. Such self-reported data are subject to several  sources of nonsampling error, including the inability to obtain information  about all sample cases; difficulties of definition; differences in the  interpretation of questions; respondents’ inability or unwillingness to  provide correct information; and errors made in collecting, recording,  coding, and processing data. These nonsampling errors can influence the  accuracy of information presented in the report, although the magnitude  of their effect is not known.

Identification of Risk Factors for Food Insecurity  In order to identify risk factors associated with food insecurity among  college students, we reviewed published articles and reports on the topic  of food insecurity and interviewed researchers, college and state officials,  and officials at relevant policy organizations. We present the list of risk  factors for food insecurity we considered in table 4. Not all of the risk  factors we identified have a corresponding NPSAS variable. For example,  NPSAS does not ask respondents about unmet medical needs or  childhood food insecurity. Additionally some of the risk factors overlapped  and were thus not included in our analysis. For example, the NPSAS  dataset contains multiple variables pertaining to student and student  household income, such as household income, financial aid, and receipt  of public benefits. Many indicators of low-income status likely overlap  (e.g., being eligible for a Pell Grant and receiving other financial aid), and  many students who have one indicator will likely have others.

Although this is not an exhaustive list of risk factors, individuals who  experience one of the following seven characteristics may be at risk of  food insecurity: being disabled, homeless or housing insecure, being a  former foster youth, receiving SNAP benefits, being a single parent, and  being the first-generation in a student’s family to attend college. Table 5  shows how we compared these risk factors with corresponding variables  from the 2016 NPSAS data.

Table 5. Selected Risk Factors and Corresponding Variables in the 2016 National Postsecondary Student Aid Study Data Set  Description  Indicates student has some type of disability or condition.

Includes some students who were determined by a professional to be homeless (via the  Free Application for Federal Student Aid or FAFSA), but predominantly measures student- determined “risk of homelessness.” This is not a direct measure of homelessness.

Indicates student is an orphan, ward of court, emancipated minor, or in legal guardianship.

Indicates whether any member of the student’s household received Food Stamp (SNAP)  Benefits during the 2013 or 2014 calendar year.

Identifies independent students who were single parents/caretakers during the 2015-2016  academic year.

Indicates total 2014 income as a percentage of the federal poverty level thresholds for  2014. For our purposes, low income is defined as having a household income level at or  below 130 percent of the federal poverty level.

Indicates the highest level of education achieved by a parent, stepparent, or guardian of  the student. Per previous Department of Education studies, we define first generation as  college students whose parents’ maximum educational attainment was a high school  diploma or less. Note that students who did not know their parent’s highest education were  not counted as first generation students.

The data are self-reported. The student may not be eligible for or receiving federal disability benefits.  The data are reported by the student and their family on the FAFSA or during the student interview.  National level, individual SNAP enrollment data are not available to verify this variable, as states  provide aggregate statistics to FNS.

Because our analysis does not include some of the risk factors for food  insecurity listed in table 4, our findings may underestimate the number of  college students who have a risk factor for food insecurity. For example,  we heard in some of our interviews with researchers and in our  discussions with students that being an undocumented or an international  student was a risk factor for food insecurity. Such students are generally  ineligible for federal financial aid and are restricted in the type of other  federal aid they can receive. Undocumented students are also more likely  than other students to be poor. However, NPSAS does not contain  detailed data about undocumented or international students, so we could  not include this risk factor for food insecurity in our analysis. The risk  factors for food insecurity we included in our analysis may also be  correlated with one another and can co-occur. For example, youth who  were formerly in foster care are more likely than other youth to be low- income. Indeed, the prevalence of additional risk factors for food  insecurity is higher among low-income than wealthier students. We did  not analyze the extent to which some risk factors are more strongly  associated with food insecurity than others or attempt to rank or weight  the relative importance of risk factors.

To calculate potential student SNAP eligibility, we first calculated the  number of students who might qualify for SNAP based upon having a  household income at or below 130 percent of the federal poverty line,  which is the standard income requirement for households that do not  include a member who is 60 years of age or older or disabled to qualify  for SNAP benefits. Next, we analyzed NPSAS variables to identify those  that corresponded with SNAP student eligibility rules. We deemed all  students who met the income requirements, were enrolled in school at  least half time, and met one of the student eligibility exemptions we were  able to identify in the data as potentially eligible for SNAP.

However, our analysis has limitations and does not precisely identify all  students who are SNAP eligible. The 2016 NPSAS data set contains  several variables that match up closely with certain student eligibility  exemptions. For example, the exemptions related to age, having young  dependents, working 20 hours per week, and receiving certain federal  benefits have corresponding NPSAS variables (see table 6). For two of  the exemptions, we used variables from the NPSAS data set that do not  perfectly correspond to the statute but were the closest available proxies  in the data. For the eligibility exemption that covers parents caring for a  child 6-11 years old who are unable to obtain childcare to attend school  and work, we identified students who have a child 6-11 years old and  indicate they have no paid childcare. However, some individuals may  have unpaid childcare, such as family members, and be able to work and  attend school despite not having paid childcare, meaning they would not  meet this SNAP student eligibility exemption. For the disability exemption,  we used the NPSAS variable based on an interview question that asks  students if they have a mental or physical disability. However, because of  different definitions, the NPSAS disability variable may include students  with disabilities who would not qualify for the SNAP student exemption  related to disability. Specifically, to qualify for this SNAP student  exemption, the student must not be “physically or mentally fit,”, while the  NPSAS interview question asks students if they have some type of  disability or condition, including a long-lasting condition such as serious  difficulty hearing; blindness or serious difficulty seeing; difficulty  concentrating, remembering or making decisions, a serious learning  disability, depression, or Attention Deficit Hyperactivity Disorder; or  serious difficulty walking or climbing stairs. As a result, we may  overestimate the number of students who would qualify for the student  exemption related to having a disability or caring for a child age 6-11.  Lastly, NPSAS does not contain a variable to capture the student  eligibility exemption related to enrollment in certain programs aimed at  employment, such as the Workforce Innovation and Opportunity Act or  Temporary Assistance for Needy Families employment and training  programs. Therefore, we could not identify any students who met this  eligibility exemption for SNAP and may have therefore underestimated  the number of students who were potentially eligible for SNAP.

Additionally, SNAP eligibility for college students depends not only on  income and meeting a student exemption, but also on other  determinations such as the level of the individual’s financial assets,  including savings and any state policy waivers that may apply to the  individual’s eligibility. Given that our analysis relied on self-reported  information, and did not capture all aspects of student SNAP eligibility, we  did not make any legal determinations about whether individuals were  eligible for SNAP, and therefore our analysis can be characterized as  providing only a rough estimate of those students who may potentially be  eligible for SNAP benefits.

To understand how selected colleges address student food insecurity, we  conducted four state site visits (California, Kentucky, Massachusetts, and  Michigan). We selected these states based on the following criteria:

Mentioned in interviews with researchers or government officials as  being a state that is: actively addressing college food insecurity, or  has at least one public college that is taking action to address food  insecurity among college students (number of mentions).

School or state program on hunger or food insecurity featured in  research papers or policy briefs (number of mentions).

FNS data on food insecurity rates in the state, to indicate whether  food insecurity among college students might also be a problem (rank  by state).

FNS data on SNAP enrollment and participation in the state, to  indicate the level of SNAP usage in the state (rank by state).

FNS information regarding the number of SNAP waivers a state has  received, as a proxy for SNAP policy activity in the state (rank by  state).

We also sought geographic diversity in our site visit states. To achieve  this, we created summary rank ordering of states based upon our criteria,  then, from those states that ranked in the top 15, we selected one state  from the Northeast, South, Midwest, and West census regions. Some of  our criteria were purely qualitative in nature, such as information from  interviews, research papers, and policy briefs regarding states and  colleges with promising practices. Our site visit selection focused  specifically on states and colleges with documented activity addressing  college student food insecurity, and is therefore biased toward those that  had taken action to address college student food insecurity. Our selection  strategy did not capture situations where there was high food insecurity  among students but the college or state was taking no action to address  it, nor did we seek to identify or visit locations where food insecurity had  not been identified as a problem. In addition to our site visits, we  conducted interviews with officials from one college in Texas and one  college in Ohio to learn about specific campus food insecurity initiatives in  these states.

In each site visit state, we visited several colleges that were taking action  to address food insecurity among their student populations, selected  based on recommendations from researchers and college officials. We  also considered geographic proximity when selecting colleges to visit.  Overall, we spoke with officials representing 14 2- and 4-year public  colleges (12 in-person and 2 telephone interviews). In each of our site  visit states, we visited at least one large public university and one  community college. See table 7 for a list of the 2- and 4-year colleges we  interviewed in each state.

At colleges, we asked members of the leadership team, financial aid  officers, student affairs administrators, and other staff members questions  about how they recognize, measure, and address college student food  insecurity. We also conducted discussion groups with students at seven  colleges we visited and asked about their experiences with food insecurity  and federal assistance programs, such as SNAP. Students were invited  by college officials to participate in these meetings. In each state we  visited, we also met with officials from the state agencies that administer  SNAP and any state governmental agencies, such as those overseeing  higher education or involved in addressing food insecurity among college  students. Lastly, in each site visit state, we identified and interviewed staff  members at policy organizations, such as legal policy institutes or hunger  advocacy groups, involved in efforts to address food insecurity among  college students.

Assessing Federal Efforts to Address Food Insecurity  We assessed the extent to which federal programs assist college  students experiencing food insecurity by reviewing relevant federal laws,  regulations, and agency guidance and program documents related to  specific SNAP requirements for college students and we interviewed FNS  national office officials, including representatives of the Divisions of SNAP  Program Development, Employment and Training, and Retailer Policy.  We also interviewed FNS regional office officials in four of the seven FNS  regions about their experiences working with the FNS national office and  with state SNAP agencies in their regions to address college student food  insecurity and access to SNAP.

We also sent an email to all 51 state SNAP agency directors (all 50 states  plus the District of Columbia) to ask about any actions their state has  taken to address college student food insecurity. We received responses  from 50 of the 51 state SNAP agencies, for a 98 percent response rate.  This email inquiry was conducted in March and April 2018 and may not  include all state actions that have occurred since April 2018.

We conducted in-depth interviews with officials at five state SNAP  agencies and asked about any specific policies or actions their agencies  have taken to address college student food insecurity or to assist  potentially eligible college students to access SNAP. We conducted these  interviews in person with state SNAP agencies during our four state site  visits, and interviewed the Washington state SNAP agency by phone.

We conducted this performance audit from July 2017 to December 2018  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: GAO Contact and Staff Acknowledgments

In addition to the contact named above, Michelle L. St. Pierre (Assistant  Director), Nora Boretti (Analyst-In-Charge), Jessica K. Rider, and  Stephen C. Yoder made significant contributions to this report. Also  contributing to this report were Holly A. Dye, Barbara J. El Osta, Sarah C.  Gilliland, Alison E. Grantham, Gina M. Hoover, Saida B. Hussain, Sheila  R. McCoy, John W. Mingus Jr., Mimi Nguyen, Monica P. Savoy, Benjamin  A. Sinoff, Almeta Spencer, Rachel R. Stoiko, Elaine L. Vaurio, and David  A. Watsula.

Many college students may not have enough to eat—but nobody knows exactly how many. Studies show a range of estimates, but none of the 31 we reviewed provided a national estimate. We also looked at student use of the Supplemental Nutrition Assistance Program. Of the 3.3 million students who were potentially eligible in 2016, less than half said they participated.

Colleges have responded to student hunger by opening food pantries and helping students understand complicated SNAP rules.

We recommended the Food and Nutrition Service clarify the rules and share information on how states help eligible students use SNAP.