NYHealth submitted the following comments on the New York State Education Department’s (NYSED’s) proposed rule regarding outreach for the Supplemental Nutrition Assistance Program (SNAP).
November 24, 2025
Angelique Johnson-Dingle, Deputy Commissioner
Education Department, P-12 Instructional Support
55 Hanson Place, Room 400, Brooklyn, New York 11217
(718) 722-2797
Regcomments@nysed.gov
I.D. No. EDU-38-25-00009-P
Re: Notice of Proposed Rule Making: Outreach for the Supplemental Nutrition Assistance
Dear Deputy Commissioner Johnson-Dingle,
The New York Health Foundation (NYHealth) appreciates the opportunity to comment on New York State Education Department’s (NYSED’s) proposed rule regarding outreach for the Supplemental Nutrition Assistance Program (SNAP).
NYHealth is a private foundation that works to improve the health of all New Yorkers, especially people of color and others who have been historically marginalized. Our Healthy Food, Healthy Lives program seeks to advance policies and programs that connect New Yorkers with the food they need to thrive. Maximizing participation in nutrition benefits programs, like SNAP, is a core strategy of this program. Our work has provided us with in-depth knowledge of how food insecurity has widespread negative ramifications on the health of individuals and their families, as well as the ways the proposed rule could improve the lives of families across New York.
SNAP is our nation’s largest anti-hunger program, helping nearly 3 million New Yorkers, including more than 850,000 children, supplement their monthly food costs.[1] SNAP lifts families with children out of poverty and improves child health. Research indicates that participation in SNAP can lead to improvements in reading and math, as well as the likelihood of graduating from high school.[2] Despite these benefits, many potentially eligible New Yorkers do not participate in SNAP.
Schools are well-positioned to address the gap in participation. Federal regulations already require schools to publish information regarding the availability and eligibility criteria for free and reduced-price meals.[3] As trusted messengers within communities, schools can leverage their existing communication channels to connect families to another nutrition program, SNAP.
NYHealth strongly supports SNAP outreach as a requirement for all schools participating in the State’s Universal Free Meals Program. Effective SNAP outreach in schools is integral to the sustainability of New York’s Universal Free School Meals Program. When more students participate in SNAP, schools can draw down more federal reimbursement through the federal school lunch and breakfast programs. Maximizing federal dollars in this way ensures that the administration of the Universal Free School Meals Program is both sustainable and cost-effective. For schools, increased SNAP uptake among families also translates to administrative efficiencies, with fewer resources spent on collecting income information from households.
SNAP outreach in schools is also a strategic opportunity to connect families with supports beyond nutrition. Families participating in SNAP no longer need to submit their income information to their schools, and they are automatically eligible for other benefits, such as fee waivers for testing, discounts on Advanced Placement (AP) courses, and Summer Electronic Benefit Transfer (EBT) benefits.
Recommended Amendments
To strengthen the final rule, we offer the following recommendations:
I. Set standards regarding the timing, frequency, and modes of outreach. We recommend that the rule requires schools to distribute SNAP educational materials at least three times each school year: at the start of each school year, mid-year, and at the end of the school year. These timeframes align with other routine district outreach to families, as well as required timelines for data reporting to the State. Schools operating the Summer Food Service Program should also be required to inform families about the availability of SNAP at service sites.
New York’s SNAP outreach requirement for schools should align with federal requirements regarding free and reduced-price school meals. SNAP outreach messaging that is strategically paired with other types of information regularly sent to families, including school lunch menus, forms to collect free/reduced-price application, or household income forms, will be more likely to reach families.
Each school or district participating in the Universal Free School Meal program should be required to provide SNAP educational materials, local SNAP outreach provider contact information, and information on how to apply. Schools can also add this information to the district’s website, social media channels, parent apps, or other relevant communication channels.
II. Ensure that direct referrals to SNAP are effective. We commend that the proposed rule instructs schools to provide direct referrals to local SNAP outreach providers which offer eligibility pre-screening, application assistance, and program education. Connecting families to SNAP navigators, such as those working under the State-funded Nutrition Outreach and Education Program (NOEP), is among the most effective ways to help families enroll in SNAP. NOEP is the State’s largest SNAP outreach program, operating through a network of community-based organizations. Statewide, more than eighty SNAP navigators provide confidential, no-cost services to individuals and families in their respective counties or boroughs.
Schools should also leverage online tools, such as Hunger Solutions New York’s SNAP eligibility pre-screening tool, which help families quickly determine if they are potentially eligible. It also provides contact information for local SNAP outreach providers. Schools have successfully connected families to SNAP by including this tool on their websites and other districtwide communications to families.
III. Continue to improve State-level data systems that support SNAP. The statewide direct certification database, which currently merges SNAP, Medicaid, and student data, helps to ensure schools can accurately and efficiently certify children who are automatically eligible for free school meals. NYSED’s ongoing efforts to improve the direct certification system’s match processes and algorithms have yielded strong results, increasing the system’s match rate from 84% in the 2016-2017 school year to 100% by the 2018-2019 school year.[4],[5] As data systems continue to evolve, New York should continue to implement best practices, such as monthly SNAP data uploads and probabilistic matching software investments, and continue to invest in new technology.
NYHealth supports the intent of the proposed rule. At a time of increased food insecurity among New Yorkers, which disproportionately impacts households with children, schools are critical partners in safeguarding students from hunger.[6] This rule will provide schools with guidance on conducting effective SNAP outreach and ensuring that eligible children are connected to nutrition support at home. It will also ensure an efficient and sustainable Universal Free School Meals Program, maximize federal dollars to strengthen food security, and advance New York as a national leader for anti-hunger policy.
We thank the State Education Department for the opportunity to comment on this proposed rule and encourage careful consideration of the recommendations provided.
Sincerely,
David Sandman, Ph.D.
President and CEO
New York Health Foundation
References
[1] New York State Office of Temporary and Disability Assistance. Who Benefits from SNAP? May 2025. https://otda.ny.gov/resources/reports/SNAP-Congressional-Districts.pdf.
[2] Carlson S, Rosenbaum D, Keith-Jennings B, Nchako C. SNAP Works for America’s Children. Center on Budget and Policy Priorities. September 29, 2016. https://www.cbpp.org/research/food-assistance/snap-works-for-americas-children#:~:text=Children%20who%20receive%20SNAP%20do,graduation%2C%20and%20program%20participation).
[3] United States Department of Agriculture, Food and Nutrition Services. Eligibility Manual for School Meals Determining and Verifying Eligibility. July 18, 2017. https://fns-prod.azureedge.us/sites/default/files/cn/SP36_CACFP15_SFSP11-2017a1.pdf.
[4] United States Department of Agriculture, Food and Nutrition Services. Direct Certification in the National School Lunch Program: State Implementation Progress Report to Congress School Year 2015-2016 & School Year 2016-2017. October 2018. https://fns-prod.azureedge.us/sites/default/files/resource-files/NSLPDirectCertification2016.pdf.
[5] United States Department of Agriculture, Food and Nutrition Services. Direct Certification in the National School Lunch Program: State Implementation Progress Report to Congress School Year 2017-2018 & School Year 2018-2019. June 2021. https://fns-prod.azureedge.us/sites/default/files/resource-files/NSLPDirectCertification2017-1.pdf.
[6] Okonkwo C, Ford MM, McCarthy J, Barrett A, Havusha A. Sandman D. Hunger on the Rise: New York’s Food Insufficiency Rates Hit New Highs and Exceed Pandemic Levels. New York Health Foundation. 2025. https://nyhealthfoundation.org/resource/hunger-on-the-rise-nys-food-insufficiency-2024update/.
