Audit: Kansas at-risk funding tied to free-lunch count may be inflated by tens of millions

Heidi Zimmerman, principal auditor at Legislative Post Audit, told the Committee on Welfare Reform on Jan. 20, 2026, that "the number of free lunch students used for determining at risk funding appears to be significantly more than the number of students who may be eligible for the free lunch program." She presented methods and caveats after giving that short answer.

Zimmerman explained how the National School Lunch Program determines eligibility: students can qualify automatically through participation in federal benefit programs such as SNAP, TANF or Medicaid, by being in foster care, or through the community eligibility provision (CEP); other students qualify by submitting the federal free-lunch application reporting household income. In Kansas, the state's at-risk funding is largely allocated based on the number of students counted as eligible for free lunch.

To test whether application-based counts reflected true eligibility, auditors compared information from a random sample of applications to Kansas Department of Revenue tax records and Department of Labor wage data when available. Zimmerman said auditors found that, among the applications they could verify, a substantial share did not appear to meet the income test. "We estimate that between 54% to 72% of all…