Work and Pensions Committee - Universal Credit implementation: meeting the needs of vulnerable claimantsWritten evidence submitted by the Children’s Food Trust


The Department for Education (DfE) has not yet published proposals for how free school meals will operate under Universal Credit, so this submission focuses on core principles and practical measures which will support the need to simplify the benefits system whilst also protecting the nutrition of children living in poverty, and helping Local Authorities and schools to manage the transition.

Key Points

Free school meal registration should be an integral part of the Universal Credit system, with no additional barriers to registration.

Free school meals must remain a benefit “in kind”.

Tapering of benefits is preferable to “cliff edges” for supporting the nutrition of children living in poverty, but this needs to be managed in a way that is practical for schools and children.

Making registration for free school meals automatic under Universal Credit would support local authorities in making the transition to the Universal Credit system.

Monitoring of free school meal registration and take up should be among the key priorities during this transition.


1. A national charity, the Children’s Food Trust believes that children must eat healthily to reach their full potential in life. By ensuring a balanced diet in their early years and at school, together with better family cooking skills, lifestyle and food education, the Trust exists to help protect every child’s right to eat better—and so, to do better.

2. The introduction of Universal Credit has major implications for the nutrition of children living in poverty. An estimated one million children are currently taking up a free school meal;i hundreds of thousands of other children are either not registered to have the free meals for which they would qualify, or do not take them up for a whole range of reasons. Research suggests that around a third of school-age children living in poverty don’t qualify for free school meals at all.ii

3. The impact of a good meal at school for children living in poverty is well-documented, and is the basis of our fundamental recommendation that all children living in poverty should have a free meal at school. Primary school children are three times more focused and able to concentrate with their teachers after a healthier lunch in a more pleasant environment;iii in secondary schools, those “on-task” behaviours increase by 18%.iv Recent research measuring the impact of universal free school meals for children in primary schools in Durham and Newham found that attainment improved by up to two months—an impact which tended to be strongest amongst pupils from less affluent families and amongst those with lower prior attainment.v For too many children, their free school meal may be the only proper meal they eat in a day. Overall, pupils having school meals tend to choose healthier foods and drinks more often than those who bring a packed lunch or buy food outside of school. Average nutrient intakes from school lunches are more often in line with healthy eating recommendations than those from packed Access to good food at school also helps all children to develop good eating habits and to get consistent messages about what it means to eat well. These are shared with their families, and can play a significant role in assisting them to maintain a healthy weight and good health.

4. Eligibility for and operation of passported benefits

4.1. Free school meal registration should be an integral part of the Universal Credit system, with no additional barriers to registration. The main thrust of Universal Credit is to remove complexity and simplify application processes. The free school meal registration process is crying out to be simplified. We know that the current system—which requires parents to understand complex eligibility criteria, recognise their entitlement and then submit a free school meal application using a process which differs across every local authority in the country—acts as a significant barrier to many families in accessing free school meals, meaning that many children miss out.

4.12 Universal Credit is the logical time to make an improvement which has long been called for. DfE has previously recognised that the complexity of the current system acts as a barrier to registration. Simplifying the process, by making free school meal registration automatic under Universal Credit, will help to ease the transition for local authorities (who will otherwise need to conduct complex communication and checking activities to determine which children qualify for free school meals, and will be required to run two systems simultaneously whilst the system is phased in), and would make life considerably easier for schools trying to administer free school meals effectively. And, of course, the simplification would lead to more eligible children eating a nutritious school meal every day—the most important issue. If a legislative change is necessary to make this change, there is an opportunity (via the Children and Families Bill) to pursue this. If this opportunity is not taken, families will continue to be confused about eligibility for free school meals, put off from registering because of the complexity of the process and, most importantly, children who are most in need of a good meal at school will be going hungry.

4.13 Finally, given the low levels of awareness of who qualifies for free school meals and how to register under the current system, we have serious concerns that should a large cohort of families become newly entitled to free school meals, the complexities of the current registration system could actually result in a sizeable fall in the number of children registered for free school meals. Not only will these children will be missing out on the nutritious meal to which they are entitled, but this will also impact on levels of Pupil Premium funding to schools.

5. Free school meals must remain a benefit “in kind”, to ensure that this funding remains focused on nutrition for children. For families living on such a tight budget, school meals may not be the first choice if they receive the benefit as cash instead.

5.1 The perception that a “healthy” packed lunch can be made for far less than the cost of a school meal remains very strong. The reality is that to produce packed lunches which are as nutritious as school meals requires a considerable investment of time, money and effort. Research shows very clearly that the vast majority of packed lunches are less healthy and nutritious than school meals.vii If families are given cash in place of an “in kind” benefit they may give the child a small amount of cash which is likely to end up being spent on things like poor quality fast food, and confectionary outside of school. Our research with pupils shows that they are careful to make their money stretch as far as possible, and that they make what they perceive to be rational decisions about the food they buy in order to save their money for other, “more important” things.

The level of the earnings disregards:

6. In the interests of nutrition for children living in poverty, we would prefer to see tapering of benefits rather than cliff edges. However, when a taper is applied to school meal eligibility, it needs to be managed in a way that is practical for schools and children.

6.1 Administering tapering effectively would mean working very closely with Local Authorities, schools, caterers and others to make sure that robust systems are in place to minimise the added complexity. The widespread introduction of cashless systems in secondary schools and online systems which allow parents of children at primary school to pay for meals would almost certainly be necessary. We do not know for sure what percentage of schools currently operate a cashless system. In 2011,viii Local Authorities reported on cashless systems for 2,297 secondary schools. Of these, 908 (38%) had cashless systems, 603 (25%) did not, and for 786 (33%) it was unknown whether schools had a cashless system. It must be recognised that costs of installing a cashless system can range between £7,000 and £10,000 with annual upkeep charges being about 10% of the installation price.

6.2 Whilst we support the principle of tapering, we do have concerns about how difficult this could be for local authorities, schools and catering teams to administer. A taper should operate on a principle of “whole meals”. For example, a taper might be offered to support a family with three of a child’s five school meals in a week (60% of a child’s weekly meals), but should not be offered as a proportion of an individual meal (30, 50 or 70% of meals in a week). This latter would not encourage pupils to eat a balanced meal, and would make administering the taper almost impossible for many schools and caterers. Feedback from our Caterers’ Forum has echoed these concerns.

The impact of the changes on Local Authorities, including budgets, staff and support for claimants

7. Making registration for free school meals automatic under Universal Credit would support Local Authorities in making the transition.

This will ease complexity for Local Authorities and schools, reducing bureaucracy around free school meals and ending the current variation in and around the application process around the country.

Impact monitoring: what the DWP’s priorities should be for monitoring the impact of the transition to Universal Credit

8. Monitoring of free school meal registration and take-up should be among the key priorities during this transition.

8.1 Free school meals are one of the main proxy measures for poverty and disadvantage in this country, the mechanism for delivering flagship policies to support children from low income homes such as the Pupil Premium. This is in spite of the fact that not all children who would qualify for free school meals are registered to receive them—due in part to the complexities of the current registration system.

8.2 A stated aim of the Government is to reduce complexity in the benefits system and to ensure free school meals are available to those pupils who need them most. Measuring the impact of the transition on free school meals take-up, particularly if recommendations are adopted to make registration for free school meals automatic under Universal Credit, will be important in assessing the efficacy of Universal Credit in achieving both of these aims and in identifying how best to ensure children living in poverty get the nutrition they need during the school day. Ensuring that all children who qualify for free school meals are actually taking them up will also support the effective delivery of schemes such as the Pupil Premium.

14 August 2012








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Prepared 21st November 2012