Economically designed to maximize consumer choice, campus meal plans deliver tremendous value to students. Dining operations offer experiences that build community, reduce food insecurity, and facilitate student wellbeing and success, resulting in more equitable opportunities and greater upward mobility for disadvantaged students, especially those from Historically Black Colleges & Universities (HBCUs) and Hispanic-Serving Institutions (HSIs). The proposed changes to the cash management rules threaten to erode these key dining objectives, escalating student costs and disproportionately impacting students from underprivileged backgrounds.
Read NACUFS' in-depth economic analysis and impact report here.
Key Concerns and Potential Impacts
Increased cost of higher education
- Mandating reimbursements for unused cash value funds is expected to increase meal plan costs, conflicting with efforts to ensure college affordability and transparency.
- The proposed changes will introduce significant administrative expenses, diminishing the value of students’ financial aid.
Disparate impacts
- Less affluent students—who depend most on university-based food outlets and stand to benefit least from the proposed refunds—will experience a reduction in meal plan value and diminished choice compared to more affluent students.
- With more expensive off-campus options available for wealthier students, a two-tiered dining system would emerge, widening existing equity gaps, increasing costs for those least able to pay, and undermining the communal and egalitarian aspects of campus life.
Increased food insecurity
- Students motivated by a cash refund would be incentivized to underutilize their meal plan, thereby forfeiting regular, balanced meals that support academic success and well-being.
- Many HBCUs and campuses with lower-income students are situated in food deserts, increasing the likelihood that campus dining alternatives would be highly processed and detrimental to students’ well-being.
- Food insecurity rates among college students are already higher than the general population, contributing to negative academic and health outcomes.
The proposed rule threatens to increase costs, jeopardize consumer options, and diminish students’ nutritional health and wellbeing. As the representative body for campus dining operations across the United States, NACUFS supports policies that strengthen dining services’ ability to support equitable access and contribute positively to student experiences and outcomes.
Proposed Department of Education regs will increase the cost of higher education.
In direct conflict with efforts to improve college affordability and transparency, mandating reimbursements for unused cash value funds is expected to require increases in meal plan costs, ultimately diminishing the value of student financial aid. This financial impact could be compounded based on student behavior and unknown administrative costs, threatening dining services’ fiscal sustainability. In addition to inflated costs for students, ripple effects could also lead to reduced employment opportunities for students and community members.
Proposed Department of Education regs will erode consumer choice for college students.
Rather than enhancing consumer-friendly provisions, the proposed amendments are expected to result in reduced service hours and facilities with limited food options, diminishing consumer choice and access. Diminished services and options would harm vulnerable students the most. Those with extenuating circumstances and the least flexibility, individual needs, or unusual schedules—perhaps due to working or caring for children—would be most faced with decreased access, due to their need to eat during off-hours. As dining services may be forced to opt for more cost-effective, possibly less varied offerings, this reduction in choice could impact the nutritional and cultural fulfillment of the campus community, particularly those of fewer economic means.
Proposed Department of Education regs will widen equity gaps on college campuses.
Less affluent students depend more on today’s economic, nutritional university-based meal plans and food outlets than their affluent peers, who can afford more expensive options. This means poor students stand to be hurt the most by the proposed refunds, due to the predicted impacts on costs and services. First generation students and HBCU students, who often live in food deserts and are most vulnerable to food insecurity, will be most affected by the reduction in meal plan value and diminished options. With wealthier students able to afford healthy alternatives to campus dining, a two-tiered dining system could emerge, widening existing equity gaps, and increasing costs for those least able to pay.
Proposed Department of Education regs will increase food insecurity on college campuses.
The proposal would introduce an incentive for students to minimize their meal consumption in the expectation of a refund at the end of the semester, which could engender meal hoarding and skimping among students that may lead them to compromise their nutrition. Campus dining meals, along with the nutritional education provided, are not only crucial for students’ academic, physical, and mental well-being during their enrollment but can continue to influence their choices and health into the future. Students already experience food insecurity at higher rates than the general population, a fact that campus dining operators actively work to combat. First generation students and HBCU students, who often live in food deserts and are most vulnerable to food insecurity, will be most affected by the reduction in meal plan value and diminished options, and stand to be disproportionately impacted by these proposed regulations.
Proposed Department of Education regs will adversely impact student well-being.
Dining services provide vital fuel, employment opportunities, and education, as well as experiences that build community, reduce food insecurity, and facilitate student well-being and persistence toward graduation. Effective dining services result in more equitable opportunities and greater upward mobility for disadvantaged students, especially those from Historically Black Colleges & Universities (HBCUs) and Hispanic-Serving Institutions (HSIs). Through the diversity of food offerings, dining programs also create inclusive environments for those with special dietary needs to meet health, religious and cultural requirements. The proposed changes to the cash management rules threaten to erode these key outcomes on which students rely. By increasing costs, jeopardizing consumer options, and initiating an array of unintended consequences, ED’s proposed cash management amendments threaten to weaken students’ nutritional health and wellbeing while reducing the affordability and value of campus dining services. This proposal also raises serious alarms about aggravating current inequities and food insecurity on college campuses, especially HBCUs, and colleges located in small towns and rural communities.
Proposed Department of Education regs will disparately impact HBCUs.
The incentive to minimize meal consumption in exchange for a refund could compound the poor health impacts of living in food deserts, where it is difficult to buy affordable fresh food. Many historically black colleges and universities (HBCUs) are in food deserts as a result of a legacy of racism and segregation. Students seeking alternatives to campus meals are likely to encounter ultra-processed foods low in nutrients and high in calories, sugar, and other additives, which are detrimental to their health and academic success. Further, predicted service cutbacks incorporated to offset some of the student cost increase created by the proposed regulations will leave many HBCU students with the need to seek off campus food which will most likely be less nutritional and more expensive than today’s meal plan options.