AS PART of an effort to rebut the notion that its policies are hard on the poor, the administration has been putting about the word that, under current policies, the federal government is buying "95 million meals a day." But the administration has a funny way of counting meals. Its calculation of the daily number of meals bought by the food stamp program, for example, assumes that the average food stamp participant can buy a meal for 47 cents--and some for less than 11 cents, which doesn't sound like the kind of repast that qualifies as a meal.

There's also a problem of double counting. To the 60 million food stamp meals, the administration adds some 27 million school lunches and breakfasts (over half of which are consumed by middle-income kids who get a subsidy of 22 cents a meal), along with 5 million high nutrition supplements (worth about 33 cents a meal) that the WIC program provides to undernourished infants and pregnant women.

Obviously most of these meals are not in fact meals but represent simply overlapping contributions to the food costs of the same group of people, made necessary by the fact that no one program provides enough money for an adequate diet. By the administration's way of counting, for example, a low-income family composed of a father, pregnant mother and two school-age children could be eating as many as 19 meals a day among them.

But even with this kind of crazy computation, you could say the administration has probably undercounted the number of meals the federal government provides, or at least helps to provide. Not all of these cost 11 cents. There are the meals for the military and their families that come through federally subsidized mess halls and bargain-rate post exchanges. There are subsidized dining rooms for congressmen and federal executives, cafeterias for congressional workers and expensive hospital meals paid for by Medicare. And last but not least--certainly not least in terms of either calories or cost-- come those consumed in fine restaurants, private clubs and ballrooms by all who can deduct the cost from their income taxes as business expenses or even, if properly arranged, as charitable contributions. Each dollar of these deductions adds just as much to the federal deficit as a dollar spent on meals for poor people. Is that somewhere in the calculation?