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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

January 2014: 

School Lunch: 

Implementing Nutrition Changes Was Challenging and Clarification of 
Oversight Requirements Is Needed: 

GAO-14-104: 

GAO Highlights: 

Highlights of GAO-14-104, a report to congressional requesters. 

Why GAO Did This Study: 

The National School Lunch Program served more than 31 million children 
in fiscal year 2012, in part through $11.6 billion in federal 
supports. The Healthy, Hunger-Free Kids Act of 2010 required USDA to 
update nutrition standards for lunches. USDA issued new requirements 
for lunch components-—fruits, vegetables, grains, meats, and milk—-and 
for calories, sodium, and fats in meals. USDA oversees state 
administration of the program, and states oversee local SFAs, which 
provide the program in schools. The changes were generally required to 
be implemented in school year 2012-2013. GAO was asked to provide 
information on implementation of the lunch changes. 

GAO assessed (1) lunch participation trends, (2) challenges SFAs faced 
implementing the changes, if any, and (3) USDA's assistance with and 
oversight of the changes. To address these areas, GAO used several 
methods, including review of federal laws, regulations, and guidance; 
analysis of USDA's lunch participation data; a national survey of 
state child nutrition program directors; and site visits to eight 
school districts selected to provide variation in geographic location 
and certain school district and food service characteristics. 

What GAO Found: 

Nationwide, student participation in the National School Lunch Program 
declined by 1.2 million students (or 3.7 percent) from school year 
2010-2011 through school year 2012-2013, after having increased 
steadily for many years. This decrease was driven primarily by a 
decline of 1.6 million students eating school lunch who pay full price 
for meals, despite increases in students eating school lunch who 
receive free meals. State and local officials reported that the 
changes to lunch content and nutrition requirements, as well as other 
factors, influenced student participation. For example, almost all 
states reported through GAO's national survey that obtaining student 
acceptance of lunches that complied with the new requirements was 
challenging during school year 2012-2013, which likely affected 
participation in the program. Federal, state, and local officials 
reported that federally-required increases to lunch prices, which 
affected many districts, also likely influenced participation. 

School food authorities (SFA) faced several challenges implementing 
the new lunch content and nutrition requirements in school year 2012-
2013. For example, most states reported that SFAs faced challenges 
with addressing plate waste-—or foods thrown away rather than consumed 
by students—-and managing food costs, as well as planning menus and 
obtaining foods that complied with portion size and calorie 
requirements. SFAs that GAO visited also cited these challenges. 
However, both states and SFAs reported that they expect many of these 
areas will become less challenging over time, with the exceptions of 
food costs, insufficient food storage and kitchen equipment, and the 
forthcoming limits on sodium in lunches. 

The U.S. Department of Agriculture (USDA) provided a substantial 
amount of guidance and training to help with implementation of the 
lunch changes and program oversight, but certain aspects of USDA's 
guidance may hinder state oversight of compliance. Starting in school 
year 2012-2013, USDA allowed states to focus their oversight of the 
lunch changes on providing technical assistance to SFAs rather than 
documenting instances of noncompliance and requiring corrective 
actions to address them. This assistance likely helped many SFAs move 
toward compliance with the new lunch requirements and become certified 
to receive increased federal reimbursements for lunches. However, 
evidence suggests this approach may have also resulted in some SFAs 
that were not fully meeting requirements being certified as in 
compliance. Without documentation of noncompliance and requirements 
for corrective actions, SFAs may not have the information needed to 
take actions to address these issues, and USDA may lack information on 
areas that are problematic across SFAs. Moving forward, USDA has been 
developing a new process for conducting program oversight, in part 
because of new statutory requirements. This new process adds 
requirements for reviewing SFA financial management, and many states 
reported a need for more guidance and training in this area. USDA has 
acknowledged that states' processes for reviewing this area have been 
inconsistent and sometimes inadequate in the past. While USDA has 
provided some assistance to states on the new requirements related to 
SFA financial management, until USDA has collected information from 
all states on their needs in this area, the department will not know 
if all states are fully prepared to oversee SFA financial management. 

What GAO Recommends: 

To improve program integrity, GAO recommends that USDA clarify the 
need to document noncompliance issues found during state reviews of 
SFAs and complete efforts to assess states' assistance needs related 
to oversight of financial management. USDA generally agreed with GAO's 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-14-104]. For more 
information, contact Kay E. Brown at (202) 512-7215 or brownke@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

School Lunch Participation Declined by 1 Million Students in Recent 
Years, Likely Due to the Changes to Lunch Requirements and Other 
Factors: 

Nationwide, SFAs Faced Challenges Implementing Lunch Changes, Though 
Some Challenges Will Likely Diminish Over Time: 

USDA's Assistance Efforts Were Substantial, but Certain Aspects of 
USDA's Guidance May Hinder State Oversight of Compliance: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Scope and Methodology: 
U.S. Department of Agriculture (USDA): Survey of States: 
Site Visits: 

Appendix II: Federal Requirements for the Content of School Lunches: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Traditional Food-Based Menu Planning Approach Requirements: 

Table 2: Traditional Food-Based Menu Planning Approach Nutrient and 
Calorie Requirements: 

Table 3: Enhanced Food-Based Menu Planning Approach Requirements: 

Table 4: Enhanced Food-Based Menu Planning Approach Nutrient and 
Calorie Requirements: 

Table 5: Food-Based Menu Planning Approach Requirements Beginning in 
School Year 2012-2013: 

Figures: 

Figure 1: Entities Responsible for Overseeing and Administering the 
National School Lunch Program: 

Figure 2: Previous and Current Federal Requirements for Meal 
Components and Nutrients in School Lunches: 

Figure 3: Examples of Three and Five Component Lunches That Comply 
with the New Content and Nutrition Requirements: 

Figure 4: Participation in the National School Lunch Program, School 
Years 2000-2001 through 2012-2013: 

Figure 5: Participation in the National School Lunch Program by 
Category of Student, School Years 2000-2001 through 2012-2013: 

Figure 6: Number of Students in Each Category, School Years 2000-2001 
through 2012-2013: 

Figure 7: Participation Rate in the National School Lunch Program, 
School Years 2000-2001 through 2012-2013: 

Figure 8: Number of States in Which SFAs Faced Challenges in Selected 
Areas during Implementation of the New Lunch Requirements in School 
Year 2012-2013: 

Figure 9: Examples of the Variety of Fruits and Vegetables Offered 
with Lunches in the Districts We Visited: 

Figure 10: USDA Memos Issued to Provide Guidance on the New 
Requirements for the Content of School Lunches and Paid Lunch Equity, 
Jan. 2011-Sept. 2013: 

Figure 11: USDA Memos that Provided Flexibilities Related to Federal 
Regulations or Changed Previous Guidance on the New Requirements for 
the Content of School Lunches and Paid Lunch Equity, Jan. 2011-Sept. 
2013: 

Figure 12: SFAs Certified and Validated by States as Complying with 
the New Lunch Requirements in School Year 2012-2013: 

Abbreviations: 

FNS: Food and Nutrition Service: 

SFA: school food authority: 

USDA: U.S. Department of Agriculture: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

January 28, 2014: 

The Honorable John Kline: 
Chairman: 
Committee on Education and the Workforce House of Representatives: 

The Honorable David P. Roe: 
Committee on Education and the Workforce: House of Representatives: 

The Honorable Kristi Noem: 
House of Representatives: 

The National School Lunch Program, which is intended to promote the 
health and well-being of schoolchildren, served an estimated 31.6 
million children in fiscal year 2012 supported in part through federal 
subsidies and commodities totaling $11.6 billion. Although federal 
requirements for the content of school lunches have existed since the 
program's creation, the Healthy, Hunger-Free Kids Act of 2010--the law 
that most recently reauthorized school meal programs--required that 
they be updated in order to help reduce childhood obesity and improve 
children's diets. The Act required the U.S. Department of Agriculture 
(USDA), which administers the National School Lunch Program, to update 
the requirements for the content of school lunches based on 
recommendations from the Institute of Medicine.[Footnote 1] USDA 
issued final regulations defining the new requirements in January 2012 
and required that many of them be implemented beginning in school year 
2012-2013. USDA's updated regulations aim to provide lunches high in 
nutrients and low in calories that better meet the dietary needs of 
schoolchildren and protect their health. To that end, the regulations 
made several changes and additions to the previous requirements for 
the content of school lunches, such as requiring that each student's 
lunch contain at least one fruit or vegetable. Under agreements with 
state agencies, local school food authorities (SFA), which are 
generally aligned with school districts, serve meals to children in 
schools and are the entities responsible for implementing these 
requirements. 

As school year 2012-2013 progressed, both USDA and the media reported 
that states, SFAs, school officials, parents, and students expressed 
some concerns about the school lunch changes. While the changes to 
school lunch were the primary school food changes required to be 
implemented in school year 2012-2013, the Healthy, Hunger-Free Kids 
Act of 2010 also required similar updates to nutrition standards for 
the School Breakfast Program and other foods sold in schools--known as 
competitive foods--and USDA prescribed that these changes generally be 
implemented in school year 2013-2014 and beyond. In view of both the 
ongoing and future changes to school foods, you asked us to provide 
information on implementation of the changes to school lunch. This 
report assesses: (1) trends in school lunch participation, (2) 
challenges, if any, SFAs faced implementing the lunch changes, and (3) 
USDA's efforts to assist with implementation of the lunch changes and 
ensure compliance with program requirements. In June 2013, we 
testified on our initial findings on challenges SFAs faced 
implementing the lunch changes, and recommended that USDA make 
modifications to some of the new lunch requirements.[Footnote 2] 

To answer these questions, we gathered information through several 
methods. At the federal level, we reviewed relevant federal laws, 
regulations, and guidance and interviewed USDA officials. Further, we 
analyzed USDA's national data on meals served in the National School 
Lunch Program and reviewed the department's method for determining 
lunch participation from these data. To assess their reliability, we 
interviewed USDA officials, reviewed related documentation, and 
compared the data we received from USDA with its published data. We 
determined these data and the participation methodology to be 
sufficiently reliable for the purposes of this report. To assess 
USDA's assistance and oversight efforts, we relied on federal 
standards for internal controls.[Footnote 3] We also reviewed several 
key studies on the National School Lunch Program. For example, we 
reviewed USDA's School Nutrition Dietary Assessment Study IV (2012), 
which provides information on school lunches and other foods sold in 
schools nationwide in school year 2009-2010.[Footnote 4] In addition, 
because it is the basis for USDA's revised regulations on the content 
of school lunches, we reviewed the Institute of Medicine's report, 
School Meals: Building Blocks for Healthy Children (2010).[Footnote 5] 
We assessed the methodologies and findings of the studies we reviewed 
and determined that they were sufficiently reliable for the purposes 
of this report. 

To gather information from the state level, we conducted a national 
survey of state child nutrition directors that oversee the National 
School Lunch Program in the 50 states and the District of Columbia. 
[Footnote 6] We administered our Web-based survey between June and 
July 2013, and all state directors responded. While we did not 
validate specific information that directors reported through our 
survey, we reviewed their responses, and we conducted follow-up, as 
necessary, to determine that their responses were complete, 
reasonable, and sufficiently reliable for the purposes of this report. 
To gather information directly from those affected by the changes in 
the schools, we conducted site visits to eight school districts in 
eight states across the country between March and May 2013. The school 
districts selected for these visits provide variation across 
geographic location, district size, and certain characteristics of the 
student population and district food services.[Footnote 7] In each 
district, we met with SFA staff at the district and school levels, 
school administrators, and students, and we observed lunch in at least 
two schools of different grade levels, for a total of 17 schools. We 
also interviewed the eight state child nutrition program directors who 
oversee these districts. We cannot generalize our findings from the 
site visits beyond the school districts we visited.[Footnote 8] To 
gather additional information, we interviewed representatives from 
several stakeholder groups, including a group of eight SFA directors 
representing both their own districts and their regions of the 
country, and a group of eleven relevant industry representatives. 
[Footnote 9] For additional information on the report's scope and 
methodology, see appendix I. 

We conducted this performance audit from February 2013 to January 2014 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

The National School Lunch Program was established in 1946 by the 
National School Lunch Act[Footnote 10] and is intended to safeguard 
the health and well-being of the nation's children. The program 
provides nutritionally balanced low-cost or free lunches to children 
in public and nonprofit private schools and residential child care 
institutions. In fiscal year 2012, the federal government spent $11.6 
billion on the National School Lunch Program, which served lunches to 
31.6 million children on average each month. 

The school lunch program is overseen by USDA's Food and Nutrition 
Service (FNS) through its headquarters and regional offices and is 
administered through state agencies and local SFAs (see figure 1). FNS 
defines program requirements and provides reimbursements to states for 
lunches served. FNS also provides states with commodities--foods 
produced in the United States that are purchased by USDA and provided 
to SFAs--based on the number of lunches served.[Footnote 11] States 
have written agreements with SFAs to administer the meal programs, and 
states provide federal reimbursements to SFAs and oversee their 
compliance with program requirements. SFAs plan, prepare, and serve 
meals to students in schools.[Footnote 12] 

Figure 1: Entities Responsible for Overseeing and Administering the 
National School Lunch Program: 

[Refer to PDF for image: illustration] 

Department of Agriculture; 
Regional offices; 
State government; 
School Food Authorities; 
Schools. 

Source: GAO. 

[End of figure] 

Meal Component and Nutrition Standards: 

Although federal requirements for the content of school lunches have 
existed since the National School Lunch Program's inception in 1946, 
as research has documented changes in the diets of Americans and the 
increasing incidence of overweight and obesity in the United States, 
the federal government has taken steps to improve the nutritional 
content of lunches. Specifically, since 1994, federal law has required 
SFAs to serve school lunches that are consistent with the Dietary 
Guidelines for Americans. In 2004, federal law required USDA to issue 
rules providing SFAs with specific recommendations for lunches 
consistent with the most recently published version of the Guidelines. 
As a result of that requirement, USDA asked the Institute of Medicine 
to review the food and nutritional needs of school-aged children in 
the United States using the 2005 Dietary Guidelines for Americans and 
provide recommended revisions to meal requirements for the National 
School Lunch Program. 

The Healthy, Hunger-Free Kids Act of 2010 required USDA to update 
federal requirements for the content of school lunches based on the 
Institute of Medicine's recommendations, which were published in 2010. 
USDA issued final regulations that made changes to many of the lunch 
content and nutrition requirements in January 2012 and required that 
many of the new lunch requirements be implemented beginning in school 
year 2012-2013.[Footnote 13] (See figure 2.) Regarding the lunch 
components--fruits, vegetables, meats, grains, and milk--lunches must 
now include fat-free or low-fat milk, limited amounts of meats/meat 
alternates and grains,[Footnote 14] and whole grain-rich foods. 
[Footnote 15] Further, lunches must now include both fruit and 
vegetable choices, and although students may be allowed to decline two 
of the five lunch components they are offered,[Footnote 16] they must 
select at least one half cup of fruits or vegetables as part of their 
meal. (See figure 3 for examples of lunches with three and five 
components.) Regarding the nutrition standards, the regulations now 
include maximum calorie levels for lunches, require that lunches 
include no trans fat, and set future targets to reduce sodium in 
lunches.[Footnote 17] In addition to changes to the content of 
lunches, regulations also required that all SFAs use the same approach 
for planning lunch menus--Food-Based Menu Planning.[Footnote 18] This 
approach involves providing specific food components in specific 
quantities, where previously districts could choose from a variety of 
approaches. Further, the new regulations require SFAs to plan menus 
based on one set of student grade groups--grades K-5, grades 6-8 and 
grades 9-12--regardless of whether their schools align with these 
groups. Although regulations have long adjusted lunch content 
requirements by student grade level, previous regulations allowed SFAs 
a few student grade group options from which to choose those that best 
aligned with their schools.[Footnote 19] 

Figure 2: Previous and Current Federal Requirements for Meal 
Components and Nutrients in School Lunches: 

[Refer to PDF for image: illustration] 

Previous daily requirements: 

Minimum calorie requirements vary by menu-planning approach and grade 
grouping: 
Kindergarten to Grade 3: 633 calories; 
Kindergarten to Grade 6: 664 calories; 
Grade 4 to Grade 12: 785 calories; 
Grade 7 to Grade 12: 825 calories. 

Fruits and vegetables: 1/2 to 1 cup combined; No specific types 
required. 

Milk: 1 cup; 
No fat content or flavor restrictions. 

Grains: 1 ounce; 
Whole grains “encouraged”; (8-15 minimum per week). 

Meat or meat alternatives: 1.5 to 2 ounces; (7.5-15 minimum per week). 

Sodium: General goal to “reduce” sodium, but no set targets. 

Saturated fat: No more than 10 percent of total calories. 

Trans fat: No limits. 

Current daily requirements: 

Minimum and maximum calorie requirements vary by grade grouping: 
Kindergarten to Grade 5: 550 to 650 calories; 
Grade 6 to Grade 8: 600 to 700 calories; 
Grade 9 to Grade 12: 750 to 850 calories. 

Fruits[A]: 1/2 to 1 cup. 

Vegetables[A]: 3/4 to 1 cup; 
Specific types required each week[B]. 

Milk: 1 cup; 
Must be fat-free (flavored) or 1% or less (unflavored). 

Grains: 1 to 2 ounces; 
All whole grain-rich by July 2014[C]; (9-12 maximum per week). 

Meat or meat alternatives: 1 to 2 ounces; (10-12 maximum per week). 

Sodium: 
Three stage targets by grade level cut sodium to no more than 740 mg 
by SY 2022-23. 

Saturated fat: No more than 10 percent of total calories. 

Trans fat: Zero grams per serving. 

Source: USDA Analysis of Previous and Current Requirements, 77 Fed. 
Reg. 4088, 4113 and 7 C.F.R. § 210.10 (2012). 

Notes: Under the previous federal requirements for school lunch, SFAs 
could choose to use one of five approved approaches to plan their 
menus. Three of these approaches focused on nutrient requirements and 
did not specify portion size requirements. The requirements for 
portion sizes in the two food-based menu planning approaches are shown 
in the figure. The ranges of portion sizes shown reflect the minimum 
requirements, which vary by grade group and, for the previous 
requirements, by menu planning approach. Under the offer versus serve 
policy required in high schools and optional for other schools, 
students may decline two of the five lunch components they are offered. 

[A] Beginning in school year 2012-2013, lunches offered to students 
must include both fruit and vegetable choices, and students must take 
at least one half cup of fruits or vegetables with their lunches. 

[B] Over the course of the week, schools must offer all vegetable 
subgroups established in the 2010 Dietary Guidelines for Americans: 
dark green, red/orange, beans/peas (legumes), starchy, and "other" 
vegetables (as defined in the Dietary Guidelines). 

[C] In school years 2012-2013 and 2013-2014, half of the grain 
products offered in the program must be whole grain-rich. 

[End of figure] 

Figure 3: Examples of Three and Five Component Lunches That Comply 
with the New Content and Nutrition Requirements: 

[Refer to PDF for image: 2 photographs] 

Students served themselves these lunches at an elementary school we 
observed as part of our site visits to eight SFAs. Both lunches comply 
with the new requirements. 

This lunch includes three components: milk, grain, and fruit. 
This lunch includes five components: milk, grain, fruit, vegetable, 
and meat/meat alternate. 

Source: GAO. 

[End of figure] 

In addition to changes to the content and nutrition requirements for 
school lunches, the Healthy, Hunger-Free Kids Act of 2010 required 
that USDA update the requirements for school breakfasts and establish 
new standards for all other foods and beverages sold in schools, which 
are commonly referred to as competitive foods because they compete 
with school meal programs. USDA's January 2012 final regulations on 
the new lunch requirements also included the new breakfast 
requirements that are to be implemented over several school years, 
beginning generally in school year 2013-2014. The regulations 
establish three meal components for breakfast--fruit or vegetable, 
grain or meat, and milk--and require that breakfasts include whole 
grain-rich foods and only fat-free or low-fat milk. Additional changes 
to the previous breakfast requirements include that breakfasts must 
now be at or below calorie maximums and comply with limits on sodium 
and trans fat. Beginning in school year 2014-2015, schools must offer 
one cup of fruit with each breakfast each day, an increase from the 
previous requirement of ½ cup, though vegetables meeting specific 
requirements may be substituted for fruit. In addition, as with lunch, 
students will be required to take a fruit or vegetable as part of 
their meal. Separate from the lunch and breakfast regulations, USDA 
issued an interim final rule on the new requirements for competitive 
foods in June 2013 and required that they be implemented in school 
year 2014-2015.[Footnote 20] Competitive foods are often sold through 
vending machines, school stores, and fundraisers, and also include SFA 
sales of a la carte items in the cafeteria. Prior to the enactment of 
the Healthy, Hunger-Free Kids Act of 2010, USDA's authority to 
regulate competitive foods was limited to those foods sold in the food 
service area during meal periods. In contrast, the new regulations 
include nutrition requirements for all foods and beverages sold on 
school campuses during the school day outside of the federal school 
meal programs. 

SFA Finances: 

SFAs generally determine the prices they charge for school meals, but 
some children are eligible to receive free or reduced-price meals. 
Under the National School Lunch Act, children are eligible for free 
meals if their families have incomes at or below 130 percent of the 
federal poverty guidelines and reduced-price meals if their families 
have incomes between 130 and 185 percent of the federal poverty 
guidelines. SFAs can charge a maximum of $0.40 for a reduced-price 
lunch. Children who are not eligible for free or reduced-price meals 
pay the full price charged by the SFA for the meal. However, SFAs 
receive federal reimbursements for all lunches served to eligible 
students that meet federal lunch component and nutrition requirements, 
regardless of whether children pay for the meals or receive them for 
free. The amount of federal reimbursement that SFAs receive for each 
meal served to a child is based on the eligibility category of the 
child and the proportion of the SFA's total lunches that are served to 
children eligible for free and reduced-price meals. For example, in 
school year 2013-2014, federal reimbursements are $2.93 for each free 
lunch, $2.53 for each reduced-price lunch, and $0.28 for each paid 
lunch for SFAs with less than 60 percent of their total lunches served 
to children eligible for free and reduced-price meals. SFAs with a 
higher proportion of their total lunches served to children eligible 
for free and reduced-price meals may qualify for a higher per lunch 
reimbursement rate: 

SFAs must comply with certain financial requirements when operating 
the National School Lunch Program. Specifically, the National School 
Lunch Act requires that SFAs operate as nonprofit entities. Federal 
regulations further dictate that SFAs must use all revenue for the 
operation or improvement of the program and generally limit their net 
cash resources--the cash SFAs carry in their accounts--to three months 
of average operating expenditures. In the event that an SFA's 
resources exceed this limit, the state agency may require the SFA to 
invest the excess funds in the program or otherwise reduce the SFA's 
account balance. 

The Healthy, Hunger-Free Kids Act of 2010 contained two new revenue 
requirements related to the prices SFAs set for paid lunches and other 
foods sold outside of the school meal programs. These provisions were 
developed, in part, because of a USDA study that found the average 
prices charged for paid lunches and for other foods by some SFAs were 
less than the cost of producing those foods.[Footnote 21] While SFAs 
continue to determine the price they charge for school lunches, 
beginning in school year 2011-2012, the Act requires SFAs to provide 
the same level of support for paid lunches as is provided for free 
lunches.[Footnote 22] If an SFA's average paid lunch price is less 
than a specified amount--$2.59 for school year 2013-2014--the SFA must 
either increase the price it charges for paid lunches or provide non-
federal funding to cover the difference.[Footnote 23] Concerning other 
foods sold by SFAs outside of the school meal programs, the Act 
requires that revenues from the sales of these foods generate at least 
the same proportion of SFA revenues as they contribute to SFA food 
costs, in effect requiring SFAs to charge prices that cover the costs 
of those foods.[Footnote 24] 

Program Oversight and Administrative Review Process: 

As required by the National School Lunch Act, USDA policies and 
regulations establish an oversight and monitoring framework for the 
National School Lunch Program to help ensure that meals served meet 
content and nutrition requirements and that SFAs follow required 
eligibility and financial practices and maintain sound financial 
health. USDA is required to review state administration of the 
program, and states are required to review SFA administration of the 
program. 

Although states have been required to regularly review SFA 
administration of the National School Lunch Program for over two 
decades, the Healthy, Hunger-Free Kids Act of 2010 required USDA to 
amend its unified accountability system to ensure SFA compliance with 
requirements for all school meal programs.[Footnote 25] Further, the 
Act requires states to review SFAs on a 3-year cycle, which is a 
change from the previous 5-year cycle. While USDA has not yet issued 
regulations on the new requirements, USDA has developed and provided 
states with guidance on an updated and streamlined administrative 
review process that changes some of the review procedures and required 
review areas. For example, USDA developed risk-based tools to 
determine the degree to which each area must be reviewed and made 
changes to procedures used when SFAs claim or receive federal 
reimbursements they are not entitled to.[Footnote 26] Further, USDA 
modified the extent to which states must review certain areas and 
added review of SFA financial management to the administrative review 
process. Specifically, states are now required to review SFAs' 
nonprofit food service accounts, use of commodities, indirect costs, 
and compliance with requirements for pricing paid lunches and other 
foods sold outside of the school meal programs. USDA officials told us 
that the new administrative review process was developed with 
extensive input from a workgroup that included state and USDA 
representatives. Although a new 3-year cycle of administrative reviews 
began in school year 2013-2014, because federal regulations have not 
yet been updated to reflect the new administrative review process, 
USDA used its waiver authority to provide states with the flexibility 
to follow the new administrative review requirements or the previous 
requirements.[Footnote 27] 

For school year 2012-2013, as SFAs worked to implement the required 
changes to the content of school lunches, USDA established interim 
procedures for program oversight.[Footnote 28] Specifically, to ensure 
that state agencies provided training and technical assistance to help 
SFAs implement the changes to the content of lunches, USDA allowed 
states to postpone administrative reviews until school year 2013-2014. 
[Footnote 29] Instead, during school year 2012-2013, states were 
required to review documentation submitted by SFAs and certify those 
SFAs determined to be in compliance with the new lunch requirements. 
USDA also required states to conduct on-site validation reviews to a 
sample of at least 25 percent of certified SFAs to ensure SFA 
compliance. Once certified, SFAs receive an additional six cents for 
each reimbursable lunch served, as provided for in the Healthy, Hunger-
Free Kids Act of 2010. 

The National School Lunch Program's oversight and monitoring 
requirements are part of the program's internal controls, which are an 
integral component of management. Internal control is not one event, 
but a series of actions and activities that occur on an ongoing basis. 
Effective internal controls include creating an organizational culture 
that promotes accountability and the reduction of errors, analyzing 
program operations to identify areas that present the risk of error, 
making policy and program changes to address the identified risks, and 
monitoring the results and communicating the lessons learned to 
support further improvement. Despite the National School Lunch 
Program's oversight and monitoring requirements, the program has been 
found to have a relatively high incidence of program errors. For 
example, USDA's most recent study of program errors found that $248 
million in improper payments (3.1 percent of federal reimbursements) 
during school year 2005-2006 resulted from school food service staff 
incorrectly assessing and recording lunches eligible for federal 
reimbursement.[Footnote 30] At the time of the study, federal 
requirements for the content of lunches had been consistent for 10 
years. 

School Lunch Participation Declined by 1 Million Students in Recent 
Years, Likely Due to the Changes to Lunch Requirements and Other 
Factors: 

Total School Lunch Participation Declined by 1 Million Students from 
School Years 2010-2011 through 2012-2013: 

Nationwide, participation in the National School Lunch Program 
declined in recent years after having increased steadily for more than 
a decade. According to our analysis of USDA's data, total student 
participation--the total number of students who ate school lunches--
dropped from school years 2010-2011 through 2012-2013 for a cumulative 
decline of 1.2 million students (or 3.7 percent), with the majority of 
the decrease occurring during school year 2012-2013.[Footnote 31] (See 
figure 4.) The decrease in the total number of students eating school 
lunches during the last 2 school years was driven primarily by a 
decrease of 1.6 million students paying full price for meals, despite 
increases in the number of students eating school lunches who receive 
free meals. While the number of students who buy full-price lunches 
each month has been declining gradually since school year 2007-2008, 
the largest one-year decline--10 percent--occurred in school year 2012-
2013.[Footnote 32] In contrast, the number of students participating 
in the program each month who receive free meals has steadily 
increased over the years, though the increase was much smaller in the 
last year.[Footnote 33] (See figure 5.) In addition, some evidence 
suggests that the total number of students eating school lunches 
declined more in schools with older students. For example, in six of 
the seven SFAs we visited that provided participation details by 
school level, participation declined to a greater extent among older 
students than elementary students in school year 2012-2013. 

Figure 4: Participation in the National School Lunch Program, School 
Years 2000-2001 through 2012-2013: 

[Refer to PDF for image: vertical bar graph] 

Change in number of students participating since SY 2000-01 (in 
millions): 

School year: 2000-2001; 
Total participants that school year: 27.5 million. 

School year: 2001-2002; 
Change since 2000-2001: 1 million. 

School year: 2002-2003; 
Change since 2000-2001: 0.5 million. 

School year: 2003-2004; 
Change since 2000-2001: 1.4 million; 
Total participants that school year: 28.9 million. 

School year: 2004-2005; 
Change since 2000-2001: 2.1 million. 

School year: 2005-2006; 
Change since 2000-2001: 2.6 million. 

School year: 2006-2007; 
Change since 2000-2001: 3.1 million; 
Total participants that school year: 30.6million. 

School year: 2007-2008; 
Change since 2000-2001: 3.5 million. 

School year: 2008-2009; 
Change since 2000-2001: 3.8 million. 

School year: 2009-2010; 
Change since 2000-2001: 4.2 million. 

School year: 2010-2011; 
Change since 2000-2001: 4.4 million; 
Total participants that school year: 31.8 million. 

School year: 2011-2012; 
Change since 2000-2001: 4.3 million. 

School year: 2012-2013; 
Change since 2000-2001: 3.2 million; 
Total participants that school year: 30.7 million; Down 1.2 million 
from high in 2010-11. 

Source: GAO analysis of USDA data. 

Note: Each month, states report to USDA the number of lunches served 
in the program and USDA adjusts the data to determine the number of 
students participating. Our analysis of school year data represents an 
average of 9 months--September through May--for each school year. Data 
for school year 2012-2013 may contain estimates as the data reporting 
process was not yet final when we received the data from USDA. The 
decline of 1.2 million does not match the yearly data due to rounding. 

[End of figure] 

Figure 5: Participation in the National School Lunch Program by 
Category of Student, School Years 2000-2001 through 2012-2013: 

[Refer to PDF for image: multiple line graph] 

Number of students participating: 

School year: 2000-01; 
Free: 12.9 million; 
Reduced-Price: 2.6 million; 
Paid: 12.0 million. 

School year: 2001-02; 
Free: 13.3 million; 
Reduced-Price: 2.6 million; 
Paid: 12.0 million. 

School year: 2002-03; 
Free: 13.7 million; 
Reduced-Price: 2.7 million; 
Paid: 11.9 million. 

School year: 2003-04; 
Free: 14.1 million; 
Reduced-Price: 2.8 million; 
Paid: 12.0 million. 

School year: 2004-05; 
Free: 14.5 million; 
Reduced-Price: 2.9 million; 
Paid: 12.2 million. 

School year: 2005-06; 
Free: 14.8 million; 
Reduced-Price: 2.9 million; 
Paid: 12.4 million. 

School year: 2006-07; 
Free: 14.9 million; 
Reduced-Price: 3.1 million; 
Paid: 12.6 million. 

School year: 2007-08; 
Free: 15.3 million; 
Reduced-Price: 3.1 million; 
Paid: 12.6 million. 

School year: 2008-09; 
Free: 16.2 million; 
Reduced-Price: 3.8 million; 
Paid: 12.0 million. 

School year: 2009-10; 
Free: 17.5 million; 
Reduced-Price: 3.1 million; 
Paid: 11.2 million. 

School year: 2010-11; 
Free: 18.3 million; 
Reduced-Price: 2.7 million; 
Paid: 10.8 million. 

School year: 2011-12; 
Free: 18.7 million; 
Reduced-Price: 2.8 million; 
Paid: 10.3 million. 

School year: 2012-13; 
Free: 18.9 million; 
Reduced-Price: 2.6 million; 
Paid: 9.2 million. 

Source: GAO analysis of USDA data. 

Note: Each month, states report to USDA the number of lunches served 
in the program by category of student and USDA adjusts the data to 
determine the number of students participating. Our analysis of school 
year data represents an average of 9 months--September through May--
for each school year. Data for school year 2012-2013 may contain 
estimates as the data reporting process was not yet final when we 
received the data from USDA. 

[End of figure] 

The changes in lunch program participation were likely influenced by 
factors that directly affected students' eligibility for free and 
reduced-price school meals. Since the recent economic downturn began 
in late 2007, the number of children under age 18 living in poverty 
nationwide has increased substantially, according to data from the 
U.S. Census Bureau.[Footnote 34] Consistent with this shift, our 
analysis of USDA's data shows that the number of students approved for 
free meals nationally has been increasing at a greater rate since 
school year 2007-2008, and the number of students required to pay full 
price for their lunches has been decreasing. (See figure 6.) This was 
also true in the districts we visited where two SFA directors noted 
that the recent economic downturn likely contributed to an increase in 
the number of children approved for free and reduced-price meals in 
their districts. In addition to economic conditions, other program 
changes may have also influenced these trends, such as adjustments to 
the process for determining student eligibility for free and reduced-
price school meals.[Footnote 35] 

Figure 6: Number of Students in Each Category, School Years 2000-2001 
through 2012-2013: 

[Refer to PDF for image: multiple line graph] 

Number of students participating: 

School year: 2000-01; 
Free: 16.0 million; 
Reduced-Price: 3.7 million; 
Paid: 28.5 million. 

School year: 2001-02; 
Free: 16.4 million; 
Reduced-Price: 3.8 million; 
Paid: 28.5 million. 

School year: 2002-03; 
Free: 16.8 million; 
Reduced-Price: 3.8 million; 
Paid: 28.4 million. 

School year: 2003-04; 
Free: 17.5 million; 
Reduced-Price: 3.9 million; 
Paid: 27.7 million. 

School year: 2004-05; 
Free: 18.4 million; 
Reduced-Price: 4.0 million; 
Paid: 27.1 million. 

School year: 2005-06; 
Free: 18.8 million; 
Reduced-Price: 4.2 million; 
Paid: 26.8 million. 

School year: 2006-07; 
Free: 18.5 million; 
Reduced-Price: 4.2 million; 
Paid: 27.3 million. 

School year: 2007-08; 
Free: 19.1 million; 
Reduced-Price: 4.3 million; 
Paid: 26.9 million. 

School year: 2008-09; 
Free: 20.2 million; 
Reduced-Price: 4.4 million; 
Paid: 25.8 million. 

School year: 2009-10; 
Free: 17.5 million; 
Reduced-Price: 4.2 million; 
Paid: 24.8 million. 

School year: 2010-11; 
Free: 22.4 million; 
Reduced-Price: 3.8 million; 
Paid: 24.9 million. 

School year: 2011-12; 
Free: 23.5 million; 
Reduced-Price: 3.9 million; 
Paid: 23.6 million. 

School year: 2012-13; 
Free: 23.7 million; 
Reduced-Price: 3.8 million; 
Paid: 24.1 million. 

Source: GAO analysis of USDA data. 

Note: For October of each school year, states report to USDA the total 
number of students enrolled in schools participating in the National 
School Lunch Program, as well as the total number of students approved 
for free and reduced-price meals in that month. Paid students in this 
figure represent enrolled students who had not been approved for free 
or reduced-price meals. 

[End of figure] 

Consistent with declines in the number of students participating in 
the lunch program, our analysis shows that the proportion of all 
students eating school lunches declined in school year 2012-2013. The 
participation rate measures the proportion of all students in schools 
with the National School Lunch Program who ate school lunches in each 
month. In school year 2012-2013, the overall participation rate 
declined, primarily driven by a decline in the participation rate for 
paid students. (See figure 7.) In that year, the participation rate 
for paid students declined to approximately 38 percent--the lowest 
rate in over a decade. 

Figure 7: Participation Rate in the National School Lunch Program, 
School Years 2000-2001 through 2012-2013: 

[Refer to PDF for image: multiple line graph] 

Percentage of students participating: 

School year: 2000-01; 
All students: 57.0%; 
Free: 80.8%; 
Reduced-Price: 69.9%; 
Paid: 42.1%. 

School year: 2001-02; 
All students: 57.4%; 
Free: 80.9%; 
Reduced-Price: 69.6%; 
Paid: 42.3%. 

School year: 2002-03; 
All students: 57.9%; 
Free: 81.7%; 
Reduced-Price: 70.7%; 
Paid: 42.1%. 

School year: 2003-04; 
All students: 58.9%; 
Free: 80.7%; 
Reduced-Price: 70.7%; 
Paid: 43.4%. 

School year: 2004-05; 
All students: 59.7%; 
Free: 78.9%; 
Reduced-Price: 71.3%; 
Paid: 44.9%. 

School year: 2005-06; 
All students: 60.3%; 
Free: 78.3%; 
Reduced-Price: 70.4%; 
Paid: 46.1%. 

School year: 2006-07; 
All students: 61.3%; 
Free: 80.7%; 
Reduced-Price: 72.9%; 
Paid: 46.3%. 

School year: 2007-08; 
All students: 61.6%; 
Free: 80.4%; 
Reduced-Price: 72.0%; 
Paid: 46.7%. 

School year: 2008-09; 
All students: 62.1%; 
Free: 79.9%; 
Reduced-Price: 73.0%; 
Paid: 46.4%. 

School year: 2009-10; 
All students: 62.8%; 
Free: 81.4%; 
Reduced-Price: 72.2%; 
Paid: 45.2%. 

School year: 2010-11; 
All students: 62.3%; 
Free: 81.6%; 
Reduced-Price: 72.4%; 
Paid: 43.5%. 

School year: 2011-12; 
All students: 62.3%; 
Free: 79.7%; 
Reduced-Price: 71.5%; 
Paid: 43.5%. 

School year: 2012-13; 
All students: 59.4%; 
Free: 79.7%; 
Reduced-Price: 68.1%; 
Paid: 38.2%. 

Source: GAO analysis of USDA data. 

Note: The participation rate measures the proportion of students in 
each category participating in the program in schools that offer the 
National School Lunch Program. Our analysis of school year data 
represents an average of 9 months--September through May--for each 
school year. Participation data for school year 2012-2013 used to 
develop the participation rate may contain estimates as the data 
reporting process was not yet final when we received the data from 
USDA. 

[End of figure] 

Participation Decreases Were Likely Influenced by Several Factors, 
Including Implementation of the New Federal Requirements: 

Several factors likely influenced the recent decreases in lunch 
participation, and while the extent to which each factor affected 
participation is unclear, state and local officials reported that the 
decreases were influenced by changes made to comply with the new lunch 
content and nutrition standards. Almost all states reported that 
student acceptance of the changes was challenging for at least some of 
their SFAs during school year 2012-2013, a factor that likely affected 
participation.[Footnote 36] All eight SFAs we visited also noted that 
students expressed dislike for certain foods that were served to 
comply with the new requirements, such as whole grain-rich products 
and vegetables in the beans and peas (legumes) and red-orange sub-
groups, and this may have affected participation.[Footnote 37] 
Further, some SFAs we visited noted that negative student reactions to 
lunches that complied with the new meat and grain portion size limits 
directly affected program participation in their districts. For 
example, in one district, changes the SFA made to specific food items, 
such as sandwiches, contributed to a middle and high school boycott of 
school lunch by students that lasted for 3 weeks at the beginning of 
school year 2012-2013. During this time, participation in school lunch 
significantly declined in those schools. 

Federally-required increases in the prices of paid lunches in certain 
districts--also known as paid lunch equity--are another change that 
state and SFA officials believe likely influenced lunch participation. 
This requirement, included in the Healthy, Hunger-Free Kids Act of 
2010, caused many SFAs to raise the price of their paid lunches 
beginning in school year 2011-2012. Officials from three states and 
four SFAs we spoke with as part of our site visits believe the price 
increases likely contributed to declines in the number of students 
buying full-price lunches. In addition, SFA officials in two districts 
we visited expressed concern that lunch price increases are 
particularly difficult for families who do not receive free or reduced-
price lunches but have limited incomes, as the new prices may no 
longer be affordable. Further, SFA officials in two districts believed 
that lunch price increases, combined with the lunch content changes, 
led some students to stop buying school lunches because they felt they 
were being asked to pay more for less food. Some middle and high 
school students we talked to in these districts echoed this sentiment 
and said this combination led them to consider food options other than 
the school lunch program, particularly at the beginning of the 2012-
2013 school year. SFA officials noted that middle and high schools are 
more likely to have alternatives to school lunches available, such as 
foods sold through vending machines, a la carte lines in the 
cafeteria, and fundraisers, as well as policies that allow students to 
purchase food off of the school campus.[Footnote 38] 

The reaction to the paid lunch price increases is consistent with 
USDA's expectations. Prior to implementation, the department estimated 
that nearly all schools would need to increase their lunch prices in 
response to the requirements, and these increases were expected to 
decrease the number of students eating school lunches as they chose 
not to eat, brought their lunches from home, or acquired food from 
other sources.[Footnote 39] Although the paid lunch equity provisions 
were included in the Healthy, Hunger-Free Kids Act of 2010 in part to 
help SFAs cover the costs of the foods needed to comply with the new 
lunch requirements, some officials we spoke with expressed concern 
about the potential impact on the program if the number of students 
buying full-price lunches continues to decrease. Specifically, several 
state and SFA officials we spoke with expressed concerns that such a 
trend would hinder the program's ability to improve the diet and 
overall health of all schoolchildren and potentially increase stigma 
in the cafeteria for low-income students.[Footnote 40] 

Officials in the SFAs we visited noted other factors that may also 
have affected lunch participation in recent years. SFA directors in 
three districts said that negative national and local media attention 
regarding changes to the lunch content and nutrition standards likely 
led some students to stop participating in school lunch, at least 
temporarily. SFA directors we visited said it is common that they 
receive feedback from students and parents. However, almost all of 
those we visited noted that they received more feedback than normal in 
school year 2012-2013 with concerns about the program, which some 
believed was in response to negative media attention. Another factor 
that may have affected participation is the time allotted for lunch 
periods, according to officials in three districts we visited. SFA 
officials in one district noted that some of the changes to lunches, 
such as the requirement that students take a fruit or vegetable with 
their lunches, confused staff and students and led to longer lunch 
lines, particularly at the beginning of school year 2012-2013. One 
district we visited also made significant changes to the system 
students use to pay for lunch, which led to longer lunch lines early 
in school year 2012-2013. One SFA director noted that if the lunch 
lines are too long or students otherwise do not have enough time to 
eat, they are more likely to look elsewhere for food or not eat at 
all. Other decisions at the district or school level may have also 
affected school lunch participation in school year 2012-2013. For 
example, one district we visited stopped allowing high school students 
to leave campus during the lunch period, which the SFA director 
believed helped mitigate the lunch participation declines the district 
experienced.[Footnote 41] In addition, states reported through our 
survey that 321 SFAs in 42 states stopped participating in the 
National School Lunch Program in school year 2012-2013,[Footnote 42] 
which directly impacted the number of students able to participate in 
the program nationwide. While districts may choose to leave the 
program for various reasons, such as low student participation, twenty-
seven of these states reported that the new lunch requirements were a 
factor in some SFAs' decisions not to participate. USDA officials also 
noted other factors that may have influenced lunch participation, 
including school closures, mergers, moves, consolidation due to 
economic conditions, and issues with food service management companies. 

Although school lunch participation has declined, it is likely that 
participation will improve over time as students adjust to the lunch 
changes. Five of the districts we visited reported that, if the past 
is an indicator, participation will improve over time as students 
adjust to the new food items, and three noted the importance of 
nutrition education for students and parents to help make the 
transition to healthier school meals more successful.[Footnote 43] The 
SFA director in one district we visited that made changes to lunches 
prior to school year 2012-2013 in anticipation of the federal 
requirements initially experienced a decrease in participation, but 
saw participation recover in the following school year. Similarly, 
although the other seven districts we visited saw decreases in lunch 
program participation in the first months after implementing the new 
requirements in school year 2012-2013, participation increased in the 
majority of these districts as the school year progressed. Nationwide, 
fewer states expected student acceptance of the changes and 
palatability of foods to be challenges for SFAs in school year 2013-
2014 than indicated they were challenges in school year 2012-2013, 
although the majority of states still expected these areas to be 
difficult.[Footnote 44] In four districts we visited, SFA directors 
noted that they had begun adding whole grains into their menus before 
the 2012-2013 school year, and they saw student acceptance of whole 
grain products improve over time. One district's SFA director also 
noted that students' willingness to eat foods in the beans and peas 
(legumes) sub-group has improved over time. When we talked with 
students in the schools we visited and asked them about the lunches, 
these specific foods were mentioned by some students in four of the 
eight districts we visited. However, at the same time, most of the 
students we spoke with indicated that they like to eat healthy and 
nutritious foods, and they think school lunches generally provide such 
foods. Further, although school year 2012-2013 was the first year that 
students nationwide were required to take a fruit or a vegetable with 
their school lunches, when we asked students what they liked about 
school lunch that year, students in 13 of the 17 schools we visited 
reported liking certain fruit and vegetable options. 

Nationwide, SFAs Faced Challenges Implementing Lunch Changes, Though 
Some Challenges Will Likely Diminish Over Time: 

Addressing Plate Waste, Managing Food Costs, and Planning Menus 
Challenged Many SFAs as They Implemented School Lunch Changes: 

As SFAs began implementing the new lunch requirements in school year 
2012-2013, they faced several challenges implementing the lunch 
changes. For example, most states reported that their SFAs faced 
challenges with plate waste--or foods thrown away rather than consumed 
by students--and food costs, as well as planning menus and obtaining 
foods that complied with the new portion size and calorie 
requirements. (See figure 8.) The majority of states also reported 
that food service staff workload and food storage or kitchen equipment 
were challenges for their SFAs while implementing the new lunch 
requirements. The eight SFAs we visited also experienced these 
challenges,[Footnote 45] although at the same time, all eight 
expressed support for the goal of improving the nutritional quality of 
lunches and felt the new requirements were moving in that direction. 

Figure 8: Number of States in Which SFAs Faced Challenges in Selected 
Areas during Implementation of the New Lunch Requirements in School 
Year 2012-2013: 

[Refer to PDF for image: horizontal bar graph] 

Number of states reporting that challenge: 

Challenge: Plate waste: 48; 
Challenge: Food costs: 47; 
Challenge: Menu planning: 47; 
Challenge: Required portion sizes: 46; 
Challenge: Calorie ranges: 43; 
Challenge: Food procurement: 41; 
Challenge: Food service staff workload: 34; 
Challenge: Food storage or kitchen equipment: 26; 
Challenge: Other: 12. 

Source: GAO survey of state child nutrition directors. 

Notes: Figure includes states that reported these areas posed 
challenges for at least some of their SFAs in school year 2012-2013. 
Areas identified by states that indicated there were "Other" 
challenges include: the amount of time provided to implement the 
changes; parent and public perception of the changes, as well as media 
coverage of the changes; and limited availability of certain foods, 
such as whole grain products. 

[End of figure] 

Addressing plate waste has been a longstanding challenge in the school 
lunch program, and officials in six of the districts we visited told 
us they believe plate waste increased in school year 2012-2013 because 
of the new lunch requirements. Specifically, students may take the 
food components they are required to as part of the school lunch but 
then choose not to eat them. Although none of the districts we visited 
had fully analyzed plate waste over the past few years to determine if 
it changed during school year 2012-2013,[Footnote 46] SFAs we visited 
said that the fruits and vegetables students are now required to take 
sometimes end up thrown away.[Footnote 47] Consistent with this, in 
our lunch period observations in 7 of 17 schools, we saw many students 
throw away some or all of their fruits and vegetables. However, in the 
other 10 schools, we saw students take and eat sizable quantities of 
fruits and vegetables and the other lunch components, resulting in 
minimal plate waste. Four of the eight SFAs we visited mentioned that 
plate waste was more of an issue with the youngest elementary school 
students, possibly because of the amount of food served with the lunch 
and the amount of time they have to eat it. The Institute of Medicine 
report that recommended the new lunch requirements acknowledged 
differences in food intake among elementary students. The report noted 
that the amounts of food offered under the new recommendations may be 
too large for some of the younger elementary schoolchildren because 
they are more likely to have lower energy needs than older elementary 
schoolchildren being served the same lunches.[Footnote 48] 

Managing the food costs associated with implementing the new lunch 
requirements was another challenge reported by all of the SFAs we 
visited. In all eight SFAs, fruit and vegetable expenditures increased 
substantially during school year 2012-2013, as compared to school year 
2011-2012, consistent with the new requirements that both fruits and 
vegetables be offered daily with lunches and each student take at 
least one fruit or vegetable with lunch. However, increases varied 
among the SFAs we visited. Several factors likely affected the extent 
to which these costs increased in SFAs nationwide as they implemented 
the new requirements, including the availability of produce suppliers, 
economies of scale, and the amount of fruits and vegetables previously 
served with lunches. Some SFA officials we spoke with also noted that 
fruit and vegetable costs may vary greatly from year to year because 
of factors that are difficult to plan for when budgeting, such as the 
weather's impact on growing seasons. By the end of school year 2012-
2013, increased fruit and vegetable costs and other factors had 
negatively impacted the overall financial health of six SFAs we 
visited.[Footnote 49] 

The SFAs we visited also cited difficulties planning menus that 
complied with the new requirements, including the portion size and 
calorie range requirements. All eight SFAs modified or eliminated some 
popular menu items because of the new portion size requirements for 
meats and grains.[Footnote 50] For example, two districts stopped 
serving peanut butter and jelly sandwiches as a daily option in 
elementary schools, and three districts reported that they changed the 
burgers they served. Specifically, one district removed cheeseburgers 
from elementary and middle school lunch menus because adding cheese to 
the district's burger patties would have made it difficult to stay 
within the weekly meat maximums. Because lunch entrees frequently 
consist of meats and grains and provide the majority of calories in 
meals, the limits on meats and grains made it difficult for SFAs to 
plan lunches that complied with both the portion size and calorie 
range requirements. For example, in order to meet the minimum calorie 
requirements, some SFAs reported that they added foods to their menus 
that generally did not improve the nutritional value of lunches, such 
as pudding or potato chips. Further, students or school officials in 
five districts raised concerns about students being hungry after 
eating lunches that complied with the new requirements, which some of 
the students we spoke with attributed to the smaller entrée sizes. The 
calorie range requirements caused additional difficulties in SFAs 
whose districts included schools with students in both the 6-8 and 9-
12 grade groups. These SFAs faced challenges planning menus that met 
the requirements for both groups because the calorie ranges for 
lunches served to those groups do not overlap.[Footnote 51] One SFA we 
visited planned its menus for schools serving students in both groups 
to generally provide a calorie total in-between the two ranges, which 
is not in compliance with requirements and may have left older 
students feeling hungry after lunch. 

USDA temporarily provided SFAs some flexibility to help address these 
challenges, and we recommended in our June 2013 testimony that the 
department take additional steps. Specifically, in response to 
feedback from states and SFAs regarding operational challenges caused 
by the meat and grain maximums, USDA lifted the maximums temporarily--
first in December 2012 for school year 2012-2013 and then in February 
2013 for school year 2013-2014.[Footnote 52] USDA indicated that they 
provided these flexibilities in response to the challenges they had 
heard about, and they did not see a problem making the temporary 
changes because the new lunch content standards include other 
requirements that also limit portion sizes. In our June 2013 
testimony, we recommended that USDA permanently remove the weekly meat 
and grain maximums, and in January 2014, USDA issued regulations that 
remove the requirement for SFAs to comply with these maximums. 
[Footnote 53] We also recommended in our testimony that USDA provide 
flexibility to help SFAs comply with the lack of overlap in the 
calorie ranges for the 6-8 and 9-12 grade groups. While USDA generally 
agreed with the recommendation, the department has not yet taken 
action to address that issue. 

SFAs we visited also discussed other challenges they faced planning 
lunch menus that complied with the new requirements in school year 
2012-2013. For example, officials from five SFAs noted that the 
requirements sometimes led them to serve meals they would not 
otherwise have planned because the specific food combinations are 
generally not served together as a meal. For example, one SFA served 
saltine crackers and croutons with certain salads to meet the minimum 
daily grain requirement and a cheese stick with shrimp to meet the 
minimum daily meat requirement. Several SFA directors and school food 
service managers also noted that the new requirements made it very 
difficult to make substitutions if they ran out of a particular menu 
item, because serving alternative food items in one day's lunch may 
result in the week's lunches exceeding the meat or grain limits or 
failing to include vegetables from all five sub-groups. 

Another factor that complicated school year 2012-2013 menu planning in 
the SFAs we visited was food procurement. Three of the SFAs we visited 
noted that because food orders for school year 2012-2013 were placed 
in the initial months of 2012--at the same time that guidance on the 
new requirements was being issued--they procured foods without knowing 
what was required. Consequently, one SFA ordered more meat and poultry 
than was needed for the year, and another SFA inadvertently ordered 
foods that were not in compliance with the new requirements.[Footnote 
54] Several SFA officials in districts we visited also mentioned that 
it was difficult to obtain from vendors certain food products that met 
the new requirements. For example, one SFA had difficulties obtaining 
the fresh produce it wanted to serve with lunches because of the 
increase in volume needed to comply with the new requirements. 
Further, three SFAs had challenges obtaining grain options from 
vendors that met portion size or whole grain requirements and were 
palatable to students. In three of the SFAs we visited, staff were 
still working with vendors during the school year to obtain food 
products needed to comply with requirements. SFA officials in some of 
the districts we visited and representatives from a group of food 
manufacturers and related industries we spoke with indicated that they 
had too little time between issuance of the final regulations and 
required implementation to reformulate food products to comply with 
the new lunch requirements. Further, after some products were 
reformulated, the temporary flexibilities that USDA provided for the 
meat and grain portion size requirements left industry experiencing 
difficulties forecasting demand, which led to food production, 
inventory, and storage challenges. In one school we visited, food 
service staff experienced related challenges at the end of school year 
2012-2013, as several items on the school's lunch menu were no longer 
being produced by vendors who were waiting for more certainty from 
USDA on the meat and grain requirements. 

According to SFA staff in all eight districts we visited, the workload 
for food service staff increased because of the new lunch 
requirements, and officials in some of the SFAs also noted that the 
requirements created new food storage and kitchen equipment 
challenges. School food service staff in all eight districts noted 
that workload increased primarily because of the need to prepare more 
fruits and vegetables each day to meet requirements. (See figure 9.) 
In two of the smallest districts we visited, the increased workload in 
this area required staff reorganizations in which staff previously 
responsible for baking began helping to prepare fruits and vegetables. 
Staff in one SFA noted that the increased amount of time and effort to 
prepare fruits and vegetables also led to morale issues when staff saw 
students throw the fruits and vegetables in the trash. Further, two 
SFAs that chose to increase their use of fresh produce in lunches, 
rather than relying on canned or frozen products, reported that this 
required more frequent deliveries of these foods because of limited 
food storage capacity on-site in the schools. In one of these SFAs, 
the more frequent deliveries resulted in increased costs from the 
supplier, and in the other, they seemed to increase the likelihood of 
workplace injuries related to unloading and lifting. In addition to 
the need for more food storage space in schools, some SFAs we visited 
discussed new kitchen equipment needs that resulted from the changes 
to the lunch requirements, such as the need for new spoons and ladles 
to match the new portion size requirements, and food choppers and 
other equipment used for preparing fruits and vegetables to be served. 
[Footnote 55] 

Figure 9: Examples of the Variety of Fruits and Vegetables Offered 
with Lunches in the Districts We Visited: 

[Refer to PDF for image: 3 photographs] 

Fruit and vegetable options offered to elementary school students with 
lunch included a pre-packaged lettuce salad, bags of baby carrots, and 
cups of mixed fruit. 

Portions of fruits and vegetables, including applesauce, kiwi, 
oranges, broccoli, and cauliflower, were offered in plastic cups to 
elementary school students with lunch. 

This salad bar, which was offered to middle school students with 
lunch, includes several different types of diced vegetables. 

Source: GAO. 

[End of figure] 

Some Areas Are Expected to Be Less Challenging for SFAs in the Future: 

As SFAs, food service staff, and students adjust to the new lunch 
requirements, it is likely that some challenges that arose during 
implementation of the new requirements in school year 2012-2013 will 
become less problematic. For example, fewer states reported that they 
expect menu planning, including the required portion sizes for lunch 
components and calorie ranges for lunches, to challenge their SFAs in 
school year 2013-2014 than reported these areas as challenges in 
school year 2012-2013.[Footnote 56] Although many states expect these 
areas to continue to be challenging, the flexibilities USDA recently 
made permanent related to the meat and grain portion size requirements 
should help ease menu planning moving forward. 

As more time elapses, food manufacturers expect the availability of 
foods that comply with the new requirements and are palatable to 
students to increase, easing SFA challenges with food procurement and 
plate waste. Food manufacturers we spoke with reported that they spent 
school year 2012-2013 focused primarily on reformulating food products 
to comply with the new lunch requirements. They added that because of 
the short timeframes between the issuance of the requirements for 
lunches and implementation, they did not have as much time to focus on 
food palatability, but as time elapses, they may have more time to do 
so. Further, both research and the experiences of some of our site 
visit districts suggest that students will likely adjust to the new 
lunch menus with time, which should result in decreased plate waste. 
While many states expect managing plate waste and food procurement to 
challenge their SFAs in school year 2013-2014, a greater number of 
states reported these areas as challenges for their SFAs in school 
year 2012-2013.[Footnote 57] 

In contrast, other areas may continue to be challenges in the future, 
including those related to costs and infrastructure. In our survey, a 
similar number of states reported that they expect their SFAs will be 
challenged by food costs and food storage or kitchen equipment in 
school year 2013-2014 as were challenged by those areas in school year 
2012-2013.[Footnote 58] Some of the SFAs we visited also suggested 
that these areas will likely be ongoing challenges. To try to remedy 
storage challenges, one SFA we visited had developed plans to expand 
coolers and freezers on-site in schools, which was not an option in 
another SFA we visited due to facility and resource constraints. A 
third SFA's plans to remodel the kitchen and serving lines in its 
largest school were put on hold because of the negative financial 
impact the SFA experienced in part because of the new lunch 
requirements. Overall, future costs were particularly concerning to 
some of the SFAs we visited. For example, officials in four SFAs 
expressed concerns about remaining financially solvent after the new 
requirements for school breakfasts or competitive foods are 
implemented, as some expect the breakfast changes to increase costs 
and the competitive foods changes to decrease revenues.[Footnote 59] 

Moving forward, states and SFAs also expressed concerns about the 
federally-required sodium limits for school lunches. The first of 
three sodium limits must be met beginning in school year 2014-2015. 
Many of the SFAs we visited noted that these limits will likely 
present a significant menu planning challenge, primarily because many 
of the foods available from manufacturers do not yet comply with these 
limits and students may not accept foods that meet the limits. These 
concerns were echoed by officials we spoke with in four states, with 
some noting that it will be very difficult for food manufacturers to 
make foods that meet the limits and are palatable to students. USDA 
has acknowledged that complying with the new limits will be a 
significant challenge that will require new technology and food 
products, and they have explained that these issues were considered 
when the department decided to require sodium to be reduced gradually 
over 10 years. 

During our site visits to eight SFAs, many also expressed concerns 
about the future nutrition standards for competitive foods, and these 
concerns were not fully addressed in USDA's interim final rule on the 
standards. At the time of our visits, SFAs expressed concerns that 
certain aspects of USDA's proposed rule on the standards would be 
challenging to implement, if finalized.[Footnote 60] For example, 
officials from seven of the eight SFAs we visited expressed concerns 
about what they viewed as a lack of clarity regarding how the 
nutrition standards for competitive food sales administered by 
entities other than the SFA would be enforced. Officials from five of 
the SFAs we visited also expressed concerns about the provision that 
would allow states discretion to exempt certain fundraisers from the 
standards, because such exemptions may result in inequitable treatment 
and put the SFA at a competitive disadvantage relative to other food 
sales within a school. USDA's interim final rule on the competitive 
food standards, issued in June 2013,[Footnote 61] requires school 
districts and SFAs to maintain records documenting compliance with the 
competitive food standards, and indicates that states and school 
districts will be responsible for ensuring compliance. However, it 
notes that forthcoming rules will describe state oversight 
requirements and fines for noncompliance. In addition, although USDA 
received many comments requesting that the department approve state 
decisions on fundraiser exemptions,[Footnote 62] the interim final 
rule does not require USDA approval of state decisions. 

USDA's Assistance Efforts Were Substantial, but Certain Aspects of 
USDA's Guidance May Hinder State Oversight of Compliance: 

USDA Provided a Substantial Amount of Guidance and Training in a Short 
Time, Which Was Both Useful and Challenging for States and SFAs: 

USDA provided a substantial amount of guidance and training to assist 
states and SFAs in complying with the required changes to school 
lunch, which states indicated was useful. According to USDA officials, 
the department's assistance effort has been unprecedented. From 
January 2011--the month after the Healthy, Hunger-Free Kids Act of 
2010 was enacted--through September 2013, USDA issued about 90 memos 
to provide guidance to states and SFAs on the new requirements for the 
content of school lunches and paid lunch equity. (See figure 10.) Most 
of the memos (85 percent) addressed the new requirements for lunch 
content and nutrition standards, as well as related issues such as 
food procurement and state review of SFA compliance with the lunch 
requirements. The remaining 15 percent of the memos addressed the paid 
lunch equity requirements. Over the past few years, USDA also provided 
training through several venues to help states and SFAs implement the 
changes. For example, USDA officials convened webinars and in-person 
trainings for states, participated in webinars and national 
conferences for SFAs, and worked with the National Food Service 
Management Institute to provide additional training and resources. 
[Footnote 63] USDA's regional offices also provided training to 
states. In addition, as the changes were implemented in school year 
2012-2013, USDA officials reported that they conducted an extensive 
amount of travel to visit school districts around the country to see 
how their efforts to implement the changes were progressing and to 
obtain feedback on additional assistance needed. All states reported 
that USDA's guidance and training were useful as the new school lunch 
requirements were implemented. Further, over half of the states 
reported that USDA's guidance was very useful or extremely useful, and 
officials from seven of the eight states we interviewed as part of our 
site visits expressed appreciation for USDA's efforts to respond to 
issues that arose as changes were implemented. 

Figure 10: USDA Memos Issued to Provide Guidance on the New 
Requirements for the Content of School Lunches and Paid Lunch Equity, 
Jan. 2011-Sept. 2013: 

[Refer to PDF for image: illustrated timeline] 

Number of memos, Main subject of memo: 

SY 2010-11: 

Dec. 2010: Healthy, Hunger-Free Kids Act of 2010 enacted; 
January: 1; 
February: 1; 
March: 1; 
April: 2; 
May: 1; 
June: 1. 

SY 2011-12: 
July: Paid Lunch Equity rules take effect[A]; 0; 
August: 1; 
September: 0; 
October: 1; 
November: 0; 
December: 1; 
January: Final regulations on content of lunches issued; 2; 
February: 8; 
March: 2; 
April: 6; 
May: 1; 
June: 2. 

SY 2012-13: 
July: New requirements for the content of lunches take effect; 5; 
August: 3; 
September: 3; 
October: 3; 
November: 1; 
December: 8; 
January: 5; 
February: 4; 
March: 3; 
April: 2; 
May: 4; 
June: 6. 

SY 2013-14: 
July: 1; 
August: 6; 
September: 4. 

Main subject of memo: 
New Requirements for the Content of Lunches (33 total memos); 
State Reviews of School Food Authority (SFA) Compliance[B] (24 total 
memos); 
Paid Lunch Equity (13 total memos); 
Other[C] (19 total memos). 

Source: GAO analysis of USDA guidance. 

[A] Paid lunch equity requirements, as well as the milk and water 
lunch content requirements, were required to be implemented by SFAs in 
school year 2011-2012. 

[B] In order to assist state efforts to certify SFA compliance in 
school year 2012-2013, USDA issued multiple tools through a guidance 
memo in May 2012 and then made additions and changes to those tools 
several times throughout the school year. Because the figure includes 
all versions of guidance memos by the date they were issued, and these 
updated tools were not provided with a revised guidance memo, these 
revised tools are not included in the figure. 

[C] "Other" guidance memos include those that address procurement of 
foods by SFAs for school lunches and state administrative funds. USDA 
provides states with administrative funds annually to assist their 
efforts to administer and oversee the National School Lunch Program, 
and the Healthy, Hunger-Free Kids Act of 2010 provided additional 
funds for fiscal years 2012 and 2013 intended to provide states with 
additional resources to assist SFAs efforts to improve the quality of 
school meals provided to children and come into compliance with the 
new requirements. 

[End of figure] 

In contrast, some states and SFAs noted that the relatively short 
timeframes within which the lunch requirements were implemented made 
it difficult to keep up with the extensive amount of guidance provided 
by USDA. In the 18 months from January 2012--the month in which the 
final rule on the changes to the lunch content and nutrition standards 
was issued--through the end of school year 2012-2013, USDA issued 
1,800 pages of guidance on these changes.[Footnote 64] Several SFAs we 
visited noted that keeping up with the extensive amount of guidance 
was difficult during school year 2012-2013 because they were 
simultaneously implementing the lunch changes. In addition, 32 states 
reported through our survey that the timing of USDA's guidance on the 
new lunch requirements was a very great challenge or extreme challenge 
during school year 2012-2013[Footnote 65]--a response echoed by most 
of the states we spoke with as part of our eight site visits. For 
example, officials in one state reported that the guidance providing 
SFAs with flexibility on the meat and grain maximums was provided too 
late in school year 2012-2013 to be helpful, as SFAs had already 
planned menus and trained food service staff on the new meat and grain 
requirements. Further, because of the fast pace with which USDA 
provided guidance on the new lunch requirements, officials from four 
states said that the department's regional offices were sometimes 
unable to answer state questions on the guidance. While six of the 
eight states we spoke with as part of our site visits commended the 
efforts that the regional offices took to help states understand the 
new lunch requirements, some noted that regional offices learned about 
the requirements at the same time as states. Because of this, regional 
office staff were not always able to answer state questions on the 
guidance, and states had to instead wait for USDA headquarters' staff 
to respond. USDA officials told us that while they recognize that the 
lunch changes were defined and implemented rather quickly, this was 
necessary because of the importance of improving school meals. 

Almost two-thirds of states also reported through our survey that the 
changes USDA made to its guidance on the lunch requirements were a 
very great challenge or extreme challenge during school year 2012-
2013. According to our analysis, 40 percent of the guidance memos 
issued by USDA on the new requirements for the content of school 
lunches and paid lunch equity from January 2011 through September 2013 
contained new flexibilities not included in federal regulations or 
substantive changes to previously issued guidance, which were to be 
enforced either temporarily or permanently.[Footnote 66] (See figure 
11.) According to USDA's general counsel, the department felt that it 
was important to provide such flexibilities to help ease the 
implementation process, although the guidance is technically non-
binding and does not modify statutory or regulatory requirements. For 
example, USDA issued several guidance memos from February through 
December 2012 that added flexibilities related to the fruit, milk, 
meat, and grain components of lunches, which had not been included in 
the January 2012 final regulations. Further, some guidance memos 
either substantively changed or contradicted aspects of previously 
issued memos. For example, in a February 2012 guidance memo, USDA 
indicated that frozen fruit served with lunches was not allowed to 
contain added sugar after school year 2012-2013.[Footnote 67] However, 
in memos issued in September 2012 and June 2013, the department 
indicated that fruit with added sugar would be allowed in school years 
2013-2014 and 2014-2015, respectively.[Footnote 68] While state and 
SFA officials we spoke with noted that some of these changes were 
likely made by USDA to respond to problems SFAs were having 
implementing the new lunch requirements, the guidance changes were 
difficult to keep up with and led to increased confusion about the 
requirements. Further, officials in six of the states we interviewed 
as part of our site visits reported that the changes USDA made to its 
guidance also frustrated SFAs or complicated training on the new lunch 
requirements. Officials from three states we spoke with as part of our 
site visits also reported that changes might have been avoided if USDA 
had piloted or phased in the new requirements more slowly, which 
suggests that the challenges states and SFAs experienced because of 
the lack of timely and consistent guidance from USDA in school year 
2012-2013 may become less problematic over time. USDA officials told 
us that their assistance efforts, and the changes made to guidance, 
reflected the department's recognition that the process needed to be 
iterative, as unexpected issues with the requirements would likely 
arise as the new lunch standards were implemented in the schools. 

Figure 11: USDA Memos that Provided Flexibilities Related to Federal 
Regulations or Changed Previous Guidance on the New Requirements for 
the Content of School Lunches and Paid Lunch Equity, Jan. 2011-Sept. 
2013: 

[Refer to PDF for image: illustrated timeline] 

[Alt]: indicate a memo that altered earlier guidance. 

Number of memos: 

SY 2010-11: 

Dec. 2010: Healthy, Hunger-Free Kids Act of 2010 enacted; 
January: 1; 
February: 1; 
March: 1; 
April: 2; 
May: 1; 
June: 1[Alt]. 

SY 2011-12: 
July: Paid Lunch Equity rules take effect[A]; 0; 
August: 1; 
September: 0; 
October: 1; 
November: 0; 
December: 1; 
January: Final regulations on content of lunches issued; 2 [1 Alt]; 
February: 8 [1 Alt]; 
March: 2; 
April: 6 [3 Alt]; 
May: 1 [1 Alt]; 
June: 2. 

SY 2012-13: 
July: New requirements for the content of lunches take effect; 5 [3 
Alt]; 
August: 3; 
September: 3 [3 Alt]; 
October: 3; 
November: 1 [1 Alt]; 
December: 8 [3 Alt]; 
January: 5 [4 Alt]; 
February: 4 [1 Alt]; 
March: 3 [1 Alt]; 
April: 2 [1 Alt]; 
May: 4 [2 Alt]; 
June: 6 [2 Alt]. 

SY 2013-14: 
July: 1 [1 Alt]; 
August: 6 [4 Alt]; 
September: 4 [3 Alt]. 

Main subject of memo: 
New Requirements for the Content of Lunches (33 total memos); 
State Reviews of School Food Authority (SFA) Compliance[B] (24 total 
memos); 
Paid Lunch Equity (13 total memos); 
Other[C] (19 total memos). 

Source: GAO analysis of USDA guidance. 

[A] Paid lunch equity requirements, as well as the milk and water 
lunch content requirements, were required to be implemented by SFAs in 
school year 2011-2012. 

[B] In order to assist state efforts to certify SFA compliance in 
school year 2012-2013, USDA issued multiple tools through a guidance 
memo in May 2012 and then made additions and changes to those tools 
several times throughout the school year. Because the figure includes 
all versions of guidance memos by the date they were issued, and these 
updated tools were not provided with a revised guidance memo, these 
revised tools are not included in the figure. 

[C] "Other" guidance memos include those that address procurement of 
foods by SFAs for school lunches and state administrative funds. USDA 
provides states with administrative funds annually to assist their 
efforts to administer and oversee the National School Lunch Program, 
and the Healthy, Hunger-Free Kids Act of 2010 provided additional 
funds for fiscal years 2012 and 2013 intended to provide states with 
additional resources to assist SFAs efforts to improve the quality of 
school meals provided to children and come into compliance with the 
new requirements. 

[End of figure] 

USDA Has Emphasized State Assistance to SFAs, but USDA Guidance 
Changes and Gaps May Hinder State Oversight of SFA Compliance: 

While SFAs transition to the new lunch requirements, USDA has 
emphasized the importance of state assistance in helping SFAs comply. 
According to the Standards for Internal Control in the Federal 
Government,[Footnote 69] federal agencies should have policies and 
practices in place to provide reasonable assurance that programs are 
operated in compliance with applicable laws and regulations. To this 
end, USDA officials told us that they directed states to work with 
SFAs to achieve compliance with the new lunch requirements during 
school year 2012-2013. Nationwide, 45 states reported that they used 
the additional administrative funds they received for fiscal year 2013 
to conduct training for SFAs and provide technical assistance to SFAs. 
[Footnote 70] In addition, many states reported using these funds to 
certify SFA compliance with the new meal requirements and conduct 
required validation reviews of a sample of those certified.[Footnote 
71] Officials in all eight of the states we spoke with as part of our 
site visits reported that they provided extensive guidance and 
assistance to SFAs to help them understand and implement the new lunch 
requirements and become certified as in compliance with the 
requirements. 

Although SFAs likely needed and benefited from state assistance as 
they worked to implement the new lunch requirements, USDA's emphasis 
on assistance, combined with new financial incentives for compliance, 
may have led to incomplete identification and documentation of SFA 
noncompliance. For many years, states have conducted administrative 
reviews of SFAs and observed lunches in schools in order to assess SFA 
compliance with federal requirements. In the past, USDA consistently 
noted the importance of these reviews for ensuring the integrity of 
the National School Lunch Program, as the review process requires that 
noncompliance be addressed. Under this process, instances of SFA 
noncompliance are required to be documented and lead to a corrective 
action plan and follow-up to ensure issues are addressed. In addition, 
the documentation of issues has also provided federal and state 
officials with information on areas for which additional assistance 
may be needed across SFAs. During school year 2012-2013, however, 
states were generally not required to conduct administrative reviews. 
Rather, states were to assist SFA efforts to comply with the new lunch 
requirements. Further, states were required to provide SFAs certified 
as in compliance with the new requirements an extra 6 cents of federal 
reimbursement for each lunch served and conduct on-site validation 
reviews in a sample of the certified SFAs. USDA officials reported 
that they considered the added funds to be an important way to offset 
the extra costs SFAs incurred as they made the required changes to 
lunches. However, while the certification and validation process 
likely helped SFAs understand the new requirements and obtain the 
additional reimbursement to help with compliance, unlike the 
administrative review process, states were not required to fully 
document issues of noncompliance they identified. For example, 
officials in two states we spoke with noted that USDA instructed them 
to work with SFAs during the certification process and during 
validation reviews of those certified, rather than strictly enforce 
requirements.[Footnote 72] This is consistent with USDA's guidance, 
which emphasized the provision of assistance during the certification 
process and validation reviews to help SFAs become compliant. However, 
because states were generally not required to document noncompliance 
issues that arose during the certification process or validation 
reviews, SFAs may not have developed or documented corrective action 
plans taken to address them.[Footnote 73] As a result, SFAs may not 
have adequate information on the types of ongoing compliance issues 
and the need to take corrective actions. Moreover, USDA has limited 
information on the extent to which SFAs are facing similar 
difficulties complying with the new requirements, which could be the 
focus of future federal technical assistance efforts.[Footnote 74] 

National data, as well as our conversations with states and visits to 
schools, suggest that some instances of SFA noncompliance may not have 
been fully documented while the new lunch requirements were being 
implemented. We and others have reported that SFAs experienced 
significant challenges implementing the new lunch requirements during 
school year 2012-2013, and several state officials we spoke with as 
part of our site visits told us that SFAs often needed a lot of state 
assistance to move forward with the new requirements, also suggesting 
that SFAs faced significant challenges fully complying. However, 
national data suggest that these challenges affected few SFAs' 
certifications.[Footnote 75] Specifically, 82 percent of SFAs 
nationwide applied to be certified as in compliance with the new lunch 
requirements during school year 2012-2013,[Footnote 76] and states 
denied 1 percent of SFAs that applied. (See figure 12.) National data 
on the results of state validation reviews of SFAs show similar 
outcomes, as 1 percent of SFAs had the extra federal reimbursement 
stopped by their states because of noncompliance issues found during 
these reviews. When reviewing the certification and validation results 
by state, we found that 25 states did not deny any SFAs that applied 
for certification and validated all SFAs reviewed. While states 
reported that they were unable to validate compliance in an additional 
4 percent of SFAs reviewed nationwide, states did not stop these SFAs 
from continuing to receive the extra federal reimbursement, possibly 
because of changes in USDA guidance during school year 2012-2013. 
[Footnote 77] One state told us that it interpreted USDA's guidance to 
mean that the state should not stop an SFA from receiving the extra 
federal reimbursement even when it was unclear if issues of 
noncompliance found during a validation review would be fully 
addressed by the SFA.[Footnote 78] In another state, we obtained 
evidence that some of the lunch menus in an SFA we visited may not 
have been fully in compliance with the new requirements, though the 
SFA was certified and validated, and in two additional certified SFAs 
we visited, we observed practices in schools that were inconsistent 
with the new requirements.[Footnote 79] While five of the eight SFAs 
we visited had been certified to be in compliance with the new 
requirements at the time of our site visits, the possible 
noncompliance issues in three of these five SFAs indicate the 
difficulty of ensuring proper implementation of the lunch changes in 
all of an SFA's schools, particularly during the first year that 
changes were required. 

Figure 12: SFAs Certified and Validated by States as Complying with 
the New Lunch Requirements in School Year 2012-2013: 

[Refer to PDF for image: illustration] 

Certification: 

Total School Food Authorities (SFAs) that applied to be certified as 
in compliance with the National School Lunch Program requirements 
during SY 2012-13: 16,521. 

15,042 SFAs: were certified as in compliance: 91%; 
155 SFAs were denied certification: 1%; 
1,324 SFAs were pending certification: 8%; 
16,366 SFAs were certified or pending certification: 99%. 

Validation: 

4,015 SFAs underwent validation review: 
222 SFAs were not validated: 6%; 
178 SFAs kept extra 6 cents per lunch: 4%; 
44 SFAs lost extra 6 cents per lunch: 1%; 
3,793 SFAs validated: 94%. 

Source: GAO survey of state child nutrition directors. 

Notes: Figure includes data obtained from state child nutrition 
directors through our survey in June and July 2013. Because school 
year 2012-2013 ended on June 30, 2013, data provided by states who 
responded to our survey in June may not reflect the full school year. 
Validation percentages do not add to 100 due to rounding. 

[End of figure] 

A new 3-year cycle of state administrative reviews of SFAs began in 
school year 2013-2014, and USDA's guidance has continued to emphasize 
the need for states to assist SFAs, which may come at the expense of 
program integrity. Consistent with USDA's guidance issued to states in 
school year 2012-2013 for certification and validation reviews, USDA's 
guidance on state administrative reviews in school year 2013-2014 
acknowledged that SFAs are in a transition period and set the 
expectation that states continue to work closely with SFAs to support 
their efforts to comply with the new lunch requirements. The guidance 
also indicated that the department believes most SFA noncompliance is 
likely the result of SFA efforts to understand and implement the new 
requirements and, as a result, states should continue to provide 
technical assistance and training to address issues of noncompliance. 
[Footnote 80] While documenting noncompliance issues and requiring 
corrective actions to address them have long been a required part of 
the administrative review process, because these actions were not 
required in school year 2012-2013, it is unclear if states will 
systematically follow this approach moving forward. Further, USDA's 
continued emphasis on state assistance to help SFAs comply may also 
inadvertently lead to states not consistently documenting SFA 
noncompliance. Without such documentation, issues of noncompliance 
will not be fully addressed through corrective actions, and program 
integrity will be at risk.[Footnote 81] This has been a long-standing 
issue for USDA. For example, in 2008, incomplete documentation of 
compliance concerned USDA, as some states were found to be conducting 
practice reviews of SFAs to allow them to fix issues of noncompliance 
before the actual reviews were held. At that time, USDA emphasized to 
states that practice reviews undermine the integrity of the review 
process and should be stopped in order to ensure that reviews include 
full documentation of SFA noncompliance and require all corrective 
actions be taken. By allowing states to not consistently document 
noncompliance during school year 2012-2013, and continuing to 
emphasize assistance in school year 2013-2014, USDA may be setting up 
a similar situation. 

Concerning specific areas assessed by states during administrative 
reviews, states reported through our survey a need for additional USDA 
assistance with oversight of SFA financial management. Specifically, 
nationwide, many states reported a need for additional guidance and 
training on oversight of SFA financial management and the related 
areas of paid lunch equity and revenue from non-program foods. 
[Footnote 82] Although federal regulations have long required states 
to generally ensure that SFAs manage their resources in accordance 
with requirements, USDA guidance on state administrative reviews of 
SFAs previously indicated that SFA financial management was not 
required to be assessed during these reviews. In contrast, in part 
because of new requirements in the Healthy, Hunger-Free Kids Act of 
2010,[Footnote 83] the new administrative review process announced by 
USDA in 2013 includes oversight of five areas of SFA resource 
management and is intended to ensure effective management of school 
meal programs' resources.[Footnote 84] USDA has indicated that 
traditionally, states developed their own processes for reviewing SFA 
finances, but the resulting processes were inconsistent and sometimes 
inadequate. We discussed oversight of this area with six states. The 
child nutrition director from one state indicated that her staff have 
been trained on accounting principles in order to review SFA financial 
management and are therefore ready to implement the new review 
requirements. However, officials from the other five states expressed 
concerns about implementing the new requirements in this area. 
Officials from two states told us that they believe nationwide, 
states' approaches for reviewing SFA financial management have been 
very different. For example, in one state, past review of this area 
consisted of ensuring that the SFA's fund balance at the end of one 
school year matched its starting fund balance at the beginning of the 
next school year, while in another state, officials have long employed 
an outside organization with expertise in this area for these reviews. 
Because state administrative reviews are the key tool used to ensure 
the integrity of the National School Lunch Program, if state reviewers 
are unable to effectively review SFA financial management, the federal 
government will lack assurance that SFAs are complying with federal 
requirements in this area--including those added by the Healthy, 
Hunger-Free Kids Act of 2010. 

Although USDA has provided training for states on SFA financial 
management and is currently in the process of talking with some states 
about oversight of this area, it is unclear if the department has 
fully addressed all states' information needs. Specifically, USDA 
provided training for all states in spring 2013 on the new 
administrative review requirements, including those for SFA financial 
management.[Footnote 85] However, states reported the need for 
additional assistance in this area through our survey after that 
training. In late July 2013, USDA provided two additional webinars for 
states on SFA financial management review requirements, and in 
December 2013, officials told us that they have been providing ongoing 
technical assistance in this area to states upon request. Officials 
added that such requests have been relatively frequent during recent 
months, which they acknowledge is likely related to the change in 
requirements for oversight of this area. Further, as part of USDA's 
larger effort to gather information on states' experiences with the 
new administrative review process, officials told us in January 2014 
that they have been talking with individual states in recent months 
and asking for their questions and concerns related to all areas of 
the administrative review process, including SFA financial management. 
Officials noted that they plan to solicit this information from all 
states implementing the new administrative review process this year. 
However, until the department systematically solicits information from 
all states on their needs related to oversight of SFA financial 
management, including those that are not currently implementing the 
new process, the department will not know if all states are fully 
prepared to oversee this area. 

Conclusions: 

The Healthy, Hunger-Free Kids Act of 2010 required that nutrition 
standards for school lunches be updated to help reduce childhood 
obesity and improve children's diets, and evidence suggests that 
lunches served are now better designed to meet those goals. Although 
some decreases in student lunch participation and challenges for SFAs 
occurred in the first year that the lunch changes were implemented, 
these outcomes are likely related to the substantial scale of the 
changes and the short time in which they were implemented. As a 
result, both participation and many of the challenges SFAs faced 
initially are expected to improve with the passage of time as students 
and SFAs adjust to the new lunch requirements. 

Since the act was passed, USDA has focused on the provision of 
assistance to help SFAs comply with the new requirements. While this 
emphasis may have been needed given the scope of the changes and the 
short timeframe for implementation, it alone will not ensure that 
students nationwide are being served healthier school lunches. Rather, 
only when government assistance is combined with an emphasis on 
program integrity will it be possible to ensure that healthier school 
lunches are served nationwide. The administrative review process has 
long been key to both addressing issues of noncompliance in the 
National School Lunch Program and ensuring that federal and state 
governments have information on areas for which they should target 
additional assistance to SFAs to improve program compliance. However, 
even with this process in place, program errors resulting from lunches 
that did not comply with requirements being served to students have 
been a long-standing issue. The substantial changes to the lunch 
requirements, combined with the delays and changes made in federal 
guidance while the requirements were being implemented, as well as 
temporary changes to the process through which states reviewed SFA 
compliance, increase the likelihood that lunches served to students 
may not meet all of the requirements. In addition, while USDA has 
developed a new administrative review process, which includes new 
requirements related to SFA financial management, the review process 
will not be effective without state understanding of all of the 
requirements they are responsible for overseeing. Further, because the 
Healthy, Hunger-Free Kids Act of 2010 included two new provisions that 
relate to SFA financial management--those addressing paid lunch prices 
and revenue from foods sold outside of the school meals programs--
without effective oversight of SFA financial management by states, 
neither states nor the federal government will have assurance that 
SFAs are correctly implementing these requirements. As new 
requirements are added this year and in the future for the School 
Breakfast Program and competitive foods, timely and consistent USDA 
guidance combined with an effective administrative review process are 
all vital to ensuring successful implementation of the changes to 
school food and achieving the laudable goal of improving school 
children's diets and health. 

Recommendations for Executive Action: 

To improve program integrity, as USDA moves forward with its new 
administrative review process, we recommend that the Secretary of 
Agriculture direct the Administrator for the Food and Nutrition 
Service to take the following actions: 

* clarify to states the importance of documenting compliance issues 
found during administrative reviews and requiring corrective actions 
to address them, and: 

* continue efforts to systematically assess all states' needs for 
information to improve their ability to oversee SFA financial 
management and provide assistance to meet identified needs. 

Agency Comments: 

We provided a draft of this report to USDA for review and comment. In 
oral comments, the Senior Policy Advisor to the Deputy Administrator 
for Child Nutrition Programs and other USDA officials generally agreed 
with our recommendations. These officials also noted that they 
consider the emphasis on technical assistance associated with school 
meals implementation in school year 2012-2013 appropriate given that 
the new meal patterns represented a major transition for local program 
operators. They also indicated their belief that the level of review 
associated with the 6-cent certification process, including detailed 
review of meal pattern documentation and on-site reviews of at least 
25 percent of certified SFAs, provides a solid foundation for ongoing 
oversight of compliance moving forward. Officials also expressed their 
belief that the new administrative review process, which they 
developed in collaboration with states, is an effective and efficient 
monitoring process that will improve program integrity. Further, they 
noted that their ongoing efforts to assist state efforts to properly 
implement the new process will help ensure that states are able to 
effectively review all required areas, including SFA financial 
management. We agree that the new administrative review process, if 
properly implemented, could improve program integrity, and as we 
discuss in the report, we agree that the emphasis on technical 
assistance likely benefited SFAs as they transitioned to the new lunch 
requirements. However, we continue to believe that the changes made in 
oversight requirements during school year 2012-2013 may have left USDA 
without key information on compliance issues SFAs faced when 
implementing the changes and may have created confusion among states 
as to the importance of consistently documenting noncompliance for 
program integrity. While we also remain concerned that the change in 
oversight requirements during school year 2012-2013 and the 
department's continued emphasis on state assistance to SFAs moving 
forward may inadvertently undercut the effectiveness of the new review 
process, we see opportunities for USDA to address these issues. 
Specifically, as USDA continues its efforts to communicate and 
collaborate with states during their implementation of the new review 
process, the department is well-positioned to emphasize the importance 
of documenting noncompliance for effective program oversight and to 
provide states with the information they need to effectively review 
all required areas. USDA officials also provided technical comments, 
which we incorporated into the report as appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution of it until 30 
days from the report date. At that time, we will send copies of this 
report to the appropriate congressional committees, the Secretary of 
Agriculture, and other interested parties. In addition, this report 
will be available at no charge on GAO's website at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions concerning this report, please 
contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made key contributions 
to this report are listed in appendix III. 

Signed by: 

Kay E. Brown: 
Director, Education, Workforce, and Income Security Issues: 

[End of section] 

Appendix I: Scope and Methodology: 

U.S. Department of Agriculture (USDA): 

Participation Data: 

To assess trends in school lunch participation, we analyzed USDA's 
national data on meals served in the National School Lunch Program 
from school year 2000-2001 through school year 2012-2013.[Footnote 86] 
Each month, states report to USDA on the FNS-10 form the number of 
lunches served by category of student--free, reduced-price, and paid--
as well as average daily lunches served to all students. These data 
are used to determine federal reimbursement payments to states. 
Additionally, in October of each school year, states report to USDA 
the total number of students enrolled in schools with the National 
School Lunch Program, as well as the total number of students approved 
for free and reduced-price meals in that month. Subtracting these 
students from the total enrolled students provides the number of 
students required to pay full price for their meals, if they choose to 
buy them, in schools with the National School Lunch Program. 

Although USDA does not collect additional data on the number of 
students participating in the program each month, the department uses 
the lunch data it collects to determine the number of students 
participating in the program. Specifically, USDA adjusts the data on 
average daily lunches served each month upward to help account for 
students who participated in the program for a number of days less 
than all days in the month. To make this adjustment, USDA uses an 
estimate of the proportion of students that attend schools daily 
nationwide.[Footnote 87] 

To analyze participation in the National School Lunch Program, we 
reviewed USDA's data on meals served and students enrolled, as well as 
the department's methodology for determining student participation, 
and determined these data and the method to be sufficiently reliable 
for the purposes of this report. Specifically, we interviewed USDA 
officials to gather information on the processes they use to ensure 
the completeness and accuracy of the school lunch data, reviewed 
related documentation, and compared the data we received from the 
department to its published data. To determine school year 
participation from these data, we relied on 9 months of data--
September through May--for each year.[Footnote 88] To determine the 
participation rate, we divided the number of students participating 
per month by the total number of students enrolled in schools with the 
program. We followed the same approach to determine the participation 
rates for students receiving free and reduced-price lunches, as well 
as those who paid full price for their lunches. 

Guidance Documents: 

To understand the scale and scope of assistance USDA has provided to 
states and SFAs, we analyzed guidance memos USDA issued from January 
2011--the month after the Healthy, Hunger-Free Kids Act was enacted--
through September 2013. We reviewed all guidance memos issued to 
states during this time period and further analyzed those that 
provided guidance addressing the new requirements for the content of 
school lunches, including related issues such as food procurement and 
state review of SFA compliance with the lunch content requirements, as 
well as those addressing the paid lunch equity requirements. These 
memos included the department's policy and technical assistance memos, 
as well as other relevant guidance memos that were not designated in 
one of those categories. For guidance memos that were released in 
multiple versions, we considered each version to be a separate piece 
of guidance.[Footnote 89] We categorized the guidance memos by their 
primary topic and analyzed their content to determine whether they 
clarified regulations, provided new flexibilities related to 
requirements included in federal regulations, or substantively changed 
previously-issued guidance. We also assessed the number of pages 
included in each document, defined as the number of digital pages for 
each guidance document, including attachments. In the case of 
spreadsheet files, we counted each worksheet within the file as a 
single page. We did not conduct an independent legal analysis of these 
guidance memos. 

Survey of States: 

To obtain information on state efforts related to implementation of 
the new school lunch content and nutrition requirements, we conducted 
a national survey of state child nutrition directors who oversee the 
National School Lunch Program in the 50 states and the District of 
Columbia.[Footnote 90] We administered our Web-based survey between 
June and July 2013, and all state directors responded. The survey 
included questions about SFA challenges with the new lunch 
requirements, state use of administrative funds, and USDA assistance 
to states. The survey also requested data on SFAs and schools 
participating in the program, SFAs that left the program in school 
year 2012-2013, and state certification and validation of SFAs in 
compliance with the new requirements. 

Because separate agencies oversee the administration of the National 
School Lunch Program in public and private schools in five states, we 
surveyed both agencies in each of these states. These five states are 
Arkansas, Colorado, Georgia, Oklahoma, and Virginia. In two of these 
states, separate state agencies oversee public and private schools 
administering the program, while in the remaining three, private 
schools administering the program are overseen by the relevant FNS 
regional office. For these five states, when analyzing survey results 
for questions with numerical responses, we combined the answers from 
entities overseeing both public and private schools in order to 
represent the state as a whole. For all other questions, such as those 
concerning SFA challenges with the lunch requirements, we reported 
responses from the agency overseeing the program in public schools 
because those agencies represented the majority of schools with the 
program in these states. 

Because this was not a sample survey, there are no sampling errors. 
However, the practical difficulties of conducting any survey may 
introduce nonsampling errors, such as variations in how respondents 
interpret questions and their willingness to offer accurate responses. 
We took steps to minimize nonsampling errors, including pretesting 
draft instruments and using a Web-based administration system. 
Specifically, during survey development, we pretested draft 
instruments with child nutrition directors from three states 
(Louisiana, Texas, and Virginia) in May 2013. We selected the pretest 
states to provide variation in state school lunch program 
characteristics and geographic location. In the pretests, we were 
generally interested in the clarity, precision, and objectivity of the 
questions, as well as the flow and layout of the survey. For example, 
we wanted to ensure definitions used in the surveys were clear and 
known to the respondents, categories provided in closed-ended 
questions were complete and exclusive, and the ordering of survey 
sections and the questions within each section were appropriate. We 
revised the final survey based on pretest results. Another step we 
took to minimize nonsampling errors was using a Web-based survey. 
Allowing respondents to enter their responses directly into an 
electronic instrument created a record for each respondent in a data 
file and eliminated the need for and the errors associated with a 
manual data entry process. To further minimize errors, programs used 
to analyze the survey data were independently verified to ensure the 
accuracy of this work. 

While we did not fully validate specific information that states 
reported through our survey, we took several steps to ensure that the 
information was sufficiently reliable for the purposes of this report. 
For example, we reviewed the responses and identified those that 
required further clarification and, subsequently, solicited follow-up 
information from those respondents via email and phone to ensure the 
information they provided was reasonable and reliable. In our review 
of the data, we also identified and logically fixed skip pattern 
errors for questions that respondents should have skipped but did not. 
On the basis of these checks, we believe our survey data are 
sufficiently reliable for the purposes of our work. 

Site Visits: 

To gather information from the local level on implementation of the 
new lunch content and nutrition requirements, we conducted site visits 
to eight school districts across the country between March and May 
2013. The school districts we visited were: Caddo Parish Public 
Schools (LA), Carlisle Area School District (PA), Chicago Public 
Schools (IL), Coeur d'Alene School District (ID), Fairfax County 
Public Schools (VA), Irving Independent School District (TX), 
Mukwonago Area School District (WI), and Spokane Public Schools (WA). 
We selected these school districts because they provided variation 
across geographic location, district size, and certain characteristics 
of the student population and district food services. For example, the 
proportion of students eligible for free and reduced-price lunches and 
the racial and ethnic characteristics of the student population varied 
across the districts selected. Further, we selected districts with 
different food service approaches, including some that generally 
prepared school lunches in one central kitchen before delivering them 
to schools, some that prepared lunches in kitchens on-site in each 
school, and others that used alternative approaches for lunch 
preparation. Seven of the school districts we visited managed their 
own food service operations, while one district contracted with food 
service management companies. We relied on the U.S. Department of 
Education's Common Core of Data, which provides information on public 
schools,[Footnote 91] to ensure selected districts met several of our 
criteria. As a result, all of the districts we selected for site 
visits were public, although non-profit private elementary and 
secondary schools, as well as residential child care institutions, 
also participate in the National School Lunch Program. 

In each district, to gather information on local level implementation 
of the new lunch requirements, we interviewed the SFA director, as 
well as other key district-level SFA staff and food service staff in 
at least two schools. During these interviews, we collected 
information about lunch participation trends; challenges, if any, 
implementing the new lunch requirements; and USDA and state assistance 
with the changes. To select the schools we visited in each district, 
we worked with the SFA director to ensure the schools included 
students of differing grade levels in order to capture any relevant 
differences in their reactions to the new lunch requirements. In each 
school, we observed lunch--including students' food selections, 
consumption, and plate waste--and, when feasible, interviewed students 
and school staff to obtain their thoughts on the lunch changes. We 
also interviewed the eight state child nutrition program directors 
overseeing these districts to gather information on statewide lunch 
participation trends; SFA challenges, if any; and USDA and state 
assistance with implementation of the changes. Following the site 
visits, in late summer 2013, we obtained school lunch participation 
data for school years 2008-2009 through 2012-2013 and information 
about school year 2012-2013 finances from the eight SFA directors. We 
cannot generalize our findings from the site visits beyond the school 
districts we visited.[Footnote 92] 

[End of section] 

Appendix II: Federal Requirements for the Content of School Lunches: 

Previous Requirements: 

Under the previous federal requirements for the content of school 
lunches, SFAs could choose to use one of five approved approaches to 
plan their menus. Three of these approaches focused on nutrient 
requirements and, aside from milk, did not specify food components or 
portion size requirements. Under the two remaining approaches, 
Traditional and Enhanced Food-Based Menu Planning, schools had to 
comply with specific food component and portion size requirements, as 
well as nutrient requirements. See tables 1 through 4 for details of 
the previous Food-Based Menu Planning approaches. 

Table 1: Traditional Food-Based Menu Planning Approach Requirements: 

Traditional Food-Based Menu Planning Approach-Meal Pattern for Lunches: 

Food components and food items: Milk (as a beverage); 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 6 fluid ounces; 
Group II: Ages 3-4 Preschool: 6 fluid ounces; 
Group III: Ages 5-8: Grades K-3: 8 fluid ounces; 
Group IV: Ages 9 and: older: Grades 4-12: 8 fluid ounces; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 8 fluid ounces. 

Food components and food items: Meat or Meat Alternate (quantity of 
the edible portion as served): 

Food components and food items: Lean meat, poultry, or fish; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 1 ounce; 
Group II: Ages 3-4 Preschool: 1½ ounces; 
Group III: Ages 5-8: Grades K-3: 1½ ounces; 
Group IV: Ages 9 and: older: Grades 4-12: 2 ounces; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 3 ounces. 

Food components and food items: Alternate Protein Products[A]; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 1 ounce; 
Group II: Ages 3-4 Preschool: 1½ ounces; 
Group III: Ages 5-8: Grades K-3: 1½ ounces; 
Group IV: Ages 9 and: older: Grades 4-12: 2 ounces; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 3 ounces. 

Food components and food items: Cheese; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 1 ounce; 
Group II: Ages 3-4 Preschool: 1½ ounces; 
Group III: Ages 5-8: Grades K-3: 1½ ounces; 
Group IV: Ages 9 and: older: Grades 4-12: 2 ounces; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 3 ounces. 

Food components and food items: Large egg; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: ½; 
Group II: Ages 3-4 Preschool: ¾; 
Group III: Ages 5-8: Grades K-3: ¾; 
Group IV: Ages 9 and: older: Grades 4-12: 1; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 1½. 

Food components and food items: Cooked dry beans or peas; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: ¼ cup; 
Group II: Ages 3-4 Preschool: 3/8 cup; 
Group III: Ages 5-8: Grades K-3: 3/8 cup; 
Group IV: Ages 9 and: older: Grades 4-12: ½ cup; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: ¾ cup. 

Food components and food items: Peanut butter or other nut or seed 
butters; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 2 tablespoons; 
Group II: Ages 3-4 Preschool: 3 tablespoons; 
Group III: Ages 5-8: Grades K-3: 3 tablespoons; 
Group IV: Ages 9 and: older: Grades 4-12: 4 tablespoons; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 6 tablespoons. 

Food components and food items: Yogurt, plain or flavored, unsweetened 
or sweetened; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 4 ounces or ½ cup; 
Group II: Ages 3-4 Preschool: 6 ounces or ¾ cup; 
Group III: Ages 5-8: Grades K-3: 6 ounces or ¾ cup; 
Group IV: Ages 9 and: older: Grades 4-12: 8 ounces or 1 cup; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 12 ounces or 1½ cups. 

Food components and food items: The following may be used to meet no 
more than 50% of the requirement and must be used in combination with 
any of the above: Peanuts, soynuts, tree nuts, or seeds, as listed in 
program guidance, or an equivalent quantity of any combination of the 
above meat/meat alternate (1 ounce of nuts/seeds = 1 ounce of cooked 
lean meat, poultry, or fish); 
Minimum quantities: 
Group I: Ages 1-2 Preschool: ½ ounce=50%; 
Group II: Ages 3-4 Preschool: ¾ ounce=50%; 
Group III: Ages 5-8: Grades K-3: ¾ ounce=50%; 
Group IV: Ages 9 and: older: Grades 4-12: 1 ounce=50%; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: 1½ ounces = 50%. 

Food components and food items: Vegetable or Fruit: 2 or more servings 
of vegetables, fruits or both; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: ½ cup; 
Group II: Ages 3-4 Preschool: ½ cup; 
Group III: Ages 5-8: Grades K-3: ½ cup; 
Group IV: Ages 9 and: older: Grades 4-12: ¾ cup; 
Recommended quantities: 
Group V: Ages 12 and older: Grades: 7-12: ¾ cup. 

Food components and food items: Grains/Breads: (servings per week): 
Must be enriched or whole grain. A serving is a slice of bread or an 
equivalent serving of biscuits, rolls, etc., or ½ cup of cooked rice, 
macaroni, noodles, other pasta products or cereal grains; 
Minimum quantities: 
Group I: Ages 1-2 Preschool: 5 servings per week[B]; minimum of ½ 
serving per day; 
Group II: Ages 3-4 Preschool: 8 servings per week[B]; minimum of ½ 
serving per day; 
Group III: Ages 5-8: Grades K-3: 8 servings per week[B]; minimum of ½ 
serving per day; 
Group IV: Ages 9 and: older: Grades 4-12: 8 servings per week[B]; 
minimum of ½ serving per day; 
Group V: Ages 12 and older: Grades: 7-12: 10 servings per week[B]; 
minimum of 1 serving per day. 

Source: 7 C.F.R. § 210.10(k)(1)(i) (2012). 

[A] Must meet the requirements in appendix A of 7 C.F.R. pt. 210. 

[B] For the purposes of this table, a week equals five days. 

[End of table] 

Table 2: Traditional Food-Based Menu Planning Approach Nutrient and 
Calorie Requirements: 

Minimum Nutrient and Calorie Levels for School Lunches: 
Traditional Food-Based Menu Planning Approach (School Week Averages): 

Nutrients and Energy Allowances: Energy allowances (calories); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 517; 
Group III: Grades K-3: Ages 5-8: 633; 
Group IV: Grades 4-12: Ages 9 and older: 785; 
Recommended: Group V: Grades 7-12: Ages 12 and older: 825. 

Nutrients and Energy Allowances: Total fat (as a percentage of actual 
total food energy); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: a; 
Group III: Grades K-3: Ages 5-8: a,b; 
Group IV: Grades 4-12: Ages 9 and older: b; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: b. 

Nutrients and Energy Allowances: Saturated fat (as a percentage of 
actual total food energy); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: a; 
Group III: Grades K-3: Ages 5-8: a,c; 
Group IV: Grades 4-12: Ages 9 and older: c; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: c. 

Nutrients and Energy Allowances: RDA for protein (g); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 7; 
Group III: Grades K-3: Ages 5-8: 9; 
Group IV: Grades 4-12: Ages 9 and older: 15; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: 16. 

Nutrients and Energy Allowances: RDA for calcium (mg); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 267; 
Group III: Grades K-3: Ages 5-8: 267; 
Group IV: Grades 4-12: Ages 9 and older: 370; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: 400. 

Nutrients and Energy Allowances: RDA for iron (mg); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 3.3; 
Group III: Grades K-3: Ages 5-8: 3.3; 
Group IV: Grades 4-12: Ages 9 and older: 4.2; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: 4.5. 

Nutrients and Energy Allowances: RDA for Vitamin A (RE); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 150; 
Group III: Grades K-3: Ages 5-8: 200; 
Group IV: Grades 4-12: Ages 9 and older: 285; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: 300. 

Nutrients and Energy Allowances: RDA for Vitamin C (mg); 
Minimum requirements: 
Group II: Preschool: Ages 3-4: 14; 
Group III: Grades K-3: Ages 5-8: 15; 
Group IV: Grades 4-12: Ages 9 and older: 17; 
Recommended: 
Group V: Grades 7-12: Ages 12 and older: 18. 

Source: 7 C.F.R. § 210.10(d)(1) (2012). 

[A] The Dietary Guidelines recommend that after 2 years of age 
"...children should gradually adopt at diet that, by about 5 years of 
age, contains no more than 30 percent of calories from fat." 

[B] Not to exceed 30 percent over a school week. 

[C] Less than 10 percent over a school week. 

[End of table] 

Table 3: Enhanced Food-Based Menu Planning Approach Requirements: 

Food Components and: Food Items: Milk (as a beverage); 
Minimum requirements: 
Ages 1-2: 6 fluid ounces; 
Preschool: 6 fluid ounces; 
Grades K-6: 8 fluid ounces; 
Grades 7-12: 8 fluid ounces; 
Option for: Grades K-3: 8 fluid ounces. 

Food Components and: Food Items: Meat or Meat Alternate (quantity of 
the edible portion as served): 

Food Components and: Food Items: Lean meat, poultry, or fish; 
Minimum requirements: 
Ages 1-2: 1 ounce; 
Preschool: 1½ ounces; 
Grades K-6: 2 ounces; 
Grades 7-12: 2 ounces; 
Option for: Grades K-3: 1½ ounces. 

Food Components and: Food Items: Alternate protein products[A]; 
Minimum requirements: 
Ages 1-2: 1 ounce; 
Preschool: 1½ ounces; 
Grades K-6: 2 ounces; 
Grades 7-12: 2 ounces; 
Option for: Grades K-3: 1½ ounces. 

Food Components and: Food Items: Cheese; 
Minimum requirements: 
Ages 1-2: 1 ounce; 
Preschool: 1½ ounces; 
Grades K-6: 2 ounces; 
Grades 7-12: 2 ounces; 
Option for: Grades K-3: 1½ ounces. 

Food Components and: Food Items: Large egg; 
Minimum requirements: 
Ages 1-2: ½; 
Preschool: ¾; 
Grades K-6: 1; 
Grades 7-12: 1; 
Option for: Grades K-3: ¾. 

Food Components and: Food Items: Cooked dry beans or peas; 
Minimum requirements: 
Ages 1-2: ¼ cup; 
Preschool: 3/8 cup; 
Grades K-6: ½ cup; 
Grades 7-12: ½ cup; 
Option for: Grades K-3: 3/8 cup. 

Food Components and: Food Items: Peanut butter or other nut or seed 
butters; 
Minimum requirements: 
Ages 1-2: 2 tablespoons; 
Preschool: 3 tablespoons; 
Grades K-6: 4 tablespoons; 
Grades 7-12: 4 tablespoons; 
Option for: Grades K-3: 3 tablespoons. 

Food Components and: Food Items: Yogurt, plain or flavored, 
unsweetened or sweetened; 
Minimum requirements: 
Ages 1-2: 4 ounces or ½ cup; 
Preschool: 6 ounces or ¾ cup; 
Grades K-6: 8 ounces or 1 cup; 
Grades 7-12: 8 ounces or 1 cup; 
Option for: Grades K-3: 6 ounces or ¾ cup. 

Food Components and: Food Items: The following may be used to meet no 
more than 50% of the requirement and must be used in combination with 
any of the above: Peanuts, soy nuts, tree nuts, or seeds, as listed in 
program guidance, or an equivalent quantity of any combination of the 
above meat/meat alternate (1 ounce of nuts/seeds equals 1 ounce of 
cooked lean meat, poultry or fish); 
Minimum requirements: 
Ages 1-2: ½ ounce = 50%; 
Preschool: ¾ ounce = 50%; 
Grades K-6: 1 ounce = 50%; 
Grades 7-12: 1 ounce = 50%; 
Option for: Grades K-3: ¾ ounce =50%. 

Food Components and: Food Items: Vegetable or Fruit: 2 or more 
servings of vegetables, fruits or both; 
Minimum requirements: 
Ages 1-2: ½ cup; 
Preschool: ½ cup; 
Grades K-6: ¾ cup plus an extra ½ cup over a week[B]; 
Grades 7-12: 1 cup; 
Option for: Grades K-3: ¾ cup. 

Food Components and: Food Items: Grains/Breads (servings per week): 
Must be enriched or whole grain. A serving is a slice of bread or an 
equivalent serving of biscuits, rolls, etc., or ½ cup of cooked rice, 
macaroni, noodles, other pasta products or cereal grains; 
Minimum requirements: 
Ages 1-2: 5 servings per week[B]; minimum of ½ serving per day; 
Preschool: 8 servings per week[B]; minimum of 1 serving per day; 
Grades K-6: 12 servings per week[B]; minimum of 1 serving per day[C]; 
Grades 7-12: 15 servings per week[B]; minimum of 1 serving per day[C]; 
Option for: Grades K-3: 10 servings per week[B]; minimum of 1 serving 
per day[C]. 

Source: 7 C.F.R. § 210.10(k)(2) (2012). 

[A] Must meet the requirements in appendix A of 7 C.F.R. pt. 210. 

[B] For the purposes of this table, a week equals five days. 

[C] Up to one grains/breads serving per day may be a dessert. 

[End of table] 

Table 4: Enhanced Food-Based Menu Planning Approach Nutrient and 
Calorie Requirements: 

Minimum Nutrient and Calorie Levels for School Lunches: 
Enhanced Food-Based Menu Planning Approach (School Week Averages): 

Nutrients and Energy Allowances: Energy allowances (calories); 
Minimum requirements: 
Preschool: 517; 
Grades K-6: 664; 
Grades 7-12: 825; 
Optional: Grades K-3: 633. 

Nutrients and Energy Allowances: Total fat (as a percentage of actual 
total food energy); 
Minimum requirements: 
Preschool: [A]; 
Grades K-6: [A,B]; 
Grades 7-12: [B]; 
Optional: Grades K-3: [A,B]. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: Saturated fat (as a 
percentage of actual total food energy); 
Minimum requirements: 
Preschool: [A]; 
Grades K-6: [A,C]; 
Grades 7-12: [C]; 
Optional: Grades K-3: [A,C]. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: RDA for protein (g); 
Minimum requirements: 
Preschool: 7; 
Grades K-6: 10; 
Grades 7-12: 16; 
Optional: Grades K-3: 9. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: RDA for calcium (mg); 
Minimum requirements: 
Preschool: 267; 
Grades K-6: 286; 
Grades 7-12: 400; 
Optional: Grades K-3: 267. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: RDA for iron (mg); 
Minimum requirements: 
Preschool: 3.3; 
Grades K-6: 3.5; 
Grades 7-12: 4.5; 
Optional: Grades K-3: 3.3. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: RDA for Vitamin A (RE); 
Minimum requirements: 
Preschool: 150; 
Grades K-6: 224; 
Grades 7-12: 300; 
Optional: Grades K-3: 200. 

Minimum Nutrient and Calorie Levels for School Lunches: Enhanced Food-
Based Menu Planning Approach (School Week Averages): Minimum 
requirements: Nutrients and Energy Allowances: RDA for Vitamin C (mg); 
Minimum requirements: 
Preschool: 14; 
Grades K-6: 15; 
Grades 7-12: 18; 
Optional: Grades K-3: 15. 

Source: 7 C.F.R. § 210.10(d)(2) (2012). 

[A] The Dietary Guidelines recommend that after 2 years of age 
"...children should gradually adopt at diet that, by about 5 years of 
age, contains no more than 30 percent of calories from fat." 

[B] Not to exceed 30 percent over a school week. 

[C] Less than 10 percent over a school week. 

[End of table] 

Current Requirements: 

Following passage of the Healthy, Hunger-Free Kids Act of 2010, USDA 
updated federal requirements for the content of school lunches and 
required all SFAs to use the same approach for planning lunch menus--
Food-Based Menu Planning. In the January 2012 final rule on these 
changes, USDA noted that over 70 percent of program operators were 
already using the Food-Based Menu Planning approach to plan their 
lunch menus. See table 5 for details of the current lunch content and 
nutrition requirements. 

Table 5: Food-Based Menu Planning Approach Requirements Beginning in 
School Year 2012-2013: 

Lunch Meal Pattern: 

Amount of food[A] per week; (minimum per day): 

Meal pattern: Fruits (cups) [B]; 
Grades K-5: 2 1/2 (1/2); 
Grades 6-8: 2 1/2 (1/2); 
Grades 9-12: 5 (1). 

Meal Pattern: Vegetables (cups); 
Grades K-5: 3 3/4 (3/4); 
Grades 6-8: 3 3/4 (3/4); 
Grades 9-12: 5 (1). 

Meal pattern: Vegetables (cups) [B]: Dark green [C]; 
Grades K-5: ½; 
Grades 6-8: ½; 
Grades 9-12: ½. 

Meal pattern: Vegetables (cups) [B]: Red/Orange [C]; 
Grades K-5: ¾; 
Grades 6-8: ¾; 
Grades 9-12: 1 ¼. 

Meal pattern: Vegetables (cups) [B]: Beans and peas (legumes) [C]; 
Grades K-5: ½; 
Grades 6-8: ½; 
Grades 9-12: ½. 

Meal pattern: Vegetables (cups) [B]: Starchy [C]; 
Grades K-5: ½; 
Grades 6-8: ½; 
Grades 9-12: ½. 

Meal pattern: Vegetables (cups) [B]: Other [C,D]; 
Grades K-5: ½; 
Grades 6-8: ½; 
Grades 9-12: ¾. 

Meal pattern: Vegetables (cups) [B]: Additional Veg to Reach Total [E]; 
Grades K-5: 1 [E]; 
Grades 6-8: 1 [E]; 
Grades 9-12: 1 1/2 [E]. 

Meal pattern: Grains (oz eq)[F]; 
Grades K-5: 8-9 (1); 
Grades 6-8: 8-10 (1); 
Grades 9-12: 10-12 (2). 

Meal pattern: Meats/Meat Alternates (oz eq); 
Grades K-5: 8-10 (1); 
Grades 6-8: 9-10 (1); 
Grades 9-12: 10-12 (2). 

Meal pattern: Fluid milk (cups) [G]; 
Grades K-5: 5 (1); 
Grades 6-8: 5 (1); 
Grades 9-12: 5 (1). 

Other Specifications: Daily Amount Based on the Average for a 5-Day 
Week: 

Meal pattern: Min-max calories (kcal) [H]; 
Grades K-5: 550-650; 
Grades 6-8: 600-700; 
Grades 9-12: 750-850. 

Meal pattern: Saturated fat (% of total calories) [H]; 
Grades K-5: less than 10; 
Grades 6-8: less than 10; 
Grades 9-12: less than 10. 

Meal pattern: Sodium (mg) [H,I]; 
Grades K-5: 640; 
Grades 6-8: 710; 
Grades 9-12: 740. 

Meal pattern: Transfat [H]; 
Nutrition label or manufacturer specifications must indicate zero 
grams of trans fat per serving. 

Source: 7 C.F.R. § 210.10(c) (2013) as added by Nutrition Standards in 
the National School Lunch and School Breakfast Programs, 77 Fed. Reg. 
4088 (Jan. 26, 2012). 

[A] Food items included in each group and subgroup and amount 
equivalents. Minimum creditable serving is 1/8 cup. 

[B] One quarter-cup of dried fruit counts as 1/2 cup of fruit; 1 cup 
of leafy greens counts as 1/2 cup of vegetables. No more than half of 
the fruit or vegetable offerings may be in the form of juice. All 
juice must be 100% full-strength. 

[C] Larger amounts of these vegetables may be served. 

[D] This category consists of "Other vegetables" as defined in 7 
C.F.R. § 210.10(c)(2)(iii)(E). For the purposes of the National School 
Lunch Program, the "Other vegetables" requirement may be met with any 
additional amounts from the dark green, red/orange, and beans/peas 
(legumes) vegetable subgroups as defined in 7 C.F.R. § 
210.10(c)(2)(iii). 

[E] Any vegetable subgroup may be offered to meet the total weekly 
vegetable requirement. 

[F] Beginning July 1, 2012 (SY 2012-2013), at least half of grains 
offered must be whole grain-rich. Beginning July 1, 2014 (SY 2014-15), 
all grains must be whole grain-rich. 

[G] Beginning July 1, 2012 (SY 2012-2013), all fluid milk must be low-
fat (1 percent or less, unflavored) or fat-free (unflavored or 
flavored). 

[H] Discretionary sources of calories (solid fats and added sugars) 
may be added to the meal pattern if within the specifications for 
calories, saturated fat, transfat, and sodium. Foods of minimal 
nutritional value and fluid milk with fat content greater than 1 
percent are not allowed. 

[I] Final sodium targets must be met no later than July 1, 2022 (SY 
2022-2023). The first intermediate target must be met no later than SY 
2014-2015 and the second intermediate target must be met no later than 
SY 2017-2018. See required intermediate specifications in 7 C.F.R. § 
210.10(f)(3). 

[End of table] 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Kay E. Brown, (202) 512-7215 or brownke@gao.gov. 

Staff Acknowledgments: 

In addition to the contact named above, Rachel Frisk and Kathy Larin 
(Assistant Directors), Robert Campbell, Jean McSween, Dan Meyer, 
Christine San, and Zachary Sivo made key contributions to this report. 
Also contributing to this report were James Bennett, Nora Boretti, 
Jessica Botsford, Sheila McCoy, Paul Schearf, and Almeta Spencer. 

[End of section] 

Related GAO Products: 

School Lunch: Modifications Needed to Some of the New Nutrition 
Standards. [hyperlink, http://www.gao.gov/products/GAO-13-708T]. 
Washington, D.C.: June 27, 2013. 

School Meal Programs: More Systematic Development of Specifications 
Could Improve the Safety of Foods Purchased through USDA's Commodity 
Program. [hyperlink, http://www.gao.gov/products/GAO-11-376]. 
Washington, D.C.: May 3, 2011. 

School Meal Programs: Improved Reviews, Federal Guidance, and Data 
Collection Needed to Address Counting and Claiming Errors. [hyperlink, 
http://www.gao.gov/products/GAO-09-814]. Washington, D.C.: September 
9, 2009. 

School Meal Programs: Changes to Federal Agencies' Procedures Could 
Reduce Risk of School Children Consuming Recalled Food. [hyperlink, 
http://www.gao.gov/products/GAO-09-649]. Washington, D.C.: August 20, 
2009. 

School Meal Programs: Experiences of the States and Districts That 
Eliminated Reduced-price Fees. [hyperlink, 
http://www.gao.gov/products/GAO-09-584]. Washington, D.C.: July 17, 
2009. 

Meal Counting and Claiming by Food Service Management Companies in the 
School Meal Programs. [hyperlink, 
http://www.gao.gov/products/GAO-09-156R]. Washington, D.C.: January 
30, 2009. 

School Meals Programs: Competitive Foods Are Widely Available and 
Generate Substantial Revenues for Schools. [hyperlink, 
http://www.gao.gov/products/GAO-05-563]. Washington, D.C.: August 8, 
2005. 

Nutrition Education: USDA Provides Services through Multiple Programs, 
but Stronger Linkages among Efforts Are Needed. [hyperlink, 
http://www.gao.gov/products/GAO-04-528]. Washington, D.C.: April 27, 
2004. 

School Meals Programs: Competitive Foods Are Available in Many 
Schools; Actions Taken to Restrict Them Differ by State and Locality. 
[hyperlink, http://www.gao.gov/products/GAO-04-673]. Washington, D.C.: 
April 23, 2004. 

School Lunch Program: Efforts Needed to Improve Nutrition and 
Encourage Healthy Eating. [hyperlink, 
http://www.gao.gov/products/GAO-03-506]. Washington, D.C.: May 9, 2003. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 111-296, § 201, 124 Stat. 3183, 3214. The Act required 
USDA to update the meal patterns and nutrition standards for the 
National School Lunch Program based on recommendations issued by the 
Food and Nutrition Board, which is part of the National Academies' 
Institute of Medicine, and throughout this report, we refer to these 
as the Institute of Medicine's recommendations, on which USDA based 
the new lunch content and nutrition requirements. 

[2] See GAO, School Lunch: Modifications Needed to Some of the New 
Nutrition Standards, [hyperlink, 
http://www.gao.gov/products/GAO-13-708T] (Washington, D.C.: June 27, 
2013). 

[3] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[4] U.S. Department of Agriculture, Food and Nutrition Service, Office 
of Research and Analysis, School Nutrition Dietary Assessment Study IV 
(Alexandria, VA: November 2012). 

[5] Institute of Medicine, School Meals: Building Blocks for Healthy 
Children (Washington, D.C.: The National Academies Press, 2010). 

[6] Because separate agencies oversee the administration of the 
National School Lunch Program in public and private schools in five 
states, we surveyed both agencies in each of these five states. In two 
of the states, separate state agencies oversee public and private 
schools administering the program, while in the remaining three, 
private schools administering the program are overseen by the relevant 
USDA regional office. 

[7] We conducted site visits to Caddo Parish Public Schools (LA), 
Carlisle Area School District (PA), Chicago Public Schools (IL), Coeur 
d'Alene School District (ID), Fairfax County Public Schools (VA), 
Irving Independent School District (TX), Mukwonago Area School 
District (WI), and Spokane Public Schools (WA). 

[8] We reported on our preliminary findings from these visits in 
[hyperlink, http://www.gao.gov/products/GAO-13-708T]. 

[9] The School Nutrition Association (SNA), a national non-profit 
organization representing 55,000 members involved in serving meals to 
children in schools, assisted our efforts to speak with these groups. 
The eight SFA directors we spoke with were representatives on SNA's 
public policy and legislation committee, which includes 
representatives from each region of the country, as well as SNA's 
board of directors. None of these SFA directors were responsible for 
administering the National School Lunch Program in districts that we 
selected for site visits, and only one of the SFA directors was from a 
state in which we conducted a site visit. The 11 industry 
representatives we spoke with were members of SNA, and some serve on 
the Association's industry advisory board. 

[10] The National School Lunch Act was redesignated as the Richard B. 
Russell National School Lunch Act in 1999. Throughout this report we 
refer to the act as the National School Lunch Act. 

[11] As authorized in the National School Lunch Act, SFAs are entitled 
to receive commodity foods or, where applicable, cash in lieu of 
commodity foods. In school year 2013-2014, SFAs received commodity 
foods valued at 23.25 cents for each reimbursable lunch served. 

[12] An SFA is the governing body that is responsible for the 
administration of the National School Lunch Program in one or more 
schools, which has the legal authority to operate the program therein 
or is otherwise approved by FNS to operate the program. 

[13] Nutrition Standards in the National School Lunch and School 
Breakfast Programs, 77 Fed. Reg. 4088 (Jan. 26, 2012) (codified at 7 
C.F.R. pts. 210 and 220). 

[14] In January 2014, USDA issued regulations that remove the 
requirement for SFAs to comply with the limits on meats/meat 
alternates and grains. See Certification of Compliance With Meal 
Requirements for the National School Lunch Program Under the Healthy, 
Hunger-Free Kids Act of 2010, 79 Fed. Reg. 325 (Jan. 3, 2014) 
(codified at 7 C.F.R. pt. 210). 

[15] Regarding the grains component of the lunch, the regulations 
require that all grain products must be made with enriched and whole 
grain meal or flour, and whole grain-rich products must contain at 
least 51 percent whole grains. 7 C.F.R. § 210.10(c)(2)(iv). Beginning 
July 1, 2012, half of the grain products offered during the school 
week must meet the whole grain-rich criteria, and beginning July 1, 
2014, all grain products must meet these criteria. 

[16] The offer versus serve policy has been required for senior high 
schools and optional for all other schools since 1975. This policy 
allows students to decline two of the five meal components offered 
with the lunch, rather than requiring students to be served all five 
components. 

[17] The final rule requires schools to gradually reduce the sodium 
content of lunches over a specified time period. The first 
intermediate sodium targets must be met no later than the beginning of 
school year 2014-2015, the second no later than the beginning of 
school year 2017-2018, and the final no later than the beginning of 
school year 2022-2023. However, prior to the implementation of the 
second and final sodium targets, USDA will evaluate relevant studies 
on sodium intake and human health, as required by the Consolidated and 
Further Continuing Appropriations Act, 2012, Pub. L. No. 112-55, div. 
A, tit. VII, § 743, 125 Stat. 552, 589 (2011). 

[18] In the preamble to the final rule, USDA noted that over 70 
percent of SFAs were already using the Food-Based Menu Planning 
approach to plan their lunch menus. 

[19] For more information on the previous and current federal 
requirements for school lunches, see appendix II. 

[20] National School Lunch Program and School Breakfast Program: 
Nutrition Standards for All Foods Sold in School as Required by the 
Healthy, Hunger-Free Kids Act of 2010, 78 Fed. Reg. 39,068 (June 28, 
2013) (codified at 7 C.F.R. pts. 210 and 220). 

[21] See USDA, Food and Nutrition Service, Office of Research, 
Nutrition and Analysis, School Lunch and Breakfast Cost Study-II, 
Final Report (Alexandria, VA: 2008). 

[22] The Act requires that SFAs set paid lunch prices that are no less 
than the difference between the total federal reimbursement for a free 
lunch and the total federal reimbursement for a paid lunch. Pub. L. 
No. 111-296, § 205, 124 Stat. 3183, 3218 (codified at 42 U.S.C. § 
1760(p)). 

[23] For SFAs that choose to increase the price charged for paid 
lunches, the Act limits the annual average required price increase to 
not more than 10 cents. However, SFAs have discretion to increase the 
average price by more than 10 cents. Id., § 205, 124 Stat. 3183, 3219 
(codified at 42 U.S.C. § 1760(p)(2)(B)(iii)). 

[24] Id. at § 206, 124 Stat. 3183, 3220 (codified at § 1760(q)). 

[25] Previously, the National School Lunch Act required states to 
review the National School Lunch Program, which was accomplished 
through the regular administrative review process. The Healthy, Hunger-
Free Kids Act of 2010 expanded oversight requirements to require that 
oversight of the National School Lunch Program and School Breakfast 
Program, including nutritional requirements for both programs, be 
conducted through one unified review process. Id., at § 207(1), 124 
Stat. 3183, 3220 (codified at 42 U.S.C. § 1769c(a)(1)). 

[26] Under USDA regulations, in certain circumstances, a state must 
take fiscal action against an SFA that it finds to be out of 
compliance with program requirements. For example, an SFA found to 
have served meals not in compliance with requirements is potentially 
subject to fiscal action, such as the recovery of federal 
reimbursements for those meals. 7 C.F.R. § 210.19(c). 

[27] According to USDA officials, 47 states, Puerto Rico, and the 
Virgin Islands are using the new administrative review process in 
school year 2013-2014. 

[28] Certification of Compliance with Meal Requirements for the 
National School Lunch Program Under the Healthy, Hunger-Free Kids Act 
of 2010, 77 Fed. Reg. 25,024 (April 27, 2012) (codified at 7 C.F.R. 
pt. 210). 

[29] During school year 2012-2013, states had the discretion to 
conduct administrative reviews. Further, states were required to 
conduct Additional Administrative Reviews, which are reviews of those 
SFAs determined to be at risk for improper payments, and planned 
follow-up administrative reviews that had already been scheduled. In 
school year 2013-2014, states are required to review SFAs whose 
reviews were postponed in school year 2012-2013 or omitted during the 
previous 5-year cycle. 

[30] These errors included counting meals as eligible for federal 
reimbursement that did not contain the required components or were 
served to ineligible people such as teachers or visitors. They also 
included failing to count meals for federal reimbursement that met 
nutrition requirements and were provided to eligible students. USDA, 
FNS, Office of Research, Nutrition and Analysis, "NSLP/SBP Access, 
Participation, Eligibility, and Certification Study - Erroneous 
Payments in the NSLP and SBP, Vol. I: Study Findings" (Alexandria, VA: 
2007). USDA has contracted for a second study that will review school 
meals programs for school year 2012-2013. 

[31] Each month, states report to USDA the number of lunches served in 
the program and USDA adjusts the data to determine the number of 
students participating. According to the data, student participation 
declined by 84,000 students (0.3 percent) in school year 2011-2012 and 
by an additional 1,086,000 students (3.4 percent) in school year 2012-
2013. See appendix I for more information on USDA's participation data. 

[32] Since peaking in school year 2006-2007 with 12.6 million 
students, participation among students paying full price for meals has 
declined by nearly 5 percent on average each year, with a decline of 
10 percent in school year 2012-2013. Prior to the decline, the number 
of students paying full price had remained relatively steady. 

[33] After increasing for over a decade at an average rate of 3.5 
percent per year, participation among students receiving free meals 
increased less than 1 percent in school year 2012-2013. 

[34] U.S. Bureau of the Census, Current Population Survey, Annual 
Social and Economic Supplements, Table 3. Poverty Status of People, by 
Age, Race and Hispanic Origin: 1959-2012. 

[35] As we have previously reported, there have been various efforts 
designed to ease administrative burden when certifying children for 
multiple assistance programs with similar eligibility criteria. For 
example, since school year 2008-2009, all school districts have been 
required to certify as eligible for free meals students in households 
that receive benefits through the Supplemental Nutrition Assistance 
Program (SNAP), previously known as the Food Stamp Program. 42 U.S.C. 
§ 1758(b)(4). Additionally, we have previously noted that changes to 
state policies that broaden eligibility criteria for SNAP may have 
resulted in an increase in students eligible for free school meals. 
For more information, see GAO, Supplemental Nutrition Assistance 
Program: Improved Oversight of State Eligibility Expansions Needed, 
[hyperlink, http://www.gao.gov/products/GAO-12-670] (Washington, D.C.: 
July 26, 2012). USDA officials reported that other policy changes in 
selected states may have influenced student eligibility during school 
years 2011-2012 and 2012-2013, including a demonstration project to 
directly certify students based on Medicaid program information and 
use of the community eligibility option. 

[36] In our state survey, 48 states identified student acceptance as a 
challenge and 33 states noted challenges with palatability--food that 
tasted good to students--for at least some of their SFAs in school 
year 2012-2013. 

[37] For more information on student acceptance of lunches served that 
complied with the new requirements in the eight SFAs we visited, see 
[hyperlink, http://www.gao.gov/products/GAO-13-708T]. 

[38] In recognition of the role that competitive foods play in schools 
and consistent with the Healthy, Hunger-Free Kids Act of 2010's goal 
of improving the diets of all schoolchildren, USDA has required that 
all foods sold or offered on the school campus comply with new 
nutritional standards beginning in school year 2014-2015. 

[39] In the preamble to the interim rule on paid lunch equity 
requirements, USDA estimated that most schools affected by the 
requirements in school year 2011-2012 would need to increase paid 
lunch prices by only 5 cents in order to comply. National School Lunch 
Program: School Food Service Account Revenue Amendments Related to the 
Healthy, Hunger-Free Kids Act of 2010, 76 Fed. Reg. 35,301, 35,306 
(June 17, 2011). USDA's research suggests that a 5 cent increase in 
paid lunch prices results in a 0.55 percent decrease in the student 
participation rate. See USDA, School Nutrition Dietary Assessment 
Study-III (Alexandria, VA: November 2007). 

[40] Previous research has noted that National School Lunch Program 
participation may be inhibited in schools where few students who pay 
full price for their lunches participate in the program, as 
participation itself may be a visible marker of income status. 

[41] Prior to the change, the district had an open campus policy for 
its high schools, which allowed students to leave high school campuses 
during their lunch period. Generally, districts may choose to have an 
open campus policy for various reasons, such as limited food service 
areas on campus or, when the policy is conditional, to incentivize 
positive student behavior or academic performance. With a closed 
campus policy, students are required to stay on the school campus 
during the lunch period, which increases the likelihood that they will 
participate in the school lunch program. 

[42] This represents 1.7 percent of the SFAs that participated in the 
National School Lunch Program in school year 2011-2012 nationwide. The 
percentage of states' SFAs that participated in the program in school 
year 2011-2012 that chose not to participate in the program in school 
year 2012-2013 varied by state. In 40 of the 42 states with such SFAs, 
this percentage ranged from 0.2 percent to 4.7 percent. In the 
remaining 2 states, 5.4 percent and 11.5 percent of SFAs that 
participated in the program in school year 2011-2012 chose not to 
participate in school year 2012-2013. While SFAs provide lunch in one 
or more schools, we did not collect data on the number of schools 
overseen by SFAs who chose not to participate in the program in school 
year 2012-2013. 

[43] In its report recommending the new school lunch requirements, the 
Institute of Medicine recognized the potential difficulty obtaining 
student acceptance of the changes and noted that various actions, 
including effective educational, marketing, and food preparation 
strategies, may help improve acceptance over time. 

[44] In our state survey, 36 states reported that they expect student 
acceptance to be a challenge in school year 2013-2014 (down from 48 in 
school year 2012-2013) and 26 reported that they expect challenges 
with palatability in school year 2013-2014 (down from 33 in school 
year 2012-2013). 

[45] For more information on challenges complying with the new 
requirements reported by the eight SFAs we visited, see [hyperlink, 
http://www.gao.gov/products/GAO-13-708T]. 

[46] One of the districts we visited has been working with a 
university researcher on a plate waste study, but a final report has 
yet to be issued. 

[47] USDA considers the offer versus serve policy, which allows 
students to decline two of the five meal components offered with the 
lunch, to be a way to minimize plate waste. However, under the current 
regulations for offer versus serve, students must select at least one 
half cup of fruits or vegetables with their lunches. 

[48] Institute of Medicine, School Meals: Building Blocks for Healthy 
Children (Washington, D.C.: The National Academies Press, 2010). 

[49] In the two other SFAs we visited, officials attributed their 
resource management efforts as enabling them to end school year 2012-
2013 with the same or a greater fund balance than they had at the end 
of school year 2011-2012, despite their fruit and vegetable costs 
having increased. 

[50] USDA's regulations specify the minimum and maximum weekly number 
of ounces of meats, cheese, or other meat alternates and the minimum 
and maximum weekly number of ounces of grains to be served with lunch, 
which differ by grade level. The regulations also specify the minimum 
number of ounces of meats and grains that must be served each day but 
do not specify the maximum number of ounces of meat and grains allowed 
to be served each day. 

[51] While the grades K-5 and 6-8 average daily calorie ranges for 
school lunches overlap at 550-650 and 600-700, the grades 6-8 and 9-12 
ranges, which are 600-700 and 750-850, do not. The Institute of 
Medicine report that recommended these ranges used data-based methods 
to provide a basis for the calculation of appropriate values for mean 
total daily calorie requirements for students in the three grade 
groups. Specifically, the report indicates that calorie range 
recommendations are based on reference growth chart data for healthy 
weights and heights, objective data on physical activity, and data on 
how calories are distributed among meals and snacks consumed by 
schoolchildren. 

[52] See USDA, "SP 11-2013, FNS Guidance to School Food Authorities: 
Flexibility in the Meat/Meat Alternate and Grain Maximums for School 
Year 2012-2013" (Alexandria, VA: Dec. 7, 2012) and USDA, "SP 26-2013, 
Extending Flexibility in the Meat/Meat Alternate and Grains Maximums 
for School Year 2013-2014" (Alexandria, VA: Feb. 25, 2013). 

[53] Certification of Compliance With Meal Requirements for the 
National School Lunch Program Under the Healthy, Hunger-Free Kids Act 
of 2010, 79 Fed. Reg. 325 (Jan. 3, 2014) (codified at 7 C.F.R. pt. 
210). 

[54] USDA recognized that these types of food procurement issues would 
likely occur in school year 2012-2013, and the department issued 
guidance in August 2012 that provided suggestions for the use of 
already procured foods, as well as those on order, that may not easily 
fit into the new lunch content and nutrition requirements. 

[55] Similarly, a national survey of SFAs conducted in late 2012 
estimated that 31 percent of SFAs nationwide needed additional kitchen 
equipment to comply with the new lunch requirements in school year 
2012-2013. See The Pew Charitable Trusts and the Robert Wood Johnson 
Foundation, Serving Healthy School Meals: Despite Challenges, Schools 
Meet USDA Meal Requirements (September 2013). 

[56] In our state survey, 39 states reported that they expect menu 
planning to be a challenge in school year 2013-2014 (down from 47 in 
school year 2012-2013), 35 reported that they expect the required 
portion sizes to be challenges in school year 2013-2014 (down from 46 
in school year 2012-2013), and 34 reported that they expect the 
calorie ranges to be challenges in school year 2013-2014 (down from 43 
in school year 2012-2013). 

[57] In our state survey, 40 states reported that they expect plate 
waste to be a challenge in school year 2013-2014 (down from 48 in 
school year 2012-2013) and 34 reported that they expect food 
procurement to be a challenge in school year 2013-2014 (down from 41 
in school year 2012-2013). 

[58] In our state survey, 45 states reported that they expect food 
costs to be a challenge in school year 2013-2014 (compared to 47 in 
school year 2012-2013) and 27 reported that they expect food storage 
and kitchen equipment to be a challenge in school year 2013-2014 
(compared to 26 in school year 2012-2013). 

[59] New school breakfast content and nutrition standards were 
required to be implemented by SFAs generally at the beginning of 
school year 2013-2014, while the new competitive foods standards are 
required to be implemented at the beginning of school year 2014-2015. 

[60] National School Lunch Program and School Breakfast Program: 
Nutrition Standards for All Foods Sold in School as Required by the 
Healthy, Hunger-Free Kids Act of 2010, 78 Fed. Reg. 9530 (proposed 
Feb. 8, 2013). 

[61] National School Lunch Program and School Breakfast Program: 
Nutrition Standards for All Foods Sold in School as Required by the 
Healthy, Hunger Free Kids Act of 2010, 78 Fed. Reg. 39,068 (June 28, 
2013) (to be codified at 7 C.F.R. pts. 210 and 220). The competitive 
food standards included in the interim final rule are generally 
required to be implemented at the beginning of school year 2014-2015. 

[62] In the preamble to the interim final rule, USDA reported that 
approximately 800 commenters expressed support for USDA approval of 
states' decisions regarding the frequency of exempted fundraisers, 
citing that this would better ensure consistent application of 
nutrient standards across all fundraisers. In contrast, USDA reported 
that approximately 85 commenters expressed support for states making 
these decisions without USDA approval. 

[63] The National Food Service Management Institute was established by 
law in 1989 and funded at the University of Mississippi in 1991 by a 
grant administered through the USDA. The Institute's mission is to 
provide information and services that promote the continuous 
improvement of child nutrition programs. 

[64] This is a subset of the guidance that we analyzed. This estimate 
includes guidance that directly addressed the lunch content and 
nutrition standards, state review of SFA compliance with those 
standards, and related areas, such as food procurement. Because USDA 
has issued multiple manuals and tools to assist state efforts to 
review SFA compliance with the new lunch requirements, almost two-
thirds of the total guidance pages are related to this area. 

[65] States' responses to our survey suggest that the timing of USDA's 
guidance on the School Breakfast Program changes required in school 
year 2013-2014 may have also been challenging. Specifically, states 
responded to our survey in June and July 2013, which coincided with 
the beginning of school year 2013-2014. At that time, the majority of 
states reported a need for more guidance and training on the School 
Breakfast Program meal patterns and nutrition standards. 

[66] This includes memos that substantively changed or contradicted 
previous explanations of requirements, and it does not include memos 
that solely provided additional clarification of requirements. 
Further, because we analyzed guidance memos, the 40 percent does not 
include additions and changes to the tools USDA provided states to 
assist their efforts to certify SFA compliance in school year 2012-
2013. While these tools were changed multiple times during school year 
2012-2013, the updated tools were not provided to states with a 
revised guidance memo. See appendix I for more information on our 
analysis of USDA guidance. 

[67] See USDA, "SP 20-2012, Frozen Fruit Products and Nutrition 
Standards in the National School Lunch and School Breakfast Programs" 
(Alexandria, VA: Feb. 24, 2012). 

[68] See USDA, "SP 20-2012-Revised, Frozen Fruit Products and 
Nutrition Standards in the National School Lunch and School Breakfast 
Programs" (Alexandria, VA: Sept. 11, 2012) and USDA, "SP 49-2013, 
"Frozen Fruit Products in the National School Lunch and School 
Breakfast Programs in School Year 2014-2015" (Alexandria, VA: June 25, 
2013). In addition, in January 2014, USDA issued regulations that 
permanently remove the requirement for SFAs to serve frozen fruit that 
does not contain added sugar. Certification of Compliance With Meal 
Requirements for the National School Lunch Program Under the Healthy, 
Hunger-Free Kids Act of 2010, 79 Fed. Reg. 325 (Jan. 3, 2014) 
(codified at 7 C.F.R. pt. 210). 

[69] [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[70] While USDA provides states with administrative funds annually to 
assist their efforts to administer and oversee the National School 
Lunch Program, the Healthy, Hunger-Free Kids Act of 2010 provided for 
states to receive additional administrative funds in fiscal years 2012 
and 2013. These funds were intended to provide states with additional 
resources to assist SFAs efforts to improve the quality of school 
meals provided to children and come into compliance with the new 
requirements. 

[71] The Healthy, Hunger-Free Kids Act of 2010 required USDA to 
provide additional reimbursement for each lunch served in SFAs 
certified by states as in compliance with the new requirements for the 
content of school lunches beginning October 1, 2012. 

[72] This emphasis on assisting SFA efforts to comply and become 
certified appears to have been strengthened by at least one USDA 
regional office, as one state told us it was directed not to deny an 
SFA's certification without first sending the SFA's paperwork to the 
regional office for review. 

[73] While documentation of noncompliance issues was not required 
during the certification process or during most validation reviews, 
USDA's guidance directed states that found significant noncompliance 
in specified areas during a validation review to transition the review 
to a focused administrative review. These reviews include 
documentation of noncompliance issues and require corrective action 
plans. 

[74] USDA officials told us that they collected information on 
challenges SFAs faced complying with the new lunch requirements in 
school year 2012-2013 through the Special Nutrition Program Operations 
Study. One of the goals of this study is to analyze the information 
obtained from a nationally representative sample of SFAs in order to 
provide technical assistance. While this study provides self-reported 
information on SFA challenges, it does not include information on SFA 
noncompliance. 

[75] Because the certification and validation process did not require 
states to document issues of noncompliance, the extent to which 
noncompliance issues occurred in SFAs is unknown. 

[76] Three of the eight SFAs we visited had not applied to be 
certified as in compliance with the new lunch requirements at the time 
of our visits in spring 2013. Two of these SFAs operated in the 
smallest school districts we visited, and both had previously used the 
nutrient standard menu planning approach for lunches, rather than the 
food-based menu planning approach--characteristics that created 
additional challenges for implementation. The remaining five SFAs we 
visited had all been certified by their states as in compliance with 
the new lunch requirements at the time of our visits. 

[77] USDA's guidance on validation reviews and the extra federal 
reimbursement substantively changed during school year 2012-2013. In 
initial guidance provided in July 2012, states were instructed to stop 
the extra federal reimbursement to SFAs not validated to be in 
compliance with the lunch requirements unless the compliance issues 
could be fixed immediately. Later, in January 2013, USDA guidance 
indicated that states could continue to allow an SFA that could not be 
validated during the review to receive the extra federal 
reimbursement, if immediate corrective action occurred or if the SFA 
agreed to take the appropriate corrective action. The January 2013 
guidance added that the extra federal reimbursement should only be 
stopped in cases of "significant noncompliance," which were also 
described as cases "where the problem is severe or intentional." 

[78] In another state, a state official told us that reviewers found 
many compliance problems during SFA validation reviews; however, that 
state reported through our survey that all SFAs it reviewed were 
validated. 

[79] For example, in one school, we observed several students whose 
lunches were counted as eligible for federal reimbursement at the 
point of sale, but the lunches did not include a fruit or vegetable. 
Federal regulations require all lunches served to include a fruit or 
vegetable, and in order to be eligible for federal reimbursement, 
lunches need to comply with all federal requirements for the content 
of lunches. 

[80] For the purposes of fiscal action associated with administrative 
reviews, guidance indicates that only for instances of "willful and 
egregious violations" by SFAs may states need to take fiscal action, 
and only then after states contact their USDA regional offices. 

[81] According to Standards for Internal Control in the Federal 
Government, internal control monitoring should assess the quality of 
performance over time and ensure that the findings of audits and other 
reviews are promptly resolved [hyperlink, 
http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[82] In our state survey, 47 and 44 states, respectively, reported 
that they needed additional guidance or training from USDA on overall 
SFA financial management; 42 and 35 states, respectively, reported 
that they needed additional guidance or training from USDA on revenue 
from non-program foods; and 30 and 24 states, respectively, reported 
that they needed additional guidance or training from USDA on paid 
lunch equity. 

[83] The Healthy, Hunger-Free Kids Act of 2010 contained two new 
revenue requirements related to the prices SFAs set for paid lunches 
and other foods sold outside of the school meal programs. These 
provisions were developed, in part, because of a USDA study that found 
the average prices charged for paid lunches and for other foods by 
some SFAs were less than the cost of producing those foods. This led 
to a concern that some SFAs were using federal reimbursements for free 
and reduced-price meals to subsidize meals and other foods for which 
they were not intended. 

[84] USDA guidance indicates that these five areas are integral to the 
financial health of an SFA's school food service. They are: 
maintenance of the nonprofit school food service account, paid lunch 
equity, revenue from non-program foods, indirect costs, and USDA foods 
(commodities). 

[85] In addition to the spring 2013 training, USDA officials told us 
that they have also provided training on indirect costs and other SFA 
financial management areas in recent years, both through the 
department's headquarters and regional offices. In part, this was in 
response to statutory requirements, as the Healthy, Hunger-Free Kids 
Act of 2010 required USDA to provide indirect cost guidance to SFAs. 

[86] These data include lunches served in public and private schools 
and residential child care institutions in the 50 states, the District 
of Columbia, Guam, Puerto Rico, the U.S. Virgin Islands, and the U.S. 
Department of Defense's military bases. 

[87] USDA divides the data reported for average daily lunches by an 
attendance factor of 0.927 to estimate monthly lunch participation. 
USDA officials said this methodology has been in place for many years 
and the attendance factor was historically derived. We determined that 
this attendance factor is similar to average daily attendance data 
published annually by the U.S. Department of Education. 

[88] On its public website, USDA reports annual school lunch 
participation based on fiscal year rather than school year. 

[89] USDA issued several policy memos with multiple versions during 
the time period assessed. For example, USDA issued seven versions of a 
key policy memo addressing the lunch content and nutrition 
requirements during this time period. Each version of this policy memo 
made substantial additions to the version previously issued, with the 
versions increasing in length from 11 to 64 pages. 

[90] Although the National School Lunch Program is also provided in 
schools in Guam, Puerto Rico, the U.S. Virgin Islands, and the U.S. 
Department of Defense's military bases overseas, we did not survey 
child nutrition program directors overseeing the program in those 
schools. 

[91] The Common Core of Data is a program of the U.S. Department of 
Education's National Center for Education Statistics that annually 
collects fiscal and non-fiscal data about all public schools, public 
school districts, and state educational agencies in the United States. 
The data are supplied by state educational agency officials and 
include information that describes schools, school districts, 
students, and staff, as well as fiscal data. 

[92] We reported on our preliminary findings from these site visits in 
GAO, School Lunch: Modifications Needed to Some of the New Nutrition 
Standards, [hyperlink, http://www.gao.gov/products/GAO-13-708T] 
(Washington, D.C.: June 27, 2013). 

[End of section] 

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