Report to Congressional Requesters

United States Government Accountability Office

GAO

August 2005 SCHOOL MEAL 

PROGRAMS 

Competitive Foods 

Are Widely Available 

and Generate 

Substantial Revenues 

for Schools 

GAO-05-563 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-563.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact David Bellis at 

(415) 904-2272 or bellisd@gao.gov. 

Highlights of GAO-05-563, a report to

Congressional Requesters 

August 2005

SCHOOL MEAL PROGRAMS 

Competitive Foods Are Widely Available 

and Generate Substantial Revenues for 

Schools 

Nearly 9 out of 10 schools sold competitive foods to students in school year 

2003-2004, and the availability of competitive foods sold in middle schools 

and through a la carte lines has increased over the last 5 years. Schools often 

sold these foods in or near the cafeteria and during lunch, and the 

competitive foods available ranged from nutritious items such as fruit and 

milk to less nutritious items such as soda and candy. High and middle 

schools were more likely to sell competitive foods than elementary schools.

Many different people made decisions about competitive food sales, but no 

one person commonly had responsibility for all sales in a school. In a 

majority of schools, district officials made competitive food policies, while 

school food authority directors and principals made decisions about specific 

sales. Other groups, such as student clubs and booster groups, also made 

competitive food decisions through their direct involvement in sales. 

Many schools, particularly high schools and middle schools, generated 

substantial revenues through competitive food sales in 2003-2004. 

Specifically, the nearly 30 percent of high schools generating the most 

revenue from these sales raised more than $125,000 per school. Food 

services, responsible for providing federal school meals, generally spent the 

revenue they generated through a la carte sales on food service operations. 

Other school groups often used revenues for student activities. 

The six school districts visited all recently took steps to substitute healthy 

items for less nutritious competitive foods. In each district, committed 

individuals took actions to initiate and lead change while also involving 

those affected. However, districts faced several barriers to change, including 

opposition due to concerns about revenue losses. In the districts visited, the 

effects of changes on revenues were often unclear because of limited data. 

A Majority of Schools Sell Competitive Foods to Students through Vending Machines 

Source: GAO.

Recent increases in child obesity 

have sparked concerns about 

competitive foods—foods sold to 

students at school that are not part 

of federally reimbursable school 

meals. The nutritional value of 

these foods is largely unregulated, 

and students can often purchase 

these foods in addition to or 

instead of school meals. In our 

April 2004 report on competitive 

foods (GAO-04-673), we reported 

that several states had enacted 

competitive food policies that were 

more restrictive than federal 

regulations. However, these 

policies differed widely in the type 

and extent of restrictions. In 

addition, it was unclear how and to 

what extent states were monitoring 

compliance with these policies. 

GAO was also asked to provide a 

national picture of competitive 

foods in schools, as well as 

strategies that districts and schools 

themselves are taking to limit the 

availability of less nutritious 

competitive foods. This report 

provides information from two 

nationally representative surveys 

about the prevalence of 

competitive foods in schools, 

competitive foods restrictions and 

groups involved in their sale, and 

the amounts and uses of revenue 

generated from the sale of 

competitive foods. It also provides 

information about strategies 

schools have used to limit the 

availability of less nutritious 

competitive foods, based on visits 

to a total of six school districts in 

California, Connecticut, 

Mississippi, Missouri, and South 

Carolina. 
Page i GAO-05-563 School Meal Programs 

Letter 1

Results in Brief 3 

Background 5 

Almost All Schools Sold Competitive Foods in 2003-2004, and 

Middle School Availability Has Increased over the Last 5 Years 12 

Many People Made Decisions about Competitive Food Sales, but 

No One Person Commonly Had Responsibility over All Sales in a 

School 21 

Many Schools Raised a Substantial Amount of Revenue through 

Competitive Food Sales and Used It to Support Food Service 

Operations and Student Activities 26 

School Districts We Visited Substituted Healthy Competitive Foods 

for Less Nutritious Items while Overcoming Obstacles to 

Change, and the Effects on Revenue Were Unclear 34 

Concluding Observations 45 

Agency Comments 46 

Appendix I Scope and Methodology 49 

Appendix II GAO Contacts and Staff Acknowledgments 57 

Related GAO Products 58 

Tables 

Table 1: Select USDA Initiatives That Promote Child Nutrition and 

Address the Competitive Food Environment 11 

Table 2: Estimated Percentage of Schools of Different Levels with 

Each Competitive Food Venue in 2003-2004 14 

Table 3: Types of Competitive Foods Often or Always Available 

through Each Venue in Schools, by Nutrition Category 17 

Table 4: Types of Competitive Foods Often or Always Available 

through Any Venue in Schools, by School Level and 

Nutrition Category 19 

Table 5: District, School, and Community Groups Involved in the 

Process of Changing Competitive Foods, by District 

Visited 37 

Contents 
Page ii GAO-05-563 School Meal Programs 

Table 6: Sampling Error Calculations for Questions in Which the 

Error Exceeded 15 Percent 51 

Table 7: SFA Director Survey: Population and Sample by School 

Level 54 

Table 8: Principal Survey: Population and Sample by School Level 54 

Figures 

Figure 1: Categories and Sources of Competitive Foods in Schools 8 

Figure 2: States That Have Made Efforts to Restrict Competitive 

Foods in Schools beyond USDA Regulations, as of April 

2005 9 

Figure 3: Estimated Percentage of Schools Selling Competitive 

Foods through Each Type of Venue in 2003-2004 13 

Figure 4: Estimated Percentage of Schools with a Written 

Competitive Food Policy in 2003-2004 Enacted by 

Districts and Schools 22 

Figure 5: Number of Groups Directly Involved in Competitive Food 

Sales in 2003-2004, Reported as an Estimated Percentage 

of Schools with Sales 24 

Figure 6: Groups Most Frequently Involved in Various Competitive 

Food Venues Commonly Available in High Schools 25 

Figure 7: Estimated Percentage of Schools Generating Different 

Minimum Amounts of Total Competitive Food Revenue in 

2003-2004, by School Level 28 

Figure 8: Estimated Percentage of High Schools in Which Food 

Services Generated Different Amounts of Revenue 

through a la Carte Sales in 2003-2004 30 

Figure 9: Estimated Percentage of High Schools in Which Other 

School Groups Generated Different Amounts of Revenue 

through Exclusive Beverage Contracts in 2003-2004 32 

Figure 10: Estimated Percentage of Schools Using Competitive 

Food Revenue, Excluding Food Service Revenue, for 

Various Purposes in 2003-2004 33 
Page iii GAO-05-563 School Meal Programs 

Abbreviations 

CCD Common Core of Data 

CDC Centers for Disease Control and Prevention 

FMNV foods of minimal nutritional value 

FNS Food and Nutrition Service 

HHS Department of Health and Human Services 

NSLP National School Lunch Program 

SFA school food authority 

USDA U.S. Department of Agriculture 

WIC Special Supplemental Nutrition Program for Women, 

 Infants, and Children 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately. 
Page 1 GAO-05-563 School Meal Programs 

August 8, 2005 

The Honorable Tom Harkin 

Ranking Member 

Committee on Agriculture, Nutrition, and Forestry 

United States Senate 

The Honorable Patrick J. Leahy 

Ranking Member 

Subcommittee on Research, Nutrition, and General Legislation 

Committee on Agriculture, Nutrition, and Forestry 

United States Senate 

The Honorable George Miller 

Ranking Member 

Committee on Education and the Workforce 

House of Representatives 

The Honorable Lynn Woolsey 

Ranking Member 

Subcommittee on Education Reform 

Committee on Education and the Workforce 

House of Representatives 

Increasing child obesity rates have recently focused attention on children’s 

health and nutrition and have raised concerns about foods available in 

schools that compete nutritionally and financially with federally regulated 

school meal programs. The number of children who are overweight has 

more than doubled, and the number of adolescents who are overweight 

has more than tripled since 1980, according to the U.S. Centers for Disease 

Control and Prevention (CDC). These changes are related, in part, to poor 

nutrition. According to U.S. Department of Agriculture (USDA) data, more 

than 60 percent of young people eat too much fat and less than 20 percent 

of the recommended daily servings of fruits and vegetables. In addition to 

having negative health outcomes, children with poor nutrition may have a 

harder time concentrating and succeeding in school than other children. 

The Surgeon General’s 2001 call to action identified schools as one of the 

key settings for public health strategies to address child nutrition. Since 

children spend a large portion of their day in school, providing them with 

healthful food options throughout the school day can be an important step 

toward good child nutrition. 

United States Government Accountability Office

Washington, DC 20548 
Page 2 GAO-05-563 School Meal Programs 

The key school meal programs, the National School Lunch Program and 

the School Breakfast Program, provide millions of children with nutritious 

meals each school day. USDA’s Food and Nutrition Service administers 

these programs through local school food authorities (SFA) and subsidizes 

the meals served in local schools as long as meals meet certain nutritional 

guidelines. However, other foods not provided through these programs, 

typically referred to as competitive foods, are often available to children at 

school. Competitive food sales can take place at a variety of venues in 

schools, including vending machines, school stores, and a la carte lines in 

the cafeteria, through which the SFA sells individually priced food and 

beverage items. Federal restrictions concerned with the nutritional value 

of competitive foods are limited. Specifically, federal regulations require 

that one segment of competitive foods, defined as foods of minimal 

nutritional value, not be sold to students during the breakfast and lunch 

periods in food service areas. 

In recent years, federal, state, and local governments have increasingly 

focused on the role that competitive foods play in children’s diets. In our 

April 2004 report on competitive foods,1

 we reported that increasing 

numbers of state legislatures have enacted and proposed legislation to 

restrict the availability of competitive foods in schools. In addition, school 

districts and schools themselves are taking steps to limit the availability of 

competitive foods. 

Because of your interest in further understanding issues related to 

competitive foods in schools, you asked us to answer the following 

questions: (1) How prevalent is the sale of competitive foods in schools 

across the country, and has this prevalence changed over time? (2) Who 

makes decisions about competitive food sales in schools? (3) What 

amount of revenue is generated from the sale of competitive foods, and for 

what purposes is the revenue used? (4) What strategies have schools used 

to limit the availability of less nutritious competitive foods, what obstacles 

did they face, and how have these strategies affected sales revenue? 

To answer your first three questions, we obtained information through two 

Web surveys, one of school principals and the other of district-level SFA 

directors. To conduct our surveys, we selected a stratified random sample 

 1

 See GAO, School Meal Programs: Competitive Foods Are Available in Many Schools; 

Actions Taken to Restrict Them Differ by State and Locality, GAO-04-673 (Washington, 

D.C.: April 23, 2004). 
Page 3 GAO-05-563 School Meal Programs 

from the 80,000 public schools nationwide that participate in the National 

School Lunch Program, which allowed us to provide national estimates 

based on school level. The surveys were administered between October 

19, 2004, and February 11, 2005, with 65 percent of principals and 70 

percent of SFA directors responding.2

 The surveys asked respondents 

about conditions in their schools during specific school years, primarily 

2003-2004, and therefore, all years cited refer to school years. In addition, 

all estimates presented from the surveys have margins of error of plus or 

minus 15 percent or less, unless otherwise noted. To answer the fourth 

question, we conducted site visits to 6 school districts in California 

(Oakland), Connecticut (New Haven), Mississippi (McComb), Missouri 

(Independence and Fort Osage), and South Carolina (Richland One), 

including visits to a total of 10 schools. Our site visit localities were 

selected from a group of approximately 100 districts and schools 

recognized as making efforts to limit access to less nutritious competitive 

foods. The 6 districts visited were also selected because it appeared that 

they used different strategies to restrict competitive foods, and when 

viewed as a group, they provided variation across characteristics such as 

geographic location, district size, and socioeconomic status. See appendix 

I for detailed information on our surveys, sampling strategy, and site visits. 

We conducted our work from May 2004 through July 2005 in accordance 

with generally accepted government auditing standards. 

Almost all schools sold competitive foods to students in school year 2003-

2004, and over the last 5 years, the availability of competitive foods has 

increased both in middle schools and in a la carte lines in many schools. 

We estimate that nearly 9 out of 10 schools offered competitive foods 

through one or more of the following venues in 2003-2004: a la carte 

cafeteria lines, vending machines, and school stores. While competitive 

foods were commonly sold in schools of all levels, high schools and 

middle schools were more likely to sell these foods than elementary 

schools. For example, vending machines were available to students in 

almost all high schools and middle schools but in less than half of 

elementary schools. Schools often sold competitive foods in or near the 

cafeteria and during lunchtime, allowing students to purchase these foods 

 2

 These percentages reflect those principals and SFA directors who actually received the 

Web surveys. We were unable to contact a subset of principals and SFA directors selected 

in our sample of 656 schools. See appendix I for detailed information on response rates for 

each survey. 

Results in Brief 
Page 4 GAO-05-563 School Meal Programs 

as their lunch or to supplement their lunch. The competitive foods 

available ranged from nutritious items such as fruit and milk to less 

nutritious items such as soda and candy, with nutritious foods more 

frequently available through a la carte lines than through vending 

machines or school stores. Between 1998-1999 and 2003-2004, the 

availability of competitive foods increased in middle schools, and the 

volume and variety of a la carte foods sold increased in many schools. 

Many people, including district and school officials as well as members of 

groups involved in sales at schools, made decisions about competitive 

foods, but no one person commonly had responsibility for all competitive 

food sales at the school level. The decisions ranged from broad policies 

about the school nutrition environment to decisions about which foods to 

sell at a specific venue or event. According to school principals, an 

estimated 60 percent of schools had written policies in place in school 

year 2003-2004 that restricted competitive food sales to students, and in a 

majority of those schools the policies were set at the district level, often by 

superintendents and school boards. Regarding competitive food sales in 

schools, district SFA directors were commonly involved in policy 

decisions related to a la carte sales, while school principals often had final 

approval over other competitive food sales, such as items sold through 

vending machines. In addition to SFA directors and school principals, 

many other groups such as teachers, student clubs, parent-teacher 

associations, and booster groups were involved in selling competitive 

foods in schools. These groups therefore often made decisions concerning 

the types of food to sell to students and when to make such food available. 

The number and variety of groups involved in these sales typically 

increased as the school level increased. 

Many schools raised a substantial amount of revenue through competitive 

food sales in school year 2003-2004 and used this revenue to support food 

service operations and student activities. High schools and middle schools 

generally raised more revenue from competitive food sales than 

elementary schools, reflecting the greater availability of competitive foods 

in high and middle schools. According to our survey, the nearly 30 percent 

of high schools generating the most revenue from competitive food sales 

raised more than $125,000 per school in 2003-2004. Across all competitive 

food sales, food services generated more revenue than other school 

groups, largely through a la carte sales, and they generally used this 

revenue to support overall food service operations. Other school groups 

commonly used their revenues to support student activities, and the most 

frequent uses were student field trips, school assemblies and programs, 

and athletic equipment and facilities. 
Page 5 GAO-05-563 School Meal Programs 

The six school districts we visited all recently took steps to substitute 

healthy competitive foods for less nutritious fare while overcoming 

obstacles to these changes, and the effects of these changes on sales 

revenues were often unclear because of limited data. Specifically, many of 

the schools we visited increased the availability of healthy items, including 

low-fat and low-sugar foods and beverages, while they decreased the 

availability of less nutritious foods, such as deep-fried French fries, candy, 

and soda. Further, although different districts used different approaches 

and achieved different outcomes, district and school officials identified 

several factors that consistently facilitated change and several that 

hindered it. For example, in all of the districts we visited, motivated 

individuals took action to initiate and lead the process of change while 

obtaining support from those affected in the district, schools, and 

community. However, districts noted that they also faced many barriers to 

implementing changes, such as opposition due to concerns about potential 

revenue losses. Regarding the effect of changes on sales revenues, none of 

the districts we visited had clear and reliable data concerning the impact 

of competitive food changes on sales revenues. From the limited data that 

were available, it appeared that changes had varied effects on revenues 

across districts. Related to this, while a few districts anticipated and 

planned for the effects of changes on sales revenues, most had not. 

Consequently, many officials expressed strong concerns about potential 

revenue losses because competitive food revenues have provided them 

with a valued source of funding. 

Competitive foods in schools are those foods sold to students during the 

school day that are not part of the federal meal programs. These federal 

programs, the National School Lunch Program (NSLP) and the School 

Breakfast Program, subsidize public school meals and regulate their 

nutritional content. Competitive foods, however, are only minimally 

regulated at the federal level. They are typically sold a la carte in the 

cafeteria, and through vending machines and school stores. 

The two largest federal school meal programs, the NSLP and the School 

Breakfast Program, aim to address problems of hunger, food insecurity, 

and poor nutrition by providing nutritious meals to children in schools. 

The NSLP, established in 1946, provides nutritionally balanced low-cost or 

free lunches in participating schools to more than 28 million children each 

school day, as well as reimbursement for snacks served to those through 

age 18 in after-school educational and enrichment programs. Similarly, the 

School Breakfast Program, permanently established in 1975, provides free 

Background 

NSLP and School 

Breakfast Program 
Page 6 GAO-05-563 School Meal Programs 

or reduced price breakfasts to more than 8 million schoolchildren daily.3

At the federal level, these programs are administered by USDA’s Food and 

Nutrition Service (FNS). As part of its strategic goal to improve the 

nation’s nutrition and health, the department has laid out plans to increase 

access to, and utilization of, these school meal programs. 

In fiscal year 2004, the federal government spent over $8 billion on the 

NSLP and the School Breakfast Program. FNS provides reimbursement in 

the form of cash subsidies and donated commodities based on the number 

of lunches and breakfasts served that meet certain federal requirements. 

The meals must adhere to the Dietary Guidelines for Americans, which 

include limits on total fat and saturated fat and call for diets moderate in 

sodium.4

 The meals must also meet standards for the recommended daily 

allowances of calories, as well as nutrients such as protein, calcium, iron, 

and vitamins A and C. Compliance with the standards is determined by 

averaging the nutritional content of the meals offered over a school week. 

USDA reimburses states, usually through the state departments of 

education, which in turn reimburse local SFAs that operate the programs 

in one or more schools. 

SFAs function as the governing entities responsible for the local 

administration of the federal meals programs. They are often, but not 

always, responsible for school meals in an entire school district. SFAs 

have some flexibility in operating their school meal programs. For 

example, they may operate the programs themselves or contract with food 

service management companies to perform functions such as planning and 

preparing menus and selecting and buying food. All or some food 

preparation may occur at on-site school kitchens or at central kitchens, 

which then distribute food to satellite schools. In addition, SFAs may 

select among different menu-planning approaches to comply with the 

federal nutritional requirements. 

SFAs receive a significant portion of their funding from federal 

reimbursements that are based on the number of meals served to students 

 3

 These data are based on the fiscal year 2004 average daily participation in the NSLP and 

the School Breakfast Program, according to the FNS Program Information Report for 

December 2004 from USDA. 

4

 These requirements for the federal meal programs were established by Congress in 1994 

through the passage of the Healthy Meals for Healthy Americans Act, Pub. L. No. 103-448, 

§ 106 (1994).
Page 7 GAO-05-563 School Meal Programs 

in their schools. In addition, SFAs also receive some funding from states 

for program operations, and they may generate revenues by selling 

competitive foods or by offering fee-based catering services. Further, SFAs 

are permitted to combine costs and revenues for reimbursable meals and 

nonreimbursable offerings, such as competitive foods, as long as they 

maintain their nonprofit status. Therefore, if revenues from reimbursable 

meals are less than the costs of producing these meals, SFAs may use 

competitive food revenues to support the cost of reimbursable meals. 

Likewise, if revenues from reimbursable meals are more than the costs of 

producing these meals, SFAs may use these funds to support competitive 

food sales. 

Competitive foods are those foods sold in schools, during the school day, 

that are not part of the federal school meal programs—that is, they 

compete with the nutritionally regulated school meal programs. These 

foods can range from candy and soda to pizza and popcorn to apples and 

milk and are typically available in cafeteria a la carte lines, vending 

machines, and school stores. 

Unlike federally subsidized school meals, the sale and nutritional content 

of competitive foods are largely unregulated by the federal government. 

Federal regulations prohibit the sale of certain competitive foods, known 

as foods of minimal nutritional value (FMNV),5

 during meal periods in 

school cafeterias and other food service areas. FMNV, as defined by 

USDA, include soda, chewing gum, and hard candy, for example (see fig. 

1). Other than this restriction, federal regulations do not prohibit or limit 

the sale of any other competitive foods anywhere on school grounds at 

any time.6

 In contrast, from 1980 to 1983, federal regulations prohibited the 

sale of FMNV anywhere in the school from the beginning of the school day 

until the last meal period. In National Soft Drink Ass’n v. Block, 721 F. 2d 

1348 (D.C. Cir. 1983), the Court of Appeals for the District of Columbia 

overturned this regulation and construed a 1977 amendment to the Child 

Nutrition Act as allowing USDA to regulate the sale of competitive foods 

only in food service areas during meal periods. Following this decision, 

 5

 FMNV are defined in regulations for the NSLP (7 C.F.R. § 210.11) and listed in appendix B 

of those regulations. USDA has the authority to change the definition of FMNV and also has 

established procedures to amend the list of these foods. 

6

 According to regulations, all income from the sale of competitive foods in the food service 

area must accrue to the nonprofit food service provider, the school, or an organization 

approved by the school. 

Minimal Federal 

Restriction of Competitive 

Foods 
Page 8 GAO-05-563 School Meal Programs 

USDA amended its regulation to limit the prohibition of these foods to 

food service areas during meal periods. 

Figure 1: Categories and Sources of Competitive Foods in Schools 

According to federal regulations, states and SFAs may impose further 

restrictions on all foods sold at any time throughout their schools. As of 

April 2005, 28 states have made efforts to restrict the sale of competitive 

foods beyond USDA regulations (see fig. 2). Five state policies do not 

restrict particular food items, but instead typically address the competitive 

food environment more broadly. For example, some of these states have 

created committees to develop policies concerning competitive foods in 

schools or have encouraged schools to find ways to improve their 

competitive food environments. The remaining 23 of these state policies 

place some form of specific restrictions on competitive foods, though they 

differ in the type and extent of restrictions. 7 The majority of these policies 

restrict some, but not all, competitive foods and restrict foods only at 

 7

 See GAO-04-673 for more information on the type and extent of restrictions implemented 

by state competitive food policies in place as of March 2004. 

Source: GAO, clip art source: Art Explosion.
Page 9 GAO-05-563 School Meal Programs 

times associated with school meal periods, rather than during the entire 

school day.8

 

Figure 2: States That Have Made Efforts to Restrict Competitive Foods in Schools beyond USDA Regulations, as of April 2005 

 8

 For example, some states restrict competitive foods for one half hour before and after 

each school meal period, while others restrict competitive foods from the start of the 

school day until the end of the last lunch period. 

Source: GAO.

States that have made efforts to restrict competitive foods beyond USDA regulations.

Alaska

Hawaii

New York

Alabama

Arizona

Arkansas

California Colorado

Florida

Georgia

Idaho

Illinois Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

Vermont

New Hampshire

Massachusetts

Rhode Island

Connecticut

New Jersey

Delaware

Maryland

New Mexico

North 

Carolina

North 

Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

South 

Carolina

South

Dakota

Tennessee

Texas

Utah

Virginia

Washington

Wisconsin

Wyoming

West

Virginia
Page 10 GAO-05-563 School Meal Programs 

The federal government has an interest in improving child nutrition in 

order to promote the health and wellness of the nation’s children. 

Moreover, the current child obesity trend poses public health risks 

because of the relationship of obesity to serious illnesses, such as type 2 

diabetes and hypertension. These illnesses can result in substantial longterm costs to society. In response, USDA has recently developed initiatives 

to support school efforts to provide a healthy nutrition environment, 

including competitive food sales. Beginning in 1995, USDA introduced the 

School Meals Initiative for Healthy Children in an effort to improve the 

nutritional quality of meals served through the NSLP and the School 

Breakfast Program. That same year, in order to assist with implementation 

of the School Meals Initiative, USDA launched Team Nutrition to focus on 

schools and promote the nutritional health of the nation’s children. Team 

Nutrition provides schools with nutrition education materials for children 

and families, technical assistance materials for school food services, and 

materials to build school and community support for healthy eating and 

physical activity.9

 Since 1995, USDA has also created additional resources 

to help schools improve student nutrition, address competitive foods, and 

foster long-term health, sometimes in collaboration with other federal 

agencies (see table 1).10

 9

 For more information on federally funded nutrition education programs, including Team 

Nutrition, see GAO, Nutrition Education: USDA Provides Services through Multiple 

Programs, but Stronger Linkages among Efforts Are Needed, GAO-04-528 (Washington, 

D.C.: April 27, 2004). 

10 In addition, USDA published its School Nutrition Dietary Assessment Study II in 2001, 

providing information on the nutritional quality of meals served in public schools that 

participate in the NSLP and the School Breakfast Program. This study found that students 

in school year 1998-1999 had access to a variety of breakfast and lunch options other than 

the federal meal programs. 

Recent Federal Initiatives 

to Promote Better 

Nutrition in Schools 
Page 11 GAO-05-563 School Meal Programs 

Table 1: Select USDA Initiatives That Promote Child Nutrition and Address the Competitive Food Environment 

Initiative Description 

Changing the Scene–Improving the School Nutrition 

Environment (2000) 

Toolkit that focuses on improving the school nutrition environment and 

serves as a guide to local action, developed with input from 16 education, 

nutrition, and health organizations 

Fruits and Vegetables Galore (2004) Toolkit for school food service professionals that contains tips on promoting 

fruits and vegetables to children 

HealthierUS School Challenge (2004) Effort to recognize schools that have met higher standards for nutrition and 

physical activity than those required by the federal government, and to 

encourage other schools to achieve such results 

Making it Happen! School Nutrition Success Stories 

(2005) 

Report that shares stories from 32 schools and school districts that have 

made innovative changes to improve the nutritional quality of all foods and 

beverages sold on school campuses, including competitive foods, developed 

in collaboration with CDC and supported by the Department of Education 

Source: GAO. 

The Department of Health and Human Services (HHS) has also focused on 

the school nutrition environment through various initiatives by CDC. 

These include 

• an eight-component coordinated health model for schools that includes 

school nutrition services as one component, and 

• a School Health Index designed to help schools assess their 

environments and improve the effectiveness of their health and safety 

policies and programs.11

In addition to these efforts to support a healthy school nutrition 

environment, the National Academy of Sciences’ Institute of Medicine 

recently released a broad-based report on preventing childhood obesity. 

Among other things, the institute recommended that the current federal 

funding structure of school meals and the policies and practices of selling 

competitive foods in schools be examined for improvements that would 

encourage students to consume nutritious foods and beverages, and that 

nutritional standards be developed and implemented for all competitive 

foods sold or served in schools. 

 11 CDC also reported in its 2000 School Health Policies and Programs Study that 

competitive foods were widely available in schools. 
Page 12 GAO-05-563 School Meal Programs 

The Child Nutrition and WIC Reauthorization Act of 2004 requires school 

districts that participate in the federal meal programs to establish local 

wellness policies by the first day of the 2006-2007 school year. 12 Congress 

added this requirement, in part, in order to promote nutrition and address 

child obesity by encouraging localities to provide healthy school 

environments. These policies must include nutrition guidelines for all 

foods available on each school campus during the school day and goals for 

nutrition education and physical activity, as well as establish a plan for 

measuring implementation of the local wellness policy. Further, the local 

wellness policies must be developed in collaboration with the 

community—including a combination of school officials, parents, 

students, and the public. The act also requires that USDA, HHS—through 

CDC—and the Department of Education provide technical assistance to 

districts regarding wellness policies. In addition, in order to assist schools 

in setting appropriate nutrition standards for foods available in schools, 

Congress—through the Conference Report of the Consolidated 

Appropriations Act of 2005—provided $1 million to the Institute of 

Medicine. With these funds, the institute will conduct a study and provide 

recommendations regarding appropriate nutritional standards for the 

availability, sale, content, and consumption of all foods at school, with a 

particular emphasis on competitive foods. 

Nearly 9 out of 10 schools sold competitive foods to students in 2003-2004, 

and over the last 5 years, the availability of competitive foods has 

increased both in middle schools and in a la carte lines in many schools. 

While competitive foods were commonly available in all school levels, 

students in high schools and middle schools had greater access to these 

foods than students in elementary schools. The competitive foods 

available ranged from nutritious items such as fruit and milk to less 

nutritious items such as soda and candy. Between 1998-1999 and 2003-

2004, the availability of competitive foods increased in middle schools, and 

the volume and variety of a la carte foods sold increased in many schools. 

 12 WIC is the acronym commonly used to refer to the Special Supplemental Nutrition 

Program for Women, Infants, and Children. 

On the Horizon: School 

Wellness Policies and 

Research on Nutritional 

Standards 

Almost All Schools 

Sold Competitive 

Foods in 2003-2004, 

and Middle School 

Availability Has 

Increased over the 

Last 5 Years 
Page 13 GAO-05-563 School Meal Programs 

We estimate that almost 90 percent of schools sold competitive foods to 

students in 2003-2004 through one or more of the following venues: a la 

carte lines, vending machines, and school stores.13 Considering each type 

of venue individually, a majority of schools sold foods through a la carte 

lines and vending machines, as shown in figure 3. 

Figure 3: Estimated Percentage of Schools Selling Competitive Foods through Each 

Type of Venue in 2003-2004 

High schools and middle schools were more likely to sell competitive 

foods than elementary schools. Table 2 shows the percentage of 

elementary, middle, and high schools selling competitive foods through 

each type of venue and through one or more venues. 

 13 We asked survey respondents questions about “school stores and/or snack bars.” 

Throughout this report, we will use the term “school stores” to refer to both school stores 

and snack bars. 

Competitive Foods Were 

Available in Almost All 

Schools and Were More 

Common in High Schools 

and Middle Schools 

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools 

Source: GAO.

75

63

25

A la carte

Vending

machines

School

stores
Page 14 GAO-05-563 School Meal Programs 

Table 2: Estimated Percentage of Schools of Different Levels with Each Competitive 

Food Venue in 2003-2004 

Elementary 

schools 

Middle 

schools

High 

schools

A la carte 67 88 91

Vending machines 46 87 91

School stores 15 25 54

One or more of the above venues 83 97 99

Source: GAO. 

In addition to the competitive food venues regularly available in schools, 

students in some schools also were able to purchase competitive foods 

through on-campus fund-raisers. For example, more than 4 out of 10 

schools allowed fund-raising—such as seasonal candy sales or short-term 

sales of baked goods raising revenues for school organizations—through 

the sale of foods to students during the school day in 2003-2004. Such 

fund-raisers were permitted in two-thirds of high schools and less than 40 

percent of middle and elementary schools. 

While federal regulations restrict access to FMNV—a subset of 

competitive foods—in food service areas during meal periods, many types 

of competitive foods are allowed to be sold in these locations at meal 

times. According to our survey, competitive foods sold in 2003-2004 

through a la carte lines, vending machines, and school stores were 

frequently available for purchase in or near school cafeterias and during 

lunch.14

• A la carte items were available to students in the cafeterias of schools 

that offered them and were available to students during lunch in 94 

percent of those schools. 

• One-half of schools with vending machines had machines in or near the 

cafeteria, and one-third of schools with vending machines had 

machines that were available to students during lunch. 

 14 A la carte foods, vending machines, and school stores were also available in some 

schools during other periods of the school day. In addition, vending machines and school 

stores were available in other locations in some schools, such as outside school buildings. 
Page 15 GAO-05-563 School Meal Programs 

• Nearly half of schools with stores had such stores in or near the 

cafeteria, and about one-third of schools with stores sold competitive 

foods through these stores during lunch. 

Although schools that sold competitive foods through a la carte lines or 

school stores often sold these foods in just one physical location, schools 

with vending machines typically had multiple machines available 

throughout the school, ranging from 1 to 25 machines. For example, the 

quarter of high schools with the most vending machines had 10 or more 

machines, the top quarter of middle schools had 7 or more machines, and 

the top quarter of elementary schools had 3 or more machines.15 Schools 

generally had more beverage vending machines than snack vending 

machines. 

Further, in many schools, particularly high schools, beverages sold in 

vending machines or elsewhere in the school were provided through an 

exclusive beverage contract—a contract granting a company exclusive 

rights to sell beverages to students in that school. In addition to covering 

vending machine sales, these contracts may require schools to provide 

beverages through the contracted company in other venues, such as 

school stores or athletic event concessions. Nearly half of all schools in 

2003-2004 had an exclusive beverage contract. In over a third of schools 

with exclusive beverage contracts, the contracts covered 5 years or more, 

with some covering at least 10 years.16 Nearly 75 percent of high schools, 

65 percent of middle schools, and 30 percent of elementary schools had 

exclusive beverage contracts. 

Competitive foods available through a la carte lines, vending machines, 

and school stores ranged from nutritious items, such as vegetables and 

salad, to less nutritious items, such as soda and candy. Nutritious foods 

were more frequently available through a la carte lines than through 

vending machines and school stores. For example, as shown in table 3, we 

estimate that many of the types of foods commonly available through a la 

carte sales were nutritious foods and beverages, such as fruit and milk. 

 15 The elementary school estimate has a margin of error that exceeds plus or minus 15 

percent. See table 6 in appendix I for more information. 

16 While contracts could be negotiated by the school district, the school, the school food 

service, or a combination of those groups, over half of schools with exclusive beverage 

contracts had a contract that was negotiated with the school district. 

Types of Competitive 

Foods Ranged from 

Nutritious to Less 

Nutritious, with High and 

Middle Schools Selling a 

Wider Variety of Items 
Page 16 GAO-05-563 School Meal Programs 

However, types of less nutritious items, such as sweet baked goods and 

salty snacks not low in fat, were also available through a la carte lines in at 

least one-third of schools. Furthermore, many of the types of foods 

commonly available through vending machines and school stores were 

less nutritious ones, such as soda and salty snacks.17

 17 While the federal government prohibits the sale of soda and certain candy in cafeterias 

and food service areas during mealtimes, these foods can be sold in other locations and 

during other periods of the school day. Other less nutritious items, such as sweet baked 

goods and salty snacks, can be sold in any school location during any period of the day. 
Page 17 GAO-05-563 School Meal Programs 

Table 3: Types of Competitive Foods Often or Always Available through Each 

Venue in Schools, by Nutrition Category 

Note: The nutrition categories, as signified by the shading, are general descriptions of the foods in 

each category. GAO created these nutrition categories to generally reflect the Dietary Guidelines for 

Americans, recognizing that they apply to many but not all foods of each type—nutritional content can 

vary depending on the ingredients and the methods used to prepare foods. Four of the estimates in 

this figure have margins of error that exceed plus or minus 15 percent. See table 6 in appendix I for 

more information. 

Water

Milk, 1% or skim

Milk, whole or 2%

100% juice

Fruit

Vegetables and/or salad

Yogurt

Less than 100% juice

Sports drinks

Low-fat salty snacks

Low-fat sweet baked goods

Low-fat frozen desserts

Sandwiches

Pizza

Fried vegetables

Frozen desserts (not low-fat)

Salty snacks (not low-fat)

Sweet baked goods (not low-fat)

Candy

Soda

A la carte School stores Vending machines

 Item is estimated to be available in approximately half or more schools with the venue

Item is estimated to be available in approximately one-third or more schools with the venue

Source: GAO.

Nutritious

Neither clearly nutritious nor less nutritious

Less nutritious
Page 18 GAO-05-563 School Meal Programs 

In addition, our data suggest that students may have had increased access 

to more types of competitive foods as they progressed from elementary 

school to middle school and high school. While nutritious foods were 

commonly available in schools of each level, students in high schools and 

middle schools had access to a greater variety of types of less nutritious 

foods than students in elementary schools. For example, salty snacks, 

sweet baked goods, soda, and candy were available in at least one-third of 

high schools and middle schools with competitive foods but in less than 

one-third of such elementary schools, as shown in table 4.18

 18 However, less nutritious foods were available in some elementary schools. For example, 

frozen desserts not low in fat were available in nearly a quarter of elementary schools with 

competitive foods. 
Page 19 GAO-05-563 School Meal Programs 

Table 4: Types of Competitive Foods Often or Always Available through Any Venue 

in Schools, by School Level and Nutrition Category 

Note: The nutrition categories, as signified by the shading, are general descriptions of the foods in 

each category. GAO created these nutrition categories to generally reflect the Dietary Guidelines for 

Americans, recognizing that they apply to many but not all foods of each type—nutritional content can 

vary depending on the ingredients and the methods used to prepare foods. 

Water

Milk, 1% or skim

Milk, whole or 2%

100% juice

Fruit

Vegetables and/or salad

Yogurt

Less than 100% juice

Sports drinks

Low-fat salty snacks

Low-fat sweet baked goods

Low-fat frozen desserts

Sandwiches

Pizza

Fried vegetables

Frozen desserts (not low-fat)

Salty snacks (not low-fat)

Sweet baked goods (not low-fat)

Candy

Soda

Item is estimated to be available in approximately half or more schools with any venue

Item is estimated to be available in approximately one-third or more schools with any venue

Source: GAO.

Nutritious

Neither clearly nutritious nor less nutritious

Less nutritious

Elementary schools Middle schools High schools
Page 20 GAO-05-563 School Meal Programs 

According to our survey, the availability of competitive food venues in 

middle schools increased during the period between 1998-1999 and 2003-

2004. 

• The percentage of middle schools offering competitive foods through a 

la carte lines, vending machines, or school stores increased from 83 to 

97 percent during this time period.19

• The percentage of middle schools with exclusive beverage contracts 

increased between 1998-1999 and 2003-2004.20

• The number of vending machines per school increased between 1998-

1999 and 2003-2004 in more than one-third of middle schools that had 

vending machines.21 In addition, the number of vending machines per 

school increased in more than half of high schools that had vending 

machines. 

In addition, the availability of a la carte items, particularly the volume sold 

and the variety available for purchase, increased between 1998-1999 and 

2003-2004 in many schools. 

• The volume of a la carte items sold—that is, the overall amount of all a 

la carte items sold—increased in more than two-thirds of high schools, 

more than half of middle schools, and nearly one-third of elementary 

schools that had a la carte sales.22

• The variety—that is, the number of different types—of a la carte items 

available to students increased in about one-half of all schools that had 

a la carte sales. 

 19 For this analysis, we compared the percentage of middle schools that had any 

competitive food venues between school years 1998-1999 and 2003-2004 with the 

percentage that had any venues in 2003-2004. 

20 According to our survey, the percentage of middle schools with exclusive beverage 

contracts increased to 65 percent in 2003-2004 from 26 percent in 1998-1999. An additional 

31 percent of middle school principals were unsure if their school had an exclusive 

beverage contract in 1998-1999. 

21 This estimate has a margin of error that exceeds plus or minus 15 percent. See table 6 in 

appendix I for more information. 

22 The elementary school estimate has a margin of error that exceeds plus or minus 15 

percent. See table 6 in appendix I for more information. 

Over the Last 5 Years, the 

Availability of Competitive 

Foods Sold in Middle 

Schools and through a la 

Carte Lines Increased 
Page 21 GAO-05-563 School Meal Programs 

According to SFA directors, reasons for the increases in a la carte volume 

and variety between 1998-1999 and 2003-2004 included responding to 

student demand, providing more nutritious foods, making foods more 

appealing to students, and generating additional revenue for the food 

service. 

Aside from increases in the availability of competitive foods sold in middle 

school and through a la carte lines, we did not find that the availability of 

competitive foods in schools changed considerably during the period 

between 1998-1999 and 2003-2004. For example, according to our survey, 

there have not been considerable changes in the percentage of high 

schools or elementary schools offering competitive foods through a la 

carte lines, vending machines, or school stores during this time period. 

Further, in a majority of all schools with school stores or vending 

machines, the number of different types of food offered for sale through 

these venues stayed the same. 

Many people, including district and school officials as well as members of 

groups selling foods in schools, made decisions about competitive food 

sales, but no one person consistently had responsibility for all competitive 

food sales at the school level. The decisions ranged from broad policies 

about the school nutrition environment to decisions about which foods to 

sell at a specific venue or event. In 2003-2004, a majority of schools had 

policies in place that restricted competitive food sales to students, and 

these policies were often set at the district level by superintendents and 

school boards. Regarding the actual selection and sale of competitive 

foods in schools, SFA directors were commonly involved in decisions 

related to a la carte sales, while principals often had final approval over 

other competitive food sales. In addition, many different groups were 

directly involved in selling competitive foods in schools in 2003-2004, and 

these groups could make decisions about which foods to sell and when to 

make them available. The number and variety of groups involved in these 

sales typically increased as the school level increased. 

Many People Made 

Decisions about 

Competitive Food 

Sales, but No One 

Person Commonly 

Had Responsibility 

over All Sales in a 

School 
Page 22 GAO-05-563 School Meal Programs 

According to principals, an estimated 60 percent of schools had written 

policies in place that restricted competitive foods accessible to students in 

2003-2004, and most often, districts enacted those policies (see fig. 4).23 In 

contrast, 40 percent of schools had no such policies. 

Figure 4: Estimated Percentage of Schools with a Written Competitive Food Policy in 2003-2004 Enacted by Districts and 

Schools 

In addition to superintendents and school boards that were involved in 

making these competitive food policy decisions for a district, both SFA 

directors and school principals commonly made policy decisions about 

actual food sales at the school level, resulting in no one person having 

responsibility over all sales. Specifically, district SFA directors often made 

ongoing decisions about policies affecting the school nutrition 

environment. For example, SFA directors provided many of the foods 

available to students through their administration of the federal meal 

programs and typically decided which foods to serve through school a la 

carte sales. In addition, SFA directors were also often concerned with 

 23 We did not collect information on the type and extent of restrictions placed on 

competitive foods by these policies or on the enforcement of these policies. 

District and School 

Officials Made Decisions 

about Competitive Food 

Policies 

40% 60%

10% 

Do not know who enacted policy 

10% 

Policy enacted by district and school

2%

Policy enacted by school

No written competitive 

foods policy enacted

Written policy enacted

Source: GAO.

78%

Policy enacted by district 
Page 23 GAO-05-563 School Meal Programs 

other competitive food sales in the schools, such as those through vending 

machines, school stores, and fund-raising sales. According to our survey, 

84 percent of SFA directors in 2003-2004 considered addressing the 

competitive food environment in schools to be part of their 

responsibilities. More than three-quarters of those directors considered it a 

priority. 

Moreover, principals also made decisions about competitive food policies 

in their schools. For example, as shown in figure 4, aside from the more 

than three-quarters of schools with competitive food policies developed by 

their districts, school principals enacted policies in conjunction with their 

districts in an additional 10 percent of schools and enacted their own 

policies in another 2 percent of schools with policies. Regarding 

operational decisions, principals in more than half of schools with 

competitive food sales reported in our survey that they provided final 

approval over the foods and beverages sold through vending machines, 

school stores, and fund-raisers in their schools. Also, similar to SFA 

directors, principals in a majority of schools reported that they considered 

addressing the competitive food environment one of their responsibilities. 

In addition to the district and school officials involved in decisions related 

to competitive food policy, myriad individuals and groups were directly 

involved in the sale of competitive foods. These groups could make 

decisions about which specific foods to sell to students and when to 

conduct sales. During 2003-2004, groups such as students, parent-teacher 

associations, and booster groups—in addition to SFA directors and school 

principals—were most commonly involved in sales, according to our 

survey. 

The number of groups involved in sales typically increased as the school 

level increased. For example, three or more different groups were much 

more likely to be involved in competitive food sales in high schools than in 

middle and elementary schools in 2003-2004 (see fig. 5). 

Many Different Groups 

Were Directly Involved in 

Deciding What to Sell and 

Selling Competitive Foods 
Page 24 GAO-05-563 School Meal Programs 

Figure 5: Number of Groups Directly Involved in Competitive Food Sales in 2003-

2004, Reported as an Estimated Percentage of Schools with Sales 

Note: The estimates for elementary schools and one estimate for middle schools in this figure have 

margins of error that exceed plus or minus 15 percent. See table 6 in appendix I for more information. 

The groups directly involved in sales varied by school level. In elementary 

schools, the SFA/school food service and student associations/clubs were 

commonly involved in sales.24 In middle schools, in addition to these 

groups, school officials/administrators were most commonly involved.25 In 

high schools, where the greatest number of competitive food venues was 

typically available, these three groups and a variety of others were directly 

involved in sales. Consequently, within a high school that has a number of 

competitive food sales occurring simultaneously, a student at lunchtime 

 24 The estimates for SFA/school food service and student associations/clubs have margins 

of error that exceed plus or minus 15 percent. See table 6 in appendix I for more 

information. 

25 The estimate for school officials/administrators has a margin of error that exceeds plus 

or minus 15 percent. See table 6 in appendix I for more information. 

0

10

20

30

40

50

60

70

80

90

100

Percentage of schools

One group

Two groups

Three or more groups

Source: GAO.

36 35

29

23

29

48

4

13

83

Elementary 

schools

Middle schools High schools
Page 25 GAO-05-563 School Meal Programs 

could be faced with many different food options sold by a variety of 

different groups through several venues (see fig. 6). 

Figure 6: Groups Most Frequently Involved in Various Competitive Food Venues Commonly Available in High Schools 

Note: The competitive food venues shown were estimated to be available in a majority of high 

schools, according to our survey. The groups listed with these venues were estimated to be directly 

involved in competitive food sales through the specified venue in at least 25 percent of high schools. 

Cafeteria

A la carte

A la carte

Gym

Vending machines

Vending machines

Vending machines Fund-raisers

Fund-raisers

 Physical

 education

 department 

 Music or

 art department 

 Business teacher

 Student 

 association

 or club

 Booster groups

 School store 

 School store 

 School official

 or administrator

 Student 

 association

 or club

School

food authority

Vending 

machines

School food

authority

Vending 

operator

School official

or administrator

Physical

education

department

Student 

association

or club

School lunch line

?

Source: GAO analysis.

High school at
Page 26 GAO-05-563 School Meal Programs 

Many schools generated substantial revenue through competitive food 

sales in 2003-2004, often using this revenue to support food service 

operations and student activities. High schools and middle schools 

generally raised more revenue from competitive food sales than 

elementary schools, reflecting the greater availability of competitive foods 

in high and middle schools. Across all competitive food sales, food 

services generated more revenue than other school groups, largely 

through a la carte sales. Some food service directors said they relied on 

this revenue to support overall food service operations, while other school 

groups primarily used their competitive food revenues to fund student 

activities. 

Many Schools Raised 

a Substantial Amount 

of Revenue through 

Competitive Food 

Sales and Used It to 

Support Food Service 

Operations and 

Student Activities 
Page 27 GAO-05-563 School Meal Programs 

Many schools generated a substantial amount of revenue through 

competitive food sales in 2003-2004.26 Total revenue generated through 

competitive food venues varied by school level, reflecting, among other 

things, the greater availability of competitive foods in high schools and 

middle schools than in elementary schools.27 In particular, we estimate that 

about 30 percent of all high schools generated more than $125,000 per 

school through competitive food sales in 2003-2004, while about 30 

percent of all elementary schools generated more than $5,000 per school 

through these sales (see fig. 7). These estimates of total competitive food 

revenue are conservative, as they are based on the sum of the minimums 

of specified revenue ranges.28 Therefore, many schools likely generated 

more total revenue from competitive food sales than our analysis reflects. 

 26 Throughout this report, revenue for each type of competitive food venue includes all 

revenue generated through competitive food sales. We did not ask survey respondents for 

information on profits retained after covering expenses. 

27 While the number of students in each school likely affects the amount of revenue 

generated through competitive foods, our data do not allow us to determine the effect of 

school size on revenue. 

28 Total revenue reflects the combined minimums of revenue ranges reported by schools for 

a la carte lines, vending machines, school stores, and exclusive beverage contracts. To 

conduct this analysis, we used matched survey responses, which combined the principal 

and SFA director’s responses for each specific school. We defined the minimum for each 

venue as the lower bound of the revenue range selected by the respondent, and we then 

summed the minimum revenues across all venues for each school. See appendix I for a 

description of this analysis. 

Total Competitive Food 

Revenue Varied by School 

Level From More than 

$125,000 in Some High 

Schools to More than 

$5,000 in Some Elementary 

Schools 
Page 28 GAO-05-563 School Meal Programs 

Figure 7: Estimated Percentage of Schools Generating Different Minimum Amounts 

of Total Competitive Food Revenue in 2003-2004, by School Level 

Note: See appendix I for more information on this analysis, which used data obtained from the 

matched responses. One of the estimates in the high school figure has a margin of error that exceeds 

plus or minus 15 percent. See table 6 in appendix I for more information. 

0

10203040

50

60

Over 125,000

100,001 -125,000

75,001-100,000

50,001-75,000

Source: GAO.

Percentage of schools

25,001-50,000

5,001-25,000

1,001-5,000

0-1,000

0 10 20 30 50 40 60

0

Over 125,000

10203040

50

60

100,001-125,000

75,001-100,000

50,001-75,000

Percentage of schools

25,001-50,000

5,001-25,000

1,001-5,000

0-1,000

0 10 20 30 50 40 60

Minimum revenue per school (in dollars) 

Minimum revenue per school (in dollars) 

Elementary schools

Middle schools

0

10203040

50

60

Over 125,000

100,001-125,000

75,001-100,000

50,001-75,000

Percentage of schools

25,001-50,000

5,001-25,000

1,001-5,000

0-1,000

0 10 20 30 50 40 60

Minimum revenue per school (in dollars) 

High schools

0

0

0

6

9

7

18

14

21

21

29

3

5

5

21

21

7

9

5

2

9

21

16

52
Page 29 GAO-05-563 School Meal Programs 

Across all competitive food sales, food services generated more revenue 

than other school groups, such as school administrators, student 

associations, and booster groups.29 Specifically, food services generated a 

greater amount of revenue through a la carte sales than through any other 

type of competitive food sale. Other school groups raised a greater amount 

of revenue through exclusive beverage contracts than through any other 

type of competitive food sale.30 In addition to raising varying amounts of 

competitive food revenues through different types of sales, food services 

and other school groups generally used their revenues for different 

purposes. 

The revenue food services generated through a la carte sales was 

substantial in many schools. For example, we estimate that 40 percent of 

high school food services and nearly a quarter of middle school food 

services selling competitive foods through a la carte lines generated more 

than $50,000 per school through these sales in 2003-2004. Furthermore, 

food services in 20 percent of high schools selling a la carte items 

generated more than $125,000 per school through a la carte sales, as 

shown in figure 8. 

 29 For the purposes of this discussion, revenue generated by food services refers to revenue 

that was raised by both the school and district food services. 

30 Many schools also held fund-raisers to generate revenue for activities and programs, but 

this revenue is difficult to measure because of the involvement of numerous groups, and it 

is not included in our analysis. 

Food Services Generated 

More Revenue through 

These Sales than Other 

School Groups, with Food 

Services Using Revenue 

for Their Operations and 

Other School Groups 

Using Revenue for Student 

Activities 

Food Services 
Page 30 GAO-05-563 School Meal Programs 

Figure 8: Estimated Percentage of High Schools in Which Food Services Generated 

Different Amounts of Revenue through a la Carte Sales in 2003-2004 

Note: Estimated percentages do not add to 100 because some SFA directors were unsure how much 

revenue they generated through a la carte sales. 

Food services typically used their substantial a la carte revenue to support 

overall food service operations, supplementing revenue earned through 

the sale of school meals. According to our survey of SFA directors, in 

2003-2004, food services in 40 percent of schools earned less revenue than 

they spent, generating a loss, and food services in an additional 20 percent 

of schools broke even. Food services in the remaining 40 percent of 

schools generated more revenue than they spent in 2003-2004, yielding a 

gain.31 From the data we collected, it is not clear what proportion of this 

food service revenue came from federal reimbursement for meals served 

and what proportion came from revenue generated through competitive 

food sales.32 In our previous work, we found that food services in some 

states had a small but increasing shortfall in total revenue compared with 

expenses between school years 1996-1997 and 2000-2001 and that a la 

 31 In addition, food services in 20 percent of schools received supplemental funds from the 

district or school in 2003-2004, while food services in 21 percent of schools transferred 

funds to the district or school in that year. 

32 Further, because we did not collect information on total school food service revenue, we 

were not able to compare food services’ competitive food revenue with their total revenue 

in 2003-2004 in order to determine the effect of competitive food revenue on food service 

budgets. 

Source: GAO.

0

10203040

50

60

Over 125,000 20

5

5

10

26

14

6

5

100,001-125,000

75,001-100,000

50,001-75,000

Percentage of schools

25,001-50,000

5,001-25,000

1,001-5,000

0-1,000

0 10 20 30 40

Revenue per school (in dollars) 
Page 31 GAO-05-563 School Meal Programs 

carte sales had become an increasingly important source for augmenting 

total food service revenue.33 Moreover, some SFA directors told us in 

survey comments for this study that they sold competitive foods in order 

to maintain balanced budgets. For example, one food service director 

commented that the food service would not be able to maintain a balanced 

budget without the substantial revenue generated through a la carte sales. 

Another commented that the district food service generated nearly half of 

its revenue through competitive food sales. 

Other school groups raised more revenue through exclusive beverage 

contracts than through any other type of competitive food sales. In 

particular, we estimate that school groups in nearly one-quarter of high 

schools with exclusive beverage contracts generated more than $15,000 

per school through these contracts in 2003-2004, as shown in figure 9. 

However, it is important to note that 15 percent of high school principals 

did not know how much revenue exclusive beverage contracts generated 

for their schools in 2003-2004. 

 33 GAO, School Meal Programs: Revenue and Expense Information from Selected States, 

GAO-03-569 (Washington, D.C.: May 9, 2003). This report analyzed revenue and expense 

data from six selected states. 

Other School Groups 
Page 32 GAO-05-563 School Meal Programs 

Figure 9: Estimated Percentage of High Schools in Which Other School Groups 

Generated Different Amounts of Revenue through Exclusive Beverage Contracts in 

2003-2004 

Note: Estimated percentages do not add to 100 because some school principals were unsure how 

much revenue other school groups generated through exclusive beverage contracts. 

Exclusive beverage contracts also provided some schools with noncash 

benefits—goods and services such as athletic scoreboards and in-kind 

support of school events. In particular, nearly 30 percent of schools of all 

levels selling competitive foods through exclusive beverage contracts 

received noncash benefits. Nearly one-third of those schools received 

athletic equipment, facilities, or uniforms, and a small number of schools 

also received support for assemblies and programs, scholarships, and 

personal items for students and school staff, such as cups and coolers. The 

value of those items was sometimes considerable: in one-quarter of those 

schools receiving noncash benefits through exclusive beverage contracts 

in 2003-2004, the benefits were worth more than $5,000 per school.34

School groups other than food services most commonly used their 

competitive food revenues to support student activities such as field trips 

and assemblies, as shown in figure 10. Similarly, groups in many schools 

 34 This estimate has a margin of error that exceeds plus or minus 15 percent. See table 6 in 

appendix I for more information. 

Percentage of schools 

0-1,000 8

14

23

19

22

1,001-5,000

5,001-10,000

Source: GAO.

Revenue per school (in dollars) 

10,001-15,000

Over 15,000

0 5 10 15 20 25
Page 33 GAO-05-563 School Meal Programs 

spent competitive food revenues on athletic equipment, facilities, or 

uniforms. However, some used revenues to meet school needs such as 

expenses associated with general school overhead or with textbooks and 

school supplies. 

Figure 10: Estimated Percentage of Schools Using Competitive Food Revenue, 

Excluding Food Service Revenue, for Various Purposes in 2003-2004 

Note: General school overhead includes facilities and grounds maintenance. Respondents in 22 

percent of schools said they spent competitive food revenues on other uses, such as student rewards 

and incentives. 

0

5

10

15

20

25

30

35

40

Source: GAO.

Student field trips

School assemblies and related programs

Athletic equipment, facilities, or uniforms

General school overhead

Percentage of schools

Textbooks and school supplies

Library supplies

Arts programs excluding band or chorus

Band or choral equipment or uniforms

Computers and information technology equipment

Staff development

Playground equipment

Scholarships

Transportation

Nutrition education

Staff salaries and/or benefits

Construction of new facilities, except athletic

0 10 20 30 40

Revenue uses

0

2

5

7

8

9

11

12

13

13

14

17

20

23

34

36
Page 34 GAO-05-563 School Meal Programs 

The six school districts we visited all recently took steps to substitute 

healthy competitive foods for less nutritious items while overcoming 

several obstacles to change, and in the end, the effects of these changes on 

revenue were unclear. Although the districts we visited increased the 

availability of healthy competitive foods and decreased less nutritious 

items through differing approaches, perseverant and committed 

individuals took actions in each district to initiate and lead the process of 

change while also taking steps to involve and obtain support from those 

affected. At the same time, officials noted that they faced several barriers 

to making changes, including concerns about potential revenue losses, 

among others. Concerning the effects of changes on sales revenues, none 

of the districts we visited had sufficient data to examine these effects, and 

few had planned for these effects before implementing changes. 

Regardless of the limited data on revenue, many officials expressed strong 

concerns about potential revenue losses largely because competitive food 

sales have provided a source of flexible funding used for a wide variety of 

purposes. 

Though the six school districts we visited varied in terms of 

socioeconomic status, student population size, and geographic location, 

they were all able to take steps to restrict the availability of less nutritious 

competitive foods in their schools. Further, rather than just remove less 

nutritious competitive foods from their schools, these districts continued 

to offer competitive foods to students by substituting healthy fare for the 

items removed. In addition, these districts all took steps beyond current 

federal and state competitive food regulations, and while there were 

differences in the details of changes, most districts’ changes had similar 

characteristics. Specifically, most, if not all, of the districts we visited 

• made changes to competitive foods in all of the schools in their 

districts, rather than changes only to certain schools, such as 

elementary;35

• made changes to the availability of competitive foods throughout the 

entire school day, rather than limiting availability only during certain 

hours of the day; 

 35 We selected Fort Osage School District as one of our site visits because of the changes 

made to competitive foods at Fire Prairie Middle School, and all references to Fort Osage 

in this report reflect only the changes made at Fire Prairie. 

School Districts We 

Visited Substituted 

Healthy Competitive 

Foods for Less 

Nutritious Items while 

Overcoming 

Obstacles to Change, 

and the Effects on 

Revenue Were 

Unclear 

School Districts We Visited 

Substituted Healthy 

Competitive Foods for 

Less Nutritious Items 
Page 35 GAO-05-563 School Meal Programs 

• made changes to the availability of competitive foods in each of the 

venues through which they were sold, including fund-raising;36and, 

• made simultaneous changes to foods served through school meal 

programs. 

Regarding districts’ efforts to increase the availability of healthy 

competitive foods, as they defined them, all of the districts we visited 

recently took steps to make water and juice more available to students in 

their schools. For example, districts and schools often replaced soda in 

their vending machines with bottled water and juices with higher 

concentrations of real fruit juice. Further, several districts also replaced 

fried potato chips with baked potato chips, and packaged desserts with 

granola bars or similar items. Several districts also increased the variety of 

flavored milk available in schools to encourage milk consumption. 

All of the districts we visited also took steps to restrict less nutritious 

items. The specific types of competitive foods restricted varied by district, 

with two of the districts limiting the availability of primarily soda and 

candy, and four districts limiting the availability of competitive foods high 

in sugar and fat.37 In these districts, different criteria were used by each 

district to define foods high in sugar and fat. For example, in Fort Osage, 

all competitive foods must be low-fat (no specified percentage) and 

cannot have sugar listed as the first ingredient, while in Richland One, all 

competitive foods must contain less than 40 percent sugar (or other 

sweeteners) and less than 8 grams of fat per 1 ounce serving. In the other 

two districts, New Haven and Independence, formulating specific nutrition 

criteria has been an ongoing process. 

In addition to making changes to the types of competitive foods sold in 

schools, all of the districts we visited also made similar changes to 

increase healthy foods available through school meals. For example, SFAs 

in both Independence and Oakland recently removed deep fryers from 

school cafeterias, and they now bake all foods. In Richland One, the SFA 

decided to implement stricter standards for school meals than those 

 36 The only exception to this was Independence, where districtwide changes had been 

made to only those competitive foods sold by the SFA through a la carte lines and vending 

machines at the time of our visit. 

37 Independence, one of the four districts restricting competitive foods high in sugar and 

fat, restricted many, but not all, of these foods. Further, as noted earlier, Independence 

made changes to only those competitive foods sold by the SFA. 
Page 36 GAO-05-563 School Meal Programs 

required by the federal government. Specifically, Richland One requires 

school meal menus to meet the federal requirements for nutrients, fat, and 

sugar intake on a daily basis, rather than averaging the nutritional value of 

meal components over the course of a week. In addition, several SFA 

directors stated that they would like to introduce a greater variety of fresh 

fruits and vegetables into school meal menus. However, they also 

expressed their opinion that the federal school meal reimbursement is 

insufficient to provide these items more frequently.38

While the characteristics of the six districts we visited differed, as well as 

the process of change in each, districts typically noted several key 

components to their success. These key components included an 

enthusiastic initiator of change, leadership by dynamic and committed 

individuals, and support from groups directly affected by changes, such as 

teachers, parents, and students. Overall, those involved in the process of 

change agreed on the importance of improving student nutrition and 

health and directing resources and energy toward achieving this goal. As 

shown in table 5, the types of individuals and groups involved in the 

process of change varied across the districts visited and often included 

individuals from the district, school, and community. 

 38 In recognition of the importance of fruits and vegetables in children’s diets, Congress 

included the Fruit and Vegetable Pilot Program in the 2002 Farm Bill and expanded and 

made the program permanent in the 2004 Child Nutrition and WIC Reauthorization Act. 

This program provides federal grants to schools in eight states and on three Indian 

reservations to provide free fruits and vegetables to students in order to improve student 

nutrition and introduce healthy snack options. 

Individuals Who Initiated 

and Led Change Also 

Obtained the Support of 

Multiple Groups 
Page 37 GAO-05-563 School Meal Programs 

Table 5: District, School, and Community Groups Involved in the Process of 

Changing Competitive Foods, by District Visited 

Note: In Independence, New Haven, Oakland, and McComb, some of the groups indicated were 

involved in the process of changing competitive foods through districtwide committees to address 

school nutrition and health issues. 

SFA Students Parents Committee 

x 

x x 

 x x x 

 x 

x x 

x x x 

x 

x 

x 

x x 

x x x 

 

x x x x x x 

 

x 

x x 

 x x 

x 

x x 

 x 

x 

x 

 x x 

Independence (Missouri)

Initiators

Leaders

Others involved

Fort Osage (Missouri)

Initiators

Leaders

Others involved

New Haven (Connecticut)

Initiators

Leaders

Others involved

Richland One (South Carolina)

Initiators

Leaders

Others involved

McComb (Mississippi)

Initiators

Leaders

Others involved

District-level involvement

School-level involvement

Community involvement

Source: GAO.

Oakland (California)

Initiators

Leaders

Others involved

School

district

officials

Community 

members

School

officials

and

teachers
Page 38 GAO-05-563 School Meal Programs 

As shown in table 5, in the districts we visited, initiators of change 

sometimes came from within the ranks of district staff and sometimes 

from the community, while leaders of change often were district or school 

staff. In some districts, one person or group acted as both the initiator and 

leader of change, while in other cases, the initiator pushed the idea of 

changing competitive foods forward and then the leader took over 

implementation of the changes. For example, in several districts, the 

superintendent or SFA director initiated and led changes to competitive 

foods because of concerns about both student nutrition and competition 

with the school food service. In another district, changes were initiated 

and led largely by a middle school principal and a physical education 

teacher. In contrast, in New Haven, a local pediatrician who was also the 

district’s medical adviser initiated change to competitive foods, and then a 

committee of district staff, school staff, and community members took 

over leadership of changes. In all of the districts we visited, a strong leader 

helped formulate new policies, reached out to parties affected by changes, 

and ensured that policies were implemented. 

While competitive food changes were often initiated and led by a few 

individuals, all six districts realized that changes would be successful only 

with the involvement of a variety of people in the process in order to 

ensure their support for the changes and help sustain changes. To address 

this need, some districts, such as Oakland and New Haven, convened 

formal committees to provide recommendations on school nutrition and 

health issues. In other districts, leaders took steps to reach out 

individually to those parties affected by changes, such as school 

principals, teachers, and students, to obtain support before their 

enactment. This support was also instrumental to sustaining changes. For 

example, the McComb superintendent noted that successful 

implementation of the district’s coordinated school health program 

required both leadership as well as substantial community involvement, 

including input from school officials and teachers, parents, and health 

providers in the community. The involvement of these groups in 

formulating changes helped ensure continued commitment and support of 

the changes. 

In addition to obtaining the support of a variety of groups before 

implementing changes, many districts noted that obtaining student 

acceptance of the changes was particularly important to the success of 

change. To that end, some districts held nutrition and health fairs to 

distribute related information to students and the broader community, and 

others involved students in taste testing and voting on the foods they 

preferred. For example, middle school students and parents in Fort Osage 
Page 39 GAO-05-563 School Meal Programs 

taste-tested healthy competitive foods during parents’ night and the 

school’s open house. In other districts, student feedback on policy 

changes was sought by officials before their implementation, sometimes 

by consulting the district’s student advisory council. 

While the districts we visited all noted several key components to 

successful change, they also cited several barriers to implementing 

changes to competitive foods that they had commonly faced. In particular, 

officials in almost all of the districts visited cited opposition because of 

concerns about future revenue losses as a barrier to changing the 

availability of competitive foods. In these cases, school principals most 

frequently expressed these concerns because competitive food revenues 

often provided discretionary money that was otherwise unavailable to 

fund a variety of projects and needs at the school level. 

In addition, a lack of information on other districts’ efforts to make 

changes to competitive foods and a lack of nutritional guidelines for these 

foods were also barriers to change in the districts we visited. While a 

majority of the districts visited implemented their own changes to 

competitive foods without knowledge of the steps taken by other districts 

to make such changes, officials in Richland One and Oakland conducted 

their own research on other state and district competitive food policies in 

order to learn from the experiences of others. Related to this, officials in 

Independence, Fort Osage, and New Haven noted that the lack of agreedupon nutrition guidelines for competitive foods was an obstacle to change 

because they had to independently develop their own nutrition standards. 

From our observations during these visits, the absence of a clear set of 

standards defining healthy and less nutritious foods can create a problem 

for districts making changes to competitive foods as continual debates and 

disagreements on such standards may slow the process of policy 

formation, particularly when many groups are involved in the process. 

Several districts mentioned additional barriers to making changes, such as 

determining the full extent of competitive food sales in schools and the 

groups involved in sales. For example, the SFA director in Independence 

noted that the district’s delay in developing nutrition standards for 

competitive foods was largely due to the difficulty of compiling a full 

picture of all competitive food sales occurring in schools. Related to this, 

given the number of groups that can be involved in these sales in each 

school, and the lack of clear roles and responsibilities in this environment, 

she noted that it has been difficult to determine the full extent of groups 

involved in sales across the district. She emphasized that it is important 

Districts Faced Several 

Barriers to Changing 

Competitive Foods, 

Including Schools’ 

Concerns about Revenue 

Losses 
Page 40 GAO-05-563 School Meal Programs 

for the groups that have a stake in the revenues generated by these sales to 

be involved in discussions concerning competitive food policy in order to 

obtain support for the policy and successful implementation of changes. 

Some districts also noted that the need to continually monitor 

implementation of competitive food changes at the school level can be an 

obstacle to change. Officials in both Oakland and Richland One stated that 

monitoring adherence to their competitive food policies at the school level 

has been difficult but is necessary to effective implementation. Even when 

school-level groups were involved in the process of developing changes, 

monitoring policy implementation was difficult because of the 

involvement of many groups in competitive food sales. In Richland One, 

the SFA director noted that she often relies on observances by food 

service staff working in the schools to ensure that the policy is being 

followed by all groups selling competitive foods. Our own observations of 

the school food environment during our visits to schools support the 

conclusion that districts have difficulty monitoring the implementation of 

policies, as we noticed a few deviations from district competitive food 

policies in some schools. Even though school officials often seemed 

devoted to the goal of improving the nutritional quality of foods available 

in their schools, they typically faced many competing priorities during the 

school day. Further, in many schools, it was unclear who was responsible 

for ensuring that policies were effectively implemented. 

Food service staff in Fort Osage and New Haven stated that the difficulty 

of finding healthy foods that both meet district nutrition goals and appeal 

to students was also a barrier to making changes to competitive foods. 

They noted that some healthy foods students found appealing were 

unavailable from vendors, while in other instances, the healthy foods 

available were too expensive to sell to students. This sentiment was 

echoed by students in several districts, as they expressed their opinions 

that some of the newly introduced healthy foods, such as bottles of 

flavored milk or juice, were too costly to purchase as part of their lunch. 

In contrast to districts that mentioned problems obtaining new healthy 

products from vendors, several districts noted that they were able to work 

within their exclusive beverage contracts to obtain healthier beverages to 

serve to students. However, at least one mentioned that the major soft 

drink company with whom the district had a contract offered few nonsoda 

options. 

In addition, districts also faced the challenge of educating students about 

healthy eating and encouraging students to change their behavior by 

choosing healthy foods. In several of the districts, schools reported 
Page 41 GAO-05-563 School Meal Programs 

providing students with nutrition information and education, sometimes 

through classroom lessons, posters, and programs and activities to 

promote healthy eating. During our visits, students we spoke with 

frequently demonstrated their understanding of the importance of healthy 

eating, and some noted that they would like to see the addition of certain 

healthy foods to school offerings, such as a greater variety of fresh fruits 

and vegetables. In addition, several middle school students in Fort Osage 

and New Haven explained that after changes were made to competitive 

foods and they began to learn more about good nutrition in their schools, 

they went home and talked to their parents about these issues.39 However, 

experts agree that it is more difficult to change behavior than to educate 

individuals.40 Related to this, high school students in most of the districts 

we visited mentioned that some students continue to purchase less 

nutritious foods before school and after school from neighborhood stores 

and restaurants. In addition, during our visits to schools, we observed 

students eating a wide range of both healthy and unhealthy items during 

lunch, with younger students being more likely to eat healthy foods than 

high school students.41

As part of their role in helping districts develop wellness policies that 

address, among other things, school nutrition, USDA has recently taken 

several steps that may help districts overcome some of these barriers.42 In 

March 2005, USDA, in partnership with HHS/CDC and the Department of 

Education, sent a letter to state superintendents, district superintendents, 

and SFA directors describing the wellness policy requirements. Through 

this letter, the agencies offered to provide technical assistance to districts, 

 39 Related to this, students we met with made comments reflecting their awareness that, in 

addition to schools, families and the broader community play a key role in teaching 

children about good nutrition. 

40 For more information on federally funded nutrition education programs and efforts to 

increase healthy eating in schools, see GAO-04-528 and GAO, School Lunch Program: 

Efforts Needed to Improve Nutrition and Encourage Healthy Eating, GAO-03-506

(Washington, D.C.: May 9, 2003). 

41 Specifically, we noticed that pizza appeared to be the most popular item purchased for 

lunch by students in almost all of the schools we visited. Burgers and fresh fruits and 

vegetables appeared to be the next most popular items, as they were purchased and eaten 

by students during lunch in almost half of the schools we visited. In the lunch periods we 

observed, these foods were sometimes sold as competitive foods and were sometimes 

served as components of the school lunch. 

42 McComb used federal resources to assist its own process of changing competitive foods. 

Changes in McComb were modeled on the CDC-developed coordinated school health 

model. 
Page 42 GAO-05-563 School Meal Programs 

and they also provided information on online resources available at the 

federal level to help districts develop their policies. Specifically, these 

agencies, in collaboration with several food and nutrition organizations, 

have begun to compile resources that will provide districts with 

information on state and local efforts to make changes to the school health 

and nutrition environment, including examples of nutrition standards used 

by states and localities that have already developed competitive food 

policies.43 In addition to online resources, these three agencies recently 

released Making it Happen! School Nutrition Success Stories, a 

publication that describes local efforts to address the school nutrition 

environment, in order to assist districts as they move forward with their 

own changes.44

In the districts we visited, reliable data on how changes to competitive 

food sales affected revenues were typically unavailable. Schools and 

districts often did not maintain detailed revenue records to enable the type 

of analyses needed to parcel out the direct effects of competitive food 

changes on revenues. Nonetheless, most schools and districts were able to 

provide partial data on revenue changes for specific venues, and these 

limited data suggest that districts experienced mixed revenue effects. 

Several schools we visited appear to have lost revenue from competitive 

food sales after they made changes, while at least one may have increased 

revenue. For example, after increasing the availability of healthy a la carte 

foods and restricting less nutritious items, SFA directors in both 

Independence and Richland One recorded decreases in a la carte sales. In 

contrast, a middle school in McComb reported that after removing soda 

from beverage vending machines and changing the policy regarding the 

times sales were allowed, vending revenues increased. However, these 

data did not account for other factors that may also have affected 

revenues. 

While the limited data available suggest that school districts experienced 

mixed revenue effects after implementing competitive food changes, they 

also illustrate the difficulty of tracking these effects. Because the 

 43 USDA stated that Action for Healthy Kids, the School Nutrition Association, and the Food 

Research and Action Center are among the organizations that have assisted with these 

efforts. 

44 Food and Nutrition Service, USDA; CDC, HHS; and the U.S. Department of Education. 

Making it Happen! School Nutrition Success Stories. Alexandria, Va., January 2005. 

The Effects of Changes to 

Competitive Foods on 

Revenues Were Often 

Unclear because of 

Limited Data; Nonetheless, 

Many Officials Expressed 

Concerns about Revenue 

Losses 
Page 43 GAO-05-563 School Meal Programs 

competitive food environment is complex, sometimes involving many 

sales and many groups, the effects of changes on revenues are often 

complicated and may differ for each group involved in sales. Some groups 

may benefit from changes, others may lose. For example, in Fort Osage, 

when the middle school decided to remove all less nutritious competitive 

foods available in the school and replace them with healthy items, it also 

simultaneously decided to stop using outside vendors to supply its vending 

machines. Subsequently, the district SFA took over operation of the 

middle school’s vending machines, and as a result, vending revenue began 

to accrue to the SFA instead of school administrators. While the SFA 

director was unable to compare the revenue before changes with that 

generated after changes, she reported that the machines were selfsupporting. In this instance, because of the changes made to competitive 

foods and their sale, school administrators lost a source of revenue while 

the SFA gained one. 

In addition to the challenge of understanding the revenue effects of 

competitive food changes on different groups in schools, the relationship 

between changes in a la carte sales and school meal participation adds 

complexity. Although food service programs rely on reimbursement for 

school meal participation as a primary source of funding, officials often 

cite the importance of using additional revenue from a la carte sales to 

balance their budgets. Therefore, officials take risks when they make 

changes to the competitive foods available in schools, because changes 

may affect revenues from these sales and they may also affect school 

meals participation. In the districts we visited, competitive food changes 

were often accompanied by increased school meals participation. In four 

districts, federal reimbursements for meals subsequently increased, 

benefiting the SFA, and in at least one instance, this increase more than 

made up for food service losses in competitive food sales. While Richland 

One reported losing approximately $300,000 in annual a la carte revenue 

after implementing changes, school lunch participation and subsequent 

federal reimbursements increased by approximately $400,000 in the same 

year. 

Despite the lack of conclusive data on revenue effects, district and school 

officials often expressed strong concerns about potential revenue losses. 

Because food services often operate on tight budgets and use competitive 

food revenues to support their operations, they take the risk of losing 
Page 44 GAO-05-563 School Meal Programs 

important revenues when they make changes to these foods.45 In addition, 

principals frequently stated that competitive food revenues are used at the 

school level as discretionary funding, and they do not typically have other 

sources of flexible funding available to use for the wide variety of 

purposes toward which competitive food revenues are directed. 

Therefore, when making changes to competitive foods, principals also risk 

losing what is an oftentimes important source of funding. For example, in 

the schools we visited, many principals reported using competitive food 

revenues for student activities and classroom supplies, and some reported 

using these revenues to support school dances and assist needy students. 

Although data on revenue effects were limited and complicated by the 

complex competitive food environment in the districts we visited, some 

districts tried to lessen adverse revenue effects by the process through 

which changes to competitive foods were implemented. Specifically, a few 

districts and schools reported taking incremental steps to change 

competitive foods in order to mitigate the severity of the effects on 

revenue. For example, in one Independence high school, incremental 

changes were being made to beverage vending machines to phase in juice 

and water and phase out soda over a span of several years. The high 

school principal reported that the school was conducting this change 

slowly in order to avoid surprising students with sudden changes and to 

maintain revenue. In addition, a few schools noted that their efforts to 

include students in decisions about changing food offerings may have 

helped ensure that the new foods would be accepted by students and 

mitigate the effects on revenues. However, many of the districts we visited 

did not fully plan for the effects on sales revenues when they were 

considering changes to competitive food policy, and several recognized 

that efforts to do so would have likely eased the implementation of 

policies. Moreover, some principals reported that their schools were able 

to find ways to support projects previously funded with competitive food 

sales after changes were implemented. For example, in several districts, 

principals reported that after restrictions on fund-raiser food sales were 

implemented, groups sold nonfood items like wrapping paper and candles, 

and also raised funds by providing services, such as car washes. 

 45 In the districts we visited, most SFA directors did not express concerns about potential 

revenue losses resulting from changes to competitive foods, possibly because they were 

often significantly involved and invested in the process of making these changes. 
Page 45 GAO-05-563 School Meal Programs 

In the publication Making it Happen! School Nutrition Success Stories, 

key contacts in selected schools reported similar mixed revenue results 

from their efforts to improve the school nutrition environment.46 Of the 

group of schools that reported on revenue changes, some experienced 

increases in revenue while others reported decreases or no change. These 

schools used approaches similar to those in the schools we visited, such as 

replacing less nutritious food with more nutritious choices, obtaining 

input from the students, and using marketing to encourage students to 

make healthy choices. In addition, several of the schools reported 

increases in school meal participation. 

Our nation’s schools are uniquely positioned to positively influence the 

eating habits of children, yet almost all schools sell readily available foods 

that are largely unregulated by the federal government in terms of 

nutritional content. While not all of these competitive foods are unhealthy, 

many are. Although schools cannot be expected to solve the current 

problems with child nutrition and growing obesity alone, many states and 

districts have begun efforts to improve the nutritional environments in 

their schools. 

As districts across the country develop their required wellness policies by 

school year 2006-2007, they will likely face decisions and challenges 

similar to those of the districts we studied and may benefit from their 

lessons learned. Although each district took a different approach, all of 

them recognized the value of including those parties affected by the 

changes, such as parents, teachers, and other community members, when 

developing new policies. In addition, they recognized that students are the 

ultimate consumers of competitive foods and took steps to consider their 

opinions. 

Because districts reported they typically lacked a source of recommended 

nutrition standards for competitive foods in schools, officials were faced 

with difficult decisions about the criteria they would use to determine 

which foods were considered adequately nutritious to offer. The technical 

assistance available from FNS, including multiple examples of nutrition 

standards developed by other districts, as well as the Institute of 

 46 This publication contains self-reported information by key contacts from 32 schools and 

districts nationwide. 

Concluding 

Observations 
Page 46 GAO-05-563 School Meal Programs 

Medicine’s forthcoming recommendations on nutritional standards for 

foods in schools, should help district efforts to address this issue. 

In addition, given the multiple groups that rely on sales of competitive 

foods for revenue, districts may choose to consider the possible revenue 

effects of changes in food offerings as they develop and implement new 

policies. Since competitive food revenues are often critical to food service 

operations and provide principals with flexible funds relied on for a 

multitude of discretionary purposes, making changes to competitive foods 

entails risks for both groups. Districts we visited took varied steps that 

may mitigate potential revenue changes, such as substituting healthy foods 

for less healthy ones instead of removing all competitive foods, asking 

students to taste and approve the more nutritious foods, offering alternate 

means for fund-raising, or implementing change gradually. Lack of support 

from the groups that use revenue from competitive food sales can scuttle 

policy changes. Furthermore, the lack of a single person responsible for 

the presence and sale of competitive foods in schools complicates efforts 

to ensure that new policies will be implemented as intended and 

maintained over time. Despite the complex food environment in schools, 

new wellness policy requirements and USDA’s efforts to provide technical 

assistance to districts will provide an opportunity for districts to plan and 

implement changes that recognize the needs of the various groups and 

assign individuals with responsibility for consistent and sustained 

implementation. 

We provided a draft of this report to the U.S. Department of Agriculture 

for review and comment. On June 17, 2005, FNS officials provided us with 

their oral comments. The officials stated that they were in general 

agreement with the findings as presented in the report and offered 

technical comments that we have incorporated as appropriate. In addition, 

the officials reiterated that the 1983 court decision in National Soft Drink 

Ass’n v. Block is significant because they believe it severely limits USDA’s 

ability to restrict the sale of competitive foods. FNS officials pointed out 

that prior to this ruling, USDA regulations prohibited the sale of FMNV 

anywhere in the school from the beginning of the school day until the last 

meal period. Following the decision, USDA restricted the sale of FMNV 

only in food service areas during meal periods. We agree that this ruling 

limited USDA’s ability to regulate competitive food sales as to time and 

place. However, we believe the department has the authority to expand 

the definition of FMNV to include additional foods with limited nutritional 

value. Doing so could further limit the types of these foods available in the 

cafeteria during meal times. 

Agency Comments 
Page 47 GAO-05-563 School Meal Programs 

Second, officials discussed what is known about the use of revenue from 

competitive food sales and reimbursable meals compared to their costs. 

We did not determine if revenues generated by competitive food sales 

were sufficient to cover the actual cost of the competitive foods sold. The 

officials stressed that the 1994 School Lunch and Breakfast Cost Study, 

the last definitive study of cost and revenue in the NSLP and the School 

Breakfast Program, found that regardless of size, most school food 

authorities failed to generate enough revenue to cover the reported costs 

of nonreimbursable food sales.47 The mean reported revenue-to-cost ratio 

was 71 percent for the study period. The officials noted that this would 

equate to a loss of 41 cents for every dollar received from the sale of 

nonreimbursable foods. Further, this revenue-to-cost ratio did not include 

all costs for school food service operations, such as uncharged labor costs, 

indirect costs, and utilities. If these were included, the revenue to cost 

ratio would generate even higher losses. FNS informed us that they are in 

the process of contracting for a new school meal cost study. 

We agree with FNS that our report focused on revenues generated by 

competitive food sales and that we did not determine if revenues 

generated by competitive food sales were sufficient to cover the actual 

cost of the foods sold. However, our report and others have shown that 

the availability of competitive foods, and particularly a la carte items, has 

increased over time. In addition, the Cost Study’s definition of 

nonreimbursable meals included food sales such as adult meals and 

special functions, as well as competitive foods, and therefore, it is unclear 

how each of these types of sales contributed to the mean reported 

revenue-to-cost ratio. Absent more current information on the actual costs 

and revenues of providing competitive foods and reimbursable school 

meals, we believe it is difficult to know whether the results of the 1994 

study are applicable today. 

As agreed with your offices, unless you release the report's contents 

earlier, we plan no further distribution of it until 30 days from its issue 

date. We will send copies of this report to the Secretary of Agriculture, 

appropriate congressional committees, and other interested parties. In 

addition, the report will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 

 47 Abt Associates, Inc. School Lunch and Breakfast Cost Study–Final Report, a special 

report prepared at the request of USDA (Cambridge, Mass.: October 1994). 
Page 48 GAO-05-563 School Meal Programs 

If you or your staff have any questions about this report, please contact me 

at (415) 904-2272 or bellisd@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix II. 

David D. Bellis 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Scope and Methodology 

Page 49 GAO-05-563 School Meal Programs 

To obtain nationally representative information on competitive food 

availability, policies, decision makers, groups involved in their sale, and 

revenues generated by their sale, we conducted two Web-based surveys. In 

addition, to gather information on strategies used by school districts to 

restrict less nutritious competitive foods in their schools, we visited six 

school districts. Further, to inform the design of our study, we spoke with 

staff at the U.S. Department of Agriculture (USDA) as well as the Centers 

for Disease Control and Prevention (CDC). We also interviewed numerous 

researchers and organizations that have been involved with child nutrition 

and school health environment issues in recent years.1

To better understand competitive foods in the school environment, we 

designed and administered two Web-based surveys. For a random sample 

of schools, we administered one survey to each school’s school food 

authority (SFA) director and a second survey to each school’s principal. 

We chose to survey these officials because we believed they would be the 

most knowledgeable sources on competitive food issues in schools. The 

surveys were conducted between October 19, 2004, and February 11, 2005. 

We defined competitive foods as all foods or beverages sold to students on 

school grounds during the school day that are not part of federally 

reimbursable school meals. 

While neither survey asked questions about the full range of competitive 

food issues, together the two surveys were designed to provide a broad 

picture of the competitive food environment. Both Web surveys contained 

school background, a la carte, (beverage and snack) vending machine, and 

school store and snack bar sections. However, each survey had unique 

sections as well. The SFA directors’ survey included sections that asked 

questions about the SFA, the school food service, and school meals 

participation. The principals’ survey included unique sections on school 

and district policies for competitive foods, including fund-raising and 

exclusive beverage contracts. 

 1

 We spoke with staff of Mathematica Policy Research Inc., Abt Associates Inc., Nutrition 

for the Future Inc., University of Minnesota—School of Public Health, School Nutrition 

Association, the National Association of Secondary School Principals, the National 

Association of Elementary School Principals, Samuels & Associates, the Association of 

School Business Officials International, the Council of Chief State School Officers, the 

National Association of State Boards of Education, and the National School Boards 

Association. 

Appendix I: Scope and Methodology 

Surveys 
Appendix I: Scope and Methodology 

Page 50 GAO-05-563 School Meal Programs 

A majority of the survey questions asked both SFA directors and principals 

to consider school year 2003-2004. To gain a sense of change for certain 

competitive food issues, a few questions asked SFA directors and 

principals to consider school year 1998-1999 alone, make comparisons 

between these reporting periods (1998-1999 versus 2003-2004), or consider 

change in specific competitive food issues over the entire time of these 

reporting periods (from 1998-1999 to 2003-2004). 

The target population consisted of all public schools in the 50 states and 

the District of Columbia that participated in the National School Lunch 

Program (NSLP) for the 2003-2004 school year. We used the Department of 

Education’s Common Core of Data (CCD) Public Elementary/Secondary 

School preliminary file for the 2002-2003 school year as a basis for defining 

our population. On the basis of our review of these data, we determined 

this source to be adequate for the purposes of our work. 

To define our sampling frame, we removed schools from the CCD that 

were permanently or temporarily closed; not yet operational; special 

education, vocational education, or alternative/other; run by the 

Department of Defense or Bureau of Indian Affairs; or located in American 

Samoa, Guam, Northern Marianas, Puerto Rico, or the Virgin Islands. From 

this analysis, we obtained a sampling frame consisting of 85,569 regular 

public schools in the 50 states and the District of Columbia. However, 

consistent information specifically identifying a school’s participation in 

the NSLP was not available in the CCD. 

The sample design for the Web surveys was a stratified random probability 

sample of 656 schools that allows for estimates to be calculated for each 

school level (elementary, middle, and high). We stratified by school level, 

census region, and rural status, and we produced estimates by school 

level. With this probability sample, each school in the population had a 

known, nonzero probability of being selected. Each selected school was 

subsequently weighted in the analysis to account statistically for all the 

schools in the population, including those that were not selected. Because 

each school was randomly chosen, some SFA directors had more than one 

school under their responsibility selected for our study, and they were 

therefore asked to complete a separate survey for each school. 

Because we surveyed a sample of schools, our results are estimates of a 

population of schools and thus are subject to sample errors that are 

associated with samples of this size and type. Our confidence in the 

precision of the results from this sample is expressed in 95 percent 

confidence intervals, which are expected to include the actual results in 95 

Population 

Sample Design and Errors 
Appendix I: Scope and Methodology 

Page 51 GAO-05-563 School Meal Programs 

percent of the samples of this type. We calculated confidence intervals for 

this sample based on methods that are appropriate for a stratified 

probability sample. 

Through a telephone survey of the schools selected in our sample, we 

determined the number of schools selected in our sample that participated 

in the NSLP. We estimate that 80,245 (94 percent) schools in our 

population participated in the NSLP. All estimates produced from the 

sample and presented in this report are for the estimated target population 

of 80,245 schools that participated in the NSLP. All percentage and 

numerical estimates included in this report have margins of error of plus 

or minus 15 percentage points or less, except for those shown in table 6. 

Table 6: Sampling Error Calculations for Questions in Which the Error Exceeded 15 Percent 

Page Question Estimate Lower bound Upper bound

15 Percentage of elementary schools with vending machines that had three or more 

vending machines in school year 2003-2004 29 15 47

17 Percentage of schools with school stores in which salty snacks (not low-fat) were 

often or always available for students to purchase from these stores in school year 

2003-2004 45 29 61

17 Percentage of schools with school stores in which sports drinks were often or 

always available for students to purchase from these stores in school year 2003-

2004 44 28 60

17 Percentage of schools with school stores in which sweet baked goods (not low-fat) 

were often or always available for students to purchase from these stores in school 

year 2003-2004 40 25 56

17 Percentage of schools with school stores in which water was often or always 

available for students to purchase from these stores in school year 2003-2004 47 32 62

20 Percentage of middle schools with vending machines in which the total number of 

vending machines on school grounds increased between school years 1998-1999 

and 2003-2004 39 25 54

20 Percentage of elementary schools with a la carte sales in which the total volume of 

a la carte items sold to students increased between school years 1998-1999 and 

2003-2004 31 19 47

24 Percentage of elementary schools with one group directly involved in competitive 

food sales in school year 2003-2004 36 19 56

24 Percentage of elementary schools with two groups directly involved in competitive 

food sales in school year 2003-2004 35 20 53

24 Percentage of elementary schools with three or more groups directly involved in 

competitive food sales in school year 2003-2004 29 14 48

24 Percentage of middle schools with two groups directly involved in competitive food 

sales in school year 2003-2004 29 17 44

24 Percentage of elementary schools with SFA/school food service directly involved in 

competitive food sales in school year 2003-2004 62 45 77
Appendix I: Scope and Methodology 

Page 52 GAO-05-563 School Meal Programs 

Page Question Estimate Lower bound Upper bound

24 Percentage of elementary schools with student associations/clubs directly involved 

in competitive food sales in school year 2003-2004 35 19 52

24 Percentage of middle schools with school officials or administrators directly 

involved in competitive food sales 35 21 51

28 Percentage of high schools that generated total minimum combined revenue of 

$25,001 to $50,000 through competitive food sales in school year 2003-2004 21 9 37

32 Percentage of schools with exclusive beverage contracts that received noncash 

benefits through these contracts that were valued at over $5,000 in school year 

2003-2004 25 13 41

Source: GAO. 

We took steps to minimize nonsampling errors that are not accounted for 

through statistical tests, like sampling errors. Nonsampling errors could 

figure into any data collection effort and involve a range of issues that 

could affect data quality, including variations in how respondents interpret 

questions and their willingness to offer accurate responses. 

In developing the Web surveys, we conducted several pretests of draft 

instruments. We held pretest discussions of the principals’ survey with 

staff and members of the National Association of Elementary School 

Principals and the National Association of Secondary School Principals. 

We pretested the SFA survey with members of the American School Food 

Service Association (now known as the School Nutrition Association). In 

addition, both surveys were also pretested during a preliminary visit to the 

SFA and an elementary school in Fairfax County, Virginia. All pretests 

were conducted between July and September 2004. 

For the survey pretests, we were generally interested in the clarity of the 

questions and the flow and layout of the surveys. 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 the survey sections and the 

questions within each section was appropriate. On the basis of our 

pretests, the Web instruments underwent some slight revisions. 

After the survey was closed, we also made comparisons between select 

items from our competitive food Web-based survey data and other 

Nonsampling Errors 
Appendix I: Scope and Methodology 

Page 53 GAO-05-563 School Meal Programs 

national-level data sets.2 Our comparisons found our survey data were 

reasonably consistent with the external sources. Of the basis of our 

comparisons, we believe our survey data are sufficient for the purposes of 

our work. 

Using Web-based surveys also helped remove error in our data collection 

effort. By allowing respondents to enter their responses directly into an 

electronic instrument, this method automatically created a record for each 

respondent in a data file and eliminated the need for and the errors (and 

costs) associated with a manual data entry process. To further minimize 

errors, programs used to analyze the survey data and make estimations 

were independently verified to ensure the accuracy of this work. 

For each school in our sample, we attempted to obtain valid e-mail 

addresses for the principal and the SFA director. For the 656 schools in 

our sample, we obtained valid e-mail addresses for 489 principals and 455 

SFA directors. We administered the surveys to those groups, and we 

received completed surveys from 70 percent of the SFA directors and 65 

percent of the principals who received the surveys. The response rates for 

our sample of 656 schools, including those officials we were unable to 

contact, were 51 percent for both principals and SFA directors, excluding 

the 26 non-NSLP schools. We received responses from both the SFA 

director and the principal for the same school (matched responses) for 192 

schools (30 percent of schools that participated in the NSLP in our 

sample). Tables 7 and 8 summarize the population and sample by school 

level for the SFA director and principal surveys respectively. 

 2

 We compared our Web-based survey data to data on competitive foods reported by USDA 

in the School Nutrition and Dietary Assessment Study II (1998-1999) and the School 

Meals Implementation Initiative— Third Year Report (2002), and by CDC in the School 

Health Policies and Programs Study (2000). 

Response Rates 
Appendix I: Scope and Methodology 

Page 54 GAO-05-563 School Meal Programs 

Table 7: SFA Director Survey: Population and Sample by School Level 

School level 

Schools in 

population 

Schools in 

sample

Non-NSLP 

schools

No valid 

e-mail

NSLP schools 

surveyed 

NSLP 

schools 

responding

Elementary 51,997 188 6 55 127 85

Middle 15,737 188 3 45 140 96

High 14,979 188 6 48 134 103

Other 2,856 92 11 27 54 35

Total 85,569 656 26 175 455 319

Source: GAO. 

Table 8: Principal Survey: Population and Sample by School Level 

School level 

Schools in 

population 

Schools in 

sample

Non-NSLP 

schools

No valid 

e-mail

NSLP schools 

surveyed 

NSLP schools 

responding

Elementary 51,997 188 6 39 143 88

Middle 15,737 188 3 39 146 91

High 14,979 188 6 41 141 96

Other 2,856 92 11 22 59 42

Total 85,569 656 26 143 489 317

Source: GAO. 

While the majority of our estimates are calculated based on survey 

responses from either the SFA directors’ survey or the principals’ survey, 

we used the matched responses (192 schools) to calculate the total 

combined minimum revenue estimates. Specifically, the amount of 

revenue earned from each competitive food venue within a school was 

reported by SFA directors and principals in multiple ranges. For example, 

SFA directors reported revenue generated by food services through 

competitive food sales, such as a la carte sales, and principals reported 

revenue generated by all other competitive food sales in the school. To 

estimate the combined competitive food revenue for a school, we defined 

the minimum for each of the school’s venues as the lower bound of the 

revenue range reported by SFA directors and principals. We then summed 

the minimum revenue across all venues for each school. 

Another type of nonsampling error is nonresponse or, in the case of our 

work, those SFA directors and principals from schools in our sample who 

did not provide a complete survey. To increase survey responses, after the 

Web surveys were initially deployed, we made several follow-ups with 

Survey Nonresponse Issues 
Appendix I: Scope and Methodology 

Page 55 GAO-05-563 School Meal Programs 

nonrespondent SFA directors and principals via e-mail and phone to 

remind them of their respective surveys. 

After the surveys were closed, we analyzed each set of survey respondents 

(SFA directors, principals, and the matched responses) to determine if 

there were any differences between the responding schools, the 

nonresponding schools, and the population.3

 We performed this analysis 

for four characteristics—total number of students enrolled, total number 

eligible for free lunch, total number eligible for reduced price lunch, and 

total number eligible for either free or reduced price lunch. We determined 

whether sample-based estimates of these characteristics compared 

favorably with the known population values, and we also tested the 

differences of the estimates for survey respondents and nonrespondents. 

We performed this analysis for all schools and separately for each school 

level (high, middle, and elementary). For each set of survey respondents, 

the population value for all of the characteristics we examined fell within 

the 95 percent confidence intervals for the estimates. We also determined 

that there were no significant differences between estimates from the 

respondents and nonrespondents. 

Additionally, we compared the distribution of several demographic 

variables, including region, school level, and rural status, for survey 

respondents and nonrespondents. On the basis of this analysis, we found 

no significant distributional differences between respondents and 

nonrespondents. Although the characteristics were selected because they 

may be related to other school characteristics asked for on our surveys, 

we do not know the extent to which the respondents reflect the 

population characteristics for our specific survey questions. On the basis 

of both sets of analyses, we chose to include the survey results in our 

report and produce sample-based estimates to the population of schools 

that participated in the NSLP. 

To gather information on local efforts to restrict the availability of less 

nutritious competitive foods, we conducted site visits to six districts 

between September 21 and December 9, 2004. The districts visited 

included Independence School District (Independence, Missouri), Fort 

Osage R-1 School District (Independence, Missouri), New Haven Public 

 3

 Nonresponding schools include both schools for which we were unable to obtain valid email addresses and schools that received the survey but did not respond. 

Site Visits 
Appendix I: Scope and Methodology 

Page 56 GAO-05-563 School Meal Programs 

Schools (New Haven, Connecticut), Richland County School District One 

(Columbia, South Carolina), Oakland Unified School District (Oakland, 

California), and McComb School District (McComb, Mississippi). We 

selected these districts from a list of approximately 100 districts and 

schools recognized as making efforts to restrict access to less nutritious 

competitive foods. This list was compiled by reviewing recently released 

reports, studies, and articles that described local efforts to make changes 

to competitive foods. The six districts visited were selected because they 

used different strategies to restrict competitive foods, and when viewed as 

a group, they provided variation across characteristics such as geographic 

location, district size, and socioeconomic status. 

During the site visits, we interviewed district officials, including the 

superintendent and SFA director, as well as visited one or two schools 

within each district. At the schools, we interviewed principals, food 

service staff, and health and physical education teachers, as well as others 

involved with the school food environment. From these interviews, we 

gathered information on the district and school food environment, 

strategies used to restrict competitive foods, individuals and groups 

involved in implementing changes, facilitators and barriers to change, 

revenues generated by competitive foods, ongoing efforts, students’ 

reactions to changes, and opinions on the school wellness policies 

mandated in the 2004 Child Nutrition and WIC Reauthorization Act. In 

addition to our interviews with district and school officials, we also met 

with students to collect their opinions regarding nutrition and healthy 

eating, competitive foods in schools, and school meals. Further, we 

observed at least one lunch period in each school visited, in order to better 

understand the school nutrition environment and the choices students 

make at lunch. 
Appendix II: GAO Contacts and Staff 

Acknowledgments 

Page 57 GAO-05-563 School Meal Programs 

David Bellis, Director, (415) 904-2272, bellisd@gao.gov 

Kay E. Brown, Assistant Director, and Rachel Frisk, Analyst in Charge, 

managed this assignment and made significant contributions to all aspects 

of this report. Marissa Jones, Avani Locke, Kevin Jackson, and Jim Ashley 

also made significant contributions to this report. In addition, Daniel 

Schwimer assisted in the legal analysis, Amber Edwards assisted in the 

analysis of local efforts to restrict competitive foods across the country, 

and Susan Bernstein assisted in the message and report development. 

Appendix II: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 
Related GAO Products 

Page 58 GAO-05-563 School Meal Programs 

Commercial Activities in Schools: Use of Student Data is Limited and 

Additional Dissemination of Guidance Could Help Districts Develop 

Policies. GAO-04-810. Washington, D.C.: August 20, 2004. 

Nutrition Education: USDA Provides Services through Multiple 

Programs, but Stronger Linkages among Efforts Are Needed. GAO-04-528. 

Washington, D.C.: April 27, 2004. 

School Meal Programs: Competitive Foods Are Available in Many 

Schools; Actions Taken to Restrict Them Differ by State and Locality. 

GAO-04-673. Washington, D.C.: April 23, 2004. 

School Lunch Program: Efforts Needed to Improve Nutrition and 

Encourage Healthy Eating. GAO-03-506. Washington, D.C.: May 9, 2003. 

School Meal Programs: Revenue and Expense Information from Selected 

States. GAO-03-569. Washington, D.C.: May 9, 2003. 

Related GAO Products 

(130379) 
The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To 

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER