Special Nutrition Program Operations 

Study: State and School Food Authority 

Policies and Practices for School Meals 

Programs School Year 2011-12

Nutrition Assistance Program Report March 2014 

Food and Nutrition Service 

Office of Policy Support 
USDA is an Equal Opportunity Provider and Employer 
 

Special Nutrition Program Operations Study: 

State and School Food Authority Policies and 

Practices for School Meals Programs School 

Year 2011-12

Authors: 

Laurie May, Ph.D. 

Kim Standing, M.A. 

Adam Chu, Ph.D. 

Joe Gasper, Ph.D. 

Jarnee Riley, M.S. 

Submitted by: 

Westat 

1600 Research Blvd. 

Rockville, MD 20850 

Project Director: 

Kim Standing 

Submitted to: 

Office of Policy Support 

Food and Nutrition Service

3101 Park Center Drive 

Alexandria, VA 22302 

Project Officer: 

John R. Endahl 

This study was conducted under Contract number AG-3198-D-10-0048 with the Food and 

Nutrition Service, United States Department of Agriculture. 

This report is available on the Food and Nutrition website: 

http://www.fns.usda.gov/research-and-analysis

Suggested Citation: 

May, Laurie, Kim Standing, Adam Chu, Joe Gasper, and Jarnee Riley. Special Nutrition Program 

Operations Study: State and School Food Authority Policies and Practices for School Meals Programs School 

Year 2011-12. Project Officer: John R. Endahl. Prepared by Westat for the U.S. Department of 

Agriculture, Food and Nutrition Service, March 2014

Food and Nutrition Service, Office of Policy Support March 2014
Authors and Contributors 

Listed below are the authors and contributors to the Final Report. 

Authors 

Laurie May, Ph.D. 

Kim Standing, M.A. 

Adam Chu, Ph.D. 

Joseph Gasper, Ph.D. 

Jarnee Riley, M.S. 

Contributors 

Frank Bennici, Ph.D. 

Westat 

Evarilla Cover, B.A. 

Westat 

Ed Dolbow, MA 

Westat 

Sujata Dixit-Joshi, Ph.D. 

Westat 

Tracy Fox, MPH, RD 

Food, Nutrition & Policy Consultants, LLC 

Patricia Freedman, B.A. 

Independent consultant 

Fred Glantz, Ph.D. 

Kokopelli Associates, LLC 

Linda Gowen, B.S. 

Westat 

Stephanie Huang, B.S. 

Westat 

Rachel Jones, B.A. 

Westat 

Mustafa Karakus, Ph.D. 

Westat 

Michael Kapombe, B.S. 

Westat 

Kate Kim, B.A. 

Westat 

Therese Koraganie 

Westat 

Juanita Lucas-McLean, M.S.W. 

Westat 

Ted Macaluso, Ph.D. 

Independent consultant 

Ray Olsen, B.S. 

Westat 

Laura Prinslow, M.B.A. 

Westat 

Ning Rui, Ph.D. 

Westat 

Priyanthi Silva, Ph.D. 

Westat 

Cynthia Thomas, Ph.D. 

Westat 

Joel Wakesberg, M.S. 

Westat 

i 

Acknowledgements 

We would like to thank the many individuals whose efforts contributed to the preparation of 

this report. 

First and foremost, we want to thank the State Child Nutrition and School Food Authority 

directors who participated in the study. This report would not be possible without their cooperation 

and hard work. We would also like to thank the Regional Offices for their support and 

encouragement during the data collection. 

We would like to express our gratitude to Tracy Fox, Food, Nutrition & Policy Consultants, 

LLC; Fred Glantz, Kokopelli Associates, LLC; and Ted Macaluso for reviewing the report and 

providing insightful comments and constructive recommendations for improving the report. 

Finally, we would like to thank John Endahl, our project officer, for his guidance throughout 

the project and particularly his patience during the preparation of this report. 

Table of Contents 

Section Page

Acknowledgements .......................................................................................................... i

Section I: Executive Summary ......................................................................................................... 1

Background and Purpose of the Study ......................................................................... 1

Participation ...................................................................................................................... 2

SFA Operations ............................................................................................................... 4

SFA Finances ................................................................................................................... 8

Meal Prices .......................................................................................................... 9

Non-Profit Operations ....................................................................................11

State Policies and Support ............................................................................................12

Conclusions ....................................................................................................................15

Section II: Study Overview ..............................................................................................................17

Study Purpose ................................................................................................................19

Study Design ..................................................................................................................19

Data Sources ...................................................................................................................19

State Child Nutrition Director Survey ..........................................................20

SFA Director Survey .......................................................................................21

SFA Sample Selection ...................................................................................................22

Data Collection Procedures .........................................................................................24

State Child Nutrition Director Survey ..........................................................24

SFA Director Survey .......................................................................................25

SFA Director Survey Response Rate ..........................................................................25

Weighting and Adjustments .........................................................................................26

Base Weights .....................................................................................................26

Non-Response Weights ..................................................................................26

Variance Estimation ........................................................................................26

Table Variables ...............................................................................................................27

Significance Tests .............................................................................................28

Missing Data .....................................................................................................28

Section III: Participation in NLSP, SBP, and Other Nutrition Programs ................................. 29

Background .....................................................................................................................29

Research Questions .......................................................................................................30

Results ............................................................................................................................31

SFA and School Participation in the NSLP and the SBP ..........................31

Student Participation in the NSLP and the SBP .........................................36

SFA Participation in Other Programs ...........................................................37

Special Initiatives to Improve Nutrition and the School Environment...40
Contents (continued) 

iv

Section Page

Section IV: SFA Operations .............................................................................................................47

IV-1. Staff Credentials and Responsibilities .........................................................................49

Background .....................................................................................................................49

Research Questions .......................................................................................................49

Results ............................................................................................................................49

Experience and Tenure ...................................................................................49

Education ..........................................................................................................51

Certification and Responsibilities .................................................................. 53

IV-2. Kitchens and Meal Service ...........................................................................................59

Background .....................................................................................................................59

Research Questions .......................................................................................................59

Results ............................................................................................................................60

Kitchen Facilities ..............................................................................................60

Use of Food Service Facilities by Other Programs .....................................61

Types of Meal Service Systems ......................................................................64

Policies and Practices Regarding Location and Timing of School 

Meals ..................................................................................................66

IV-3. Food Safety and Training .............................................................................................73

Background .....................................................................................................................73

Research Questions .......................................................................................................73

Results ............................................................................................................................74

Food Safety Plans and Staff Certifications ...................................................74

Food Safety Certification ................................................................................75

Safety Topics Covered in Trainings ..............................................................76

USDA Materials ...............................................................................................76

Food Defense Plan or Practices ....................................................................77

Special Diets ......................................................................................................78

Components of Food Safety ..........................................................................81

Food Recall Notification Procedures ............................................................85

IV-4. Food Procurement ........................................................................................................89

Background .....................................................................................................................89

Research Questions .......................................................................................................89

Results ............................................................................................................................90

Use of Geographic Preference and Farm to School ...................................90

Food Purchasing Specifications .....................................................................93

Food Service Management Companies ........................................................98
Contents (continued) 

v 

Section Page

IV-5. Menu Planning and Nutritional Analysis ................................................................. 101

Background ...................................................................................................................101

Research Questions .....................................................................................................102

Results ..........................................................................................................................102

Menu Planning Systems ................................................................................102

Nutrition Analysis of Planned Menus .........................................................104

IV-6. Meal Counting and Claiming Procedures ................................................................107

Background ...................................................................................................................107

Research Questions .....................................................................................................108

Results ..........................................................................................................................108

Technology Used at the Point of Service ...................................................108

Training and Monitoring of Cashiers ..........................................................109

Types of Payment Accepted for School Meals ..........................................111

IV-7. Availability of Non-USDA Meal Alternatives .........................................................113

Background ...................................................................................................................113

Research Questions .....................................................................................................114

Results ..........................................................................................................................114

Alternative Meal Practices ............................................................................114

Comparison of State and SFA Nutrition Standards to Federal 

Requirements ..................................................................................116

Availability of Free Potable Water Where School Lunches Are Served 117

Policies and Practices for Serving Meals to Students Who Are Unable 

to Pay ...............................................................................................119

Section V: SFA Financials .............................................................................................................121

V-1. Meal Prices....................................................................................................................123

Background ...................................................................................................................123

Reimbursement Rates ....................................................................................123

The Potential for Cross-Subsidization and the New HHFKA 

Provisions .......................................................................................123

Research Questions .....................................................................................................124

Results ..........................................................................................................................125

Meal Prices from SY 2009-10 to SY 2011-12............................................125

Factors that May Have Influenced Meal Pricing Decisions ....................132

Actions Taken to Avoid Raising Meal Prices and Minimize the 

Effects on Participation ................................................................135
Contents (continued) 

vi

Section Page

V-2. Expenditures, Revenues, and Unpaid Meals ...........................................................137

Background ...................................................................................................................137

Measuring Expenditures versus Costs ........................................................137

Operational Definition of Breaking Even ..................................................138

Unpaid Meals ..................................................................................................138

Research Questions .....................................................................................................138

Results ..........................................................................................................................139

Expenditures and Revenues .........................................................................139

Operating as a Nonprofit ..............................................................................145

Lost Revenues from Unpaid Meals .............................................................147

Section VI: State Policies and Administration of the NSLP and SBP ......................................151

VI-1. Communication Issues ................................................................................................153

Background ...................................................................................................................153

Research Questions .....................................................................................................153

Results ..........................................................................................................................154

Communication between State Agencies and SFAs ................................. 154

Communication between SFAs and School Staff .....................................155

Communication between SFA and Participating Households ................156

Communicating About Food Holds or Recalls .........................................158

VI-2. State Finances and Budget .........................................................................................161

Background ...................................................................................................................161

Research Questions .....................................................................................................161

Results ..........................................................................................................................161

State Subsidies to SFAs .................................................................................161

Budget Issues ..................................................................................................163

VI-3. State Policies and Practices.........................................................................................165

Background ...................................................................................................................165

Eligibility and Alternative Meals ..................................................................165

School Meal Operations ................................................................................166

Charter Schools ..............................................................................................167

Research Questions .....................................................................................................167

Results ..........................................................................................................................169

Eligibility Provisions ......................................................................................169

Alternative Meals ............................................................................................173

School Meal Operations ................................................................................174

Charter Schools ..............................................................................................180
Contents (continued) 

vii

Section Page

VI-4. Training and Technical Assistance ............................................................................183

Background ...................................................................................................................183

Research Questions .....................................................................................................183

Results ..........................................................................................................................183

Section VII:Conclusions ..................................................................................................................187

References.....................................................................................................................189

Appendices

 A State Child Nutrition (CN) Director Survey 2011................................................. A-1 

 B School Food Authority (SFA) Director Survey 2011 ............................................ B-1 

 C Weighting Procedures for the Base-Year Survey of School Food 

 Authorities ................................................................................................................... C-1 

 D Nonresponse Bias Analysis ....................................................................................... D-1 

 E Supplementary Tables ................................................................................................ E-1 
Contents (continued) 

viii

Tables Page

I-1. Percentage of SFAs with All Schools within each Grade Level 

Participating in the NSLP and the SBP, SY 2011-12 .....................................................2

I-2. Percentage of Students Approved for Free or Reduced-Price Meals and 

Percentage of Students without Access to the SBP and NSLP, SY 2011-12 .............3

I-3. Percentage of SFAs with One or More Schools Participating in Other 

Nutrition Programs and Initiatives, SY 2011-12.............................................................4

I-4. Percentage of SFAs with Select Operational Characteristics, SY 2011-12 .................6

I-5. Percentage of SFAs with Various Shares of their Schools having Food 

Safety Plans and Regular Inspections, SY 2011-12.........................................................8

I-6. Reimbursement Rates for the NSLP and SBP, SY 2009-10 to SY 2011-12...............8

I-7. SFA’s Average Meal Prices, Reimbursement Rates, and Revenues per 

Meal for the NSLP and SBP by Grade Level, SY 2010-11 ...........................................9

I-8. SFAs’ Average Difference in Revenues per Meal, SY 2010-11 versus SY 

2011-12............................................................................................................................... 10

I-9. NSLP and SBP Reimbursement Rates for Free School Meals and 

Average Prices for Paid Meals, SY 2009-10 to SY 2011-12 ....................................... 11

I-10. Percentage of SFAs by Annual Cash Receipts as a Percentage of Cash 

Expenditures, SY 2010-11............................................................................................... 12

I-11. Percentage of States with Select Policies, SY 2011-12 ................................................ 13

I-12. Percentage of States with Charter Schools and their NSLP Participation 

Levels, SY 2011-12 ........................................................................................................... 14

I-13. Percentage of States Providing School Meal Training and Technical 

Assistance by Topic and Frequency, SY 2011-12........................................................ 14

II-1. State Director Questionnaire Content ........................................................................... 21

II-2. SFA Director Questionnaire Content ........................................................................... 22

II-3. Sample Frame Coverage of SFAs, Schools, and Students in SY 2009-10................ 23

II-4. SFA Sample by Enrollment............................................................................................. 24
Contents (continued) 

ix

Tables Page

II-5. Response Rate for the SFA Survey ................................................................................ 25

II-6. Unweighted and Weighted Sample Sizes for the Base-Year CrossSectional Estimates, by SFA Size, Urbanicity, and Poverty Level ............................. 27

III-1. Percentage of SFAs with All Schools within each Grade Level 

Participating in the NSLP by SFA Characteristics, SY 2011-12................................ 32

III-2. Percentage of SFAs with All Schools within each Grade Level 

Participating in the SBP by SFA Characteristics, SY 2011-12 ................................... 33

III-3. Among SFAs that Participate in the SBP, Percentage of SFAs with 

Schools that Received SBP Severe-Need Reimbursement by SFA 

Characteristics, SY 2011-12............................................................................................. 34

III-4. Percentage of SFAs with Pre-K Programs that Provide Access to School 

Meals, SY 2011-12 ............................................................................................................ 35

III-5. Percentage of Students Approved for Free or Reduced-Price Meals and 

Percentage of Students without Access to the SBP and NSLP, SY 2011-12 .......... 36

III-6. Percentage of Students, in Each Grade Level, Approved to Receive Free 

Meals and Reduced-Price Meals by SFA Characteristics, SY 2011-12 ..................... 38

III-7. Percentage of SFAs with One or More Schools Participating in Other 

Nutrition Programs, SY 2011-12.................................................................................... 40

III-8. Among DoD Fresh Program Participants, the Percentage of SFAs 

Satisfied with the Program, SY 2011-12........................................................................ 41

III-9. Among DoD Fresh Program Participants, the Percentage of SFAs 

Satisfied with Various Aspects of Program by SFA Characteristics, SY 

2011-12............................................................................................................................... 42

III-10. Percentage of SFAs that Participate in the Farm to School Activities by 

SFA Characteristics, SY 2011-12.................................................................................... 43

III-11. Among Farm to School Participants, the Percentage of SFAs that 

Participate in Various Specific Activities, SY 2011-12................................................ 44

III-12. Among SFAs Providing Nutrition Education, the Percentage of SFAs 

that Took Part in Other Farm to School Activities, SY 2011-12 .............................. 44
Contents (continued) 

x 

Tables Page

III-13. Percentage of SFAs Recognized as a HealthierUS School by SFA 

Characteristics, SY 2011-12............................................................................................. 45

IV-1.1. Percentage of SFAs with Directors with Various Levels of Food Service 

and Job Tenure Experience, SY 2011-12...................................................................... 50

IV-1.2. Percentage of SFAs with Directors with Various Tenure Levels by SFA 

Characteristics, SY 2011-12............................................................................................. 50

IV-1.3. Percentage of SFAs with Differing Director Education Requirements by 

SFA Characteristics, SY 2011-12.................................................................................... 51

IV-1.4. Percentage of SFAs with Directors with Different Levels of Education 

by SFA Characteristics, SY 2011-12 .............................................................................. 52

IV-1.5. Percentage of SFAs with Directors with Different Highest Level of 

Education by Total Years of Directors’ Experience, SY 2011-12............................. 53

IV-1.6. Percentage of SFAs with Licensure Requirements as Compared to 

Percentage of SFA Directors who have the Qualifications by SFA 

Characteristics, SY 2011-12 ............................................................................................. 56

IV-1.7. Percentage of SFAs with Directors who are Full-Time or Part-Time by 

SFA Characteristics, SY 2011-12.................................................................................... 57

IV-2.1. Percentage of SFAs Using Different Types of Kitchen Facilities by SFA 

Characteristics, SY 2011-12............................................................................................. 61

IV-2.2. Percntage of SFAs that Used Food Service Facilities for Various Types 

of Reimbursable and Nonreimbursable Meals by SFA Characteristics, SY 

2011-12............................................................................................................................... 62

IV-2.3. Among SFAs that Allow Food Service Facilities to be Used for more 

than SBP and NSLP, the Percentage of SFAs Using those Facilities for 

Other Reimbursable Meals by SFA Characteristics, SY 2011-12.............................. 63

IV-2.4. Among SFAs that Allow Food Service Facilities to be Used for More 

Than SBP and NSLP, the Percentage of SFAs Using those Facilities for 

Nonreimbursable Purposes by SFA Characteristics, SY 2011-12............................. 64

IV-2.5. Percentage of SFAs with Schools Using Various Types of Eating 

Locations by SFA Characteristics, SY 2011-12............................................................ 67
Contents (continued) 

xi

Tables Page

IV-2.6. Among SFAs that have High Schools, the Percentage of SFAs with High 

Schools that Allow Students to Eat Off Campus by SFA Characteristics, 

SY 2011-12 ........................................................................................................................ 70

IV-2.7. Among SFAs that Have Elementary, Middle, High, or Other Schools, the 

Percentage of SFAs with Different After Lunch Student Mobility Policies 

by School Type, SY 2011-12........................................................................................... 71

IV-2.8. Among SFAs that Have Elementary Schools, the Percentage of SFAs 

with Elementary Schools Following Various Lunch and Recess Schedules 

by SFA Characteristics, SY 2011-12 .............................................................................. 72

IV-3.1. Percentage of SFAs with Written Food Safety Plan Based on HACCP 

Principles in Schools by SFA Characteristics, Food Safety Program 

Components, and SFA Director Certification, SY 2011-12....................................... 74

IV-3.2. Percentage of SFAs that Followed Various Food Safety Practices, SY 

2011-12............................................................................................................................... 75

IV-3.3. Percentage of SFAs Using a Food Defense Plan or Food Defense 

Practice by SFA Characteristics, SY 2011-12 ............................................................... 78

IV-3.4. Among SFAs that Used a Food Defense Plan or Practices, the 

Percentage of SFAs Using Various Food Defense Practices by SFA 

Characteristics, SY 2011-12............................................................................................. 79

IV-3.5. Percentage of SFAs with Policies and Procedures to Accommodate 

Students with Special Diets by SFA Characteristics, SY 2011-12 ............................. 79

IV-3.6. Percentage of SFAs that Use Various Types of Food Service Procedures to 

Protect Students with Special Diets by SFA Characteristics, SY 2011-12 ............... 80

IV-3.7. Percentage of SFAs with All, Most, Some, or No Schools having Two or 

More Safety Inspections by SFAs Characteristics, SY 2010-11................................. 81

IV-3.8. Among SFAs that reported their Schools Did Not Have Two Safety 

Inspections, the Percentage of SFAs Citing Various Reasons, SY 2010-11 ............ 82

IV-3.9. Percentage of SFAs that Reported Food Safety Inspections are 

Conducted by Various Types of Agencies by SFA Characteristics, SY 

2010-11............................................................................................................................... 83
Contents (continued) 

xii 

Tables Page

IV-3.10. Percentage of SFAs with One or More Schools Cited for Food Safety 

Inspection Violations by SFA Characteristics, SY 2009-10 ....................................... 84

IV-4.1. Percentage of SFAs that Gave Preference to Purchasing Unprocessed 

Foods that Have Been Locally Grown, Raised, or Produced, SY 2011-12 ............. 91

IV-4.2. Among SFAs Giving Preference to Local Foods, the Percentage of SFAs 

that Do This Always, Sometimes, or Only If they are Priced 

Competitively, SY 2011-12.............................................................................................. 92

IV-4.3. Among SFAs Giving Preference to Local Foods, the Percentage of SFAs 

that Purchase Various Foods and Define Local in Different Ways, SY 

2011-12............................................................................................................................... 92

IV-4.4. Percentage of SFAs that Used Selected Methods to Purchase Foods by 

SFA Size, SY 2011-12 ...................................................................................................... 98

IV-4.5. Percentage of SFAs that Contracted with an FSMC by SFA 

Characteristics, SY 2011-12............................................................................................. 99

IV-5.1. Percentage of SFAs that Used Various Menu Planning Methods by SFA 

Characteristics, SY 2011-12........................................................................................... 103

IV-5.2. Percentage of SFAs that Conducted Nutrition Analysis of Planned 

Menus by SFA Characteristics and Type of Menu Planning System, SY 

2011-12............................................................................................................................. 105

IV-6.1. Percentage of SFAs that Had at least one School that Used Certain 

Technologies to Capture Meal Counts at POS, SY 2011-12.................................... 109

IV-6.2. Percentage of SFAs that Provided Select Training to Cashiers, SY 2011-12 ............... 110

IV-6.3. Percentage of SFAs that Accepted Different Payment Methods, SY 2011-12 ..... 111

IV-7.1. Percentage of SFAs that Reported Meal Alternatives were Offered in 

their Schools by SFA Characteristics, SY 2011-12 .................................................... 116

IV-7.2. Percentage of SFAs by the Strictness of their SFA and State Nutrition 

Standards Policies for School Meals, SY 2011-12...................................................... 117

IV-7.3. Percentage of SFAs by whether their State had an À la carte or Vending 

Machines Policy and the Strictness of their Local Policies, SY 2011-12................ 117
Contents (continued) 

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Tables Page

IV-7.4. Among SFAs that Provide Free Drinking Water during Meals, the 

Percentage of SFAs that Had Various Sources of Water by SFA 

Characteristics, SY 2011-12........................................................................................... 118

IV-7.5. Percentage of SFAs that Take Various Actions When a Student, Not 

Approved for Free Meals, Does Not Have the Money to Pay by SFA 

Characteristics, SY 2011-12........................................................................................... 120

V-1.1. Reimbursement Rates for the NSLP and SBP, SY 2009-10 to SY 2011-12.......... 123

V-1.2. Average Price Charged by SFAs for a Paid Student Breakfast and Lunch, 

SY 2009-10 to SY 2011-12 ............................................................................................ 126

V-1.3. SFA’s Average Meal Prices, Reimbursement Rates, and Revenues per 

Meal for the NSLP and SBP by Grade Level, SY 2010-11 ...................................... 127

V-1.4. Price Increases for Paid Student Breakfasts and Lunches, SY 2009-10 to 

SY 2011-12 ...................................................................................................................... 129

V-1.5. Patterns of Price Change in the NSLP and SBP across Two Periods: SY 

2009-10 to SY 2010-11 and SY 2010-11 to SY 2011-12........................................... 130

V-1.6. SFAs’ Average Difference in Revenues per Meal, SY 2010-11 versus SY 

2011-12............................................................................................................................. 131

V-1.7. Comparison of the Average Price Charged by SFAs for Adult Meals to 

the Minimum Price Guidance by Grade Level, SY 2011-12.................................... 132

V-1.8. NSLP Minimum Nutrient and Calorie Requirements: Nutrient Standard 

Menu Approaches (School Week Averages) .............................................................. 133

V-1.9. NSLP and SBP Reimbursement Rates for Free School Meals and 

Average Prices for Paid Meals, SY 2009-10 to SY 2011-12 ..................................... 134

V-1.10. Top Four Strategies SFAs Report Their LEA Used to Avoid Increasing 

the Price of Paid NSLP and SBP Student Meals, SY 2011-12 versus SY 

1988-89............................................................................................................................. 135

V-2.1. Percentage of SFAs by Daily Food Service Expenditures per ADA, SY 

2010-11............................................................................................................................. 140

V-2.2. SFAs’ Daily Food Service Cash Expenditure per ADA by SFA 

Characteristics, SY 2010-11........................................................................................... 141
Contents (continued) 

xiv 

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V-2.3. On Average, the Percentage of SFAs’ Cash Expenditures Spent on 

Various Inputs, SY 2010-11 .......................................................................................... 142

V-2.4. Percentage of SFAs Reporting they were Charged for Indirect Costs by 

SFA Characteristics, SY 2010-11.................................................................................. 143

V-2.5. Percentage of SFAs by Daily Cash Receipts per ADA, SY 2010-11 ...................... 144

V-2.6. SFA’s Daily Cash Receipts per ADA by SFA Characteristics, SY 2010-11........... 145

V-2.7. Percentage of SFAs by Annual Cash Receipts as a Percentage of Cash 

Expenditures, SY 2010-11............................................................................................. 146

V-2.8. Percent of SFAs Operating At or Above the Break-Even Level by SFA 

Characteristics, SY 2010-11........................................................................................... 147

V-2.9. Among SFAs with Unpaid Meal Costs, the Percentage of SFAs with 

Various Practices for Providing a Meal to Students Who Cannot Pay, SY 

2010-11............................................................................................................................. 148

V-2.10. Among SFAs with Unpaid Meal Costs, the Percentage of SFAs that 

Took Various Actions to Recover Costs from Unpaid Meals, SY 2011-12 .......... 148

V-2.11. Among SFAs with Unrecovered Lost Revenue from Unpaid Meals, the 

Percentage of SFAs with Various Magnitudes of Losses, SY 2010-11................... 149

V-2.12. Among SFAs with Unrecovered Lost Revenues from Unpaid Meals, the 

Percentage of SFAs by Break-Even Status given Actual Lost Revenues 

versus the Assumption All Unpaid Revenues were Recovered, SY 2010-11 ........ 150

VI-1.1. Percentage of States that Used Various Methods to Communicate with 

SFAs by Topic, SY 2011-12.......................................................................................... 154

VI-1.2. Percentage of SFAs that Used Various Methods to Communicate to 

School Staff by SFA Characteristics, SY 2011-12...................................................... 156

VI-1.3. Percentage of SFAs that Used Various Methods to Communicate with 

Individual Households by SFA Characteristics, SY 2011-12 ................................... 157

VI-1.4. Percentage of SFAs that Communicated to Households on Various 

Topics by SFA Characteristics, SY 2011-12 ............................................................... 158
Contents (continued) 

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VI-1.5. Percentage of SFAs that Received and Communicated Information about 

Food Holds/Recalls by Various Methods, SY 2011-12............................................ 159

VI-2.1. Percentage of States Providing Different Types of Subsidies and Support 

for School Meals, SY 2010-11 ...................................................................................... 163

VI-2.2. Percentage of States that Reported Various Food Service Program Areas 

were Affected by State Budget Issues, SY 2011-12................................................... 164

VI-3.1. Number and Percentage of SFAs and Schools in Each State Operating 

under Provision 2 or Provision 3, SY 2011-12........................................................... 170

VI-3.2. Among the States that Used Direct Verification, the Percentage of States 

that Used Various Implementation Procedures, SY 2011-12 .................................. 172

VI-3.3. Percentage of States by Use of Direct Verification and Future Plans, SY 

2011-12............................................................................................................................. 173

VI-3.4. Percentage of States with Policies for Providing Meals When Students 

Are Unable to Pay, SY 2011-12.................................................................................... 174

VI-3.5. Percentage of States that Used Various Warehouses Practices for USDA 

Foods, SY 2011-12 ......................................................................................................... 175

VI-3.6. Among SFAs that Used FSMCs, the Percentage of SFAs and Schools by 

the type of FSMC used as Reported by State Directors, SY 2011-12..................... 176

VI-3.7. Among SFAs that Used National FSMCs, the Percentage of SFAs and 

Schools that Used Specific Companies as Reported by State Directors, 

SY 2011-12 ...................................................................................................................... 176

VI-3.8. Use and Review of State-Developed Prototype Contracts for Food 

Service Management Companies (SY 2011-12) ......................................................... 177

VI-3.9. Percentage of States with Different Policies Governing Food Recalls and 

Notification of District-Level Personnel, SY 2011-12.............................................. 178

VI-3.10. Nutritional Standards for Food and Beverages Offered in School Meals, 

SY 2011-12 ...................................................................................................................... 179

VI-3.11. Number of Charter Schools Operating in Each State and Participating in 

NSLP and SBP, SY 2011-12 ......................................................................................... 181
Contents (continued) 

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VI-4.1. Percentage of States Providing School Meal Training and Technical 

Assistance by Topic and Frequency, SY 2011-12...................................................... 184

VI-4.2. Percentage of States that Used Various Approaches for Training and 

Technical Assistance, SY 2011-12................................................................................ 185

C-1. Base Weights for the SN-OPS SFA Sample ............................................................... C-2

C-2. Distribution of the SFA Sample by Survey Response Status ................................... C-3

C-3. Definition of Nonresponse Adjustment Cells ........................................................... C-4

C-4. JKN and FPC Factors to Be Used for Variance Estimation ................................... C-5

D-1. Sample Sizes by Response Status, Response Rates, and Test of 

Association Between Response Status and Selected Characteristics of 

Sampled SFAs ................................................................................................................. D-3

D-2. Comparison of Weighted Distributions of Sampled SFAs, by Response 

Status and Selected Characteristics............................................................................... D-4

D-2. Comparison of Weighted Distributions of Sampled SFAs, by Response 

Status and Selected Characteristics (continued) ......................................................... D-5

D-3. Comparison of Weighted Estimates of FNS-742 Frame Statistics for 

Sampled SFAs, by Response Status and Selected SFA Characteristics .................. D-8

D-4. Comparison of Weighted Estimates of Select Survey Statistics Before and 

After Nonresponse Adjustment, by Response Status ............................................... D-9

E-1. Educational Requirements and Years of Experience for State CN 

Directors, SY 2011-12.................................................................................................... E-1

E-2. Percent of SFAs where all schools had two or more safety inspections, by 

SFA Characteristics for SY 2008-09, SY 2009-10, and SY 2010-11 ....................... E-3

E-3. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price 

Lunches in Elementary Schools, SY 2009-10, SY 2010-11, and SY 2011-12........ E-4

E-4. Distribution of NSLP Meal Prices for Full-Price Lunches in Elementary 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12.................................................. E-5

E-5. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price 

Lunches in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12................ E-6
Contents (continued) 

xvii 

Tables Page

E-6. Distribution of NSLP Meal Prices for Full-Price Lunches in Middle 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12.................................................. E-7

E-7. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price 

Lunches in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12 ................... E-8

E-8. Distribution of NSLP Meal Prices for Full-Price Lunches in HighSchools, SY 2009-10, SY 2010-11, and SY 2011-12.................................................. E-9

E-9. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price 

Lunches in Elementary Schools, SY 2009-10, SY 2010-11, and SY 2011-12...... E-10

E-10. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price 

Lunches in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12.............. E-11

E-11. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price 

Lunches in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12 ................. E-12

E-12. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches 

in Elementary Schools, SY 2009-10, SY 2010-11, and SY 2011-12...................... E-13

E-13. Distribution of NSLP Meal Prices for Adult Lunches in Elementary 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12................................................ E-14

E-14. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches 

in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12.............................. E-15

E-15. Distribution of NSLP Meal Prices for Adult Lunches in Middle Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12................................................................ E-16

E-16. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches 

in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12 ................................. E-17

E-17. Distribution of NSLP Meal Prices for Adult Lunches in High Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12................................................................ E-18

E-18. Median, Minimum, and Maximum SBP Meal Prices for Full-Price 

Breakfasts in Elementary Schools, SY 2009-10, SY 2010-11, and SY 

2011-12........................................................................................................................... E-19

E-19. Distribution of SBP Meal Prices for Full-Price Breakfasts in Elementary 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12................................................ E-20
Contents (continued) 

xviii 

Tables Page

E-20. Median, Minimum, and Maximum SBP Meal Prices for Full-Price 

Breakfasts in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12........... E-21

E-21. Distribution of SBP Meal Prices for Full-Price Breakfasts in Middle 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12................................................ E-22

E-22. Median, Minimum, and Maximum SBP Meal Prices for Full-Price 

Breakfasts in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12.............. E-23

E-23. Distribution of SBP Meal Prices for Full Price Breakfasts in High 

Schools, SY 2009-10, SY 2010-11, and SY 2011-12................................................ E-24

E-24. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price 

Breakfasts in Elementary Schools, SY 2009-10, SY 2010-11, and SY 

2011-12........................................................................................................................... E-25

E-25. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price 

Breakfasts in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12........... E-26

E-26. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price 

Breakfasts in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12.............. E-27

E-27. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts 

in Elementary Schools, SY 2009-10, SY 2010-11, and SY 2011-12...................... E-28

E-28. Distribution of SBP Meal Prices for Adult Breakfasts in Elementary 

Schools, SY 2009-10, SY 2010-11, and SY2011-12................................................. E-29

E-29. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts 

in Middle Schools, SY 2009-10, SY 2010-11, and SY 2011-12.............................. E-30

E-30. Distribution of SBP Meal Prices for Adult Breakfasts in Middle Schools, 

SY 2009-10, SY2010-11, and SY 2011-12................................................................. E-31

E-31. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts 

in High Schools, SY 2009-10, SY 2010-11, and SY 2011-12 ................................. E-32

E-32. Distribution of SBP Meal Prices for Adult Breakfasts in High Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12................................................................ E-33

E-33. USDA Meal Reimbursements as a Percent of Total Revenue: 

Distribution of SFAs, SY 2010-11 ............................................................................. E-34
Contents (continued) 

xix 

Tables Page

E-34. Student Payments for Reimbursable Meals as a Percent of Total 

Revenue: Distribution of SFAs, SY 2010-11............................................................ E-34

E-35. State and Local Funds as a Percent of Total Revenue: Distribution of 

SFAs, SY 2010-11......................................................................................................... E-35

E-36. Non-Reimbursable Sales as a Percent of Total Revenue: Distribution of 

SFAs, SY 2010-11......................................................................................................... E-35

E-37. Type and Dollar Amount of State Subsidies for Breakfast to SFAs in 

Each State, SY 2010-11................................................................................................ E-36

E-38. Type and Dollar Amount of State Subsidies for Lunch to SFAs in Each 

State, SY 2010-11.......................................................................................................... E-37

E-39. Number of SFAs and Schools Using FSMC in Each State, SY 2011-12 ............. E-38

E-40. Number of Charter Schools Participating in the NSLP and SBP as 

Separate SFAs or Part of a Larger SFA in Each State, SY 2011-12...................... E-39

Figures Page

I-1. Percentage of SFAs with Certification Requirements as Compared to the 

Percentage of SFA Directors Holding the Qualification, SY 2011-12 ........................5

III-1. NSLP Student Participation, 1969-2012 ....................................................................... 30

IV-1.1. Percentage of SFA with Certification Requirements as Compared to the 

Percentage of SFA Directors Holding the Qualification, SY 2011-12 ..................... 54

IV-2.1. Percentage of SFAs Using Different Types of Meal Service Systems, SY 

2011-12............................................................................................................................... 65

IV-2.2. Percentage of SFAs with Various Average Times Allotted for Breakfast 

by Type of School, SY 2011-12...................................................................................... 68

IV-2.3. Percentage of SFAs with Various Average Times Allotted for Lunch by 

Type of School, SY 2011-12 ........................................................................................... 69

IV-3.1. Percentage of SFAs with Differing Proportion of Schools that Have at 

least One Food Service Supervisor or Manager with Food Safety 

Certification, FY 2011-12................................................................................................ 76
Contents (continued) 

xx

Figures Page

IV-3.2. Percentage of SFAs Using USDA Materials to Assist in Food Safety, FY 

2011-12............................................................................................................................... 77

IV-3.3. Among SFAs with Schools Cited for Food Safety Violations, the 

Percentage of SFAs with All, Most, Some, and No Schools having 

Various Types of Violations............................................................................................ 85

IV-3.4. Percentage of SFAs that Receive Alerts about Food Recalls via Various 

Methods, SY 2011-12....................................................................................................... 86

IV-3.5. Percentage of SFAs that Use Various Methods to Alert Schools about 

Holds or Food Recalls, SY 2011-12............................................................................... 87

IV-4.1 Percentage of SFAs Obtaining Nutrition Information for Foods Via 

Various Methods, SY 2011-12........................................................................................ 93

IV-4.2. Percentage of SFAs that Specify Nutrient Requirements for a Single 

Serving When Ordering Food, SY 2011-12.................................................................. 94

IV-4.3. Percentage of SFAs Satisfied with the Availability of Nutrition 

Information, SY 2011-12................................................................................................. 94

IV-4.4. Percentage of SFAs that Specify Per-Serving Nutrient Requirements by 

Food Type, SY 2011-12................................................................................................... 95

IV-4.5. Percentage of SFAs that Require Various Nutrition Information from 

Food Vendors, SY 2011-12............................................................................................. 96

IV-4.6. Percentage of SFAs that Received Requested Nutritional Information 

from Vendors, SY 2011-12 ............................................................................................. 97

IV-4.7. Percentage of SFAs that Used Various Methods to Purchase Foods, SY 

2011-12............................................................................................................................... 97

IV-4.8. Among SFAs that Used a FSMC, the Percentage of SFAs that Used 

Various Methods to Track Rebates, Discounts, or Fees, SY 2011-12.................... 100

IV-6.1. Percentage of SFAs that Conducted Onsite Monitoring of Cashiers, SY 

2011-12............................................................................................................................. 111

IV-7.1. Percentage of SFAs that Offered Alternatives to SBP and NSLP Meals, 

SY 2011-12 ...................................................................................................................... 115
Contents (continued) 

xxi

Figures Page

VI-1.1. Percentage of SFAs that Reported their State Communicated to them by 

Various Methods, SY 2011-12...................................................................................... 155

VI-2.1. Percentage of States Providing Subsidies for Meals to SFAs, SY 2010-11............ 162

VI-3.1. Percentage of States with at Least One SFA that Used Direct 

Verification, SY 2011-12................................................................................................ 171

VI-3.2. Among Those that Have Charter Schools that Participated in NSLP or 

SBP, the Percentage of States by Various Charter School-SFA 

Relationships, SY 2011-12 ............................................................................................. 182

E-1. Safety Topics on Which Food Service Employees Have Been Trained ................ E-2

1 

Section I: Executive Summary 

Background and Purpose of the Study 

The National School Lunch Program (NSLP) and the School Breakfast Program (SBP) are 

the two largest school-based child nutrition (CN) programs providing meals and snacks to millions 

of school-age children every day. Since its inception in 1946, when malnourishment was a 

nationwide concern, the program has focused on improving the health and well-being of the 

Nation’s children through the provision of CN programs. More recently, concern has shifted from 

malnutrition to childhood obesity and the nutritional quality of school meals. After expert review, 

the Institute of Medicine (IOM) in the 2009 report, School Meals: Building Blocks for Healthy Children, 

recommended that the U.S. Department of Agriculture (USDA) adopt revised standards for menu 

planning, including (1) increasing the amount and variety of fruits, vegetables, and whole grains; (2) 

setting minimum and maximum levels of calories; and (3) focusing more on reducing saturated fat 

and sodium. These recommendations were incorporated into the Healthy, Hunger-Free Kids Act 

(HHFKA) in 2010 and resulted in USDA revising the CN program requirements. While the 

HHFKA is a very comprehensive bill that includes over 70 sections divided among four titles, 

several of the provisions are particularly important for school food operations and include:

 School meal pattern standards: the HHFKA required USDA to issue a proposed rule 

within 18 months to update meal pattern requirements for the NSLP and the SBP. 

 Competitive foods standards: the HHFKA provided USDA the authority to set 

nutrition standards for all foods regularly sold in schools during the school day, 

including vending machines, the à la carte lunch lines, and school stores. 

 Professional standards: the HHFKA required USDA to establish a program of required 

education, training, and certification for various categories of school food service staff. 

 School lunch pricing and accounting: the HHFKA required USDA to administer a 

number of provisions related to equitable school lunch pricing and strengthened 

accounting procedures for the sale of non-program foods. 

The implementation timeline for the new requirements began in late 2010 and continues 

through school year (SY) 2013-14, with the meal pattern changes being phased in starting in SY 

2012-13. Given the number of students participating in NSLP and SBP, there is a realization that the 

quality and nutrient content of school meals is one way to improve children’s diets and potentially 

reduce the obesity problem as well as improve food security and help children’s readiness to learn. 

The Special Nutrition Program Operations Study (SN-OPS) is a multiyear study designed to 

provide the USDA’s Food and Nutrition Service (FNS) with a snapshot of current state and School 

Food Authority (SFA) policies and practices and a baseline for observing the improvements 

resulting from the implementation of the HHFKA. The SN-OPS base-year activities involved 

collecting data via surveys from all state CN directors and a stratified sample of SFA directors, 

which was weighted to represent the population of SFAs. The study provides FNS with key 

information about the characteristics, ongoing efficiency, and effectiveness of the school meals 
2 

programs so FNS has a better understanding of what is happening at the state and local levels and 

then can address program policy needs, develop informed regulations and guidance, and provide 

needed technical assistance. 

Participation 

Participation levels in the school meals programs, especially among students certified for free 

or reduced-price meals (F/RP), measure the degree to which the programs are successful in reaching 

low-income children. In addition, because NSLP and SBP reimbursements are tied to the number of 

meals served, student participation data are important for Federal budgeting and planning purposes. 

Changes in participation levels over time as compared to SY 2011-12 may provide one early (albeit 

gross) indication of how schools and students react to the implementation of the provisions 

included in the HHFKA. 

Table I-1 shows that school participation in the NSLP was nearly universal, and participation 

in the SBP was high. As the table shows, 97 percent of SFAs had all their schools participating in the 

NSLP. Participation in the SBP was similar, albeit a bit lower, and 79 percent of SFAs had all their 

schools participating in the program. 

Table I-1. Percentage of SFAs with All Schools within each Grade Level Participating in 

the NSLP and the SBP, SY 2011-12

Program Elementary Middle High Other All schools

NSLP 99.1% 99.7% 99.0% 92.7% 96.6%

SBP 85.9 88.2 88.1 77.8 78.8

Weighted n 12,495 9,410 10,828 4,569 14,533

Unweighted n

1

1,281 1,097 1,182 547 1,389

1

n is less than 1,401 because not all SFAs have each type of school, and 12 SFAs provided implausible school count data. 

Data Source: SFA Director Survey 2011, question 2.1. 

While all students who attend a school that participates in the NSLP and SBP can participate 

in the program by selecting a reimbursable meal, student eligibility to get F/RP meals is based on the 

combination of household size and income. Students living in families earning at or below 130 

percent of poverty qualify for free meals. In addition, students are categorically eligible for free 

school meals if they or any member of the household receives benefits from certain assistance 

programs. Students living in families with incomes between 131 percent and 185 percent of poverty 

qualify for reduced-price meals. 

As shown in Table I-2, SFA directors reported that over half (51 percent) of their students 

were approved for either F/RP meals during SY 2011-12. Forty-four percent of students in all 

schools were approved to receive free meals during SY 2011-12. Additionally, SFAs reported that 7 

percent of students were approved for reduced-price meals. These percentages were fairly consistent 

across school levels. 

While school participation in the NSLP and SBP was very high, access to school meals at the 

student level was not universal. SFA directors reported that, overall, 7 percent of students did not 

have access to the SBP, and 2 percent did not have access to the NSLP during SY 2011-12. Students 
3 

did not have access to the programs because either their schools did not participate or they were 

attending half-day kindergarten and did not have access to meals. Students enrolled in schools with 

nontraditional grade spans (“Other” schools) were the least likely to have access to the SBP (15

percent were without access) and the NSLP (6 percent were without access) compared with 

elementary, middle, and high schools.

Table I-2. Percentage of Students Approved for Free or Reduced-Price Meals and 

Percentage of Students without Access to the SBP and NSLP, SY 2011-12

Student group

Percentage of students

Elementary Middle High Other All schools

Approved to receive free meals 48.8% 42.6% 36.9% 41.5% 43.9%

Approved to receive reduced-price meals 7.0 7.5 6.7 6.9 7.0

Students without access to the SBP 7.2 6.5 5.7 14.5 6.9

Students without access to the NSLP 2.1 1.7 2.5 5.7 2.3

Total student enrollment: weighted n 23,049,561 9,106,558 13,786,311 2,132,498 48,074,928

Total SFAs: weighted n

1

12,269 9,158 10,488 4,450 14,281

1

n is less than 14,678 weighted (1,401 unweighted) because not all SFAs have each type of school and item non-response. 

Data Source: SFA Director Survey 2011, question 3.1. 

In addition to participating in the NSLP and SBP, SFAs and their schools have opportunities 

to participate in several other FNS-administered programs and initiatives that are intended to 

complement the core breakfast and lunch programs. These other programs and initiatives extend 

meal service beyond lunch and breakfast (NSLP After-School Snack Program and the Child and 

Adult Care Food Program (CACFP) At-Risk Afterschool Snack or Supper Program), offer meal 

service in the summer (Summer Food Service Program (SFSP)), provide access to and information 

about fruits and vegetables during the school day (Fresh Fruit and Vegetable Program (FFVP) and 

farm to school activities) and promote a healthier school environment (Healthier US Schools 

Challenge (HUSSC)). Additionally, some SFAs utilize the DoD Fresh Program as a purchasing 

alternative to obtain fresh fruits and vegetables. Table I-3 shows that about one-third of SFAs had at 

least one school that participated in NSLP Afterschool Snack Program or SFSP that extended meal 

services beyond school year breakfast and lunch. SFA participation in the fresh fruit and vegetable 

programs also was substantial, with 20 percent of SFAs having at least one school engaged in the 

farm to school activities, 26 percent participating in the DoD Fresh Program, and 35 percent 

participating in the FFVP. DoD Fresh and FFVP both target increasing the quantities of fresh fruits 

and vegetables in students’ diets, and 45 percent (not shown) of SFAs had schools participating in at 

least one of these programs. Far fewer SFAs had schools participating in the CACFP At-Risk 

Afterschool Snack or Supper Program, which can only be offered in areas where at least 50 percent 

of the students are eligible for F/RP meals. Similarly, only 6 percent of SFAs had schools in the 

HUSSC voluntary initiative that recognizes participating schools that meet a relatively high standard 

for healthier school environments through the promotion of nutrition and physical activity. 
4 

Table I-3. Percentage of SFAs with One or More Schools Participating in Other Nutrition 

Programs and Initiatives, SY 2011-12

Program Percentage of SFAs

Total SFAs

Weighted n Unweighted n

1

USDA FFVP 

NSLP Afterschool Snack Program

SFSP

DoD Fresh

Farm to school

CACFP At-Risk Afterschool Snack or Supper Program

HUSSC (received an award)

34.7%

31.9

30.0

26.0

20.4

4.4

5.6

14,544

14,544

14,544

14,544

14,530

14,533

14,678

1,392

1,392

1,392

1,392

1,391

1,392

1,401

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 11.1 and 11.2. 

SFA Operations 

The resources and methods SFAs use to produce school meals will likely affect how quickly 

they can adapt to the new regulations stemming from the HHFKA. During this period of change, it 

is important to examine the current status of SFA operations to provide insight into how prepared 

they are to adopt and respond to changes brought about as a result of the HHFKA and identify 

potential transition challenges. 

One provision contained in the HHFKA relates to professional standards for school food 

service and state agency directors. USDA is required to establish a program of required education, 

training, and certification for all SFA directors and establish criteria and standards for states to use in 

the selection of state agency directors responsible for the CN programs. USDA may contract with 

universities and professional associations to establish and manage the program. At the time of this 

report, USDA was in the process of finalizing proposed regulations related to professional 

standards. Although the majority of SFAs had director-level professional food service training 

requirements, 42 percent (not shown) of the SFA directors indicated that their district did not 

require any of the certifications listed in the questionnaire. Figure I-1 shows the training 

requirements SFAs had for their directors relative to the percentage of SFA directors who held these 

qualifications. The most commonly reported district requirement was to be certified as a ServSafe 

Food Safety professional; this was also the most common credential held among SFA directors. 

Given the current certification and training profile of SFA directors, it is highly likely that new 

minimum requirements for SFA directors will affect the majority of SFAs.
5 

Figure I-1. Percentage of SFAs with Certification Requirements as Compared to the 

Percentage of SFA Directors Holding the Qualification, SY 2011-12

n is less than 14,678 weighted (1,401 unweighted) because of item non-response. The estimate for question 14.6 on district requirements is 

based on 14,250 weighted (1,376 unweighted) responses, and the estimates for question 14.7 on certifications held by current SFA directors is 

based on 14,267 total (1,378 unweighted). Multiple responses were allowed. 

Data Source: SFA Director Survey 2011, questions 14.6 and 14.7. 

The updated school meal patterns for NSLP and SBP meals require schools to increase the 

availability of fruits, vegetables, whole grains, and fat-free and low-fat fluid milk in school meals; 

reduce the levels of sodium, saturated fat, and trans fat in meals; and meet the nutrition needs of 

school children within their age/grade calorie requirements. The new school meal patterns are being 

phased in starting in SY 2012-13. The USDA also established science-based nutrition standards for 

foods and beverages sold in schools (throughout the school campus and the school day) outside of 

the school meals program that will affect the competitive (also called alternative) foods available to 

students. These updated competitive food standards will be implemented by the beginning of SY 

2014-15. In addition, the regulation codified previously issued guidance on the need for schools to 

make available free drinking water during the lunch meal service, which began in SY 2011-12.

Many SFAs already engage in activities in line with many of the provisions in the HHFKA. 

For example, many SFAs participated in FNS programs promoting fresh fruits and vegetables. Table 

I-4 shows that 51 percent of SFAs gave geographical preference to locally grown or local raised 

agricultural products at least some of the time. However, within this group only 8 percent reported 

that they gave local preference most of the time. Not surprisingly, prices appear to be an important 

factor driving purchasing behavior, and about one-third (not shown) of the SFA directors reported 

only purchasing local foods when they were competitively priced. 

SFAs have varying types of kitchen facilities and meal service systems available at their 

schools, which affect the options they have for producing nutritious meals and whether the food is 

41.3

28.5

25.3

22.3

11.4

2.8

54.8

37.0

31.8

30.4

17.2

5.6

0.0 10.0 20.0 30.0 40.0 50.0 60.0

Certified ServSafe Food 

Safety Professional

Certified Professional 

in Food Safety

Certified Professional 

Food Handler

Certified Professional 

Food Manager

School Nutrition Specialist

Licensed Dietitian

Percentage of SFAs

Certifications Held Certification Requirements
6 

prepared fresh onsite or cooked at a central site with final preparation or reheating at the local site. 

An SFA’s kitchen facilities affect both the number and types (e.g., staff training) of changes that 

must occur to implement the new regulations stemming from the HHFKA. Table I-4 shows the 

percentage of SFAs with select operational characteristics. It is noteworthy that 55 percent of SFAs 

have only onsite kitchens at the individual schools, while 17 percent have only centralized (offsite) 

kitchens, and the remaining 29 percent have a mixture. Similarly, 21 percent of SFAs used Food 

Service Management Companies (FSMCs) to manage the food service operations in at least some of 

their schools. 

Table I-4. Percentage of SFAs with Select Operational Characteristics, SY 2011-12 

Operational characteristics

Percentage of SFAs with select 

operational characteristics

Total SFAs

Weighted

n

Unweighted 

n

Gave preference to purchasing local foods

Most of the time

Some of the time

Never

8.3%

42.7

49.0

14,540 1,3931

Type of kitchen

Only offsite

Only onsite

Combination

16.5

54.7

28.8

14,422 1,3881

Used food service management company 20.8 14,494 1,3891

Menu planning method 

Food based

Nutrient base

New or innovative

Combination

Other 

71.8

12.9

0.3

13.2

1.7

14,621 1,3971

Competitive foods offered in schools

À la carte at breakfast

À la carte at lunch

Vending machines

Snack bar

School store

Alternative food source

53.2

70.9

29.4

19.0

15.4

10.8

14,678 1,401

Offered potable water with meals

Elementary schools

Middle schools

High schools

Other schools

97.3

97.7

98.5

76.9

12,639

9,499

10,863

4,594

1,2922

1,1062

1,1882

5512

1

n is less than 1,401 due to item non-response. 

2

n is less than 1,401 because not all SFAs have each type of school. 

Data Source: SFA Director Survey 2011, questions 4.3, 4.10, 4.16, 4.19, 10.1, and 10.12. 

Starting in the 2012-13 school year, food-based menu planning was required for the NSLP1

and in SY 2013-14 it will be extended to the SBP. As Table I-4 shows, 72 percent of the SFAs used 

the food-based (traditional or enhanced) approach; 13 percent used the nutrient-based (NuMenus or 

 

1 Federal Register, Vol. 77, No. 17, January 26, 2012.
7 

Assisted NuMenus) approach; and 13 percent used a combination of food- and nutrient-based menu 

planning approaches in SY 2011-12. Overall, traditional food-based menu planning was the most 

frequently used approach. The fact that the majority of SFAs already were using food-based menu 

planning or a combination approach should help ease the transition to the new regulations.

Competitive foods are widely offered by most SFAs, and 80 percent (not shown) reported 

that their schools provided at least one competitive food source venue such as à la carte items at 

meals, vending machines, or school stores. As Table I-4 shows, the most common competitive food 

source was offering à la carte items during breakfast (53 percent) and lunch (71 percent); in addition,

29 percent of SFAs reported their schools had vending machines; 19 percent had snack bars; and 26

percent had other competitive food venues, including school stores. Given the widespread practice 

of offering competitive foods through multiple venues, the new regulations on competitive foods 

will affect the majority of SFAs. It should be noted, however, that 28 percent (not shown) of SFAs 

had local policies on à la carte items and vending machines. Similarly, 59 percent (not shown) of the 

SFAs are in states that had à la carte policies, and 66 percent (not shown) reside in states with 

vending machine policies. The transition to the new regulations may prove to be easier for SFAs in 

states and localities with existing policies. 

As part of encouraging healthy eating, the HHFKA also dictated that schools need to make 

potable water available at lunch time. This provision was to be implemented no later than SY 2011-

12. For elementary, middle, and high schools, 97 to 98 percent of SFAs said they provided potable 

water with meals. For the much smaller group of SFAs with other types of schools, only 77 percent 

said they provided water with meals at these schools. 

Starting in SY 2005-06, SFAs were required to implement a food safety program to ensure 

the meals served in schools were safe. The HHFKA reinforces this focus on food safety by requiring 

that schools continue to receive two food safety inspections a year and that the food safety program 

applies to the entire school campus. Table I-5 shows that nearly all SFAs (96 percent) reported that 

all schools in their district had a written food safety plan based on hazard analysis and critical control 

points (HACCP) principles by SY 2011-22. Overall, only 4 percent of the all SFAs reported that 

only some or none of their schools had written plans. About 84 percent of SFAs reported that all of 

their schools had two or more safety inspections during SY 2010-11, and another 8 percent said that 

most or some schools had two or more safety inspections. Eight percent of SFAs reported that 

none of their schools had two or more safety inspections during SY 2010-11. 
8 

Table I-5. Percentage of SFAs with Various Shares of their Schools having Food Safety 

Plans and Regular Inspections, SY 2011-12

Food safety plans and inspections

Percentage of 

SFAs 

Total SFAs

Weighted n Unweighted n

1

Share of schools with food safety plans

All schools

Most or some schools

No schools

95.6%

1.8

2.6

14,439 1,3871

Share of schools having two or more safety inspections 

annually

All schools 

Most or some schools

No schools

84.2

7.7

8.1

14,418 1,3861

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 12.1 and 12.7a. 

SFA Finances 

SFAs operate under tight financial constraints and within the policy and regulatory 

boundaries set by the Federal government, their states, and their local education agency (LEA). Four 

facts heavily dictate SFA’s financial operations:

 SFAs must operate on a nonprofit basis. 

 They are reimbursed for NSLP and SBP meals at rates set by the Federal government as 

shown in Table I-6. 

 The maximum price they can charge for reduced-price meals is set by Federal regulations. 

 The price they can charge for a paid reimbursable meal is set by their LEA. 

In many ways an SFA may be viewed as a nonprofit business that produces reimbursable food items 

as well as a variety of competitive foods and must set the prices for each of its different products so 

that at the end of the year it breaks even (revenue equals cost). 

Table I-6. Reimbursement Rates for the NSLP and SBP, SY 2009-10 to SY 2011-12

Income-eligibility 

category

SY 2009-10 

reimbursement rates

SY 2010-11 

reimbursement rates

SY 2011-12 

reimbursement rates

Breakfast Lunch Breakfast Lunch Breakfast Lunch

Free $1.46 $2.68 $1.48 $2.72 $1.51 $2.77

Reduced-price 1.16 2.28 1.18 2.32 1.21 2.37

Paid 0.26 0.25 0.26 0.26 0.27 0.26
9 

Meal Prices 

In addition to updating and strengthening nutrition standards for school meals and other 

foods sold in schools, the HHFKA requires SFAs to make changes in the pricing structure of all 

foods sold in schools. A key change is the Paid Meal Equity Provision that requires SFAs to provide 

the same level of financial support for lunches sold to students who have been approved for F/RP 

meals and students who must pay full price. This can be accomplished either through gradually 

raising the prices of paid lunches or through providing the equivalent funds from non-Federal 

sources. There is an additional provision that requires SFAs to set the prices of competitive foods 

basically at levels no less than the cost of these foods.2

The Paid Meal Equity Provision that went into effect in July 2011 is expected to result in an 

increase in prices for a paid school lunch over time. Under the HHFKA rules, SFAs have to raise 

their prices over time on school lunches so they match the Federal reimbursement for free lunch 

minus and the Federal reimbursement for paid lunches. Table I-7 presents the status of meal pricing 

and reimbursements in SY 2010-11, the year just prior to the Paid Meal Equity Provision going into 

effect. As the table shows, on average, SFAs (specifically their LEAs) set the price of a paid meal at 

levels below the Federal reimbursement rates for free meals. Considering the prices charged for a 

paid meal along with the reimbursement rates for paid and free meals, Table I-7 reveals that, on 

average, SFAs receive about the same per unit revenues on free and paid breakfasts but get more 

revenue on free lunches as compared to paid lunches. 

Table I-7. SFA’s Average Meal Prices, Reimbursement Rates, and Revenues per Meal for 

the NSLP and SBP by Grade Level, SY 2010-11

SFA’s average meal prices, reimbursement rates, and revenues per 

meal

Elementary Middle High

Breakfast

Paid meal price $1.15 $1.23 $1.24

Paid meal reimbursement rate 0.26 0.26 0.26

Paid meal revenues 1.41 1.49 1.50

Free meal reimbursement rate and revenues 1.48 1.48 1.48

Difference in revenue -0.07 0.01 -0.02

Weighted n

1

9,792 7,437 8,813

Lunch

Paid meal price $1.91 $2.14 $2.14

Paid meal reimbursement rate 0.26 0.26 0.26

Paid meal revenues 2.18 2.40 2.40

Free meal reimbursement rate and revenues 2.72 2.72 2.72

Difference in revenue -0.54 -0.32 -0.32

Weighted n

1

11,763 8,888 10,314

1

n is less than 14,678 because not all SFAs participate in the SBP or have each type of school and item non-response. 

 

2 “National School Lunch Program: School Food Service Account Revenue Amendments Related to the Healthy, Hunger-Free Kids 

Act of 2010,” Federal Register, Vol. 76, No. 117, June 17, 2011, p. 35301. Available at http://www.fns.usda.gov/cnd/governance/ 

regulations/2011-06-17.pdfRevenue. 
10

Based on the prices charged for a paid meal in SY 2010-11, under the Paid Meal Equity 

Provision, SFAs were going to have to raise average school lunch prices by about 30 to 50 cents 

gradually over time or provide off-setting non-Federal subsidies. SFAs could continue to charge 

different prices across grade levels so long as the average price of paid claimed meals was brought in 

line with the difference in the reimbursement rates. As this study did not collect data on meals 

claimed, we cannot precisely estimate the number of SFAs expected to be affected by the price 

changes. However, the SY 2010-11 price data suggested that the majority of SFAs were going to be 

affected by the Paid Meal Equity Provision because over 90 percent of SFAs (not shown) had paid 

lunch prices in elementary schools that were below the target price and over 80 percent (not shown) 

had paid lunch prices in middle and high schools that were below the target price. In any given year, 

any required price increase is limited to a maximum of 10 cents, although SFAs may increase their 

average paid meal prices more than the required amount. The provision allows SFAs to round down 

the required price increase to the nearest 5 cents for SY 2011-12.

Table I-8 shows the impact that price increases under the Paid Meal Equity Provision in SY 

2011-12 have had on closing the gap between the revenue generated by free and paid lunches. The 

price increases in the first year under the provision have already reduced the price gap by 6 percent. 

For example, looking at elementary schools in SY 2010-11, on average, SFAs generated 54 cents 

more revenue from free lunches than from paid lunches. In SY 2011-12, average revenue from free 

lunches was 51 cents greater than from paid lunches—a decrease in the price gap of 6 percent. 

Similar reductions in the gap were observed for middle and high schools. 

Table I-8. SFAs’ Average Difference in Revenues per Meal, SY 2010-11 versus SY 2011-12

SFA’s average difference in revenue per meal, SY 2010-11 versus SY 

2011-12

Elementary Middle High

Difference in revenue in 2010-11 0.54 0.32 0.32

Difference in revenue in 2011-12 0.51 0.30 0.30

Percent gap has been narrowed 5.6% 6.3% 6.3%

Weighted n 2010-11 11,794 8,808 10,349

Weighted n 2011-12 11,763 8,888 10,314

Data Source: SFA Director Survey 2011, questions 5.4, 5.5a, and 5.5b. 

Table I-9 shows that the rise in school meal prices was between 5 and 7 percent since SY 

2009-10 which was higher than inflation. During this time period, prices for “food away from 

home” increased 3.4 percent,

3

and the meal reimbursement rates were increased accordingly. 

Between SY 2009-10 and SY 2010-11, the rise in meal price tracked tightly with the rise in the 

reimbursement rate which is tied to the inflation rate. In contrast, between SY 2010-11 and SY 

2011-12, meal prices increased at a rate (3 to 4 percent) greater than inflation (2 percent). Although 

this recent rise in lunch prices above inflation is likely due in part to the Paid Meal Equity Provision, 

breakfast prices also rose more than inflation between SY 2010-11 and SY 2011-12. Both the recent 

recession and other HHFKA policy changes may be affecting meal pricing decisions. The recent 

economic downturn, which placed a great deal of stress on state and local budgets, appears to have 

also been a contributor to LEAs’ increasing school lunch prices, and 28 percent (not shown) of state 

CN directors said meal prices were affected by their state’s budget issues.

 

3 See www.fns.usda.gov/cnd/menu/menu_planning.doc).
11

Table I-9. NSLP and SBP Reimbursement Rates for Free School Meals and Average Prices 

for Paid Meals, SY 2009-10 to SY 2011-12

2009-10 2010-11 2011-12

% change

2009-10 to 2010-11

% change

2010-11 to 2011-12

Reimbursement rate for free meals

Breakfast $1.46 $1.48 $1.51 1.5% 2.0%

Lunch 2.68 2.72 2.77 1.5 1.8

Average paid meal prices

Elementary

Breakfast $1.13 $1.15 $1.19 1.8% 3.5%

Lunch $1.89 $1.92 $2.00 1.6 4.2

Middle

Breakfast $1.21 $1.23 $1.26 1.7 2.4

Lunch $2.10 $2.14 $2.21 1.9 3.3

High

Breakfast $1.21 $1.24 $1.27 2.5 2.4

Lunch $2.11 $2.14 $2.21 1.4 3.3

Data Source: http://www.fns.usda.gov/cnd/governance/notices/naps/NAPsHistorical.htm and SFA Director Survey 2011, questions 5.1, 5.2, 5.4, 

and 5.5.

Non-Profit Operations 

SFAs are required to operate on a nonprofit basis. In a given year, an SFA may not break 

even, but one would expect to see individual SFAs operate near the break-even band over time. In 

SY 2010-11, less than half of the SFAs were operating at a break-even level (defined as the average 

ratio of total cash revenues to total cash expenditures is between .95 and 1.05). Table I-10 shows 

that although over time SFAs may be just breaking even, only 41 percent actually operated within 

the break-even band in SY 2010-11. Thirty-four percent incurred a deficit, and 25 percent produced 

a surplus, suggesting that in a given year, there is significant variation around break-even levels. 

However it is important to note that these break-even levels compare total revenue with total 

expenditure only and do not take into account operating balances of SFAs at the beginning of the 

school year. 
12

Table I-10. Percentage of SFAs by Annual Cash Receipts as a Percentage of Cash 

Expenditures, SY 2010-11

Annual SFA cash receipts as a percentage of annual cash 

expenditures Percentage of SFAs

≤85% 19.0

86% to 90% 5.4

91% to 95% 9.6

96% to 100% 23.6

101% - 105% 17.8

106% to 110% 12.2

111% to 115% 4.0

≥116% 8.4

Total 100.0

Total SFAs: Weighted n

Total SFAs: Unweighted n

10,680

1,0821

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 6.1a and 7.1a.

State Policies and Support 

The states play an important role in administering the NSLP and SBP. While FNS sets 

policies for the school meals programs, the programs are administered at the state level. States 

provide oversight and guidance to help ensure that SFAs are in compliance with the program 

requirements, and in many cases provide additional financial assistance. 

Some states provided a subsidy to SFAs beyond the Federal reimbursement that SFAs 

received for the F/RP meals served to income eligible students. Table I-11 shows that about twothirds of the states reported that they provided subsidies for breakfast or lunch. Forty-two percent 

of states provided a subsidy for breakfast and lunch; 9 percent provided a subsidy for breakfast only; 

11 percent provided a subsidy for lunch only. Just over one-third of states did not provide subsidies 

to their SFAs. 

A key policy area for which states provided oversight to SFAs is NSLP and SBP program 

eligibility and verification. Table I-11 shows that a substantial number of states reported having 

SFAs that use Provisions 2 and 3 and direct verification to lessen the administrative burden 

associated with determining students’ program eligibility. Overall, many more states (77 percent) had 

at least some SFAs using Provision 2 as compared to Provision 3 (28 percent), and just about half 

(48 percent) of the states reported having at least one SFA using direct verification. 
13

Table I-11. Percentage of States with Select Policies, SY 2011-12

State policies Percentage of states with select policies

Provide subsidies (n = 531)

41.5%

11.3

9.4

37.7

Lunch and breakfast

Lunch only

Breakfast only

No subsidy 

Percentage of SFAs in Provision 2 (n = 53

1

)

More than 20 percent

>5-20 percent

>0-5 percent

None

7.5

26.4

43.4

22.6

Percentage of SFAs in Provision 3 (n = 531)

More than 20 percent

>5-20 percent

>0-5 percent

None

1.9

1.9

24.5

71.7

At least one SFA using direct verification (n = 521)

Currently using 

Used in past

Never used

48.1

1.9

50.0

1 

n is less than 54 due to item non-response. 

Data Source: State CN Director Survey 2011, questions C1, C2, D1 and D2. 

States vary substantially in their policies on charter schools. As the number of charter 

schools grows, there is significant variation as to how they are served. The number of charter 

schools in the country, their participation in the NSLP and SBP, and whether they operate as a 

separate SFA have implications for the programs’ coverage of students in need and the efficiency of 

operations. Table I-12 shows that 74 percent of states had charter schools in SY 2011-12, and 23 

percent of the states had more than 100 charter schools. Table I-12 also shows that 12 percent of 

the states had all their charter schools participating in the NSLP, while 33 percent had less than 70 

percent participating. Overall, 53 out of 54 state CN directors reported a total of 4,762 charter 

schools (not shown), with 69 percent (not shown) participating in NSLP and 59 percent (not shown) 

participating in SBP.4 The participation rate among charter schools was considerably less than the 

participation rate among all schools, which was over 90 percent for both the SBP and NSLP. 

 

4 According to the National Alliance for Public Charter Schools, there were 5,618 public charter schools in operation during SY 

2011-12 (http://dashboard.publiccharters.org/dashboard/schools/page/overview/year/2012). The reason for the discrepancy is 

unknown. One state CN director did not respond to this survey item. Additionally, the number of charter schools can fluctuate 

from year to year due to new schools opening and schools closing due to non-compliance with their charters. The number of states 

without charter school legislation according to the Alliance is smaller than the number of states without charter schools reported by 

state CN directors. Differences in how terms such as “operating” are defined, the speed with which change of status is reported to 

an advocacy organization vs. to state officials, and different time frame window may also have contributed to the differences. 
14

Table I-12. Percentage of States with Charter Schools and their NSLP Participation Levels, 

SY 2011-12

Number and participation of charter schools Percentage of states

Charter schools (n = 531)

None

Less than 20 schools

21-100 schools

More than 100 schools 

26.4%

17.0

34.0

22.6

Charter school participation in NSLP (n = 521,2)

100 percent

70-99 percent

Less than 70 percent 

Did not have charter schools

11.5

28.8

32.7

26.9

1 

n is less than 54 due to item non-response. 

2 One state reported the number of charter schools but did not provide the number participating in NSLP. 

Data Source: State CN Director Survey 2011, questions C11a and C11b.

State agencies provide programmatic training and technical assistance on numerous NSLP 

and SBP topics, ranging from the safe handling of food to program regulations and procedures. 

These trainings can be provided through written documents such as manuals or through various 

forms of verbal communication. As Table I-13 shows, states provided some level of training or 

technical assistance in many of the topics, with program regulations, recordkeeping, and menu 

planning being the most frequent training topics. A third of the states provided training on topics 

that were not listed in the questionnaire, and these included a wide range of subjects such as a backto-basics course, students with special dietary needs, farm to school, and salad bars. 

Table I-13. Percentage of States Providing School Meal Training and Technical Assistance 

by Topic and Frequency, SY 2011-12

Topic

Percentage of states providing training and technical assistance

At least annually Less than annually

Only when 

requested Not provided

Food safety plans 63.0% 9.3% 24.1% 3.7%

Other food sanitation and safety 57.4 3.7 25.9 13.0

Food purchasing 51.9 1.9 27.8 18.5

Menu planning 83.4 5.6 9.3 1.9

Food preparation 51.9 1.9 29.6 16.7

Contracting procedures 46.4 3.7 31.5 18.5

Recordkeeping 87.1 1.9 11.1 0.0

Merchandising 40.8 3.7 27.8 27.8

Program regulations and procedures 100.0 0.0 0.0 0.0

Use of commodities 74.1 0.0 9.3 16.7

Other 27.8 0.0 5.6 66.7

Total States: n 54

Data Source: State CN Director Survey 2011, question E1. 
15

Conclusions 

In many areas, SFAs appear to be well positioned to implement the regulations and policies 

stemming from the HHFKA. Several of the provisions included in the HHFKA were reported to 

have already been met, including near universal provision of potable water at lunch and the 

promulgation of school food safety plans. Similarly, SFAs reported high compliance with conducting 

at least two annual food safety inspections at each school. In light of the current operations and 

processes in place in many SFAs, there are some areas that may prove to be more challenging to 

implement and will require substantial changes on the part of SFAs. Specific to schools 

implementing the updated food-based meal patterns, nearly three-quarters of the SFAs used foodbased menu planning systems, which should make the transition to the updated patterns easier than 

if they had been using other menu planning options. Regarding competitive foods, although a 

majority of SFAs reported they offered competitive foods, many SFAs have operated under local 

and state policies that regulate these items to some degree. Additionally, the data show that many 

SFAs began to raise the prices in SY 2011-12 of paid lunches to comply with the Paid Meal Equity 

Provision of the HHFKA that went into effect in July 2011. Staff professional education and 

training may prove challenging, as a substantial share of SFAs did not previously require specific 

certifications or licenses. Finally, all the states responded that they provided training and technical 

assistance at least annually on program regulation and procedures. Most states also regularly 

provided training on other topics critical to implementing various provision of the HHFKA, which 

should help facilitate implementation. 
16

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17

Section II: Study Overview 

The NSLP and the SBP are the two largest school-based CN programs providing meals and 

snacks to millions of school-age students every day. During the 2011-12 school year, the NSLP 

provided lunch and afterschool snacks to about 31.8 million students each day in over 100,000 

public and nonprofit private schools nationwide.5 The SBP provided breakfast to about 12.18 

million students each day in over 89,000 schools.6

Since their inception in 1946 when malnourishment was a nationwide concern, the Federal 

government has used the CN programs as a major resource for safeguarding the health and wellbeing of the Nation’s children. More recently, concern has shifted from malnutrition to childhood 

obesity and the nutritional quality of school meals. Researchers examined school food environments 

and policies (Finkelstein et al., 2008)7

and found that less than one-half of the schools had a 

nutrition policy and less than one-quarter of schools had a nutrition or health advisory council. The 

authors also found a majority of secondary schools sold items à la carte in the cafeteria and through 

vending machines that were low-nutrient, energy-dense foods and beverages, commonly referred to 

as junk food. Another study found that most high school students can access soft drinks through 

both vending machines (88 percent) and in the school cafeteria at lunch (59 percent), with middle 

schools providing somewhat less access (Johnston et al., 2007). 

Similarly, findings from the 2006 School Health Policies and Practices Study indicate that 

while significant increases were observed between 2000 and 2006 in the percentage of states that 

required schools to prohibit the sale of junk food à la carte, room for improvement still exists 

(O’Toole et al., 2007). The authors reported that in 2006 less than half of states (42 percent) and 

almost 40 percent of districts (39 percent) required that schools prohibit the sale of junk food à la 

carte during breakfast or lunch. Delva (2007) and colleagues found indisputable evidence that lesshealthy foods are more available than more-healthy foods in the majority of secondary schools 

across the country, especially so for youth who are racial or ethnic minorities or of lower 

socioeconomic status. In a survey administered by the School Nutrition Association (SNA), school 

nutrition directors reported major challenges in finding affordable products that meet policy 

nutrition standards and acceptance by students.8 This body of research led to calls from the public 

for improvements in the quality of school meals through the establishment of stricter nutritional 

requirements. 

The USDA commissioned the IOM to convene a committee to recommend revised 

standards and requirements to make school meals healthier. In its 2009 report, School Meals: Building 

Blocks for Healthy Children, the committee recommended that USDA adopt standards for menu 

planning, including (1) increasing the amount and variety of fruits, vegetables, and whole grains; (2) 

setting minimum and maximum levels of calories; and (3) focusing more on reducing saturated fat, 

trans fat, and sodium. Given the number of students participating in NSLP and SBP, there is a 

realization that the quality and nutrient content of school meals is one way to improve children’s 

 

5 http://www.fns.usda.gov/pd/slsummar.htm, http://www.fns.usda.gov/cnd/Lunch/AboutLunch/NSLPFactSheet.pdf. 

6 http://www.fns.usda.gov/pd/sbsummar.htm. http://www.fns.usda.gov/cnd/breakfast/AboutBFast/SBPFactSheet.pdf. 

7 http://pediatrics.aappublications.org/cgi/content/full/122/1/e251. 

8 http://docs.schoolnutrition.org/newsroom/jcnm/08spring/mcdonnell/index.asp. 
18

diets and potentially affect the obesity problem while providing additional food security and 

ensuring that children are ready to learn. 

These recommendations were incorporated into the HHFKA in 2010 and resulted in USDA 

revising the CN program requirements. While the HHFKA is a very comprehensive bill that 

includes over 70 sections divided among four titles, several of the provisions are particularly 

important for school food operations and include: 

 School meal pattern standards: the HHFKA required USDA to issue a proposed rule 

within 18 months to update meal pattern requirements for the NSLP and the SBP. 

 Competitive foods standards: the HHFKA provided USDA the authority to set 

nutrition standards for all foods regularly sold in schools during the school day, 

including vending machines, the à la carte lunch lines, and school stores. 

 Professional standards: the HHFKA required USDA to establish a program of required 

education, training, and certification for various categories of school food service staff. 

 School lunch and competitive foods pricing: the HHFKA required USDA to administer 

a number of provisions related to school lunch pricing and competitive foods pricing. 

SFAs must bring paid lunch prices in line with subsidized school lunch levels and price 

competitive foods at or above the cost to avoid cross subsidization of funds from 

reimbursable meals. 

 Standards for local school wellness policies: the HHFKA required that local school 

wellness policies have input from diverse stakeholders, reflect the new nutrition 

standards set by USDA and set goals for nutrition promotion, include a plan for 

measuring and reporting on effectiveness, and are communicated to the public. 

The implementation timeline for the new requirements began in late 2010 and continue over 

10 years, with the meal pattern changes being phased in starting in SY 2012-13. FNS requires 

information, not already provided through state reporting, that will assist in understanding 

characteristics and administration of the state and local CN programs. This information will help 

FNS identify training and technical assistance needs and opportunities, as well as assess achievement 

of the new legislative goals. 

At the Federal level, FNS administers the NSLP and the SBP programs. FNS develops 

program eligibility requirements, benefits, and application processes and provides guidance to SFAs 

on implementing the NSLP and SBP. At the state level, the two programs are usually administered 

by state education agencies (SEAs), which administer the program through agreements with SFAs. 

SFAs are semi-autonomous nonprofit entities established by LEAs for the sole purpose of operating 

the school meals programs. State agencies monitor and supervise SFA compliance with Federal 

financial management standards, review SFA contracts with food service management companies, 

conduct training programs, provide onsite technical assistance, and assist SFAs with the operation of 

computerized nutrient menu planning systems and direct certification of students’ eligibility. 

However, differences in demographics, staffing, financial status, and other school- and district-level 

circumstances result in considerable variability in program implementation. 
19

Study Purpose 

The SN-OPS is a multiyear study involving several surveys designed to provide the USDA, 

FNS with a snapshot of current state and SFA policies and practices and a baseline for observing 

improvements resulting from the implementation of the HHFKA. The study provides FNS with key 

information about the characteristics, ongoing efficiency, and effectiveness of the CN program so 

FNS has a better understanding of what is happening at the state and local levels and can then 

address program policy needs, develop informed regulations and guidance, and provide needed 

technical assistance. 

The design of SN-OPS combines elements of cross-sectional and longitudinal research with 

the goal of maximizing the utility of data while conserving resources and reducing burden on states 

and SFAs. The general plan was to explore options for data collection over the initial study years and 

then settle on a carefully constructed (refined) set of data points or modules to collect information 

periodically or annually with minimal burden or disruption to state administrative offices and SFAs. 

SN-OPS comprises two core surveys initially: one targeting directors of state CN programs and one 

targeting directors of local SFAs. At the outset, the State CN Director Survey included directors 

from all states and five territories. FNS assumed that variability among state policies was unknown, 

and thus warranted a complete accounting from all states and territories. 

The initial round of data collection attempted to gain a full census of the 50 states, the 

District of Columbia, and the five U.S. territories. The survey of SFA directors used a stratified 

sample of SFAs serving at least one school participating in NSLP from the entire list of 14,797 

public school SFAs (as of 2010). A second round of surveys with state and SFA directors is being 

conducted for SY 2012-13. A third source, also conducted for SY 2012-13 consists of onsite visits to 

a sample of SFAs and schools. The purpose of these visits is to gain more depth of understanding of 

SFA operations by observing breakfast and lunch service and collect information about the 

availability of competitive foods. The schedule for these onsite observations is Year 2 of the study, 

and thus they are not reflected in this report. The SN-OPS study will provide USDA with up-to-date 

information about the nature of current CN program implementation, administration, and 

operations, to better inform future policy development. 

Study Design 

The following sections describe the various dimensions of the SN-OPS design. The first 

section describes the State CN Director and SFA Director Surveys, including their focus, content, 

and key variables. The next sections elaborate the sample design for the SFA Director Survey and 

the data collection procedures for both surveys. The remaining sections present relevant statistical 

information, including survey completion rates, data preparation, and adjustments (weighting). 

Data Sources 

This report of SN-OPS base-year activities comprises data collected from the survey of all 

state CN directors and data collected from a stratified sample of SFA directors. The two surveys 

provide a cross-sectional snapshot of state and local program characteristics and establish baseline 

estimates for year-to-year changes in operations with implementation of the HHFKA. Data 
20

collected from the same samples during Years 2 and 3 of the study provide a basis for assessing 

change. Both surveys focus on three general topic areas, including: (1) descriptive characteristics of 

CN programs, (2) program administration, and (3) program operations. 

State Child Nutrition Director Survey 

FNS sets policies for federally supported school meals programs. However, each state 

identifies an agency that is accountable to the Federal government for administering the programs. A 

state CN director who is responsible for applying Federal policies administers the state agency, 

developing supplementary state policies where needed, ensuring program implementation, and filing 

required reports with FNS. It is the state, rather than FNS, that has a direct connection with SFAs.9

States report to the Federal government (i.e., FNS) basic characteristics of their ongoing 

implementation of CN programs, including such data as numbers of students eligible and numbers 

of meals served under the F/RP lunch categories. However, with recent Federal policy 

developments (e.g., the Community Eligibility Provision) and new developments for CN programs 

over the next several years stemming from the HHFKA, FNS requires a more involved 

understanding of evolving state policies, practices, and local implementation of the nutrition 

programs. Such information will assist FNS in understanding the facilitators and barriers to efficient 

and effective program implementation and identifying state training and technical assistance needs. 

The 2011 State CN Director Survey consisted of 6 sections and 52 questions. Table II-1 

provides an overview of these topics, component subsections, and the number of items associated 

with each component. The six sections included standards, resources and finances, program 

administration, operations, training and technical assistances, and state CN director background. 

Each section and its components addressed issues of particular interest to FNS. A copy of the State 

CN Director Survey is provided in Appendix A. For example, the section on standards seeks 

information about how states interpret the Federal guidelines for food and beverages offered in 

schools. Of particular interest is whether states implement stricter guidelines (than the Federal 

guidelines), the extent to which the state has and enforces guidelines for various food sources (à la 

carte items, school stores, vending machines, etc.), the perceived impact of these guidelines, and 

whether or not the state promulgates policies for feeding students who were not certified for F/RP 

meals and were unable to pay for school meals. 

 

9 FNS uses a tiered approach in communicating with states and SFAs. Headquarters first contacts the directors of the seven FNS 

Regional Offices who then contact the state CN directors in their region. It is the state CN directors who maintain contact with 

SFA directors within each state. 
21

Table II-1. State Director Questionnaire Content

Section Component Number of items

Standards State standards of practice 4

Resources and finances Food subsidies

Support for food service operations

Budget issues

State level staffing (FTEs)

State warehouse arrangements

Charging SFA fees

1

1

1

4

2

3

Program administration Direct verification

Charter schools

10

1

Operations Provision 2 or 3

Use of external food service firms

Contracting provisions

Food recall procedures

Communication with SFAs

2

2

1

7

1

Training and technical assistance (TA) TA topic areas

Delivery of TA

1

6

CN director background Experience

Education

2

3

SFA Director Survey 

The 2011 SFA Director Survey consisted of 14 sections and 102 questions. The sections 

included SFA characteristics, school participation, student participation, food service characteristics, 

meal prices, revenues, expenditures, alternative meals/recouping credits for unpaid meals, meal 

counting and claiming, procurement issues, involvement in other programs, food safety program, 

communication issues, and SFA director background. Table II-2 provides an overview of these 

topics, component subsections, and the number of items associated with each component. A copy 

of the SFA Director Survey is provided in Appendix B. 
22

Table II-2. SFA Director Questionnaire Content 

Section Component Number of items

SFA characteristics Composition

Pre-K student access to school meals

1

2

1. School participation School-level participation in SBP and NSLP

Severe need schools 

1

1

2. Student participation Student access to/participation in meals 1

3. Food service characteristics Meal service delivery

Eating locations, duration, and recess

Menu planning and food selection

Policies for school meals 

Nutrition information and free potable water

Types and uses of kitchen facilities

1

6

3

2

6

4

4. Meal prices Breakfast prices for 3 years 

Lunch prices for 3 years 

Steps taken to minimize price increases 

3

3

4

5. Revenues Total income and sources

State and school district subsidies received 

1

1

6. Expenditures Categories of expenditures 1

7. Alternative meals Unpaid meals 4

8. Meal counting and claiming Meal counting and payment methods

Cashier training and onsite monitoring

2

3

9. Procurement issues Geographic preference

Nutrition information requirements

Purchasing and using food service firms

4

6

3

10. Other programs Other USDA programs 9

11. Food safety program Food safety plans, inspections/violations

Food safety training

14

4

12. Communication Communications with state agencies, households, and 

school staff 

5

13. SFA director background Experience

Education and certifications

Responsibilities

District position requirements

2

2

1

2

Total 102

SFA Sample Selection 

The goal of the 2011 SFA Director Survey was to collect data from a representative sample 

of SFAs from which to generate a nationally representative picture of SFA program characteristics, 

administrative practices, and food service operations. The 2009-10 Verification Summary Report 

data (Form FNS-742) provided the data needed to build a sample frame from which to select SFAs 

for the survey. 

Table II-3 presents an overview of SFAs with at least one school participating in the NSLP 

in the U.S. during the 2009-10 academic school year. In total, 18,634 SFAs with at least one school 

participating in the NSLP were reported to FNS on Form FNS-742 during that school year. Of 

those, 79 percent (14,797) represented public schools participating in the NSLP. Importantly, public 

school SFAs represent 94 percent of schools participating in the NSLP in the U.S. during that year 
23

and 98 percent of the students participating in the program. The public school SFAs with at least 

one school participating in the NSLP comprised the sampling frame for the survey. 

Table II-3. Sample Frame Coverage of SFAs, Schools, and Students in SY 2009-10

SFA type SFAs Schools Students

All SFAs with at least one school 

participating in NSLP 18,634 97,274 49,803,000

Public school SFAs with at least one 

school participating in the NSLP 14,797 (79.4%) 91,066 (93.6%) 48,544,000 (97.5%)

Before sampling, public school SFAs were organized into strata based on enrollment (seven 

levels), percentage of students eligible for F/RP lunch (three levels), and FNS region (seven levels). 

The 26 largest SFAs were included in the sample with certainty (i.e., a sampling rate of 1.0). 

Selection of the remaining SFAs followed rates roughly proportional to the average square root of 

the enrollment of SFAs in the stratum to which the SFA belonged. This allocation gives large SFAs 

relatively higher selection probabilities than smaller ones while producing acceptable sampling 

precision for both prevalence estimates and numeric measures correlated with enrollment. Note that 

while both poverty level and FNS region defined the detailed sampling strata, the actual sampling 

rates used to select the sample depended only on the size class of the SFA. Before sample selection, 

the sampling frame was sorted by selected district-level characteristics available from the 2008-09 

National Center for Education Statistics (NCES) Common Core of Data (CCD) LEA universe file. 

The CCD variables used in the sorting were urbanicity (locale) and categories of percentage minority 

enrollment. The sorting in effect created implicit strata within each detailed sampling stratum to 

ensure appropriate representation of the different types of SFAs within strata under systematic 

sampling. 

Table II-4 presents a summary of the sample selection by the seven student enrollment 

categories. The table shows the number of SFAs in each of the seven enrollment categories, the 

sampling rate associated with the category, and the number of SFAs sampled. The final sample, 

including the 26 largest SFAs sampled with certainty, was 1,768. 

Data collection activities brought to light the fact that two of the sampled SFAs represented 

six entities (school district), thus serving as if they were actually more than one SFA. These two 

cases required the study to collect data multiple times from the SFA director as if he/she were 

multiple directors. This situation effectively increased the sample size to 1,774. A detailed 

description of the sampling strategy for selecting the SFAs appears in Appendix C. 
24

Table II-4. SFA Sample by Enrollment 

SFA enrollment

Number of SFAs in 

sampling frame

Sampling

rate

Number of SFAs selected 

for sample1

Under 1,000 7,632 0.0589 447 

1,000 to 2,499 3,297 0.1101 366 

2,500 to 4,999 1,945 0.1612 310 

5,000 to 9,999 1,043 0.2280 237 

10,000 to 24,999 594 0.3483 210 

25,000 to 99,999 260 0.6582 172 

100,000 or more 26 1.0000 26 

Total 14,797 --- 1,768 

1

 The numbers sampled only approximate the rate times the number on the frame due to adjustments made by including the two additional 

sorting variables (type of locale and minority status). 

Data Collection Procedures 

The following sections describe the data collection procedures for the two surveys. The 

discussion includes a description of the survey mode, data collection period, and prompting 

strategies. 

State Child Nutrition Director Survey 

The data collection period for the State CN Director Survey stretched from a planned 3 to 

41⁄2 months, from October 1, 2011, through February 13, 2012. State CN directors in all 50 states, 

the District of Columbia, and the 5 U.S. territories received a packet of information about the 

survey. The packet included a letter, Frequently Asked Questions (FAQ) and answers sheet, a copy 

of the 22-page questionnaire, and instructions for its completion. The letter explained the survey, its 

purpose, and its importance to FNS. The only option for completing the questionnaire was the hard 

copy, paper/pencil version. There was no availability for completing the questionnaire online. 

Throughout the data collection period, a series of communications attempted to improve the 

number of responding state directors. For example, a little more than a week following the initial 

mailing, a second letter to state directors described answers to questions received during the first 

week. Non-responding state directors continued to receive email messages and phone calls 

periodically throughout the data collection period. Finally, in mid-January 2012, non-responding 

state directors received a FedEx envelope containing a final request to complete the survey along 

with a new copy of the questionnaire. The final cutoff data for the survey was set at February 13, 

2012. 

Fifty-four State CN directors completed the questionnaire, for a response rate of 96 percent. 

Survey responses included all 50 states, the District of Columbia, and 3 U.S. territories. 
25

SFA Director Survey 

The data collection period for the SFA Director Survey went from September 30, 2011, 

through February 17, 2012. The SFA Director Survey was a web-enabled, password-protected 

questionnaire. However, SFA directors had the option to complete the questionnaire on paper. SFA 

directors could download and print a paper version of the questionnaire or request to have one sent 

by mail. 

With contact information provided by FNS, a letter and supplementary materials sent to 

SFA directors introduced the survey and gave information about its purpose and importance to 

FNS. The packet of materials included the study’s Web address and the SFA’s unique username and 

password. Also included with the mailing were instructions for getting started, FAQs and answers, and 

an endorsement letter from the SNA. 

The initial request gave SFA directors a month to complete the questionnaire. However, to 

meet minimum response rate requirements set by FNS, several extensions carried the data collection 

through February 17, 2012. In an effort to assist a few SFA directors, staff completed some 

questionnaires over the telephone. Throughout the data collection period, SFA directors received a 

number of contacts to encourage completion of the questionnaire. These contacts included letters, 

phone calls, emails, and reminder postcards as well as encouragement from the state office. 

SFA Director Survey Response Rate 

Table II-5 shows the final disposition of the SFA sample. Of the 1,774 SFAs in the sample, 

1,328 completed the survey in its entirety. Another 73 SFA directors completed 7 or more sections 

of the questionnaire, enough to consider the questionnaire complete. Nine SFAs were ineligible for a 

variety of reasons, however, mainly due to having gone out of business. The remaining 364 (21 

percent) SFA directors did not respond at all to the questionnaire, or they opened it but did not 

complete enough of the survey to consider it a response. The final response rate was 79 percent. 

Table II-5. Response Rate for the SFA Survey 

Sample disposition Number

Sample 1,774

Complete (all sections) 1,328

Partial complete (7 or more sections) 73

Total available for analysis 1,401

Incomplete (6 or fewer sections) 179

No response 185

Ineligible 9

Response rate (complete + partial complete) ÷ (total sample – ineligibles) 79.4%
26

Weighting and Adjustments 

This section describes the procedures for weighting and variance estimation and the general 

approach to the analysis of the base-year SFA survey data. 

Base Weights 

Following data collection, a base weight was computed for each sampled SFA. Weights 

compensate for differential probabilities of selection and non-response. Since the data collection 

involved only one wave of data, a set of cross-sectional weights was created to produce nationally 

representative estimates of public school SFAs for the base year. The base weight, whi, for SFA i in 

sampling stratum h was computed as whi = 1/Phi, where Phi is the corresponding probability of 

selecting the SFA from the stratum. Given SFAs sampling at varying rates under the stratified 

sampling scheme, the base weights varied accordingly. Phi varied from 0.06 to 1.0 as shown in Table 

II-4, depending on enrollment size category. The base weights are theoretically unbiased in the 

absence of survey non-response. However, as noted in Table II-5, non-response did occur. 

Therefore, to minimize the potential for non-response bias, intentional adjustments to the base 

weights compensated for differential non-response. 

Non-Response Weights 

The conduct of a non-response bias analysis helped to (1) determine characteristics that are 

correlated with non-response, (2) inform construction of the sampling weights, and (3) determine 

the extent to which weighting adjustments were effective in reducing possible non-response bias. 

The requirement for a responding SFA was completion of at least seven questionnaire sections. 

Therefore, non-responding SFAs were those with zero to six completed sections. The non-response 

bias analysis resulted in the specification of appropriate weighting classes within which to carry out 

weight adjustments. The base weights were adjusted for non-response within adjustment cells with 

similar response propensity. The non-response adjustment cells were defined using SFA-level 

characteristics available from the FNS database and data from the most current CCD. Within these 

cells, a weighted response rate was computed and applied to the SFA base weights to obtain the 

corresponding non-response-adjusted weights. The non-response bias analysis in Appendix D 

shows that these weighting adjustments were effective in reducing non-response bias. 

Variance Estimation 

In addition to the full sample weights described above, a series of jackknife replicate weights 

were created and attached to each data record for variance estimation. Replication methods provide 

a relatively simple and robust approach to estimating sampling variances for complex survey data 

(Rust and Rao, 1996). Jackknife replication has some advantages over Taylor series approximation in 

reflecting statistical adjustments used in weighting such as non-response and post-stratification. 

Under the replication approach used, 100 jackknife replicates were formed by deleting selected cases 

from the full sample and adjusting the base weights of the retained cases accordingly. The entire 

weighting process developed for the full sample was then applied separately to each jackknife 

replicate, which produced a series of replicate weights. The replicate weights were imported into 

variance estimation software (i.e., SAS) to calculate standard errors of the survey-based estimates 

and to conduct significance tests on key variables. 
27

Table Variables 

A majority of the tables in this report contain crosstabs of relevant topical variables by three 

key characteristics of the SFA. The three variables are SFA size (student enrollment levels in the 

SFA), urbanicity, and poverty level. Table II-6 provides an overview of the unweighted and weighted 

sample sizes for the SFA survey cross-sectional estimates for each of the three variables. 

Table II-6. Unweighted and Weighted Sample Sizes for the Base-Year Cross-Sectional 

Estimates, by SFA Size, Urbanicity, and Poverty Level 

SFA characteristics

Percentage of 

SFAs

Weighted 

n

1

Unweighted 

n

All SFAs 100.0% 14,678 1,401

SFA size

Small (1-999) 50.2 7,374 332

Medium (1,000-4,999) 36.7 5,390 536

Large (5,000-24,999) 11.1 1,629 364

Very large (25,000+) 1.9 284 169

Urbanicity

City 11.1 1,630 256

Suburban 19.7 2,885 380

Town 19.0 2,794 266

Rural 50.2 7,369 499

Poverty level

Low (0-29% F/RP) 23.2 3,407 348

Medium (30%-59% F/RP) 46.5 6,828 650

High (60% or more F/RP) 30.3 4,443 403

1 SFA size group sums to 14,677 rather than 14,678 due to rounding. 

Table II-6 shows that: 

 Half of all SFAs (50 percent) are small districts; 37 percent are medium-size districts; 11 

percent are large districts; and 2 percent are very large districts. Looked at another way, 

only 13 percent of SFAs are districts with at least 5,000 students. 

 Fifty percent of SFAs are in areas categorized as rural; 39 percent are located in towns 

and suburban areas; and 11 percent are in cities.10

 Urbanicity and SFA size are strongly related. Cities are large population centers, which 

tend to have large or very large school districts. Because only 13 percent of SFAs have 

at least 5,000 students, it is not surprising that 11 percent of SFAs are in cities. 

Conversely, rural areas have low population densities and relatively small schools. 

Because 50 percent of SFAs have fewer than 1,000 students, it is not surprising that 50 

percent of SFAs are also located in rural areas. Further examination of the cross 

relationship between urbanicity and size revealed that 69 percent (not shown) of small 

SFAs are rural and that 91 percent (not shown) of the very large SFAs are in cities or 

suburbia. 

 

10 Urbanicity levels are from the NCES CCD. 
28

 In terms of SFAs’ poverty level, 23 percent of SFAs are in low-poverty areas; 30 percent 

are in high-poverty areas; and 47 percent are in medium-poverty areas. 

Significance Tests 

Significance tests were conducted on the crosstabs to determine if SFA characteristics (e.g., 

SFA size) are associated with the variables of interest (e.g., student participation in NSLP). Most of 

the variables of interest are proportions. In these cases a Chi-Square test was used to determine if 

observed differences were statistically significant or the result of normal sampling error. Using the 

percentage of students participating in NSLP and SFA size as an example, the Chi-Square test was 

run to determine whether the student participation percentages were different across the SFA size 

categories or equal. Similarly, when the variable of interest was a mean (e.g., average meal prices) an 

F-test11 was used to determine if observed differences between SFA subgroups were statistically 

significant or the result of normal sampling error. Finally, when the variable of interest was a 

median, a Kruskall-Wallis test was used to determine whether SFA subgroup differences were 

statistically significant. 

Because of the descriptive nature of this report, tests of pairwise differences between 

subgroups for the analyses of SFA characteristics were not conducted. For example, a Chi-Square 

test of the association between the percentage of students participating in NSLP and SFA size 

indicates whether student participation percentages differ by SFA size categories but not which 

subgroups differ from each other (i.e., whether very large SFAs are different from large SFAs). Only 

very large differences between specific subgroups are likely to be statistically significant and pairwise 

comparisons should be viewed with caution. 

Missing Data 

There are two sources of missing data. First, not all questions pertained to all respondents 

and, second, respondents skipped questions or groups of questions. Analyses that only pertain to a 

subset of respondents are noted in the table or figure title. To address the fact that the sample sizes 

vary between analyses due to item non-response, the relevant sample sizes have been included as a 

footnote to all tables and figures. 

 

11 Regression was used to conduct the F-test. For example, average meal prices were regressed on SFA size represented by three 

dummy variables for medium, large, and very large SFAs (base case is small SFAs). The F-test shows whether the variation in 

average prices among SFAs in these size categories is statistically significant. 
29

Section III: Participation in NLSP, SBP, and 

Other Nutrition Programs 

The socio-economic characteristics of the population the SFAs serve are important factors 

associated with students’ nutritional needs, program eligibility, and ultimately program participation. 

In turn, the degree of need in the schools is likely to affect SFA participation in the NSLP and SBP 

as well as participation in other nutrition-related programs. 

School and student participation are critical to the economic viability of SFAs and for SFAs 

to meet the goal of improving students’ diets and health outcomes (including reducing childhood 

obesity). The levels of participation and the factors influencing student decisions about eating school 

meals are therefore important to both FNS and the broader school nutrition community. Examining 

participation rates from numerous perspectives provides a baseline for assessing the changes that are 

coming with implementation of the new regulations stemming from the HHFKA that are likely to 

affect NSLP and SBP participations rates. 

This section presents estimates of SFA, public school, and student participation in the NSLP 

and SBP during SY 2011-12. It also examines SFA participation in other nutrition-related programs. 

Background 

Since its inception in 1946, participation in the NSLP has grown. Figure III-1 shows the 

program served about 20 million students in 1969, of which only 15 percent received F/RP lunches. 

In contrast, by 2012, about 32 million students participated in the NSLP with 68 percent of students 

receiving F/RP meals. The NSLP is a very different program today than it was 30 years ago. In 

1969, the NSLP was available in only 65 percent of the nation’s public schools (USDA, 1971). As 

current administrative data reveal, today the program is nearly universally available with an estimated 

95 percent of public schools participating in the program (FRAC, 2013), and about 75 percent of all 

public and private schools participate in the program.12 As Figure III-1 shows, although student 

participation in the program has grown steadily since the early 1980s, the increase is entirely 

attributable to increases in participation among students approved for F/RP meals, while 

participation among students in the paid income-eligibility category has declined. 

Looking to the future, many of the provisions of the HHFKA are likely to bring about 

changes in the way SFAs do business. Specifically, the HHFKA is intended to improve the quality of 

the foods offered and requires SFAs to make significant changes in the pricing structure of all foods 

sold in schools, both of which could significantly affect participation rates. 

Participation levels, especially among students certified for F/RP meals, measure the degree 

to which the school meals programs are successful in reaching low-income students. In addition, 

because NSLP and SBP reimbursements are tied to the number of meals served, student 

participation data are important for Federal budgeting and planning purposes. This first-year report 

 

12

 Calculated from data from the FNS National Data Bank (2013) and from NCES data on the total number of schools in the U.S. 
30

serves as a baseline for comparing participation levels from SY 2011-12 to levels from subsequent 

school years as implementation of the HHFKA provisions proceeds. 

Figure III-1. NSLP Student Participation, 1969-2012 

Data Source: National Data Bank (http://www.fns.usda.gov/pd).

SFAs vary on a number of important characteristics that may affect both school and student 

participation in the school meals programs. The major subgroups included in the analysis include 

SFA size, urbanicity, and school district poverty level. Finally, because it can have an effect on 

students’ diets and health outcomes as well as on SFA finances, this section also examines 

participation in other FNS school-based nutrition assistance programs. 

Research Questions 

 The research questions associated with program participation include: 

 What is the level of public school participation in the NSLP and SBP? 

 What are the characteristics of public schools participating in NSLP and SBP compared with those 

that are not? 

 What percentage of SFAs have schools that are identified as “severe need”?

 What percentage of SFAs have schools that provide access to school meals for prekindergarten (pre-K) 

students? 

 What percentage of students are approved for F/RP meals? 

― Does the percentage vary by type of SFA? 

― Does the percentage vary for elementary and secondary schools? 

0

5

10

15

20

25

30

35

1969197119731975197819801982198419861988199019921994199619982000200220042006200820102012

Average Participation (Millions)

Full Price F/RP Paid
31

 Do SFAs participate in other USDA programs such as Fresh Fruit and Vegetable Program, 

Afterschool Snack Program, Summer Food Service Program, or Child and Adult Care Food Program 

At-Risk Afterschool Snack or Supper Program? 

 Do SFAs participate in the Department of Defense Fresh Program? How satisfied are SFAs with the 

program? 

 Do SFAs participate in the farm to school activities? What types of activities? 

 How many SFAs have schools that are recognized as HealthierUS Schools? At what level have these 

schools been recognized? What areas give you the most problems in attaining this recognition? 

Results 

SFA and School Participation in the NSLP and the SBP 

Although the sample selection criteria for the study only required at least one school in an 

SFA to be participating in the NSLP, the vast majority of SFAs reported that all schools in their 

districts participated in the program. In fact, as Table III-1 shows, in SY 2011-12, 97 percent of 

SFAs had all their schools participating in the NSLP. Translating this to the school level, 99 percent 

(not shown) of all public schools participated in the NSLP in SY 2011-12. While no major 

differences were observed in this measure by urbanicity and poverty level, size of the SFAs is 

associated with the percentage of SFAs with all their schools participating in the NSLP. While 98 

percent of SFAs in small districts reported full participation of schools, only 84 percent of SFAs in 

very large districts had full participation of all schools in the district in NLSP. 

Table III-2 shows that participation in the SBP was high, but it is not as high as participation 

in NSLP. Specifically, 79 percent of SFAs reported that all their schools participated in SBP, while 

10 percent (not shown) reported having no participating schools. Similarly, at the school level, 90 

percent (not shown) of all schools participated in the SBP. In smaller SFAs, there were higher rates 

of universal participation in SBP relative to large school districts. In terms of urbanicity, suburban 

districts had lower rates of “all schools participating in SBP” relative to others. Also, SFAs in lowpoverty areas reported lower full participation by all schools in the district compared with SFAs in a 

medium or high poverty level. 
32

Table III-1. Percentage of SFAs with All Schools within each Grade Level Participating in the NSLP by SFA Characteristics, SY 

2011-12

SFA characteristics

Percentage of SFAs with all schools within each grade level participating in the NSLP

Elementary Middle High Other All schools

Percent 

of SFAs

Wgtd 

n

Unwgtd 

n

Percent of 

SFAs

Wgtd 

n

Unwgtd 

n

Percent 

of SFAs

Wgted 

n

Unwgtd 

n

Percent 

of SFAs

Wgtd 

n

Unwgtd 

n

Percent of 

SFAs

Wgtd

n

Unwgtd 

n

All SFAs 99.1% 12,495 1,281 99.7% 9,410 1,097 99.0% 10,828 1,182 92.7% 4,569 547 96.6% 14,533 1,3891

SFA size2

Small (1-999) 99.1 5,518 256 100.0 3,179 148 99.0 4,205 195 97.8 2,040 90 98.4 7,269 328

Medium (1,000-4,999) 99.1 5,115 509 99.4 4,435 450 99.5 4,790 476 90.4 1,525 149 96.2 5,360 532

Large (5,000-24,999) 99.6 1,590 354 99.7 1,533 342 97.9 1,554 345 86.4 796 186 91.7 1,623 362

Very large (25,000+) 97.5 273 162 99.1 263 157 95.3 280 166 83.7 208 122 84.3 281 167

Urbanicity3

City 99.1 1,240 229 99.4 913 208 98.8 906 211 90.4 532 128 96.1 1,597 252

Suburban 97.9 2,450 351 99.3 2,056 322 98.8 2,191 329 89.2 936 159 94.1 2,848 377

Town 99.5 2,404 247 100.0 2,174 231 99.0 2,303 238 90.0 1,101 105 94.8 2,773 264

Rural 99.5 6,401 454 99.7 4,267 336 99.0 5,427 404 96.5 2,000 155 98.4 7,316 496

Poverty level4

Low (0-29% F/RP) 98.3 2,818 310 98.7 2,229 279 97.9 2,569 303 94.4 819 104 96.5 3,381 346

Medium (30%-59% F/RP) 100.0 6,104 609 100.0 4,690 522 99.9 5,424 565 91.6 2,368 272 97.0 6,786 645

High (60% or more F/RP) 98.3 3,574 362 99.9 2,491 296 98.1 2,835 314 93.6 1,382 171 96.0 4,366 398

1

n is less than 1,401 because not all SFAs have each type of school, and 12 SFAs provided implausible school count data. 

2

 Percentage of SFAs with schools participating in the NSLP for high, other, and all schools differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs with schools participating in the NSLP for other and all schools differed significantly by urbanicity at the .05 level. 

4

 Percentage of SFAs with schools participating in the NSLP for elementary and middle schools differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, question 2.1. 
33

Table III-2. Percentage of SFAs with All Schools within each Grade Level Participating in the SBP by SFA Characteristics, SY 

2011-12

SFA characteristics

Percentage of SFAs with all schools within each grade level participating in the SBP

Elementary Middle High Other All Schools

Percent 

of SFAs

Wgtd 

n

Unwgtd 

n

Percent 

of SFAs

Wgtd 

n

Unwgtd 

n

Percent 

of SFAs

Wgted 

n

Unwgtd 

n

Percent 

of SFAs

Wgtd 

n

Unwgtd 

n

Percent 

of SFAs

Wgtd

n

Unwgtd 

n

All SFAs 85.9% 12,495 1,281 88.2% 9,410 1,097 88.1% 10,828 1,182 77.8% 4,569 547 78.8% 14,533 1,3891

SFA size2

Small (1-999) 84.9 5,518 256 87.3 3,179 148 86.5 4,205 195 80.3 2,040 90 80.4 7,269 328

Medium (1,000-4,999) 87.0 5,115 509 87.5 4,435 450 89.1 4,790 476 77.5 1,525 149 79.0 5,360 532

Large (5,000-24,999) 86.4 1,590 354 91.5 1,533 342 90.4 1,554 345 71.7 796 186 73.4 1,623 362

Very large (25,000+) 80.0 273 162 91.7 263 157 83.7 280 166 74.3 208 122 64.7 281 167

Urbanicity3

City 84.5 1,240 229 92.6 913 208 90.6 906 211 83.4 532 128 80.6 1,597 252

Suburban 69.9 2,450 351 79.3 2,056 322 82.6 2,191 329 63.8 936 159 61.2 2,848 377

Town 93.8 2,404 247 93.0 2,174 231 91.7 2,303 238 73.6 1,101 105 81.1 2,773 264

Rural 89.3 6,401 454 89.2 4,267 336 88.5 5,427 404 84.8 2,000 155 84.4 7,316 496

Poverty level4

Low (0-29% F/RP) 64.2 2,818 310 67.6 2,229 279 73.1 2,569 303 59.8 819 104 54.0 3,381 346

Medium (30%-59% F/RP) 91.8 6,104 609 93.9 4,690 522 92.0 5,424 565 74.4 2,368 272 83.5 6,786 645

High (60% or more F/RP) 92.8 3,574 362 95.9 2,491 296 94.4 2,835 314 93.7 1,382 171 90.8 4,366 398

1

n is less than 1,401 because not all SFAs have each type of school, and 12 SFAs provided implausible school count data. 

2

 Percentage of SFAs with schools participating in the SBP for all schools differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs with schools participating in the SBP for elementary, middle, other, and all schools differed significantly by urbanicity at the .05 level. 

4

 Percentage of SFAs with schools participating in the SBP for elementary, middle, high, other, and all schools differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, question 2.1. 
34

Severe-Need Schools 

Schools with a high percentage of low-income students may qualify as “severe need” and 

receive higher reimbursements for the F/RP breakfasts served in their schools. To apply for severeneed reimbursement, a school must currently be participating in or initiating the SBP, and at least 40 

percent of the lunches served 2 years before the school’s application must have been counted as 

F/RP meals. 

Table III-3 shows that among the SFAs that participated in the SBP during SY 2011-12, a 

total of 73 percent reported that one or more of their schools received SBP severe-need 

reimbursement. Not surprisingly, the percentage of SFAs that reported the presence of severe-need 

eligible schools was higher among the high-poverty SFAs compared with the more affluent SFAs 

(90 percent versus 40 percent). Although high-poverty SFAs participating in the SBP should have 

schools that are eligible for severe-need reimbursement, it is possible that some SFAs may not apply 

for the additional reimbursement, which would explain the reported 90 percent participation rate. 

Among the large and very large SFAs, 87 to 100 percent of the SFAs had at least one school eligible 

for severe-need status, compared with 72 percent among medium and 69 percent among small 

SFAs. SFAs with severe-need eligible schools were most likely to be located in cities and towns (87 

percent and 82 percent, respectively) and less likely to be found in suburban and rural areas (70 

percent and 68 percent, respectively). 

Table III-3. Among SFAs that Participate in the SBP, Percentage of SFAs with Schools that 

Received SBP Severe-Need Reimbursement by SFA Characteristics, SY 2011-12

SFA characteristics Percentage of SFAs

Total SFAs

Weighted n Unweighted n

All SFAs 73.2% 13,227 1,3151

SFA size

Small (1-999) 69.4 6,292 286

Medium (1,000-4,999) 72.1 5,047 501

Large (5,000-24,999) 86.6 1,603 359

Very large (25,000+) 100.0 284 169

Urbanicity2

City 87.4 1,482 250

Suburban 70.4 2,454 347

Town 81.5 2,637 256

Rural 67.7 6,654 462

Poverty level2

Low (0-29% F/RP) 40.0 2,647 297

Medium (30%-59% F/RP) 75.7 6,339 624

High (60% or more F/RP) 90.2 4,241 394

1 

n equals the 1,315 SFAs that had any of their schools participating in the SBP. 

2 Percentage of SFAs with schools eligible for SBP severe-need reimbursement differed significantly by urbanicity and poverty level at the .05 

level. Because all very large SFAs had schools eligible for SBP severe-need reimbursement, a significance test for SFA size was not conducted. 

Data Source: SFA Director Survey 2011, question 2.2. 
35

Prekindergarten Programs 

 Some school districts offer comprehensive programs for 3-year-olds (preschool) and 4-yearolds (pre-K) that provide stimulating activities and learning experiences to help prepare children for 

success in kindergarten and beyond. Depending on the type of pre-K program, school meals may or 

may not be provided. For example, children enrolled in a federally funded Head Start program or a 

comparable state-funded Head Start program or pre-K program are automatically eligible for free 

meal benefits. 

 Although approximately 70 percent (not shown) of SFAs had a pre-K program, only 56 

percent of SFAs had pre-K programs that provided school meals to students, as shown in Table III4.13 Looking at SFAs by size of enrollment, 95 percent of very large SFAs and 71 percent of large 

SFAs provided meals to students in pre-K programs, compared with 60 percent of medium SFAs 

and 49 percent of small SFAs. High-poverty SFAs were more than twice as likely as low-poverty 

SFAs to provide school meals to pre-K students within the district (65 percent versus 31 percent). 

Table III-4. Percentage of SFAs with Pre-K Programs that Provide Access to School Meals, 

SY 2011-12

SFA characteristics

Percentage of SFAs with pre-K programs that 

provide access to school meals

Total SFAs

Weighted n Unweighted n

All SFAs 56.0% 14,383 1,3711

SFA size2

Small (1-999) 48.6 7,301 329

Medium (1,000-4,999) 59.7 5,228 522

Large (5,000-24,999) 71.0 1,569 351

Very large (25,000+) 94.5 284 169

Urbanicity2

City 44.7 1,570 249

Suburban 46.2 2,832 372

Town 58.9 2,708 257

Rural 61.2 7,272 493

Poverty level2

Low (0-29% F/RP) 30.6 3,276 333

Medium (30%-59% F/RP) 62.7 6,765 641

High (60% or more F/RP) 64.7 4,342 397

1

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs with pre-K programs that provide access to school meals differed significantly by SFA size, urbanicity, and poverty level at 

the .05 level. 

Data Source: SFA Director Survey 2011, questions 1.2 and 1.3. 

 

13 The survey asked only if meals were provided. It did not include a specific question about Head Start. 
36

Student Participation in the NSLP and the SBP 

 The proportions of students certified for free, reduced-price, and paid meals are vital 

statistics for the school meals programs, as these counts affect reimbursements. Estimates of these 

statistics for SY 2011-12 were based on the number of students reported by SFAs as approved for 

F/RP meals and the total number of students reported as enrolled in the school.14

 Eligibility to participate in the NSLP and the SBP is based on the combination of household 

size and income. Students living in families earning at or below 130 percent of poverty qualify for 

free meals. In addition, students are categorically eligible for free school meals if: (1) they or any 

member of the household receives benefits from certain assistance programs (e.g., Supplemental 

Nutrition Assistance Program, Temporary Assistance for Needy Families, or the Food Distribution 

Program on Indian Reservation); (2) they are living in families designated as homeless, migrant, 

runaway, or foster; or (3) they are enrolled in a federally funded or comparable state-funded Head 

Start program or pre-K program or an Even Start program. Students living in families with incomes 

between 131 percent and 185 percent of poverty qualify for reduced-price meals. 

 As shown in Table III-5, SFA directors reported that over half of students were approved 

for either F/RP meals during SY 2011-12 (51 percent in total or 44 and 7 percent, respectively). 

Forty-four percent of students in all schools (49 percent of students in elementary schools, 43 

percent in middle schools, 37 percent in high schools, and 42 percent in other schools) were 

approved to receive free meals during SY 2011-12. Also, SFAs reported that the percentage of 

students approved to receive reduced-price meals was much smaller than the percentage approved 

for free meals. Overall, SFAs reported that 7 percent of students were approved for reduced-price 

meals. This percentage was fairly consistent across school type. 

Table III-5. Percentage of Students Approved for Free or Reduced-Price Meals and 

Percentage of Students without Access to the SBP and NSLP, SY 2011-12

Student group

Percentage of students

Elementary Middle High Other Total

Approved to receive free meals 48.8% 42.6% 36.9% 41.5% 43.9%

Approved to receive reduced-price meals 7.0 7.5 6.7 6.9 7.0

Students without access to the SBP 7.2 6.5 5.7 14.5 6.9

Students without access to the NSLP 2.1 1.7 2.5 5.7 2.3

Total student enrollment: Weighted n 23,049,561 9,106,558 13,786,311 2,132,498 48,074,928

Total SFAs: Weighted n

1

12,269 9,158 10,488 4,450 14,281

1

n is less than 14,678 weighted (1,401 unweighted) because not all SFAs have each type of school and item non-response. 

Data Source: SFA Director Survey 2011, question 3.1. 

 

14 Year 1 data were collected on total enrollment and numbers of students approved for F/RP meals. In Year 2, data will be collected 

on the number of meals claimed for reimbursement by income-eligibility status of students. 
37

While access to school meals in public schools was high, it was not universal: 7 percent of 

students did not have access to the SBP, and 2 percent did not have access to the NSLP during SY 

2011-12. Students did not have access to the programs either because their school did not participate 

or they were attending half-day kindergarten and did not eat meals at school. Students enrolled in 

schools with nontraditional grade spans (“Other” schools) were least likely to have access to the SBP 

(15 percent were without access) and the NSLP (6 percent were without access) compared with 

elementary, middle, and high schools. 

More than half of the students enrolled in public-school SFAs are approved for either F/RP 

meals. Specifically, free meals are intended for students at the lowest income levels. Table III-6 

shows that a higher percentage of students in very large SFAs as compared to small ones were 

approved for free meals (50 percent versus 42 percent). Similarly, a higher percentages of students in 

city areas than in suburban areas were approved for free meals (54 percent versus 35 percent). In 

contrast to free meals, smaller SFAs and those located in rural areas or towns reported relatively 

higher percentage of students approved to receive reduced-price meals. 

SFA Participation in Other Programs 

SFA Directors were also asked about their participation in other FNS-administered 

programs or initiatives that complement the NSLP and the SBP. These include extending meal 

service beyond lunch and breakfast (NSLP Afterschool Snack Program and the CACFP At-Risk 

Afterschool Snack or Supper program), offering meal service in the summer (SFSP), providing 

access to fruits and vegetables during the school day (DoD Fresh Program, FFVP, and farm to 

school activities), and creating healthier school environments (HUSCC). A short description of each 

of these programs or initiatives is provided here. 

Afterschool Snacks: The NSLP offers cash reimbursement to help schools serve snacks to 

students in afterschool activities aimed at promoting the health and well-being of children 

and youth. To be eligible, a school must provide students with regularly scheduled 

afterschool activities in an organized, structured, and supervised environment, including 

educational or enrichment activities. 

The Child and Adult Care Food Program: Schools that sponsor community-based programs that 

offer enrichment activities for at-risk children and youth, age 18 years and under, after the 

regular school day ends, can provide free meals and snacks through CACFP. Programs must 

be offered in areas where at least 50 percent of the children are eligible for F/RP meals 

based on the local school attendance area. 

Summer Food Service Program: The SFSP was established to ensure that low-income children 

continue to receive nutritious meals when school is not in session. Free meals that meet 

Federal nutrition guidelines are provided to all children at approved SFSP sites in areas with 

significant concentrations of low-income children. The Seamless Summer Option has similar 

goals and is streamlined for SFAs participating in the NSLP or the SBP.15

 

15 http://www.fns.usda.gov/cnd/seamless_summer.htm.
3

38

Table III-6. Percentage of Students, in Each Grade Level, Approved to Receive Free Meals and Reduced-Price Meals by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of students

Elementary Middle High Other All schools

Percent 

of 

students

Wgtd 

students 

(millions)

Wgtd 

SFAs1

Percent 

of 

students

Wgtd 

students 

(millions)

Wgtd 

SFAs1

Percent 

of 

students

Wgtd

students 

(millions)

Wgtd 

SFAs1

Percent 

of 

students

Wgtd 

students 

(millions)

Wgtd 

SFAs1

Percent 

of 

students

Wgtd 

students 

(millions)

Wgtd 

SFAs2

Free meals

All SFAs 48.8% 23.0 12,269 42.6% 9.1 9,158 36.9% 13.8 10,488 41.5% 2.1 4,450 43.9% 48.1 14,281

SFA size

Small (1-999) 46.1 1.6 5,472 36.3 0.4 3,026 36.6 0.9 4,024 44.0 0.5 2,022 42.1 3.3 7,207

Medium (1,000-4,999) 43.3 5.5 5,021 37.4 2.5 4,415 31.3 3.6 4,710 39.4 0.5 1,474 38.4 12.0 5,257

Large (5,000-24,999) 46.8 7.6 1,512 40.3 3.1 1,461 34.6 4.5 1,484 44.1 0.5 754 41.9 15.7 1,545

Very large (25,000+) 54.6 8.4 264 49.6 3.1 256 43.3 4.8 270 39.4 0.7 200 50.0 17.0 272

Urbanicity 

City 58.3 8.1 1,230 53.1 2.8 855 47.8 4.3 890 47.5 0.8 541 54.1 16.0 1,614

Suburban 39.2 8.0 2,405 34.0 3.5 2,025 28.6 5.1 2,125 33.4 0.5 876 34.8 17.1 2,791

Town 52.0 2.7 2,356 45.4 1.2 2,137 37.5 1.7 2,262 40.8 0.3 1,102 45.9 6.0 2,724

Rural 46.2 4.2 6,278 40.6 1.6 4,141 35.0 2.6 5,210 41.1 0.6 1,930 41.6 9.0 7,151

Reduced-price meals

All SFAs 7.0% 23.0 12,269 7.5% 9.1 9,158 6.7% 13.8 10,488 6.9% 2.1 4,450 7.0% 48.1 14,281

SFA size

Small (1-999) 9.1 1.6 5,472 9.4 0.4 3,026 8.8 0.9 4,024 8.5 0.5 2,022 9.0 3.3 7,207

Medium (1,000-4,999) 7.3 5.5 5,021 7.7 2.5 4,415 6.9 3.6 4,710 7.9 0.5 1,474 7.3 12.0 5,257

Large (5,000-24,999) 7.2 7.6 1,512 7.7 3.1 1,461 6.5 4.5 1,484 7.4 0.5 754 7.1 15.7 1,545

Very large (25,000+) 6.2 8.4 264 6.9 3.1 256 6.3 4.8 270 4.6 0.7 200 6.3 17.0 272

Urbanicity 

City 6.4 8.1 1,230 7.3 2.8 855 6.5 4.3 890 5.3 0.8 541 6.5 16.0 1,614

Suburban 6.6 8.0 2,405 6.9 3.5 2,025 6.0 5.1 2,125 5.5 0.5 876 6.5 17.1 2,791

Town 8.1 2.7 2,356 8.7 1.2 2,137 7.7 1.7 2,262 7.6 0.3 1,102 8.1 6.0 2,724

Rural 8.0 4.2 6,278 8.2 1.6 4,141 7.7 2.6 5,210 9.9 0.6 1,930 8.1 9.0 7,151

Percentages were calculated by summing the number of students approved for F/RP meals across all SFAs and dividing by the number of students served by each SFA. Table does not show the relationship 

between the percentage of students approved for F/RP meals and SFA poverty level because the SFA poverty level variable, itself, is based on the percentage of students approved for F/RP meals. 

1

n is less than 14,678 because not all SFAs have each type of school and item non-response. 

2

n is less than 14,678 due to item non-response. 

Data Source: SFA Director Survey 2011, question 3.1. 
39

DoD Fresh Fruit and Vegetable Program: The DoD Fresh Program allows schools to use USDA 

Foods entitlement dollars to buy fresh produce. The program is available to all schools and 

operated by the Defense Logistics Agency at DoD. 

USDA Fresh Fruit and Vegetable Program: The FFVP reimburses selected elementary schools 

with high rates of F/RP meal enrollment for providing fresh fruits and vegetables to 

students during the school day outside of normal school breakfast and lunch meals. The goal 

of the FFVP is to improve students’ overall diet and create healthier eating habits.16

Farm to School: The USDA Farm to School Program is operated by FNS through its seven 

regional offices around the country; in each is a farm to school regional lead who is available 

to provide farm to school-related support to state agencies and other entities in that region. 

USDA awards up to $5 million in grants to help schools connect with local producers and 

teach students where their food comes from. Funds support activities ranging from training, 

planning, and developing partnerships, to purchasing equipment, planting school gardens, 

and organizing field trips. 

HealthierUS Schools. Established in 2004, HUSSC is a voluntary certification initiative 

recognizing those schools enrolled in Team Nutrition and participating in the NSLP that 

have created healthier school environments through promotion of nutrition and physical 

activity. The certification initiative includes four award levels—Bronze, Silver, Gold, and 

Gold Award of Distinction. In 2010, as part of the Let’s Move initiative, First Lady Michelle 

Obama called on stakeholders to double the number of HUSSC schools and to continue to 

add 1,000 schools per year for 2 years after that. When the data for the study were collected 

in SY 2011-12, an estimated 4,030 schools had received certification. As of March 2013, 

USDA reported that 5,524 schools in 49 states and the District of Columbia have received 

certification.17

 SFAs and their schools may simultaneously participate in several FNS nutrition programs. 

Table III-7 indicates that 35 percent of SFAs have at least one school that took part in the FFVP 

(which is only available to elementary schools); 32 percent of SFAs have at least one school that 

participated in the NSLP Afterschool Snack Program; 30 percent of SFAs participate in the SFSP; 

and 26 percent of SFAs participate in DoD Fresh. DoD Fresh and FFVP both target increasing the 

quantities of fresh fruits and vegetables in students’ diets. About 45 percent (not shown) of SFAs 

had schools participating in at least one of these programs. Because the CACFP At-Risk Afterschool 

Snack or Supper Program was only available in a limited number of states before the enactment of 

the HHFKA, it is not surprising that only 4 percent of SFAs reported participating in the program 

when the survey data were collected. 

 

16 In March 2013 FNS released an evaluation of the Fresh Fruit and Vegetable Program: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/cnp.htm.

17 http://www.fns.usda.gov/hussc, accessed April 26, 2013. Beginning in 2010, monetary incentives were available for HUSSC 

schools as follows: $2,000, Gold Award of Distinction; $1,500, Gold; $1,000, Silver; and $500, Bronze. 
40

Table III-7. Percentage of SFAs with One or More Schools Participating in Other Nutrition 

Programs, SY 2011-12

Program Percentage of SFAs 

USDA FFVP 34.7%

NSLP Afterschool Snack Program 31.9

SFSP 30.0

DoD Fresh 26.0

CACFP At-Risk Afterschool Snack or Supper Program 4.4

Total SFAs: Weighted n 14,544

Total SFAs: Unweighted n 1,3921

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 11.1 and 11.2. 

Special Initiatives to Improve Nutrition and the School Environment 

 Because this is an SFA-focused study, questions about the USDA FFVP were limited to 

whether or not SFAs had participating schools. However, given increasing interest in promoting 

fruits and vegetables, improving the school environment, and promoting more local/regional foods, 

the survey requested additional information on satisfaction with DoD Fresh, participation in farm to 

school activities, and level of recognition in the HUSSC. 

DoD Fresh 

 Although the DoD Fresh Program was widely available, only about one-quarter of SFAs 

reported participating in it during SY 2011-12. Among SFAs participating in the program, more than 

91 percent were satisfied or very satisfied with major aspects of the program as shown in Table III8. Among the small group of SFA directors who commented on other aspects of the program, 83 

percent were dissatisfied or very dissatisfied. The most common “other” responses given by SFA 

directors focused on the quality and freshness of the items (48 percent, not shown), the variety of 

items offered (26 percent, not shown), and the availability of items (10 percent, not shown). 

Additionally, respondents who were dissatisfied with any aspect of DoD Fresh were asked to 

expand on the reasons. Common reasons included the level of difficulty of the online ordering 

system, the high price of produce, and concerns that the produce was not fresh, took too long to 

ship, or arrived spoiled. 
41

Table III-8. Among DoD Fresh Program Participants, the Percentage of SFAs Satisfied with 

the Program, SY 2011-12

Aspects of the program

Among SFAs that participate in program, the percentage of 

SFAs: Total SFAs

Very 

satisfied Satisfied Dissatisfied

Very 

dissatisfied

Weighted 

n

Unweighted

n

1

Price for fruits and vegetables 35.2 % 56.0% 6.7% 2.1% 3,661 456

Online ordering 41.5 50.3 6.6 1.6 3,488 436

Overall customer service 41.5 52.7 3.6 2.1 3,624 451

Other210.8 6.5 52.3 30.5 360 55

1 

n is less than the 470 SFAs that participated in the DoD Fresh Program due to item non-response. 

2

 Other responses included: quality and freshness, variety of items offered, availability of items, ability to adjust orders or return items, timing 

of ordering, and delivery issues. 

Data Source: SFA Director Survey 2011, question 11.3. 

As shown in Table III-9, among DoD Fresh participants, the percentage of SFAs satisfied 

with the price for fruits and vegetables varied by SFA characteristics. Virtually all small SFAs (98 

percent) were satisfied, but only 76 percent of very large SFAs were satisfied. Similarly, as SFA size 

and urbanicity are closely related (larger SFAs tend to be urban or suburban), these differences in 

satisfaction with price may reflect the fact that larger, urban, and suburban SFAs may be used to 

lower prices due to their volume purchasing, making the DoD Fresh Program relatively less 

attractive. Ninety-five percent of SFAs were satisfied with the price for fruits and vegetables in rural 

areas, but only 84 percent of SFAs in a city reported satisfaction. In terms of online ordering, there 

were no significant differences in satisfaction by SFA characteristics, with satisfaction ranging from 

87 to 97 percent. Similarly, SFAs report high satisfaction with overall customer service, with 94 

percent satisfied and no significant difference by SFA characteristics. 

Farm to School Activities 

Farm to school activities can be varied, ranging from culinary classes to visits to farms. Farm 

to school activities generally center around procurement of local or regional foods and food, 

agriculture or nutrition-based educational activities such as but not limited to: 

 Serving local food products in school meals and snacks; 

 Serving local food products in classrooms (snacks, taste tests, educational tools); 

 Conducting educational activities related to local foods such as farmers in the classroom 

and culinary education focused on local foods; field trips to farms, farmers' markets, or 

food processing facilities; and educational sessions for parents and community 

members; and 

 Creating and tending school gardens (growing edible fruits and vegetables). 
3

42

Table III-9. Among DoD Fresh Program Participants, the Percentage of SFAs Satisfied with Various Aspects of Program by SFA 

Characteristics1, SY 2011-12

SFA characteristics

Prices of fruits & vegetables Online ordering Overall customer service

Percentage of 

SFAs

Total SFAs

Percentage of 

SFAs

Total SFAs

Percentage of 

SFAs

Total SFAs

Weighted 

n

Unweighted 

n

Weighted 

n

Unweighted 

n

Weighted 

n

Unweighted 

n

All SFAs 91.1% 3,661 456191.8% 3,488 436194.2% 3,624 4511

SFA size2

Small (1-999) 98.0 1,128 53 87.5 1,100 52 98.0 1,128 53

Medium (1,000-4,999) 88.9 1,711 176 94.7 1,596 165 93.4 1,682 173

Large (5,000-24,999) 88.1 705 157 91.8 680 152 90.5 696 155

Very large (25,000+) 76.1 118 70 90.9 112 67 90.6 118 70

Urbanicity3

City 84.4 464 105 91.9 467 103 89.1 475 106

Suburban 94.0 813 129 96.2 768 122 92.9 814 128

Town 85.8 920 93 93.5 833 86 96.1 893 90

Rural 95.1 1,464 129 88.3 1,420 125 95.4 1,442 127

Poverty level 

Low (0-29% F/RP) 89.6 763 108 97.4 730 104 93.8 758 107

Medium (30%-59% F/RP) 92.2 1,745 209 92.6 1,645 199 95.0 1,711 205

High (60% or more F/RP) 90.6 1,154 139 86.9 1,122 133 93.3 1,154 139

1 

n is less than the 470 SFAs that participate in the DOD Fresh Program due to item non-response.

2

Percentage of SFAs satisfied with the prices of fruits and vegetables differed significantly by SFA size at the .05 level.

3 Percentage of SFAs satisfied with the prices of fruits and vegetables differed significantly by urbanicity at the .05 level.

Data Source: SFA Director Survey 2011, question 11.3. 
43

As shown in Table III-10, about 20 percent of SFA directors reported that their districts 

were involved in some form of farm to school activities. However, 51 percent (not shown) of SFAs 

reported giving preference to purchasing locally sourced unprocessed foods for school meals 

programs at least “some of the time” in SY 2011-12, suggesting that many SFA directors excluded 

this activity when reporting their districts’ involvement in farm to school activities. SFA participation 

in farm to school activities varies with SFA size, urbanicity, and poverty level. Although 45 percent 

of very large SFAs are involved with farm to school, only 14 percent of small SFAs are involved. 

Suburban SFAs participate about twice as often as city or town SFAs (31 percent versus 15 and 17 

percent, respectively). Only 19 percent of SFAs in rural areas reported participation in the program. 

Low-poverty SFAs were more than twice as likely to participate as high-poverty SFAs (29 versus 14 

percent). 

Table III-10. Percentage of SFAs that Participate in the Farm to School Activities by SFA 

Characteristics, SY 2011-12

SFA characteristics Percentage of SFAs

Total SFAs

Weighted n Unweighted n

All SFAs 20.4%114,530 1,3912

SFA size3

Small (1-999) 13.7 7,283 328

Medium (1,000-4,999) 24.9 5,338 531

Large (5,000-24,999) 31.8 1,625 363

Very large (25,000+) 44.7 284 169

Urbanicity3

City 14.9 1,599 254

Suburban 31.1 2,855 378

Town 16.7 2,763 263

Rural 18.9 7,312 496

Poverty level3

Low (0-29% F/RP) 28.6 3,371 345

Medium (30-59% F/RP) 20.7 6,761 645

High (60% or more F/RP) 13.8 4,398 401

1

 Although only 20 percent of SFAs said they participated in farm to school activities, 51 percent of SFA directors indicated that they gave 

geographic preference to locally grown food, which is typically considered a farm to school activity. 

2

n is less than 1,401 due to item non-response.

3 Percentage of SFAs participating in farm to school activities differed significantly by SFA size, urbanicity, and poverty level at the .05 level.

Data Source: SFA Director Survey 2011, question 11.5. 

 SFA directors who reported participating in farm to school activities were asked to indicate 

which activities (aside from buying locally sourced foods) their schools participated in during SY 

2011-12. Table III-11 shows that with 80 percent of SFAs participating, taste testing was the most 

commonly reported activity. Nutrition education at school was a very close second at 79 percent. 

Almost half of the SFAs reported having agriculture-related lessons and curriculum (47 percent) and 

school or community gardens (45 percent). Over a third of SFAs (37 percent) reported participation 

in farm tours. Parent and community educational lessons were less common activities (28 percent 

and 19 percent, respectively). 
44

Table III-11. Among Farm to School Participants, the Percentage of SFAs that Participate in 

Various Specific Activities, SY 2011-121

Farm to school activity Percentage of SFAs

Taste testing 80.0%

Nutrition education at school 78.8

Agriculture-related lessons and curriculum 47.0

School or community gardens 44.8

Farm tours 36.9

Parent educational lessons 28.0

Community educational lessons 19.3

Total SFAs: Weighted n 2,971

Total SFAs: Unweighted n 3662

1

 In the list of farm to school activities, the questionnaire did not include giving preference to locally grown foods but rather asked about these 

procurement preferences separately in questions 10.1 to 10.4. Fifty-one percent of SFAs reported giving preference to locally grown, raised, or 

produced foods. 

2 

n equals the 366 SFAs that reported participating in farm to school activities. 

Data Source: SFA Director Survey 2011, question 11.6. 

 While the intent of the nutrition education category was to distinguish between activities 

inside and outside of school, given the varied definitions and interpretations of nutrition education, 

it is likely that many directors selected this as a broad category and also selected other specific 

activities as part of their overall education efforts. Table III-12 indicates that this was likely the case 

given the high degree of overlap between nutrition education and other activities. 

Table III-12. Among SFAs Providing Nutrition Education, the Percentage of SFAs that Took 

Part in Other Farm to School Activities, SY 2011-12

Farm to school activities

Among SFAs providing nutrition education, the percentage of SFAs 

that took part in other farm to school activities

Agricultural related lessons and curriculum 56.8%

School or community gardens 47.4

Farm tours 44.2

Taste testing 87.9

Parent educational lessons 33.1

Community educational lessons 23.5

Total SFAs: Weighted n 2,340

Total SFAs: Unweighted n 2921

1 

n equals the 292 SFAs that reported providing nutrition education. 

Data Source: SFA Director Survey 2011, question 11.6. 

HealthierUS Schools Challenge 

 Table III-13 shows the percentage of SFAs with schools that received the HUSSC 

recognition in SY 2011-12 by level of award received. Over the past several years, there have been a 

number of changes to the HUSSC certification criteria to reflect the importance of the SBP as well 

as program and policy changes resulting from passage of the HHFKA. The data in this report reflect 
45

recognitions before the new criteria for applications submitted to state agencies went into effect.18

Approximately 6 percent of SFAs indicated that they had one or more schools that received one of 

the four award levels. Very large SFAs received the most awards, but the percentage of SFAs 

receiving awards is small for all other subgroups. 

Table III-13. Percentage of SFAs Recognized as a HealthierUS School by SFA Characteristics, 

SY 2011-12

SFA characteristics

Percentage of SFAs with schools recognized with: Total SFAs

Gold award 

of 

distinction Gold Silver Bronze

Any 

award1

Weighted 

n

Unweighted 

n

All SFAs 1.3% 1.2% 1.3% 2.8% 5.6% 14,678 1,401

SFA size1

Small (1-999) 0.9 0.4 0.3 1.5 2.8 7,374 332

Medium (1,000-4,999) 1.6 1.8 1.6 4.1 7.9 5,390 536

Large (5,000-24,999) 1.9 1.7 3.6 3.4 7.5 1,629 364

Very large (25,000+) 4.4 6.7 8.9 11.1 21.2 284 169

Urbanicity2

City 2.6 2.8 2.0 3.7 9.3 1,630 256

Suburban 2.1 2.0 2.2 4.3 7.8 2,885 380

Town 1.3 1.7 1.6 2.1 6.2 2,794 266

Rural 0.8 0.3 0.7 2.4 3.6 7,369 499

Poverty level3

Low (0-29% F/RP) 3.0 0.5 1.0 3.3 6.5 3,407 348

Medium (30%-59% F/RP) 0.6 0.8 1.4 2.8 4.9 6,828 650

High (60% or more F/RP) 1.3 2.2 1.4 2.5 5.9 4,443 403

1 Percentage of SFAs with schools recognized with gold, silver, bronze, or any award differed significantly by SFA size at the .05 level.

2 Percentage of SFAs with schools recognized with gold or any award differed significantly by urbanicity at the .05 level.

3 Percentage of SFAs with schools recognized with the gold award of distinction or gold differed significantly by poverty level at the .05 level.

Data Source: SFA Director Survey 2011, question 11.7. 

 All SFAs were asked to list the challenges their schools faced in trying to obtain HUSSC 

certification. A total of 11,005 (weighted) SFA directors responded to this question (not shown). 

Although the responses were diverse, the most frequent types of challenges reported involved 

finances and budget. SFA directors frequently cited the cost of food and labor and budgetary 

constraints as challenges in achieving HUSSC certification. They also reported that they did not have 

the time or staff to complete the required paperwork. Other challenges included getting students to 

eat healthier foods, obtaining the support of parents, and meeting requirements for whole grains, 

beans, or sodium. Some SFAs mentioned that the program simply was not a priority. 

 

18 The new criteria are summarized in an FNS FAQ: http://www.fns.usda.gov/tn/HealthierUS/faq.pdf, accessed April 26, 2013. Major changes 

include new breakfast criteria and updated lunch criteria, a new “other criteria for excellence” category, a change in how average daily participation 

is calculated, and modifications to nutrition education requirements and Local Wellness Policy criteria to be consistent with HHFKA. 
46

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47

Section IV: SFA Operations 

 Under the supervision of their states, SFAs operate their school-meal programs at the local 

level to provide nutritional meals to students at an affordable price. SFAs also process applications 

and certify students as being eligible for free or reduced-price lunches and maintain program data for 

reporting and reimbursement claims. How SFAs go about these activities likely affects the 

nutritional quality and appeal of the meals as well as production costs and efficiency. 

 At the most basic level, SFAs produce school meals through a production process that uses 

labor (staff), capital (kitchen facilities), and consumables (food). Many of the inputs in meal 

production are the result of long-term capital investments, such as kitchen equipment, and are 

essentially fixed in the short run and cannot be quickly changed. Also, an SFA’s socio-economic 

characteristics (size, urbanicity, etc.) are likely to affect the feasibility of production options as well as 

staffing, facilities and equipment, and purchasing. Therefore, how SFAs operate in terms of the 

inputs and procedures they use to produce school meals will likely affect how quickly they can adapt 

to changes such as the new regulations stemming from the HHFKA. Exploring SFA operations 

provides insights into how SFAs are currently conducting business and how well aligned their 

operations are with the goals of the HHFKA. Ultimately, this can be informative for identifying 

potential transition issues. 

 This section examines the different attributes of SFA operations, including the variation in 

SFA staffing in terms of credentials and responsibilities, the use of alternative kitchen and meal 

service systems, food safety, food procurement, menu planning, and SFAs use of non-USDA meal 

alternatives. In addition to describing the variation of these attributes in SFAs across the country, 

this section also considers how they may affect school meal production. 
48

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49

IV-1. Staff Credentials and Responsibilities 

Background 

 Administering the school-meal programs and delivering high-quality meals on a consistent 

basis require a skill set covering a range of food service operation components. SFA directors are 

usually responsible for planning menus that meet or exceed nutritional requirements; procure, store, 

and prepare meals on a timely basis; oversee the administrative efforts to ensure that eligibility for 

free and reduced-price meals is determined correctly; and ensure the accuracy of the meal counts 

and submission of claims for reimbursement. Directors must also make certain that health and 

sanitation standards for storage, preparation, and service of food are maintained. 

 Section 306 of the HHFKA explicitly recognizes the importance of establishing professional 

standards for school food service personnel. The Act requires USDA to establish a program of 

required education, training, and certification for all school food service directors at SFAs. The 

components of this program were under development at the time of data collection. The findings 

below, therefore, constitute a baseline for future assessment of the impact of FNS professional 

standards requirements for SFA directors. 

Research Questions 

 This chapter describes the education and certification requirements for SFA directors and 

answers research questions listed below. 

 What are the minimum educational and certification requirements for SFA directors? 

 What are the education, certification, and work experience of current SFA directors? 

Results 

Experience and Tenure 

 In general, SFA directors have a considerable amount of experience in the field of schoolfood service.19As seen in Table IV-1.1, summing across years of experience one can see that 89 

percent of SFA directors had more than 5 years of food service experience; nearly half (47 percent) 

had more than 20 years of total experience. Similarly, 61 percent of SFA directors had been in their 

current position for over 5 years. 

 

19 Total experience is calculated as years as SFA director (tenure) plus years of prior experience in food service. 
50

Table IV-1.1. Percentage of SFAs with Directors with Various Levels of Food Service and Job 

Tenure Experience, SY 2011-12

Type of experience

Percentage of SFAs with directors whose tenure in positions is: Total SFAs

Less than 5 years 5-10 years 11-20 years

More than 20 

years

Weighted 

n

Unweighted 

n

In food service 11.4% 12.8% 28.4% 47.4% 14,098 1,3671

In SFA director position 38.7 24.0 25.2 12.1 14,284 1,3801

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 14.1 and 14.2. 

 While total food service experience and tenure in the current position could make a 

difference in an SFA director’s effectiveness, tenure more directly corresponds to a director’s 

familiarity with his or her SFA and knowledge of how to accomplish improvements given the local 

environment. The mean number of years of tenure for SFA directors was 9.7 (not shown).20 The 

mean number of years in food service, including tenure as an SFA director, was 21.8 (not shown). 

Table IV-1.2 reveals that about one-third (37 percent) of SFA directors were relatively new to their 

position at the time of the survey and had less than 5 years of tenure. Examination of tenure level by 

SFA characteristics reveals no significant differences. 

Table IV-1.2. Percentage of SFAs with Directors with Various Tenure Levels by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with directors whose tenure in positions is: Total SFAs

Less than 5 

years 5-10 years 11-20 years

More than 20 

years

Weighted

n

Unweighted 

n

All SFAs 36.5% 20.6% 27.8% 15.1% 14,284 1,3801

SFA size

Small (1-999) 39.2 23.9 26.4 10.5 7,053 319

Medium (1,000-4,999) 39.8 24.9 23.1 12.1 5,330 530

Large (5,000-24,999) 33.7 20.8 26.9 18.6 1,616 362

Very Large (25,000+) 33.3 26.8 25.4 14.6 284 169

Urbanicity

City 42.7 23.6 26.5 7.2 1,543 252

Suburban 42.4 21.5 25.1 11.1 2,798 374

Town 38.0 22.6 22.8 16.5 2,760 264

Rural 36.7 25.6 25.9 11.8 7,183 490

Poverty level

Low (0-29% F/RP) 40.9 19.4 25.7 14.0 3,266 339

Medium (30%-59% F/RP) 37.4 26.2 24.5 11.9 6,665 642

High (60% or more F/RP) 39.0 24.1 26.0 10.9 4,352 399

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 14.2. 

 

20 SNDA IV Table 2.21 reports that the mean number of years of tenure for SFA directors was 10. 
51

Education 

Level of Education Required for SFA Directors 

 The educational requirements for SFA directors are typically set by the LEA. Table IV-1.3 

shows how the educational requirements for SFA directors vary by SFA characteristics. 

Approximately three-quarters (74 percent) of all SFAs do not require the director to have a 

bachelor’s degree. About one-fifth (22 percent) of SFA directors reported that a bachelor’s degree 

was required, and only a very small portion (5 percent) reported a graduate degree as a requirement. 

 The educational requirements for SFA directors appear to be associated with SFA size and 

urbanicity. Most small SFAs (88 percent) do not require a bachelor’s degree as compared to only 13 

percent of very large SFAs. Larger SFAs are much more likely to require a higher minimum level of 

education for SFA directors. Whereas 69 percent of very large SFAs required a bachelor’s degree, 

less than 9 percent of small SFAs did. A graduate degree was required in 17 percent of very large 

SFAs, 8 percent of large SFAs, and 4 percent of medium and small SFAs. Not surprisingly, the same 

pattern holds when examining SFAs by urbanicity, where a minimum of a bachelor’s degree is 

required in 43 percent of the SFAs located in cities but only 11 percent of SFAs located in rural 

areas. 

Table IV-1.3. Percentage of SFAs with Differing Director Education Requirements by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs where district requirements for 

SFA director education: Total SFAs

Require less 

than BA Require BA

Require graduate 

degree Weighted n Unweighted n

All SFAs 73.7% 21.6% 4.6% 14,013 1,3651

SFA size2

Small (1-999) 87.8 8.7 3.5 6,855 311

Medium (1,000-4,999) 69.4 26.2 4.4 5,257 523

Large (5,000-24,999) 38.9 53.1 8.0 1,616 362

Very Large (25,000+) 13.4 69.3 17.3 284 169

Urbanicity2

City 50.9 42.8 6.3 1,442 248

Suburban 58.3 36.2 5.5 2,709 368

Town 71.9 23.4 4.7 2,705 261

Rural 84.9 11.2 4.0 7,157 488

Poverty level2

Low (0-29% F/RP) 71.8 26.2 1.9 3,272 338

Medium (30%-59% F/RP) 77.8 18.0 4.2 6,531 634

High (60% or more F/RP) 68.8 23.7 7.5 4,210 393

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with various director education requirements differed significantly by SFA size, urbanicity, and poverty level at the .05 

level. 

Data Source: SFA Director Survey 2011, question 14.5. 
52

Education Level of Current SFA Directors 

 Table IV-1.4 displays the educational degrees of SFA directors by SFA characteristics. More 

than three-quarters of SFA directors have some college education. Only 23 percent have a high 

school degree or less, another 25 percent have some college; 11 percent have an associate’s degree; 

24 percent have a bachelor’s degree; and 17 percent have a graduate degree.21 Overall, this is a 

relatively high level of education given that 74 percent of the districts do not require SFA directors 

to have a bachelor’s degree. Directors who attained higher levels of education tend to be found at 

larger SFAs. Over 90 percent of directors at very large SFAs had a bachelor’s or graduate degree, 

and over 70 percent of directors at large SFAs had at least a bachelor’s degree, but only 30 percent 

of directors at small SFAs had attained a bachelor’s or graduate degree. Although not as 

pronounced, the education level of the SFA directors also significantly varies with urbanicity and 

poverty level. 

Table IV-1.4. Percentage of SFAs with Directors with Different Levels of Education by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with directors who have: Total SFAs

High school 

degree or 

less

Some 

college

Associate’s 

degree

Bachelor’s

degree

Graduate 

degree

Weighted

n

Unweighted

n

All SFAs 22.7% 25.2% 11.1% 24.0% 16.9% 14,417 1,3851

SFA size2

Small (1-999) 31.6 29.3 9.6 14.3 15.2 7,184 324

Medium (1,000-4,999) 17.7 23.7 14.1 29.7 14.8 5,332 530

Large (5,000-24,999) 3.6 16.2 9.3 44.7 26.2 1,616 362

Very large (25,000+) 1.4 3.6 3.6 44.2 47.3 284 169

Urbanicity2

City 7.6 22.4 7.9 34.7 27.4 1,553 253

Suburban 9.0 19.9 12.1 37.9 21.1 2,845 375

Town 18.5 28.2 12.1 27.6 13.7 2,787 265

Rural 33.0 26.8 11.1 14.8 14.3 7,231 492

Poverty level2

Low (0-29% F/RP) 16.7 22.5 16.3 32.0 12.6 3,280 339

Medium (30%-59% F/RP) 27.3 23.4 11.0 22.6 15.8 6,720 644

High (60% or more F/RP) 20.3 30.2 7.5 20.2 21.9 4,416 402

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with directors with varying levels of education differed significantly by SFA size, urbanicity, and poverty level at the .05 

level. 

Data Source: SFA Director Survey 2011, question 14.3. 

 

21 These data were collected October 2011-March 2012 and are broadly similar but slightly higher than the corresponding data in 

SNDA IV Table 2.21, which were collected in January-June 2010. It is unlikely that the difference represents an increase in 

educational level among SFA directors. Rather, it is likely the result of sampling variation and the fact that the SFA sample sizes 

and designs of both studies are slightly different. 
53

 Table IV-1.5 shows the relationship between SFA director’s education levels and their years 

of experience. In general, SFA directors with fewer than 11 years of experience had higher levels of 

education than those with more experience. For example, 39 percent of directors with fewer than 5 

years total food service experience have graduate degrees compared to about 12 percent of directors 

with more than 20 years total food service experience. Similarly, over half (54 percent) of directors 

with 11 or more years of total experience have only a high school degree or less compared to a 

quarter (26 percent) of directors with less than 11 years of total experience. Looking to the future, it 

is likely that the education level of SFA directors will increase as incumbents retire and new directors 

are selected to replace them. This change in education levels over time is well aligned with the 

development of professional standards for SFA directors as required by the HHFKA. 

Table IV-1.5. Percentage of SFAs with Directors with Different Highest Level of Education by 

Total Years of Directors’ Experience, SY 2011-12

SFA director’s total 

years of food service 

experience

Percentage of SFA’s with directors whose highest levels of education is: Total SFAs

High school 

degree or 

less

Some 

college

Associate’s 

degree

Bachelor’s 

degree

Graduate 

degree

Weighted

n

Unweighted 

n

All SFAs 22.7% 25.7% 11.1% 24.1% 16.4% 14,076 1,3661

Less than 5 years 10.8 17.4 5.3 28.0 38.5 1,613 115

5-10 years 14.7 31.5 9.4 23.1 21.2 1,800 135

11-20 years 32.0 25.4 8.8 20.4 13.5 3,997 367

More than 20 years 22.1 26.3 14.4 25.7 11.5 6,666 749

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 14.1, 14.2, and 14.3. 

Certification and Responsibilities 

 Section 306 of the HHFKA requires that FNS establish a program of required education, 

training, and certification for all school food service directors. FNS is expected to issue regulations 

implementing Section 306 by the end of 2013. The following is a description of the certifications 

required of and attained by SFA directors as of SY 2011-12. This information will provide a valuable 

point of comparison for similar data gathered after implementation of the professional standards 

regulations. 

Certification Requirements for SFA Directors 

 Often SFA directors are required to have certifications in addition to their education 

requirements. The SFA Director Survey included questions on both the requirements and 

credentials of the SFA director. Respondents selected from a comprehensive list of credentials with 

the expectation that an individual may hold multiple certifications. The credentials included licensed 
54

dietitian,22 school nutrition specialist, certified professional food manager, certified professional in 

food safety, certified professional food handler, and certified ServSafe Food Safety professional.23

 Figure IV-1.1 shows the percentage of SFAs with certification requirements as compared to 

the percentage of SFA directors holding these qualifications. The most commonly reported district 

requirement to be an SFA director was certification in ServSafe Food Safety; this was also the most 

commonly held credential among SFA directors. The least common requirement was licensed 

dietician (3 percent). However, nearly 6 percent of the SFA directors held this certification. 

Interestingly, about 42 percent (not shown) of the SFA directors indicated that their district did not 

have any of the listed certification requirements; about 14 percent (not shown) required the SFA 

director to be certified in all four areas (food manager, food safety, food handler, and ServSafe Food 

Safety) and about 15 percent (not shown) of the districts required the SFA director to be certified 

only in ServSafe Food Safety. Also about 23 percent (not shown) of the SFA directors did not have 

any of the listed certifications; 19 percent (not shown) were certified in all four areas (food manager, 

food safety, food handler, and ServSafe Food Safety), and about 20 percent (not shown) were only 

certified ServSafe Food Safety Professionals. 

Figure IV-1.1. Percentage of SFA with Certification Requirements as Compared to the 

Percentage of SFA Directors Holding the Qualification, SY 2011-12

n is less than 14,678 weighted (1,401 unweighted) because of item non-response. The estimate for question 14.6 on district requirements is 

based on 14,250 weighted (1,376 unweighted) responses, and the estimates for question 14.7 on certifications held by current SFA directors is 

based on 14,267 total (1,378 unweighted). Multiple responses were allowed. 

Data Source: SFA Director Survey 2011, questions 14.6 and 14.7. 

 

22 A licensed dietitian is a registered dietitian, but a registered dietitian may not be a licensed dietitian. 

23 Training and certification for professional food handlers, food safety professionals, and professional food managers are provided 

by the National Registry of Food Safety Professionals, the National Environmental Health Association, and NSF International 

(formerly the National Sanitation Foundation). Training for ServSafe Food Safety is provided by the National Restaurant 

Association.

41.3

28.5

25.3

22.3

11.4

2.8

54.8

37.0

31.8

30.4

17.2

5.6

0.0 10.0 20.0 30.0 40.0 50.0 60.0

Certified ServSafe Food 

Safety Professional

Certified Professional 

in Food Safety

Certified Professional 

Food Handler

Certified Professional 

Food Manager

School Nutrition Specialist

Licensed Dietitian

Percentage of SFAs

Certifications Held Certification Requirements
55

 As Figure IV-1.1 shows, overall, a greater percentage of SFA directors held each certification 

relative to the percentage of SFAs requiring the certification. For example, about 3 percent of the 

districts required licensed dietitians but twice as many SFA directors were licensed. Similarly, while 

about 41 percent of districts required certification in ServSafe Food Safety, about 55 percent of SFA 

directors were certified. 

 Table IV-1.6 shows the district requirements for SFA director licensure and certification as 

compared to the actual qualifications of the SFA directors by SFA characteristics. Consistent with 

the overall findings, across all types of SFAs, more SFA directors held licenses and certifications 

than districts that required them. The table also reveals that requirements vary substantially by SFA 

characteristics. For example, larger SFAs tended to have higher training requirements with 12 

percent of very large SFAs and 7 percent of large SFAs requiring that SFA directors be licensed 

dietitians compared to 2 percent of small SFAs. It appears that the requirements to be a licensed 

dietitian or school nutrition specialist often take the place of some other food handling 

certifications, and a smaller percentage of the larger SFAs require their directors to be food 

managers/handlers or certified in professional food safety, as compared to smaller SFAs. However, 

it is not surprising that SFA directors of large and very large SFAs are not required to be certified in 

these areas as it is unlikely that they are involved with food service preparation. Additionally, SFA 

directors in large and very large SFAs are more likely to have licensures and certifications above the 

typical requirements than those in small and medium SFAs. 
3

56

Table IV-1.6. Percentage of SFAs with Licensure Requirements as Compared to Percentage of SFA Directors who have the 

Qualifications by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs licensure/certification requirements (A) versus percentage of SFA directors who have required certification (B)

Licensed 

dietitian

School nutrition 

specialist

Certified 

professional food 

manager

Certified 

professional in 

food safety

Certified 

professional 

food handler

Certified 

ServSafe food 

safety 

professional

Total SFAs

Weighted n Unweighted n

A B A B A B A B A B A B A B A B

All SFAs 2.8% 5.6% 11.4% 17.2% 22.3% 30.4% 28.5% 37.0% 25.3% 31.8% 41.3% 54.8% 14,250 14,267 1,3761

1,3781

SFA size2,3

Small (1-999) 1.6 0.6 9.2 10.3 22.0 27.9 29.3 33.3 25.8 29.6 35.3 41.8 7,056 7,079 319 320

Medium (1,000-4,999) 2.5 7.5 12.6 20.4 24.0 34.5 29.5 42.6 26.0 34.3 47.3 66.3 5,293 5,282 526 526

Large (5,000-24,999) 7.2 17.3 16.9 33.0 19.1 28.9 24.0 36.1 22.8 34.7 48.1 71.5 1,616 1,622 362 363

Very large (25,000+) 12.1 29.5 10.1 35.4 15.5 28.6 18.1 30.4 14.4 23.0 41.1 69.1 284 284 169 169

Urbanicity4,5

City 8.6 13.0 13.8 20.1 20.5 25.8 23.1 23.9 22.9 25.9 43.1 49.3 1,543 1,543 252 252

Suburban 4.2 9.1 13.7 22.3 24.4 33.6 37.2 46.0 30.6 39.6 54.4 68.5 2,767 2,759 372 372

Town 2.0 6.7 11.6 21.3 24.7 34.0 27.5 41.9 23.9 32.8 35.6 53.6 2,741 2,746 263 263

Rural 1.3 2.3 9.9 12.9 20.9 28.9 26.8 34.5 24.3 29.6 38.1 51.3 7,198 7,219 489 491

Poverty level6,7

Low (0-29% F/RP) 2.6 7.0 10.6 20.1 21.0 29.1 32.9 44.0 24.6 31.2 46.2 65.6 3,280 3,250 339 338

Medium (30%-59% F/RP) 2.9 6.3 9.3 16.8 21.5 33.3 24.6 35.5 21.7 31.6 38.4 54.4 6,618 6,653 638 641

High (60% or more F/RP) 2.8 3.6 15.1 15.5 24.5 27.1 31.2 34.2 31.4 32.5 42.2 47.4 4,352 4,364 399 399

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFA directors required to be licensed dietitians, school nutrition specialists, and certified ServSafe food safety professionals differed significantly by SFA size at the .05 level. 

3 Percentage of SFA directors holding different certifications differed by SFA size for all six certifications at the .05 level. 

4 Percentage of SFA directors required to be licensed dietitians, certified professionals in food safety, and certified ServSafe food safety professionals differed significantly by urbanicity at the .05 level. 

5 Percentage of SFA directors being licensed dietitians, school nutrition specialists, certified professionals in food safety, certified professional food handlers, and certified ServSafe food safety professionals 

differed significantly by urbanicity at the .05 level. 

6

 Percentage of SFA directors required to be school nutrition specialists, certified professionals in food safety, and certified professional food handlers differed significantly by poverty level at the .05 level. 

7

 Percentage of SFA directors being licensed dietitians, certified professionals in food safety, and certified ServSafe food safety professionals differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, questions 14.6 and 14.7. 
57

District-Level Responsibilities 

 Table IV-1.7 shows that nearly two-thirds (64 percent) of SFA directors reported that they held 

their positions full-time and did not have any other responsibilities; about 22 percent are full-time with 

other responsibilities, and 15 percent of SFA directors were engaged part-time. As one might expect, in 

very large SFAs, 93 percent of directors were full-time with no other responsibilities. Even in small 

SFAs, however, about half (48 percent) of directors were full-time with no other responsibilities. The 

differences in SFA directors’ work status and responsibilities by urbanicity or poverty level were not 

statistically significant. 

The most frequently reported “Other” responsibilities were superintendent, school cook, and 

wellness coordinator. Additional “Other” responsibilities noted by part-time SFA directors were 

principal, warehouse supervisor, cafeteria manager, teacher, treasurer, administrative assistant, 

maintenance worker, and purchasing manager. 

Table IV-1.7. Percentage of SFAs with Directors who are Full-Time or Part-Time by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with directors who are: Total SFAs

Full-time directors, 

no other 

responsibilities

Full-time directors 

with other 

responsibilities

Part-time 

directors

Weighted 

n

Unweighted

n

All SFAs 63.5% 21.6% 14.9% 14,329 1,3811

SFA size2

Small (1-999) 48.2 30.2 21.6 7,106 321

Medium (1,000-4,999) 75.4 14.4 10.1 5,322 529

Large (5,000-24,999) 86.5 10.2 3.3 1,616 362

Very Large (25,000+) 92.5 4.7 2.8 284 169

Urbanicity

City 64.6 21.7 13.6 1,543 252

Suburban 70.5 19.5 10.0 2,845 375

Town 68.4 20.6 11.0 2,787 265

Rural 58.6 22.8 18.6 7,154 489

Poverty level

Low (0-29% F/RP) 69.1 15.7 15.2 3,252 338

Medium (30-59% F/RP) 64.4 22.5 13.1 6,698 643

High (60% or more F/RP) 58.0 24.6 17.4 4,378 400

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with directors with various district-level responsibilities differed significantly by SFA size at the .05 level. 

Data Source: SFA Director Survey 2011, question 14.4. 
58

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59

IV-2. Kitchens and Meal Service 

Background 

 Food service facilities vary between SFAs and schools. Additionally, the experience students 

have each day—where they eat, how much time they have to eat, what happens before and after their 

meals—also varies. These factors are important to the health of students and have been shown to 

affect obesity (SNDA III: Volume I, 2007). 

 SFAs vary in the types of kitchen facilities and meal service systems available at schools. Onsite 

school kitchens both prepare and serve the meals for the school in which they are located. Base school 

kitchens are school kitchens that prepare and serve meals in the school in which they are located, but 

also produce food items or whole meals that are sent to other schools and served to the students in the 

receiving (satellite) schools. A base kitchen may have one or many satellites for which it prepares meals. 

Central kitchens are not located in schools. No food is served to students directly from a central 

kitchen. Rather, these are production facilities (and in many ways are similar to commercial food 

production facilities). To be economically viable, a central kitchen must produce a very large volume of 

meals for the schools that it serves. Satellite school kitchens primarily serve food items produced 

elsewhere. Although some satellite kitchens may produce a small amount of their meals onsite, for the 

most part they receive and serve foods produced in a central or base kitchen. The findings included in 

this section use the following categories for kitchen facilities: 

 Onsite production only: this includes SFAs that use only onsite kitchens to prepare and 

serve meals; 

 Off-site production only (base and central): this includes SFAs that use base or central 

kitchens to prepare and serve meals (as opposed to using onsite kitchens) and may send to 

a receiving satellite kitchen; 

 Combination or other: this includes SFAs that use a variety of kitchen types where some 

food is prepared onsite for consumption and some food is received fully or partially 

prepared from an off-site location. 

Meal service systems such as cafeteria configurations also vary. The types of kitchen facilities 

and meal service systems dictate the staffing needs, qualifications of the food service staff, food 

purchasing practices, and meal prices. 

Research Questions 

 In this study, the following research questions relate to where school meals are prepared, how 

the meals are served, and what students do once they have their meals. 

 What types of kitchen facilities (e.g., central kitchen, satellite) do SFAs utilize? 
60

 Are SFA food service facilities used to prepare foods for purposes other than the NSLP and the SBP? 

Are the facilities used to prepare reimbursable meals for other programs (Child and Adult Care Food 

Program [CACFP], Summer Food Service Program [SFSP], Elderly Nutrition Program, Head Start, 

other schools or school systems, disaster feeding, etc.)? 

 Are the facilities used to prepare food for other nonreimbursable purposes (events such as athletic events, 

Parent-Teacher Association [PTA] meetings, school staff meals, etc.)? 

 What types of meal service systems (e.g., cafeteria configuration, meal kiosks) do SFAs utilize? 

 Where do students eat lunch (eating locations, open versus closed campus)? 

 Do students have sufficient time to eat their school breakfast and lunch? 

 In elementary schools, is lunch provided before or after recess? 

Results 

Kitchen Facilities 

 There are primarily two types of kitchens used by SFAs to prepare school meals: (1) onsite 

kitchens and (2) base or central kitchens with satellite or receiving kitchens. Onsite kitchens are located 

at the school where students are served their meals and offer the simplest, most direct means for 

preparing and serving food; all food is prepared onsite. SFAs using base or central kitchens, on the 

other hand, prepare food for shipment to multiple schools that may have satellite or receiving kitchens 

that handle the final stages of preparing the meals. These types of base or central kitchen facilities are 

referred to in the tables as offsite kitchens. SFAs may also have a combination of types of kitchens in 

the various schools they serve (i.e., a mix of onsite and offsite kitchens), which may reflect decisions 

made by the local school system over many years regarding school construction and renovations. A 

very small percentage of SFAs (1.4 percent, not shown separately) reported using some other type of 

kitchen. 

 SFA directors were asked to identify the types of kitchen facilities used across the schools they 

serve. During SY 2011-12, just over half of the SFAs (55 percent) operated exclusively with onsite 

kitchens where all food is prepared and served onsite as shown in Table IV-2.1. Only 17 percent of 

SFAs reported using only base or central kitchens to prepare meals for distribution to satellite or 

receiving kitchens (i.e., offsite kitchens). Additionally, 29 percent of SFAs reported using a combination 

of onsite and offsite kitchens or some other type of kitchen facility. Thus, the most common type of 

kitchen used is the onsite kitchen. 

 The types of kitchen facilities significantly varied by SFA size and urbanicity, but not by poverty 

level. Small SFAs were more likely to operate exclusively with onsite kitchens. Sixty-two percent of 

small SFAs used only onsite kitchens, whereas just over half (53 percent) of medium SFAs and 36 

percent of large SFAs reported using only onsite kitchens. Only 18 percent of very large SFAs used 

onsite kitchens only. However, a majority (65 percent) of very large SFAs used a combination of onsite 

and offsite kitchens or used some other type of kitchen facility. 
61

Table IV-2.1. Percentage of SFAs Using Different Types of Kitchen Facilities by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs using the following types 

of kitchen facilities: Total SFAs

Offsite

kitchen only

Onsite 

kitchen only

Combination 

or other

Weighted 

n

Unweighted 

n

All SFAs 16.5% 54.7% 28.8% 14,422 1,3881

SFA size2

Small (1-999) 16.6 61.8 21.7 7,160 324

Medium (1,000-4,999) 17.7 53.1 29.2 5,350 532

Large (5,000-24,999) 11.8 35.6 52.6 1,629 364

Very Large (25,000+) 16.6 18.0 65.4 283 168

Urbanicity2

City 10.4 26.7 62.9 1,511 251

Suburban 20.0 41.6 38.3 2,810 375

Town 22.9 47.6 29.5 2,767 265

Rural 13.9 68.2 17.8 7,335 497

Poverty level

Low (0-29% F/RP) 16.3 57.6 26.1 3,358 345

Medium (30%-59% F/RP) 17.5 53.5 29.0 6,712 644

High (60% or more F/RP) 14.9 54.5 30.6 4,352 399

1

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs using different types of kitchen facilities differed significantly by SFA size and urbanicity at the .05 level.

Data Source: SFA Director Survey 2011, question 4.19. 

Use of Food Service Facilities by Other Programs 

 In addition to using food service facilities for student-related activities during the school day 

or after school, schools can make the facilities available for other programs or activities depending 

on the policies set by the local school district. For example, the school food service facilities may be 

used to prepare meals for other reimbursable meal programs, such as CACFP or SFSP, as well as for 

nonreimbursable meal programs such as catering school and non-school functions. The school 

principal, the facilities director, or the SFA director (or the cafeteria manager) is usually responsible 

for overseeing policies and regulations for facility use adopted by the local school board. 

 For SY 2011-12, 62 percent of SFAs indicated that the school food service facilities were 

used only to prepare food for the SBP and NSLP as shown in Table IV-2.2. Twenty-three percent 

used the facilities to prepare both reimbursable and nonreimbursable meals for other programs in 

addition to the SBP and NSLP. Another 2 percent used their facilities to prepare only reimbursable 

meals for other programs (e.g., CACFP, SFSP, Head Start, etc.), and 13 percent used the facilities to 

prepare only nonreimbursable meals for other programs (e.g., athletic events, PTA meetings, school 

staff meals, etc.). The smaller the size of the SFA, the more likely was the SFA to use facilities for 

SBP and NSLP only. Similarly, SFAs with medium and high poverty levels and offsite kitchens also 

tended to use their kitchens only for the SBP and NSLP relative to others. 
62

Table IV-2.2. Percntage of SFAs that Used Food Service Facilities for Various Types of 

Reimbursable and Nonreimbursable Meals by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that used food service facilities for preparing 

food for: Total SFAs

SBP 

and 

NSLP 

meals 

only

The SBP and NSLP and:

Weighted 

n

Unweighted 

n

Other 

reimbursable and 

nonreimbursable 

meals

Other 

reimbursable 

meals only

Other 

nonreimbursable 

meals only

All SFAs 61.6% 23.4% 2.0% 13.1% 14,566 1,3941

SFA size2

Small (1-999) 72.2 11.8 2.7 13.3 7,302 329

Medium (1,000-4,999) 53.7 30.8 1.2 14.4 5,351 532

Large (5,000-24,999) 43.6 45.4 1.5 9.5 1,629 364

Very Large (25,000+) 40.9 53.8 2.1 3.2 284 169

Urbanicity

City 63.3 24.6 6.4 5.7 1,630 256

Suburban 55.9 26.4 0.1 17.6 2,885 380

Town 55.6 32.8 0.7 10.9 2,775 264

Rural 65.8 18.2 2.2 13.8 7,276 494

Poverty level2

Low (0-29% F/RP) 57.7 15.9 0.4 26.0 3,376 346

Medium (30%-59% F/RP) 62.9 25.0 1.3 10.9 6,747 645

High (60% or more F/RP) 62.6 26.6 4.3 6.5 4,443 403

Type of kitchen2

Onsite kitchen only 59.4 26.9 4.2 9.5 2,343 218

Offsite kitchen only 62.4 20.0 0.6 16.9 7,860 638

Combination or other 59.4 28.6 3.5 8.5 4,106 525

1

n is less than 1,401 due to item non-response.

2 Percentage of SFAs using their food service facilities for various types of reimbursable and nonreimbursable meals differed significantly by SFA 

size, urbanicity, poverty level, and type of kitchen at the .05 level. 

Data Source: SFA Director Survey 2011, questions 4.20, 4.21, and 4.22. 

Table IV-2.3 shows that for SFAs that allowed food service facilities to be used to prepare 

reimbursable meals for other programs or events, 39 percent of the SFAs supported SFSP meals. 

Other reimbursable programs commonly using SFA food service facilities were Head Start (28 

percent) and disaster feeding (19 percent); the latter is generally provided through the Red Cross. An 

estimated 12 percent of SFAs reported preparing food for CACFP, which provides meals and 

snacks to children and elderly adults. Eleven percent of SFAs that use their facilities for other 

reimbursable meals reported they supported other schools or school systems programs, and only 3 

percent provided reimbursable meals for the Elderly Nutrition Program. Finally, 4 percent of 

respondents wrote in the Afterschool Snack Program as a specific additional program for which they 

provided reimbursable meals. The use of school food service facilities for preparing reimbursable 

meals served for other programs varied with SFA size, which is not surprising as it is likely that the 

availability of these programs in the schools is driven by SFA size. Similarly, the use of food service 

facilities to prepare foods for other programs that served reimbursable meals varied by the poverty 

level of the SFAs; those with high poverty levels reported higher use of facilities for almost all of 

these programs than those with low poverty levels. 
63

Table IV-2.3. Among SFAs that Allow Food Service Facilities to be Used for more than SBP 

and NSLP, the Percentage of SFAs Using those Facilities for Other Reimbursable 

Meals by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs using facilities for: Total SFAs

CACFP SFSP

Elderly 

nutrition 

program

Head 

Start

Other

school or 

school 

systems

Disaster 

feeding

Afterschool 

snack

Weighted 

n

Unweighted 

n

All SFAs 12.1% 38.9% 2.5% 28.1% 11.4% 19.4% 4.2% 5,691 6511

SFA size2

Small (1-999) 8.8 22.2 4.8 16.0 6.5 10.5 2.6 2,100 92

Medium (1,000-4,999) 10.6 39.9 0.5 33.9 10.0 22.1 4.0 2,505 251

Large (5,000-24,999) 20.2 67.1 3.0 35.6 23.2 27.6 7.6 918 209

Very large (25,000+) 32.6 78.5 1.9 53.2 29.3 46.1 9.7 168 99

Urbanicity3

City 28.3 60.1 1.4 34.9 31.1 18.0 5.7 598 139

Suburban 11.9 32.8 1.0 22.6 12.6 17.3 4.5 1,273 186

Town 10.9 49.6 0.0 29.6 14.1 29.6 5.4 1,239 129

Rural 9.1 31.9 4.7 28.5 5.0 15.9 3.2 2,582 197

Poverty level4

Low (0-29% F/RP) 3.4 9.2 1.6 17.0 9.7 18.5 1.1 1,459 168

Medium (30%-59% F/RP) 11.8 42.7 2.3 35.0 11.1 17.2 5.2 2,571 290

High (60% or more F/RP) 20.3 59.1 3.7 27.3 13.5 23.8 5.4 1,662 193

Type of kitchen5

Onsite kitchen only 8.4 30.8 2.6 22.3 3.5 19.2 3.9 2,987 278

Offsite kitchen only 12.7 50.1 1.6 34.8 14.0 15.9 6.7 980 95

Combination or other 18.7 46.0 2.9 34.7 23.9 22.0 3.5 1,702 275

1

n equals the 651 SFAs that allow their food service facilities to be used for other programs.

2

 Percentage of SFAs using their food service facilities for all types of other reimbursable meals with the exception of afterschool snack differed 

significantly by SFA size at the .05 level. 

3

 Percentage of SFAs using their food service facilities for CACFP, SFSP, other school or school systems, and disaster feeding differed significantly 

by urbanicity at the .05 level. 

4

 Percentage of SFAs using their food service facilities for CACFP, SFSP, Head Start, and afterschool snack differed significantly by poverty level 

at the .05 level. 

5

 Percentage of SFAs using their food service facilities for CACFP, SFSP, Head Start, and other school or school systems differed significantly by 

type of kitchen at the .05 level. 

Data Source: SFA Director Survey 2011, questions 4.20 and 4.21.

As seen in Table IV-2.4, school food service facilities were also used to prepare foods for a 

range of nonreimbursable purposes, with many SFAs using these facilities to support more than one 

activity. The most common nonreimbursable uses of school food service facilities were school staff 

meals (76 percent), catering (64 percent), and athletic events (63 percent). More than one-third of these 

SFAs (36 percent) reported using food service facilities for PTA events. Eleven percent of these SFAs 

used food service facilities for daycare. In general, a higher percentage of large and very large SFAs than 

small or medium SFAs used the food service facility to prepare meals for PTA meetings, daycare, and 

catering. In some cases, the facility is the site for many other events, including fundraisers, community 

activities and events, banquets and dinners, meetings, outside organizations renting, before- and 

afterschool programs, and summer activities. Of those citing other events, the following were reported: 

fundraisers (27 percent, not shown), community activities and events (23 percent, not shown), banquets 

and dinners (18 percent, not shown), meetings (8 percent, not shown), outside organizations renting (7 

percent, not shown), before- and afterschool programs (5 percent, not shown), summer activities (3 

percent, not shown), and other (8 percent, not shown). 
64

Table IV-2.4. Among SFAs that Allow Food Service Facilities to be Used for More Than SBP and 

NSLP, the Percentage of SFAs Using those Facilities for Nonreimbursable Purposes 

by SFA Characteristics, SY 2011-12 

SFA characteristics

Percentage of SFAs using facilities for: Total SFAs

Athletic 

events

PTA 

meetings

School 

staff meals Daycare Catering Other

Weighted

n

Unweighted

n

All SFAs 63.4% 35.8% 76.2% 11.3% 64.1% 20.0% 5,654 6471

SFA size2

Small (1-999) 56.0 23.2 71.7 6.4 34.7 31.3 2,078 91

Medium (1,000-4,999) 71.8 38.3 80.6 10.5 78.1 14.3 2,497 250

Large (5,000-24,999) 59.6 53.3 74.1 21.4 87.6 10.8 911 207

Very large (25,000+) 51.2 59.9 78.0 27.6 92.4 16.1 168 99

Urbanicity3

City 41.6 37.2 56.6 14.3 69.7 15.2 594 138

Suburban 59.1 38.6 77.8 14.8 88.9 21.0 1,270 185

Town 64.4 36.7 83.0 14.3 71.6 19.2 1,239 129

Rural 70.1 33.7 76.6 7.3 46.8 21.1 2,551 195

Poverty level4

Low (0-29% F/RP) 59.4 42.9 83.0 10.4 79.7 19.7 1,425 165

Medium (30%-59% F/RP) 68.4 32.0 78.6 11.4 63.9 20.4 2,571 290

High (60% or more F/RP) 59.0 35.5 66.6 11.8 51.1 19.8 1,659 192

Type of kitchen5

Onsite kitchen only 71.6 35.3 81.1 8.7 63.6 18.3 2,961 276

Offsite kitchen only 54.9 31.5 66.7 14.8 53.7 24.5 976 94

Combination or other 54.0 39.5 72.7 13.9 70.6 20.8 1,694 274

1

n is less than 651 SFAs that allow their food service facilities to be used for other programs due to item non-response. 

2

 Percentage of SFAs using their food service facilities for all types of other nonreimbursable purposes with the exception of school staff meals 

differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs using their food service facilities for athletic events, school staff meals, and catering differed significantly by urbanicity at the 

.05 level. 

4

 Percentage of SFAs using their food service facilities for school staff meals and catering differed significantly by poverty level at the .05 level. 

5

 Percentage of SFAs using their food service facilities for athletic events and school staff meals differed significantly by type of kitchen at the .05 

level. 

Data Source: SFA Director Survey 2011, questions 4.20 and 4.22. 

Types of Meal Service Systems 

Schools use different types of meal service systems when providing meals to students, with 

many including a blend of self-service and operator service. Figure IV-2.1 shows that many SFAs 

used more than one approach to serving meals, but the most common type of meal service system 

used by SFAs during SY 2011-12 was the traditional cafeteria line (94 percent), where students line 

up to be served their food by cafeteria staff. Most meals served in the SBP and the NSLP are 

prepared and served to students as they pass through a cafeteria line. 
65

Figure IV-2.1. Percentage of SFAs Using Different Types of Meal Service Systems, SY 2011-12

n is less than 1,401 due to item non-response. Responses based on a weighted n = 14,656, unweighted n = 1,399. 

Data Source: SFA Director Survey 2011, question 4.1. 

Figure IV-2.1 also shows the types and frequency of other meal service arrangements: 

 Food courts (34 percent)—Students select food from various specialty stations, such as 

a grill bar, salad bar, or pizza bar.24

 Window service (29 percent)—Students walk up to a window to obtain food from a 

limited menu, which often includes prepackaged food. 

 Speed lines (29 percent)—Multiple points of service are offered to allow students to 

receive faster service. Timeliness of service is more important when students have 

limited time to buy and eat their lunch. Some speed lines incorporate cashless/prepay 

lines or require students to use a PIN. 

 Packaged reimbursable meals at a pick-up and go setting (21 percent)—This service 

includes prepackaged food such as sandwiches or fruit. 

 Marché concepts (13 percent)—This approach is based on European open-air 

marketplaces where the emphasis is on visual display and fresh foods prepared to order 

in full view of customers at a variety of themed stations. 

 

24 http://www.fns.usda.gov/tn/Resources/equip02.pdf 

94.3

33.6

29.3

29.2

20.5

13.4

9.6

2.1

1.6

0 20 40 60 80 100

Traditional cafeteria line

Food court concepts where students select 

from various specialty stations

Window service where students can walk-up 

and obtain food from a limited menu

Speed lines where multiple points of service 

are offered

Packaged, reimbursable meals at a pick-up 

and go setting

Emphasis on visual display (Marché concepts)

Kiosks that offer food for faster service at 

small, free-standing carts

Food boutiques and convenience stores

Other

Percentage of SFAs
66

 Kiosks (10 percent)—For faster service, food is offered at small, freestanding carts. 

Kiosks or carts with specialty foods give cafeterias the look and feel of a food court in 

shopping malls. 

 Food boutiques (2 percent)—These boutiques resemble retail activity areas where 

specialized foods and meal components are served. 

Policies and Practices Regarding Location and Timing of School Meals 

 Food service operations are affected by policies and practices that do not fall under the 

control of food service staff. Typically the school principal, under the guidance of district policies, 

determines allowable locations for students to eat, when meals will be served, how much time 

students will have to eat their meals, and the timing of recess. District policies also govern whether 

students are permitted to leave the school property during meals. 

Eating Locations 

 Where students may eat their meals varies across SFAs. Table IV-2.5 shows that although 

SFAs reported more than one eating location across the schools they served, not surprisingly the 

cafeteria was the most common setting for breakfast (88 percent) and lunch (96 percent). Almost 

one-third of SFAs (29 percent) allowed students to eat breakfast in classrooms; 17 percent of SFAs 

reported that students were permitted to eat breakfast at outside tables; and 3 percent of SFAs had 

students eating breakfast in other locations, such as gymnasiums and hallways. A similar pattern was 

observed for lunch, but with a higher percentage of SFAs reporting that students ate lunch at 

outside tables (35 percent). Classrooms were used by fewer SFAs during lunch (19 percent). 

 There are some notable differences in the locations where students eat based on the size, 

urbanicity, and poverty level of the SFA. For lunch and breakfast, the larger the SFA size, the more 

likely that students eat at outside tables or in classrooms. In addition, SFAs in rural areas or towns 

were less likely to have breakfast or lunch at outside tables, and SFAs in rural areas were less likely to 

allow breakfast in classrooms. SFAs in rural and suburban areas were less likely to allow the use of 

classrooms for lunch. SFAs with medium and high poverty levels were less likely than those with 

low poverty levels to allow lunch at outside tables. 
67

Table IV-2.5. Percentage of SFAs with Schools Using Various Types of Eating Locations by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with schools using: Total SFAs

Cafeterias Outside Classrooms Other Weighted n Unweighted n

Breakfast

All SFAs 87.9% 17.3% 28.6% 3.4% 14,666 1,4001

SFA size2

Small (1-999) 81.9 11.0 21.1 4.5 7,374 332

Medium (1,000-4,999) 92.9 20.0 32.5 2.3 5,378 535

Large (5,000-24,999) 97.2 30.7 43.1 1.8 1,629 364

Very large (25,000+) 94.8 54.0 67.8 4.0 284 169

Urbanicity3

City 80.3 28.5 44.0 5.6 1,630 256

Suburban 84.8 24.7 30.9 3.7 2,885 380

Town 90.9 18.0 31.8 3.6 2,782 265

Rural 89.7 11.7 23.1 2.6 7,369 499

Poverty level4

Low (0-29% F/RP) 77.5 17.1 24.3 3.3 3,407 348

Medium (30%-59% F/RP) 92.6 15.9 28.2 2.8 6,816 649

High (60% or more F/RP) 88.7 19.7 32.6 4.3 4,443 403

Lunch

All SFAs 96.2% 34.6% 19.2% 3.5% 14,666 1,4001

SFA size5

Small (1-999) 94.0 23.4 18.4 4.3 7,374 332

Medium (1,000-4,999) 98.5 41.9 19.1 2.7 5,378 535

Large (5,000-24,999) 98.7 53.8 20.4 2.3 1,629 364

Very large (25,000+) 95.5 76.3 35.7 4.6 284 169

Urbanicity3

City 89.3 39.0 31.7 6.4 1,630 256

Suburban 97.9 43.1 16.3 3.1 2,885 380

Town 96.0 35.6 22.0 3.8 2,782 265

Rural 97.2 30.0 16.6 2.9 7,369 499

Poverty level6

Low (0-29% F/RP) 98.1 43.5 16.0 3.9 3,407 348

Medium (30%-59% F/RP) 97.0 32.8 20.5 3.2 6,816 649

High (60% or more F/RP) 93.5 30.5 19.7 3.6 4,443 403

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs using all types of eating locations for breakfast differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs using all types of eating locations with the exception of other for breakfast and lunch differed significantly by urbanicity at 

the .05 level. 

4

 Percentage of SFAs using all types of eating locations for breakfast differed significantly by poverty level at the .05 level. 

5

 Percentage of SFAs using all types of eating locations with the exception of classrooms for lunch differed significantly by SFA size at the .05 

level. 

6

 Percentage of SFAs using all types of eating locations with the exception of classrooms for lunch differed significantly by poverty level at the 

.05 level. 

Data Source: SFA Director Survey 2011, question 4.4. 
68

Time Allotted for Meals 

 The scheduling of school meals has a major influence on food service operations, and how 

quickly students can be served is affected by the type of meal service system used. How much time 

students have to eat their meal is a concern particularly with the changes in the new meal patterns, as 

certain foods such as fresh fruit may take longer for students to eat, especially if it needs to be 

peeled (e.g., an orange). As shown in Figure IV-2.2, the most commonly reported amount of time 

allotted for breakfast was 20 minutes (about 40 percent of SFAs). This varied little across type of 

school (elementary, middle, high, or other). However, high schools were less likely to have less than 

20 minutes for breakfast than the other types of schools and more likely to have 30 minutes or more 

for breakfast. 

Figure IV-2.2. Percentage of SFAs with Various Average Times Allotted for Breakfast by Type 

of School, SY 2011-12

For elementary schools, n is less than the 1,292 SFAs that reported having elementary schools due to item non-response, and weighted n = 

11,836 and unweighted n = 1,239. 

For middle schools, n is less than the 1,106 SFAs that reported having middle schools due to item non-response, and weighted n = 8,806 and 

unweighted n = 1,055. 

For high schools, n is less than the 1,188 SFAs that reported having high schools due to item non-response, and weighted n = 10,264 and 

unweighted n = 1,148. 

For other school types, n is less than the 551 SFAs that reported having other schools due to item non-response, and weighted n = 3,774 and 

unweighted n = 464. 

Data Source: SFA Director Survey 2011, question 4.6. 

25.9

43.5

29.2

1.5

26.4

41.4

30.4

1.8

22.1

40.0

33.5

4.5

27.4

42.9

27.2

2.6

0

5

10

15

20

25

30

35

40

45

50

Less than 20 minutes 20 minutes 30 minutes 45 minutes or more

Percentage of SFAs

Elementary Middle High Other
69

 Figure IV-2.3 shows that 30 minutes was the most frequently reported amount of time 

allotted for lunch for all types of schools (at least 50 percent). Elementary schools were most likely 

to have less than 30 minutes for lunch and high schools the least likely. High schools were most 

likely to allow at least 45 minutes for lunch (9 percent). 

Figure IV-2.3. Percentage of SFAs with Various Average Times Allotted for Lunch by Type of 

School, SY 2011-12

For elementary schools, n is less than the 1,292 SFAs that reported having elementary schools due to item non-response, and weighted n = 

12,499 and unweighted n = 1,284. 

For middle schools, n is less than the 1,106 SFAs that reported having middle schools due to item non-response, and weighted n = 9,347 and 

unweighted n = 1,097. 

For high schools, n is less than the 1,188 SFAs that reported having high schools due to item non-response, and weighted n = 10,741 and 

unweighted n = 1,181. 

For other school types, n is less than the 551 SFAs that reported having other schools due to item non-response, and weighted n = 4,342 and 

unweighted n = 529. 

Data Source: SFA Director Survey 2011, question 4.7. 

 Policies governing whether students can leave the school campus during the meal service 

vary by school district and school and are determined by the school district superintendent and the 

local board of education or the school principal. Reasons for allowing an off-campus policy may 

include lack of food service/cafeteria space and meal preparation and serving capabilities and 

providing more flexibility and responsibility to high school students. In geographic areas where local 

food outlets are available near school, off-campus lunch options are considered important revenue 

streams for local businesses. Although the primary driver for open-campus policies tends to be 

space and time constraints, such policies are thought to increase truancy, pose safety risks for 

students who travel off campus, and stigmatize students who eat at school (Miura, 2009). 

46.4

50.2

3.4

0.0

40.9

53.4

5.7

0.0

36.1

54.1

9.1

0.7

39.5

55.6

4.7

0.2

0

10

20

30

40

50

60

70

Less than 30 minutes 30 minutes 45 minutes 60 minutes

Percentage of SFAs

Elementary Middle High Other
70

 Analysis of the 2006 School Health Policies and Programs Study data indicated that 71 

percent of the high school districts and 73 percent of high schools had a closed-campus policy 

(O’Toole, Anderson, Miller, and Guthrie, 2007). In SY 2009-10, about 81 percent of high schools 

had a closed-campus policy; of the 19 percent that had an off-campus policy, the schools were 

located in proximity to supermarkets, convenience stores, or other stores and fast food restaurants 

(SNDA-IV Vol. 1). The school food service characteristics section of the SFA Director Survey 

asked whether any of their high schools allowed students to go off-campus during lunch. SFAs that 

did not have a high school were excluded from this analysis. As seen in Table IV-2.6, in SY 2011-12, 

about two-thirds (68 percent) of responding SFAs had a closed-campus policy during lunch, but 25 

percent of the SFAs allowed all high school students to go off campus for lunch. SFAs that allowed 

all high school students to go off campus for lunch tended to be small or medium in size (versus 

large or very large in size), in suburban areas or towns (versus in rural or city), and allotted 45 

minutes or more for lunch (versus allotting 30 minutes or less). 

Table IV-2.6. Among SFAs that have High Schools, the Percentage of SFAs with High Schools 

that Allow Students to Eat Off Campus by SFA Characteristics, SY 2011-12

SFA characteristics

Percent of SFAs with high schools allowing students 

to go off campus for lunch for: Total SFAs

All schools Some schools No schools Weighted n Unweighted n

All SFAs 25.0% 7.4% 67.7% 10,592 1,1651

SFA size2

Small (1-999) 27.4 8.0 64.7 4,106 191

Medium (1,000-4,999) 24.6 4.7 70.7 4,679 467

Large (5,000-24,999) 20.0 11.4 68.6 1,526 340

Very large (25,000+) 21.8 21.2 57.0 281 167

Urbanicity2

City 21.3 17.9 60.7 889 211

Suburban 25.1 4.4 70.5 2,149 324

Town 30.0 7.9 62.1 2,294 237

Rural 23.3 6.6 70.1 5,260 393

Poverty level

Low (0-29% F/RP) 25.6 6.8 67.7 2,505 297

Medium (30%-59% F/RP) 26.6 8.0 65.4 5,339 560

High (60% or more F/RP) 21.1 6.8 72.1 2,748 308

Time allotted for lunch in high 

school2

Less than 30 minutes 19.6 8.2 72.2 6,174 720

30 minutes 31.9 5.6 62.5 3,383 352

45 minutes or more 45.6 12.1 42.3 448 54

Number of schools recognized as 

HealthierUS Schools2

None 24.5 7.2 68.3 9,908 1,061

1-5 36.5 10.0 53.5 554 70

6 or more 7.4 8.9 83.8 130 34

1

n is less than the 1,188 SFAs that reported having high schools due to item non-response. 

2 Percentage of SFAs that allow students to eat off campus differed significantly by SFA size, urbanicity, time allotted for lunch, and the number 

of schools recognized as HealthierUS schools at the .05 level. 

Data Source: SFA Director Survey 2011, questions 4.5, 4.7, 11.7, and 14.7.
71

Student Mobility 

 Some schools allow students to leave the cafeteria (or location where they are eating) before 

the lunch period is over, provided they have finished eating. It is up to the school principal and 

district policy, rather than the food service staff, to decide whether students can move around. 

High school students are more likely than elementary or middle school students to be 

allowed to leave the cafeteria before the end of the lunch period. About 58 percent of SFAs 

reported that high school students could leave, but only 25 percent of SFAs reported that 

elementary school students were allowed to leave; 39 percent reported that middle school students 

could leave before the end of the lunch period as shown in Table IV-2.7. A small percentage of SFA 

directors were unsure of the school policies or practices in this regard. 

Table IV-2.7. Among SFAs that Have Elementary, Middle, High, or Other Schools, the 

Percentage of SFAs with Different After Lunch Student Mobility Policies by 

School Type, SY 2011-12

School type

Percentage of SFAs reporting that once students have finished eating: Total SFAs

Students are allowed to 

leave the cafeteria

Students must 

remain in the 

cafeteria

Policy or practice is 

unknown to 

director

Weighted 

n

Unweighted 

n

Elementary 25.3% 72.4% 2.4% 12,555 1,2861

Middle 39.1 57.2 3.7 9,404 1,0982

High 57.7 38.1 4.2 10,766 1,1813

Other 29.0 60.2 10.9 3,619 4274

1

n is less than the 1,292 SFAs that reported having elementary schools due to item non-response. 

2

n is less than the 1,106 SFAs that reported having middle schools due to item non-response. 

3

n is less than the 1,188 SFAs that reported having high schools due to item non-response. 

4

n is less than the 551 SFAs that reported having other schools due to item non-response. 

Data Source: SFA Director Survey 2011, question 4.9. 

Recess 

 Engaging in physical activity at any time of day is important to the health and well-being of 

students, but research has shown that there may be added benefits to students if they have recess 

before lunch as opposed to after lunch. Several studies found that students ate more food and 

nutrients and wasted less food when recess occurred before lunch (Bergman, Buergel, England, and 

Femrile, 2004; Getlinger et al., 1996; Read and Moosburner, 1985; Ruppenthal and Hogue, 1977). 

The Montana Team Nutrition Program found that the average amount of food and beverage waste 

decreased after working with four schools to implement recess before lunch (Rainville et al., 2006). 

Some other benefits noted in the study were: 

 Quieter and more relaxed atmosphere in the cafeteria during lunch that was more 

conducive to eating; 

 A dramatic decrease in discipline problems on the playground, in the lunchroom, and in 

the classroom; and 

 Students returning to their classroom more settled, calmer, and ready to learn. 
72

 As shown in Table IV-2.8, elementary schools provide lunch before recess in 45 percent of 

SFAs and provide lunch after recess in only 12 percent of SFA. The remaining 43 percent of SFAs 

indicated that the timing of lunch and recess varied, with some elementary schools having recess 

before lunch and some after lunch. The smaller the SFA size, the more likely that lunch was 

provided before recess. Conversely, the larger the SFA size, the more likely that lunch was provided 

in some schools before recess and in other schools after recess. 

Table IV-2.8. Among SFAs that Have Elementary Schools, the Percentage of SFAs with 

Elementary Schools Following Various Lunch and Recess Schedules by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with most of their elementary 

schools providing lunch: Total SFAs

Before recess After recess

Before recess in 

some schools and 

after recess in 

other schools

Weighted

n

Unweighted

n

All SFAs 44.5% 12.2% 43.3% 11,777 1,1871

SFA size2

Small (1-999) 52.4 12.1 35.5 5,283 244

Medium (1,000-4,999) 41.2 12.0 46.8 4,808 480

Large (5,000-24,999) 29.4 13.5 57.1 1,451 325

Very large (25,000+) 28.2 12.0 59.7 235 138

Urbanicity2

City 39.4 9.4 51.3 1,164 209

Suburban 35.3 17.2 47.5 2,303 323

Town 45.2 9.2 45.6 2,248 232

Rural 48.7 12.0 39.3 6,062 423

Poverty level2

Low (0-29% F/RP) 34.1 16.5 49.5 2,745 296

Medium (30%-59% F/RP) 45.8 8.7 45.5 5,651 555

High (60% or more F/RP) 50.8 14.7 34.5 3,381 336

Once elementary school students 

finish eating they2

Are allowed to leave the 

cafeteria

61.4 7.8 27.6 3,182 325

Must remain in the cafeteria 35.5 12.4 45.5 9,157 932

1

n is less than 1,292 SFAs that reported having elementary schools due to item non-response. 

2 Percentage of SFAs following various lunch and recess schedules differed significantly by SFA size, urbanicity, poverty level and after lunch 

student mobility policy at the .05 level. 

Data Source: SFA Director Survey 2011, question 4.8. 
73

IV-3. Food Safety and Training 

Background 

 Food safety is a critical aspect of daily life in the home and in public venues. In 2000, the 

Centers for Disease Control and Prevention (CDC) reported that foodborne disease caused 

approximately 76 million illnesses, 325,000 hospitalizations and 5,000 deaths nationally. At that time, 

there was concern that throughout the food industry the most basic food safety precautions, such as 

washing hands, storing leftovers properly, and cooking food to required temperatures, were not 

being taken when cooking, preparing, and consuming food products. 

 Although NSLP and SBP are permanently authorized, Congress reviews the child nutrition 

programs every 5 years through the reauthorization process. When Congress passed the Child 

Nutrition and WIC Reauthorization Act (PL 108-265) in 2004, it required all SFAs to implement a 

food safety program by the beginning of SY 2005-06 to ensure the meals served in schools were 

safe. The law stipulated that the food safety program must be based on hazard analysis and critical 

control point (HACCP) principles and conform to all guidance issued by USDA. Additionally, the 

HHFKA reinforces the focus on food safety by requiring that schools continue to receive two food 

safety inspections a year and that the food safety program applies to the entire school campus. 

Research Questions 

 This section presents data on a variety of issues related to food safety in SFAs, including the 

availability of a written food safety plan and food safety training, types of food safety program 

components implemented in the schools, use of food defense practices, policies and procedures in 

place to accommodate students with special diets, safety inspections and violations, and hold or 

recall procedures for the USDA Foods program. Specifically, this section addresses the following 

research questions.

 What percent of SFAs have written food safety plans? 

 What food safety program components have been implemented? 

 What percent of schools have a food service supervisor or manager with a food safety certification? 

 What topics did food service employees receive training on during the prior year? What USDA 

materials were used? 

 How many students with non-allergy special diets are served in your district? 

 What food defense practices are being done in states and school districts? 

 What percent of SFAs had two or more safety inspections for all schools? Who conducted these 

inspections? If some schools did not have at least two inspections, what were the reasons? 

 What types of violations were schools cited? 

 How are SFAs alerted about food recalls? How do SFAs alert schools about food recalls? 
74

 What procedures do states and school districts use to ensure traceability of USDA Foods in the event of 

a hold or recall? 

Results 

Food Safety Plans and Staff Certifications 

 Following enactment of PL 108-265, the USDA provided guidance to SFAs on preparing 

written food safety plans.25 By SY 2011-12 nearly all SFAs (96 percent) reported that all schools in 

their district had a written food safety plan based on HACCP principles. This represents a 

substantial increase over the percentage of SFAs reported before the enactment of the legislation 

when only 35 percent reported having formal HACCP plans in place (SNDA-III, 2007). Table IV3.1 shows the percentage of SFAs with schools that have written food safety plans by SFA 

characteristics. In SY 2011-12, about 4 percent of small SFAs reported that none of their schools 

had written plans, while less than 1 percent of the very large SFAs fell into this category. Overall, 3 

percent of the all SFAs reported this situation. A review of open-ended responses provided by SFA 

directors suggests that some of the reasons for not having a written plan included the plan is in 

process, no time to develop a plan, no “working kitchen,” or meal preparation is a satellite 

operation. 

Table IV-3.1. Percentage of SFAs with Written Food Safety Plan Based on HACCP Principles in 

Schools by SFA Characteristics, Food Safety Program Components, and SFA 

Director Certification, SY 2011-12

SFA characteristics

Percentage of SFAs with written food safety 

plan based on HACCP at: Total SFAs

All 

schools

Most 

schools

Some 

schools

No 

schools

Weighted 

n

Unweighted

n

All SFAs 95.6% 1.0% 0.8% 2.6% 14,439 1,3871

SFA size

Small (1-999) 93.8 1.0 0.7 4.4 7,207 325

Medium (1,000-4,999) 97.1 1.4 0.9 0.6 5,331 531

Large (5,000-24,999) 97.5 0.0 1.2 1.3 1,616 362

Very large (25,000+) 99.6 0.0 0.0 0.4 284 169

Urbanicity

City 94.5 1.7 0.6 3.1 1,581 254

Suburban 95.2 0.3 2.1 2.4 2,809 376

Town 97.3 1.4 0.9 0.4 2,763 263

Rural 95.3 1.0 0.3 3.4 7,286 494

Poverty level

Low (0-29% F/RP) 96.0 1.2 0.4 2.3 3,339 343

Medium (30-59% F/RP) 96.1 1.1 0.6 2.3 6,743 645

High (60% or more F/RP) 94.5 0.8 1.4 3.3 4,357 399

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 12.1. 

 

25 http://www.fns.usda.gov/fns/safety/pdf/HACCPGuidance.pdf
75

 As Table IV-3.2 shows, most SFA directors reported the following three primary 

components to food safety were implemented in the schools: 

 Written standard operating procedures for food safety (93 percent), 

 Annual review and updating of food safety plans (88 percent), and 

 Menu items grouped by processes (79 percent) such as same day service or complex or 

no cooking involved. 

 Another aspect to food safety is taking and recording temperatures of the food at set points 

starting when the SFA receives the raw products through serving the meal to students. As shown in 

Table IV-3.2, most SFAs took temperatures and recorded them when receiving the food (84 

percent). Ninety to 96 percent of SFAs recorded temperatures at the other stages of food 

production and service. 

Table IV-3.2. Percentage of SFAs that Followed Various Food Safety Practices, SY 2011-12

Food safety practice Percentage of SFAs

Components of food safety program

Written standard operating procedures 92.5%

Annual review and updating of food safety plan 88.4

Menu items groups by process 78.8

Temperatures taken and recorded for:

Foods at receiving 84.1

Foods in storage 90.3

End-point cooking temperatures 95.3

Holding temperatures 95.2

Serving temperatures 96.0

Cooling temperatures 90.6

Total SFAs: Weighted n

Total SFAs: Unweighted n

14,422

1,3841

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 12.1 and 12.3. 

Food Safety Certification 

 A key aspect of understanding the elements of food safety is having staff trained and 

certified to carry out the written plans for handling food for the school-meal programs. Figure IV3.1 shows the percentage of SFAs with varying proportions of schools having at least one food 

safety supervisor or manager with a food safety certification. Seventy-four percent of SFAs reported 

that all of their schools had at least one food service supervisor or manager with a food safety 

certification. About 12 percent of SFAs said that none of their schools had supervisors or managers 

who hold a food safety certification. However, further analysis of the characteristics of these 111 

SFAs reporting that none of their schools have supervisors or managers holding a food safety 

certification reveals that this group of SFAs mostly includes small SFAs (75 percent, not shown) 

located in rural areas (65 percent, not shown). Furthermore, almost 95 percent (not shown) of these 

SFAs reported having fewer than 10 schools in their districts. 
76

Figure IV-3.1. Percentage of SFAs with Differing Proportion of Schools that Have at least One 

Food Service Supervisor or Manager with Food Safety Certification, FY 2011-12

n is less than 1,401 due to item non-response. Percentages based on a weighted response of 14,346 (unweighted 1,376). 

Data Source: SFA Director Survey 2011, question 12.15. 

Safety Topics Covered in Trainings 

 Because of the importance of preventing foodborne illness, all food service employees are 

expected to follow guidelines to maintain a safe food service environment in schools. When asked 

about food safety training topics during the school year (SY 2010-11), the vast majority of SFAs 

reported that food service employees were trained on all the major food safety topics. Furthermore, 

Appendix E, Figure E-1 shows that the percentage of SFAs ranged from 88 percent of SFAs 

training staff on proper equipment use and maintenance to 98 percent of SFAs reporting that they 

trained employees on personal hygiene and proper hand washing techniques. Safe food handing at 

different points in the food preparation process was reported by 94 to 96 percent of SFAs. 

USDA Materials 

 As part of its assistance to SFAs, the USDA develops and makes available materials on a 

variety of topics. SFA directors were asked about their use of these materials. Almost three-fourths 

(not shown) of SFAs reported using some of the USDA materials to assist in food safety. The most 

frequently cited material was the “Fresh Fruit and Vegetable Program Handbook,” where 48 percent 

of SFAs reported using it to assist them in food safety, as shown in Figure IV-3.2.26 Although the 

majority of the handbook focuses on the operations of the program and which schools are eligible 

to participate, it does contain a section on food safety within the USDA FFVP program. 

 

26 http://www.fns.usda.gov/cnd/ffvp/handbook.pdf.

12.1

5.2

8.5

74.2

None

Less than 25 percent

25 to 99 percent

100 percent
77

Figure IV-3.2. Percentage of SFAs Using USDA Materials to Assist in Food Safety, FY 2011-12

n is less than 1,401 due to item non-response. Percentages based on a weighted response of 14,225 (unweighted 1,372). 

Data Source: SFA Director Survey 2011, question 12.17. 

Food Defense Plan or Practices 

 Another element in food safety is the food defense plan—a written plan that describes steps 

that school cafeterias can make to minimize the risk of food product contamination and ensure safe 

working environments for staff.27 The measures are periodically assessed to see if adjustments to the 

plan are needed. Although the plan should be in place at all times, it is particularly helpful during 

emergencies. During a crisis, when stress is high and response time is at a premium, a documented 

set of procedures improves a school’s ability to respond quickly. A food defense plan also helps 

maintain a safe working environment for staff, provide a quality product to students, and protect the 

SFA’s bottom line. A functional food defense plan must be:

 In writing, 

 Put into place and used as intended, 

 Tested or drilled periodically to see if it is being followed and the measures work, 

 Assessed periodically to see if production procedures have changed or new equipment 

has been put into place that may require adjustment to the plan, and 

 Maintained by training new employees and ensuring provisions required by the plan are 

available. 

 Table IV-3.3 shows that less than half (44 percent) of all SFAs reported they used either a 

food defense plan or food defense practices; so 56 percent of SFAs do not use them. A higher 

percentage of the very large SFAs reported having food defense plans or practices in place 

compared to other SFAs. Sixty percent of very large SFAs reported having a plan or practice, while 

 

27 http://www.fsis.usda.gov/pdf/guidance_document_warehouses.pdf.

47.8

45.3

43.5

30.9

24.5

0 20 40 60 80 100

Fresh Fruit and Vegetable 

Program Handbook

Fruits and Vegetables Galore: 

Helping Kids Eat More

Best Practices: 

Handling Fresh Produce in Schools

Produce/Salad Area: 

Produce/Salad Area – Educational Poster

Choice Plus: Food Safety Supplement

Percentage of SFAs
78

39 percent of the small SFAs indicated they had a plan or practice. Compliance with having a plan 

did not differ significantly by SFA urbanicity or poverty level. 

Table IV-3.3. Percentage of SFAs Using a Food Defense Plan or Food Defense Practice 

by SFA Characteristics, SY 2011-12

1 

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs using a food defense plan or food defense practices differed significantly by SFA size at the .05 level. 

Data Source: SFA Director Survey 2011, question 12.18a. 

 Table IV-3.4 shows that during SY 2011-12, 89 percent of SFAs that used defense plans or 

practices reported their food service operations included a plan to prevent the intentional 

contamination of food, and 84 percent reported that school food service operators are involved in 

the school district emergency plan. Almost one-third of these SFAs (31 percent) used a biosecurity 

checklist. 

Special Diets 

 Some students require a special diet. These students include those with food allergies as well 

as those with non-allergy-related special diets, such as students with certain disabilities. While most 

people are aware of safety concerns surrounding students with food allergies, fewer may understand 

the extent of providing meals to students with non-allergy-related special diets. Table IV-3.5 shows 

that the vast majority of SFAs (91 percent) stated that they have policies and procedures to 

accommodate students with special diets. However, when asked about the number of students 

having non-allergy-related special diets, 43 percent (not shown) of SFAs stated they did not know 

the number of students with non-allergy-related special diets. The remaining 57 percent (not shown) 

reported serving over 100,000 students (weighted) with non-allergy-related special diets. 

SFA characteristics Percentage of SFAs

Total SFAs

Weighted n Unweighted n

All SFAs 43.5% 14,206 1,3681

SFA size2

Small (1-999) 38.5 7,080 320

Medium (1,000-4,999) 48.4 5,250 523

Large (5,000-24,999) 46.6 1,596 358

Very large (25,000+) 59.7 280 167

Urbanicity

City 38.4 1,531 249

Suburban 46.9 2,747 370

Town 42.6 2,733 260

Rural 43.6 7,196 489

Poverty level

Low (0-29% F/RP) 40.9 3,262 337

Medium (30%-59% F/RP) 43.6 6,677 639

High (60% or more F/RP) 45.3 4,267 392
79

Table IV-3.4. Among SFAs that Used a Food Defense Plan or Practices, the Percentage of 

SFAs Using Various Food Defense Practices by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that reported having: Total SFAs

Plan to 

prevent food 

contamination

School district 

emergency 

plan

Biosecurity 

checklist

Other 

practices

Weighted 

n

Unweighted 

n

All SFAs 88.9% 83.8% 30.7% 3.2% 6,155 6511

SFA size2

Small (1-999) 92.4 79.8 31.5 3.1 2,726 125

Medium (1,000-4,999) 86.9 84.6 28.2 2.7 2,525 257

Large (5000-24,999) 83.6 93.6 35.9 3.9 738 169

Very Large (25,000+) 85.6 93.8 34.8 11.4 166 100

Urbanicity

City 87.8 83.1 29.3 6.7 586 127

Suburban 83.9 91.1 30.0 3.4 1,268 181

Town 91.4 79.8 36.5 3.6 1,165 120

Rural 90.3 82.5 29.2 2.4 3,135 223

Poverty level3

Low (0-29% F/RP) 89.0 84.4 20.8 5.3 1,329 146

Medium (30-59% F/RP) 87.9 82.9 30.0 2.5 2,896 303

High (60% or more F/RP) 90.3 84.8 38.7 2.8 1,930 202

1

n is less than the 654 SFAs that used food defense plan or practices due to item non-response. 

2

 Percentage of SFAs having a school district emergency plan differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs having a biosecurity checklist differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, question 12.18b. 

Table IV-3.5. Percentage of SFAs with Policies and Procedures to Accommodate Students 

with Special Diets by SFA Characteristics, SY 2011-12

SFA characteristics Percentage of SFAs

Total SFAs

Weighted n Unweighted n

All SFAs 91.4% 13,762 1,3461

SFA size2

Small (1-999) 89.9 6,713 304

Medium (1,000-4,999) 91.9 5,163 515

Large (5,000-24,999) 95.1 1,606 360

Very large (25,000+) 98.6 281 167

Urbanicity

City 92.1 1,440 247

Suburban 92.0 2,653 365

Town 92.9 2,675 256

Rural 90.5 6,993 478

Poverty level

Low (0-29% F/RP) 88.2 3,238 336

Medium (30-59% F/RP) 93.7 6,514 627

High (60% or more F/RP) 90.4 4,010 383

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with policies to accommodate students with special diets differed significantly by SFA size at the .05 level. 

Data Source: SFA Director Survey 2011, question 12.4. 
80

 There was very little variation across SFA characteristics in terms of those with policies and 

procedures to accommodate students with special diets. As shown in Table IV-3.5, nearly 90 percent 

of the smallest SFAs had such policies compared to 95 and 99 percent of the large and very large 

SFAs. Differences among levels of urbanicity and poverty were not statistically significant. 

 Table IV-3.6 shows the most frequent practices to protect students with special diets cited 

by SFAs included obtaining a signed prescription from a child’s physician (88 percent) and having 

the cashier check the student’s tray (66 percent). The percentage of SFA directors reporting 

requiring a signed prescription increased with the size of the SFA. Eighty-one percent of small SFAs 

required a signed prescription from a physician, while 99 percent of the very large SFAs had this 

requirement. 

Table IV-3.6. Percentage of SFAs that Use Various Types of Food Service Procedures to 

Protect Students with Special Diets by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs with the following policies and procedures to 

accommodate students with special diets: Total SFAs

Signed 

prescription 

from physician

Cashier has 

child names to 

check trays

Consultation with 

registered dietitian 

to plan menus Other

Weighted 

n

Unweighted 

n

All SFAs 87.5% 65.7% 26.4% 8.5% 14,344 1,3811

SFA size2

Small (1-999) 80.7 54.3 14.7 10.9 7,146 322

Medium (1,000-4,999) 93.5 74.5 32.7 6.1 5,296 528

Large (5,000-24,999) 96.0 82.8 48.4 6.0 1,618 362

Very large (25,000+) 98.9 88.6 76.3 9.9 284 169

Urbanicity3

City 87.0 67.7 36.4 13.2 1,541 252

Suburban 87.4 72.5 30.4 8.4 2,823 376

Town 93.1 70.5 29.9 4.8 2,744 262

Rural 85.5 60.8 21.4 9.0 7,225 491

Poverty level4

Low (0-29% F/RP) 83.6 65.1 24.4 5.9 3,265 340

Medium (30-59% F/RP) 91.2 70.0 25.9 9.1 6,709 642

High (60% or more F/RP) 84.7 59.5 28.6 9.7 4,370 399

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs that use a signed prescription from physician, have cashier check child names against trays, consult with registered 

dietitians, and implement other policies to accommodate students with special diets differed significantly by SFA size at the .05 level. 

3 Percentage of SFAs that have cashier check child names against trays and consult with registered dietitians to accommodate students with 

special diets differed significantly by urbanicity at the .05 level. 

4 Percentage of SFAs that use a signed prescription from physician and have cashier check child names against trays to accommodate students 

with special diets differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, question 12.6.
81

Components of Food Safety 

Safety Inspections 

 About 84 percent of SFAs reported that all of their schools had two or more safety 

inspections during SY 2010-11 as shown in Table IV-3.7.28 Another 4 percent said that most schools 

had two or more safety inspections. Eight percent of SFAs reported that none of their schools had 

two or more safety inspections during SY 2010-11, and this was more likely among smaller SFAs 

than larger SFAs. Furthermore, Appendix E, Table E-2 shows that the percentage of SFAs that had 

all schools inspected for SY 2010-11 is similar to those reported in SY 2008-09 (84 percent) and SY 

2009-10 (85 percent). 

Table IV-3.7. Percentage of SFAs with All, Most, Some, or No Schools having Two or More 

Safety Inspections by SFAs Characteristics, SY 2010-11

SFA characteristics

Percentage of SFAs with two or more safety 

inspections in SY 2010-11 at: Total SFAs

All 

schools

Most 

schools

Some 

schools

No

schools

Weighted 

n

Unweighted 

n

All SFAs 84.2% 4.1% 3.6% 8.1% 14,418 1,3861

SFA size2

Small (1-999) 84.9 2.4 2.9 9.8 7,179 324

Medium (1,000-4,999) 84.7 4.0 4.2 7.2 5,337 531

Large (5,000-24,999) 80.7 10.1 4.2 4.9 1,618 362

Very large (25,000+) 75.3 14.7 7.3 2.7 284 169

Urbanicity2

City 74.5 11.1 5.8 8.6 1,539 252

Suburban 84.7 4.7 4.6 6.0 2,860 378

Town 83.6 5.5 4.8 6.1 2,769 263

Rural 86.2 1.8 2.3 9.6 7,250 493

Poverty level

Low (0-29% F/RP) 85.5 3.0 2.8 8.6 3,341 344

Medium (30-59% F/RP) 83.2 3.3 4.2 9.3 6,757 645

High (60% or more F/RP) 84.6 6.2 3.3 6.0 4,319 397

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with schools having two or more safety inspections differed significantly by SFA size and urbanicity at the .05 level. 

Data Source: SFA Director Survey 2011, question 12.7a. 

 

28 http://www.fns.usda.gov/fns/safety/pdf/inspections_09-10.pdf. 
82

 For those 8 percent of SFAs reporting that schools did not have two or more safety 

inspections, Table IV-3.8 shows the reasons, which included lack of local public health inspectors 

(54 percent), insufficient funding at state and local public health agencies (51 percent), public health 

agencies setting a low priority for such inspections (35 percent), and schools in general being a low 

priority for inspections (27 percent). 

Table IV-3.8. Among SFAs that reported their Schools Did Not Have Two Safety Inspections, 

the Percentage of SFAs Citing Various Reasons, SY 2010-11

Reasons

Among SFAs with less than two 

school inspections, the percentage of 

SFAs citing various reasons

Insufficient funding at state and local public health agencies 51.0%

Lack of local public health inspectors 53.8

Schools are a low priority 27.0

Public health agencies prioritize inspections according to risk 35.4

Insufficient funding in the school district to pay for two or more inspections 7.0

Other129.5

SFAs with schools that did not have two inspections: Weighted n 1,188

SFAs with schools that did not have two inspections: Unweighted n 862

1

 The other responses were: requested two inspections but only received one (12 percent), only one inspection per year required (7 percent), 

and don’t know reason (6 percent) and other (4 percent).

2

n is equal to the 86 SFAs in which no schools had at least two safety inspections in SY 2010-11.

Data Source: SFA Director Survey 2011, question 12.9. 

Both state and local agencies may conduct school food safety inspections, and some SFAs 

are inspected by multiple agencies. The predominant government agencies conducting school food 

safety inspections were state agencies, such as public health agencies (76 percent). Forty percent of 

SFAs indicated that local government agencies conducted inspections in SY 2010-11 as shown in 

Table IV-3.9. The agency that conducted the safety inspections varied by SFA size, urbanicity, and 

poverty level. For example, local government inspections were more likely for large and very large 

SFAs. 
83

Table IV-3.9. Percentage of SFAs that Reported Food Safety Inspections are Conducted by 

Various Types of Agencies by SFA Characteristics, SY 2010-11

SFA characteristics

Percentage of SFAs reporting inspections by: Total SFAs

State 

governmental 

agency

Local 

governmental 

agency

Some other 

agency

Weighted 

n

Unweighted 

n

All SFAs 75.6% 40.2% 3.8% 13,243 1,3001

SFA size2

Small (1-999) 82.7 30.4 2.5 6,474 293

Medium (1,000-4,999) 71.3 45.2 4.3 4,954 495

Large (5,000-24,999) 64.6 59.7 7.7 1,538 347

Very large (25,000+) 47.1 70.8 6.2 277 165

Urbanicity2

City 63.9 53.4 2.9 1,407 240

Suburban 60.0 61.4 7.4 2,688 357

Town 81.1 35.3 6.0 2,599 249

Rural 82.4 30.5 1.7 6,548 454

Poverty level3

Low (0-29% F/RP) 64.0 49.7 4.7 3,053 317

Medium (30-59% F/RP) 77.8 36.5 3.8 6,128 601

High (60% or more F/RP) 81.1 38.6 3.2 4,061 382

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs reporting inspections by state government, local government, and other agencies differed significantly by SFA size and 

urbanicity at the .05 level. 

3

 Percentage of SFAs reporting inspections by state government and local government agencies differed significantly by poverty level at the .05 

level. 

Data Source: SFA Director Survey 2011, question 12.8. 

Schools Cited for Food Safety Violations 

 Eighty-three percent of SFAs reported that none of the schools under their purview were 

cited for food safety violations, while 17 percent had one or more schools cited during SY 2009-10 

as shown in Table IV-3.10. There was virtually no difference by poverty level of SFAs reporting 

food safety violations among their schools, but there was substantial variation based on the size of 

the SFAs and urbanicity. An estimated 40 percent of large SFAs and 59 percent of very large SFAs 

reported having at least one school cited for violations. By contrast, only 9 percent of small SFAs 

reported having schools cited for food safety violations. Twenty-seven percent of SFAs located in 

urban areas reported schools with violations, while only 14 percent of SFAs in rural areas reported 

violations. 

 During SY 2010-11, an estimated 7,968 elementary schools were cited for food safety 

violations.29 Approximately 2,793 middle/junior high schools and 2,837 high schools were also cited 

for violations. Among “other” schools not classified as elementary, middle or high school, 1,163 

received citations for food safety violations.30

 

29 Weighted numbers of students based on responses to question 12.11 of the 2011 SFA Director Survey. 

30 These numbers are weighted numbers and represent estimates of the number of schools with food safety violations in the states 

and territories. 
84

Table IV-3.10. Percentage of SFAs with One or More Schools Cited for Food Safety Inspection 

Violations by SFA Characteristics, SY 2010-11 

SFA characteristics Percent of SFAs

Total SFAs

Weighted n Unweighted n

All SFAs 17.3% 14,407 1,3841

SFA size2

Small (1-999) 9.4 7,181 324

Medium (1,000-4,999) 19.0 5,337 531

Large (5,000-24,999) 40.2 1,605 360

Very large (25,000+) 58.6 284 169

Urbanicity2

City 26.7 1,566 253

Suburban 21.2 2,847 376

Town 17.8 2,769 263

Rural 13.6 7,224 492

Poverty level

Low (0-29% F/RP) 17.7 3,329 342

Medium (30-59% F/RP) 17.5 6,757 645

High (60% or more F/RP) 16.7 4,321 397

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs with one or more schools cited for food safety inspection violations differed significantly by SFA size and urbanicity at the 

.05 level. 

Data Source: SFA Director Survey 2011, question 12.10. 

Types of Violations 

 Figure IV-3.3 shows that among SFAs that had schools cited for food safety violations, the 

most common reasons were improper food temperature (43 percent), unsanitary surfaces or utensils 

(36 percent), food storage problems (36 percent), pests (25 percent), and inconsistent use of gloves 

and/or hair restraints (23 percent). 
85

Figure IV-3.3. Among SFAs with Schools Cited for Food Safety Violations, the Percentage of 

SFAs with All, Most, Some, and No Schools having Various Types of Violations 

n is less than the 389 SFAs that had schools cited for food safety violations due to non-response. 

Percentages are based on a weighted n of 2,493 (unweighted 388). 

Data Source: SFA Director Survey 2011, question 12.12. 

Food Recall Notification Procedures 

 Food recalls protect consumers and are governed by several laws, regulations, and policies. 

Federal agencies— Food Safety Inspection Service (FSIS), Food and Drug Administration (FDA), 

or the Centers for Disease Control and Prevention (CDC)—could be informed when a company 

identifies a problem. When a product and its source are identified, either FSIS or FDA—whichever 

agency has jurisdiction over the product—works with the company to recall the affected food. 

 FNS provides information to the states on food recalls and provides instructions on how to 

dispose of the recalled food. FNS also provides information on how the schools will be reimbursed 

for recalled products. FNS sends this information to the states, and the states then inform the SFAs 

and schools. 

 From the survey of state directors detailed in section VI of this report, the data reveal that 

over half of the states had formal policies regarding food recalls. Also, nearly all of the states 

reported contacting SFA directors primarily by email when recalls occur. The states provide the SFA 

91.0

84.4

73.8

77.5

76.6

74.6

63.7

63.6

57.1

6.0

9.7

11.6

18.7

17.4

21.0

30.3

28.3

32.5

0% 20% 40% 60% 80% 100%

Raw meat or fish not properly separated from 

ready-to-eat food

Lack of proper, adequate hand washing

Other

Chemicals and other poisonous or toxic 

materials not properly marked, stored, or used

Inconsistent or not using gloves and/or hair 

restraints

Presence of pests

Food storage problems

Surfaces and/or utensils not properly 

cleaned/sanitized

Improper temperature of food during storage, 

cooking, holding, and/or cooling

None of the Schools Some Schools Most Schools All Schools
86

director with the hold or recall notice along with information about the product. In nearly all states, 

the SFA director receives disposal instructions and contact information for any questions. Most 

states also indicated they provide SFAs with press releases about the hold or recall. 

 SFA directors were asked to provide information about how they receive information about 

food holds and recalls. As Figure IV-3.4 shows, the vast majority of SFAs (95 percent) said they 

were informed through email. Twenty-six percent of the SFA directors received faxes, 39 percent 

received telephone calls, and 39 percent received notices by mail. Clearly, some SFA directors 

received notices via multiple means. 

Figure IV-3.4. Percentage of SFAs that Receive Alerts about Food Recalls via Various 

Methods, SY 2011-12

n is less than 1,401 due to item non-response. Percentages based on a weighted response of 14,426 (unweighted 1,386). 

Data Source: SFA Director Survey 2011, question 12.13. 

After receiving information about food holds and recalls, it is the SFA’s responsibility to 

disseminate the information to schools. Figure IV-3.5 shows that SFAs typically sent emails (76 

percent) or made telephone calls (65 percent) to notify schools about holds or food recalls. Given 

the relationship between the SFA and the schools it serves, as well as the physical proximity of 

offices in some cases, it is not surprising that about 9 percent reported notifying the schools in 

person. 

95.4

38.7 38.6

25.7

1.2 3.5

0

10

20

30

40

50

60

70

80

90

100

Email 

notification

Telephone 

calls

Notice by 

mail

Faxes Website Other

Percentage of SFAs
87

Figure IV-3.5. Percentage of SFAs that Use Various Methods to Alert Schools about Holds or 

Food Recalls, SY 2011-12

n is less than 1,401 due to item non-response. Percentages based on a weighted response of 14,396 (unweighted 1,385). 

Data Source: SFA Director Survey 2011, question 12.14. 

76.0

65.1

17.8 15.6

8.8 5.8

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

90.0

100.0

Email 

notification

Telephone 

calls

Notice by 

mail

Faxes In-person/

personal visit

Other

Percentage of SFAs
88

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89

IV-4. Food Procurement 

Background

The procurement process and practices for school foods are influenced by a number of 

factors, including the following: 

 Procurement regulations and guidance; 

 Nutritional requirements and standards set by USDA at the Federal level, as well as 

those set by state and local agencies that oversee the child nutrition programs; 

 The financial resources of the SFA; and 

 Constraints and capabilities of the food service operation, including cafeteria layout and 

kitchen type, storage facilities. 

Given the substantial governmental investment in school meals, Federal law requires SFAs 

to devote at least 51 percent of their school food budget to domestically grown agricultural 

products. Some states and local governments have additional requirements that exceed the Federal 

laws regarding food procurements using public funds. The updated nutritional standards for the 

NSLP and the SBP as required by the HHFKA will affect procurement practices in schools, LEAs, 

and states across the country. The new meal patterns call for schools to offer more fruits and 

vegetables, phase in more whole-grain and low-fat and non-fat dairy products, and reduce sodium 

and sugar content. 

Research Questions 

This chapter answers the following research questions regarding food procurement 

processes and practices. 

 Are SFAs using geographic preference in their procurement of foods? If yes, how frequently? 

 Do SFAs use food purchasing specifications that include specific per-serving nutrient requirements? Are 

these product specifications required for all foods or just some foods? What nutritional information is 

requested from potential vendors? Is this information provided? 

 What proportion of SFAs utilizes an FSMC? 
90

Results 

Use of Geographic Preference and Farm to School 

The 2008 amendments to the National School Lunch Act require the Secretary of 

Agriculture to encourage SFAs to purchase unprocessed31 locally grown and locally raised 

agricultural products.32 To accomplish this, SFAs have the option of including a geographic 

preference clause when procuring such products. If a geographic preference has been established for 

procurements, the bidders in a specified geographic area can be awarded additional points or the 

SFA may prescribe geographic preference in terms of a percentage of the price. The chosen method 

must be clearly outlined in the procurement scoring criteria. Although a geographic preference is not 

a procurement set-aside for bidders located in the specified geographic area, it is a tool that gives 

bidders in a specified geographic area a defined advantage in the procurement process. However, 

procurements must still be conducted in a manner that allows for maximum free and open 

competition. 

To gain an understanding of how SFAs go about the process of food procurement, directors 

were asked a series of questions about their preference for purchasing unprocessed foods that were 

locally grown, raised, or produced. During SY 2011-12, just under half of all SFAs (49 percent) 

reported never giving preference for purchasing unprocessed foods that have been locally grown, 

raised, or produced as shown in Table IV-4.1. The use of geographic preference in procurements 

varied depending on the characteristics of the SFA. Compared with other SFA size categories, a 

higher percentage of the small SFAs reported never giving preference when purchasing foods (60 

percent). Higher percentages of large, very large, and more affluent SFAs gave preference based on 

geographic proximity compared with other groups. Larger SFAs may be able to secure better pricing 

from food suppliers based on the sheer volume of their purchases. Although SFAs located in more 

rural areas may be expected to have greater access to locally grown or raised products, 54 percent 

reported they never give preference to locally produced products. 

When asked about their participation in farm to school activities, only 20 percent (shown 

previously in Table III-10) of SFAs indicated their involvement in this initiative. This percentage is 

considerably below the 51 percent of SFAs that gave geographic preference at least some of the 

time. Because a primary focus of farm to school activities is connecting schools with local or 

regional producers and bringing locally sourced fresh fruits and vegetables as well as minimally 

processed foods into schools, the difference is surprising. However, it is possible that the 

discrepancy stems from some SFA directors perceiving geographic preference as a procurement 

issue rather than an element of farm to school. For those SFAs that indicated participation in farm 

to school, 89 percent used geographic preference in procurement decisions at least some of the time. 

 

31 Unprocessed is defined as agricultural products that retain their inherent character. 

32 “Geographic Preference Option for the Procurement of Unprocessed Agricultural Products in Child Nutrition Programs,” 76 

Federal Register ,78, April 22, 2011, p. 22603. Available at http://www.fns.usda.gov/cnd/Governance/regulations/2011-04-22.pdf. 
91

Table IV-4.1. Percentage of SFAs that Gave Preference to Purchasing Unprocessed Foods 

that Have Been Locally Grown, Raised, or Produced, SY 2011-12

SFA characteristics

Percentage of SFAs that give preference to 

purchasing unprocessed, local foods: Total SFAs

Most of the time Some of the time Never Weighted n Unweighted n

All SFAs 8.3% 42.7% 49.0% 14,540 1,3931

SFA size2

Small (1-999) 7.6 32.5 59.9 7,261 327

Medium (1,000-4,999) 8.5 50.4 41.1 5,370 534

Large (5,000-24,999) 10.0 60.3 29.7 1,625 363

Very large (25,000+) 11.3 58.4 30.3 284 169

Urbanicity2

City 10.2 42.0 47.7 1,627 255

Suburban 9.0 57.5 33.5 2,865 379

Town 8.5 37.8 53.7 2,773 264

Rural 7.5 39.0 53.5 7,275 495

Poverty level2

Low (0-29% F/RP) 10.3 51.8 37.9 3,357 346

Medium (30%-59% F/RP) 7.5 42.1 50.4 6,799 647

High (60% or more F/RP) 7.9 36.8 55.3 4,384 400

Particpating in the farm to school

initiative 19.2 70.1 10.7 2,971 366

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs giving preference to purchasing unprocessed, local foods differed significantly by SFA size, urbanicity, and poverty level at 

the .05 level. 

Data Source: SFA Director Survey 2011, questions 10.1 and 11.5. 

Not surprisingly, given budget constraints and the need to operate at a break-even level, 

price is an important factor in SFA directors’ decisions when purchasing local foods. Table IV-4.2 

shows that about one-third of SFA directors who give preference to purchasing local foods reported 

that they only purchase them when they are priced competitively. Only 10 percent of SFA directors 

reported that they always purchased or tried to purchase local foods even when similar products 

could be purchased outside the geographic area for less. 

Table IV-4.3 shows that the most commonly preferred local foods by far were fresh fruits 

and vegetables (97 percent). Other local food items that SFA directors were inclined to purchase 

were reported by less than one-quarter of the SFAs. This may be related to the location of the SFA 

and the availability of these foods within the local area. For example, pasteurized milk may not be 

available within the locally defined area for all SFAs. Definitions of what is “local” varied among 

SFA directors. Table IV-4.3 also shows the percentage of SFA directors who use different 

definitions of local. For example, nearly half (41 percent) of SFA directors considered a within-50-

mile distance from their schools as their definition to be local, while another 29 percent use 51-100 

miles. Fifteen percent considered within 101-200 miles to be local, and the remaining 15 percent 

consider more than 200 miles or “other” as local. 
92

Table IV-4.2. Among SFAs Giving Preference to Local Foods, the Percentage of SFAs that Do 

This Always, Sometimes, or Only If they are Priced Competitively, SY 2011-12

SFA characteristics

Among SFAs giving preference to local foods, the percentage 

of SFAs that: Total SFAs

Always 

purchases or 

tries to purchase 

locally

Sometimes 

purchases or 

tries to purchase 

locally

Only purchases 

locally when priced 

competitively

Weighted 

n

Unweighted

n

All SFAs 10.3% 55.2% 34.4% 7,395 8121

SFA size

Small (1-999) 11.0 54.2 34.9 2,913 127

Medium (1,000-4,999) 9.8 57.0 33.2 3,141 310

Large (5,000-24,999) 8.6 54.4 37.0 1,143 257

Very large (25,000+) 19.2 48.8 32.0 198 118

Urbanicity 

City 16.4 52.4 31.2 850 167

Suburban 10.2 59.7 30.1 1,904 275

Town 11.3 51.3 37.4 1,270 125

Rural 8.5 55.0 36.5 3,371 245

Poverty level 

Low (0-29% F/RP) 10.6 56.5 32.9 2,070 239

Medium (30%-59% F/RP) 7.8 54.1 38.1 3,364 362

High (60% or more F/RP) 14.5 55.8 29.7 1,961 211

1

n is less than the 814 SFAs that gave preference to local foods due to item non-response. 

Data Source: SFA Director Survey 2011, questions 10.2, 10.3, and 10.4. 

Table IV-4.3. Among SFAs Giving Preference to Local Foods, the Percentage of SFAs that 

Purchase Various Foods and Define Local in Different Ways, SY 2011-12

Action Percentage of SFAs

Purchased local foods

Fresh fruits and vegetables 96.5%

Pasteurized milk 23.0

Meat, fish, or poultry 10.9

Breads or grains 1.2

Other foods 2.0

Total SFAs: Weighted n 

Total SFAs: Unweighted n

7,405

8121

Defined local as:

Within 50 miles of schools 41.2

Within 51-100 miles of schools 28.6

Within 101-200 miles of schools 15.4

More than 200 miles 5.7

Within state 4.4

Other 4.8

Total SFAs: Weighted n 

Total SFAs: Unweighted n

7,384

8111

1

n is less than the 814 SFAs that gave preference to local foods due to item non-response. 

Data Source: SFA Director Survey 2011, questions 10.3 and 10.4. 
93

Food Purchasing Specifications 

The HHFKA directed USDA to update the NSLP and SBP meal pattern and nutrition 

standards and to base the updates on the latest Dietary Guidelines for Americans (Schneider et al., 2012). 

USDA issued a final interim regulation describing the updated standards and the implementation 

schedule in January 2012. The updated NSLP meal patterns began in SY 2012-13 (though some 

requirements such as sodium reduction and whole-grain increases are to be phased in over time). 

SBP meal pattern changes will begin to be implemented in SY 2013-14. The updated meal patterns 

increase the offering of fruits, vegetables, and whole grains. The updated standards also establish 

calorie ranges for different age groups to ensure age-appropriate meals for grades K-5, 6-8, and 9-12. 

Other meal requirements include gradual reductions in the sodium content of meals; specific sodium 

content targets must be reached by SY 2014-15 and SY 2017-18 and fully implemented by SY 2022-

23. Although meal patterns have been updated to reflect current dietary guidelines, decisions about 

what specific foods to serve, and therefore procure, and how they are prepared and presented 

continue to be made at the school and SFA levels. 

Most SFAs obtained nutrition information about the foods they received in more than one 

way. Nutritional labels included with the product (86 percent) and contacting the vendor or 

manufacturer directly (64 percent) were the two most common methods of obtaining product 

nutrition information, as shown in Figure IV-4.1. Much less common were online searches (9 

percent) and “other” (9 percent).

Figure IV-4.1 Percentage of SFAs Obtaining Nutrition Information for Foods Via Various 

Methods, SY 2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,454 (unweighted 1,387). 

Data Source: SFA Director Survey 2011, question 10.5. 

86.1

63.6

8.8 8.6

0

10

20

30

40

50

60

70

80

90

100

Percentage of SFAs

Nutrition labels packaged 

with or directly on the 

product

Contacting the 

vendor/manufacturer 

directly

Online

Other
94

 Figure IV-4.2 shows that when ordering food for the school-meal programs, less than half of 

SFAs (45 percent) always specified nutrient requirements for a single serving of a specific type of 

food or meal in the bid specifications. Another 43 percent sometimes specified such requirements. 

Only 12 percent of SFAs never required certain levels of nutrients in school meals or food in bid 

specifications. 

Figure IV-4.2. Percentage of SFAs that Specify Nutrient Requirements for a Single Serving 

When Ordering Food, SY 2011-12 

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,455 (unweighted 1,388). 

Data Source: SFA Director Survey 2011, question 10.7. 

 

As shown in Figure IV-4.3, the vast majority (96 percent) of SFA directors rated the 

nutritional information they received as either excellent or satisfactory. Only 4 percent of SFA 

directors reported not being satisfied with nutritional information they receive. 

Figure IV-4.3. Percentage of SFAs Satisfied with the Availability of Nutrition Information, SY 

2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,513 (unweighted 1,390). 

Data Source: SFA Director Survey 2011, question 10.6. 

45.4%

42.6%

12.0%

Always Sometimes Never

24.8%

71.5%

3.7%

Excellent Satisfactory Unsatisfactory
95

 The study asked SFA directors if they specified per-serving nutrient requirements for nine 

specific food types. Figure IV-4.4 shows, among all SFAs, the percentage of directors who specify 

nutrient requirements for each of these food types. Nearly 60 percent of SFA directors specify perserving nutrients for at least one food type. More than 80 percent of them use per-serving 

specifications for bread, milk, and the main dish or entrée. Although 45 percent (Figure VI-4.2) 

responded that they always specified nutrient requirements per single serving when ordering, only 

about one-third (not shown) of SFAs specify per-serving nutrients for all nine food types. 

Figure IV-4.4. Percentage of SFAs that Specify Per-Serving Nutrient Requirements by Food 

Type, SY 2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,435 (unweighted 1,384). 

Data Source: SFA Director Survey 2011, question 10.8. 

 Many SFAs require vendors to supply specific types of nutrient information for the foods 

they purchase. Figure IV-4.5 shows the percentage of SFA directors that require various nutrition 

information. SFA directors reported that the top three pieces of nutrition information required were 

total calories (90 percent), percent of calories from total fat (89 percent), and sodium content (88 

percent). Only slightly smaller percentages of SFA directors reported requiring information on 

saturated fat (86 percent), sugar (85 percent), percent of calories from trans fat (85 percent), protein 

(84 percent), and carbohydrates (83 percent). Fiber was close behind carbohydrates at 78 percent. 

The remaining nutrients ranged between 60 percent and 72 percent. 

85.0

84.2

81.8

68.5

67.1

62.4

62.1

61.5

59.1

0 10 20 30 40 50 60 70 80 90 100

Main dish/entrée

Milk

Bread or bread alternate 

Cooked vegetables

Fruit 

Snack foods

Salad/raw vegetables

Beverages other than milk

Desserts

Percentage of SFAs
96

Figure IV-4.5. Percentage of SFAs that Require Various Nutrition Information from Food 

Vendors, SY 2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,220 (unweighted 1,371). 

Data Source: SFA Director Survey 2011, question 10.9. 

 Figure IV-4.6 reveals that 72 percent of SFA directors reported that, over the last year, 

vendors always supplied the requested nutrition information. Only 5 percent of SFAs indicated they 

never received the information they requested. 

89.7

89.2

87.7

86.2

84.7

84.8

84.5

83.2

78.3

72.3

68.6

68.1

67.7

62.5

59.7

3.7

0 10 20 30 40 50 60 70 80 90 100

Total calories

% of calories 

from total fat

Sodium

% of calories 

from saturated fat

Sugar

% of calories 

from trans fat

Protein

Carbohydrates

Fiber 

Calcium

Vitamin A

Iron

Vitamin C

Vitamin D

Vitamin B

Other

Percentage of SFAs
97

Figure IV-4.6. Percentage of SFAs that Received Requested Nutritional Information from 

Vendors, SY 2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,487 (unweighted 1,389). 

Data Source: SFA Director Survey 2011, question 10.10. 

 Although SFAs used a variety of methods to purchase foods for the schools they serve, the 

most common method was to purchase at least some foods directly by the SFA (68 percent), as 

shown in Figure IV-4.7. In approximately one-third of SFAs, food was purchased by the schools (36 

percent) or through a food co-op (34 percent). About one-quarter of SFAs (24 percent) purchased 

food through the DoD Fresh Program. 

Figure IV-4.7. Percentage of SFAs that Used Various Methods to Purchase Foods, SY 2011-12

n is less than 1,401 due to item non-response. Percentages are based on a weighted item response of 14,454 (unweighted 1,388). 

Data Source: SFA Director Survey 2011, question 10.11. 

71.9%

22.9%

5.2%

Always Sometimes Never

68.4

35.5

33.8

23.9

18.5

16.4

2.7

6.5

0 10 20 30 40 50 60 70 80 90 100

By the SFA

By the schools

Through a 

food co-op

Through the 

DoD Fresh 

By FSMCs

By the state

By a consortium 

of states

Other

Percentage of SFAs
98

It is possible for SFAs to increase their purchasing power by forming a consortium or food 

co-op. Table IV-4.4 presents the use of food co-ops and consortiums by the size category of the 

SFAs. These methods are most often reported by medium and large SFAs. Small SFAs, which could 

most benefit from combining their purchasing power with other SFAs, reported using these 

methods least often, perhaps because their combined size is not enough to obtain increased 

purchasing power. 

Table IV-4.4. Percentage of SFAs that Used Selected Methods to Purchase Foods by SFA Size, 

SY 2011-12

SFA Size

Percentage of SFAs that purchased food products: Total SFAs

Through a food co-op By a consortium of states Weighted n Unweighted n

All SFAs 33.8% 2.7% 14,454 1,3881

SFA size2

Small (1-999) 26.8 1.2 7,201 325

Medium (1,000-4,999) 38.3 4.1 5,350 532

Large (5,000-24,999) 49.5 4.9 1,619 362

Very large (25,000+) 37.8 1.3 284 169

1

n is less less than 1,401 due to item non-response. 

2

 Percentage of SFAs purchasing food products through a food co-op and by a consortium of states differed significantly by SFA size at the .05 

level. 

Data Source: SFA Director Survey 2011, question 10.11. 

Food Service Management Companies 

 One option available to SFAs to manage food service operations is to contract with an 

FSMC. The SFA is still required to comply with existing Federal, state, and local procurement 

requirements listed at 7 CFR Parts 3016.36 and 3019.40 when contracting with an FSMC. 

 Table IV-4.5 shows the percentage of SFAs that contracted with an FSMC by SFA 

characteristics and the type of menu planning system used. Overall, 21 percent of SFAs contracted 

with an FSMC during SY 2011-12. The use of an FSMC did significantly vary by SFA urbanicity and 

poverty level. SFAs in rural areas and towns and with medium poverty levels were less likely to 

contract with an FSMC. Although very large SFAs were also less likely to use an FSMC, they 

represented a small number of SFAs, and overall SFA size did not result in statistically different 

FSMC use rates. There were some differences based on the type of menu planning system used. 

However, these differences are most likely a function of the type of system used by the FSMC rather 

than selection of the FSMC based on the menu planning system used. 
99

Table IV-4.5. Percentage of SFAs that Contracted with an FSMC by SFA Characteristics, SY 

2011-12

SFA characteristics Percent of SFAs that use an FSMC

Total SFAs

Weighted n Unweighted n

All SFAs 20.8% 14,494 1,3891

SFA size

Small (1-999) 20.1 7,255 327

Medium (1,000-4,999) 22.1 5,329 530

Large (5,000-24,999) 21.2 1,625 363

Very large (25,000+) 12.9 284 169

Urbanicity2

City 34.5 1,577 253

Suburban 31.3 2,841 377

Town 21.2 2,777 264

Rural 13.6 7,298 495

Poverty level2

Low (0-29% F/RP) 24.9 3,335 344

Medium (30%-59% F/RP) 17.1 6,758 645

High (60% or more F/RP) 23.4 4,401 400

Menu planning2

Traditional food based 15.5 8,618 808

Enhanced food based 17.2 1,723 174

Nutrient standard menu planning 38.8 1,792 218

Assisted nutrient standard menu planning 

New or innovative approach

Combination

51.7

6.7

29.2

94

49

1,932

8

8

157

Other 22.4 256 13

1

n is less than 1,401 due to item non-response. 

2

 Percentage of SFAs contracting with a FSMC differed significantly by urbanicity, poverty level, and menu planning at the .05 level. 

Data Source: SFA Director Survey 2011, questions 4.10 and 10.12. 

SFAs that contracted with an FSMC used multiple methods to track rebates, discounts, or 

fees. Figure IV-4.8 shows that 81 percent of SFA directors indicated that the contracts they were 

responsible for specified that the value of USDA-donated foods must be credited to the school 

district. Other common methods included checking invoices for credits and reductions (75 percent) 

and requiring the return of discounts, rebates, and credits, and related documentation (71 percent). 

About 66 percent of SFA directors said that they obtained documentation supporting the calculation 

of the bid rate per meal, and 62 percent indicated that they reviewed documentation on variable 

costs. 
100

Figure IV-4.8. Among SFAs that Used a FSMC, the Percentage of SFAs that Used Various 

Methods to Track Rebates, Discounts, or Fees, SY 2011-12

n is less than the 279 SFAs that used an FSMC due to item non-response. 

Percentages are based on a weighted item response of 2,927 (unweighted 272). 

Data Source: SFA Director Survey 2011, question 10.13.

81.2

74.8

70.9

66.4

62.2

5.9

0 20 40 60 80 100

Contracts specify value of 

USDA-donated foods must be 

credited to the district

Check that invoices 

specify credits and reductions

Require the return of 

discounts, rebates, and 

credits and documentation

Obtain documentation 

supporting the calculation 

of the bid rate per meal

Review documentation 

on variable costs

Other review and 

oversight procedures

Percentage of SFAs
101

IV-5. Menu Planning and Nutritional Analysis 

Background 

The National School Lunch Act mandates that school meals “safeguard the health and wellbeing of the Nation's children,”33 and local food service professionals are required to prepare and 

serve meals consistent with Federal school nutrition standards. The current study was conducted to 

examine school nutrition operations during SY 2011-12; schools used the nutrition standards 

established under the School Meals Initiative (SMI).34 The SMI standards are based on the 1995 

Dietary Guidelines and the 1989 RDAs and specify that school lunch should provide one-third the 

RDA and school breakfast should provide one-fourth the RDA for energy, proteins, vitamins A and 

C, and the minerals calcium and iron. Together, school lunch and breakfast should provide no more 

than 30 percent of the calories from fat and no more than 10 percent of the calories from saturated 

fat.35

To provide the SFAs with flexibility in meeting the SMI nutrition goals, the USDA 

established five menu planning approaches, which were in use through SY 2011-12. As described 

below, two of these menu planning approaches are food based, two are nutrient based, and one is an 

alternative “reasonable” approach. 

A. Food-Based Menu Planning (FBMP) Approach

Traditional Food-Based Menu Planning—This menu planning approach specifies food 

component requirements and quantity requirements for each component, as follows: 

― School lunch must include five food items from four food components: meat/meat 

alternate, vegetables and/or fruits, grains/breads, and milk. 

― School breakfast must include four food items from four food components: 

vegetables and/or fruits; milk; meat/meat alternate, grains/breads. 

― For school lunch as well as breakfast, minimum portion sizes are set by ages and 

grade groups. 

Enhanced Food-Based Menu Planning—This menu planning approach uses the same 

meal pattern and age groups as the traditional food-based menu planning approach but 

specifies an option for grades 7 to 12. This option was added to meet the nutritional 

needs of children during their critical growth period; it includes a greater number of 

servings from grains and larger portion size for fruits and vegetables. This approach 

attempts to increase calories from low-fat food sources to meet the Dietary Guidelines. 

 

33 http://www.fns.usda.gov/cnd/menu/menu.planning.nslp.htm. 

34 In 2010, the nutrition standards for school meals were revised based on the IOM recommendations; these recommendations 

aligned the school meals with the most recent Dietary Guidelines for Americans and the nutrition requirements specified in the 

Dietary Reference Intakes (DRIs). In SY 2012-13, all schools were expected to begin implementing the new meal requirements and 

to use the food-based menu planning approach http://www.fns.usda.gov/cnd/Governance/Legislation/nutritionstandards.htm. 

35 School breakfasts must provide, on average over each school week, at least one-fourth of the daily RDAs for protein, iron, calcium, 

and vitamins A and C. 
102

― For school lunch, the four food components specified in the traditional food-based 

menu planning approach are retained, but the component quantities for the weekly 

servings of vegetables and fruits and grains/breads are increased. 

― For school breakfast, an optional age/grade group was added for grades 7-12 to 

better meet the needs of children in that crucial growth period by adding low-fat 

calories from additional servings of grains/breads. 

B. Nutrient-Based Menu Planning Approach 

Nutrient Standard Menu Planning (NSMP)—Also known as NuMenus, NSMP is a 

computer-based menu planning system that uses approved computer software to 

analyze the nutrient content of school menus during the menu planning stage. It is 

designed to assist menu planners in choosing food items that create nutritious meals 

and meet the nutrient standards. SFAs using this approach are directed to offer milk, 

one entrée, and one side dish, but there are no specifications on portion size or foods. 

Assisted Nutrient Standard Menu Planning—This variation of NSMP is also known as 

Assisted NuMenus. This approach is designed for schools that lack the technical 

resources to conduct nutrient analysis themselves. It allows schools to use an outside 

source, such as another school district, state agency, or a consultant, to plan and analyze 

menus. The outside source also provides schools with recipes and product 

specifications to support the menus. 

C. Alternative “Reasonable” Menu Planning Approach—With approval from the state, 

SFAs may use other innovative approaches that are similar to the food-based and nutrientbased menu planning approaches, with slight variations. Regardless of the menu planning 

method, all school meals should meet the nutrition requirements specified in the SMI. The 

USDA works with state and local food service authorities to provide the food service staff 

with training and technical support in menu planning and nutritional analysis. 

Research Questions 

 The research questions addressed in this chapter focus on the types of menu planning 

options used and nutrition analysis conducted during SY 2011-12. Specific questions include: 

 What types of menu planning options are being used by SFAs? 

 Do SFAs conduct a formal nutritional analysis of their planned menus? 

Results 

Menu Planning Systems 

 As Table IV-5.1 shows, in SY 2011-12, 72 percent of the SFAs used a food-based 

(traditional or enhanced) approach, 13 percent used the nutrient-based (NuMenus or Assisted 

NuMenus) approach, and 13 percent used a combination of food- and nutrient-based menu 

planning approaches. Overall, traditional FBMP was the most frequently used approach. Less than 1 
103

percent of the SFAs used new or innovative approaches to menu planning. The new or innovative 

approaches included providing flexibility to the schools to plan their own menu rather than a 

standard menu for the district; some SFA directors also indicated that they engaged students and 

parents in menu planning, designed theme days and planned menus specifically to fit the theme, or 

offered taste tasting. 

Table IV-5.1. Percentage of SFAs that Used Various Menu Planning Methods by SFA 

Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs using various menu planning methods:

Food based Nutrient based Other “reasonable” approach Total SFAs

Traditional 

food-based 

only

Enhanced 

foodbased 

only

NuMenus 

only

Assisted 

NuMenus 

only

New or 

innovative 

approaches 

only

Combination OtherWgt

n

Unwgt

n

All SFAs 59.9% 11.9% 12.3% 0.6% 0.3% 13.2% 1.7% 14,621 1,3971

SFA size

Small (1-999) 59.5 11.8 10.0 0.8 0.3 14.5 3.1 7,347 331

Medium (1,000-4,999) 62.3 11.1 12.7 0.4 0.2 13.0 0.4 5,366 534

Large (5,000-24,999) 55.4 14.3 19.4 0.5 1.0 9.3 0.2 1,623 363

Very large (25,000+) 50.1 14.5 25.5 0.0 1.1 8.2 0.5 284 169

Urbanicity 

City 62.4 7.4 16.8 0.0 0.4 5.7 7.3 1,630 256

Suburban 55.2 13.7 11.3 1.1 0.3 17.5 1.0 2,867 378

Town 61.5 11.1 15.1 1.0 0.0 10.9 0.4 2,782 265

Rural 60.5 12.4 10.7 0.5 0.5 14.1 1.3 7,342 498

Poverty level

Low (0-29% F/RP) 59.7 12.4 12.2 0.0 0.3 15.1 0.3 3,361 345

Medium (30%-59% F/RP) 57.7 13.9 12.8 0.6 0.2 13.6 1.3 6,816 649

High (60% or more F/RP) 63.2 8.3 11.7 1.3 0.6 11.2 3.6 4,443 403

Number of schools 

recognized as HealthierUS 

Schools

None 59.7 12.0 12.2 0.7 0.2 13.3 1.9 13,816 1284

1-5 61.9 10.5 10.7 0.0 3.1 13.9 0.0 618 73

6 or more 65.8 6.8 24.9 0.0 0.0 2.6 0.0 186 40

Type of kitchen

Onsite production 62.6 10.6 11.0 0.6 0.4 14.1 0.7 7,877 638

Offsite production 53.3 12.7 13.0 1.8 0.5 15.1 3.6 2,373 220

Mostly onsite production 58.2 14.3 14.1 0.0 0.2 10.7 2.5 4,114 526

Because some of the categories contain zero values, no significance tests were conducted. 

1

 n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 4.10, 4.19, and 11.7. 

 Furthermore, comparing the menu planning methods used over time, the data reveal a trend 

toward using traditional FBMP and less use of nutrient-based menus. In SY 2009-10, 73 percent of 

schools used the FBMP approach, with 53 percent using the traditional approach and 20 percent 

using the enhanced approach; about 27 percent used nutrient-based menu planning (SNDA IV, 

Volume 1). Although the overall proportion of schools using the FBMP approach appears 

unchanged between SY 2009-10 and SY 2011-12, the use of the traditional FBMP approach was 
104

about 7 percentage points higher in SY 2011-12 than in SY 2009-10. In contrast, the overall 

proportion of schools using nutrient-based menus was 14 percentage points lower in SY 2011-12 

than in SY 2009-10. It is likely that SFAs began moving toward the FBMP approach in advance of 

the new changes in meal pattern requirements. 

Nutrition Analysis of Planned Menus 

 SFAs using the FBMP approach or an alternative menu planning approach may choose to 

analyze planned menus but are not required to do so. The SFAs that use the nutrient-based menu 

planning approach must conduct nutrient analysis to plan school meals that are age/grade 

appropriate. SFAs may use USDA-approved nutrient analysis software programs to analyze the 

nutrients offered over one school week (typically over 5 consecutive days). Regardless of the menu 

planning approach, all SFAs must ensure that the planned meals meet the SMI nutrition standards. 

Each state agency is responsible for assessing SFAs’ compliance with the SMI nutrition standards 

every 3 years and to provide guidance to SFAs that are not in compliance. 

 Table IV-5.2 shows how the percentage of SFAs that conduct formal nutrition analysis of 

planned menus varies by SFA characteristics and menu planning systems. Overall in SY 2011-12, 45 

percent of the SFAs conducted a formal nutrition analysis of the planned menus, and 11 percent of 

the SFA directors did not know if planned menus were analyzed for their nutritional content. 

Although SFAs that use the NuMenus approach are required to conduct a formal nutrition analysis, 

only 72 percent of SFAs using this approach reported doing so. As expected, however, nutritional 

analysis was still conducted more often by SFAs that used the NuMenus approach (about 72 

percent) than by SFAs that used an FBMP approach (approximately 40 percent). In general, 

nutritional analysis of planned menus was conducted by a greater percentage of SFAs that were large 

or very large, in cities, and in high-poverty areas as compared to others. 

 Additionally, the percentage of SFAs conducting nutritional analyses of planned menus 

appears to be declining over time. The percentage of SFAs using the NuMenus approach that 

conducted nutritional analysis for planned menus in SY 2011-12 was lower (72 percent as shown in 

Table IV-5.2)) than in SY 2009-10 as reported in SNDA IV (97 percent). In addition, fewer SFAs 

using the traditional FBMP approach conducted nutritional analysis than in SNDA IV (40 percent 

versus 52 percent). 
105

Table IV-5.2. Percentage of SFAs that Conducted Nutrition Analysis of Planned Menus by SFA 

Characteristics and Type of Menu Planning System, SY 2011-12

SFA characteristics

Percentage of SFAs that conducted nutrition 

analysis of planned menus: Total SFAs

Yes No Don’t Know Weighted n Unweighted n

All SFAs 45.3% 43.6% 11.1% 14,617 1,3971

SFA size2

Small (1-999) 39.8 43.1 17.2 7,348 331

Medium (1,000-4,999) 46.4 47.1 6.4 5,355 533

Large (5,000-24,999) 60.1 38.9 1.0 1,629 364

Very Large (25,000+) 80.5 18.5 0.5 284 169

Urbanicity2

City 53.4 31.4 15.1 1,616 255

Suburban 44.8 49.3 5.9 2,876 379

Town 44.9 46.5 8.6 2,782 265

Rural 43.8 43.0 13.2 7,343 498

Poverty level2

Low (0-29% F/RP) 43.9 47.3 8.8 3,399 347

Medium (30%-59% F/RP) 43.3 46.2 10.5 6,816 649

High (60% or more F/RP) 49.5 36.7 13.8 4,403 401

Number of schools recognized as 

HealthierUS Schools

None 44.9 43.8 11.4 13,800 1,283

1-5 47.7 44.1 8.2 630 74

6 or more 66.4 30.7 3.0 186 40

Current SFA director is3

Licensed dietitian 57.5 41.0 1.5 14,205 1,373

School nutrition specialist 58.1 38.0 3.9 14,205 1,373

Type of menu planning system2

Food based

Traditional food-based only 39.9 49.2 10.8 8,744 815

Enhanced food-based only 39.7 50.5 9.7 1,707 174

Nutrient based

NuMenus only 71.6 20.8 7.6 1,804 220

Assisted NuMenus only 49.3 27.4 23.3 94 8

Other “reasonable” approach

New or innovative approaches only 72.8 20.5 6.7 49 8

Combination 51.7 34.4 14.0 1,917 156

Other 14.4 54.0 31.6 256 13

1

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs conducting nutrition analysis differed significantly by SFA size, urbanicity, poverty level, and menu planning system at the 

.05 level. 

3

 Significance testing does not apply because the categories are not mutually exclusive. An SFA director can be both a licensed dietitian and a 

school nutrition specialist. 

Data Source: SFA Director Survey 2011, questions 4.10, 4.13, and 11.7. 
106

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107

IV-6. Meal Counting and Claiming Procedures 

Background 

The fiscal integrity of the school meals programs is critically dependent on four factors: 

 Accurate determination of students’ eligibility for F/RP meals; 

 Accurate counting of the number of students in each income-eligibility category taking a 

reimbursable meal in each school within an SFA; 

 A system for accurately aggregating the meal counts from each school into a total for 

the SFA, and 

 Accurately using this information to complete an SFA’s monthly claim for 

reimbursement that is submitted to the state for payment. 

 Each of these factors is susceptible to a wide range of possible errors that result in erroneous 

payments. Indeed, because of the potential for a high level of erroneous payments, the NSLP and 

SBP are subject to the provisions of the Improper Payments Information Act of 2002, which 

requires USDA to provide Congress with annual estimates of the total and various types of 

erroneous payments in the school meals program.36 Previous research has estimated that household 

misreporting when certifying students’ eligibility for F/RP meals as opposed to administrative errors 

is by far the largest source of erroneous payments in the school meals programs. Additionally, noncertification errors (i.e., errors in reporting the number and type of meals served when preparing or 

submitting the SFA’s claim for reimbursement) are a relatively minor source of erroneous payments, 

especially for the NSLP. However, erroneous payments due to non-certification errors account for a 

higher percentage of reimbursements in the SBP, compared to the NSLP (USDA 2004, 2007). Noncertification errors are largely the result of cashier errors at the Point of Service (POS) and have 

been found to be concentrated among a relatively small number of schools with high levels of 

cashier errors (USDA, 2007).37

Cashiers at the POS are responsible for: 

 Determining if what is on a student’s tray constitutes a reimbursable meal (i.e., complies 

with FNS requirements); 

 Determining the reimbursement status (free, reduced-price, or paid) for each student 

who has taken what the cashier has determined to be a reimbursable meal (without 

overtly identifying students getting F/RP meals); 

 

36 USDA is required to report annually on the extent of erroneous payments in programs (including the NSLP and SBP) that may be 

susceptible to significant erroneous payments (exceeding $10 million and 2.5 percent of benefits paid out) and to report annually on 

the actions they are taking to reduce the erroneous payments. 

37 In general, a relatively small number of school cashiers account for a very high number of errors and erroneous (USDA, 2007). 
108

 Ensuring that only one reimbursable meal is recorded for each eligible student (if a 

student goes through the line a second time and takes a reimbursable meal, that the 

second meal taken is not included in the total count of reimbursable meals that is 

submitted for reimbursement); 

 Accurately recording and tabulating the total number of reimbursable meals taken in 

each of the three reimbursement categories; and 

 Accurately transmitting these counts to the SFA for inclusion in the SFA’s monthly 

claim for reimbursement. 

 The SFA is responsible for instituting an internal control system that checks for potential 

cashier errors and taking corrective action when a pattern of errors is detected. Examples of internal 

controls include checking to see if a student takes a reimbursable meal every day (regardless of 

attendance), checking that the total number of F/RP meals claimed on any given day does not 

exceed the total number of students approved for such meals (after applying an attendance factor), 

and checking that the total daily participation rates are not out of line with historical patterns. 

Research Questions 

 This chapter focuses on factors at the school level that may lead to erroneous payments. 

These factors include the types of technology used and the accuracy with which cashiers at the POS 

use these technologies. This chapter addresses three specific research questions: 

 What type of technology is being used at the POS to differentiate and record the number of students in 

each of the three income-eligibility categories that take reimbursable meals? 

 What type of training and oversight is provided to cashiers to ensure that reimbursable meals are 

properly distinguished from nonreimbursable food sales, and that the income-eligibility status of each 

reimbursable meal is accurately recorded and totals are accurately tabulated at each meal period? 

 What types of payments are accepted at the POS? 

Results 

Technology Used at the Point of Service 

 USDA does not specify the use of any particular system for meal counting at the POS. It 

recognizes that there is no “one size fits all” technology for meal counting. Rather, it recognizes that 

SFAs must consider the cost-effectiveness of the various types of available meal counting 

technologies and what is right for each of their schools. State administering agencies have materials 

available to help guide the choice of an SFA’s meal counting and claiming system. An SFA may use 

different systems in different schools. 

 As Table IV-6.1 shows, by far the most common technology used by SFAs in SY 2011-12 

was student personal identification numbers (PINs), which were used by 72 percent of SFAs in at 

least one of their schools. Swipe cards, which record information about a student’s reimbursement 
109

status when swiped through a card reader (much as ATM cards are used in the retail world), were 

used by 28 percent of SFAs. Student rosters, where a cashier checks off the names of students who 

take a reimbursable meal and later matches the names that were checked off with their 

reimbursement status, were used by 13 percent of SFAs in at least one of their schools. All other 

methods (tickets/tokens, biometric technology, and other systems) combined accounted for only 18 

percent of SFAs in at least one of their schools. Although the study did not address the question of 

why an SFA selected the particular technology used in each of its schools, those technologies that 

were more costly tended to be used less frequently. 

Table IV-6.1. Percentage of SFAs that Had at least one School that Used Certain Technologies 

to Capture Meal Counts at POS, SY 2011-12

Technology at POS Percent of SFAs that used the technology

Personal Identification Numbers (PINs) 71.6%

Swipe cards 27.8

Rosters or cashier lists 13.4

Tickets or tokens 6.8

Other 5.7

Biometric technology (e.g. fingerprint scanners) 5.5

Total SFAs: Weighted n 14,590

Total SFAs: Unweighted n 1,3941

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 9.1. 

 Regardless of how accurately a cashier records the reimbursement status of reimbursable 

meals taken, none of these methods addresses the accuracy with which a cashier identifies which 

trays contain a reimbursable meal and which do not. This is still a judgment call that cashiers must 

make very quickly based on a brief look at what is on each tray as students pass through the line. In 

a study of erroneous payments in the school meals program (USDA, 2007), it was found that cashier 

errors in identifying trays containing a reimbursable meal accounted for nearly half of all noncertification errors. This form of counting error is less amenable to the use of better (and more 

expensive) technology, but it can be addressed through better training of cashiers. 

Training and Monitoring of Cashiers 

 All SFAs provided at least some form of training to their cashiers at various times over the 

course of a school year. However, which training topics were offered and when they were offered 

varied across SFAs. Table IV-6.2 shows the percentage of SFAs that provided training on selected 

topics to their cashiers. More than 90 percent of SFAs provided some training to their cashiers on 

how to distinguish reimbursable meals from nonreimbursable meals as students pass through the 

point of service. Because training was not universal and frequency varied, it might explain, in part, 

why cashier misclassification of meals occurs. Previous studies show that misclassification on 

student’s trays represents about 10 percent of total reimbursements (USDA, 2007). Another factor 

that may affect misclassification is the quality of the training provided. 
110

Table IV-6.2. Percentage of SFAs that Provided Select Training to Cashiers, SY 2011-12

Training topic Percentage of SFAs that provided training

Method of counting meals 92.8%

Monitoring student meal selections to ensure reimbursability 92.0

Managing cash for à la carte and adult meal sales 80.4

Acceptable types of payments 86.3

Meal and food pricing 83.6

Offer vs. served 86.3

Applications for free or reduced-price meals 61.6

Operating a POS system 86.1

Other training topics 3.1

Total SFAs: Weighted n 14,567

Total SFAs: Unweighted n 1,3921

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 9.3. 

 Monitoring cashier performance is another key factor in determining non-certification 

errors. USDA provides guidance for states to review SFA performance (USDA, 2012). In addition, 

the program regulations stipulated that SFAs must conduct no fewer than one onsite review of the 

accuracy of meal counting procedures for each school in the SFA. The regulations further specify 

the types of acceptable edit checks such as “comparing the number of each school’s daily counts of 

free, reduced-price, and paid lunches against the product of the number of children in that school 

currently eligible for free, reduced-price, and paid lunches, respectively, times an attendance 

factor.”38 Despite this requirement, as shown in Figure IV-6.1, about 18 percent of all SFAs do not 

conduct such onsite reviews of the accuracy of each school’s meal counting procedures. At the other 

end of the spectrum, 34 percent of SFAs reported conducting three or more onsite monitoring visits 

of cashiers, and another 17 percent reported conducting two such monitoring visits to schools in SY 

2011-12.

 

38 64 Federal Register, 50740, Sept. 20, 1999. 
111

Figure IV-6.1. Percentage of SFAs that Conducted Onsite Monitoring of Cashiers, SY 2011-12

n is less than 1,401 due to item non-response. Responses based on a weighted n = 14,575 (unweighted n = 1,392). 

Data Source: SFA Director Survey 2011, questions 9.4 and 9.5. 

Types of Payment Accepted for School Meals 

 Not all SFAs accept cash payments for school meals at the POS as shown in Table IV-6.3. 

Even fewer SFAs accept credit or debit cards at the POS. In SY 2011-12, 80 percent of SFAs 

reported accepting cash payments for school meals, and only 18 percent reported accepting credit or 

debit cards at the POS. The most commonly accepted form of payment for school meals was 

prepayment by check or money order; 93 percent of SFAs accepted this form of payment in SY 

2011-12. Other forms of payment accepted include prepayment through the Internet (41 percent) 

and prepayment by mail, telephone, or fax (20 percent). 

Table IV-6.3. Percentage of SFAs that Accepted Different Payment Methods, SY 2011-12

Payment method Percent of SFAs that used the method

Personal check or money order 92.9%

Cash at POS 79.9

Payment via the Internet 41.4

Payment via phone, email, or fax 20.0

Credit or debit card 17.7

Other 4.8

Other cash 4.6

Total SFAs: Weighted n 14,581

Total SFAs: Unweighted n 1,3941

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 9.2

34.2%

17.2%

28.4%

1.8%

18.3%

Three or more times a year

Twice a year

Once a year

Less frequently than once a year

No onsite monitoring
112

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113

IV-7. Availability of Non-USDA Meal 

Alternatives 

Background 

 The school food environment encompasses foods and beverages available through the 

NSLP and the SBP; those sold at outlets such as à la carte, vending machines, snack bars, school 

stores, and fund raisers/bake sales; as well as those offered in-class (i.e., class parties). The foods 

offered outside of the NSLP and the SBP are generally referred to as competitive foods since they 

compete with the sale of reimbursable school meals. Besides offering competitive foods on campus, 

some schools and school districts may permit students to leave the school campus during the meal 

service to purchase foods elsewhere. 

 The current study examined the school nutrition operations during SY 2011-12 prior to 

when USDA updated the nutrition standards for both school meals (NSLP and SBP) and 

competitive foods.39 Only the sale of foods of minimal nutritional value (FMNV), i.e. those with less 

than 5 percent of the RDA for eight key nutrients, were prohibited from being sold in the food 

service areas during meal periods. A few examples of foods considered FMNV include soft drinks, 

water ices, chewing gum, and certain candies. Before passage of the HHFKA, the USDA did not 

have the authority to regulate all other competitive foods such as chips, cookies, ice cream, and fruit 

and sports drinks. However, several states and localities implemented policies to limit the sale of less 

healthy options by setting limits on certain nutrients such as fat, saturated fat, sugar, and/or calories 

for foods and beverages sold à la carte and in school stores and vending machines. 

 Moving forward in the next few years, Section 208 of the HHFKA, which directed USDA to 

establish science-based nutrition standards for foods and beverages sold in schools (throughout the 

school campus and the school day) outside of the school meals program, will affect the competitive 

foods available to students. In February 2013, USDA issued a proposed regulation specifying 

minimum standards for foods and beverages sold as competitive foods. The USDA proposal 

emphasizes foods to encourage, such as fruits, vegetables, whole grains and low-fat dairy products, 

and places limits on calories, saturated fat, sodium, and sugar. In addition, the regulation codified 

previously issued guidance on the need for schools to make available free drinking water during the 

lunch meal service. In June 2013, USDA issued the interim final regulation updating standards for 

competitive foods, and schools will have at least a year to fully implement the updated standards 

(National School Lunch Program and School Breakfast Program: Nutrition Standards for All Foods 

Sold in School as Required by the Healthy, Hunger-Free Kids Act of 2010). Until then, schools can 

continue to sell a range of competitive foods and beverages throughout the school campus. 

 

39 Competitive foods are items sold in the school during the meal service and compete with the sale of reimbursable meals. These 

foods are not credited as a component of a reimbursable meal; the revenue from these sales may be utilized by the food service, 

school, or approved student organization. http://www.fns.usda.gov/cnd/About/faqs.htm#Competitive Foods. 
114

Research Questions 

 This section focuses on answering the following research questions concerning competitive 

foods available to students and provides a baseline picture of the local practices before 

implementation of the new regulations stemming from the HHFKA. 

 What types of non-USDA meal alternatives (e.g., vending machines, à la carte, school stores, etc.) are 

available in SFAs? 

 Do SFAs make free potable water available where school lunches are served? 

Results 

Alternative Meal Practices 

 Competitive foods generate $2.3 billion in annual revenue, with the majority of the revenue 

generated from sales of à la carte offerings.40,41 The revenue generated from à la carte offerings were 

within the domain of the school food services department and were typically used within the food 

service program, whereas revenue from other venues like vending machines and school stores were 

more likely to accrue to non-school food service accounts and usually benefit the broader school 

programs and student activities.42

 At this time, and until full implementation of updated competitive foods standards related to 

HHFKA, school districts as well as schools will continue to decide the types of competitive foods 

available in the schools and when and where they are sold. Thus, considerable variability exists 

across schools related to the sale of competitive foods. While some schools placed significant limits 

on the types of competitive foods sold, and the frequency and location of sales, others placed few 

restrictions on their sale. 

 The SFA Director Survey requested information about the types of alternatives available in 

their schools. As seen in Figure IV-7.1, about 20 percent of the SFAs indicated that there were no 

alternatives to SBP and NSLP meals available in their schools; at the other end of the spectrum 16 

percent of the SFAs indicated at least four different types of alternatives were available to students. 

For purposes of this discussion, “types of alternatives” does not refer to the quantity of foods and 

beverages available but rather to the venue where the alternatives were sold such as à la carte, 

vending machines, or school stores. 

 

40 IOM, Nutrition Standards for Foods in Schools. Page 92. 

41 USDA, Food and Nutrition Service, School Lunch and Breakfast Cost Study-II, Final Report. CN-08-MCII, April 2008, page 6-1. 

www.fns.usda.gov/ORA/menu/published/CNP/FILES/MealCostStudy.pdf. 

42 IOM, Nutrition Standards for Foods in Schools. Page 95. 
115

Figure IV-7.1. Percentage of SFAs that Offered Alternatives to SBP and NSLP Meals, SY 

2011-12

Percentages based on a weighted response of 14,678 (unweighted 1,401). 

Data Source: SFA Director Survey 2011, question 4.3. 

 Table IV-7.1 shows the most common alternate meal option available to students was à la 

carte items at lunch, and the least common option was food items from school stores. Seventy-one 

percent of the SFAs reported having schools that provided students with the option to purchase à la 

carte foods at lunch,43 and 53 percent of the SFAs had schools that provided the option to purchase 

à la carte foods at breakfast. Vending machines were available in almost 30 percent of the SFAs, 

snack bars in 19 percent of the SFAs, and school stores in about 15 percent of the SFAs. The use of 

à la carte items increased with size of the SFA, with 54 percent of small SFAs using à la carte items 

during lunch compared to 92 percent of very large SFAs. A similar pattern is observed for à la carte 

items during breakfast. SFAs in high-poverty areas were least likely to use nearly every meal 

alternative (except “alternative food source”). Having HealthierUS schools and the type of kitchen 

facility did not reveal any significant differences in the availability of competitive foods. 

 

43 The estimate for schools offering à la carte items at lunch and at breakfast as well as the availability of vending machines for the 

current study is about 10 percentage points lower than the estimate from SNDA IV. The reason for this difference in a 1-year time 

frame is not clear and may be the result of question wording differences. 

20.1%

17.5%

29.3%

17.1% 10.4%

4.2%

1.5%

No alternative

1 alternative

2 alternatives

3 alternatives

4 alternatives

5 alternatives

6 alternatives
116

Table IV-7.1. Percentage of SFAs that Reported Meal Alternatives were Offered in their 

Schools by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that reported the following meal alternatives were 

offered in their schools: Total SFAs

À la carte items

Vending 

machines

Snack 

bars

School 

store

Alternate 

food source

Weighted

n

Unweighted

n

During 

breakfast

During 

lunch

All SFAs 53.2% 70.9% 29.4% 19.0% 15.4% 10.8% 14,678 1,401

SFA size1

Small (1-999) 35.8 53.6 13.4 7.0 4.2 10.5 7,374 332

Medium (1,000-4,999) 68.2 86.7 41.7 28.5 22.5 9.4 5,390 536

Large (5,000-24,999) 77.3 92.8 53.8 36.7 36.9 14.7 1,629 364

Very large (25,000+) 82.3 92.4 70.5 47.0 48.4 23.0 284 169

Urbanicity2

City 39.9 51.0 27.2 16.7 22.2 15.0 1,630 256

Suburban 62.9 82.9 47.6 34.1 24.3 12.7 2,885 380

Town 63.9 78.3 30.9 21.5 16.4 12.8 2,794 266

Rural 48.3 67.7 22.2 12.6 10.0 8.4 7,369 499

Poverty level3

Low (0-29% F/RP) 63.7 86.9 45.4 30.4 20.6 8.6 3,407 348

Medium (30%-59% F/RP) 60.3 77.5 29.5 17.0 14.7 11.8 6,828 650

High (60% or more F/RP) 34.2 48.3 16.9 13.2 12.6 11.0 4,443 403

Number of schools 

recognized as HealthierUS 

schools

None 52.9 70.7 28.6 19.1 15.3 10.7 13,862 1,287

1-5 59.1 74.9 42.4 17.8 18.0 11.9 630 74

6 or more 56.1 68.0 44.2 15.6 13.0 16.4 186 40

Type of kitchen

Onsite production only 53.6 71.4 27.5 15.8 12.1 9.0 7,895 640

Offsite production only 56.5 73.5 30.8 20.9 14.9 12.3 2,373 220

Combination or other 52.4 71.2 33.3 24.6 22.9 12.1 4,154 528

1

 Percentage of SFAs offering all types of meal alternatives in schools differed significantly by SFA size at the .05 level. 

2

 Percentage of SFAs offering all types of meal alternatives in schools with the exception of alternate food source differed significantly by 

urbanicity at the .05 level. 

3

 Percentage of SFAs offering all types of meal alternatives in schools with the exception of alternate food source differed significantly by 

poverty level at the .05 level. 

Data Source: SFA Director Survey 2011, questions 4.3, 4.19, 11.7, and 14.7. 

Comparison of State and SFA Nutrition Standards to Federal 

Requirements 

 The State Director Survey requested information about their state’s nutrition standards for 

school meals relative to Federal requirements. Similarly, the SFA Director Survey asked respondents 

about school district policies for school meals relative to the Federal rules. Table IV-7.2 shows the 

cross-tabulations between strictness of the states’ and SFAs’ school nutrition meal polices. The table 

shows that 8 percent of the SFAs operate under state and school district policies that are stricter 

than the Federal regulations. In contrast, 50 percent of the SFAs operate under state and local 

policies that are less strict than the Federal regulations. 
117

Table IV-7.2. Percentage of SFAs by the Strictness of their SFA and State Nutrition Standards 

Policies for School Meals, SY 2011-12

State nutrition policy on 

school meals

Percentage of SFAs that reported: Total SFAs

SFA policy on school meals 

stricter than Federal rules

SFA policy on school meals not 

stricter than Federal rules

Weighted 

n

Unweighted

n

1

All SFAs 33.1% 66.9% 13,763 1,344

State policy stricter than 

Federal rules

8.3 17.2 13,763 1,343

State policy not stricter 

than Federal rules

24.7 49.7 13,763 1,344

1

n is less than 1,401 due to item non-response. 

Data Source: State CN Director Survey 2011, question A1 and SFA Director Survey 2011, question 4.11a. 

Many states and school districts also have added regulations for competitive foods sold in 

the school as à la carte items or through vending machines. In the State CN Director Survey 2011, 

directors reported if they had a policy regarding à la carte and vending machine foods. Table IV-7.3 

shows that 59 percent of the SFAs are in states that had a policy on à la carte food, and 66 percent 

are in states that had a policy on foods sold in vending machines. Twenty-eight percent of SFAs also 

report that their local policies for foods sold as à la carte and vending machine items are stricter than 

the Federal rules. 

Table IV-7.3. Percentage of SFAs by whether their State had an À la carte or Vending 

Machines Policy and the Strictness of their Local Policies, SY 2011-12

Type of alternative food

Percentage of SFAs that reported: Total SFAs

State had policy

SFA had a policy that was stricter 

than Federal rules

Weighted 

n

Unweighted

n

1

À la carte foods 59.1% 28.0% 13,763 1,344

Vending machines 65.9 27.5 13,763 1,344

1

n is less than 1,401 due to item non-response. 

Data Source: State CN Director Survey 2011, questions A2b and A2e and SFA Director Survey 2011, questions 4.11b and 411c. 

Availability of Free Potable Water Where School Lunches Are Served 

 Almost all SFA directors responded that water was available to students during both 

breakfast and lunch. Specifically, 97 percent (not shown) of SFAs said water was available at 

elementary schools, 98 percent (not shown) reported it was available at both their middle and high 

schools, and 77 percent (not shown) reported it was provided at their other schools. Table IV-7.4 

shows that for those that provided water at breakfast and lunch, water fountains were the most 

frequently reported source of potable water (at least 88 percent of SFAs) followed by water in 

pitchers, jugs, and cups. A lower percentage of small SFAs than medium to very large SFAs 

indicated that water fountains and water in pitchers, jugs, or cups were available during breakfast 

and lunch. The availability of water in pitchers, jugs, or cups at breakfast and lunch increased with 

increase in SFA size. Bottled water was offered more often in high-poverty than low- or mediumpoverty SFA and in cities. High-poverty schools offer bottled water more frequently than others. 
118

Table IV-7.4. Among SFAs that Provide Free Drinking Water during Meals, the Percentage of 

SFAs that Had Various Sources of Water by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that had the following sources of drinking water: Total SFAs

Water 

fountains

Water in pitchers, 

jugs, or cups

Free bottled 

water Other

Weighted 

n

Unweighted 

n

Breakfast

All SFAs 87.7% 34.2% 2.6% 0.2% 14,178 1,3631

SFA size2

Small (1-999) 82.3 27.8 3.2 0.0 7,070 319

Medium (1,000-4,999) 92.9 36.2 2.2 0.4 5,223 521

Large (5,000-24,999) 93.7 51.2 1.5 0.3 1,611 359

Very Large (25,000+) 94.7 61.0 1.9 0.0 275 166

Urbanicity3

City 87.9 36.9 6.4 0.0 1,506 245

Suburban 92.4 30.1 0.7 0.0 2,777 371

Town 85.5 39.3 1.8 0.3 2,737 261

Rural 86.8 33.3 2.9 0.3 7,159 486

Poverty level4

Low (0-29% F/RP) 89.9 28.8 1.3 0.0 3,306 341

Medium (30%-59% F/RP) 88.7 35.5 1.7 0.1 6,612 633

High (60% or more F/RP) 84.5 36.5 5.1 0.5 4,261 389

Lunch

All SFAs 89.0 40.6 3.1 0.2 14,150 1,362

1

SFA size5

Small (1-999) 84.4 33.1 4.3 0.0 7,044 318

Medium (1,000-4,999) 93.8 43.8 2.0 0.4 5,220 521

Large (5,000-24,999) 92.5 57.6 2.0 0.3 1,611 359

Very Large (25,000+) 95.2 69.6 3.2 0.7 275 164

Urbanicity6

City 91.0 41.4 9.7 0.1 1,534 246

Suburban 95.6 32.6 1.7 0.0 2,746 370

Town 85.7 47.9 2.0 0.3 2,737 261

Rural 87.4 40.7 2.7 0.3 7,133 485

Poverty level7

Low (0-29% F/RP) 93.8 31.8 2.3 0.0 3,292 340

Medium (30%-59% F/RP) 88.8 42.4 1.8 0.1 6,646 635

High (60% or more F/RP) 85.7 44.5 5.9 0.6 4,213 387

1

n is less than the 1,386 SFAs that reported providing potable water due to item non-response. 

2

 Percentage of SFAs using water fountains and water in pitchers, jugs, or cups for breakfast differed significantly by SFA size at the .05 level. 

3

 Percentage of SFAs using free bottled water for breakfast differed significantly by urbanicity at the .05 level. 

4

 Percentage of SFAs using free bottled water for breakfast differed significantly by poverty level at the .05 level. 

5

 Percentage of SFAs using water fountains and water in pitchers, jugs, or cups for lunch differed significantly by SFA size at the .05 level. 

6

 Percentage of SFAs using all sources of drinking water with the exception of other for lunch differed significantly by urbanicity at the .05 level. 

7

 Percentage of SFAs using all sources of drinking water with the exception of other for lunch differed significantly by poverty level at the .05 

level. 

Data Source: SFA Director Survey 2011, questions 4.17 and 4.18. 
119

Policies and Practices for Serving Meals to Students Who Are Unable 

to Pay 

 Schools vary in their policies for serving meals to students who are not approved for free 

meals and are not able to pay for meals. School policies range from denying a meal to serving a 

reimbursable or alternate meal to students for a limited number of days. In most schools, students 

who are unable to pay get one free lunch in a week; if they are unable to pay in the second week, 

they get an alternate or courtesy meal. In SY 2011-12, 47 percent of the SFAs reported they served a 

reimbursable meal to students who were unable to pay for a meal, and 39 percent served an alternate 

meal as shown in Table IV-7.5). Only 3 percent of the SFAs indicate that they did not serve a meal 

to students who were unable to pay; 6 percent took other action such as serving only students in 

elementary schools that were unable to pay but not those in middle or high school, or school faculty 

paying for a student, or borrowing from PTA funds. In general, SFA characteristics were not related 

to actions taken when a student was unable to pay for a school meal. Very large SFAs were less likely 

to serve reimbursable meals and more likely to take “other” action. 
120

Table IV-7.5. Percentage of SFAs that Take Various Actions When a Student, Not Approved 

for Free Meals, Does Not Have the Money to Pay by SFA Characteristics, SY 

2011-12

SFA characteristics

Percentage of SFAs that take the following actions: Total SFAs

Serve 

reimbursable 

meal

Serve 

alternate 

meal

Do not 

serve 

any meal Other

Serve 

reimbursable 

meal initially, 

then serve 

alternate meal

Weighted 

n

Unweighted 

n

All SFAs 47.3% 38.9% 2.5% 6.2% 5.1% 13,865 1,3461

SFA size2

Small (1-999) 48.2 36.9 3.6 6.6 4.7 6,777 305

Medium (1,000-4,999) 48.0 41.2 1.7 4.4 4.6 5,211 519

Large (5,000-24,999) 44.7 39.1 0.4 8.4 7.4 1,598 356

Very Large (25,000+) 27.4 41.5 2.4 15.7 13.1 279 166

Urbanicity 

City 42.9 35.1 3.9 10.1 8.0 1,457 245

Suburban 50.1 38.7 1.7 6.0 3.5 2,818 373

Town 41.0 42.5 3.5 4.9 8.0 2,598 252

Rural 49.4 38.4 2.2 5.9 4.1 6,991 476

Poverty level 

Low (0-29% F/RP) 51.8 35.7 2.2 5.5 4.7 3,326 343

Medium (30%-59% F/RP) 44.6 41.5 2.9 5.8 5.1 6,697 640

High (60% or more F/RP) 48.0 37.0 2.0 7.4 5.6 3,842 363

State level policy to serve 

meals to children without 

funds 

Have policy 50.4 33.0 3.0 8.0 5.6 2,619 293

No policy but standard 

practice

43.5 41.6 2.5 5.8 6.5 4,045 376

No policy or standard 

practice

48.3 39.5 2.3 5.7 4.2 7,198 676

1

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs taking action when a student cannot pay and is not approved for free meals differed significantly by SFA size at the .05 

level. 

Data Source: State CN Director Survey 2011, question A3 and SFA Director Survey 2011, question 8.1. 
121

Section V: SFA Financials 

SFAs produce reimbursable school meals, for which they receive government subsidization, 

as well as a variety of nonreimbursable food items (also referred to as competitive foods). An SFA’s 

operating costs include not only the cost of producing reimbursable meals but also the cost of 

individual food items that school staff may purchase or students may buy instead of, or in addition 

to, reimbursable meals. In many ways, an SFA may be viewed as a nonprofit business that produces 

several different products and that must set the prices for each of its different products so that at the 

end of the year it breaks even (revenue equals cost). 

SFAs operate within the policy and regulatory boundaries that are set by the Federal 

government, their states, and their LEA. Four facts dictate SFAs’ financial operations:

 SFAs must operate on a nonprofit basis. 

 They are reimbursed for NSLP and SBP meals at rates set by the Federal government. 

 The maximum price they can charge for reduced-price meals is set by Federal 

regulations. 

 The price they can charge for a paid reimbursable meal is set (or approved) by their 

LEA. 

In addition to the standard economic relationships, this structure dictates a strong 

correlation between price and reimbursement rates and reimbursement rates and cost. Furthermore, 

to operate on a nonprofit basis, revenues (price * quantity “sold”) must equal costs, although there 

may be small deviations from this in any given year. 

Although SFAs operate under common rules, there is variation in price, revenue, cost, and 

break-even status. In this section, we examine the relationships between each of these financial 

components and how they vary by SFA characteristics such as size, urbanicity, and poverty levels 

and the food production processes they use. 
122

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123

V-1. Meal Prices 

Background 

The prices SFAs charge for the foods they serve are heavily regulated and tied to Federal 

reimbursement rates for school meals. This chapter examined the pricing patterns of SFAs in terms 

of their relationship to the reimbursement rates and how they vary among SFAs and over time. In 

assessing how prices have changed over time, we consider the potential impact economic factors 

and new policy changes may be having as well as how the new policy changes are likely to affect 

pricing in the future. 

Reimbursement Rates 

During SY 2011-12, students from households with an income at or below 130 percent of 

the Federal poverty guidelines were eligible to receive nutritious school meals free of any charges; 

children from households with an income between 131 and 185 percent of the Federal poverty level 

(FPL) were eligible to receive the school lunch for a price not to exceed 40 cents and breakfasts not 

to exceed 30 cents. All other students were required to pay the price established by their LEA for a 

full school meal or alternative food item they choose to purchase. The USDA reimburses SFAs 

based on the number of full meals served within each income-eligibility category. Table V-1.1 

presents the base reimbursement rates for SY 2009-10, SY 2010-11, and SY 2011-12 for the 

continental United States.44

Table V-1.1. Reimbursement Rates for the NSLP and SBP, SY 2009-10 to SY 2011-12

Income-eligibility 

category

SY 2009-10 reimbursement 

rates

SY 2010-11 reimbursement 

rates

SY 2011-12 reimbursement 

rates

Breakfast Lunch Breakfast Lunch Breakfast Lunch

Free $1.46 $2.68 $1.48 $2.72 $1.51 $2.77

Reduced-price 1.16 2.28 1.18 2.32 1.21 2.37

Paid 0.26 0.25 0.26 0.26 0.27 0.26

The Potential for Cross-Subsidization and the New HHFKA Provisions 

Previous analyses of production costs (School Lunch and Breakfast Cost Study (SLBCS)-I 

and -II, USDA 1994 and 2008) revealed that, for the average SFA, reimbursable lunches generated 

substantial surplus revenues. The SLBCSs showed that when an SFA’s indirect and overhead costs 

were properly allocated across the various foods produced, the reimbursement rate for lunches was 

greater than the cost of producing the meal. The surplus revenues generated by reimbursable 

 

44 Higher reimbursement rates are provided for Hawaii and Alaska and for SFAs serving a high proportion of school meals to 

children in the F/RP income-eligibility categories. The complete reimbursement structure is available at 

http://www.fns.usda.gov/cnd/governance/notices/naps/naps.htm.
124

lunches were used by SFAs to offset the deficits being generated by reimbursable breakfasts and 

nonreimbursable food items. Although on average SFAs were operating at a break-even level in SY 

2005-06, revenues from reimbursable lunches exceeded the cost of producing these lunches by 16 

percent, while revenues from reimbursable breakfasts fell short of the cost of producing breakfasts 

by 4 percent, and revenues from the sale of nonreimbursable food items fell short of their costs by 

29 percent (SLBCS-II, 2008). 

As a result of this research, a number of changes to meal pricing and accounting procedures 

were included in several of the provisions of the HHFKA2 and will, over time, have a profound 

impact on the pricing structure, particularly in some SFAs. 

 The Paid Meal Equity Provision, which went into effect on July 1, 2011, requires SFAs to 

provide the same level of financial support for lunches sold to students who have not been 

approved for F/RP meals as that provided to students who must pay full price. This 

provision is intended to reduce, or eliminate, the implicit subsidization of paid school 

lunches with revenues derived from Federal reimbursements for F/RP lunches. The 

regulation requires SFAs to either set the average price of a paid school lunch at no less than 

the difference between the reimbursement rate for free and paid meals or make up for the 

revenues lost to the SFA through the “underpricing” of paid lunches with funds from nonFederal sources. 

For SFAs that increase the prices of paid lunches, the annual rate of increase is to be 2 

percent plus the rate of inflation until the price equity is achieved. The provision allows 

SFAs to round down the required price increase to the nearest 5 cents for SY 2011-12. The 

maximum that an SFA is required to increase prices in any given year is 10 cents. This allows 

SFAs to raise prices gradually over the course of several years to minimize the impact. 

However, an SFA can chose to raise prices by more than 10 cents in a given year, and such 

increases will count toward meeting the next year’s requirements. 

 The Nonprogram Food Sale provision requires SFAs to set the prices of competitive foods 

basically at levels no less than the cost of these foods. This provision is intended to reduce, 

or eliminate, the implicit subsidization of nonreimbursable foods sold in schools and 

charged to the food service account (i.e., competitive foods) with revenues derived from 

Federal reimbursements for F/RP lunches. The regulations now require SFAs to set the 

prices of competitive foods such that the revenue generated from the sale of such foods is 

no less than the cost of these foods.45

Research Questions 

The research questions for this chapter focus on the prices charged by SFAs for SY 2011-12 

and how these prices changed over a 3-year period ending in SY 2011-12.

 

45 “National School Lunch Program: School Food Service Account Revenue Amendments Related to the Healthy, Hunger-Free Kids 

Act of 2010,” 76 Federal Register 117 (June 17, 2011), p. 35301. Available at 

http://www.fns.usda.gov/cnd/governance/regulations/2011-06-17.pdfRevenue
125

 What were the average prices charged for reduced-price and paid breakfasts and lunches in SY 2011-

12? How do they relate to reimbursement rates? Do average prices vary across different types of SFAs? 

 How have meal prices changed over the past 3 years? What is the pattern of price changes across 

different types of SFAs? 

 What factors influence LEAs’ decisions about meal pricing? What actions do SFAs take to avoid 

having to increase meal prices? What actions do SFAs take to minimize the effects of price increases on 

NSLP and SBP participation? 

The answers to these questions take on additional importance when juxtaposed with the pricing 

provisions included in the HHFKA. 

Results 

Meal Prices from SY 2009-10 to SY 2011-12

Table V-1.2 presents the average prices charged for full-price, paid breakfasts, and paid 

lunches from SY 2009-10 through SY 2011-12.46 On average, SFAs (specifically their LEAs) charged 

considerably more for paid meals purchased by secondary school students than by elementary 

school students. The price differentials between elementary and secondary schools for paid student 

meals were evident across all types of SFAs. While the magnitude of these price differentials varies 

somewhat, differentials were seen across SFAs of various sizes, urbanicity, and poverty levels. For 

example, during SY 2011-12, the average price for a paid breakfast was about 6 to 7 percent higher 

in secondary schools than in elementary schools. Lunch prices showed the same pattern. In SY 

2011-12, the average price for a paid lunch in secondary schools was about 11 percent higher than in 

elementary schools. This may reflect the differences in portion sizes, and hence food costs, between 

elementary and secondary schools. 

Impetus for the Paid Meal Equity Provision 

Table V-1.2 also reveals that before implementing the Paid Meal Equity Provision in July 

2011, SFAs set the price of paid lunches at levels below the difference between the free and paid 

meal Federal reimbursement rates (calculated as the free lunch reimbursement rate minus the paid 

lunch reimbursement rate which was $2.43, $2.46, and $2.51 respectively in SY 2009-10, SY 2010-

11, and SY 2011-12). The historical pricing pattern resulted in SFAs earning different revenue 

amounts for F/RP lunches versus paid reimbursable lunches.47

 

46 The weighted and unweighted numbers of SFAs with data on meal prices by grade level and school year are shown in Appendix 

Tables E-2, E-4, E-6, E-17, E-19, and E-21.

47 FNS regulations place a cap of 30 cents on the price that SFAs can charge for reduced-price breakfasts and a cap of 40 cents on the 

price of reduced-price lunches. Virtually all SFAs charge the maximum permitted by these price caps. 
126

Table V-1.2. Average Price Charged by SFAs for a Paid Student Breakfast and Lunch, SY 2009-10 to SY 2011-12

SFA characteristics

Average price charged by SFAs by school grade level and year (Weighted and unweighted n shown in Appendix E)

Elementary Middle High Other

‘09/10 ‘10/11 ‘11/12 ‘09/10 ‘10/11 ‘11/12 ‘09/10 ‘10/11 ‘11/12 ‘09/10 ‘10/11 ‘11/12

Breakfast

All SFAs $1.13 $1.15 $1.19 $1.21 $1.23 $1.26 $1.21 $1.24 $1.27 $1.13 $1.18 $1.23

SFA size1

Small (1-999) 1.12 1.14 1.17 1.20 1.23 1.24 1.17 1.20 1.22 1.09 1.18 1.24

Medium (1,000-4,999) 1.15 1.17 1.21 1.21 1.23 1.27 1.24 1.25 1.30 1.18 1.20 1.26

Large (5,000-24,999) 1.12 1.14 1.17 1.21 1.24 1.26 1.24 1.26 1.28 1.13 1.16 1.17

Very large (25,000+) 1.10 1.13 1.16 1.19 1.23 1.25 1.21 1.24 1.27 1.15 1.18 1.21

Urbanicity2

City 1.24 1.23 1.31 1.26 1.27 1.29 1.27 1.29 1.32 1.15 1.40 1.46

Suburban 1.16 1.21 1.23 1.27 1.31 1.32 1.34 1.39 1.41 1.20 1.24 1.26

Town 1.16 1.18 1.21 1.20 1.21 1.25 1.21 1.22 1.26 1.16 1.18 1.24

Rural 1.09 1.11 1.14 1.18 1.20 1.23 1.16 1.17 1.21 1.09 1.12 1.16

Poverty level3

Low (0-29% F/RP) 1.21 1.26 1.28 1.32 1.36 1.38 1.35 1.39 1.42 1.29 1.50 1.52

Medium (30%-59% F/RP) 1.13 1.15 1.19 1.21 1.23 1.27 1.20 1.23 1.26 1.12 1.14 1.20

High (60% or higher F/RP) 1.07 1.07 1.10 1.12 1.12 1.13 1.11 1.12 1.13 1.07 1.09 1.11

Lunch

All SFAs $1.89 $1.92 $2.00 $2.10 $2.14 $2.21 $2.11 $2.14 $2.21 $2.01 $2.06 $2.15

SFA size4

Small (1-999) 1.85 1.89 1.96 2.04 2.08 2.14 2.00 2.03 2.09 2.01 2.11 2.20

Medium (1,000-4,999) 1.92 1.94 2.02 2.14 2.16 2.25 2.17 2.20 2.29 1.99 2.02 2.11

Large (5,000-24,999) 1.93 1.96 2.03 2.15 2.18 2.25 2.20 2.23 2.31 2.01 2.04 2.13

Very large (25,000+) 1.87 1.90 1.96 2.12 2.14 2.21 2.16 2.19 2.25 2.07 2.10 2.17

Urbanicity5

City 2.12 2.17 2.22 2.24 2.27 2.29 2.26 2.30 2.34 2.05 2.33 2.41

Suburban 2.09 2.13 2.21 2.33 2.36 2.44 2.38 2.42 2.51 2.26 2.30 2.40

Town 1.87 1.88 1.96 2.07 2.08 2.15 2.13 2.14 2.21 2.01 2.03 2.13

Rural 1.78 1.80 1.88 1.99 2.03 2.12 1.98 2.00 2.08 1.90 1.92 2.01

Poverty level5

Low (0-29% F/RP) 2.11 2.15 2.22 2.34 2.38 2.48 2.34 2.38 2.45 2.14 2.28 2.37

Medium (30%-59% F/RP) 1.88 1.90 1.98 2.09 2.12 2.19 2.10 2.13 2.20 2.01 2.04 2.13

High (60% or higher F/RP) 1.71 1.73 1.81 1.90 1.91 1.97 1.91 1.93 2.01 1.92 1.94 2.02

1

The average price charged for breakfast in other schools in ’11/12 differed significantly by SFA size at the .05 level. 

2

The average price charged for breakfast in elementary, middle, and high schools in ’09/10 and in all schools in ’10/11 and ’11/12 differed significantly by urbanicity at the .05 level.

3

The average price charged for breakfast in all schools in ’09/10, ’10-/1, and ’11/12 differed significantly by poverty level at the .05 level.

4

The average price charged for lunch in middle and high schools in ’09/10, in high schools in ’10/11, and in middle and high schools in ’11/12 differed significantly by SFA size at the .05 level. 

5

The average price charged for lunch in all schools in ’09/10, ’10-/1, and ’11/12 differed significantly by urbanicity and by poverty level at the .05 level.

Data Source: SFA Director Survey 2011, questions 5.1, 5.2a, 5.2b.,5.4, 5.5a, and 5.5b. 
127

Table V-1.3 shows that in the year just before the implementation of the Paid Meal Equity 

Provision (SY 2010-11), prices were such that SFAs typically got about the same per unit revenues 

on free and paid breakfasts but received more on free lunches as compared to paid lunches. For 

every paid breakfast provided, SFAs on average charged between $1.15 and $1.24 and received a 

reimbursement of $0.26 per meal for total revenue per breakfast of $1.41 to $1.50. For free 

breakfasts, they received the reimbursement rate of $1.48. Thus, the total revenue per paid breakfast 

was highly similar to the free breakfast reimbursement rate, resulting in basically equal per-meal 

revenues across the reimbursement eligibility categories. In contrast, for every paid lunch provided 

in SY 2010-11, SFAs on average charged between $1.91 and $2.14 and received a reimbursement of 

$0.26 per meal for total revenue per lunch of $2.18 to $2.40, which was substantially below the $2.72 

reimbursement rate they receive for a free lunch. This pattern of SFAs earning more revenue per 

meal on free lunches than on paid lunches was partly the impetus for the Paid Meal Equity 

Provision. 

Table V-1.3. SFA’s Average Meal Prices, Reimbursement Rates, and Revenues per Meal for 

the NSLP and SBP by Grade Level, SY 2010-11

SFA’s average meal prices, reimbursement rates, and revenues per 

meal

Elementary Middle High

Breakfast

Paid meal price $1.15 $1.23 $1.24

Paid meal reimbursement rate 0.26 0.26 0.26

Paid meal revenues 1.41 1.49 1.50

Free meal reimbursement rate and revenues 1.48 1.48 1.48

Difference in revenue -0.07 0.01 -0.02

Weighted n

1

9,792 7,437 8,813

Lunch

Paid meal price $1.92 $2.14 $2.14

Paid meal reimbursement rate 0.26 0.26 0.26

Paid meal revenues 2.18 2.40 2.40

Free meal reimbursement rate and revenues 2.72 2.72 2.72

Difference in revenue -0.54 -0.32 -0.32

Weighted n

1

11,763 8,888 10,314

1

n is less than 14,687 because not all SFAs participate in the SBP or have each type of school and item non-response. 

Based on the prices charged for a paid meal in SY 2010-11, SFAs were going to have to raise 

average paid lunch prices by about 30 to 50 cents over time or provide offsetting non-Federal 

subsidies. SFAs could continue to charge different prices across grade levels so long as the average 

price of paid claimed meal was brought in line with the difference in the reimbursement rates. As 

this study did not collect data on meals claimed, we cannot precisely estimate the number of SFAs 

expected to be affected by the price changes. However, the SY 2010-11 price data suggested that the 

majority of SFAs were going to be affected by the Paid Meal Equity Provision because over 90 

percent of SFAs had paid lunch prices in elementary schools that were below the target price (which 

was $2.46), and over 80 percent had paid lunch prices in middle and high schools that were below 

the target price (see Appendix Tables E-4, E-6, and E-8). 
128

Effect of Paid Meal Equity Provision 

Beginning in SY 2011-12, SFAs that were not in compliance with the Paid Meal Equity 

Provision were required to either begin increasing paid lunch prices or provide additional nonFederal funds to offset their low prices. As Table V-1.4 shows, the majority of SFAs raised prices 

after the implementation of the Paid Meal Equity Provision, and the typical increase was 10 cents. 

As expected, a higher percentage of SFAs increased paid lunch prices in SY 2011-12 as compared to 

SY 2010-11. For example, in elementary schools, only 16 percent of SFAs raised prices for 

SY 2010-11, whereas 55 percent raised prices for SY 2011-12. A similar pattern was observed for 

middle, high, and other schools. The required annual price rise is capped at 10 cents, and Table V1.4 shows that the modal (or most frequent) price increase was 10 cents. However, the average price 

increases were higher, ranging from $.14 to $.17 across grade levels, indicating that some SFAs 

chose to raise prices more than the required amount. Although not subject to Paid Lunch Equity 

Provision, a higher percentage of SFAs also increased breakfast prices in SY2011-12 as compared to 

SY 2010-11. However, far fewer SFAs increased breakfast prices in SY 2011-12 than increased lunch 

prices. 
129

Table V-1.4. Price Increases for Paid Student Breakfasts and Lunches, SY 2009-10 to SY 2011-12

‘09/10 to ‘10/11 (Year 1 to Year 2) ’10/11 to ‘11/12 (Year 2 to Year 3)

Elementary Middle High Other Elementary Middle High Other

Lunch

Percentage of SFAs that 

increased prices1

15.5% 16.6% 16.1% 15.9% 55.2% 55.4% 55.9% 55.1%

Mean increase2$.19 $.17 $.18 $.33 $.14 $.14 $.14 $.17

Median increase2.15 .15 .15 .25 .10 .10 .10 .10

Modal increase2.25 .25 .25 .25 .10 .10 .10 .10

Breakfast

Percent of SFAs that increased 

prices1

12.3% 12.9% 12.9% 13.5% 26.2% 25.8% 24.8% 29.2%

Mean increase2$.16 $.15 $.17 $.36 $.15 $.14 $.15 $.17

Median increase2.10 .10 .10 .15 .10 .10 .10 .10

Modal increase2.25 .25 .25 .25 .05 .05 .05 .25

Data Source: SFA Director Survey 2011, questions 5.4, 5.5a, 5.5b, 5.1, 5.2b, 5.4, and 5.4b. 

1 Based on SFAs that provided price data in a given pair of years. 

2 Based on SFAs that increased prices. 
130

If an SFA increases paid lunch prices under the Provision, it is up to the SFA to decide how 

to distribute the price increases to meet the requirements. An SFA may choose to increase prices 

across all grade levels, or to increase prices only for some grade levels but not for others (e.g., 

increase prices for middle and high schools but not elementary schools). Table V-1.5 shows the 

percentage of SFAs that followed the same price increase behavior for elementary, middle, and high 

schools, versus those that increased prices for some grade levels but not for others. SFA pricing 

behavior is consistent across grade levels. That is, whether an SFA decides to raise prices or not, the 

majority of SFAs (91 percent) apply the direction of the increases consistently across all grade levels. 

The table shows the details of price changes for SFAs where all grade levels followed the same 

pattern. The most common pattern was to increase prices only once in elementary, middle, and high 

schools from SY 2010-11 to SY 2011-12 (44 percent of SFAs). Despite the large percentage of SFAs 

increasing prices in the second period, 34 percent of SFAs did not raise prices in elementary, middle, 

or high schools in either year. Only 9 percent of SFAs applied price increases differently across 

elementary, middle, and high schools, increasing prices for some grades levels but not for others. 

Price increases for breakfast followed a similar pattern, with SFAs applying the same decisions about 

the direction of changes across all grade levels. 

Table V-1.5. Patterns of Price Change in the NSLP and SBP across Two Periods: SY 2009-10 

to SY 2010-11 and SY 2010-11 to SY 2011-12

Type of price change Lunch Breakfast

Elementary, middle, and high schools follow the 

same price increase behavior

91.2 97.5

No increase in either of 2 years 33.7 64.3

Increase in 1 of 2 years 48.3 29.0

SY 2009-10 to SY 2010-11 4.8 7.9

SY 2010-11 to SY 2011-12 43.5 21.1

Increase in both years 9.2 4.2

Elementary, middle, and high schools do not

follow the same price increase behavior

8.8 2.5

Total SFAs: Weighted n 8,050 6,381

Total SFA: Unweighted n

1

987 791

1

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4, 5.5a, 5.5b, 5.1, 5.2b, 5.4, and 5.4b. 

Table V-1.6 shows the impact that price increases under the Paid Meal Equity Provision in 

SY 2011-12 have had on closing the gap between the revenue generated by free and paid lunches. 

The price increases in the first year under the provision have already reduced the price gap by 6 

percent. For example, looking at elementary schools in SY 2010-11, on average, SFAs generated 54 

cents more revenue from free lunches than from paid lunches. In SY 2011-12, average revenue from 

free lunches was 51 cents greater than from paid lunches—a decrease in the price gap of 6 percent. 

Similar reductions in the gap were observed for middle and high schools. 
131

Table V-1.6. SFAs’ Average Difference in Revenues per Meal, SY 2010-11 versus SY 2011-12

SFA’s average difference in revenue per meal, SY 2010-11 versus SY 

2011-12

Elementary Middle High

Difference in revenue in 2010-11 0.54 0.32 0.32

Difference in revenue in 2011-12 0.51 0.30 0.30

Percent gap has been narrowed 5.6% 6.3% 6.3%

Weighted n

1

2010-11 11,794 8,808 10,349

Weighted n

1

2011-12 11,763 8,888 10,314

1

n is less than 14,678 because not all SFAs have each type of school and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4, 5.5a, 5.5b. 

Adult Meal Prices 

In addition to students,school meals are available to teachers and other adults in the school. 

However, program regulations specify that Federal subsidies (both cash reimbursements and USDA 

Foods received) may not be used for the benefit of adults. As such, the regulations require that the 

price charged for a school meal served to adults may be no less than the cost of producing those 

meals. Because it is extremely difficult for an SFA to determine the actual cost of producing 

individual school breakfasts and lunches, the National Food Service Management Institute 

(NFSMI), funded by USDA, has provided SFAs with guidance for pricing adult meals. 

 Adult lunches: The minimum price charged for an adult lunch is equal to the 

reimbursement rate for free lunches plus the value of entitlement commodities48

(approximately $0.20/school lunch in SY 2011-12). This formula produces a minimum 

price for adult lunches of $2.97 plus any applicable sales tax. 

 Adult breakfasts: The minimum price charged for an adult breakfast is equal to the 

reimbursement rate for a free breakfast plus any applicable sales tax, or $1.51 during SY 

2011-12.

Table V-1.7 presents a comparison of the average price of adult meals and the minimum 

price derived from the NFSMI guidance. On average, in SY 2011-12, SFAs charged adults about 13 

to 15 percent more than the recommended minimum for a school breakfast and charged 3 to 4 

percent more than the minimum for a school lunch. These results suggest that many SFAs follow 

the guidance when charging for adult meals. 

 

48 As commodities are allocated based on reimbursable lunches, their value is included in the adult lunch price formula but not in the 

adult breakfast price formula. 
132

Table V-1.7. Comparison of the Average Price Charged by SFAs for Adult Meals to the 

Minimum Price Guidance by Grade Level, SY 2011-12 

Meal

Average Price Charged by SFAs by School Grade Level 

Elementary Wgt n (Unwgt)1 Middle Wgt n (Unwgt)1High Wgt n (Unwgt)1

Breakfast

Adult $1.71 10418 (1105) $1.74 7736 (934) $1.74 9075 (1020)

Minimum price $1.51 -- $1.51 -- $1.51 --

Percent difference +13.2% +15.2% +15.2%

Lunch

Adult $3.05 12004 (1228) $3.09 9076 (1053) $3.07 10365 (1129)

Minimum price $2.97 -- $2.97 -- $2.97 --

Percent difference +2.7% +4.0% +3.4%

1

n is less than 1,401 because not all SFAs have each type of school and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.4. 

Factors that May Have Influenced Meal Pricing Decisions 

In addition to the Paid Meal Equity Provision, there are several other factors that likely 

contributed to the variation in school meal prices. First, nutritional requirements and portion sizes 

vary by grade, which likely resulted in cost differences between elementary and secondary school 

meals. Second, both inflation and the recent recession likely influenced meal pricing decisions over 

time. Finally, other HHFKA provisions that have not yet been implemented may also be affecting 

pricing as SFAs get ready for these anticipated changes. 

Nutritional Requirements by Grade 

Although USDA has since issued guidance lifting the weekly limits on servings of meats and 

grains,49 at the time of the survey the nutritional requirements and portion sizes for school meals 

were higher for secondary grades than elementary grades. Table V-1.8 shows the NSLP minimum 

nutrient and calorie requirements for secondary schools as compared to elementary schools under 

the Nutrient Standard Menu Planning approach that SFAs used during SY2009-10 to SY 2011-12 

(which is before the new regulations stemming from the HHFKA were implemented). The 

differences in portion sizes required under the Traditional Food-Based Menu Planning system are 

more complex, varying not only by grade level but also by food components and food items. For 

example, in the meat or meat alternate category, the requirement may be met by serving the 

following amounts of lean meat, poultry or fish (or alternate protein products or cheese): for grades 

K-3, 11⁄2 ounces; for grades 4-12, 2 ounces; with SFAs having an option to serve larger portions (3 

ounces) for grades 7-12.50 These higher nutritional requirements for the upper grades increase the 

cost of the food and contribute to the tiered pricing strategy typically used in which secondary 

school meal prices are higher than elementary school prices. 

 

49 SP 26-2013, Extending Flexibility in the Meat/Meat Alternate and Grains Maximums for School Year 2013-14, 

http://www.fns.usda.gov/cnd/governance/regulations/7cfr210_09.pdf

50 See www.fns.usda.gov/cnd/menu/menu_planning.doc).
133

Table V-1.8. NSLP Minimum Nutrient and Calorie Requirements: Nutrient Standard Menu 

Approaches (School Week Averages) 

Nutrients and energy allowances

Minimum requirements Optional

Grades K-6 Grades 7-12 Grades K-3

Energy allowances (calories) 664 825 633

Total fat (as a percentage of actual total food energy) a, b b a, b

Saturated fat (as a percentage of actual total food energy) a, c c a, c

RDA for protein (g) 10 16 9

RDA for calcium (mg) 286 400 267

RDA for iron (mg) 3.5 4.5 3.3

RDA for vitamin A (RE) 224 300 200

RDA for vitamin C (mg) 15 18 15

a The Dietary Guidelines recommend that after 2 years of age “children should gradually adopt a diet that, by about 5 years of age, contains no 

more than 30 percent of calories from fat.”

b

 Not to exceed 30 percent over a school week. 

c

 Less than 10 percent over a school week. 

Source: Menu Planning in the National School Lunch Program, available at www.fns.usda.gov/cnd/menu/menu planning.doc . 

Inflation 

Inflation likely contributed to the price changes over time. The National School Lunch Act 

requires FNS to adjust the NSLP and SBP reimbursement rates to reflect changes in the “food away 

from home” series of the Consumer Price Index for All Urban Consumers (CPI-U). As shown in 

Table V-1.9, recent increases have been quite modest with prices, and therefore the reimbursement 

rates, rising by 1.5 percent between SY 2009-10 and SY 2010-11 and by about 2 percent between SY 

2010-11 and SY 2012.51 In SY 2010-11, SFAs raised prices for paid meals on average less than 2 

percent, or about equal to inflation. In SY 2011-12, prices increased at a rate greater than inflation. 

On average, SFAs increased prices 3 to 4 percent or about 1 or 2 percent more than inflation. 

Although this recent rise in lunch prices above inflation is likely due in part to the Paid Meal Equity 

Provision, breakfast prices also rose more than inflation between SY 2010-11 and SY 2011-12. Both 

the recent recession and other HHFKA policy changes may be affecting meal pricing decisions. 

 

51 Reimbursement rates for reduced-price breakfasts are set at 30 cents below the free rate. Similarly, the reduced-price lunch rate is 

set at 40 cents below the free rate. SFAs are permitted to charge students approved for reduced-price meals no more than the 

difference in reimbursement rates between F/RP meals. 
134

Table V-1.9. NSLP and SBP Reimbursement Rates for Free School Meals and Average Prices 

for Paid Meals, SY 2009-10 to SY 2011-12

‘09/10 ‘10/11 ‘11/12

% change

‘09/10 to ’10/11

% change

‘10/11 to ’11/12

Reimbursement rate for free meals

Breakfast $1.46 $1.48 $1.51 1.5% 2.0%

Lunch 2.68 2.72 2.77 1.5 1.8

Average paid meal prices

Elementary

Breakfast $1.13 $1.15 $1.19 1.8% 3.5%

Lunch 1.89 1.92 2.00 1.6 4.2

Middle

Breakfast 1.21 1.23 1.26 1.7 2.4

Lunch 2.10 2.14 2.21 1.9 3.3

High

Breakfast 1.21 1.24 1.27 2.5 2.4

Lunch 2.11 2.14 2.21 1.4 3.3

Data Source: http://www.fns.usda.gov/cnd/governance/notices/naps/NAPsHistorical.htm and SFA Director Survey 2011, questions 5.1, 5.2, 5.4, and 5.5. 

The Recent Recession 

The recent economic downturn, which placed a great deal of stress on state and local 

budgets, may have contributed to LEAs’ increasing school lunch prices. Although the recession 

began in December 2007 and lasted 18 months, the post-recession economy has continued to 

perform poorly, which has affected the tax base of states and localities. This austere financial 

environment has likely put pressure on LEAs and SFAs to ensure they fully cover the costs of their 

school food services through the revenues generated. In fact, 28 percent (not shown) of state CN 

directors noted that meal prices were affected by their state’s budget issues.

HHFKA Policy Changes 

It is likely that some of the price increases that occurred between SY 2009-10 and SY 2011-

12 were due to changes based on the new meal pattern requirements stemming from the HHFKA. 

The new NSLP and SBP standards stemming from the HHFKA require schools to increase the 

availability of fruits, vegetables, whole grains, and fat-free and low-fat fluid milk in school meals; 

reduce the levels of sodium, saturated fat, and trans fat in meals; and meet the nutrition needs of 

school children within their age/grade calorie requirements. Although these new nutritional 

standards did not go into effect until SY 2012-13, it is possible that SFAs have already begun to 

move in the direction of serving healthier foods in anticipation of the requirements and increased 

meal prices with SY 2011-12 to cover the costs of more nutritious offerings. Beginning on October 

1, 2012, the HHFKA provided SFAs that comply with the new meal standards an additional Federal 

reimbursement (6 cents per reimbursable meal) and offers provisions for generating revenues to 

offset expected increased costs. 

SFAs will also have to raise the prices of nonreimbursable food items by a considerable 

amount. As discussed above, both SLBCS-I and SLBCS-II reported that revenues derived from the 

sale of nonreimbursable food items were considerably less than the cost of these food items. 
135

These two changes in pricing structure act in opposite directions with regard to participation 

of students who are paying full-price. Increasing the prices of paid lunches could act to reduce 

NSLP participation, but the increase in the prices of competitive foods makes the purchase of these 

foods a less desirable alternative to buying a school lunch and should act to increase NSLP 

participation. The net effect of these two provisions will become clearer over the next few years as 

they continue to be implemented. 

Actions Taken to Avoid Raising Meal Prices and Minimize the Effects 

on Participation 

Both LEAs and SFAs seek to minimize price increases. While an SFA is responsible for 

running its LEA’s school food service programs, decisions about meal prices are made by LEAs 

(and sometimes require the approval of the school board). Historically, LEAs have been reluctant to 

change meal prices each year. Rather than have a series of small annual increases, LEAs typically 

hold their meal prices constant for several years and then raise prices by a larger amount (St. Pierre 

et al. 1991). 

LEAs and SFAs rely on many different approaches to minimize or avoid increasing prices 

charged to students paying full price for school meals, and in general their strategies have not 

changed in over 20 years. Table V-1.10 compares the top four strategies used in SY 2011-12 with 

those used in SY 1988-89. Although the order of importance has changed, the top four strategies 

were the same in the two time periods. Interestingly, all four strategies for avoiding raising prices in 

one way or another involve reducing the direct cost of producing reimbursable meals and were used 

with more frequency in SY 2011-12 than in SY 1988-89. 

Table V-1.10. Top Four Strategies SFAs Report Their LEA Used to Avoid Increasing the Price of 

Paid NSLP and SBP Student Meals, SY 2011-12 versus SY 1988-89

Strategies used to avoid price increases

Percentage of SFAs reporting strategy used: 

SY 2011-12 SY 1988-89

Increase use of USDA-donated foods 63.4% 29%

Improve food staff efficiency 60.3 16

Switch to lower-priced foods 41.9 33

Reduce kitchen staff hours 38.4 21

Total SFAs: Weighted n

Total SFAs: Unweighted n

12,121

1,2241

14,259

1,401

1 

n is less than 1,401 due to item non-response. 

Data Sources: SFA Director Survey 2011, question 5.8, and St. Pierre et al. 1991. 

When prices are increased, SFAs typically experience a decline in the participation of 

students who are not approved for F/RP meals, because it is only this group of students who 

experience price increases. Somewhat surprisingly, only 55 percent (not shown) of SFAs that 

increased meal prices in SY 2011-12 took any special steps to maintain student participation. Ninetytwo percent (not shown) of these SFAs tried to increase parent awareness of the school meals 

program; 90 percent (not shown) offered more popular foods; and 89 percent (not shown) tried to 

improve meals.
136

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137

V-2. Expenditures, Revenues, and Unpaid 

Meals 

Background 

The current regulations stipulate that an SFA must operate on a nonprofit basis and abide by 

a series of financial rules.52 In this context, we looked at an SFA’s cash receipts and cash 

expenditures to examine the extent to which SFAs operate on a nonprofit basis and provide some 

insight into the relative efficiency of their production processes. Additionally, we examined the 

extent to which LEAs charge their SFAs for indirect costs versus absorbing these costs in the local 

school budget. Finally, we examined the financial implications to the SFAs of covering the cost of 

meals for children who have not been approved for free meals but who are unable to pay for school 

meals during the school year. 

Measuring Expenditures versus Costs 

Ideally, to assess if SFAs are operating on a nonprofit basis, all SFAs revenues and costs 

would need to be measured. However, there are several challenges associated with calculating the 

cost of school food service operations (Child Nutrition Meal Cost Methodology Study, USDA 

1992). First, not all resources used are reported as part of SFAs costs; this is particularly true for 

indirect costs such as overhead functions that may be covered by the LEA to support school food 

service operations. Second, in addition to cash reimbursements for school meals, USDA provides 

in-kind support to SFAs in the form of donated foods. In SY 2011-12, SFAs were entitled to receive 

approximately 18 cents in USDA Foods plus all of the available bonus commodities that could be 

used without waste. SLBCS-II reported that the total value of USDA Foods accounted for an 

average of about 5 percent of total SFA revenues (SLBCS-II, USDA 2008). However, donated 

USDA Foods appear on both sides of the ledger, as both a cost item and revenue item, and are 

therefore a wash when considering the relationship between costs and revenues. Finally, there is 

often interest in examining the costs and revenues associated specifically with reimbursable meals as 

this is the component of food service production that is subsidized by the Federal government. 

However, because reimbursable and non-reimbursable foods are often prepared by the same staff 

with ingredients that are used in common, it is difficult to identify the inputs, and therefore costs, 

used to produce reimbursable meals. As it was not within the scope of SN-OPS to measure 

unreported costs or to allocate food service costs between reimbursable and non-reimbursable 

meals, the cost of producing a reimbursable meal was not estimated. Instead, the study examined 

cash expenditures and revenues that provide insight into total production cost and revenues and 

whether the SFA is operating on a nonprofit basis. 

 

52 7CFR210.9b(1), January 1, 2009 edition. Available at http://www.fns.usda.gov/cnd/governance/regulations/7cfr210_09.pdf
138

Operational Definition of Breaking Even 

As with any business, in some years an SFA may have a year-end surplus, and in other years, 

it may incur a deficit. Although an SFA’s year-end operating balance may be expected to fluctuate 

from year to year, over time it is expected that the deficits incurred in some years will be offset by 

surpluses generated in other years, so that over time, an SFA operates on a nonprofit basis (i.e., at a 

break-even level, with revenues equaling expenditures).53

Defining breaking even as ending the school year with revenues equaling expenditures does 

not work operationally when trying to examine if SFAs are operating on a nonprofit basis. With any 

cross-sectional sample of SFAs, many SFAs will end the year with an operating deficit, while many 

others will end the year with an operating surplus. The proportion of SFAs operating at exactly the 

break-even level will be extremely small. For analytic purposes, it is necessary to define “operating at 

a break-even level” more broadly, that is, to define it as operating within a narrow range around the 

point where the ratio of revenues to expenditures is equal to 1. The narrower the range selected, the 

fewer SFAs will be found to be operating at the break-even level; the wider the range, the more 

SFAs will be found to be operating at the break-even level. While admittedly arbitrary, the 

operational definition of breaking even used is in this study is ending a school year with a ratio of 

revenues to expenditures equal to 1.0±0.05. 

Unpaid Meals 

SFAs may incur costs for providing unpaid meals to students who have not been approved 

for free meals and who are unable to pay for these school meals. Although FNS does not require 

schools to provide a school meal or an alternative meal to these students, it does encourage them to 

do so.54 The School Nutrition Association (SNA) has issued guidance to its members on dealing 

with this issue, and it notes that the cost of unpaid meals is not reimbursable and must often be 

borne by the SFA (SNA 2008). In a 2009 survey of its membership, SNA reported that 21 percent 

of SFA directors indicated that unpaid meals “... were one of the top three most pressing issues 

facing their school nutrition program” (SNA 2009).55 However, the SNA report does not address the 

actual fiscal implications of revenues lost because of unpaid meals. 

Research Questions 

The research questions in this section focus on SFA costs and revenues for SY 2010-11 and 

whether SFAs are operating at a break-even level. The research questions also address the issue of 

unpaid meals and the effect of unpaid meals on an SFA’s ability to operate on a nonprofit basis.

 

53 FNS limits an SFA’s net cash resources to an amount that does not exceed 3 months of operating expenditures. Previous studies 

(SLBCS-II; USDA 2008) reported that, on average, in SY 2005-06, SFAs maintained cash balances that were about one-half of the 

allowable maximum, and only about 25 percent of SFAs had an end-of-year cash balance that exceeded 3 months of expenses. 

54 USDA, FNS. “About School Meals: FAQs.” Available at http://www.fns.usda.gov/cnd/About/faqs.htm

55 SNA conducted a Web survey of 2,250 SFA directors and received 310 responses, for a response rate of 13.8 percent. 
139

 What is the magnitude of SFA cash expenditures? What is the composition of SFA cash 

expenditures? 

 How many LEAs charge their SFA for indirect cost? 

 What is the magnitude of cash revenues? 

 How do total SFA cash expenditures compare with total SFA cash revenues? 

 Are SFAs operating on a nonprofit basis? 

 What actions are taken when a child who has not been approved for free meals cannot pay for a school 

meal? 

 What steps are taken to recover revenues lost because of unpaid meals? 

 What percent of SFAs have lost revenues because of unpaid meals? 

 Are SFAs able to recover any of the revenues lost from unpaid meals? 

 What is the relative magnitude of lost revenues because of unpaid meals when compared with SFAs’ 

total revenues? 

 How do unpaid meals affect an SFA’s ability to operate on a nonprofit basis? 

Results 

For the financial analyses in this chapter, several constructed variables were created, and 

many of these constructs have a high degree of dispersion. As such, the median rather than mean 

was used as the main measure of central tendency for the financial data, as it is less sensitive to 

outliers. The median is the 50th percentile (or middle) of the distribution, with half of the cases 

having values above this amount and half of the case having values below this amount. 

Expenditures and Revenues 

Many environmental factors affect an SFA’s total expenditures and revenues. Among those 

factors are the number and reimbursement status of students participating in the school meals 

programs and the appeal and quantity of nonreimbursable foods. However, a major factor affecting 

an SFA’s total expenditures and revenues is simply the size of the SFA, both in the number of 

schools and the number of students served (and hence the amount of food that must be prepared 

and served). It makes little sense to compare the annual expenditures and revenues of the Los 

Angeles Unified School District, which has an enrollment of nearly 700,000 children in grades K-12 

in over 1,000 schools, to, say, the Mora, New Mexico, Independent School District, which has 4 

schools with a total enrollment of about 500 students. To account for the very large differences in 

SFA size, this study used total annual daily expenditures (and revenues) per average daily attendance 

(ADA) to examine expenditures and revenues.56 This measure was calculated by dividing the annual 

 

56 An alternative measure to account for differences in SFA size in the number of reimbursable meals served. These data were not 

collected in Year 1. 
140

expenditure and revenue measures by 180 days57 (typical number of school days per year) to get an 

approximation of an SFA’s daily expenditures and revenues. This daily expenditure (revenue)

measure was then divided by ADA to get expenditure (revenue) per ADA, which captures the 

expenditure per student in attendance per day. 

Cash Expenditures 

Table V-2.1 shows the distribution of SFAs by their daily expenditures per ADA day. About 

41 percent of all SFAs spent daily between $2.01 and $3.00 per ADA; 39 percent spent more than 

$3.00; and 20 percent spent $2.00 or less. 

Table V-2.1. Percentage of SFAs by Daily Food Service Expenditures per ADA, SY 2010-11

SFA daily cash expenditures per ADA Percentage of SFAs

≤1.50 5.7%

$1.51-$2.00 14.5

$2.01-$2.50 20.8

$2.51-$3.00 20.1

$3.01-$3.50 11.6

≥ $3.51 27.3

Total 100.0

Total SFAs: Weighted n 11,005

Total SFA: Unweighted n 1,1141

1 

n is less than 1,401 because of item non-response. 

Data Source: SFA Director Survey 2011, question 7.1a. 

Table V-2.2 shows that the median daily expenditure per ADA was $2.68. SFAs’ median 

daily expenditure per ADA varies significantly by SBP participation status and SFA size. SFAs that 

participated in both the NSLP and the SBP spent more ($2.74) than SFAs that participated only in 

the NSLP ($1.89). Small SFAs (with an enrollment of fewer than 1,000 students) also spent more 

($3.00) than medium ($2.54), large ($2.53), and very large SFAs ($2.35). Daily spending per ADA 

varied significantly as the percentage of students approved for F/RP meals increased; high-poverty 

SFAs spent more than low-poverty SFAs ($3.30 vs. $2.12). There was also significant variation by 

urbanicity level, by the use of a FSMC, and by type of kitchen used. 

 

57 The National Center for Education Statistics reports that the average number of operating days for school district is 180. http\9I 

the distributiontp://nces.ed.gov/surveys/pss/tables/table_15.asp
141

Table V-2.2. SFAs’ Daily Food Service Cash Expenditure per ADA by SFA Characteristics, SY 

2010-11

SFA characteristics SFAs’ median daily expenditure per ADA

Total SFAs

Weighted n Unweighted n

All SFAs $2.68 11,004 1,1141

Participation in SBP2

NSLP and SBP 2.74 10,092 1,059

NSLP only 1.89 913 55

SFA size2

Small (1-999) 3.00 5,288 241

Medium (1,000-4,999) 2.54 4,096 411

Large (5,000-24,999) 2.53 1,361 308

Very large (25,000+) 2.35 260 154

Urbanicity2

City 2.43 1,131 218

Suburban 2.09 1,974 293

Town 2.79 2,273 215

Rural 2.94 5,627 388

Poverty level2

Low (0-29% F/RP) 2.12 2,501 269

Medium (30%-59% F/RP) 2.67 5,233 519

High (60% or higher F/RP) 3.30 3,270 326

Type of kitchen2

Onsite kitchen only 2.63 1,811 176

Offsite kitchen only 2.79 6,111 508

Combination or other 2.54 2,909 420

Use of a FSMC2

SFA uses a FMSC 2.43 2,023 202

SFA does not use a FMSC 2.78 8,923 908

1 

n is less than 1,401 because of item non-response. 

2 Median daily expenditure per ADA significantly differs by participation in SBP, SFA size, urbanicity, poverty level, type of kitchen, and use of an 

FSMC at the .05 level. 

Data Source: SFA Director Survey 2011, question 7.1a. 

Table V-2.3 shows the components of cash expenditures. As expected, food and labor 

account for most food service costs, with food accounting for an average of 41 percent of SFAs’ 

reported costs, and labor accounting for 43 percent of SFAs’ reported costs. This is consistent with 

previous studies (SLBCS-I and -II, USDA 1994, 2008).58 SFA size was significantly related to how 

SFAs allocated their resources. For small SFAs, labor accounted for 40 percent of total expenditures 

but accounted for 45 to 46 percent of total expenditures for larger SFAs. By contrast, contract 

services accounted for a larger percentage of total reported cost in small SFAs (12 percent) 

compared with larger SFAs, where contracted services accounted for between 4 percent and 7 

percent of reported costs. 

 

58 SLBCS-I and SLBCS-II found that food accounted for 48 to 47 percent of SFAs’ total reported costs, but these studies included 

the assigned value of USDA Foods as part of an SFA’s reported costs, while the present study does not. In SY 2005-06, USDA 

Foods accounted for 12 percent of the total food cost of an average SFA (USDA 2008). 
1

42

Table V-2.3. On Average, the Percentage of SFAs’ Cash Expenditures Spent on Various Inputs, SY 2010-11

Type of SFA

On average, the percentage of SFA cash expendituresspent on:

Food Labor Contracted services Other expenditures

Mean

%

Wtd 

n

Unwtd 

n

Mean

%

Wtd 

n

Unwtd 

n

Mean

%

Wtd

n 

Unwtd 

n

Mean

%

Wtd

n

Unwtd 

n

All SFAs 41.0% 10,987 1,116142.6% 10,807 1,10219.3% 10,835 1,10317.8% 10,712 1,0951

Participation in SBP

NSLP and SBP 40.7 10,074 1,061 42.8 9,920 1,048 9.2 9,947 1,049 7.9 9,824 1,041

NSLP only 43.4 913 55 40.0 888 54 11.0 888 54 6.3 888 54

SFA size2

Small (1-999) 42.0 5,261 240 40.3 5,163 236 12.1 5,167 236 6.5 5,090 233

Medium (1,000-4,999) 40.6 4,096 411 44.5 4,032 405 6.8 4,060 408 8.4 4,020 404

Large (5,000-24,999) 38.3 1,367 309 44.9 1,348 305 7.2 1,347 304 9.9 1,340 303

Very large (25,000+) 38.8 263 156 45.7 263 156 3.5 262 155 12.0 262 155

Meal Production System3

On-site kitchens only 41.6 2,197 254 42.4 2,170 252 7.3 2,154 250 8.8 2,154 2,450

Base/Central with 

satellites only

42.4 6,113 508 43.8 6,038 501 6.6 6,025 501 7.4 5,987 498

Combination kitchens 37.2 2,677 354 40.0 2,600 349 17.1 2,655 352 7.6 2,571 347

1 

n is less than 1,401 because of item non-response. 

2 Percentage of expenditures on food, labor, contracted services, and other expenditures significantly differs by SFA size at the .05 level.

3 Percentage of expenditures on contracted services and other expenditures significantly differs by meal production system at the .05 level. 

Data Source: SFA Director Survey 2011, question 7.1a. 
143

Indirect Costs 

 As school budgets have become much tighter, LEAs have sought ways to increase revenues 

without raising taxes. One potential source of revenue for an LEA is to charge the school food 

service accounts for the indirect costs attributable to its food service program. Historically, LEAs 

have not charged their SFAs for indirect costs, even though the regulations permit them to do so 

(USDA 2010).59 Between SY 1992-93 and SY 2005-06, there were very large increases in the 

percentage of LEAs that charged some, or all, of the indirect costs attributable to their food service 

program to their SFA (SLBCS-I and II, USDA 1994 and 2008). Even so, in SY 2005-06, only 16 

percent of LEAs charged their SFAs for any indirect costs. The SNA surveyed its membership and 

reported that in SY 2004-05, a total of 52 percent of the 972 SFA directors who responded to the 

Web survey were being charged for indirect costs (SNA 2006).60

 In SY 2010-11, a total of 22 percent of SFAs reported being charged for indirect costs by 

their LEA as shown in Table V-2.4. This is similar to the SLBCS-II estimate. The percentage of 

SFAs charged for indirect costs varied significantly with SFA size. Only 13 percent of small SFAs 

were charged for indirect costs in SY 2010-11, compared to 28 percent of medium size, 42 percent 

of large, and 71 percent of very large SFAs. 

Table V-2.4. Percentage of SFAs Reporting they were Charged for Indirect Costs by SFA 

Characteristics, SY 2010-11

1 SFAs were asked to report total SY 2010-11 expenditures by category with one of the choices being indirect/overhead costs. 

2 Percentage of SFAs reporting that they were charged for indirect costs significantly differs by participation in SBP, SFA size, and type of kitchen 

at the .05 level. 

Data Source: SFA Director Survey 2011, question 7.1a.

 

59 Charging an SFA for indirect costs is equivalent to billing the SFA for these costs. Many LEAs charge their SFAs for indirect costs, 

but do not actually recover these costs, which involves actually getting paid. 

60 The SNA estimate of the percentage of SFAs being charged for indirect costs should, however, be viewed with some caution 

because the SNA survey response rate was only 23 percent. 

SFA characteristics

Percentage of SFAs reporting that they 

were charged for indirect costs1

Total SFAs

Weighted n Unweighted n

All SFAs 22.4% 14,678 1,401

Participation in SBP2

NSLP and SBP 23.8 13,253 1,315

NSLP only 9.5 1,424 85

SFA size2

Small (1-999) 12.5 7,374 332

Medium (1,000-4,999) 27.5 5,390 536

Large (5,000-24,999) 42.4 1,629 364

Very large (25,000+) 70.7 284 169

Type of kitchen2

Onsite kitchen only 25.3 2,373 220

Offsite kitchen only 19.3 7,895 640

Combination or other 27.8 4,154 528

Use of a FSMC

SFA uses a FMSC 20.3 3,014 279

SFA does not use a FMSC 23.3 11,479 1,110
144

Cash Revenues 

 Table V-2.5 shows the distribution of SFAs by their revenues per ADA. As one would 

expect, given that SFAs are supposed to operate at a break-even level, the distribution of SFAs by 

their receipts per student attending per day looks very much like the distribution of SFAs by 

expenditures. About 44 percent of all SFAs received between $2.01 and $3.00 daily per student 

attending; 34 percent received more than $3.00 daily per student attending; and 23 percent received 

$2.00 or less daily per student attending. 

Table V-2.5. Percentage of SFAs by Daily Cash Receipts per ADA, SY 2010-11

Annual SFA cash receipts per student 

(attending) per day Percentage of SFAs

≤1.50 8.2%

$1.51-$2.00 14.7

$2.01-$2.50 22.8

$2.51-$3.00 20.9

$3.01-$3.50 11.6

≥ $3.51 21.9

Total 100.0

Total SFAs: Weighted n

Total SFAs: Unweighted n

10,982

1,1061

1 

n is less than 1,401 due to item non-response. 

Data source: SFA Director Survey 2011, question 6.1a. 

 As Table V-2.6 shows, the median daily cash receipt per student attending was $2.59. As 

with expenditures, there were some differences in median daily cash receipts per student attending 

among different types of SFAs. The differences in daily cash receipts per student attending follow 

the same pattern as the differences in daily expenditures per student in attendance. Daily cash 

receipts per ADA significantly differ by SBP participation, SFA size, and poverty level. For example, 

SFAs that participate in both the NSLP and the SBP had higher daily cash receipts per ADA ($2.64) 

than SFAs that participate only in the NSLP ($1.80). Small SFAs had higher receipts ($2.68) than 

medium ($2.51), large ($2.47), and very large SFAs ($2.45). Daily receipts per ADA were higher in 

high-poverty SFAs ($3.03) than in medium-poverty level SFAs ($2.61), and low-poverty level SFAs 

($2.07). There were also significant differences by urbanicity level and use of an FSMC. 

Appendix Tables E-33 through E-36 provide a breakdown of SFA revenues by source. The 

tables reveal that in SY 2011-12, 52 percent (not shown) of SFA revenues came from USDA 

subsidies, making it the largest single source of SFA revenues. USDA subsidies include subsidies for 

reimbursable meals as well as other Federal subsidies. Another 26 percent (not shown) of SFA 

revenues came from student payments for paid and reduced-price meals. Only 12 percent (not 

shown) of SFA revenues came from state and local funds, and 9 percent of revenues came from 

non-reimbursable sales. 
145

Table V-2.6. SFA’s Daily Cash Receipts per ADA by SFA Characteristics, SY 2010-11

SFA characteristics SFA’s median daily cash receipt per ADA

Total SFAs

Weighted n Unweighted n

All SFAs $2.59 10,982 1,1061

Participation in SBP2

NSLP and SBP 2.64 10,005 1,049

NSLP only 1.80 978 57

SFA size2

Small (1-999) 2.68 5,317 242

Medium (1,000-4,999) 2.51 4,081 408

Large (5,000-24,999) 2.47 1,323 300

Very large (25,000+) 2.45 262 156

Urbanicity2

City 2.46 1,199 221

Suburban 2.09 1,961 289

Town 2.77 2,265 214

Rural 2.70 5,557 382

Poverty level2

Low (0-29% F/RP) 2.07 2,487 266

Medium (30%-59% F/RP) 2.61 5,182 516

High (60% or higher F/RP) 3.03 3,313 324

Type of kitchen

Onsite kitchen only 2.58 1,758 173

Offsite kitchen only 2.66 6,092 502

Combination or other 2.47 2,967 422

Use of an FSMC2

SFA uses an FMSC 2.26 2,100 206

SFA does not use an FMSC 2.66 8,820 895

1

n is less than 1,401 due to item non-response. 

2 Median daily revenues per ADA significantly differ by participation in SBP, SFA size, urbanicity, poverty level, and use of an FSMC at the .05 

level. 

Source: SFA Director Survey 2011, question 6.1a. 

Operating as a Nonprofit 

Consistent with previous studies, the data suggest that in SY 2010-11, SFAs, on average, 

were operating at a break-even level; the median ratio of total cash revenues to total cash 

expenditures was equal to 1.0 (USDA 1992, 1994, 2008; St. Pierre 1991). However, as discussed 

earlier in this chapter, it would be highly unlikely for this ratio to equal 1.0 for any individual SFA in 

a particular year. Breaking even is more properly viewed as a phenomenon that happens over time 

rather than every year. Over time, one would expect an SFA that is operating at a break-even level to 

experience year-to-year fluctuations in both revenues and expenditures, but one would also expect 

that over a period of years, its average ratio of revenues to expenditures would equal approximately 

1.0.61 The results from a cross-section of SFAs in any given year should approximate the results of a 

time series for a single “typical” SFA.

 

61 Technically, as a consequence of the law of large numbers, an SFA’s ratio of revenues to expenditures should asymptotically 

approach 1.0. The longer the period of time included in calculating the ratio, the closer the ratio will be to 1.0. 
146

Table V-2.7 shows the distribution of SFAs by the ratio of annual cash receipts as a 

percentage of annual cash expenditures. Although on average SFAs are breaking even, only 41 

percent actually operated at a break-even level, with the ratio of revenues to expenditures between 

0.95 and 1.05. One third (34 percent) incurred a deficit, and 25 percent produced a surplus.62 As 

indicated earlier in this chapter, the percentage of SFAs operating at the break-even level is 

dependent on the operational definition of breaking even. Narrowing the operational definition of 

breaking even to a ratio of revenues to expenditures between 0.975 and 1.025 reduces the 

percentage of SFAs that would be considered as breaking even from 41 to 28 (not shown). Similarly, 

widening the definition to a ratio between 0.90 and 1.10 increases the percentage of SFAs that 

would be considered as breaking even from 41 to 63. As discussed previously, one would expect to 

see movement of individual SFAs in and out of the break-even band over time. 

Table V-2.7. Percentage of SFAs by Annual Cash Receipts as a Percentage of Cash 

Expenditures, SY 2010-11

Annual SFA cash receipts as a percentage of annual cash 

expenditures Percentage of SFAs

≤85% 19.0

86% to 90% 5.4

91% to 95% 9.6

96% to 100% 23.6

101% - 105% 17.8

106% to 110% 12.2

111% to 115% 4.0

≥116% 8.4

Total 100.0

Total SFAs: Weighted n

Total SFAs: Unweighted n

10,680

1,0821

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, questions 6.1a and 7.1a. 

Table V-2.8 shows the median cash receipts as a percentage of expenditures and the 

percentage of SFAs operating at the break-even level by SFA characteristics. As the table shows, the 

median ratio of cash receipts as a percentage of expenditures is 1.0, suggesting that most SFAs were 

breaking even. Sixty-six percent of SFAs operated at or above the break-even level (ratio of cash 

receipts to expenditures of .95 or greater). Several SFA characteristics were significantly associated 

with breaking even, including SBP participation, SFA size, poverty level, and being charged with 

indirect costs. For example, SFAs that participated in both the NSLP and SBP were more likely to 

break even than those that operated only a lunch program (68 percent versus 49 percent). Similarly, 

very large SFAs were more likely to break even than small SFAs (90 percent versus 58 percent). The 

type of kitchen used by SFAs and use of FSMCs were unrelated to breaking even. 

 

62 The analysis of breaking even relied on a comparison of total cash receipts to total cash expenditures for SY 2010-11. SFAs are 

allowed to carry up to 3 months of operating expenses in their nonprofit school food service accounts. The Year 1 data collection 

did not obtain information on SFAs’ 3-month operating balance, so the analysis could not consider any operating balance (or 

deficit) that an SFA had going into the school year. Because the Year 2 survey will again collect data on revenues and expenditures 

for SY 2011-12, it will be possible to analyze break-even status over a longer (2-year) period and take into account any surplus or 

deficit from Year 1 when analyzing break-even status in Year 2. 
147

Table V-2.8. Percent of SFAs Operating At or Above the Break-Even Level by SFA 

Characteristics, SY 2010-11

SFA characteristics

Median ratio of cash 

receipts/expenditures

Percentage of SFAs ≥ 

break-even level1

Total SFAs

Weighted

n

Unweighted

n

All SFAs 1.00 65.9% 10,678 1,0822

Participation in SBP3

NSLP and SBP 1.00 67.5 9,801 1,030

NSLP only 0.95 48.8 878 52

SFA size4

Small (1-999) 0.99 58.1 5,142 234

Medium (1,000-4,999) 1.00 70.0 3,974 397

Large (5,000+) 1.02 79.8 1,303 296

Very large (25,000+) 1.03 90.4 261 155

Type of kitchen

Onsite kitchen only 1.00 66.1 1,707 168

Offsite kitchen only 1.00 65.5 5,987 494

Combination or other 1.00 69.5 2,821 411

Use of an FSMC

SFA uses an FMSC 1.00 65.9 1,952 195

SFA does not use an FMSC 1.00 66.0 8,669 883

Poverty level5

Low (0-29% F/RP) 1.00 67.2 2,411 260

Medium (30%-59% F/RP) 1.00 70.3 5,083 505

High (60% or higher F/RP) 0.99 57.9 3,185 317

Indirect Costs6

SFA is charged for indirect costs 1.00 71.7 7,448 616

SFA is not charged for indirect costs 1.00 63.4 3,231 466

1 Operating at or above the break-even level is defined as a ratio of revenues to expenditures of greater than .95. 

2

n is less than 1,401 due to item non-response. 

3 Median ratio of cash receipts/expenditures and percentage of SFAs breaking even significantly differs by participation in SBP at the .05 level. 

4 Median ratio of cash receipts/expenditures and percentage of SFAs breaking even significantly differs by SFA size at the .05 level. 

5 Percentage of SFAs breaking even significantly differs by poverty at the .05 level. 

6 Median ratio of cash receipts/expenditures and percentage of SFAs breaking even differs by indirect costs at the .05 level. 

Data Source: SFA Director Survey 2011, questions 6.1a, 7.1a, and 8.3. 

Lost Revenues from Unpaid Meals 

Although not required to do so by FNS regulations, SFAs are, in fact, providing meals to 

children who cannot pay for them. SFAs were asked to report the total amount of money owed to 

them from unpaid meals before any attempts were made to recover any of these lost revenues and 

the total amount of money recovered. More than half of the SFAs (58 percent) reported that they 

incurred unpaid meal costs (before recovery attempts) in SY 2010-11 (not shown). Table V-2.9 

shows that among SFAs that reported unpaid meal costs in SY 2010-11, 88 percent regularly 

provided either a reimbursable school meal or some form of alternative meal to children who were 

not approved for a F/RP meal and who could not pay for a meal. Common types of alternative 

meals include peanut butter and jelly sandwiches and cheese sandwiches (SNDA 2008). Half of 
148

SFAs with unpaid meal costs provide children who cannot pay a full school meal, and another 38 

percent provide an alternative meal. 

Table V-2.9. Among SFAs with Unpaid Meal Costs, the Percentage of SFAs with Various 

Practices for Providing a Meal to Students Who Cannot Pay, SY 2010-11

SFA practice Percentage of SFAs

Serve a reimbursable meal 50.4%

Serve an alternative meal 38.0

Serve a reimbursable meal for a limited number of times and then serve 

an alternative meal

5.4

Do not serve the child a reimbursable or alternative meal 1.3

Other 4.9

Total 100.0

Total SFAs: Weighted n

Total SFAs: Unweighted n

8,533

9121

1 

n equals the 912 SFAs that reported unpaid meal costs before recovery attempts in SY 2011-12.

Data Source: SFA Director Survey 2011, question 8.1. 

While the initial cost of providing unpaid meals is charged to the SFA, the LEA, or the 

school, not all SFAs keep track of the monies owed for unpaid meals or try to recover the costs of 

unpaid meals. In SY 2011-12, 13 percent of SFAs did not keep track of these unpaid meal costs. Of 

those SFAs that reported unpaid meal costs, nearly all (over 99 percent) took some actions to 

recover these costs. Table V-2.10 shows the steps taken by SFAs to recover unpaid meal costs. Most 

often, SFAs billed the parents (94 percent). Other common approaches included providing the 

student with an alternative meal until the debt is paid (60 percent), taking some administrative action 

such as withholding a student’s grades (36 percent), and trying to retroactively approve the student 

for F/RP meals (25 percent). 

Table V-2.10. Among SFAs with Unpaid Meal Costs, the Percentage of SFAs that Took Various 

Actions to Recover Costs from Unpaid Meals, SY 2011-12 

Actions taken to recover lost revenues Percentage of SFAs

Bill the parents 94.1%

Provide student with an alternative meal until the debt is paid 60.1

Administrative actions (e.g., withhold grades) 35.5

Try to have student retroactively approved for free meals 25.0

Use a debt collection agency 5.9

Other steps 9.2

No steps taken to recover lost revenues 0.4

Total SFAs: Weighted n 8,518

Total SFAs: Unweighted n 9111

1 

n is less than the 912 SFAs that reported unpaid meal costs before recovery attempts in SY 2011-12 due to item non-response. 

Data Source: SFA Director Survey 2011, question 8.4. 
149

Regardless of the approaches used, only 14 percent (not shown) of SFAs recovered all of the 

revenues initially lost due to unpaid meals. At the other end of the spectrum, 51 percent (not shown) 

of SFAs that had unpaid meal costs did not recover any of these lost revenues.63 On average, SFAs 

recovered 31 percent (not shown) of the revenues initially lost from unpaid meals. Although less 

than half of SFAs with unpaid meal costs recover some of these lost revenues, the net revenues lost 

(i.e., after recoveries) is quite small compared with the total expenditures incurred by an SFA. Table 

V-2.11 shows that for 89 percent of SFAs with lost revenues from unpaid meals after recovery 

attempts, the net revenues lost amounted to no more than 1 percent of their annual expenditures. 

For another 10 percent, the revenue lost was more than 1 percent but less than 10 percent of their 

annual expenditures. Less than 1 percent of SFAs with lost revenues reported that the losses 

exceeded 10 percent of annual expenditures. On average, for all SFAs that lost some revenue as a 

result of unpaid meals, the net revenue lost was less than 1 percent (0.51 percent) of total 

expenditure for the year. 

Table V-2.11. Among SFAs with Unrecovered Lost Revenue from Unpaid Meals, the 

Percentage of SFAs with Various Magnitudes of Losses, SY 2010-11

Unrecovered lost revenues from unpaid meals as a 

percentage of total annual SFA cash expenditures

Of those with lost revenue, the percentage of 

SFAs by the magnitude of the loss

≤1.0% 89.4%

1.1% to 10.0% 10.0

≥10.1% 0.7

Total all SFAs with lost revenues for unpaid meals 100.0

Average percentage (lost revenues/expenditures) 0.51

Total SFAs: Weighted n

Total SFAs: Unweighted n

6,148

6881

1 

n is less than the 801 SFAs that reported unpaid meal costs and did not recover all of the money due to item non-response. 

Data Source: SFA Director Survey 2011, questions 7.1a, 8.2, and 8.3. 

Lost revenue from unpaid meals did not appear to have a meaningful effect on the ability of 

an SFA to operate at the break-even level. Table V-2.12 shows that 31 percent of SFAs with lost 

revenue after recoveries from unpaid meals incurred a deficit in SY 2010-11. Even if these SFAs had 

recovered all of the revenue initially lost from unpaid meals, it would not have substantially reduced 

the percentage of SFAs that incurred a deficit in SY 2010-11 (30 percent would still have incurred a 

deficit). 

 

63 About 50 percent (not shown) of all SFAs experience some revenue losses due to unpaid meals. 
150

Table V-2.12. Among SFAs with Unrecovered Lost Revenues from Unpaid Meals, the 

Percentage of SFAs by Break-Even Status given Actual Lost Revenues versus the 

Assumption All Unpaid Revenues were Recovered, SY 2010-11

Annual SFA cash receipts as a percentage of 

annual cash expenditures (break-even status)

Percentage of SFAs by break-even level given:

Actual losses

Assuming all lost revenue 

recovered

≤95% 30.9% 29.5%

96% to 100% 22.8 22.5

101% - 105% 20.5 21.2

>105% 25.8 26.8

Total all SFAs with lost revenue for unpaid meals 100.0 100.0

Median ratio (receipts/expenditures) 1.00 1.01

Total SFAs: Weighted n 5,990

Total SFAs: Unweighted n 6691

1 

n is less than the 801 SFAs that reported unpaid meal costs and did not recover all of the money due to item non-response. 

Data Source: SFA Director Survey 2011, questions 6.1, 7.1, 8.2, and 8.3. 
151

Section VI: State Policies and Administration 

of the NSLP and SBP 

The states play an important role in administering the NSLP and SBP. While FNS sets 

policies for the school meals programs, state agencies are responsible for administering the 

programs. The state CN director is responsible for applying Federal policies, developing 

supplementary state policies where needed, and administering the program through agreements with 

the local SFAs. States’ administration role includes managing fiscal elements of the program, 

monitoring SFA performance, providing SFAs with technical assistance, and making required 

reports back to FNS. As such, to fully understand the SFA operating environment, state program 

procedures and policies should be examined. 

 This section presents findings from the State CN Director Survey. The findings include data 

from 54 directors in 50 states, the District of Columbia, and three territories that completed the 

State CN Director Survey.64 Some findings from the SFA Director Survey are also included where 

they are relevant to the topics discussed. The topics discussed in each chapter include state 

communication with SFAs, state finances and budget, state policies, and training and technical 

assistance provided by states to SFAs. 

 

64 Questionnaires were sent to directors in all 50 states, the District of Columbia and the five territories. Responses were received 

from 54 of the 56 directors for a response rate of 96 percent. Only two of the territories did not respond to the survey. 
152

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153

VI-1. Communication Issues 

Background 

 It is the state, rather than FNS, that has a direct connection with SFAs. FNS uses a tiered 

approach in communicating with states and SFAs. Headquarters first contacts the directors of the 

seven FNS Regional Offices who then contact the state CN directors in their Region. It is the state 

CN directors who maintain contact with SFA directors within each state. In turn, SFA directors 

contact schools and households in their districts. 

 The ability of states and SFAs to communicate with each other and with parents is always 

crucial but was perhaps of particular importance in SY 2011-12 when the study data were collected, 

approximately 1 year after the enactment of the HHFKA. During this time period, USDA focused 

on developing the HHFKA regulations and beginning implementation. Accomplishments included 

the proposal of new meal patterns, issuance of common-sense guidance for revenue, nationwide 

expansion of at-risk afterschool meals, the implementation of categorical eligibility for foster 

children, bolstering farm to school connections, and actions on direct certification and community 

eligibility. All of these activities required communication among states, SFAs, school staff, and, 

sometimes, parents. This chapter presents an overview of the methods of communication used in 

SY 2011-12 and the broad types of topics communicated. It focuses both on the state director and 

local SFA directors, who are responsible for effectively communicating various aspects of the school 

food service program to students, parents, and school staff. Both state and SFA directors can use an 

array of communication channels, including newsletters, emails, videos, and in-person meetings and 

presentations, to share information on planned menus, food recalls, new policies and procedures, 

and other topics with various stakeholders. 

Research Questions 

 FNS is interested in answering the following research questions about communication: 

 How do state agencies communicate with SFAs (written correspondence, blanket emails, etc.)? 

 Does the method of communication vary by type of information communicated (policy memos, 

announcements, commodity recalls, etc.)? 

 How do SFAs communicate with school staff in their districts? 

 How do SFAs communicate with households? Do they utilize a website? What information is provided 

to households (menus, nutritional information, etc.)? 

Data collected from both the State CN Director Survey and the SFA Director Survey are 

examined to present a comprehensive picture of communication at various levels regarding the 

NSLP and SBP. 
154

Results 

Communication between State Agencies and SFAs 

 The State CN Director Survey asked state directors about the methods they used to 

communicate with SFAs in their state and the topics communicated. State directors reported having 

used a variety of methods to communicate with SFAs depending on the topic or issue. Table VI-1.1 

shows the typical ways that state directors reported communicating with SFAs on policy-related 

matters, for various types of announcements, about commodity recalls, and for other matters. State 

directors were asked about the extent to which they used regular mail, email, a web posting, 

automated phone or fax, or some other method to communicate on each of these topics. 

 Regardless of the topic, email was the most frequently used form of communication 

reported by state directors, with over 85 percent of states using email for policy memos, 

announcements, and commodity recalls. Web postings were used well over half the time for policy 

memos and announcements and nearly half the time for commodity recalls. Regular mail was used 

by some states as a follow-up to ensure that a particular communication was on record. Thirteen to 

20 percent of states sent all three types of messages by mail. Automated phone or fax was a fairly 

uncommon form of communication. 

Table VI-1.1. Percentage of States that Used Various Methods to Communicate with SFAs by 

Topic, SY 2011-12

Topic

Percentage of states that used various methods to communicate with SFAs:

Regular 

mail Email Web posting

Automated 

phone or fax Other

Policy memos 20.4% 85.2% 75.9% 1.9% 3.7%

Announcements 16.7 88.9 63.0 3.7 1.9

Commodity recalls 13.0 85.2 46.3 14.8 13.0

Other 3.7 5.6 5.6 3.7 0.0

Total states: n 54

Data Source: State CN Director Survey 2011, question D13. 

 In the SFA Director Survey, SFA directors were also asked about the various methods state 

agencies used to communicate with them and whether the method varied by topic. As expected, the 

methods that SFA directors reported state agencies used to communicate with them were similar to 

the methods that state directors reported using to communicate with SFAs. The vast majority of 

SFA directors reported that state agencies used email to communicate with them. As seen in Figure 

VI-1.2, 86 to 97 percent of SFA directors reported that state agencies communicated with them 

using email correspondence, posting information on their website, and postal mail.65

 

65 Respondents selected among email correspondence, blanket emails, and email blasts. The choices were not defined in the 

questionnaire and therefore may have been interpreted differently between respondents. Blanket emails were reported by 72 

percent of SFA directors, and email blasts were reported by 45 percent of directors.
155

Figure VI-1.1. Percentage of SFAs that Reported their State Communicated to them by 

Various Methods, SY 2011-12

Unweighted n=1,395 (weighted n=14,540) is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey, question 13.1. 

Communication between SFAs and School Staff 

 The SFA Director Survey also asked about the methods the directors used to communicate 

with school staff in their districts. Overall, email and text messages were the most common method 

used by SFA directors to communicate with school staff in their districts. Table VI-1.2 shows that 

84 percent of SFAs reported using email and text messages to communicate with school staff. Other 

common methods are websites and letters/memos; each of these methods was used by about threequarters or more of all SFAs (73 percent used a website, and 75 percent sent letters/memos). There 

were differences in the use of email or text messages, letters/memos, and websites by SFA size and 

poverty level. Fewer small SFAs, as compared to very large SFAs, used all of the communication 

methods specified. Compared with low- or medium-poverty-level SFAs, fewer high-poverty-level 

SFAs used email or text messages and websites; more high-poverty-level SFAs used letters/memos. 

97.1 89.1 86.2

72.3

45.3

7.5

0

20

40

60

80

100

Email 

correspondence

Website Mail Blanket emails Email blasts Other
156

Table VI-1.2. Percentage of SFAs that Used Various Methods to Communicate to School Staff 

by SFA Characteristics, SY 2011-12

 

SFA characteristics

Percentage of SFAs that: Total SFAs

Use website 

to provide 

information

Send letters/ 

memos

Send periodic 

newsletters

Send emails or 

text messages

Weighted

n

Unweighted 

n

All SFAs 73.4% 74.9% 34.7% 84.4% 14,514 1,3941

SFA size2

Small (1-999) 62.6 73.8 38.6 80.6 7,220 326

Medium (1,000-4,999) 83.5 73.8 29.4 87.6 5,381 535

Large (5,000-24,999) 84.6 81.2 33.1 88.9 1,629 364

Very large (25,000+) 90.7 88.9 45.3 92.1 284 169

Urbanicity3

City 60.4 78.8 32.4 85.7 1,576 254

Suburban 78.0 72.8 30.8 88.6 2,848 378

Town 81.0 74.7 30.8 85.6 2,794 266

Rural 71.5 75.0 38.2 82.0 7,297 496

Poverty level4

Low (0-29% F/RP) 78.6 70.2 30.0 88.6 3,370 346

Medium (30-59% F/RP) 76.7 73.9 37.3 87.0 6,754 647

High (60% or higher F/RP) 64.4 80.2 34.2 77.1 4,390 401

1 

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs that use a website, letters/memos, periodic newsletters, and emails or text messages differed significantly by SFA size at 

the .05 level. 

3 Percentage of SFAs that use a website differed significantly by urbanicity at the .05 level. 

4 Percentage of SFAs that use a website, letters/memos, and emails or text messages differed significantly by poverty level at the .05 level. 

Data Source: SFA Director Survey, question 13.5. 

Communication between SFA and Participating Households 

 The SFA Director Survey included items related to how SFAs communicated with individual 

households in the school district and what information was provided to those households. In SY 

2011-12, SFAs used a variety of methods to communicate with households in their school districts. 

The most common method was to send letters or memos home with students; the next most 

common method was posting updates on a website. Newsletters as well as email or text messages 

were each used by about one-half of the SFAs. Table VI-1.3 shows that the percentage of SFAs that 

used each communication method varied by SFA characteristics. For example, websites were used to 

provide information to households by over 91 percent of medium to very large SFAs but by only 70 

percent of small SFAs. Similarly, over 86 percent of SFAs classified as low- or medium-poverty 

status used websites, compared with about 65 percent of SFAs classified as high-poverty status. 
157

Table VI-1.3. Percentage of SFAs that Used Various Methods to Communicate with 

Individual Households by SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that: Total SFAs

Use website 

to provide 

information

Send letters/ 

memos home 

with students

Send 

periodic 

newsletters

Send emails 

or text 

messages Other

Weighted 

n

Unweighted 

n

All SFAs 81.3% 90.4% 51.3% 43.8% 19.7% 14,547 1,3941

SFA size2

Small (1-999) 70.0 87.7 52.6 38.4 15.8 7,273 328

Medium (1,000-4,999) 91.2 93.5 50.5 49.6 20.2 5,360 533

Large (5,000-24,999) 96.3 92.2 49.0 49.7 31.4 1,629 364

Very large (25,000+) 96.8 91.0 47.5 40.0 42.0 284 169

Urbanicity3

City 73.8 89.6 55.3 45.0 22.8 1,576 254

Suburban 85.5 88.4 50.6 49.6 23.8 2,875 379

Town 88.1 92.2 51.6 38.3 16.9 2,773 264

Rural 78.6 90.7 50.7 43.4 18.5 7,323 497

Poverty level4

Low (0-29% F/RP) 91.7 84.6 53.3 58.6 17.8 3,370 346

Medium (30-59% F/RP) 86.7 92.4 55.6 44.5 20.5 6,775 647

High (60% or higher F/RP) 64.9 91.8 43.3 31.3 20.0 4,402 401

1 

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs that use a website, letters/memos, and emails or text messages differed significantly by SFA size at the .05 level. 

3 Percentage of SFAs that use a website differed significantly by urbanicity at the .05 level. 

4

 Percentage of SFAs that use a website, letters/memos, period newsletters, and emails or text messages differed significantly by poverty level 

at the .05 level. 

Data Source: SFA Director Survey, question 13.3. 

 Table VI-1.4 shows that nearly all SFAs (98 percent) include breakfast and/or lunch menus 

when communicating information to parents. Communication about other topics is much lower: 

approximately 42 percent of SFAs communicate nutritional information, and about 18 to 21 percent 

communicate information regarding cafeteria inspections or insecticide sprayings. There is little 

variation by SFA characteristics on the frequency with which information about insecticide sprayings 

are communicated. The percentage of SFAs communicating nutritional information, however, varies 

by SFA size: 72 percent of large and 83 percent of very large SFAs communicate nutritional 

information, compared with 30 percent of small SFAs. Reports of cafeteria inspections are also 

more likely to be communicated by larger SFAs than smaller SFAs (42 percent of very large SFAs 

communicate the results of cafeteria inspections versus 18 percent of small SFAs). 
158

Table VI-1.4. Percentage of SFAs that Communicated to Households on Various Topics by 

SFA Characteristics, SY 2011-12

SFA characteristics

Percentage of SFAs that communicated to households on: Total SFAs

Breakfast 

and/or lunch 

menus

Nutritional 

information

Inspections 

of cafeteria

Insecticide 

spraying Other

Weighted 

n

Unweighted 

n

All SFAs 97.8% 42.0% 21.1% 17.8% 8.8% 14,396 1,3881

SFA size2

Small (1-999) 96.4 29.8 18.4 15.1 6.7 7,121 322

Medium (1,000-4,999) 99.0 46.9 21.3 22.5 8.0 5,362 533

Large (5,000-24,999) 99.6 72.0 29.1 15.9 16.5 1,629 364

Very large (25,000+) 99.3 83.2 41.8 16.2 31.3 284 169

Urbanicity3

City 95.5 57.4 22.8 15.1 15.6 1,576 254

Suburban 96.6 57.6 17.8 19.8 13.4 2,820 377

Town 97.7 39.4 22.6 19.5 7.0 2,726 262

Rural 98.8 33.6 21.5 16.2 6.2 7,275 495

Poverty level4

Low (0-29% F/RP) 99.1 48.2 20.2 19.5 9.2 3,336 344

Medium (30-59% F/RP) 99.6 38.5 21.8 17.5 7.4 6,747 646

High (60% or higher F/RP) 94.0 42.8 20.8 16.8 10.7 4,313 398

1

n is less than 1,401 due to item non-response. 

2 Percentage of SFAs that communicated about breakfast and/or lunch menus, nutritional information, inspections of cafeteria, and other 

information differed significantly by SFA size at the .05 level. 

3 Percentage of SFAs that communicated about nutritional information and other information differed significantly by urbanicity at the .05 level. 

4 Percentage of SFAs that communicated about breakfast and/or lunch menus and nutritional information differed significantly by poverty level 

at the .05 level. 

Data Source: SFA Director Survey, question 13.4. 

Communicating About Food Holds or Recalls 

 Communications about food holds or recalls are among the most important 

communications for parents. SFA directors were asked how they are notified about food holds or 

recalls and how they, in turn, notify schools in their districts. Consistent with earlier findings that 

email is the dominant method of communication for states and SFAs, Table VI-1.5 shows that email 

is the most common way that SFAs receive and pass on information about food holds and recalls 

(95 percent and 76 percent, respectively). Telephone calls were the second most common method 

by which SFAs were notified and, in turn, notified schools about food holds and recalls (39 percent 

and 65 percent, respectively).66

 

66 The surveys did not ask why states or SFAs choose one method over another. It is possible that states supplement emails with 

phone calls primarily on items of severe risk and/or time sensitivity. 
159

Table VI-1.5. Percentage of SFAs that Received and Communicated Information about Food 

Holds/Recalls by Various Methods, SY 2011-12

Communication method

Percentage of SFAs that:

Are alerted to food holds/recalls 

through indicated media

Alert schools about food holds/recalls through 

indicated media

Email notification 95.4% 76.0%

Telephone call 38.7 65.1

Fax 25.7 15.6

Postal mail 38.6 17.8

Other 4.7 14.6

Total SFAs: Weighted n 14,426 14,396

Total SFAs: Unweighted n 1,38611,3851

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey, questions 12.13 and 12.14. 
160

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161

VI-2. State Finances and Budget 

Background 

 In FY 2009, the Federal government spent $16 billion on the SBP and NSLP, making school 

meals the second largest food and nutrition assistance program in the United States.67 While most of 

the assistance to schools and school districts is in the form of Federal cash reimbursements for 

meals served, there are other sources of support. A second source of support from USDA is 

donated USDA Foods, also called commodity “entitlements.” The amount is determined on a yearly 

basis. Schools can receive additional “bonus” commodities as they become available from surplus 

agricultural stocks. 

 States may provide subsidies to SFAs for the school meals programs. The subsidy could be 

on a per meal basis, on a per meal basis based on the number of F/RP meals rather than all meals, 

on a per student basis, or an annual lump sum based on a formula set by the state. 

Research Questions 

 This chapter addresses the following research questions: 

 Do states provide financial resources for school meals to SFAs in the form of per-meal subsidies? 

 Do states provide support for aspects of the school food service operations other than meal 

reimbursement? 

 What areas of the food service program were affected by state budget issues? 

 Do states have adequate staffing resources? 

 Are states using contracted staff for any functions? 

 Are states operating under a hiring freeze? 

Results 

State Subsidies to SFAs 

 The state agencies are responsible for managing the finances of the SLP at the state level. 

SFAs receive an advance of funds to support operations or are reimbursed through their state 

agency at various rates, depending on whether the student was served a free, reduced-price, or fullprice meal. 

 

67 Budget of the United States Government: Fiscal Year 2010: Appendix, p. 163. 
162

 Some states provided a subsidy to SFAs beyond the Federal reimbursement that SFAs 

received for the F/RP meals served to income-eligible students. As Figure VI-2.1 shows, about twothirds of the states reported that they provided subsidies for breakfast or lunch. Forty-two percent 

of states provided a subsidy for breakfast and lunch; 9 percent provided a subsidy for breakfast only; 

11 percent provided a subsidy for lunch only; and 38 percent of states provided no subsidies to 

SFAs. 

Figure VI-2.1. Percentage of States Providing Subsidies for Meals to SFAs, SY 2010-11

n is 53 due to item non-response. 

Data Source: State CN Director Survey, question B2. 

As Table VI-2.1 shows, of the states subsidizing breakfast or lunch, about half (46 percent 

breakfast; 52 percent lunch) provided the subsidy on a per-meal basis. About a quarter of the states 

reported using supplements for specific costs or lump sum payments; another 22 to 23 percent of 

the states said they used another method; and less than 4 percent said they subsidized based on the 

percentage of low-income students. Beyond providing meal subsidies, all states were asked if they 

provide financial or personnel support to SFAs for school service operations. Over a quarter of 

states (28 percent) reported providing support for the preparation of reimbursable meals at schools. 

Over 20 percent of states provided support for preparing claims or for storage. 

41.5%

9.4% 11.3%

37.7%

Subsidy for breakfast and lunch Subsidy for breakfast only

Subsidy for lunch only No subsidy provided
163

Table VI-2.1. Percentage of States Providing Different Types of Subsidies and Support for 

School Meals, SY 2010-11

Subsidies Percentage of states

Among states providing a breakfast subsidy (n = 26), it is provided through:1

Per-meal reimbursement 46.2

Supplement to cover specific costs 11.5

Annual lump sum 15.4

Based on percentage of low-income students 3.9

Other 23.1

Among states providing a lunch subsidy (n = 27), it is provided through:2

Per-meal reimbursement 51.9

Supplement to cover specific costs 14.8

Annual lump sum 11.1

Based on percentage of low-income students 0.0

Other 22.2

Among all states (n = 54), support for aspects of school food service operations other than 

meal reimbursements

Reimbursable meal preparation 27.8

Preparing claims 22.2

Storage 22.2

Contracted services 18.5

Overhead/indirect costs 16.7

Non-reimbursable meal preparation 13.0

Equipment 24.1

1 

n is less than the 27 states that provided a breakfast subsidy due to item non-response. 

2 

n is less than the 28 states that provided a lunch subsidy due to item non-response. 

Data Source: State CN Director Survey 2011, questions B1a and B2. 

Budget Issues 

Over the past several years, states have faced major budget crises. Although the severity of 

the crises has varied by state, the pressure of the budget generally has been felt across all sectors. 

The State CN Director Survey asked state CN directors in what ways budget issues in their state had 

affected their school meals programs. State directors could choose more than one response. Table 

VI-2.2 shows that 59 percent of the states indicated that state budget issues affected their ability to 

hire and retain staff. Thirty-nine percent of states said the purchasing and upgrading of equipment 

had been affected. Similarly, 35 to 32 percent said that procuring and contracting services was 

affected, and 28 and 24 percent said meal prices and food purchases were affected, respectively. 

 States are required to conduct monitoring visits to SFAs to ensure compliance with 

regulations. Less than one-third of state CN directors (30 percent) reported that their state had 

adequate staffing in place to conduct monitoring activities for the SBP and NSLP programs. In 

contrast, 20 percent of state directors reported that staffing was not adequate, and 50 percent said it 

was somewhat adequate.68

 

68 State directors were also asked about the number of FTE staff they have for monitoring. There was very little variation in the 

number of FTE monitoring staff, with 95 percent of states reporting less than 1 FTE per 1,000 students. 
164

Table VI-2.2. Percentage of States that Reported Various Food Service Program Areas were 

Affected by State Budget Issues, SY 2011-12

Impacts Percentage of states 

Areas affected by state budget issues (n = 54)

Hiring/retaining staff 59.3%

Purchasing/upgrading equipment 38.9

Procuring contracted services 35.2

Contracted services 31.5

Meal prices 27.8

Food purchases 24.1

Other 9.6

Adequacy of current staffing for monitoring program operations (n = 54)

Adequate 29.6

Somewhat adequate 50.0

Not adequate 20.4

Functions for which state is using contracted staff (n = 54)

Nutrition education 40.7

Technical assistance 37.0

Monitoring 33.3

Claims processing 5.6

Other 29.6

States currently operating under a state-mandated hiring freeze for child nutrition/school 

program staff (n = 54)

24.1

Among states with a hiring freeze (n = 12), length of time hiring freeze has been in effect1

Less than 1 year 8.3

1 year 8.3

2 years 33.3

3 or more years 50.0

1 

n is less than the 13 states that were operating under a hiring freeze for child nutrition/school program staff due to item non-response. 

Data Source: State CN Director Survey 2011, questions B3, B5, B6, and B7. 

One strategy for containing costs is to outsource monitoring and other operational 

responsibilities. States were asked if contracted staff were being used for these functions. Table VI2.2 shows that while 33 to 41 percent of the states reported using contracted staff for monitoring, 

technical assistance, or nutrition education, only 6 percent reported contracting out tasks related to 

claims processing. 

As a result of budget cuts, some states were operating under state-mandated hiring freezes, 

which have affected the offices operating the school CN programs. According to state CN directors, 

24 percent of states were operating under a hiring freeze. Among the states that were under a hiring 

freeze, half reported that the hiring freeze had been in effect for 3 or more years, and one-third said 

their freeze had been in effect for 2 years. 

 
165

VI-3. State Policies and Practices 

Background 

 States manage the school meals program by developing certain policies and practices that 

SFAs and schools must follow. They also provide assistance to SFAs on how to implement both 

their state policies as well as the Federal policies. NSLP and SBP program eligibility and verification 

is a key policy area for which states provide implementation oversight to SFAs. Also, states often 

provide assistance and guidance on providing alternative meals to students who are not certified for 

F/RP meals and do not have the funds to pay. Additionally, states play a significant role in guiding 

and supporting local SFA school meal operations. State agencies are responsible for ordering USDA 

food products and ensuring that they are delivered to school districts, often playing a critical role in 

contract oversight of FSMCs, and typically developing school meal policies regarding food recalls or 

nutritional standards. Finally, as the number of charter schools grows, significant variation in the 

number of charter schools across states and how they are served could affect program access and 

efficiency. Each of these topics―eligibility and alternative meals, school meal operations, and charter 

schools―is examined in more detail in the sections below.

Eligibility and Alternative Meals

 The burden of paperwork on parents has long been perceived to be a barrier to applying for 

the NSLP. School districts may also experience significant burden processing applications and 

meeting administrative requirements. FNS has introduced a number of policies to reduce paperwork 

and burden for both parents and school districts, including Provisions 2 and 3 and direct 

verification. These policies reduce burden on parents and on school districts by reducing application 

requirements and automating the process of verifying eligibility using extant data. States may provide 

assistance to SFAs on how to implement these policies. 

 Provision 2 requires schools to serve meals to participating students at no charge but reduces 

the application burden to once every 4 years and simplifies meal counting and claiming procedures. 

Schools can obtain additional 4-year extensions if the SFA documents that the economic conditions 

of the district have not changed significantly. Schools must pay the difference between the Federal 

reimbursement and the cost of providing all meals at no charge, using a source other than Federal 

funds. This provision has been available to school districts since 1980. 

 Provision 3 similarly requires schools to serve meals to participating students at no charge. It 

allows a school to receive a comparable level of Federal cash and commodity assistance as it 

received in the last year in which F/RP eligibility determinations were made, for a period up to 4 

years, adjusted to reflect changes in enrollment and inflation. The school may be approved for a 4-

year extension if the income level of the school’s population remains stable. Under this provision, 

school districts agree to pay the meal cost not covered by program income from a source other than 

Federal funds. This provision has been available to school districts since 1995. 
166 

 In 2007, research on the accuracy of certification for F/RP meals indicated that Provisions 2 

and 3 base year schools had more erroneous payments than schools not using these provisions.69

The number of SFAs and schools using Provisions 2 and 3 is therefore of interest both for its 

implications for certification accuracy and for its ability to reduce burden on schools and families. 

 Direct verification is designed to lessen the burden on schools when verifying application 

information. Because households self-report their income and family size, schools have long been 

required to select a sample of households, contact them, and verify that students approved for F/RP 

meals were, in fact, eligible for those subsidized meals, which is burdensome for both school 

districts and families. Under the 2004 Child Nutrition and WIC Reauthorization Act, LEAs can directly 

verify information provided on F/RP meal applications for the NSLP and SBP, instead of 

contacting households to confirm student eligibility. LEAs can obtain income and program 

participation information from public agencies administering the Supplemental Nutrition Assistance 

Program (SNAP), Food Distribution Program on Indian Reservations (FDPIR), Temporary 

Assistance for Needy Families (TANF), state Medicaid programs under Title XIX of the Social 

Security Act, and similar means-tested programs. Although the decision whether to use direct 

verification falls to LEAs, state agencies must work with LEAs to determine the best method for 

carrying out direct verification. States must also assist in facilitating contacts with other state 

agencies to establish the procedures for conducting direct verification. 

 In addition to their role in facilitating the application and verification process for F/RP 

meals, states are instrumental in setting the policies and practices for providing alternative meals to 

students who are not certified for a free meal but cannot pay for their meal. These situations arise 

daily and create challenges for the student, for the school officials who must decide how to handle 

the situation, and, increasingly, for policy makers. Most schools provide some type of alternate meal, 

however, this requires additional labor and materials from schools, is embarrassing for students, 

allegedly leads to negative opinion of cafeteria staff, effects the schools’ ability to provide a healthy 

meal, and may discourage students from even coming to lunch (if they know they don’t have money 

in their account).70

School Meal Operations 

 Although SFAs are responsible for implementing the SBP and NSLP at the local level, state 

agencies oversee several important aspects of school meal operations and policies. State agencies are 

responsible for ordering USDA food products and ensuring that they are delivered to school 

districts. When SFAs contract with FSMCs to assist with meal service operations in the districts, 

states often play a critical role in contract oversight and management with the FSMCs. In addition to 

these responsibilities, states also develop new policies for school meal operations that SFAs are 

expected to follow. Two important areas of school meal operations in which states may set policies 

are food recalls and nutritional standards. 

 

69 NSLP/SBP Access, Participation, Eligibility, and Certification Study—Erroneous Payments in the NSLP and SBP—November 

2007, http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/APECSummaryofFind.pdf. 

70 “The Perpetual Problem of Unpaid Meal Charges,” Margie Bowers, Child Nutrition Director, Rogers Public Schools, Rogers 

Arkansas. Presented at the March 2013 Legislative Action Conference of the SNA. 

http://docs.schoolnutrition.org/meetingsandevents/lac2013/presentations.asp. 
167

 Most of the new requirements stemming from the HHFKA began to be implemented after 

the first year of data collection for the study (SY 2011-12) Therefore, the 2011-12 school year could 

be considered as a baseline for the changes, but, perhaps more accurately, a transition year in which 

states and SFAs were adjusting to the changes to come. Policy makers have long recognized that 

states can serve as a laboratory for social policy, with some having had policies that were more 

stringent than the potential Federal rules and others less so. Given this fact and the temporal 

proximity of SY 2011-12 to implementation of the final school meal standards, it is instructive to 

examine the degree to which states had regulations that exceeded Federal standards and whether 

they had tackled some of the more controversial issues in HHFKA such as nutrition and pricing 

standards for competitive food products. 

Charter Schools 

 The growth of charter schools in recent years raises new policy questions for both FNS and 

the states. Charter schools are publically funded schools that provide an alternative to the traditional 

public school and operate autonomously. Charter schools are not required to operate under the SBP 

or NSLP, and many charter schools may choose to opt out of these programs due to their more 

autonomous nature. As their numbers become substantial, their participation in the SBP and NSLP 

is important to ensure the program is available to all students in need. States vary in the number of 

charter schools they have and how those charter schools are treated when it comes to school food 

services. States may grant charter schools that participate in the SBP or NSLP SFA status or 

facilitate having them served by a larger SFA that hosts them. These practices have implications for 

the future size of SFAs and potentially could lead to further growth of very small SFAs, which has 

implications for efficiency, training, and oversight. 

Research Questions 

This chapter addresses the following topics and research questions: 

Eligibility Provisions 

 How many SFAs/schools are operating under Provision 2 or 3 in each state? 

 Are state agencies currently conducting direct verification using SNAP, TANF, FDPIR, Medicaid, 

or SCHIP data? 

 How is direct verification being implemented by states? 

 Do states anticipate conducting direct verification in the future? 

Alternative Meals 

 What are the current state policies and practices regarding providing students who are without funds a 

school meal? 
168

School Meal Operations 

 USDA Foods 

o How are state warehouses for USDA Food funded? 

o What additional charges do state agencies assess SFAs for the delivery of USDA Foods 

on a per case basis (administrative fees, storage fees, delivery fees, etc.)? 

o Has the increase in processing USDA Foods over the years resulted in a reduction in the 

warehouse fees states collect? 

o Do states purchase food products for all, most, some, or no SFAs? 

 Food service management companies 

o How many SFAs/schools are using food service management companies? How many of 

these are national companies? Regional companies? Local companies? 

o Do state agencies require the use of a state-developed prototype contract? 

 Food recalls 

o Do states have policies governing food recalls? What are these policies? 

o How do states notify schools and districts about food recalls? What types of information do 

states provide? 

o What procedures do states expect schools and districts to follow in the event of a food recall? 

How much time do states give to schools and districts to respond to a food recall? What 

types of information are schools and districts expected to report to states in the event of a 

food recall? 

 Nutrition standards 

o Do states have nutrition standards that exceed Federal requirements for foods and 

beverages offered in school meals? 

o Do states have nutrition standards for foods and beverages offered in competition with the 

school meals? 

o What is the impact of states’ nutritional standards on participation? 

Charter Schools 

 How many charter schools are participating in the NSLP/SBP in each state? 

 For purposes of school food operations, are charter schools treated as a separate SFA, as part of an 

existing SFA, or a combination of both? Does this vary by state? 
169

Results 

Eligibility Provisions 

 A substantial number of states reported having SFAs that use Provisions 2 and 3 and direct 

verification to lessen the administrative burden associated with determining students’ program 

eligibility. Overall, many more states had SFAs using Provision 2 (41 states) as compared to 

Provision 3 (15 states), and just about half (25) of the states reported having at least one SFA that 

was using direct verification. 

 State directors were asked to report the number of SFAs and schools in their states that were 

operating under Provision 2 and Provision 3. Table VI-3.1 shows the number of SFAs and schools 

operating under Provision 2 or Provision 3 in each state during SY 2011-12. Although the majority 

of states reported at least one SFA was operating under Provision 2, many had only a few SFAs 

using the Provision. As such, a total of 1,095 SFAs (6 percent of all SFAs) and 6,922 schools (7 

percent of all schools) operated under Provision 2 in SY 2011-12. Additionally, compared to 

Provision 2, far fewer states used Provision 3, and only 62 SFAs and 254 schools operated under 

Provision 3. 
170

Table VI-3.1. Number and Percentage of SFAs and Schools in Each State Operating under 

Provision 2 or Provision 3, SY 2011-12

State

Number 

of SFAs 

in state1

Number 

of schools 

in state2

In Provision 2 In Provision 3

Number of SFAs 

(Percentage)

Number of schools 

(Percentage)

Number of SFAs 

(Percentage)

Number of schools 

(Percentage)

Alabama 189 1,600 6 (3.2) 30 (1.9) 0 (0.0) 0 (0.0)

Alaska 73 509 0 (0.0%) 0 (0.0%) 14 (19.2%) 106 (20.8%)

Am. Samoa -- 28 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

Arkansas 289 1,110 19 (6.6) 93 (8.4) 0 (0.0) 0 (0.0)

Arizona 458 2265 58 (12.7) 220 (9.7) 9 (2.0) 18 (0.8)

California 1,094 10,124 150 (13.7) 1,418 (14.0) 3 (0.3) 5 (0.1)

Colorado 226 1,796 4 (1.8) 47 (2.6) 0 (0.0) 0 (0.0)

Connecticut 185 1,157 5 (2.7) 110 (9.5) 0 (0.0) 0 (0.0)

Delaware 42 214 5 (11.9) 12 (5.6) 0 (0.0) 0 (0.0)

Dist. of Columbia 61 228 1 (1.6) 66 (29.0) 0 (0.0) 0 (0.0)

Florida 223 4,131 19 (8.5) 556 (13.5) 0 (0.0) 0 (0.0)

Georgia 232 2449 69 (29.7) 375 (15.3) 0 (0.0) 0 (0.0)

Hawaii 35 289 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

Idaho 148 748 85 (57.4) 325 (43.5) -- -- 0 (0.0)

Illinois 1,132 4,361 2 (0.2) 26 (0.6) 2 (0.2) 3 (0.1)

Indiana 499 1,936 11 (2.2) 96 (5.0) 1 (0.2) 25 (1.3)

Iowa 480 1,436 10 (2.1) 26 (1.8) 2 (0.4) 2 (0.1)

Kansas 400 1,378 2 (0.5) 4 (0.3) 0 (0.0) 0 (0.0)

Kentucky 189 1,554 3 (1.6) 21 (1.4) 0 (0.0) 0 (0.0)

Louisiana 113 1,471 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

Maine 189 631 6 (3.2) 6 (1.0) 0 (0.0) 0 (0.0)

Maryland 73 1,449 1 (1.4) 207 (14.3) 1 (1.4) 5 (0.4)

Massachusetts 429 1,829 16 (3.7) 107 (5.9) 0 (0.0) 0 (0.0)

Michigan 882 3,877 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

Minnesota 697 2,392 5 (0.7) 63 (2.6) 3 (0.4) 8 (0.3)

Mississippi 197 1,083 20 (10.2) 54 (5.0) 0 (0.0) 0 (0.0)

Missouri 785 2,410 0 (0.0) 0 (0.0) 2 (0.3) 2 (0.1)

Montana 241 827 26 (10.8) 75 (9.1) 0 (0.0) 0 (0.0)

Nebraska 378 1,096 8 (2.1) 104 (9.5) 0 (0.0) 0 (0.0)

Nevada 32 645 3 (9.4) 46 (7.1) 0 (0.0) 0 (0.0)

New Hampshire 100 480 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

New Jersey 697 2,607 5 (0.7) 23 (0.9) 0 (0.0) 0 (0.0)

New Mexico 220 862 118 (53.6) 405 (47.0) 0 (0.0) 0 (0.0)

New York 1,105 4,757 125 (11.3) 750 (15.8) 0 (0.0) 0 (0.0)

North Carolina 162 2,567 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

North Dakota 215 516 22 (10.2) 28 (5.4) 1 (0.5) 4 (0.8)

Ohio 1,222 3,758 46 (3.8) 344 (9.2) 0 (0.0) 0 (0.0)

Oklahoma 574 1,785 24 (4.2) 48 (2.7) 14 (2.4) 22 (1.2)

Oregon 245 1,296 39 (15.9) 194 (15.0) 0 (0.0) 0 (0.0)

Pennsylvania 853 3,233 6 (0.7) 6 (0.2) 0 (0.0) 0 (0.0)

Puerto Rico 38 1,473 11 (29.0) NR -- 2 (5.3) NR --

Rhode Island 54 317 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

South Carolina 106 1,214 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

South Dakota 211 710 40 (19.0) 142 (20.0) 5 (2.4) 45 (6.3)

Tennessee 201 1,784 1 (0.5) 1 (0.1) 1 (0.5) 5 (0.3)

Texas 1,259 8,732 94 (7.5) 695 (8.0) 0 (0.0) 0 (0.0)

Utah 85 1,016 2 (2.4) 6 (0.6) 2 (2.4) 4 (0.4)

Vermont 226 320 7 (3.1) 19 (5.9) 0 (0.0) 0 (0.0)

Virgin Islands -- 32 -- -- 32 (100.0) 0 .(0.0) 0 (0.0)

Virginia 161 2,175 6 (3.7) 115 (5.3) 0 (0.0) 0 (0.0)

Washington 327 2,338 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

West Virginia 73 757 0 (0.0) 0 (0.0) 0 (0.0) 0 (0.0)

Wisconsin 848 2,238 11 (1.3) 17 (0.8) 0 (0.0) 0 (0.0)

Wyoming 58 360 4 (6.9) 10 (2.8) 0 (0.0) 0 (0.0)

Total all states 19,011 100,350 1,095 (5.8) 6,922 (6.9) 62 (0.3) 254 (0.3)

1 Data on number of SFAs in each state comes from USDA Administrative data form FNS-742. The file did not include data for American Samoa or 

Virgin Islands. Idaho and the Virgin Islands reported some inconsistent data on the number of Provision 2/3 SFAs and schools and therefore are 

not shown in those cases. 

2

 NCES CCD 2010-11 http://nces.ed.gov/pubs2012/pesschools10/tables/table_02.asp. 

NR = non-response; state did not report number of SFAs or schools. 

Data Source: State CN Director Survey 2011, questions D1 and D2. 
171

 A recent policy to lessen the administrative burden associated with determining students’ 

program eligibility is direct verification. Figure VI-3.1 shows that just under half (48 percent) of the 

states reported that at least one of their SFAs used direct verification in SY 2011-12. However, 

despite encouragement from FNS, half of the states (50 percent) reported that none of the SFAs in 

their states had ever used direct verification.71

Figure VI-3.1. Percentage of States with at Least One SFA that Used Direct Verification, SY 

2011-12

n is 52 due to item non-response. 

Data Source: State CN Director Survey 2011, questions C1 and C2. 

 Table VI-3.2 shows that among the 25 states conducting direct verification, SNAP and 

TANF were identified most often (23 and 22 states, respectively) as the source of data for verifying 

student data provided on applications. Direct verification with Medicaid was reported by 10 states.72

Fifteen states (60 percent) reported that the school district was the entity responsible for matching 

the student records to program records to verify information included in the household application 

for NSLP and SBP. Most of the states reported that verification was conducted only once during 

each school year. Eleven of the 25 states that used direct verification reported that SFAs in the state 

had access to a web-based lookup system to search the records of individual students. Of the 25 

states using direct verification, over half (56 percent) reported having difficulties matching student 

records while implementing direct verification. Other difficulties experienced included staff not 

 

71 One state reported that SFAs in the state had used direct verification in the past but had discontinued using it (questions C.1 and 

C.2). The survey included question C.3 on “reasons why you are not currently using direct verification.” As this question is best 

asked at the LEA level, it is not surprising that only two states responded to it. 

72 At the end of school year 2009-10, FNS reported that seven states were implementing direct verification with Medicaid and six 

more states were in development (“Feasibility of Wider Implementation of Direct Verification with Medicaid: A Summary”

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/DirectVerificationw_Medicaid_Summary.pdf ).

48.1%

1.9%

50.0%

Currently using Not currently using, 

used in the past

Never used
172

having sufficient time (28 percent), inadequate computer systems or needing to upgrade computer 

systems (24 percent), and difficulty gaining cooperation of the program providing data (20 percent). 

Table VI-3.2. Among the States that Used Direct Verification, the Percentage of States that 

Used Various Implementation Procedures, SY 2011-12

Implementation procedures

Among states that used direct verification1, the 

percentage of states that use different 

implementation procedures 

Source of program record data used when conducting direct 

verification (n = 25)1

Supplemental Nutrition Assistance Program (SNAP) 92.0%

Temporary Assistance for Needy Families (TANF) 88.0

Medicaid 40.0

Food Distribution Program in Indian Reservations (FDPIR) 12.0

State Children’s Health Insurance Program (SCHIP) 8.0

State unemployment office 0.0

Other 4.0

Program records are matched to the student records by: (n = 25)

The district 60.0

The state 20.0

A third party (e.g., TANF, SNAP, or other program office) 12.0

Both state and district 8.0

Frequency of direct verification (n = 24)2

Once each school year 62.5

Once each semester or quarter 0.0

On a monthly basis 16.7

Other 20.0

States where SFAs have access to web-based lookup system to 

search individual student records (n = 25) 44.0

Types of problems encountered when implementing direct 

verification (n = 25)

Difficulties matching student records 56.0

Staff did not have time for direct verification 28.0

Had to upgrade computer systems 24.0

Difficulty gaining cooperation of program providing data 20.0

Students known to be eligible were determined ineligible 12.0

Other 0.0

1

n equals the 25 states or territories that use direct verification. 

2

n is less than the 25 states that use direct verification due to item non-response. 

Data Source: State CN Director Survey 2011, question C5, C6, C7, C8, and C9. 

 All state CN directors were asked whether the state anticipated conducting direct verification 

during the 2012-13 and 2013-14 school years as shown in Table VI-3.3. Of the 23 states that 

reported using direct verification at the time of the survey and responded to the question about 

future plans, 74 percent indicated that they anticipated continuing to use direct verification during 

the subsequent two school years. Twenty-six percent of these states plan to discontinue using direct 

verification (with half citing problems with matching student records, two reporting issues with 

computers, and one citing staff time for conducting the verification as the problem). Of the 22 states 

that were not using direct verification and answered the question about future plans, 45 percent (10 
173

states) plan to start during SY 2012-13 or SY 2013-14, while the remaining 55 percent of these states 

(12 states) had no plans to use direct verification. 

Table VI-3.3. Percentage of States by Use of Direct Verification and Future Plans, SY 2011-12 

Current use and future plans Percentage of states

Currently using direct verification (n = 251)

Plan to continue using 68.0%

Plan to stop using 32.0

Not currently using direct verification (n = 272)

Plan to start using 44.4

No plans to start 55.6

1 

n equals the 25 states that used direct verification. 

2

n is less than the 28 states that were not using direct verification due to item non-response. 

Data Source: State CN Director Survey 2011, questions C1, C2, and C10. 

Alternative Meals 

 The State CN Director Survey included two questions relevant to the issue of alternative 

meals: whether the state had a policy or standard practice for providing breakfast or lunch to 

students who were not certified for F/RP meals and were unable to pay for school meals, and, if 

they did, what the policy was. In general, states either (1) left these decisions to the SFAs or (2) 

required or recommended that SFAs provide meals. 

 For the most part, during SY 2011-12, states did not prescribe a course of action on whether 

to provide either breakfast or lunch to students without the funds to pay for school meals or how 

meals should be provided if the schools are providing meals. Table VI-3.4 shows that nearly 65 

percent of states had neither a policy nor a standard practice for providing such meals. Only 15 

percent of states had a policy, and an additional 20 percent had a standard practice regarding 

providing meals to students who cannot pay for their meal. Of the states with policies and standard 

practices, 65 percent indicated that they let the SFA determine whether and how to provide a meal 

to students who are unable to pay; 6 percent required or recommended that the SFA provide the full 

reimbursable meal; 6 percent required or recommended that the SFA provide an alternative meal; 

and 12 percent (2 states) had some other policy or practice. 
174

Table VI-3.4. Percentage of States with Policies for Providing Meals When Students Are 

Unable to Pay, SY 2011-12 

Policy

Percentage of 

states

State’s approach to providing breakfast or lunch when students are unable to pay (n = 54)

Has policy 14.8%

No policy but standard practice 20.4

No policy or standard practice 64.8

Among states with policy or standard practice for providing meals1 (n = 17)

State requires SFA provide full reimbursable meal 5.9

State requires SFA provide alternative meal 5.9

State recommends SFA provide full reimbursable meal 5.9

State recommends SFA provide alternative meal 5.9

State leaves it up to SFA to determine how to handle 64.7

Other 11.8

1

n is less than the 19 states that have a policy or standard practice with regard to providing school breakfasts or lunches to students who are 

without funds for breakfast or lunch due to item non-response. 

Data Source: State CN Director Survey 2011, questions A3 and A4. 

School Meal Operations 

 Although SFAs oversee the daily serving of school meals, state agencies are responsible for 

several important aspects of school meal operations such as the ordering and delivery of USDA 

food products and overseeing the contracting of FSMCs. Also, many states have set additional rules 

and standards for the school meals programs. As both procedures and policies vary by state, there is 

variation in how the school meals programs operate at the local level. 

USDA Food Products 

 As Table VI-3.5 shows, deliveries of USDA food products are shipped to warehouses 

owned by the state or under contract with the state. Three-quarters (76 percent) of states indicate 

that their warehouse space was contracted, and another 10 percent said that some of their 

warehouse space was contracted, and some was owned by the state. Only 14 percent of states said 

that their warehouse space was owned by the state. Most states (64 percent) charged a fee to school 

districts to fund their warehouses. State budgets covered these costs in 23 percent of states. 

 Costs are also incurred when states deliver USDA Foods from warehouses to the SFAs, as 

shown in Table VI-3.5. In 64 percent of the states, SFAs are expected to pay for some or all of these 

costs. The costs associated with food delivery may or may not be charged to the SFAs on a per case 

basis. Of the states that charged for food delivery, 82 percent charged for delivery fees by the case. 

Over 60 percent of states charged for storage fees per case; 43 percent of states charged for 

warehouse fees on a per-case basis; and 39 percent charged for administrative fees, for each case. 

Eighteen percent of states indicated that they charged other fees to the SFAs on a per-case basis in 

addition to these four types. 
175

Table VI-3.5. Percentage of States that Used Various Warehouses Practices for USDA Foods, 

SY 2011-12

Warehouse practice Percentage of states 

Ownership of state warehouse (n = 49)1

Owned by state 14.3%

Contracted 75.5

Some owned/some contracted 10.2

Method of funding state warehouse (n = 49)1

School districts are charged a fee 63.6

Funded in state budget 22.5

Other 14.3

Among states that charged SFAs for the delivery of USDA Foods, fees 

charged to SFAs on a per case basis (n = 28)2

Delivery fees 82.1

Storage fees 60.7

Warehouse fees 42.9

Administrative fees 39.3

Other fees 17.9

Effect of increased processing of USDA Foods on warehouse fees charge to 

SFAs over the last 3 years (n = 49)1

Increased storage fees 14.3

Decreased storage fees 12.2

No change in storage fees 73.5

State purchases food products for SFAs (n = 49)1

Purchases food products for all SFAs 25.0

Purchases food products for most SFAs 32.7

Purchases food products for some SFAs 3.9

1

n is less than 54 due to item non-response. 

2 

n equals the 28 states that charged SFAs for the delivery of USDA Foods. 

Data Source: State CN Director Survey 2011, questions B8, B9, B10, B10a, B11, and B12.

 Increases in the processing of USDA Foods may have an impact on the warehouse fees 

charged to SFAs. USDA Foods may be shipped directly to the processor to produce more userfriendly products. These end-products may be sent directly to the SFAs, eliminating the need to be 

stored in state warehouses. Nearly three-fourths of states (74 percent) indicated that they had not 

changed storage fees in the past 3 years, regardless of the increased processing of foods. In fact, 12 

percent have actually decreased their fees during this time period. Fourteen percent of states, 

however, did increase storage fees. 

 Additionally, 62 percent (sum of last rows in table) of states engaged in purchasing food 

products for their SFAs. One in four states (25 percent) purchased these products for all of their 

SFAs, with an additional one-third purchasing food products for most of their SFAs. 

Food Service Management Companies (FSMCs) 

 State directors were asked to provide the number of SFAs and schools in their states that 

used FSMCs. Nearly all of the states (85 percent or 46 states) indicated that some SFAs in their 
176

states used FSMCs. As Table VI-3.6 shows, according to state directors, a total of 2,697 SFAs used 

FSMCs. About half (51 percent) of the SFAs that used FSMCs used national companies operating in 

over three-fourths of the schools that used FSMCs (77 percent). Regional and local companies 

served 27 and 23 percent of SFAs, respectively. Appendix E, Table E-50 shows the number of SFAs 

and the number of schools in each state that used FSMCs during SY 2011-12. More than half of the 

SFAs that used FSMCs were found in seven states (New Jersey, Pennsylvania, Michigan, New York, 

Illinois, Missouri, and California). 

Table VI-3.6. Among SFAs that Used FSMCs, the Percentage of SFAs and Schools by the type 

of FSMC used as Reported by State Directors, SY 2011-12

Type of FSMC

Among SFAs that used FSMCs, the number and percentage of SFAs and 

schools as reported by state directors that used different types of FSMCs

Number of SFAs

Percentage of 

SFAs

Number of 

schools

Percentage of 

schools

National companies 1,365 50.6% 7,645 77.2%

Regional companies 713 26.4 1,481 15.0

Local companies 619 22.9 777 7.8

Total SFAs and schools: n Total SFAs = 2,697 Total schools = 9,903

Total states: n 49 41

Percentages are based on the number of SFAs and schools that use FSMC as reported by state directors. The analysis is restricted to 49 states 

that provided complete information regarding the number of SFAs using national, regional, or local companies and 41 states that provided 

complete information regarding schools. 

Data Source: State CN Director Survey 2011, question D3. 

Table VI-3.7 shows that among SFAs that used national FSMCs, Chartwells was used in 

about one-third of SFAs (34 percent). Another 29 percent used Sodexo; 23 percent used Aramark; 7 

percent used Preferred Meal Systems; and 7 percent used other companies. 

Table VI-3.7. Among SFAs that Used National FSMCs, the Percentage of SFAs and Schools 

that Used Specific Companies as Reported by State Directors, SY 2011-12

Specific FSMC used

Among SFAs that used national FSMCs, the number and percentage of SFAs and schools 

as reported by state directors that used specific companies

Number of SFAs Percentage of SFAs

Number of 

schools

Percentage of 

schools

Aramark 318 23.3% 1,932 25.3%

Chartwells 470 34.4 2,293 30.0

Preferred Meal Systems 91 6.7 236 3.1

Sodexo 391 28.7 2,785 36.4

Other companies 95 7.0 399 5.2

Total SFAs and schools: n Total SFAs = 1,365 Total schools = 7,645

Total states: n 49 41

For some states, the number of SFAs or schools using the four national companies was less than the total number of SFAs or schools using 

national companies. The number of SFAs/schools using other companies is the difference between the total number using national companies 

and the number using the four national companies in the questionnaire. 

Data Source: State CN Director Survey 2011, question D3. 

 Table VI-3.8 shows that while contracts with FSMCs were generally executed between the 

company and the SFA, states may have played a role in setting standards or providing oversight. 
177

Ninety percent of states reviewed the contracts before they were signed to ensure that appropriate 

clauses were included regarding the return of rebates, discounts, and credits. Over 62 percent of 

states developed a prototype contract that they expected SFAs to follow when negotiating with an 

FSMC. All 30 states with prototype contracts provided oversight of the contract provisions. 

Table VI-3.8. Use and Review of State-Developed Prototype Contracts for Food Service 

Management Companies (SY 2011-12) 

Policy/Action Percentage of states

Provisions of FSMC contracts that states review in advance of execution (n = 49)1

Return of rebates 89.8%

Discounts 89.8

Credits 89.8

Require use of a state-developed prototype contract for food service management (n = 49)162.1

Among states that require a prototype contract, states with oversight of the provisions in the 

contract (n = 30)2

100.0

1 

n is less than 54 due to item non-response. 

2

n equals the 30 states that require a prototype contract. 

Data Source: State CN Director Survey 2011, questions D4 and D5.

Food Recalls 

 When a recall was announced, nearly all states (96 percent) notified food service directors 

directly as shown in Table VI-3.9. Some states notified others as well—almost half (48 percent) 

notified distributors, and more than a third (37 percent) notified further processors. Notifications 

were always sent by email (100 percent). In addition, over half of states also made phone calls to 

relevant parties. Regular mail was reported by 9 percent of states only. 

States conveyed details about food recalls to schools and districts using multiple methods. 

Nearly all (96 percent) of the states provided copies of the USDA hold or recall notice in their 

communications. Most (89-91 percent) also included more than one of the following in their 

notifications: the name of the product and other information about it, instructions on how to 

dispose of the food item, and contact information if there were any questions about the recall. 

Eighty percent of states also included a press release if one was available. 

 Seventy-four percent of states have state food recall guidelines or procedures.73 Over half of 

states reported that their school districts had procedures or guidelines for USDA recalls, and nearly a 

third of states said they had other procedures. Additionally, states generally expected schools and 

districts to respond quickly to information about a food recall and to report back to the state about 

the results of their actions. Two-thirds of states expected a response within 24 hours, and about 

one-fourth of states allowed a response to take up to 48 hours. More than 80 percent of the states 

wanted districts and schools to provide information about the location and quantity of the product 

 

73 Somewhat surprisingly, when asked if the state had a policy about food recalls (QD.6), only about half of the states responded that 

they did. However, 74 said they had state-established procedures and guidelines (QD.10) The reason for the discrepancy is not 

known. It may reflect the different interpretations of the phrasing of the two questions. The term “policy” implies a written plan 

produced in advance of an actual recall; the phrase “state-established procedures” (QD.10) could refer either to a policy or to

directions given in connection with a specific recall (rather than something developed in advance). 
178

in storage and actions already taken to ensure the recall was handled properly; 70 percent of them 

also wanted to know how much of the food had already been consumed. 

Table VI-3.9. Percentage of States with Different Policies Governing Food Recalls and 

Notification of District-Level Personnel, SY 2011-12

Policy/action Percentage of states 

School/district-level personnel notified by the state about holds or food recalls (n = 52)1

Food services directors 96.3%

Distributors 48.2

Further processors 37.0

Food safety coordinator 29.6

Someone else 22.9

Method of notification

Email notification 100.0 

Phone calls 53.7

Fax 22.2

Regular mail 9.3

Some other way 25.9

Information provided to the schools and districts about holds or food recalls (n = 54)

USDA Foods hold/recall notice 96.3

Product name and information 90.7

Contact information for questions 88.9

Product disposition/disposal instructions 88.9

Press release regarding the hold or recall 79.6

Other 16.7

Procedures or guidelines for when there is a USDA Foods recall (n = 54)

State-established procedures or guidelines 74.1

School district-established procedures or guidelines 57.4

Other 31.5

Time frame schools and districts are expected to respond to a USDA Foods recall (n = 52)1

On the day the notice is received (within 24 hours) 67.3

Within 2 days (24 to 48 hours) 26.9

Within 1 week 1.9

Other 3.9

Information schools and districts are expected to report to the state when there is a 

USDA Foods recall (n = 53)1

Location and quantity of the product in storage 81.1

Actions taken 81.1

Amount of the product already consumed 69.8

Reimbursable costs 56.6

Other 15.1

1 

n is less than 54 due to item non-response. 

Data Source: State CN Director Survey 2011, questions D6, D7, D8, D9, D10, D11 and D12.
179

Nutritional Standards 

 Although states can mandate stricter nutrition standards for school meals, in SY 2011-12 less 

than a third of them reported having standards that were more stringent than those established by 

the Federal government, as shown in Table VI-3.10.74 Among the 16 states that claimed to have 

stricter standards and responded to the questions about those standards, 9 had standards regarding 

dietary fat; and 8 each had standards for sugar, sodium, and some other nutrient. Additionally, 11 of 

these states reported having a maximum number of calories for snack and à la carte items. 

Table VI-3.10. Nutritional Standards for Food and Beverages Offered in School Meals, SY 

2011-12

Standards

Percentage of 

states

Among all states, states that have nutrition standards for school meals that are 

stricter than Federal standards (n = 54)

31.5%

Among the states with stricter school meal standards than Federal, the areas 

where state standards are stricter were (n = 16):1

Dietary fat 56.3

Calories from sugar 50.0

Sodium content for snack items 50.0

Other

Maximum calories for snack and à la carte items

50.0

68.8

Among all states, states that have nutritional standards for food and beverages 

in (n = 54):

Vending machines 57.4

À la carte items 53.7

School stores 51.9

Snack bars 50.0

Bake sales 42.6

Among states with nutritional standards for competitive foods (n = 31), 

perceived impact of nutrition standards on participation in the school meals 

program was:

Increased 38.7

Decreased 9.7

No impact 51.6

1 

n is less than the 17 states that had nutritional standards that were stricter than Federal standards due to item non-response. 

Data Source: State CN Director Survey 2011, questions A1 and A1a, A2, A2a. 

 Although only a small share of states believed their standards for school meals were stricter 

than Federal standards, over half of the state CN directors reported that their state had standards for 

foods and beverages sold in school stores and other places besides the breakfast and lunch 

programs. Fifty-seven percent of states had nutritional standards for food sold in vending machines. 

Almost as many states had standards for à la carte choices in the cafeteria (54 percent), food items 

offered for sale in school stores (52 percent), and snack bars (50 percent). Fewer than half the states 

(43 percent) had standards for bake sales. 

 

74 The question wording did not provide guidance on whether to compare state standards to then current Federal standards or to 

proposed standards. 
180

 Among the states that indicated that they had standards for foods sold on school premises 

that were not formally part of the school meals program, most perceived that these standards did 

not have any impact on participation in the school meals program itself (52 percent). However, 39 

percent believed that the presence of state standards for competitive foods has actually increased 

participation in the school meals program. Only 10 percent of states believed that such standards 

encouraged a decrease in participation. 

Charter Schools 

 The number of charter schools in the country, their participation in the NSLP and SBP, and 

whether they operate as a separate SFA, have implication for the programs’ coverage of students in 

need and the efficiency of operations. According to the state CN directors, 37 states had charter 

schools participating in the NSLP, and 35 states had charter schools participating in SBP.75 About 

half of the charter schools are located in five states (Arizona, California, Florida, Pennsylvania, and 

Ohio.) Only Connecticut and Nevada had charter schools that did not also participate in the SBP. 

Table VI-3.11 provides the number of charter schools operating in each state and the number 

participating in NSLP and SBP. 

Overall, 53 out of 54 state CN directors reported a total of 4,762 charter schools. Of the 52 

states that also provided charter school program participation numbers, 68 percent participated in 

NSLP and 58 percent participated in SBP.76, The participation rate among charter schools is 

considerably less than the participation rate among all schools, which is over 90 percent for both the 

SBP and NSLP. Six states (Arizona, Georgia, Maryland, Rhode Island, South Carolina, and 

Tennessee) reported that all charter schools participated in NSLP, and four states (Maryland, Rhode 

Island, South Carolina, and Tennessee) reported that all charter schools participated in SBP. 

 

75 Although Wisconsin reported the number of charter schools in operation, it did not provide the number of charter schools 

participating in NSLP or SBP. Although Pennsylvania reported the number of charter schools participating in NSLP or SBP, it did 

not report the number of charter schools in operation. Hence, the percentages reported in the text above are based on only those 

states that reported the total number of charter schools operating in their state and the total number of charter schools in their state 

participating in NSLP or SBP. 

76 According to the National Alliance for Public Charter Schools, there were 5,618 public charter schools in operation during SY 

2011-12 (http://dashboard.publiccharters.org/dashboard/schools/page/overview/year/2012). The reason for the discrepancy is 

unknown. The number of charter schools can fluctuate from year to year due to new schools opening and schools closing due to 

non-compliance with their charters. The number of states without charter school legislation according to the Alliance is smaller 

than the number of states without charter schools reported by state child nutrition directors. Differences in how terms such as 

“operating” are defined, in speed with which change of status is reported to an advocacy organization versus state officials, and 

different time frame windows may also have contributed to the differences. 
181

Table VI-3.11. Number of Charter Schools Operating in Each State and Participating in NSLP 

and SBP, SY 2011-12

State

Number of charter 

schools in 

operation

Charter schools participating in NSLP Charter schools participating in SBP

Number Percent Number Percent

Alabama 0 0 0% 0 0%

Alaska 27 9 33 7 26

American Samoa 0 0 0 0 0

Arizona 513 389 76 310 60

Arkansas 13 13 100 10 77

California 983 625 64 478 49

Colorado 175 30 17 19 11

Connecticut 16 15 94 0 0

Delaware 22 16 73 14 64

District of Columbia 53 50 94 50 94

Florida 517 375 73 353 68

Georgia 34 34 100 26 76

Hawaii 31 24 77 19 61

Idaho 43 24 56 8 19

Illinois 23 18 78 17 74

Indiana 65 55 85 52 80

Iowa 6 3 50 3 50

Kansas 17 8 47 8 47

Kentucky10 0 0 0 0

Louisiana 78 47 60 46 59

Maine10 0 0 0 0

Maryland 42 42 100 42 100

Massachusetts 72 70 97 70 97

Michigan 256 185 72 151 59

Minnesota 148 121 82 100 68

Mississippi 0 0 0 0 0

Missouri 41 39 95 39 95

Montana10 0 0 0 0

Nebraska10 0 0 0 0

Nevada 30 7 23 0 0

New Hampshire 18 3 17 1 6

New Jersey 75 68 91 64 85

New Mexico 88 57 65 43 49

New York 196 109 56 106 54

North Carolina 100 43 43 43 43

North Dakota10 0 0 0 0

Ohio 355 242 68 231 65

Oklahoma 22 18 82 18 82

Oregon 115 66 57 52 45

Pennsylvania NR 200 -- 200 --

Puerto Rico 0 0 0 0 0

Rhode Island 14 14 100 14 100

South Carolina 12 12 100 12 100

South Dakota10 0 0 0 0

Tennessee 45 45 100 45 100

Texas 194 143 74 152 78

Utah 82 46 56 27 33

Vermont10 0 0 0 0

Virgin Islands 0 0 0 0 0

Virginia 2 0 0 0 0

Washington10 0 0 0 0

West Virginia10 0 0 0 0

Wisconsin 235 NR -- NR --

Wyoming 4 0 0 0 0

Total all states 4,762 3,265 68%

2

2,830 58%

2

The number of charter schools reported by several states differed substantially from the numbers reported by the National Alliance of Public 

Charter Schools. In all cases the SFA reported a smaller number of public charter schools than identified by the National Alliance. 

1 These states do not have legislation permitting charter schools. Maine enacted a law allowing charter schools in 2011.

2 This percentage is based on only those states that reported the total number of charter schools operating in their state and the total number 

of charter schools in their state participating in NSLP or SBP. 

Data Source: State CN Director Survey 2011, question C11a and C11b. 

NR = non-response. 
182

 States reported a mixture of organizational arrangements for charter schools in their state. 

Figure VI-3.2 shows that over half (59 percent) of the states reported that some charter schools 

within the state operated as a separate SFA for purposes of school food operations, while others 

operated as part of a larger SFA. Some of this difference may be explained by the provisions in the 

state charter school law. In some states, charter schools are required by law to be a part of the LEA; 

they are not permitted to operate independent of the chartering authority. Thirty percent of states 

reported that all of their charter schools operated as separate SFAs with respect to school food 

operations, while 11 percent indicated that all charter schools operated as part of a larger SFA. 

Figure VI-3.2. Among Those that Have Charter Schools that Participated in NSLP or SBP, the 

Percentage of States by Various Charter School-SFA Relationships, SY 2011-12

n equals the 37 states that have one or more charter schools that participate in the NSLP or SBP. 

Data Source: State CN Director Survey 2011, question C11c. 

Appendix E, Table E-40 shows for each state the number of charter schools that were 

separate SFAs and the number that were part of a larger SFA. Thirty-three states reported that 1,804 

charter schools (or 39 percent77 of charter schools) operated as separate SFAs with respect to food 

service operations. Twenty-six states reported that 1,421 charter schools (31 percent78 of charter 

schools) were part of the food service operations of a larger SFA. The numbers reported only 

account for 70 percent of the charter schools reported because many states with charter schools in 

the NSLP or SBP did not answer the question about whether the charter schools were separate 

SFAs or part of a larger SFA.78

 

77 This percentage is based on only those states that reported the total number of charter schools operating in their state and the total 

number of charter schools operating in their state as a separate SFA. Minnesota reported the total number of charter schools 

operating in the state but did not report the number of charter schools operating as a separate SFA. Pennsylvania did not report the 

total number of charter schools operating in the state nor the number of charter schools operating as a separate SFA. 

78 It should be noted that while the purpose of this chapter is to provide information on the relationship between charter schools and 

the NSLP/SBP, the state may not be the best source of information about charter schools, which are highly concentrated in 

specific districts. See “A Growing Movement : America’s Largest Charter School Communities; Seventh Annual Edition,” 

http://www.publiccharters.org/data/files/Publication_docs/NAPCS%202012%20Market%20Share%20Report_20121113T12531

2.pdf.

29.7%

10.8%

59.5%

All charter schools 

are separate SFAs

All charter schools 

are part of a larger SFA

Some charter schools 

are separate SFAs and 

some part of a larger SFA
183

VI-4. Training and Technical Assistance 

Background 

 Training, technical assistance, and minimum educational requirements are integral to the 

ability to comply with nutritional standards and to implement Federal, state, and local policies 

regarding school meals. State agencies provide training and technical assistance to SFAs on 

numerous topics. The skills of state agency directors are likely an important factor in determining 

the success and efficiency of administrating the NSLP and SBP at the state level. State agency 

directors are responsible for implementing Federal policies and guidelines and ensuring that SFA 

staff in their states are appropriately trained on those policies. This section explores issues related to 

technical assistance and training offered by state agencies during SY 2011-12. 

Research Questions 

 This section addresses the following research questions:

 What specific topic areas do state agencies include in training and technical assistance programs? 

 How frequently is training or technical assistance provided? Is technical assistance provided routinely or 

only in response to SFA requests? 

 What mechanisms do state agencies use in providing technical assistance (e.g., written materials, 

workshops or courses, discussions during program reviews, etc.)? 

 What new training topics have state agencies offered in the past year? 

Results 

 State agencies provide training and technical assistance on numerous topics related to school 

meals ranging from the safe handling of food through NSLP/SBP regulations and procedures. 

These trainings can be provided in written documents such as manuals or through various forms of 

verbal communication. As Table VI-4.1 shows, states provided some level of training or technical 

assistance in many of the topics identified on the survey questionnaire. 

 Program regulations, recordkeeping, and menu planning were the most frequent training topics. 

All states provided training on program regulations and procedures at least annually. 

Menu planning and recordkeeping were close seconds, with 84 to 87 percent of states 

providing training at least annually, respectively. 

 Food safety plans, other food sanitation and safety topics, and use of commodities were also 

frequently covered but not necessarily by all states. Nearly all states (96 percent) 

provided training on food safety plans with two-thirds (63 percent) providing it at least 

annually. Training on other food sanitation and safety topics was never provided by 13 

percent of the states but 57 percent provided it annually or more often. Use of 
184

commodities was addressed at least annually by 74 percent of states, but 17 percent 

never provided that training. 

 Food purchasing, food preparation, and contracting procedures were training subjects that fewer 

states provided, but still, close to half of the states (46 to 52 percent) addressed these 

topics at least annually. Merchandising was a training topic for fewer than half the states 

and not provided by 28 percent of them. 

 A third of the states provided training on topics that were not listed in the questionnaire. Additional 

training was provided in areas related to monitoring and reviewing CN program 

implementation (e.g., Coordinated Review Effort, School Meals Initiative for Healthy 

Children, new program training, new CN requirements, outreach); administrative issues 

(e.g., customer service, financial management, CN program administration, 

procurement, media communications, new employee training, work simplification, 

personnel management); and implementation of various CN programs (e.g., students 

with special dietary needs, farm to school, salad bars, team nutrition, Healthier US 

School Challenge, standardized recipes, and FFVP). 

Table VI-4.1. Percentage of States Providing School Meal Training and Technical Assistance 

by Topic and Frequency, SY 2011-12

Topic

Percentage of states providing training and technical assistance (n=54):

At least annually Less than annually

Only when 

requested Not provided

Program regulations and procedures 100.0% 0.0% 0.0% 0.0%

Recordkeeping 87.1 1.9 11.1 0.0

Menu planning 83.4 5.6 9.3 1.9

Use of commodities 74.1 0.0 9.3 16.7

Food safety plans 63.0 9.3 24.1 3.7

Other food sanitation and safety 57.4 3.7 25.9 13.0

Food purchasing 51.9 1.9 27.8 18.5

Food preparation 51.9 1.9 29.6 16.7

Contracting procedures 46.4 3.7 31.5 18.5

Merchandising 40.8 3.7 27.8 27.8

Other 27.8 0.0 5.6 66.7

Total states: n 54

Data Source: State CN Director Survey 2011, question E1. 

 Most training, regardless of topic, was provided on an annual basis. Six topics were covered 

on an ‘only when requested’ basis by about a quarter or more of states: food safety plans (24 

percent), other food sanitation and safety (26 percent), food purchasing (28 percent), food 

preparation (30 percent), contracting procedures (32 percent), and merchandising (28 percent). Five 

percent (not shown) of states reported that the number of training sessions decreased over the past 

3 years because of budgetary constraints and changes in staffing resources (e.g., staffing cuts or 

having an insufficient number of trained staff). 

 Table VI-4.2 shows that states used a variety of methods for delivering trainings on the 

various topics. The most common methods of delivering trainings were through workshops and 

courses (100 percent), through written materials such as manuals (98 percent), and during 
185

discussions at the time of program reviews (98 percent).Three-fourths of states also used on-line 

training materials and webinars to provide training. 

 In most instances, there was overlapping or joint responsibility for training. Table VI-4.2 

shows, for example, 94 percent of the states reported that CN office staff were reported to have the 

responsibility, and 56 percent of states indicated that the state CN director was responsible for 

training. Over a third of states identified some “other” source as responsible for the training and 

technical assistance (e.g., CN field staff, contracted trainers, school nutrition consultants, training 

coordinator, cadre trainers, other state agency personnel, contracting with NSFMI, state food and 

nutrition education staff, Department of Public Health, and University Extension Service). 

Table VI-4.2. Percentage of States that Used Various Approaches for Training and Technical 

Assistance, SY 2011-12

Approaches for training and technical assistance Percentage of states

Methods used by states to provide training and technical assistance (n = 54)

Workshops or courses 100.0%

Written materials (e.g., manuals) 98.2

Discussions during program reviews 98.2

On-line training materials 75.9

Webinars 74.1

Other 24.1

Responsibility for providing training and technical assistance to SFA resides with: (n = 54)

State CN director 55.6

Child nutrition office staff 94.4

Other 38.9

Among states offering new training topics during 2011-12 (n = 39), topics included:1

Program regulations and procedures 46.2

Menu planning 35.9

Food preparation 30.8

Other food sanitation and safety 23.1

Record keeping 20.5

Food purchasing 20.5

Contracting procedures 18.0

Food safety plans based on HACCP principles 12.8

Merchandising 12.8

Use of commodities 12.8

Other 59.0

1 

n is less than the 40 states that offered new training topics during 2011-12 due to item non-response. 

Data Source: State CN Director Survey 2011, questions E2, E5, and E7. 

Forty states introduced new training topics during the 2011-12 school year. The 10 topics 

offered as possibilities were the same topics listed in the questions on frequency of training sessions. 

Interestingly, among the states that offered new training, some reported that they had introduced 

new training topics under the four most popular training areas that are covered by virtually all the 

states: food safety (13 percent), menu planning (36), recordkeeping (21 percent), and regulations (46 

percent). This development of new topics in areas already covered by training suggests either that 

these states were responding to changes in program regulations, or they were sensitive to updating 

or improving their training content on important topics. Over half of the states that added training 

offered training on new topics that were not covered in the list of 10 items in the question.
186

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187

Section VII: Conclusions 

SFA and school participation in the NSLP was nearly universal, and participation in the SBP 

was high. Less than 8 percent of students do not have access to these programs. As these programs 

continue to evolve and concern has shifted from malnutrition to healthy eating, SFAs are well 

positioned to implement the new regulations stemming from the HHFKA in many areas. Several of 

the goals of the HHFKA have already been met, including near universal provision of potable water 

at lunch and the promulgation of school food safety plans. Similarly, there is high compliance with 

conducting at least two annual food safety inspections at each school. 

There are a few areas that may prove to be challenging as SFAs will have to make substantial 

changes to fully meet the new requirements, but it appears that many SFAs may have begun the 

transition in advance of the policy implementation. Nearly three-quarters of the SFAs used foodbased menu planning systems, and, although an overwhelming majority of SFAs offer alternative 

foods, many SFAs have operated under local and state policies that regulate these items. 

Additionally, to meet the requirements of the Paid Meal Equity Provision of HHFKA that 

went into effect in July 2011, many SFAs began to raise the prices of paid lunches to bring them in 

line with free-meal reimbursement rates. Similarly, staff training is likely to require significant 

changes, as a large share of SFAs did not previously require specific certifications or licenses for 

their directors. However, this is somewhat mitigated by the fact that the profile of SFA directors’ 

training qualifications exceeded the profile of SFA requirements, and more junior directors tended 

to have higher education levels. 

There are some structural factors that may make rapid change difficult, such as the type of 

kitchen system used within an SFA (e.g., onsite production only versus offsite production only) 

Additionally, SFA size is highly linked to school district size, with half serving fewer than 1,000 

students. As the results show, SFA size is often associated with meal production practices, as it likely 

limits the options available to the director and staff. With over 14,000 SFAs, the system is inherently 

decentralized, and therefore, implementing the HHFKA policy changes will likely require significant 

communication, training, and time. 

FNS and the states have recognized the need for extensive communication and training, and 

all the states provided training and technical assistance at least annually on program regulation and 

procedures. Most states also regularly provided training on other topics critical to implementing the 

provisions of the HHFKA, which should help facilitate implementation. 
188

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189

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U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and 

Evaluation. School Nutrition Dietary Assessment Study-II: Final report (Nutrition Assistance 

Program Report Series, Special Nutrition Programs Report No. CN-01-SNDAIIFR), by 

M.K. Fox, M.K. Crepinsek, P. Connor, and M. Battaglia. Alexandria, VA: April 2001. 

Available at: http://www.fns.usda.gov/ora/MENU/Published/CNP/FILES/sndaII.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition and 

Evaluation. The School Meals Initiative Implementation Study: Third year report (Nutrition 

Assistance Program Report Series, Special Nutrition Programs Report No. CN-02-SMI3), by 

S. Abraham, M. Chattopadhyay, M. Montgomery, D.M. Steiger, L. Daft, and B. Wilbraham. 

Alexandria, VA: June 2002. Available at: 

http://www.fns.usda.gov/ora/menu/published/cnp/files/smiyear3.pdf

U.S. Department of Agriculture, Office of Inspector General Midwest Region. Audit Report: Chicago 

SFA’s accountability and oversight of the NSLP, SBP, and CACFP supper (Report No. 27010-0017-

Ch). Chicago, IL: September 2004. Available at: http://www.usda.gov/oig/webdocs/27010-

17-CH.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Analysis, Nutrition, and 

Evaluation. Evaluation of the School Breakfast Program Pilot Project: Final report (Nutrition 

Assistance Program Report Series, Special Nutrition Programs Report No. CN-04-SBP), by 

L.S. Bernstein, J.E. McLaughlin, M.K. Crepinsek, and L.M. Daft.. Alexandria, VA: 

December 2004. Available at: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/SBPPFinal.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research, Nutrition and 

Analysis. NSLP/SBP Access, Participation, Eligibility, and Certification Study—Erroneous payments 

in the NSLP and SBP, Vol. I: Study findings (Nutrition Assistance Program Report Series, 

Special Nutrition Program Report No. CN-07-APEC), by M. Ponza, P. Gleason, L. Hulsey, 

and Q. Moore. Alexandria, VA: November 2007. Available at: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/apecvol1.pdf
192

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research, Nutrition, and 

Analysis. School Nutrition Dietary Assessment Study-III, Summary of findings, by A. Gordon and 

M.K. Fox. Alexandria, VA: November 2007. Available at: http://www.mathematicampr.com/publications/redirect_pubsdb.asp?strSite=pdfs/SNDA3summ.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research, Nutrition and 

Analysis. School Nutrition Dietary Assessment Study-III, Vol. I: School foodservice, school food 

environment, and meals offered and served (Nutrition Assistance Program Report Series, Special 

Nutrition Program Report No. CN-07-SNDA-III), by A. Gordon, M.K. Crepinsek, R. 

Nogales, and E. Condon. Alexandria, VA: November 2007. Available at: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/SNDAIII-Vol1.pdf 

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research, Nutrition and 

Analysis. School Lunch and Breakfast Cost Study-II, Final report (Nutrition Assistance Program 

Report Series, Special Nutrition Programs Report No. CN-08-MCII), by S. Bartlett, F. 

Glantz, and C. Logan. Alexandria, VA: April 2008. Available at: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/MealCostStudy.pdf

U.S. Department of Agriculture, Food and Nutrition Service. Contracting with food service management 

companies: Guidance for state agencies. Alexandria, VA: Author, January 2009. Available at: 

http://www.fns.usda.gov/cnd/guidance/FSMCguidance-sa.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Child Nutrition Division, Program 

Analysis Monitoring Branch. Coordinated review effort procedures manual. Alexandria, VA: Author, 

December 2011. Available at: http://www.fns.usda.gov/cnd/guidance/CREmanual.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis. School 

Nutrition Dietary Assessment Study-IV: Summary of findings, by M.K. Fox and E. Condon. 

Alexandria, VA, November 2012. Available at: 

http://www.fns.usda.gov/Ora/menu/Published/CNP/FILES/SNDA-IV_Findings.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis. School 

Nutrition Dietary Assessment Study-IV, Vol. I: School foodservice operations, school environments, and 

meals offered and served (Child Nutrition Programs Report No. CN-12-SNDA), by M.K. Fox et 

al. Alexandria, VA: November 2012. Available at: http://www.mathematicampr.com/publications/PDFs/nutrition/snda-iv_vol1.pdf

U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and Analysis. School 

Nutrition Dietary Assessment Study-IV, Vol. II: Sampling and data collection methods (Child Nutrition 

Programs Report No. CN-12-SNDA), by J. Hall, E. Zeidman, M.K. Crepinsek, and E. 

Condon. Alexandria, VA: November 2012. Available at: http://www.mathematicampr.com/publications/PDFs/nutrition/snda-iv_vol2.pdf

U.S. Department of Agriculture, Food and Nutrition Service. Interim Final Rule. 7 CFR Parts 210 

and 220. National School Lunch Program and School Breakfast Program: Nutrition 

Standards for All Foods Sold in School as Required by the Healthy, Hunger-Free Kids Act 

of 2010. Federal Register, Vol. 78, No. 125, June 28, 2013. Available at: 

http://www.gpo.gov/fdsys/pkg/FR-2013-06-28/pdf/2013-15249.pdf
Appendix A 

State Child Nutrition (CN) Director Survey 2011 

A-1 
A-2 
A-3 
A-4 
A-5 
A-6 
A-7 
A-8 
A-9 
A-10
A-11
A-12
A-13
A-14
A-15
A-16
A-17
A-18
A-19
A-20
A-21
A-22
Appendix B 

School Food Authority (SFA) Director 

Survey 2011 

B-1 
B-2 
B-3 
B-4 
B-5 
B-6 
B-7 
B-8 
B-9 
B-10
B-11
B-12
B-13
B-14
B-15
B-16
B-17
B-18
B-19
B-20
B-21
B-22
B-23
B-24
B-25
B-26
B-27
B-28
B-29
B-30
B-31
B-32
B-33
B-34
B-35
B-36
B-37
B-38
B-39
B-40
B-41
B-42
Appendix C 

Weighting Procedures for the Base-Year 

Survey of School Food Authorities 

C-1 

Weighting Procedures for the Base-Year Survey of 

School Food Authorities 

 This appendix summarizes the procedures used to weight the sample of SFAs included in 

the base-year (Round 1) SFA survey analysis files. Both full-sample weights and a series of replicate 

weights designed for variance estimation purposes were constructed. We first describe the 

construction of the base weights. Next, we describe the procedures used to adjust the base weights 

for survey nonresponse. Finally, we describe the procedures used to create a series of jackknife 

replicate weights for variance estimation. 

Construction of Full-Sample SFA Weights 

Initial Base Weights 

 A stratified sample design was used to select the SFA sample for the SN-OPS evaluation 

(refer to SN-OPS project sampling memo 6 dated Feb. 24, 2011, for details about the sample 

selection process). Although explicit strata defined by a cross-classification of 7 categories of SFA 

enrollment size, 3 categories of poverty status, and 7 FNS regions were specified for sample 

selection purposes, the sampling rates varied only by size class (see Attachment C.1). The base 

weight for sample SFA i in SFA size class h was therefore computed as: 

 

 = 1/ (1) 

where = the sampling rate used to select SFAs in size class h. The base weights are often 

referred to as “unbiased” weights because weighted totals using the base weights are theoretically 

unbiased in the absence of survey nonresponse. The values of the sampling rates used to select the 

SN-OPS sample along with the corresponding base weights assigned to the sampled SFAs are 

summarized in Table C-1.

Special Cases 

 Two types of situations required special procedures to assign the base weights. The first 

involved SFAs consisting of multiple school districts for which the selected SFA could not provide a 

single consolidated report covering all of the school districts under its supervision. The second 

involved a sampled SFA that merged with another SFA in the sampling frame. We describe the ways 

in which these cases were handled below. 
C-2 

Table C-1. Base Weights for the SN-OPS SFA Sample 

SFA enrollment

size class (h)

Number of SFAs in 

sampling frame

Number of SFAs 

selected for sample

Sampling

rate

Base

weight

Under 1,000 7,632 447 0.0589 16.99 

1,000 to 2,499 3,297 366 0.1101 9.08 

2,500 to 4,999 1,945 310 0.1612 6.20 

5,000 to 9,999 1,043 237 0.2280 4.39 

10,000 to 24,999 594 210 0.3483 2.87 

25,000 to 99,999 260 172 0.6582 1.52 

100,000 or more 26 26 1.0000 1.00 

TOTAL 14,797 1,768 --- ---

Multidistrict SFAs 

 There were 3 instances where the originally sampled SFA consisted of more than 1 

independent school district. Of these 3, 2 were sampled as individual SFAs in the sampling frame. 

One of these served 5 school districts, and the other served 3 districts. Ordinarily, such SFAs would 

be asked to provide a single report that covered all of their constituent districts. However, in both of 

these instances, the originally sampled SFA could not provide the required consolidated report. 

Thus, the individual school districts were contacted separately for data collection, bringing the total 

number of SFAs fielded for data collection in the base year to 1,774. 

 For the 2 multidistrict SFAs described above, each of the individual school districts 

associated with the SFA received the same base weight as the originally sampled SFA; that is, the 

base weight for district d in sample SFA i in SFA size class h was computed as: 

 

 = 1/ (2) 

where = the sampling rate originally used to select the SFA in size class h. 

 The third instance involved 2 school districts in Los Angeles (the Los Angeles Unified 

School District and the Los Angeles County Board of Education) combined as a single unit for 

sampling purposes based on linkage information provided by FNS. Like the above two cases, the 

individual districts comprising the original combined sampling unit were able to report their data 

separately. However, since the two districts had been combined at the time of sampling, they are 

treated as a single sampling unit, with each of the two component districts receiving the same base 

weight. 

Merged SFAs 

 There was 1 instance where a sampled SFA merged with another SFA in the sampling frame. 

In this case, the merged entity could have been selected for the study sample if either of the 

individual SFAs had been sampled. The 2 SFAs that merged were in the same SFA size stratum. To 

reflect the multiple chances of selection, the base weight of the merged SFA m in size class h was 

computed as: 
C-3 

 

 = 1/ (3) 

where = = the sampling rate associated with the 2 SFAs in size class h that subsequently 

merged. 

Nonresponse Adjustment 

The base weights are often referred to as “unbiased” weights because weighted totals using 

the base weights are theoretically unbiased in the absence of survey nonresponse. The next step in 

the weighting process was to adjust the base weights defined by formulas 1 to 3 to compensate for 

nonresponse in the base-year survey. The adjustments were made as described in this section. 

 Table C-2 summarizes the distribution of the SFA sample by six response-status groups. 

Note that 73 of the 252 “partial completes” (cases with a final result code of 2) completed 50 

percent or more of the survey sections and are considered to be sufficiently complete for analysis 

purposes. Though a distinction is made in the receipt control system between refusals and other 

nonrespondents, together they make up the group of survey nonrespondents for weighting 

purposes. All nonresponding cases are considered to be eligible SFAs. The small number of 

ineligible SFAs are primarily closed or inactive SFAs. 

Table C-2. Distribution of the SFA Sample by Survey Response Status 

Response status group Final result codes

Number of SFAs in 

sample

1a. Complete 4 1,327 **

1b. Partial complete (50%+ comp. sections)* 2 73

1c. Partial completes (<50% comp. sections)* 2 179

2a. Refusal 7-10 18

2b. Other nonrespondent 0, 1 168

3. Ineligible 12 9

Total 1,774

* Out of a total of 252 partial completes, 73 completed 50 percent or more of the survey sections and are considered to be “respondents” for 

the purposes of weighting and analysis. 

** The combined SFA consisting of 2 SFAs in Los Angeles is counted as 1 SFA in this table (see discussion under Multidistrict SFAs).

 The purpose of the adjustment was to compensate for differential nonresponse losses by 

distributing a portion of the base-weighted count of the nonresponding cases (excluding the 

ineligibles) to the responding cases in the sample. The nonresponse adjustment had the effect of 

distributing the weight of the cases in response-status groups 1c (partial completes with less than 50 

percent of the sections completed), 2a (refusals), and 2b (other nonrespondents) to response-status 

groups 1a and 1b defined in Table C-2. The nine ineligible cases were excluded from the adjustment. 

 To be effective in reducing potential nonresponse biases, the nonresponse adjustment was 

made within subsets of SFAs (or “weighting classes”) expected to have similar propensities for 

responding to the survey. We used a CHAID analysis (Chi-square Automatic Interaction Detector) 

to identify subsets of SFAs in which the predicted probabilities of response were similar. 

To conduct the CHAID analysis, the “dependent” variable for a sampled SFA was defined 

by the zero-variable: 
C-4 

Y = 

 

 

 In addition to the variables used in sample stratification (i.e., SFA size, SFA poverty status, 

and FNS region), we also used SFA characteristics available in the FNS-742 sampling frame and 

selected district-level variables from the Common Core of Data (CCD) Local Education Agency 

Universe Survey as potential predictor variables in the CHAID analysis (see Attachment B.2). 

 The output from the CHAID analysis was a tree diagram that defined the final cells (labeled 

r = 1, 2, ..., R) used in the nonresponse adjustment. Table C-3 summarizes the 12 nonresponse 

adjustment cells determined by the CHAID analysis. It can be seen that the weighted response rates 

varied from around 62 percent to over 99 percent across the 12 adjustment cells. The weighted 

response rates shown in Table D.3 are relevant because they provide a measure of the potential 

impact of nonresponse on weighted estimates derived from the survey. 

Next, a nonresponse adjustment factor, , was computed as the inverse of the weighted 

response rate in final cell r: 

 = 

 

 

 

 

 

 (4) 

where the sum of base weights in the numerator extended over the 

 eligible sampled SFAs in 

final cell r, while the sum of base weights in the denominator extended over the 

 responding 

SFAs in final cell r. 

Table C-3. Definition of Nonresponse Adjustment Cells 

Nonresponse 

adjustment 

cell Definition of cell based on CHAID analysis*

Weighted 

response 

rate**

1 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 1, 2 75.1%

2 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 3, 9, sfapov = 1, 3, ap_fr_el = 1, 2 65.9

3 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 3, 9, sfapov = 1, 3, ap_fr_el = 3 87.8

4 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 3, 9, sfapov = 2 92.6

5 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 4, sfa_lev = 1, 2, 9 86.4

6 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 4, sfa_lev = 3, pct_wh = 1, 2 65.1

7 region = 1, 2, 3, 4, 7, type08 = 1, minstat = 4, sfa_lev = 3, pct_wh = 3 79.7

8 region = 1, 2, 3, 4, 7, type08 = 2, 4, 5, 7, 9 61.8

9 region = 5, 6, pct_ai = 1, 2, pct_bk = 1 77.1

10 region = 5, 6, pct_ai = 1, 2, pct_bk = 2, 3 89.8

11 region = 5, 6, pct_ai = 3, sfapov = 1, 3 99.6

12 region = 5, 6, pct_ai = 3, sfapov = 2 90.9

* See Attachment B.2 for definitions of variables used above to construct nonresponse adjustment cells. 

** Computed using base weights. 
C-5 

 The final nonresponse-adjusted weight for the ith responding SFA in cell r was computed as: 

 

 =  (5) 

Replicate Weights for Variance Estimation 

 The sampling rates used to select the SFA samples varied widely by enrollment size (see 

Table C-1). For example, SFAs with 100,000 or more students were selected with certainty (i.e., 

probability 1), while smaller SFAs were selected at rates ranging from 1 in 17 to 1 in 1.5. For strata 

in which the sampling rates are relatively high, the impact of the finite population correction (FPC) 

on sampling variances can be appreciable. For this reason, a form of jackknife replication referred to 

as the JKN method was used to construct the replicates. 

 To create the jackknife replicates, we first created 6 variance strata, 1 for each level of SFA 

enrollment size (excluding the 26 SFAs in the largest enrollment size class that were selected with 

certainty). Within variance stratum h, we created variance units, where a variance unit is a 

systematic sample of the full sample within the stratum. We created a total of 100 variance units 

consisting of roughly equal numbers of SFAs spanning the 6 variance strata. Next, we created 100 

jackknife replicates by deleting a specified variance unit in stratum h and then multiplying the 

weights of the remaining units in that stratum by a factor of ( -1)/ , where 

is the number of 

variance units in the stratum. To complete the construction of the given replicate, the weights of the 

SFAs in the deleted variance unit were set to 0 while the weights of the SFAs in variance units in the 

other 5 strata were set equal to the full-sample base weights. This process was repeated for all 100 

variance units to create a total of 100 jackknife replicates. 

Table C-4. JKN and FPC Factors to Be Used for Variance Estimation 

Variance 

stratum

No. of variance units 

used to 

form replicates 

in variance 

stratum JKN factor FPC factor*

Replicates to 

which factors 

are applied

1 25 0.960000 0.9558 1 to 25

2 21 0.952381 0.9117 26 to 46

3 17 0.941176 0.8766 47 to 63

4 13 0.923077 0.8219 64 to 76

5 12 0.916667 0.6987 77 to 88

6 12 0.916667 0.4423 89 to 100

* FPC is computed as 1 minus the effective sampling rate, 

  /  , where  = the number of responding SFAs in variance 

stratum h, and 

 is the corresponding estimated number of eligible SFAs in the frame. 

To derive the required replicate weights, the entire weighting process described above was 

applied separately to each replicate, resulting in a set of 100 replicate-specific weights for each 

responding SFA. Together with the full-sample weight, the replicate weights can be used to calculate 

the sampling errors of survey-based estimates using the grouped jackknife variance estimator 
C-6 

described in Rust (1986) and Wolter (1985).79 The grouped jackknife estimator, appropriately 

modified to reflect the within-stratum FPC factors, is given by the formula: 

vGJ(

^

y

) = 















 

 

 h

h

L

h

h

l

l

f

1

)1(

1

^ 2

1

^

)

_ ( yy

hl

i

 ih



(6) 

where 

^

y

is an estimated total based on the full stratified sample of SFAs, 

^

y

ih is the corresponding 

estimate in which the ith subsample (referred to as a “dropout” group) in stratum h has been 

omitted, lhis the number of drop-out groups in stratum h, and fhis the sampling fraction used to 

select SFAs in stratum h. The term ( -1)/ in formula 6 is referred to as the JKN factor. The 

term (1- ) is the corresponding FPC. Both factors are applied to particular sets of replicate 

weights as indicated in Table B-4. See WesVar 4.3 User’s Guide 

(http://www.westat.com/Westat/pdf/wesvar/WV_4-3_Manual.pdf ) for examples of the use of the 

JKN and FPC factors in variance estimation. 

 

79 Rust, K. Efficient replicated variance estimation. In Proceedings of the Section on Survey Research Methods, American Statistical 

Association, 1986, pp. 81-87; and Wolter, K. Introduction to Variance Estimation. New York: Springer-Verlag, 1985, p. 183. 
C-7 

ATTACHMENT C.1

SN-OPS Sampling Frame, Sample Sizes, and Sampling Rates by Stratum 

* Based on percentage of students eligible for free or reduced-price lunch. 

STRATUM SFA Enrollment Size SFA poverty status* FNS Regional Office

No. SFAs in 

frame

No. SFAs in 

sample

Sampling

rate

1 1. Less than 1,000 1. <30 1 Northeast 271 0.058875 16

2 2 Mid Atlantic 179 0.058875 10

3 3 Southeast 23 0.058875 2

4 4 Midwest 322 0.058875 19

5 5 South West 42 0.058875 2

6 6 Mountain Plains 329 0.058875 19

7 7 Western 96 0.058875 6

8 2. 30-59 1 Northeast 367 0.058875 22

9 2 Mid Atlantic 175 0.058875 10

10 3 Southeast 51 0.058875 3

11 4 Midwest 904 0.058875 53

12 5 South West 500 0.058875 29

13 6 Mountain Plains 1,093 0.058875 65

14 7 Western 419 0.058875 25

15 3. 60+ 1 Northeast 124 0.058875 7

16 2 Mid Atlantic 176 0.058875 10

17 3 Southeast 161 0.058875 9

18 4 Midwest 664 0.058875 39

19 5 South West 800 0.058875 47

20 6 Mountain Plains 366 0.058875 21

21 7 Western 570 0.058875 33

22 2. 1,000 to 2,499 1. <30 1 Northeast 277 0.110146 31

23 2 Mid Atlantic 183 0.110146 20

24 3 Southeast 7 0.110146 1

25 4 Midwest 276 0.110146 30

26 5 South West 24 0.110146 3

27 6 Mountain Plains 91 0.110146 10

28 7 Western 44 0.110146 5

29 2. 30-59 1 Northeast 185 0.110146 21

30 2 Mid Atlantic 192 0.110146 21

31 3 Southeast 103 0.110146 11

32 4 Midwest 610 0.110146 67

33 5 South West 178 0.110146 20

34 6 Mountain Plains 199 0.110146 22

35 7 Western 143 0.110146 16

36 3. 60+ 1 Northeast 12 0.110146 1

37 2 Mid Atlantic 46 0.110146 5

38 3 Southeast 195 0.110146 22

39 4 Midwest 145 0.110146 16

40 5 South West 212 0.110146 23

41 6 Mountain Plains 56 0.110146 7

42 7 Western 119 0.110146 14
C-8 

ATTACHMENT C.1 (continued) 

SN-OPS Sampling Frame, Sample Sizes, and Sampling Rates by Stratum 

* Based on percentage of students eligible for free or reduced-price lunch. 

STRATUM SFA Enrollment Size SFA poverty status* FNS Regional Office

No. SFAs in 

frame

No. SFAs in 

sample

Sampling

rate

43 3. 2,500 to 4,999 1. <30 1 Northeast 240 38 0.1612 

44 2 Mid Atlantic 161 26 0.1612 

45 3 Southeast 7 0.1612 1

46 4 Midwest 169 27 0.1612 

47 5 South West 15 0.1612 3

48 6 Mountain Plains 32 0.1612 5

49 7 Western 45 0.1612 8

50 2. 30-59 1 Northeast 77 13 0.1612 

51 2 Mid Atlantic 109 17 0.1612 

52 3 Southeast 120 19 0.1612 

53 4 Midwest 218 35 0.1612 

54 5 South West 104 17 0.1612 

55 6 Mountain Plains 79 12 0.1612 

56 7 Western 97 15 0.1612 

57 3. 60+ 1 Northeast 9 0.1612 1

58 2 Mid Atlantic 21 0.1612 3

59 3 Southeast 171 27 0.1612 

60 4 Midwest 68 11 0.1612 

61 5 South West 87 14 0.1612 

62 6 Mountain Plains 18 0.1612 3

63 7 Western 98 15 0.1612 

64 4. 5,000 to 9,999 1. <30 1 Northeast 78 18 0.2280 

65 2 Mid Atlantic 69 16 0.2280 

66 3 Southeast 8 0.2280 2

67 4 Midwest 105 24 0.2280 

68 5 South West 10 0.2280 2

69 6 Mountain Plains 27 0.2280 6

70 7 Western 49 11 0.2280 

71 2. 30-59 1 Northeast 38 0.2280 9

72 2 Mid Atlantic 59 14 0.2280 

73 3 Southeast 93 21 0.2280 

74 4 Midwest 77 17 0.2280 

75 5 South West 43 10 0.2280 

76 6 Mountain Plains 32 0.2280 7

77 7 Western 84 19 0.2280 

78 3. 60+ 1 Northeast 12 0.2280 3

79 2 Mid Atlantic 17 0.2280 4

80 3 Southeast 74 16 0.2280 

81 4 Midwest 40 0.2280 9

82 5 South West 58 14 0.2280 

83 6 Mountain Plains 11 0.2280 2

84 7 Western 59 13 0.2280 
C-9 

ATTACHMENT C.1 (continued) 

SN-OPS Sampling Frame, Sample Sizes, and Sampling Rates by Stratum 

* Based on percentage of students eligible for free or reduced-price lunch. 

STRATUM SFA Enrollment Size SFA poverty status* FNS Regional Office

No. SFAs in 

frame

No. SFAs in 

sample

Sampling

rate

85 5. 10,000 to 24,999 1. <30 1 Northeast 17 0.3483 6

86 2 Mid Atlantic 24 0.3483 8

87 3 Southeast 8 0.3483 3

88 4 Midwest 35 13 0.3483 

89 5 South West 12 0.3483 4

90 6 Mountain Plains 18 0.3483 7

91 7 Western 31 11 0.3483 

92 2. 30-59 1 Northeast 9 0.3483 3

93 2 Mid Atlantic 24 0.3483 8

94 3 Southeast 75 26 0.3483 

95 4 Midwest 34 12 0.3483 

96 5 South West 38 14 0.3483 

97 6 Mountain Plains 26 10 0.3483 

98 7 Western 79 28 0.3483 

99 3. 60+ 1 Northeast 12 0.3483 4

100 2 Mid Atlantic 11 0.3483 4

101 3 Southeast 18 0.3483 6

102 4 Midwest 19 0.3483 7

103 5 South West 35 12 0.3483 

104 6 Mountain Plains 8 0.3483 3

105 7 Western 61 21 0.3483 

106 6. 25000-99999 1. <30 1 Northeast 1 0.6582 1

107 2 Mid Atlantic 12 0.6582 8

108 3 Southeast 6 0.6582 4

109 4 Midwest 4 0.6582 2

110 5 South West 9 0.6582 6

111 6 Mountain Plains 12 0.6582 7

112 7 Western 12 0.6582 8

113 2. 30-59 1 Northeast 1 - 0.6582 

114 2 Mid Atlantic 4 0.6582 3

115 3 Southeast 46 30 0.6582 

116 4 Midwest 4 0.6582 2

117 5 South West 18 12 0.6582 

118 6 Mountain Plains 8 0.6582 6

119 7 Western 33 22 0.6582 

120 3. 60+ 1 Northeast 2 0.6582 1

121 2 Mid Atlantic 5 0.6582 4

122 3 Southeast 15 10 0.6582 

123 4 Midwest 9 0.6582 6

124 5 South West 28 19 0.6582 

125 6 Mountain Plains 5 0.6582 3

126 7 Western 26 18 0.6582 

127 7. 100,000+ ALL ALL 26 26 1.0000 

TOTAL 14,797 1,768 
C-10

ATTACHMENT C.2

Variables Used as Potential Predictors of Response Propensity

SFA Sampling Frame Variables 

REGION (SFA regional office): 

1. Northeast 

2. Mid Atlantic 

3. Southeast 

4. Midwest 

5. South West 

6. Mountain Plains 

7. Western 

SFAPOV (SFA F/R lunch percentage categories/poverty status): 

1. Low ( < 30 percent F/RP); 

2. Medium (Between 30 and 59.9 percent F/RP); 

3. High ( ≥ 60 percent F/RP);

SFASIZE (SFA enrollment size): 

1. < 1,000; 

2. 1,000 - 2,499; 

3. 2,500 - 4,999; 

4. 5,000 - 9,999; 

5. 10,000 - 24,999; 

6. 25,000 - 99,999; 

7. 100,000+; 

AP_FR_EL (Number of applications free eligible): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

AP_FR_IN (Number of applications free eligible income): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 
C-11

ATTACHMENT C.2 (continued) 

Variables Used as Potential Predictors of Response Propensity

AP_TR (Number of applications total reduced-price eligible): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

PROVSCH (Dichotomous variable number of provision schools in SFA): 

0. 0 provision schools in SFA; 

1. 1+ provision schools in SFA; 

SCH_SFA (Number of schools in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

ST_FE_CA (Number of students free eligible categorically): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

ST_FE_NV (Number of students free eligible not verified): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

ST_FIE (Number of students free income eligible): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

ST_TR_PE (Number of students total reduced-price eligible): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 
C-12

ATTACHMENT C.2 (continued) 

Variables Used as Potential Predictors of Response Propensity 

ST_T_FE (Number of students total free eligible): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

CCD Variables80

MINSTAT (Percent minority status) 

1. < 5% minority; 

2. 5 to 19.9% minority; 

3. 20 to 49.9% minority; 

4. 50%+ minority; 

9. Not matched or missing in CCD; 

LOCALE (Type of locale): 

1. City; 

2. Suburban; 

3. Town; 

4. Rural; 

9. Not matched or missing in CCD; 

SFA_LEV (Instructional level): 

1. Elementary schools only; 

2. Secondary schools only; 

3. Both elementary and secondary schools; 

9. Not matched or missing in CCD; 

TYPE08 (Education agency type code): 

1. Regular local school district; 

2. Local school district that is a component of a supervisory union; 

3. Supervisory union; 

4. Regional education service agency; 

5. State-operated agency; 

 

80 Sable, J., and Plotts, C. (2010). Documentation to the NCES Common Core of Data Local Education Agency Universe Survey: School Year 2008-

09 (NCES 2010-351). U.S. Department of Education. Washington, DC: National Center for Education Statistics. 

http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2010351.
C-13

ATTACHMENT C.2 (continued) 

7. Charter agency; 

9. Not matched or missing in CCD; 

Variables Used as Potential Predictors of Response Propensity

PCT_AI (Percent American Indian in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

9. Not matched or missing in CCD; 

PCT_AS (Percent Asian in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

9. Not matched or missing in CCD; 

PCT_BK (Percent Black/African American in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

9. Not matched or missing in CCD; 

PCT_HS (Percent Hispanic in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

9. Not matched or missing in CCD; 

PCT_PI (Percent Pacific Islander in SFA): 

Low ( < 25th percentile); 

Medium (Between 25th and 75th percentile); 

High ( > 75th percentile); 

9- Not matched or missing in CCD; 
C-14

ATTACHMENT C.2 (continued) 

PCT_WH (Percent White in SFA): 

1. Low ( < 25th percentile); 

2. Medium (Between 25th and 75th percentile); 

3. High ( > 75th percentile); 

9. Not matched or missing in CCD; 
Appendix D 

Nonresponse Bias Analysis 

D-1 

Nonresponse Bias Analysis 

As specified in the Standards and Guidelines for Statistical Surveys published by the Office of 

Management and Budget (September 2006; http://www.whitehouse.gov/sites/default/files/

omb/inforeg/statpolicy/standards_stat_surveys.pdf ), a nonresponse bias analysis is required if the 

overall unit response rate for a survey is less than 80 percent (Guideline 3.2.9). For the SFA Survey 

conducted under SN-OPS, a sampled SFA is considered to be nonresponding if it did not provide 

sufficiently complete questionnaire data for analysis (e.g., see Appendix C). Under this criterion, the 

overall unweighted and weighted response rates for the SFA survey were 79 and 77 percent, 

respectively, where the weight used in the response rate calculations is the base weight described in 

Appendix C. 

In this appendix, we summarize the findings of an analysis of nonresponse in the survey of 

SFAs. As one of survey responses was completed after the fielding window, we conducted the nonresponse bias analysis on a sample of 1,400 respondents rather than 1,401. The two main goals of 

the analysis are (1) to assess and document the impact nonresponse may have on estimates derived 

from the survey and (2) to inform the construction of sampling weights for analysis that will be 

effective in reducing potential nonresponse biases. As discussed later in this appendix in the section 

Derivation of Nonresponse-Adjusted Weights, the culmination of the analysis was the specification 

of appropriate weighting classes within which to carry out weight adjustments for nonresponse. To 

the extent that the weighting classes are formed using relevant SFA characteristics that are correlated 

with both response propensity and survey responses, we can expect the nonresponse bias in the 

survey estimates using the nonresponse-adjusted weights to be reduced. 

This appendix is divided into eight sections. We first provide an overview of the sample 

design and a brief discussion of the development of the base weights. This is followed by a summary 

of the survey response rates by selected SFA characteristics. Next, we compare the distributions of 

the respondents by selected SFA characteristics with the corresponding distributions of the 

nonresponding SFAs. We then describe the procedures used to adjust the sampling weights to 

compensate for nonresponse, and we assess the effectiveness of the weight adjustments in reducing 

potential nonresponse biases. The last section of the appendix presents a summary and conclusions. 

Sample Design and Construction of Base Weights 

A total of 1,768 SFAs were selected for the survey from a sampling frame constructed from 

the 2009-10 FNS-742 universe file compiled by the FNS. The sample was stratified by 7 categories 

of enrollment size class, 3 categories of poverty status based on the percentage of students eligible 

for free/reduced-price lunch, and the 7 FNS regional offices. SFAs were selected systematically 

within strata at rates that depended on the size class of the SFA. During data collection, it was 

discovered that 2 of the originally sampled SFAs represented multiple school districts that operated 

as independent SFAs. The independent SFAs associated with the original selections were added to 

the SFA sample, bringing the total SFA sample size to 1,774. 

For subsequent weighting purposes, a base weight was calculated for each sampled SFA. The 

base weight, whi, for SFA i in sampling stratum h was computed as whi = 1/Phi, where Phi is the 

corresponding probability of selecting the SFA from the stratum. Under the SFA sample design, Phi
D-2 

varied from 0.06 to 1.0 depending on enrollment size class. The base weights are theoretically 

unbiased in the absence of survey nonresponse. When survey nonresponse is relatively high (e.g., 20 

percent or higher), use of the base weights to derive estimates from the survey can result in serious 

biases. To minimize the potential for nonresponse bias, adjustments were made to the base weights 

to compensate for differential nonresponse losses (see the section Derivation of NonresponseAdjusted Weights, below, and Appendix C for details about the weighting adjustments). 

Response Rates by Selected SFA Characteristics 

To examine the extent to which missing data resulting from nonresponse are “missing at 

random,” we calculated response rates for subsets of sample based on selected characteristics of 

SFAs. The characteristics included SFA enrollment size class, poverty status based on percentage of 

students eligible for free/reduced-price lunch, FNS region, type of LEA, SFA level, minority status 

of SFA, and levels of the number of approved categorically eligible applications on file (i.e., low, 

medium, high based on quartiles). The results are summarized in Table D-1. As indicated in Table 

D-1, 9 of the 1,774 sample SFAs were determined to be ineligible for the survey (e.g., closed, 

inactive, or not an SFA) and were excluded from the calculation of the response rates summarized 

below. The last column of the table shows the p-value of a test of association between response 

status and each of the selected SFA characteristics. A p-value of 0.05 or less indicates that there is a 

statistically significant association between the (weighted) response rate and the specified 

characteristic. 

As can be seen in Table D-1, FNS region, type of LEA, instructional level of SFA, and 

minority status of SFA are all strongly correlated with response status (p-value = 0.006 or less). By 

FNS region, (weighted) response rates are highest in the Southwest and Mountain Plains regions 

(85-90 percent) and lowest in the Northeast and Mid-Atlantic regions (71 percent). By type of LEA, 

the weighted response rates tend to be higher among the “regular” school districts (81 percent) than 

in other types of LEAs (63 percent). By SFA level, response rates for SFAs serving both elementary 

and secondary schools were generally higher (80 percent) than those serving elementary schools only 

(75 percent). By minority status, SFAs with 20-49.9 percent minority populations had higher 

response rates (85 percent) than those in other categories (64-79 percent). For the remaining SFA 

characteristics shown in Table D-1, the unweighted and weighted response rates did not vary 

significantly by the individual categories. 

Comparison of Respondents and Nonrespondents by Selected 

Characteristic 

We also compared the base-weighted distributions of the respondents and nonrespondents 

for the same categories of SFA characteristics shown in Table D-1. The base-weighted distributions 

of responding SFAs (respondent sample) can be compared with the corresponding base-weighted 

distributions of the total sample to obtain a measure of the potential impact of nonresponse on the 

survey-based estimates. These comparisons, which are presented in Table D-2, provide an 

alternative but equivalent way of examining the variation in response rates across selected subgroups 

of the sample. The p-value shown in column 6 of the table corresponds to an overall test of the 

hypothesis that the base-weighted distribution of the respondent sample is the same as the 

distribution of the 
D-3 

Table D-1. Sample Sizes by Response Status, Response Rates, and Test of Association 

Between Response Status and Selected Characteristics of Sampled SFAs 

SFA characteristic

Sample sizes by response status Unweighted 

response 

rate

Weighted 

response

rate1

Test of 

association 

(p-value)2Total Response Nonresponse Ineligible

All SFAs 1,774 1,4003365 9 79.32 77.44

SFA enrollment size class 0.114

Under 1,000 447 332 108 7 75.45 75.45

1,000-2,499 368 292 75 1 79.56 79.56

2,500-4,9999 314 243 71 0 77.39 77.38

5,000-9,999 237 185 51 1 78.39 78.39

10,000-24,999 210 179 31 0 85.24 85.24

25,000 or more 198 169 29 0 85.35 85.03

Percent of students eligible for 

free or reduced-price lunch 0.094

Less than 35% 459 348 110 1 75.98 74.64

35%-59% 802 650 149 3 81.35 80.24

60 % or more 513 402 106 5 79.13 75.39

FNS region 0.000#

Northeast (1) 202 147 54 1 73.13 70.63

Mid-Atlantic (2) 196 142 53 1 72.82 70.75

Southeast (3) 225 183 41 1 81.70 76.92

Midwest (4) 390 278 108 4 72.02 71.04

Southwest (5) 254 237 17 0 93.31 90.22

Mountain Plains (6) 215 188 26 1 87.85 85.93

Western (7) 292 225 66 1 77.32 75.87

Type of LEA 0.000#

Regular district 1,507 1,233 272 2 81.93 81.29

All other codes 118 72 41 5 63.72 62.98

Not available 149 95 52 2 64.63 63.60

SFA level 0.006

Elementary only 171 130 38 3 77.38 75.07

Secondary only 48 35 11 2 76.09 78.02

Combined 1,403 1,139 263 1 81.24 80.03

Not available 152 96 53 3 64.43 63.31

Minority status of SFA 0.002

Less than 5% minority 269 207 62 0 76.95 78.56

5%-19.9% minority 433 343 89 1 79.40 78.16

20%-49.9% minority 424 367 56 1 86.76 85.47

50%+ minority 485 380 101 4 79.00 76.16

Not available in CCD 163 103 57 3 64.38 63.63

Number approved categorically 

eligible applications 0.716

1st quartile 251 190 58 3 76.61 75.81

2

nd or 3rd quartiles 701 546 152 3 78.22 78.03

4

th quartile 822 664 155 3 81.07 77.79

CCD = Common Core of Data LEA universe file 

# Rounds to zero. 

1 Weighted response rates are calculated using base weights. 

2 Test of association between response status and SFA characteristic. 

3

 The non-response bias analysis was conducted on 1400 responses rather than the final 1,401 responses because there were delays in 

obtaining the last response. 

NOTE: Detail may not sum to totals because of rounding. SFA characteristics are based on data available on the frame at the time of sampling 

and may differ from classification variables used in other reports. 
3

D-4

Table D-2. Comparison of Weighted Distributions of Sampled SFAs, by Response Status and Selected Characteristics 

SFA characteristic

Base-weighted data Nonresponse-adjusted data

Percent distribution of sample Relative bias

(percent)1

Test of association 

(p-value)2

Respondents

(percent)

Relative bias

(percent)3

Test of association 

(p-value)4Total Respondents Non-Respondents

All SFAs 100 100 100 100

SFA enrollment size class 0.114 0.522

Under 1,000 50.9 49.6 55.4 -2.6 50.2 -1.3

1,000-2,499 22.7 23.3 20.6 2.8 23.4 3.1

2,500-4,9999 13.3 13.3 13.3 -0.3 13.3 0.2

5,000-9,999 7.1 7.1 6.8 0.5 6.9 -3.3

10,000-24,999 4.1 4.5 2.7 11.1 4.2 3.9

25,000 or more 2.0 2.1 1.3 9.7 1.9 -1.1

Percent of students eligible for 

free or reduced-price lunch 0.094 0.652

Less than 35% 23.3 22.4 26.2 -3.6 23.2 -0.2

35%-59% 45.9 47.5 40.2 3.6 46.5 1.4

60% or more 30.9 30.0 33.7 -2.6 30.3 -1.9

FNS Region 0.000# 0.439

Northeast (1) 12.0 11.0 15.7 -8.8 12.2 1.3

Mid-Atlantic (2) 9.7 8.9 12.6 -8.6 9.5 -2.3

Southeast (3) 8.0 7.9 8.2 -0.6 8.3 4.0

Midwest (4) 24.7 22.7 31.8 -8.3 23.7 -4.4

Southwest (5) 15.1 17.6 6.5 16.5 15.0 -0.2

Mountain Plains (6) 16.4 18.2 10.2 11.0 16.4 0.2

Western (7) 14.0 13.8 15.0 -2.0 14.9 6.0

Type of LEA 0.000# 0.619

Regular district 78.6 82.5 65.2 5.0 79.0 0.5

All other codes 10.8 8.7 17.6 -18.7 10.3 -3.8

Not available 10.6 8.7 17.1 -17.9 10.6 0.1

SFA level 0.006 0.829

Elementary only 14.3 13.9 15.8 -3.1 14.1 -1.9

Secondary only 3.1 3.1 3.0 0.8 3.4 9.0

Combined 71.7 74.1 63.5 3.3 71.7 0.0

Not available 10.9 8.9 17.7 -18.2 10.8 -0.3
3

D-5

Table D-2. Comparison of Weighted Distributions of Sampled SFAs, by Response Status and Selected Characteristics 

(continued) 

SFA characteristic

Base-weighted data Nonresponse-adjusted data

Percent distribution of sample Relative bias

(percent)1

Test of association 

(p-value)2

Respondents

(percent)

Relative bias

(percent)3

Test of association 

(p-value)4Total Respondents Non-Respondents

Minority status of SFA 0.002 0.731

Less than 5% minority 21.8 22.1 20.7 1.4 22.4 3.0

5%-19.9% minority 26.7 27.0 25.9 0.9 26.3 -1.5

20%-49.9% minority 18.7 20.6 12.0 10.4 18.8 0.9

50%+ minority 20.8 20.4 21.9 -1.7 20.3 -2.0

Not available in CCD 12.1 9.9 19.5 -17.9 12.1 -0.1

Number approved categorically 

eligible applications 0.716 0.399

1st quartile 23.8 23.3 25.5 -2.1 23.6 -0.7

2nd and 3rd quartiles 51.3 51.7 49.9 0.8 52.2 1.8

4th quartile 24.9 25.0 24.5 0.4 24.2 -3.0

# Rounds to zero. 

1

 Relative bias defined to be 100*(B-A)/A, where A = base-weighted estimate for total sample and B = base-weighted estimate for respondent sample. 

2

 Test comparing distribution of total sample versus respondent sample using base weights. 

3

 Relative bias defined to be 100*(C-A)/A, where A = base-weighted estimate for total sample and C = nonresponse-adjusted estimate for respondent sample. 

4 Test comparing distribution of respondent sample using nonresponse-adjusted weights with distribution of total sample using base weights. 

NOTE: Detail may not sum to totals because of rounding. SFA characteristics are based on data available in either the sampling frame or Common Core of Data (CCD) files at the time of sampling and 

may differ from classification variables used elsewhere in this report. 
D-6 

total sample for the given characteristic. A p-value of 0.05 or less indicates that the 2 distributions 

are significantly different, which implies that the distribution of respondents is significantly different 

from that of the nonrespondents. Column 5 of the table shows an estimate of the relative bias of the 

percentage of a particular level of a characteristic if no adjustment is made to the base weights to 

compensate for nonresponse. (The tests associated with the p-values shown in the last column of 

this table are discussed in the next section.) 

Overall, there are significant differences between the distributions of the respondents and 

nonrespondents by FNS region, type of LEA, SFA level, and minority status. These are essentially 

the same results presented earlier in Table D-1, but viewed in a different way. For example, by FNS 

region, the respondent sample has a greater percentage of SFAs in the Southwest and Mountain 

Plains regions (17-18 percent) than the total sample (15-16 percent) and a smaller percentage of 

SFAs in the Northeast and Mid-Atlantic regions (9-11 percent) than the total sample (10-12 

percent). This disparity is also reflected in the relatively large spread of the relative biases shown in 

column 5 of the table. Similarly, by type of LEA, the percentage of responding SFAs that are regular 

districts (82 percent) is higher than the percentage of the total sample that are regular districts (79 

percent), reflecting the generally higher response rates for regular SFAs. By SFA level, the 

percentage of responding SFAs that serve both elementary and secondary schools (74 percent) is 

higher than the corresponding percentage for the total sample (72 percent), reflecting the generally 

lower response rates among the nonregular SFAs. By minority status, a greater percentage of 

responding SFAs have 20-49.9 percent minority populations (21 percent) than the total sample (19 

percent). It is noteworthy that both the magnitude and variation of the relative biases shown in 

column 5 tend to be large for those characteristics that are significantly correlated with response 

status. 

Derivation of Nonresponse-Adjusted Weights 

As noted in the previous section, the base-weighted distribution of the responding SFAs 

differed significantly from the total sample for a number of characteristics. In general, weighting 

adjustments are used to compensate for any distributional differences resulting from differential 

response rates. To be effective in reducing potential nonresponse biases, the nonresponse 

adjustment should be made within subsets of SFAs (or “weighting classes”) that have similar 

propensities for responding to the survey. We used a CHAID analysis (Chi-square Automatic 

Interaction Detector) to identify subsets of SFAs in which the predicted probabilities of response 

were similar. In addition to the variables used in sample stratification (i.e., SFA size, SFA poverty 

status, and FNS region), we also specified SFA characteristics available in the FNS-742 sampling 

frame and selected district-level variables from the Common Core of Data (CCD) LEA universe file 

as potential predictor variables in the CHAID analysis. The output from the CHAID analysis was a 

tree diagram that defined the final cells used in the nonresponse adjustment. 

Twelve nonresponse adjustment cells were determined by the CHAID analysis. The 

variables used to create the weight adjustment cells included all (or variants) of the variables listed in 

Attachment C.2 of Appendix C). Across the 12 adjustment cells, the weighted response rates ranged 

from around 62 percent to over 99 percent. The nonresponse-adjusted weight, 

 , for the ith 

responding SFA in weighting class k was computed as: 

 

 = (1/ ) 

 

,
D-7 

where 

 is the base weight for the ith responding SFA in weighting class k, and is 

the base-weighted response rate for SFAs in weighting class k. The 

 ’s defined above are the 

final weights used to construct the survey-based estimates presented in this report. For more 

information about the procedures used to construct the final weights, see Appendix C. 

Comparisons Before and After Nonresponse Adjustment for Selected 

Distributions 

The last three columns of Table D-2 summarize results related to distributions of the 

respondent sample using the nonresponse-adjusted weights described above. Column 7 shows the 

(nonresponse-adjusted) weighted distributions. Column 8 shows the corresponding relative bias. 

Column 9 shows the p-value for a test comparing the nonresponse-adjusted weighted distribution in 

column 7 with the corresponding base-weighted distribution in column 2. Although significant 

differences were observed for some characteristics prior to nonresponse adjustment (see column 6), 

after nonresponse adjustment the differences for all of these characteristics have essentially 

disappeared, as can be seen by the small relative biases in column 8 and the nonsignificant p-values 

in column 9. 

Comparisons Before and After Nonresponse Adjustments for 

Estimates of CCD Data Items 

Another way of gauging the effectiveness of the weighting procedures is to compare 

weighted estimates of characteristics available from the sampling frame for both responding and 

nonresponding SFAs before and after the nonresponse adjustments. Table D-3 summarizes such a 

comparison. The variables presented in these tables are a subset of the items available (or derived) 

from the FNS-742 sampling frame. The p-value given in column 6 of the table corresponds to a test 

comparing the base-weighted estimate for respondents with the corresponding base-weighted 

estimate for the total sample (which is an unbiased estimate of the true population value). The pvalue shown in the column 9 of the tables corresponds to a test comparing the nonresponseadjusted estimate for respondents with the corresponding base-weighted estimate for the total 

sample. In Table D-3, the five items listed under “numeric variables” are estimated means of 

selected counts reported in the FNS-742 form. The two items under “attribute variables” are 

estimated percentages derived from data reported in the FNS-742 form. 

For all of the numeric variables presented in Table D-3, the base-weighted mean of the 

respondents is significantly different from the base-weighted mean of the total sample (p-value = 

0.007 or less in column 6 of the table). The corresponding relative biases are positive (indicating that 

responding SFAs tend to report higher FNS-742 counts than nonresponding SFAs) and range from 

5.3 percent to 8.4 percent. However, after nonresponse adjustment, it can be seen in column 8 of 

the table that the relative biases have been reduced considerably, ranging from 0.1 percent to 3.2 

percent. Although some of the differences remain significant at the 0.05 level, none are significant at 

the 0.01 level (p-value = 0.016 or greater in column 9). This suggests that the nonresponse 

adjustments used to create the final SN-OPS weights can be effective in reducing the bias of survey 

estimates that are correlated with the count variables listed in Table D-3.
D-8 

A similar comparison was made for the two attribute variables shown in Table D-3. In both 

cases, there were no significant differences between the respondents and the total sample before 

nonresponse adjustment (column 6) and after nonresponse adjustment (column 9). 

Table D-3. Comparison of Weighted Estimates of FNS-742 Frame Statistics for Sampled 

SFAs, by Response Status and Selected SFA Characteristics 

FNS-742 data item Total Respondents

NonrespondentsRelative 

bias1T-test2

Estimates of FNS742 data items for 

respondents

Relative 

bias3T-best4

1 2 3 4 5 6 7 8 9

Numeric variables (Mean) (Percent) (p-value) (Mean) (Percent) (p-value)

SFA enrollment 3326.74 3569.27 2494.18 7.3 0.000 3424.83 2.9 0.016

Students eligible for free 

or reduced-price lunch 1301.92 1407.73 938.72 8.1 0.000 1342.07 3.1 0.022

Students free eligible not 

verified 546.09 585.33 411.41 7.2 0.000 563.66 3.2 0.042

Number of applications 

free eligible 90.38 95.16 73.97 5.3 0.007 90.49 0.1 0.092

Number of applications 

free eligible income 327.06 354.43 233.12 8.4 0.000 333.95 2.1 0.924

Attribute variables (Percent) (p-value) (Percent) (p-value)

SFAs with provision 

schools 4.2 4.3 3.9 2.4 0.784 4.1 -2.9 0.753

SFAs with applications 

exceeding 75th

percentile 25.0 24.9 25.0 -0.2 0.887 24.2 -3.2 0.848

1

 Relative bias defined to be 100*(B-A)/A, where A = base-weighted estimate for total sample and B = base-weighted estimate for respondent 

sample. 

2

 Test comparing base-weighted estimate of total sample with base-weighted estimate of respondent sample. 

3

 Relative bias defined to be 100*(C-A)/A, where A = base-weighted estimate for total sample and C = nonresponse-adjusted estimate for 

respondent sample. 

4 Test comparing nonresponse-adjusted estimate of respondent sample with base-weighted estimate of total sample. 

Comparisons Before and After Nonresponse Adjustments for Selected 

Survey Results 

The final set of comparisons conducted in the nonresponse bias analysis involved a 

comparison of weighted estimates of selected survey characteristics using the base weights and 

nonresponse-adjusted weights. The results are summarized in Table D-4. The p-value given in this 

table corresponds to a test of the hypothesis that there is no difference between the two weighted 

estimates. The difference between the base-weighted and nonresponse-adjusted estimates was 

statistically significant for 10 out of the 24 meal price variables considered in the analysis. This 

suggests that the use of the nonresponse-adjusted weights will have a non-negligible effect on meal 

price estimates derived from the survey, potentially reducing the bias of such estimates. 
D-9 

Table D-4. Comparison of Weighted Estimates of Select Survey Statistics Before and After 

Nonresponse Adjustment, by Response Status 

Survey variable Base-weighted 

estimates

Nonresponseadjusted estimates Relative bias1

T-test2

Meal Prices (Percent) (p-value)

Full-price breakfast price, elementary $1.18 $1.19 0.3 0.1056

Full-price breakfast price, middle $1.27 $1.27 -0.8 0.3558

Full-price breakfast price, high $1.27 $1.27 -0.5 0.0026

Full-price breakfast price, other $1.21 $1.23 1.4 0.3022

Reduced-price breakfast price, elementary $0.30 $0.30 0.1 0.8528

Reduced-price breakfast price, middle $0.31 $0.30 -1.4 0.6650

Reduced-price breakfast price, high $0.31 $0.30 -0.5 0.8657

Reduced-price breakfast price, other $0.31 $0.31 -0.5 0.3956

Adult breakfast price, elementary $1.76 $1.71 -2.7 0.0076

Adult breakfast price, middle $1.79 $1.74 -2.6 0.0734

Adult breakfast price, high $1.79 $1.74 -2.8 0.0091

Adult breakfast price, other $1.80 $1.78 -1.3 0.4392

Full-price lunch price, elementary $2.01 $2.00 -0.8 0.0055

Full-price lunch price, middle $2.22 $2.21 -0.6 0.0189

Full-price lunch price, high $2.25 $2.21 -1.7 0.0013

Full-price lunch price, other $2.13 $2.15 1.0 0.0266

Reduced-price lunch price, elementary $0.40 $0.40 0.1 0.1151

Reduced-price lunch price, middle $0.40 $0.40 0.2 0.1437

Reduced-price lunch price, high $0.40 $0.40 -0.2 0.0511

Reduced-price lunch price, other $0.41 $0.40 -2.1 0.6669

Adult lunch price, elementary $3.07 $3.05 -0.7 0.0002

Adult lunch price, middle $3.11 $3.09 -0.7 0.0005

Adult lunch price, high $3.11 $3.06 -1.4 0.0012

Adult lunch price, other $3.11 $3.06 -1.7 0.1342

1

 Relative bias defined to be 100*(B-A)/A, where A = base-weighted estimate for respondents and B = nonresponse adjusted estimate for 

respondents. 

2

 Test of difference between base-weighted and nonresponse-adjusted estimates 

Summary and Conclusions 

The overall response rate for the SN-OPS survey of SFAs was 79 percent unweighted and 

77 percent weighted. Response rates varied significantly by FNS region, type of LEA, SFA level, and 

minority status of SFA. To compensate for the differential survey response rates, weight adjustments 

were developed and applied to the base weights using a CHAID analysis to identify appropriate 

weight adjustment classes. In general, such weight adjustments will reduce nonresponse bias if the 

variables used in forming the weight adjustment classes are correlated with response propensity (the 

probability that a sampled SFA will respond to the survey) and with the characteristics obtained 

from the survey. 

There are reasons to believe that the nonresponse-adjusted weights developed for the survey 

of SFAs will be reasonably effective in reducing potential biases. First, the weight adjustments 

removed most of the disparities between the weighted distributions of the respondents and the 

distributions of the total sample. Second, a comparison of weighted estimates of selected 

characteristics available in the FNS-742 files showed that the weight-adjustment procedures reduced 

the difference between the nonresponse-adjusted estimate for the respondent sample and the 

corresponding base-weighted estimate for the total sample. Further evidence of the potential bias 
D-10

reductions is given by a comparison of weighted estimates of selected survey items before and after 

nonresponse adjustment, where it was found that for 10 out of 24 meal price variables, there was a 

statistically significant difference between the base-weighted and nonresponse-adjusted estimates. 

Although it is possible to conduct more in-depth analysis and possibly refine the weighting 

procedures, the results of this analysis suggest that any potential improvements will be modest. 
Appendix E 

Supplementary Tables 

E-1 

Table E-1. Educational Requirements and Years of Experience for State CN Directors, 

SY 2011-12

Percentage of states

Minimum education requirement for the State CN Director (n = 49)1

High school 6.1%

Some college, no degree 0.0

Associate’s degree 0.0

Bachelor’s degree 51.0

Graduate degree 40.8

There is no requirement 2.0

Highest grade or year of schooling State CN Director completed (n = 53)2

High school diploma 0.0

Some college, no degree 1.9

Associate’s degree 0.0

Bachelor’s degree 30.2

Graduate degree 67.9

State CN Director’s major in college (n = 53)3

Business 18.9

Education 30.2

Food service administration/management 18.9

Home economics/family and consumer services 24.5

Nutrition/dietetics 47.2

Other 34.0

Years of experience in food service prior to position as the CN Director (n = 43)4

1-2 years 7.0

3-5 years 2.3

6-10 years 27.9

11 or more years 62.8

Tenure as State CN Director (n = 54)

Less than 1 year 14.8

1-2 years 13.0

3-5 years 29.6

6-10 years 24.1

11 or more years 18.5

1 Five states did not answer the question about the minimum education requirement. 

2 One state did not answer the question about the highest grade completed. 

3 One state did not answer the question about major in college. 

4 Eleven SFAs did not answer the question about years of experience in food service. 

Data Source: State CN DIretctor Survey, question F3. 
E-2 

Figure E-1. Safety Topics on Which Food Service Employees Have Been Trained 

Percentages based on a weighted response of 14,383 (unweighted 1,383). 

Source: SFA Director Survey 2011, question 12.16. 

98.3

97.2

96.1

95.5

95.2

94.7

94.6

94.2

93.9

93.9

92.9

92.4

90.4

87.6

0 20 40 60 80 100

Personal hygiene, proper 

hand washing

Kitchen sanitation

Safe food handling at storage

Proper thermometer

use and maintenance

Safe food handling at preparation

Safe food handling at receiving

Safe food handling at cooking

Safe food handling at reheating

Safe food handling at thawing

Safe food handling at cooling

Storing and labeling chemicals 

and sanitizers

Illnesses and symptoms that should be 

reported to a foodservice supervisor

Pathogens and characteristics of 

foodborne illness

Equipment and maintenance

Percent
E-3 

Table E-2. Percent of SFAs where all schools had two or more safety inspections, by SFA 

Characteristics for SY 2008-09, SY 2009-10, and SY 2010-11

SFA characteristics

Percentage of SFAs where all schools had two or more 

safety inspections Total SFAs

SY 2010-11 SY 2009-10 SY 2008-09 Weighted n Unweighted n

All SFAs 84.2% 84.9% 83.7% 14,418 1,3861

SFA size

Small (1-999) 84.9 85.9 86.2 7,179 324

Medium (1,000-4,999) 84.7 85.7 83.5 5,337 531

Large (5,000-24,999) 80.7 79.8 76.0 1,618 362

Very large (25,000+) 75.3 72.2 68.0 284 169

Urbanicity

City 74.5 69.7 68.3 1,539 252

Suburban 84.7 86.0 81.7 2,860 378

Town 83.6 83.8 81.4 2,769 263

Rural 86.2 88.1 88.6 7,250 493

Poverty level

Low (0-29% F/RP) 85.5 84.6 84.9 3,341 344

Medium (30-59% F/RP) 83.2 85.3 83.7 6,757 645

High (60% or higher F/RP) 84.6 84.5 82.9 4,319 397

1 

n is less than 1,401 due to item non-response. 

Data Source: SFA Director Survey 2011, question 12.7. 
3

E-4

Table E-3. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price Lunches in Elementary Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.90 $0.75 $3.50 11,763 1,2281$1.90 $0.75 $3.50 11,794 1,2291$2.00 $0.75 $4.50 11,763 1,2291

SFA size 

Small (1-999) 1.75 0.80 3.50 5,050 235 1.85 0.80 3.50 5,073 236 1.95 0.75 3.50 5,045 235

Medium (1,000-4,999) 1.95 0.75 3.50 4,900 489 2.00 0.75 3.50 4,907 490 2.00 0.75 3.50 4,901 489

Large (5,000-24,999) 1.95 0.75 3.05 1,542 343 2.00 0.80 3.25 1,544 343 2.00 0.80 4.50 1,545 343

Very large (25,000+) 1.90 0.85 3.25 271 161 1.95 0.85 3.50 269 160 2.00 0.85 3.50 272 162

Urbanicity

City 2.20 0.75 3.27 1,149 221 2.15 0.80 3.27 1,154 222 2.25 0.80 3.27 1,145 221

Suburban 2.00 1.00 3.50 2,299 337 2.05 1.00 3.50 2,325 337 2.25 1.00 4.50 231 339

Town 1.90 0.75 3.05 2,269 236 1.95 0.80 3.05 2,283 237 2.00 0.80 3.00 2,296 238

Rural 1.75 0.75 3.25 6,046 434 1.75 0.75 3.50 6,031 433 1.85 0.75 3.50 6,009 431

Poverty level 

Low (0-29% F/RP) 2.05 1.20 3.50 2,765 304 2.10 1.20 3.50 2,795 305 2.20 1.20 3.50 2,809 307

Medium (30-59% F/RP) 1.90 0.90 3.50 6,026 603 1.90 0.90 3.50 6,023 602 2.00 0.75 3.50 6,020 604

High (60% or higher 

F/RP)

1.75 0.75 3.25 2,971 321 1.75 0.75 3.50 2,976 322 1.75 0.75 4.50 2,935 318

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-5 

Table E-4. Distribution of NSLP Meal Prices for Full-Price Lunches in Elementary Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤$1.00 3.1 2.9 1.8

$1.01 - $1.10 0.5 0.6 1.0

$1.11 - $1.20 0.9 0.9 0.5

$1.21 - $1.30 5.1 4.6 3.7

$1.31 - $1.40 2.7 2.4 1.7

$1.41 - $1.50 9.7 9.7 6.6

$1.51 - $1.60 3.9 3.4 4.2

$1.61 - $1.70 4.0 3.9 2.5

$1.71 - $1.80 17.2 16.0 13.4

$1.81 - $1.90 5.2 5.8 7.5

$1.91 - $2.00 19.2 18.2 13.3

$2.01 - $2.10 4.2 4.6 9.7

$2.11 - $2.20 2.1 2.5 4.8

$2.21 - $2.30 8.2 9.4 9.5

$2.31 - $2.40 1.6 2.1 3.4

$2.41 - $2.50 7.2 6.8 9.0

$2.51 - $2.60 0.1 0.5 0.7

$2.61 - $2.70 0.2 0.0 0.3

$2.71 - $2.80 1.9 1.9 2.2

$2.81 - $2.90 0.1 0.2 0.2

$2.91 - $3.00 2.3 2.6 2.5

> $3.00 0.6 1.0 1.8

Total SFAs: Weighted n 11,763 11,794 11,763

Total SFAs: Unweighted n

1

1,228 1,229 1,229

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-6

Table E-5. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price Lunches in Middle Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SY 2009-10 SY 2010-11 SY 2011-12

SFA characteristics Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $2.05 $0.80 $3.75 8,895 1,0591$2.10 $0.80 $3.75 8,908 1,0611$2.25 $0.80 $4.50 8,888 1,0611

SFA size

Small (1-999) 2.00 1.00 3.50 2,874 135 2.00 1.00 3.75 2,874 135 2.10 1.00 4.22 2,847 134

Medium (1,000-4,999) 2.10 0.80 3.75 4,258 433 2.15 0.80 3.75 4,265 434 2.25 0.80 3.75 4,269 434

Large (5,000-24,999) 2.10 1.00 3.75 1,502 335 2.15 1.00 3.75 1,507 336 2.25 1.00 4.50 1,509 336

Very large (25,000+) 2.10 0.85 3.75 262 156 2.15 0.85 3.75 262 156 2.25 0.85 3.75 263 157

Urbanicity

City 2.25 0.85 3.75 829 202 2.25 0.85 3.75 835 203 2.25 0.85 3.75 798 201

Suburban 2.25 1.00 3.75 2,003 314 2.30 1.00 3.75 2,011 315 2.40 1.00 4.50 2,017 317

Town 2.00 0.80 3.50 2,047 220 2.05 0.80 3.50 2,061 221 2.25 0.80 3.50 2,073 222

Rural 2.00 0.85 3.25 4,017 323 2.00 0.95 3.50 4,002 322 2.10 1.00 4.22 4,000 321

Poverty level

Low (0-29% F/RP) 2.25 1.40 3.75 2,165 274 2.30 1.40 3.75 2,174 275 2.40 1.40 4.22 2,213 277

Medium (30-59% F/RP) 2.05 1.00 3.50 4,691 522 2.10 1.00 3.75 4,691 522 2.25 1.00 3.75 4,670 523

High (60% or higher 

F/RP)

1.85 0.80 3.25 2,039 263 1.85 0.80 3.50 2,043 264 2.00 0.80 4.50 2,004 261

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-7 

Table E-6. Distribution of NSLP Meal Prices for Full-Price Lunches in Middle Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤$1.00 1.2 1.1 0.7

$1.01 - $1.10 0.2 0.2 0.3

$1.11 - $1.20 0.1 0.2 0.3

$1.21 - $1.30 2.5 2.5 1.6

$1.31 - $1.40 1.1 1.1 0.8

$1.41 - $1.50 4.9 4.4 3.4

$1.51 - $1.60 1.7 1.3 2.2

$1.61 - $1.70 1.6 2.0 1.1

$1.71 - $1.80 12.3 10.6 8.0

$1.81 - $1.90 5.7 5.8 4.9

$1.91 - $2.00 18.2 18.0 12.8

$2.01 - $2.10 5.8 4.7 8.1

$2.11 - $2.20 4.0 5.1 3.8

$2.21 - $2.30 14.4 14.8 15.7

$2.31 - $2.40 3.5 3.1 6.7

$2.41 - $2.50 10.3 11.7 11.6

$2.51 - $2.60 1.1 1.3 3.1

$2.61 - $2.70 0.9 0.5 1.0

$2.71 - $2.80 5.1 5.2 6.3

$2.81 - $2.90 0.4 0.3 1.1

$2.91 - $3.00 3.2 4.1 3.8

> $3.00 1.9 2.1 2.7

Total SFAs: Weighted n 8,895 8,908 8,888

Total SFAs: Unweighted n

1

1,059 1,061 1,061

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-8

Table E-7. Median, Minimum, and Maximum NSLP Meal Prices for Full-Price Lunches in High Schools, SY 2009-10, SY 2010-11, 

and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $2.05 $0.80 $4.00 10,344 1,1491$2.10 $0.80 $4.00 10,349 1,1501$2.25 $0.80 $4.50 10,314 1,1501

SFA size

Small (1-999) 2.00 0.85 3.25 3,919 183 2.00 0.85 3.50 3,919 183 2.10 1.00 4.00 3,869 181

Medium (1,000-4,999) 2.20 0.80 4.00 4,618 461 2.25 0.80 4.00 4,617 461 2.25 0.80 4.00 4,630 462

Large (5,000-24,999) 2.20 1.00 4.00 1,529 340 2.25 1.00 4.00 1,535 341 2.25 1.00 4.50 1,536 341

Very large (25,000+) 2.20 1.00 3.75 278 165 2.25 1.00 3.75 278 165 2.25 1.00 3.75 279 166

Urbanicity 

City 2.25 1.00 3.75 844 208 2.25 1.00 3.75 850 209 2.35 1.00 3.75 818 207

Suburban 2.35 1.25 3.75 2,098 321 2.45 1.25 4.00 2,098 321 2.50 1.25 4.50 2,104 323

Town 2.15 0.80 4.00 2,196 229 2.20 0.80 4.00 2,210 230 2.25 0.80 4.00 2,222 231

Rural 2.00 0.85 3.50 5,206 391 2.00 0.85 3.50 5,192 390 2.10 1.00 3.50 5,170 389

Poverty level

Low (0-29% F/RP) 2.25 1.30 4.00 2,515 298 2.30 1.30 4.00 2,515 298 2.40 1.40 4.00 2,527 299

Medium (30-59% 

F/RP)

2.05 0.85 4.00 5,360 561 2.10 0.85 4.00 5,360 561 2.25 1.00 4.00 5,338 562

High (60% or higher 

F/RP)

2.00 0.80 3.50 2,470 290 2.00 0.80 3.50 2,474 291 2.00 0.80 4.50 2,449 289

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-9 

Table E-8. Distribution of NSLP Meal Prices for Full-Price Lunches in High Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤$1.00 1.4 1.3 0.6

$1.01 - $1.10 0.3 0.3 0.3

$1.11 - $1.20 0.1 0.2 0.4

$1.21 - $1.30 2.9 2.7 1.8

$1.31 - $1.40 1.3 1.4 1.2

$1.41 - $1.50 5.3 4.4 3.6

$1.51 - $1.60 1.5 1.3 2.1

$1.61 - $1.70 1.9 2.2 1.3

$1.71 - $1.80 11.5 10.7 9.1

$1.81 - $1.90 5.7 5.5 3.7

$1.91 - $2.00 17.2 17.0 11.5

$2.01 - $2.10 5.1 4.9 8.6

$2.11 - $2.20 4.0 4.3 4.4

$2.21 - $2.30 13.8 14.6 14.5

$2.31 - $2.40 3.3 3.1 6.4

$2.41 - $2.50 10.4 11.4 11.7

$2.51 - $2.60 1.2 1.1 3.0

$2.61 - $2.70 0.9 0.8 1.1

$2.71 - $2.80 5.8 6.0 6.5

$2.81 - $2.90 0.5 0.7 1.4

$2.91 - $3.00 3.5 3.6 3.9

> $3.00 2.2 2.7 3.0

Total SFAs: Weighted n 10,344 10,349 10,314

Total SFAs: Unweighted n

1

1,149 1,150 1,150

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-10

Table E-9. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price Lunches in Elementary Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.40 $0.25 $0.40 11,258 1,1721$0.40 $0.25 $0.40 11,302 1,1741$0.40 $0.25 $0.40 11,288 1,1701

SFA size

Small (1-999) 0.40 0.25 0.40 4,759 222 0.40 0.25 0.40 4,800 224 0.40 0.25 0.40 4,803 224

Medium (1,000-4,999) 0.40 0.25 0.40 4,778 476 0.40 0.25 0.40 4,785 477 0.40 0.25 0.40 4,775 475

Large (5,000-24,999) 0.40 0.25 0.40 1,480 330 0.40 0.25 0.40 1,476 329 0.40 0.25 0.40 1,469 327

Very large (25,000+) 0.40 0.25 0.40 241 144 0.40 0.25 0.40 241 144 0.40 0.25 0.40 241 144

Urbanicity

City 0.40 0.25 0.40 1,065 204 0.40 0.25 0.40 1,081 205 0.40 0.25 0.40 1,067 202

Suburban 0.40 0.25 0.40 2,180 318 0.40 0.25 0.40 2,209 319 0.40 0.25 0.40 2,190 318

Town 0.40 0.25 0.40 2,188 229 0.40 0.25 0.40 2,202 230 0.40 0.25 0.40 2,217 231

Rural 0.40 0.25 0.40 5,825 421 0.40 0.25 0.40 5,810 420 0.40 0.25 0.40 5,814 419

Poverty level

Low (0-29% F/RP) 0.40 0.25 0.40 2,671 295 0.40 0.25 0.40 2,700 296 0.40 0.25 0.40 2,713 297

Medium (30-59% 

F/RP)

0.40 0.25 0.40 5,904 585 0.40 0.25 0.40 5,897 584 0.40 0.25 0.40 5,901 586

High (60% or higher 

F/RP)

0.40 0.25 0.40 2,682 292 0.40 0.25 0.40 2,705 294 0.40 0.25 0.40 2,674 287

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-11

Table E-10. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price Lunches in Middle Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.40 $0.25 $0.40 8,537 1,0101$0.40 $0.25 $0.40 8,557 1,0101$0.40 $0.25 $0.40 8,523 1,0061

SFA size

Small (1-999) 0.40 0.25 0.40 2,713 127 0.40 0.25 0.40 2,732 128 0.40 0.25 0.40 2,705 127

Medium (1,000-4,999) 0.40 0.25 0.40 4,148 421 0.40 0.25 0.40 4,155 422 0.40 0.25 0.40 4,155 421

Large (5,000-24,999) 0.40 0.25 0.40 1,442 322 0.40 0.25 0.40 1,438 321 0.40 0.25 0.40 1,431 319

Very large (25,000+) 0.40 0.25 0.40 234 140 0.40 0.25 0.40 232 139 0.40 0.25 0.40 232 139

Urbanicity

City 0.40 0.25 0.40 770 186 0.40 0.25 0.40 785 186 0.40 0.25 0.40 716 181

Suburban 0.40 0.25 0.40 1,901 297 0.40 0.25 0.40 1,908 297 0.40 0.25 0.40 1,908 297

Town 0.40 0.25 0.40 1,966 213 0.40 0.25 0.40 1,979 214 0.40 0.25 0.40 1,995 215

Rural 0.40 0.25 0.40 3,899 314 0.40 0.25 0.40 3,885 313 0.40 0.25 0.40 3,904 313

Poverty level

Low (0-29% F/RP) 0.40 0.25 0.40 2,082 264 0.40 0.25 0.40 2,089 264 0.40 0.25 0.40 2,128 266

Medium (30-59% 

F/RP)

0.40 0.25 0.40 4,609 507 0.40 0.25 0.40 4,603 506 0.40 0.25 0.40 4,585 507

High (60% or higher 

F/RP)

0.40 0.25 0.40 1,845 239 0.40 0.25 0.40 1,865 240 0.40 0.25 0.40 1,810 233

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-12

Table E-11. Median, Minimum, and Maximum NSLP Meal Prices for Reduced-Price Lunches in High Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.40 $0.25 $0.40 9,967 1,0951$0.40 $0.25 $0.40 9,959 1,0951$0.40 $0.25 $0.40 9,909 1,0931

SFA size

Small (1-999) 0.40 0.25 0.40 3,775 176 0.40 0.25 0.40 3,775 176 0.40 0.25 0.40 3,709 173

Medium (1,000-4,999) 0.40 0.25 0.40 4,479 446 0.40 0.25 0.40 4,472 446 0.40 0.25 0.40 4,487 447

Large (5,000-24,999) 0.40 0.25 0.40 1,467 326 0.40 0.25 0.40 1,466 326 0.40 0.25 0.40 1,467 326

Very large (25,000+) 0.40 0.25 0.40 246 147 0.40 0.25 0.40 246 147 0.40 0.25 0.40 246 147

Urbanicity

City 0.40 0.25 0.40 809 194 0.40 0.25 0.40 808 194 0.40 0.25 0.40 777 192

Suburban 0.40 0.25 0.40 1,966 298 0.40 0.25 0.40 1,974 299 0.40 0.25 0.40 1,978 300

Town 0.40 0.25 0.40 2,114 222 0.40 0.25 0.40 2,128 223 0.40 0.25 0.40 2,145 224

Rural 0.40 0.25 0.40 5,078 381 0.40 0.25 0.40 5,049 379 0.40 0.25 0.40 5,010 377

Poverty level

Low (0-29% F/RP) 0.40 0.25 0.40 2,395 283 0.40 0.25 0.40 2,389 283 0.40 0.25 0.40 2,405 285

Medium (30-59% 

F/RP)

0.40 0.25 0.40 5,276 545 0.40 0.25 0.40 5,269 544 0.40 0.25 0.40 5,232 544

High (60% or higher 

F/RP)

0.40 0.25 0.40 2,296 267 0.40 0.25 0.40 2,301 268 0.40 0.25 0.40 2,271 264

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-13

Table E-12. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches in Elementary Schools, SY 2009-10,

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $3.00 $1.00 $6.35 11,908 1,2211$3.00 $1.00 $6.35 11,976 1,2271$3.00 $1.00 $6.35 12,004 1,2281

SFA size

Small (1-999) 2.85 1.00 6.30 5,255 245 3.00 1.00 6.30 5,278 246 3.00 1.00 6.30 5,300 247

Medium (1,000-4,999) 3.00 1.10 6.35 4,890 488 3.00 1.35 6.35 492 491 3.00 1.40 6.35 4,938 492

Large (5,000-24,999) 3.00 1.25 5.00 1,508 337 3.00 1.50 5.00 1,517 339 3.00 1.50 5.00 1,510 337

Very large (25,000+) 3.00 1.60 5.00 255 151 3.00 1.60 5.00 255 151 3.00 1.60 5.00 256 152

Urbanicity

City 3.00 1.25 5.00 1,061 215 3.00 1.60 5.00 1,067 216 3.00 1.50 5.00 1,063 215

Suburban 3.00 1.35 5.00 2,272 328 3.00 1.35 5.00 2,320 332 3.10 1.40 5.00 2,326 334

Town 3.00 1.60 4.50 2,323 240 3.00 1.60 4.75 2,337 241 3.00 1.60 4.75 2,349 242

Rural 2.85 1.00 6.35 6,251 438 3.00 1.00 6.35 6,251 438 3.00 1.00 6.35 6,266 437

Poverty level

Low (0-29% F/RP) 3.00 1.75 5.00 2,723 294 3.01 1.75 5.00 2,754 296 3.15 1.80 5.00 2,764 296

Medium (30-59% 

F/RP)

3.00 1.35 6.30 5,926 585 3.00 1.35 6.30 5,943 587 3.00 1.35 6.30 5,939 587

High (60% or higher

F/RP)

2.80 1.00 6.35 3,259 342 3.00 1.00 6.35 3,279 344 3.00 1.00 6.35 3,300 345

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-14

Table E-13. Distribution of NSLP Meal Prices for Adult Lunches in Elementary Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $2.00 6.8 5.8 4.5

$2.01 - $2.10 0.6 0.2 0.5

$2.11 - $2.20 0.7 0.9 0.7

$2.21 - $2.30 5.1 4.8 3.6

$2.31 - $2.40 1.9 1.4 1.2

$2.41 - $2.50 12.7 12.3 9.2

$2.51 - $2.60 1.9 1.5 2.5

$2.61 - $2.70 2.5 2.6 1.9

$2.71 - $2.80 10.5 9.2 8.5

$2.81 - $2.90 3.4 3.1 3.1

$2.91 - $3.00 21.5 23.5 21.3

$3.01 - $3.10 2.5 2.8 4.9

$3.11 - $3.20 1.8 2.5 2.1

$3.21 - $3.30 8.9 8.7 10.8

$3.31 - $3.40 0.7 1.0 2.1

$3.41 - $3.50 9.0 8.9 9.2

$3.51 - $3.60 0.3 0.6 1.0

$3.61 - $3.70 0.2 0.3 0.4

$3.71 - $3.80 2.4 2.3 3.4

$3.81 - $3.90 0.4 0.6 0.5

$3.91 - $4.00 3.8 4.3 4.7

> $4.00 2.4 2.9 3.8

Total SFAs: Weighted n 11,908 11,976 12,004

Total SFAs: Unweighted n

1

1,221 1,227 1,228

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-15

Table E-14. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches in Middle Schools, SY 2009-10, SY 2010-11, 

and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $3.00 $1.10 $6.35 8,990 1,0471$3.00 $1.35 $6.35 9,008 1,0491$3.00 $1.00 $6.35 9,076 1,0531

SFA size

Small (1-999) 2.95 1.35 5.00 2,985 140 3.00 1.35 5.00 2,985 140 3.00 1.00 5.00 3,035 142

Medium (1,000-4,999) 3.00 1.10 6.35 4,300 436 3.00 1.40 6.35 4,312 437 3.00 1.40 6.35 4,334 439

Large (5,000-24,999) 3.00 1.50 5.00 1,463 327 3.00 1.50 5.00 1,469 328 3.10 1.50 5.00 1,464 327

Very large (25,000+) 3.00 1.75 5.00 242 144 3.00 1.75 5.00 242 144 3.00 1.75 5.00 243 145

Urbanicity

City 3.00 1.75 5.00 789 195 3.00 1.75 5.00 792 195 3.10 1.50 5.00 790 195

Suburban 3.06 1.40 5.00 1,971 304 3.06 1.40 5.00 1,982 306 3.25 1.40 5.00 1,988 308

Town 3.00 1.60 4.50 2,085 224 3.00 1.60 4.75 2,099 225 3.00 1.60 4.75 2,111 226

Rural 3.00 1.10 6.35 4,145 324 3.00 1.35 6.35 4,135 323 3.00 1.00 6.35 4,187 324

Poverty level

Low (0-29% F/RP) 3.06 1.75 5.00 2,144 264 3.10 1.75 5.00 2,152 265 3.25 1.80 5.00 2,190 266

Medium (30-59% 

F/RP)

3.00 1.35 4.75 4,597 504 3.00 1.35 5.00 4,600 505 3.00 1.35 5.00 4,596 505

High (60% or higher 

F/RP)

3.00 1.10 6.35 2,249 279 3.00 1.40 6.35 2,255 279 3.00 1.00 6.35 2,290 282

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-16

Table E-15. Distribution of NSLP Meal Prices for Adult Lunches in Middle Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $2.00 4.7 3.8 3.2

$2.01 - $2.10 0.8 0.3 0.4

$2.11 - $2.20 0.7 1.0 0.9

$2.21 - $2.30 5.4 5.3 3.7

$2.31 - $2.40 1.3 1.0 1.0

$2.41 - $2.50 11.1 10.5 6.1

$2.51 - $2.60 1.7 1.3 2.4

$2.61 - $2.70 2.2 2.4 1.7

$2.71 - $2.80 10.5 9.0 8.8

$2.81 - $2.90 3.7 3.7 3.7

$2.91 - $3.00 23.7 25.3 21.9

$3.01 - $3.10 2.4 3.0 5.3

$3.11 - $3.20 2.1 2.5 3.0

$3.21 - $3.30 9.8 9.3 10.6

$3.31 - $3.40 0.6 0.9 2.0

$3.41 - $3.50 9.1 9.1 10.4

$3.51 - $3.60 0.3 0.6 1.0

$3.61 - $3.70 0.4 0.4 0.7

$3.71 - $3.80 2.3 2.4 3.1

$3.81 - $3.90 0.5 0.5 0.4

$3.91 - $4.00 4.3 4.8 5.1

> $4.00 2.5 3.1 4.6

Total SFAs: Weighted n 8,990 9,008 9,076

Total SFAs: Unweighted n

1

1,047 1,049 1,053

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5.
3

E-17

Table E-16. Median, Minimum, and Maximum NSLP Meal Prices for Adult Lunches in High Schools, SY 2009-10, SY 2010-11, and 

SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $3.00 $1.10 $6.35 10,292 1,1231$3.00 $1.35 $6.35 10,360 1,1291$3.00 $1.00 $6.35 10,365 1,1291

SFA size

Small (1-999) 2.85 1.35 5.00 3,963 185 3.00 1.35 5.00 3,986 186 3.00 1.00 5.00 3,985 186

Medium (1,000-4,999) 3.00 1.10 6.35 4,603 458 3.00 1.50 6.35 4,639 461 3.00 1.50 6.35 4,651 462

Large (5,000-24,999) 3.00 1.50 5.00 1,468 327 3.00 1.50 5.00 1,477 329 3.10 1.50 5.00 1,469 327

Very large (25,000+) 3.00 1.75 5.00 258 153 3.00 1.75 5.00 258 153 3.00 1.75 5.00 260 154

Urbanicity

City 3.00 1.75 6.00 801 199 3.00 1.75 6.00 806 200 3.00 1.50 6.00 802 199

Suburban 3.15 1.75 5.00 2,032 307 3.15 1.75 5.00 2,057 310 3.25 1.75 5.00 2,063 312

Town 3.00 1.60 4.50 2,218 230 3.00 1.60 4.75 2,232 231 3.00 1.60 4.75 2,222 231

Rural 2.85 1.10 6.35 5,241 387 3.00 1.35 6.35 5,264 388 3.00 1.00 6.35 5,278 387

Poverty level

Low (0-29% F/RP) 3.01 1.75 5.00 2,485 287 3.10 1.75 5.00 2,494 288 3.25 1.80 5.00 2,504 288

Medium (30-59% 

F/RP)

3.00 1.35 6.00 5,244 541 3.00 1.35 6.00 5,284 544 3.00 1.35 6.00 5,257 543

High (60% or higher 

F/RP)

3.00 1.10 6.35 2,563 295 3.00 1.50 6.35 2,582 297 3.00 1.00 6.35 2,604 298

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
E-18

Table E-17. Distribution of NSLP Meal Prices for Adult Lunches in High Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

Lunch price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $2.00 4.4 3.9 2.9

$2.01 - $2.10 0.7 0.2 0.4

$2.11 - $2.20 0.6 0.8 0.8

$2.21 - $2.30 5.9 5.7 3.9

$2.31 - $2.40 1.8 1.5 1.3

$2.41 - $2.50 11.3 10.8 7.4

$2.51 - $2.60 2.0 1.5 2.7

$2.61 - $2.70 2.7 2.9 2.1

$2.71 - $2.80 10.7 9.2 8.6

$2.81 - $2.90 3.6 3.0 3.7

$2.91 - $3.00 22.6 24.3 21.8

$3.01 - $3.10 2.7 2.8 5.0

$3.11 - $3.20 2.0 2.9 2.5

$3.21 - $3.30 8.8 8.8 10.4

$3.31 - $3.40 0.8 1.0 2.5

$3.41 - $3.50 9.3 9.0 9.9

$3.51 - $3.60 0.6 0.8 1.1

$3.61 - $3.70 0.3 0.4 0.4

$3.71 - $3.80 2.8 2.9 3.7

$3.81 - $3.90 0.4 0.6 0.4

$3.91 - $4.00 4.2 4.6 4.9

> $4.00 1.8 2.3 3.6

Total SFAs: Weighted n 10,292 10,360 10,365

Total SFAs: Unweighted n

1

1,123 1,129 1,129

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.4 and 5.5. 
3

E-19

Table E-18. Median, Minimum, and Maximum SBP Meal Prices for Full-Price Breakfasts in Elementary Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.10 $0.25 $3.00 9,596 1,0311$1.15 $0.25 $3.00 9,732 1,0411$1.25 $0.25 $3.00 9,792 1,0361

SFA size

Small (1-999) 1.10 0.40 2.25 3,969 187 1.15 0.40 2.00 4,076 192 1.20 0.40 2.30 4,147 195

Medium (1,000-4,999) 1.15 0.40 3.00 4,022 402 1.25 0.40 3.00 4,030 401 1.25 0.40 3.00 4,058 404

Large (5,000-24,999) 1.10 0.25 2.25 1,377 307 1.10 0.25 2.25 1,393 310 1.20 0.25 2.25 1,358 301

Very large (25,000+) 1.00 0.40 2.00 227 135 1.10 0.40 2.25 232 138 1.15 0.40 2.25 230 136

Urbanicity

City 1.25 0.25 2.25 928 183 1.25 0.25 2.25 941 187 1.25 0.25 2.30 9,167 180

Suburban 1.20 0.60 2.00 1,702 279 1.25 0.60 2.10 1,764 284 1.25 0.60 2.00 17,752 282

Town 1.15 0.40 3.00 1,898 200 1.15 0.40 3.00 1,931 201 1.25 0.40 3.00 1,924 202

Rural 1.00 0.40 2.00 5,067 369 1.10 0.40 2.25 5,096 369 1.20 0.40 2.25 5,176 372

Poverty level

Low (0-29% F/RP) 1.20 0.65 2.25 1,901 234 1.25 0.65 2.25 2,027 243 1.25 0.65 2.25 2,098 249

Medium (30-59%

F/RP)

1.10 0.40 3.00 5,321 545 1.15 0.40 3.00 5,353 547 1.25 0.40 3.00 5,339 542

High (60% or higher 

F/RP)

1.00 0.25 2.25 2,373 252 1.00 0.25 2.25 2,353 251 1.00 0.25 2.30 2,355 245

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-20

Table E-19. Distribution of SBP Meal Prices for Full-Price Breakfasts in Elementary Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $0.50 2.8 2.6 2.5

$0.51 - $0.60 1.2 1.2 0.7

$0.61 - $0.70 0.8 0.7 0.8

$0.71 - $0.80 9.0 7.9 7.1

$0.81 - $0.90 4.3 4.1 3.2

$0.91 - $1.00 26.8 24.6 20.7

$1.01 - $1.10 6.2 5.4 6.3

$1.11 - $1.20 7.6 7.6 6.3

$1.21 - $1.30 21.8 22.9 25.2

$1.31 - $1.40 5.2 7.2 8.1

$1.41 - $1.50 9.1 9.8 11.6

$1.51 - $1.60 1.4 1.2 2.5

$1.61 - $1.70 0.8 1.3 1.0

$1.71 - $1.80 1.6 2.2 2.8

$1.81 - $1.90 0.0 0.0 0.1

$1.91 - $2.00 0.9 1.3 0.8

>$2.00 0.4 0.2 0.4

Total SFAs: Weighted n 9,596 9,732 9,792

Total SFAs: Unweighted n

1

1,031 1,041 1,036

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-21

Table E-20. Median, Minimum, and Maximum SBP Meal Prices for Full-Price Breakfasts in Middle Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.25 $0.25 $2.50 7,308 8951$1.25 $0.25 $2.50 7,510 9121$1.25 $0.25 $2.50 7,437 8991

SFA size

Small (1-999) 1.25 0.50 2.00 2,313 109 1.25 0.50 2.00 2,417 114 1.25 0.50 2.00 2,384 113

Medium (1,000-4,999) 1.25 0.40 2.50 3,417 349 1.25 0.40 2.50 3,496 355 1.25 0.40 2.50 3,503 356

Large (5,000-24,999) 1.25 0.25 2.25 1,353 303 1.25 0.25 2.25 1,367 306 1.25 0.25 2.25 1,324 295

Very large (25,000+) 1.20 0.45 2.25 225 134 1.25 0.45 2.25 230 137 1.25 0.45 2.25 227 135

Urbanicity

City 1.25 0.25 2.25 727 172 1.25 0.25 2.25 743 177 1.25 0.25 2.25 661 167

Suburban 1.25 0.60 2.50 1,510 262 1.25 0.60 2.50 1,571 267 1.25 0.60 2.50 1,613 267

Town 1.25 0.40 2.00 1,731 188 1.25 0.40 2.25 1,759 190 1.25 0.40 2.00 1,730 188

Rural 1.25 0.50 2.00 3,341 273 1.25 0.50 2.25 3,435 278 1.25 0.50 2.30 3,433 277

Poverty level

Low (0-29% F/RP) 1.25 0.85 2.50 1,463 208 1.25 0.90 2.50 1,521 213 1.30 1.00 2.50 1,569 217

Medium (30-59% 

F/RP)

1.25 0.50 2.01 4,207 477 1.25 0.50 2.25 4,291 485 1.25 0.50 2.30 4,200 475

High (60% or higher 

F/RP)

1.15 0.25 2.00 1,638 210 1.15 0.25 2.25 1,698 214 1.25 0.25 2.25 1,669 207

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-22

Table E-21. Distribution of SBP Meal Prices for Full-Price Breakfasts in Middle Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $0.50 1.8 1.5 1.4

$0.51 - $0.60 1.5 1.5 1.1

$0.61 - $0.70 0.4 0.2 0.3

$0.71 - $0.80 5.0 4.5 4.4

$0.81 - $0.90 3.1 3.0 1.9

$0.91 - $1.00 22.6 21.1 16.9

$1.01 - $1.10 5.2 4.3 5.6

$1.11 - $1.20 5.7 5.3 4.4

$1.21 - $1.30 24.9 25.6 25.8

$1.31 - $1.40 6.9 9.2 10.5

$1.41 - $1.50 14.7 14.2 16.4

$1.51 - $1.60 1.9 1.6 3.6

$1.61 - $1.70 0.7 1.4 1.5

$1.71 - $1.80 3.2 3.7 3.7

$1.81 - $1.90 0.5 0.5 0.5

$1.91 - $2.00 1.6 1.8 1.4

>$2.00 0.3 0.5 0.7

Total SFAs: Weighted n 7,308 7,509 7,437

Total SFAs: Unweighted n

1

895 912 899

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-23

Table E-22. Median, Minimum, and Maximum SBP Meal Prices for Full-Price Breakfasts in High Schools, SY 2009-10, SY 2010-11, 

and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.25 $0.25 $2.85 8,622 9821$1.25 $0.25 $2.85 8,834 1,0021$1.25 $0.25 $2.85 8,813 9941

SFA size

Small (1-999) 1.20 0.45 2.50 3,098 146 1.25 0.45 2.50 3,193 150 1.25 0.45 2.50 3,215 151

Medium (1,000-4,999) 1.25 0.40 2.85 3,907 389 1.25 0.40 2.85 3,997 397 1.25 0.40 2.85 3,988 397

Large (5,000-24,999) 1.25 0.25 2.25 1,383 308 1.25 0.25 2.60 1,404 313 1.25 0.25 2.25 1,374 306

Very large (25,000+) 1.25 0.45 2.25 234 139 1.25 0.45 2.25 239 142 1.25 0.45 2.50 236 140

Urbanicity

City 1.25 0.25 2.25 663 172 1.25 0.25 2.25 710 179 1.30 0.25 2.25 700 175

Suburban 1.25 0.60 2.85 1,687 279 1.25 0.60 2.85 1,750 286 1.25 0.60 2.85 1,759 284

Town 1.25 0.40 2.00 1,858 196 1.25 0.40 2.00 1,894 199 1.25 0.40 2.00 1,897 199

Rural 1.20 0.45 2.25 4,414 335 1.25 0.45 2.25 4,480 338 1.25 0.45 2.30 4,457 336

Poverty level

Low (0-29% F/RP) 1.25 0.80 2.85 1,819 235 1.30 0.80 2.85 1,886 241 1.35 0.80 2.85 1,910 243

Medium (30-59% 

F/RP)

1.25 0.50 2.50 4,788 515 1.25 0.50 2.50 4,854 522 1.25 0.50 2.50 4,814 517

High (60% or higher 

F/RP)

1.10 0.25 2.00 2,014 232 1.15 0.25 2.60 2,094 239 1.20 0.25 2.25 2,089 234

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-24

Table E-23. Distribution of SBP Meal Prices for Full Price Breakfasts in High Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $0.50 1.9 1.7 1.6

$0.51 - $0.60 1.5 1.5 1.1

$0.61 - $0.70 0.5 0.4 0.4

$0.71 - $0.80 6.7 6.0 5.3

$0.81 - $0.90 3.4 3.4 2.4

$0.91 - $1.00 22.6 21.1 17.4

$1.01 - $1.10 4.6 3.9 5.0

$1.11 - $1.20 5.1 4.8 4.0

$1.21 - $1.30 23.2 22.7 24.1

$1.31 - $1.40 7.3 9.2 10.2

$1.41 - $1.50 13.4 14.3 15.7

$1.51 - $1.60 1.8 1.6 2.4

$1.61 - $1.70 0.6 1.2 1.4

$1.71 - $1.80 3.7 4.0 4.3

$1.81 - $1.90 0.4 0.3 0.4

$1.91 - $2.00 2.4 2.4 2.2

>$2.00 1.0 1.5 1.9

Total SFAs: Weighted n 8,622 8,834 8,813

Total SFAs: Unweighted n

1

982 1,002 994

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2.
3

E-25

Table E-24. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price Breakfasts in Elementary Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.30 $0.15 $0.30 8,156 8841$0.30 $0.15 $0.30 8,256 8861$0.30 $0.15 $0.30 8,257 8731

SFA size

Small (1-999) 0.30 0.15 0.30 3,282 158 0.30 0.15 0.30 3,396 163 0.30 0.15 0.30 3,395 163

Medium (1,000-4,999) 0.30 0.20 0.30 3,520 353 0.30 0.20 0.30 3,511 351 0.30 0.20 0.30 3,581 358

Large (5,000-24,999) 0.30 0.15 0.30 1,167 262 0.30 0.15 0.30 1,163 261 0.30 0.15 0.30 1,101 246

Very large (25,000+) 0.30 0.20 0.30 186 111 0.30 0.20 0.30 186 111 0.30 0.20 0.30 181 106

Urbanicity

City 0.30 0.15 0.30 722 147 0.30 0.15 0.30 770 150 0.30 0.15 0.30 730 144

Suburban 0.30 0.20 0.30 1,470 240 0.30 0.20 0.30 1,509 241 0.30 0.20 0.30 1,516 236

Town 0.30 0.20 0.30 1,549 167 0.30 0.20 0.30 1,609 171 0.30 0.20 0.30 1,622 173

Rural 0.30 0.15 0.30 4,414 330 0.30 0.15 0.30 4,369 324 0.30 0.15 0.30 4,389 320

Poverty level

Low (0-29% F/RP) 0.30 0.20 0.30 1,640 201 0.30 0.20 0.30 1,713 204 0.30 0.20 0.30 1,753 204

Medium (30-59% 

F/RP)

0.30 0.15 0.30 4,561 470 0.30 0.15 0.30 4,565 469 0.30 0.15 0.30 4,503 457

High (60% or higher 

F/RP)

0.30 0.15 0.30 1,954 213 0.30 0.15 0.30 1,979 213 0.30 0.15 0.30 2,001 212

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-26

Table E-25. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price Breakfasts in Middle Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.30 $0.15 $0.30 6,183 7611$0.30 $0.15 $0.30 6,340 7691$0.30 $0.15 $0.30 6,329 7541

SFA size

Small (1-999) 0.30 0.15 0.30 1,890 91 0.30 0.15 0.30 1,996 96 0.30 0.15 $0.30 2,008 97

Medium (1,000-4,999) 0.30 0.20 0.30 2,979 305 0.30 0.20 0.30 3,034 309 0.30 0.20 $0.30 3,085 315

Large (5,000-24,999) 0.30 0.15 0.30 1,132 256 0.30 0.15 0.30 1,128 255 0.30 0.15 $0.30 1,059 238

Very large (25,000+) 0.30 0.20 0.30 182 109 0.30 0.20 0.30 182 109 0.30 0.20 $0.30 177 104

Urbanicity

City 0.30 0.15 0.30 573 140 0.30 0.15 0.30 595 142 0.30 0.15 $0.30 551 135

Suburban 0.30 0.20 0.30 1,245 219 0.30 0.20 0.30 1,295 221 0.30 0.20 $0.30 1,319 217

Town 0.30 0.20 0.30 1,410 158 0.30 0.20 0.30 1,442 161 0.30 0.20 $0.30 1,459 163

Rural 0.30 0.15 0.30 2,954 244 0.30 0.15 0.30 3,009 245 0.30 0.15 $0.30 2,999 239

Poverty level

Low (0-29% F/RP) 0.30 0.20 0.30 1,263 175 0.30 0.20 0.30 1,309 178 0.30 0.20 $0.30 1,309 175

Medium (30-59% 

F/RP)

0.30 0.15 0.30 3,562 408 0.30 0.15 0.30 3,606 410 0.30 0.15 $0.30 3,555 399

High (60% or higher 

F/RP)

0.30 0.15 0.30 1,357 178 0.30 0.15 0.30 1,425 181 0.30 0.15 $0.30 1,465 180

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-27

Table E-26. Median, Minimum, and Maximum SBP Meal Prices for Reduced-Price Breakfasts in High Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $0.30 $0.15 $0.30 7,348 8391$0.30 $0.15 $0.30 7,512 8501$0.30 $0.15 $0.30 7,471 8331

SFA size

Small (1-999) 0.30 0.15 0.30 2,610 125 0.30 0.15 0.30 2,706 129 0.30 0.15 0.30 2,723 130

Medium (1,000-4,999) 0.30 0.20 0.30 3,376 338 0.30 0.20 0.30 3,443 344 0.30 0.20 0.30 3,450 345

Large (5,000-24,999) 0.30 0.15 0.30 1,170 262 0.30 0.15 0.30 1,171 263 0.30 0.15 0.30 1,111 249

Very large (25,000+) 0.30 0.20 0.30 192 114 $0.30 0.20 0.30 192 114 0.30 0.20 0.30 186 109

Urbanicity

City 0.30 0.15 0.30 584 143 0.30 0.15 0.30 620 147 0.30 0.15 0.30 604 142

Suburban 0.30 0.20 0.30 1,378 232 0.30 0.20 0.30 1,432 236 0.30 0.20 0.30 1,428 230

Town 0.30 0.20 0.30 1,505 165 0.30 0.20 0.30 1,537 168 0.30 0.20 0.30 1,582 171

Rural 0.30 $0.15 0.30 3,881 299 $0.30 0.15 0.30 3,923 299 0.30 0.15 0.30 3,858 290

Poverty level

Low (0-29% F/RP) 0.30 0.20 0.30 1,546 197 0.30 0.20 0.30 1,609 201 0.30 0.20 0.30 1,574 194

Medium (30-59% 

F/RP)

0.30 0.15 0.30 4,057 441 0.30 0.15 0.30 4,099 444 0.30 0.15 0.30 4,032 433

High (60% or higher 

F/RP)

0.30 0.15 0.30 1,745 201 0.30 0.15 0.30 1,804 205 0.30 0.15 0.30 1,866 206

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2.
3

E-28

Table E-27. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts in Elementary Schools, SY 2009-10, 

SY 2010-11, and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.50 $0.35 $4.00 10,108 1,0771$1.60 $0.35 $4.00 10,332 1,1001$1.70 $0.35 $4.00 10,418 1,1051

SFA size

Small (1-999) 1.50 0.35 3.00 4,282 202 1.50 0.35 3.00 4,381 207 1.55 0.35 3.00 4,425 209

Medium (1,000-4,999) 1.60 0.50 4.00 4,183 418 1.65 0.50 4.00 4,283 427 1.75 0.50 4.00 4,333 433

Large (5,000-24,999) 1.75 0.75 3.53 1,407 317 1.75 0.75 3.53 1,427 322 1.75 0.75 3.53 1,420 320

Very large (25,000+) 1.75 0.75 3.00 235 140 1.75 0.75 3.00 242 144 1.85 0.75 3.50 241 143

Urbanicity

City 1.75 0.75 3.25 906 200 1.75 0.75 3.25 918 204 1.75 0.75 3.50 883 200

Suburban 1.75 0.85 3.10 1,691 272 1.75 0.85 3.25 1,738 278 1.75 0.85 3.10 1,763 280

Town 1.55 0.85 4.00 2,098 220 1.60 0.85 4.00 2,159 225 1.70 0.85 4.00 2,175 227

Rural 1.50 0.35 3.53 5,413 385 1.50 0.35 3.53 5,517 393 1.60 0.35 3.53 5,598 398

Poverty level 

Low (0-29% F/RP) 1.75 1.00 3.53 1,728 207 1.75 1.00 3.53 1,834 214 1.75 1.00 3.53 1,904 219

Medium (30-59% 

F/RP)

1.50 0.50 4.00 5,393 547 1.60 0.50 4.00 5,472 558 1.70 0.50 4.00 5,459 556

High (60% or higher 

F/RP)

1.50 0.35 3.25 2,987 323 1.50 0.35 3.25 3,026 328 1.55 0.35 3.50 3,055 330

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-29

Table E-28. Distribution of SBP Meal Prices for Adult Breakfasts in Elementary Schools, 

SY 2009-10, SY 2010-11, and SY2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤$1.00 9.1 8.8 7.5

$1.01 - $1.10 1.0 0.9 0.9

$1.11 - $1.20 1.5 1.4 1.2

$1.21 - $1.30 12.8 12.2 8.9

$1.31 - $1.40 3.6 3.1 3.8

$1.41 - $1.50 22.6 20.8 19.7

$1.51 - $1.60 3.4 3.4 5.3

$1.61 - $1.70 3.0 3.6 2.9

$1.71 - $1.80 14.1 14.5 14.2

$1.81 - $1.90 3.2 3.6 4.4

$1.91 - $2.00 14.7 16.0 16.8

$2.01 - $2.10 1.1 1.3 2.1

$2.11 - $2.20 0.5 0.7 1.2

$2.21 - $2.30 2.5 2.8 4.1

$2.31 - $2.40 0.4 0.6 0.5

$2.41 - $2.50 3.3 2.9 2.7

$2.51 - $2.60 0.1 0.3 0.1

$2.61 - $2.70 0.2 0.2 0.2

$2.71 - $2.80 0.5 0.5 0.9

$2.81 - $2.90 0.1

$2.91 - $3.00 1.2 1.2 1.3

> $3.00 1.0 1.2 1.3

Total SFAs: Weighted n 10,108 10,332 10,418

Total SFAs: Unweighted n

1

1,077 1,100 1,105

1 

n is less than 1,401 because not all SFAs have elementary schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-30

Table E-29. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts in Middle Schools, SY 2009-10, SY 2010-11, 

and SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.60 $0.50 $3.53 7,500 9091$1.70 $0.50 $4.00 7,691 9311$1.75 $0.50 $4.00 7,736 9341

SFA size

Small (1-999) 1.50 0.60 3.00 2,428 114 1.50 0.60 3.00 2,505 118 1.55 0.75 3.00 2,499 118

Medium (1,000-4,999) 1.65 0.50 3.50 3,505 358 1.70 0.50 3.50 3,589 366 1.75 0.50 3.50 3,648 372

Large (5,000-24,999) 1.75 0.75 3.53 1,342 303 1.75 0.75 4.00 1,366 309 1.80 0.75 4.00 1,358 307

Very large (25,000+) 1.75 0.75 3.00 224 134 1.80 0.75 4.00 231 138 1.95 0.75 4.00 230 137

Urbanicity

City 1.75 0.75 3.25 736 184 1.75 0.75 3.25 753 189 1.80 0.75 3.45 717 185

Suburban 1.75 0.85 3.10 1,400 245 1.75 0.85 4.00 1,448 252 1.75 0.85 4.00 1,494 255

Town 1.60 0.85 3.25 1,865 203 1.65 0.85 3.25 1,886 205 1.75 0.85 3.25 1,903 207

Rural 1.50 0.50 3.53 3,499 277 1.50 0.50 3.53 3,604 285 1.60 0.50 3.53 3,623 287

Poverty level

Low (0-29% F/RP) 1.75 1.00 3.53 1,282 180 1.75 1.00 3.53 1,335 185 1.75 1.00 3.53 1,382 188

Medium (30-59% 

F/RP)

1.55 0.50 3.50 4,161 466 1.65 0.50 4.00 4,230 476 1.75 0.50 4.00 4,200 474

High (60% or higher 

F/RP)

1.50 0.60 3.25 2,057 263 1.50 0.60 4.00 2,126 270 1.70 0.75 4.00 2,154 272

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-31

Table E-30. Distribution of SBP Meal Prices for Adult Breakfasts in Middle Schools, 

SY 2009-10, SY2010-11, and SY 2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $1.00 7.6 7.6 6.4

$1.01 - $1.10 0.4 0.5 0.6

$1.11 - $1.20 0.7 0.8 0.7

$1.21 - $1.30 12.7 11.5 8.2

$1.31 - $1.40 4.3 3.9 3.6

$1.41 - $1.50 22.7 21.2 20.7

$1.51 - $1.60 2.8 3.1 4.6

$1.61 - $1.70 2.8 3.0 2.8

$1.71 - $1.80 14.8 15.2 14.6

$1.81 - $1.90 3.5 4.1 4.6

$1.91 - $2.00 14.8 15.6 16.6

$2.01 - $2.10 1.6 1.4 2.2

$2.11 - $2.20 0.6 0.8 1.5

$2.21 - $2.30 3.2 3.6 4.6

$2.31 - $2.40 0.3 0.4 0.3

$2.41 - $2.50 3.2 3.1 3.5

$2.51 - $2.60 0.1 0.1 0.1

$2.61 - $2.70 0.1 0.1 0.0

$2.71 - $2.80 0.7 0.8 1.0

$2.81 - $2.90 0.2 0.0 0.0

$2.91 - $3.00 1.6 1.6 1.7

> $3.00 1.2 1.4 1.4

Total SFAs: Weighted n 7,500 7,691 7,736

Total SFAs: Unweighted n

1

909 931 934

1 

n is less than 1,401 because not all SFAs have middle schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
3

E-32

Table E-31. Median, Minimum, and Maximum SBP Meal Prices for Adult Breakfasts in High Schools, SY 2009-10, SY 2010-11, and 

SY 2011-12

SFA characteristics

SY 2009-10 SY 2010-11 SY 2011-12

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Median Min Max

Total SFAs

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

Wgt

n

Unwgt

n

All SFAs $1.55 $0.50 $4.00 8,822 9961$1.65 $0.50 $4.00 9,041 1,0191$1.75 $0.50 $4.00 9,075 1,0201

SFA size

Small (1-999) 1.50 0.60 3.15 3,313 156 1.50 0.60 3.15 3,409 160 1.55 0.75 3.15 3,425 161

Medium (1,000-4,999) 1.70 0.50 4.00 3,898 389 1.75 0.50 4.00 3,990 398 1.75 0.50 4.00 4,015 401

Large (5,000-24,999) 1.75 0.75 3.53 1,371 308 1.75 0.75 4.00 1,395 314 1.80 0.75 4.00 1,388 312

Very large (25,000+) 1.75 0.75 3.00 241 143 1.85 0.75 4.00 247 147 2.00 0.75 4.00 247 146

Urbanicity

City 1.75 0.75 4.00 699 187 1.75 0.75 4.00 743 193 1.80 0.75 4.00 707 189

Suburban 1.75 0.85 3.15 1,560 261 1.75 0.85 4.00 1,626 269 1.75 0.85 4.00 1,638 269

Town 1.60 0.85 3.25 1,992 210 1.65 0.85 3.25 2,013 212 1.75 0.85 3.25 2,052 215

Rural 1.50 0.50 3.53 4,571 338 1.50 0.50 3.53 4,659 345 1.60 0.50 3.53 4,678 347

Poverty level

Low (0-29% F/RP) 1.75 1.00 3.53 1,611 206 1.75 1.00 3.53 1,678 212 1.75 1.00 3.53 1,723 214

Medium (30-59% 

F/RP)

1.50 0.50 4.00 4,803 506 1.60 0.50 4.00 4,881 516 1.70 0.50 4.00 4,841 513

High (60% or higher 

F/RP)

1.50 0.60 3.25 2,408 284 1.50 0.60 4.00 2,482 291 1.75 0.75 4.00 2,511 293

1 

n is less than 1,401 because not all SFAs have high schools and item non-respone. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-33

Table E-32. Distribution of SBP Meal Prices for Adult Breakfasts in High Schools, 

SY 2009-10, SY 2010-11, and SY 2011-12

Breakfast price

Percent of SFAs

SY 2009-10 SY 2010-11 SY 2011-12

≤ $1.00 8.5 8.3 6.7

$1.01 - $1.10 0.6 0.5 0.6

$1.11 - $1.20 1.2 1.3 1.3

$1.21 - $1.30 11.9 10.9 7.6

$1.31 - $1.40 4.0 3.7 3.4

$1.41 - $1.50 23.4 21.9 21.1

$1.51 - $1.60 2.7 2.9 4.9

$1.61 - $1.70 2.8 3.1 2.5

$1.71 - $1.80 14.5 15.3 15.1

$1.81 - $1.90 3.5 3.6 4.2

$1.91 - $2.00 14.8 14.9 16.1

$2.01 - $2.10 1.3 1.3 2.0

$2.11 - $2.20 0.5 0.7 1.3

$2.21 - $2.30 3.1 3.4 4.0

$2.31 - $2.40 0.3 0.5 0.3

$2.41 - $2.50 3.3 3.6 4.1

$2.51 - $2.60 0.1 0.1 0.1

$2.61 - $2.70 0.1 0.1 0.0

$2.71 - $2.80 0.6 0.6 0.8

$2.81 - $2.90 0.2 1.6 0.1

$2.91 - $3.00 1.3 0.0 1.7

> $3.00 1.4 1.7 1.8

Total SFAs: Weighted n 8,822 9,041 9,075

Total SFAs: Unweighted n

1

996 1,019 1,020

1 

n is less than 1,401 because not all SFAs have high schools and item non-response. 

Data Source: SFA Director Survey 2011, questions 5.1 and 5.2. 
E-34

Table E-33. USDA Meal Reimbursements as a Percent of Total Revenue: Distribution of 

SFAs, SY 2010-11

USDA reimbursements/total revenue Percentage of SFAs

Less than 20% 15.6%

20% - < 30% 7.2

30% - < 40% 9.3

40% - < 50% 13.7

50% - < 60% 12.8

60% - < 70% 11.5

70% - < 80% 12.5

80% or more 17.4

Total 100.0

Average percentage: USDA reimbursements/total revenue 51.7%

Total SFAs: Weighted n

Total SFAs: Unweighted n

6,876

7021

1 

n is less than 1,401 because of item non-response. 

Data Source: SFA Director Survey, question 6.1. 

Table E-34. Student Payments for Reimbursable Meals as a Percent of Total Revenue: 

Distribution of SFAs, SY 2010-11

Student payments/total revenue Percentage of SFAs

Less than 20% 42.7%

20% - < 30% 18.7

30% - < 40% 16.1

40% - < 50% 12.3

50% - < 60% 6.1

60% or more 4.1

Total All SFAs 100.0

Average percentage: student payments/total revenue 26.1%

Total SFAs: Weighted n

Total SFAs: Unweighted n

10,788

1,0951

1 

n is less than 1,401 because of item non-response. 

Data Source: SFA Director Survey, question 6.1. 
E-35

Table E-35. State and Local Funds as a Percent of Total Revenue: Distribution of SFAs, 

SY 2010-11

State and local funds/total revenue Percentage of SFAs

Less than 5% 57.8%

5% - < 10% 17.2

10% - < 15% 5.8

15% - < 20% 2.9

20% - < 25% 3.4

More than 25% 12.9

Total All SFAs 100.0

Average percentage: student payments/total revenue 11.5%

Total SFAs: Weighted n

Total SFAs: Unweighted n

10,456

1,0581

1 

n is less than 1,401 because of item non-response. 

Data Source: SFA Director Survey, question 6.1. 

Table E-36. Non-Reimbursable Sales as a Percent of Total Revenue: Distribution of SFAs, 

SY 2010-11

Non-reimbursable sales/total revenue Percentage of SFAs

Less than 10% 64.8%

10% - < 20% 20.9

20% - < 30% 8.8

30% - < 40% 3.2

40% or more 2.3

Total All SFAs 100.0

Average percentage: student payments/total revenue 9.3%

Total SFAs: Weighted n

Total SFAs: Unweighted n

10676

10791

1 

n is less than 1,401 because of item non-response. 

Data Source: SFA Director Survey, question 6.1. 
E-36

Table E-37. Type and Dollar Amount of State Subsidies for Breakfast to SFAs in Each State, 

SY 2010-11

State Type of subsidy Dollar amount

California Per-meal reimbursement $44,195,133

Colorado Per-meal reimbursement $682,722

Connecticut Other DK

District of Columbia Other $1,105,048

Florida Based on percentage of low income students $7,590,912

Hawaii Supplement to cover specific costs $6,000,000

Illinois Per-meal reimbursement $7,534,530

Iowa Per-meal reimbursement DK

Maine Per-meal reimbursement $210,000

Maryland Other $2,820,000

Massachusetts Supplement to cover specific costs $3,511,060

Michigan Annual lump sum $3,360,000

Minnesota Per-meal reimbursement DK

Nebraska Per-meal reimbursement $438,282

New Hampshire Per-meal reimbursement $118,809

New Mexico Annual lump sum $1,924,600

New York Per-meal reimbursement $9,359,296

North Carolina Other $2,200,000

Oregon Supplement to cover specific costs $542,752

Pennsylvania Per-meal reimbursement DK

Puerto Rico Annual lump sum $30,638,177

Rhode Island Other $270,000

Vermont Per-meal reimbursement $132,632

Virgin Islands Supplement to cover specific costs $1,006,907

Virginia Per-meal reimbursement $2,497,421

Washington DK DK

Wisconsin Other $2,789,400

Analysis includes only states that provided a subsidy for breakfast. 

DK = don’t know

Data Source: State CN Director Survey, question B.1c. 
E-37

Table E-38. Type and Dollar Amount of State Subsidies for Lunch to SFAs in Each State, 

SY 2010-11

State Type of Subsidy Dollar Amount

California Per-meal reimbursement $101,182,742

Colorado Other $685,061

Connecticut Annual lump sum $2,354,000

District of Columbia Other $1,069,397

Georgia Supplement to cover specific costs $24,230,678

Hawaii Supplement to cover specific costs $30,000,000

Illinois Per-meal reimbursement $16,709,527

Iowa Per-meal reimbursement DK

Kansas Per-meal reimbursement $2,435,171

Maine Per-meal reimbursement $1,050,000

Massachusetts Per-meal reimbursement $5,426,986

Michigan Other $600,000

Minnesota Per-meal reimbursement DK

Nebraska Annual lump sum $392,032

New Hampshire Annual lump sum $832,003

New Jersey Per-meal reimbursement $5,612,975

New York Per-meal reimbursement $20,716,431

North Carolina Other $5,000,000

Ohio Per-meal reimbursement $8,447,732

Oklahoma Per-meal reimbursement $4,601,288

Pennsylvania Per-meal reimbursement DK

Puerto Rico Annual lump sum $118,261,757

Utah Per-meal reimbursement $28,860,635

Vermont Per-meal reimbursement $407,738

Virgin Islands Supplement to cover specific costs $1,869,971

Virginia Other $5,801,932

Washington DK DK

Wisconsin Other $4,218,100

Analysis includes only States that provided a subsidy for lunch. 

DK = don’t know

Data Source: State CN Director Survey, question B.1c.
E-38

Table E-39. Number of SFAs and Schools Using FSMC in Each State, SY 2011-12

State

Number of SFAs in 

state1

Number of SFAs 

using FSMCs2

Number of schools 

in state2

Number of schools 

using FSMCs

Alabama 73 4 509 NR

Alaska 189 13 1600 39

American Samoa 289 NR 1110 NR

Arizona -- 87 28 395

Arkansas 458 NR 2265 NR

California 1094 169 10124 831

Colorado 226 21 1796 NR

Connecticut 185 53 1157 323

Delaware 61 5 228 5

District of Columbia 42 54 214 208

Florida 223 6 4131 92

Georgia 232 22 2449 135

Hawaii 35 2 289 NR

Idaho 480 4 1436 30

Illinois 148 190 748 1,472

Indiana 1132 55 4361 218

Iowa 499 17 1936 53

Kansas 400 10 1378 39

Kentucky 189 0 1554 0

Louisiana 113 14 1471 79

Maine 429 2 1829 2

Maryland 73 5 1449 133

Massachusetts 189 74 631 593

Michigan 882 218 3877 NR

Minnesota 697 71 2392 NR

Mississippi 785 4 2410 18

Missouri 197 170 1083 754

Montana 241 5 827 53

Nebraska 162 18 2567 105

Nevada 215 NR 516 NR

New Hampshire 378 28 1096 87

New Jersey 100 412 480 NR

New Mexico 697 75 2607 197

New York 220 195 862 951

North Carolina 32 4 645 117

North Dakota 1105 0 4757 0

Ohio 1222 97 3758 NR

Oklahoma 574 18 1785 322

Oregon 245 36 1296 418

Pennsylvania 853 301 3233 NR

Puerto Rico 38 0 1473 0

Rhode Island 54 42 317 333

South Carolina 106 14 1214 205

South Dakota 211 28 710 93

Tennessee 201 11 1784 17

Texas 1259 105 8732 1,337

Utah 85 4 1016 118

Vermont 161 56 2175 103

Virgin Islands -- 0 32 0

Virginia 226 11 320 NR

Washington 327 0 2338 0

West Virginia 848 NR 2238 2

Wisconsin 73 66 757 NR

Wyoming 58 3 360 26

Total 19,011 2,799 100,350 9,903

1 Data on number of SFAs in each state comes from USDA Administrative data form FNS-742. The file did not include data for American Samoa 

or Virgin Islands. Idaho and the Virgin Islands reported some inconsistent data on the number of Provision 2/3 SFAs and schools and therefore 

are not shown in those cases. 

2

 NCES CCD 2010-11 http://nces.ed.gov/pubs2012/pesschools10/tables/table_02.asp 

NR = non-response. 

Data Source: State CN Director Survey, question D3.
E-39

Table E-40. Number of Charter Schools Participating in the NSLP and SBP as Separate SFAs 

or Part of a Larger SFA in Each State, SY 2011-12

State

Number of charter 

schools operating 

in state

Charter schools that are a 

separate SFA

Charter schools that are part of a larger 

SFA

Number Percent Number Percent

Alabama10 0 0% 0 0%

Alaska 27 1 4 8 30

Arizona 513 145 28 244 48

Arkansas 13 -- -- 0 0

California 983 345 35 283 29

Colorado 175 3 2 46 26

Connecticut 16 12 75 3 19

Delaware 22 16 73 0 0

District of Columbia 53 50 94 0 0

Florida 517 97 19 278 54

Georgia 34 31 91 0 0

Hawaii 31 24 77 0 0

Idaho 43 17 40 7 16

Illinois 23 6 26 12 52

Indiana 65 38 58 17 26

Iowa 6 0 0 3 50

Kansas 17 0 0 8 47

Kentucky10 0 0 0 0

Louisiana 78 20 26 17 22

Maine10 0 0 0 0

Maryland 42 0 0 42 100

Massachusetts 72 47 65 23 32

Michigan 256 185 72 0 0

Minnesota 148 NR -- NR --

Mississippi 0 0 0 0 0

Missouri 41 39 95 0 0

Montana10 0 0 0 0

Nebraska20 0 0 0 0

Nevada 30 1 3 6 20

New Hampshire 18 3 17 0 0

New Jersey 75 62 83 6 8

New Mexico 88 38 43 19 22

New York 196 41 21 72 37

North Carolina 100 43 43 0 0

North Dakota10 0 0 0 0

Ohio 355 234 66 8 2

Oklahoma 22 17 77 1 5

Oregon 115 17 15 51 44

Pennsylvania NR NR -- NR --

Puerto Rico 0 0 0 0 0

Rhode Island 14 5 36 9 64

South Carolina 12 12 100 0 0

South Dakota 0 0 0 0 0

Tennessee 45 12 27 33 73

Texas 194 152 78 0 0

Utah 82 46 56 7 9

Vermont10 0 0 0 0

Virgin Islands 0 0 0 0 0

Virginia 2 0 0 2 100

Washington10 0 0 0 0

West Virginia10 0 0 0 0

Wisconsin 235 19 8 216 92

Wyoming 4 0 0 0 0

Total 4,762 1,804 39%21,421 31%2

1

 These states do not have legislation permitting charter schools. Maine enacted a law in 2011 allowing charter schools. 

2 This percentage is based on only those states that reported the total number of charter schools operating in their state and the total number 

of charter schools operating in their state as a separate SFA. 

Idaho reported inconsistent data on the number of charter schools and is not included in the table. 

Note: National Alliance for Public Charter Schools reports 5,618 public charter schools for SY 2011-12.

NR = non-response. 

Data Source: State CN Director Survey, questions C11a and C11c.