SCHOOL NUTRITION

USDA Has Efforts 

Underway to Help 

Address Ongoing 

Challenges 

Implementing 

Changes in Nutrition 

Standards 

Report to the Chairman, Committee on 

Education and the Workforce, House of 

Representatives

September 2015

GAO-15-656

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-15-656, a report to the 

Chairman, Committee on Education and the 

Workforce, House of Representatives

September 2015

SCHOOL NUTRITION

USDA Has Efforts Underway to Help Address 

Ongoing Challenges Implementing Changes in 

Nutrition Standards

Why GAO Did This Study

The Healthy, Hunger-Free Kids Act of 

2010 required USDA to update 

nutrition standards for school lunches 

and breakfasts and add standards for 

other food sold in schools, known as 

competitive foods. In response, USDA 

set new nutrition requirements, 

including limits on calories, sodium, 

and fats. Previously, GAO reported on 

the implementation of changes to 

school lunches in school year 2012-

2013. Since then, additional 

requirements for lunches have taken 

effect, as well as new requirements for 

breakfasts and competitive foods. GAO 

was asked to review implementation of 

the nutrition changes to school food. 

GAO reviewed (1) recent trends in 

school meals participation, (2)

challenges SFAs faced in

implementing the new requirements for 

school meals, (3) challenges SFAs and 

districts faced in implementing new 

requirements for competitive foods, 

and (4) USDA assistance in 

implementing the changes. 

GAO reviewed relevant federal laws, 

regulations, and guidance; analyzed 

federal school meals participation data

from school years 2000-2001 through 

2013-2014; reviewed implementation 

in the same eight school districts 

visited for the report on school year 

2012-2013 lunch changes, selected to 

provide variation in geographic location 

and certain district and food service 

characteristics; and interviewed USDA 

and state officials, as well as food 

industry and stakeholder groups.

What GAO Recommends

GAO is not making any 

recommendations.

What GAO Found

Nationwide, participation in the National School Lunch Program declined by 1.4 

million children (or 4.5 percent) from school year 2010-2011 through school year 

2013-2014, to 30.4 million children. The participation rate of enrolled students 

also declined, from 62 to 58 percent. Seven of eight states that GAO interviewed

reported that challenges with student acceptance of changes made to comply 

with new federal nutrition requirements contributed to the decrease. Also, four of 

eight states noted that recent required increases in the price of lunch may have 

decreased participation among some students. At the same time, nationwide 

participation in the breakfast program continued its trend of steady increases, 

which can be explained, in part, by program expansion into more schools.

The U.S. Department of Agriculture (USDA), states, and the eight School Food 

Authorities (SFAs) GAO reviewed, which administer meal programs in school 

districts, reported some ongoing challenges with meal requirements; however 

some SFAs noted success in certain areas. For example, five of eight SFAs,

described continuing challenges with plate waste, that is, students taking 

required foods and then not eating them. However, officials in the other three, as 

well as GAO’s mealtime observations across the two school years, suggest that 

plate waste may be decreasing in some SFAs. Also, five of the SFAs reported

difficulty serving certain required food items in ways that appeal to students, 

though others reported some success. Regarding sodium, SFA, state, and food 

company officials expressed concerns about meeting future targets, which USDA 

plans to phase in over the next 8 years. To address these concerns, USDA is 

gathering information from SFAs and the food industry on progress toward 

reducing sodium levels in school meals. 

New requirements for competitive foods—foods sold to students in schools other 

than through the school meals programs—also challenged SFAs and schools 

during school year 2014-2015. Six of eight SFAs reported difficulty procuring 

items that met the new requirements, particularly at the beginning of the school 

year. Also, four SFAs and two school groups selling competitive foods in the 

eight districts GAO reviewed reported decreased revenues due to lower student 

demand for products that comply with the requirements. In addition, SFA and 

state officials reported issues with ensuring compliance and providing oversight 

of these sales. To identify and help address such issues, USDA recently required 

states to begin including competitive foods in their periodic reviews of SFAs.

Officials from five states and four SFAs reported that USDA’s assistance in 

implementing these changes has been helpful or improving over time; however,

some SFAs noted problems with the amount or clarity of the guidance. USDA 

has initiated efforts to assist SFAs, such as by conducting webinars on a variety 

of topics, including menu planning. At the same time, officials from three of eight 

SFAs said USDA guidance on the new requirements—comprising nearly 4,700 

pages issued from January 2012 through April 2015—has been challenging to 

keep up with. However, according to USDA, the substantial changes to nutrition 

standards have already occurred, and therefore, the need for additional guidance 

should decrease in future years. Moreover, USDA has provided other types of 

assistance that help clarify the guidance, including initiatives that facilitate the

sharing of best practices and provide peer mentoring. 

View GAO-15-656. For more information, 

contact Kay E. Brown, (202) 512-7215, 

brownke@gao.gov
Page i GAO-15-656 School Nutrition

Letter 1

Background 4

National School Lunch Participation Continued to Decline in 

School Year 2013-2014, While Breakfast Participation 

Continued to Increase 11

SFAs Continue to Report Challenges with New School Meals 

Requirements and Expressed Concern about Future Sodium 

Restrictions 18

SFAs and Schools Made Changes to Comply with the New 

Federal Competitive Food Standards and Faced Challenges 

with Procurement, Revenue, and Oversight 27

USDA’s Assistance Has Included a Substantial Amount of 

Guidance and Other Efforts 35

Agency Comments 39

Appendix I Scope and Methodology 41

Appendix II GAO Contact and Staff Acknowledgments 46

Tables

Table 1: Sodium Targets for Lunch 7

Table 2: Sodium Targets for Breakfast 9

Table 3: State Fundraiser Exemptions 31

Figures

Figure 1: Examples of Lunches Provided Pursuant to the New 

Content and Nutrition Requirements 6

Figure 2: Examples of Breakfasts Provided Pursuant to New 

Content and Nutrition Requirements 9

Figure 3: Participation Changes Since School Year (SY) 2000-

2001 in the National School Lunch Program for SY 2000-

2001 through 2013-2014 12

Figure 4: Participation in the National School Lunch Program by 

Category of Student, School Years 2000-2001 through 

2013-2014 13

Contents
Page ii GAO-15-656 School Nutrition

Figure 5: Participation Changes Since School Year (SY) 2000-

2001 in the School Breakfast Program for SY 2000-2001 

through 2013-2014 16

Figure 6: Participation in the School Breakfast Program by 

Category of Student, School Years 2000-2001 through 

2013-2014 17

Figure 7: Salt and Pepper Shakers Brought to Lunch by a High 

School Student 23

Abbreviations

CEP Community Eligibility Provision

SFA school food authority

SNA School Nutrition Association

USDA U.S. Department of Agriculture

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

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

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necessary if you wish to reproduce this material separately.
Page 1 GAO-15-656 School Nutrition

441 G St. N.W.

Washington, DC 20548

September 14, 2015

The Honorable John Kline

Chairman

Committee on Education and the Workforce 

House of Representatives

Dear Mr. Chairman:

In fiscal year 2014, the National School Lunch Program and the School 

Breakfast Program, which are intended to promote the health and wellbeing of schoolchildren, provided school meals to an estimated 30.4 

million and 13.6 million children, respectively, supported in part through 

federal subsidies and commodities totaling $16.3 billion. The U.S. 

Department of Agriculture (USDA) administers the school meals 

programs at the federal level and, under agreements with state agencies, 

local school food authorities (SFA)—which are generally aligned with 

school districts—serve meals to children in schools. Federal standards for 

the content of school lunches and breakfasts have existed since the 

programs were created; however, the Healthy, Hunger-Free Kids Act of 

2010, which most recently reauthorized school meal programs, required 

that these standards be updated. More specifically, the Act required 

USDA to update the standards for the content of school meals based on 

recommendations from the Institute of Medicine.1 The Act also required 

USDA to establish nutrition standards for all other foods and beverages 

sold in schools, commonly known as competitive foods.2 The changes to 

lunch, breakfast, and competitive foods were required in order to improve 

 1 Pub. L. No. 111-296, § 201, 124 Stat. 3183, 3214. The Act required USDA to update the 

meal patterns and nutrition standards for the National School Lunch Program and School 

Breakfast Program based on recommendations issued by the Food and Nutrition Board,

which is part of the National Academies’ Institute of Medicine. Throughout this report, we 

refer to these as the Institute of Medicine’s recommendations, on which USDA based the 

lunch and breakfast content and nutrition requirements.

2 Pub. L. No. 111-296, § 208, 124 Stat. 3183, 3221. The Act required USDA to establish 

standards for competitive foods that are consistent with the most recent Dietary 

Guidelines for Americans, taking into consideration authoritative scientific 

recommendations for nutrition standards and other factors.

Letter
Page 2 GAO-15-656 School Nutrition

children’s diets and help reduce childhood obesity. USDA has established 

these new requirements over the last few years.3

In the 2012-2013 school year, as many of the new nutrition standards for 

lunches were implemented, both USDA and the media reported that 

states, SFAs, school officials, parents, and students raised issues about 

the lunch changes. In June 2013 and January 2014, we reported to 

Congress on challenges SFAs encountered in implementing the lunch 

changes and recommended that USDA make modifications to some of 

the new lunch requirements and take steps to improve program 

oversight.4 Subsequently, additional nutrition requirements for lunches 

have taken effect, as well as new nutrition requirements for breakfasts 

and competitive foods. Accordingly, you asked us to review the current 

status of local implementation of the school meals and competitive food 

nutrition requirements.

This report assesses: (1) recent trends in school meals participation; (2) 

challenges that SFAs reported they continued to face in implementing the 

new requirements for school lunch and school breakfast; (3) challenges 

SFAs and schools reported they have faced during their first year 

implementing the new requirements for competitive foods; and (4) 

USDA’s efforts to assist with implementation of the new requirements for 

school lunch, school breakfast, and competitive foods.

For this study, we gathered information through several methods. First, 

we reviewed relevant federal laws, regulations, and guidance; analyzed 

national school meals participation data from school years 2000-2001 

through 2013-2014; and interviewed USDA officials. Second, we 

reviewed implementation in eight school districts across the country and 

talked with their state agency officials who have knowledge of the 

experiences of multiple school districts across their states. In addition, we 

 3 These requirements were phased-in, generally beginning in school year 2012-2013 for 

lunch, school year 2013-2014 for breakfast, and school year 2014-2015 for competitive 

foods.

4 In GAO, School Lunch: Modifications Needed to Some of the New Nutrition Standards, 

GAO-13-708T (Washington, D.C.: June 27, 2013) we made two recommendations on 

nutrition standards which are discussed later in this report. In GAO, School Lunch: 

Implementing Nutrition Changes Was Challenging and Clarification of Oversight 

Requirements is Needed, GAO-14-104 (Washington, D.C.: January 28, 2014) we made 

two additional recommendations regarding program oversight. USDA generally agreed 

with both of these and has indicated they are taking steps to address them.
Page 3 GAO-15-656 School Nutrition

met with industry and stakeholder groups that vary in their perspectives 

on the nutrition standards and implementation of the changes. More 

specifically, to assess national school meals participation, we analyzed 

USDA’s national data on meals served in the National School Lunch 

Program and the School Breakfast Program and reviewed the 

department’s method for determining school meals participation from 

these data. To assess the reliability of the data, we interviewed USDA 

officials, reviewed related documentation, and compared the data we 

received from USDA with its published data. We determined that these 

data and the participation methodology are sufficiently reliable for the 

purposes of this report.5 To gather information on challenges directly from 

those affected by the changes to food in schools, we contacted the eight 

school districts in eight states across the country that we had visited as 

part of our prior study of implementation of the new school lunch 

requirements in school year 2012-2013. From December 2014 through 

March 2015, we visited seven of the districts and gathered information 

from the eighth district through phone interviews.6 The school districts 

selected for these visits provide variation across geographic location, 

district size, and certain characteristics of the student population and 

district food services. In each district we visited, we met with SFA staff at 

the district and school levels, school administrators, and students, and we 

also observed lunch and breakfast, as well as competitive food sales, in 

at least two schools of different grade levels, for a total of 14 schools.

Contacting these districts and states a second time provides a short-term 

longitudinal perspective on challenges related to implementation of the 

phased-in changes. We cannot generalize our findings from the site visits 

beyond the school districts we visited or the findings from states beyond 

the eight states we interviewed. To understand the scale and scope of 

assistance USDA has provided, we interviewed USDA officials, reviewed 

relevant agency documents, talked with states and SFAs about their 

perspectives on the assistance provided, and analyzed guidance memos 

 5 We used the same approach to analyze school meals participation data as was used for 

our 2014 report. For more information on our analysis of participation data, see appendix 

I.

6 We conducted site visits to Carlisle Area School District (PA), Chicago Public Schools 

(IL), Coeur d’Alene School District (ID), Fairfax County Public Schools (VA), Irving 

Independent School District (TX), Mukwonago Area School District (WI), and Spokane 

Public Schools (WA). We were unable to visit Caddo Parish Public Schools (LA) because 

of weather-related school closings, but we gathered information from the district’s SFA 

director and officials from two schools over the phone.
Page 4 GAO-15-656 School Nutrition

USDA issued on the nutrition changes from October 2013 through May 

2015. We chose this time period in order to continue our previous 

analysis of this guidance, as in our prior report on the school lunch 

nutrition changes, we analyzed guidance issued from January 2011 

through September 2013.

For additional information on the report’s scope and methodology, see 

appendix I.

We conducted this work from November 2014 through August 2015 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

The two largest federal school meals programs, the National School 

Lunch Program, established in 1946, and the School Breakfast Program, 

permanently established in 1975,7 aim to address problems of hunger, 

food insecurity, and poor nutrition by providing nutritious meals to children 

in schools. Although federal requirements for the content of school meals 

have existed since the programs began, as research has documented the 

increasing incidence of children who are overweight and obese in the 

United States, the federal government has taken steps to improve the 

nutritional content of meals. The Healthy, Hunger-Free Kids Act of 2010 

required USDA to update federal requirements for school lunches, 

breakfasts, and to establish standards for competitive foods—foods sold 

to children in schools other than through the school meals programs. 

USDA issued final regulations that made changes to many of the meal 

content and nutrition requirements in January 2012, and many of the new 

lunch requirements were required to be implemented beginning in school 

year 2012-2013, with changes to breakfast generally beginning in school 

year 2013-2014.8 USDA issued interim final regulations that established 

 7 The School Breakfast Program began as a pilot project in 1966.

8 Nutrition Standards in the National School Lunch and School Breakfast Programs, 77 

Fed. Reg. 4088 (Jan. 26, 2012) (codified at 7 C.F.R. pts. 210 and 220).

Background
Page 5 GAO-15-656 School Nutrition

new nutrition standards for competitive foods in June 2013, and USDA 

required them to be implemented beginning in school year 2014-2015.9

For lunches, USDA regulations implementing the Healthy, Hunger-Free 

Kids Act of 2010 made changes to meal components and nutrition 

standards. Regarding meal components—fruits, vegetables, meats, 

grains, and milk—lunches must now include fat-free or low-fat milk and 

both fruit and vegetable choices.10 While students may be allowed to 

decline two of the five lunch components they are offered, they must 

select at least one half cup of fruits or vegetables as part of their meal in 

order for it to be reimbursable.11 (See fig. 1.) For nutrition standards, the 

regulations include minimum and maximum calorie levels for lunches and 

require that lunches do not include trans fat and contain reduced amounts 

of sodium and saturated fat.

 9 National School Lunch Program and School Breakfast Program: Nutrition Standards for 

All Foods Sold in School as Required by the Healthy, Hunger-Free Kids Act of 2010, 78 

Fed. Reg. 39,068 (June 28, 2013) (codified at 7 C.F.R. pts. 210 and 220).

10 For the fruit and vegetable meal components, total weekly juice offerings may not 

exceed one-half the total fruits and vegetables offered over the week. USDA regulations 

also specified additional requirements for maximum portions of meats and grains, 

however, USDA temporarily lifted these requirements for school years 2012-2013 and 

2013-2014 and issued regulations in January 2014 that removed the requirement that 

SFAs comply with these maximums. See GAO-14-104. We had previously recommended 

that the meat and grain maximum requirements be permanently removed, see 

GAO-13-708T.

11 The offer versus serve policy for lunch has been required for senior high schools and 

optional for all other schools since 1975. This policy provides an alternative to requiring 

students to be served all components. 
Page 6 GAO-15-656 School Nutrition

Figure 1: Examples of Lunches Provided Pursuant to the New Content and Nutrition Requirements

Note: These are examples of lunches selected by students from meal components offered. These 

lunches all include at least the required minimum of three meal components under the offer versus 

serve policy and some include four or five meal components.

USDA regulations also phased in some of the new lunch requirements. 

For example, in school year 2012-2013, USDA initially required that at 

least 50 percent of grain products offered in lunches had to be whole 

grain-rich—containing at least 50 percent whole grains—during the 

school week. In school year 2014-2015, the whole grain-rich requirement 

was increased to 100 percent of grain products, although SFAs may 
Page 7 GAO-15-656 School Nutrition

request temporary exemptions from this requirement from their states.12

USDA regulations also phase in requirements for sodium reductions in 

lunches. The Target 1 sodium limits became effective in school year 

2014-2015, and future sodium reductions are set for school years 2017-

2018 (Target 2) and 2022-2023 (Target 3). (See table 1.) However, USDA 

cannot implement these future reductions until the latest scientific 

research establishes that they are beneficial to children.13

Table 1: Sodium Targets for Lunch

Grade Group

Target 1: meet by 

July 1, 2014 (School 

Year 2014-2015) (mg)

Target 2: meet by 

July 1, 2017 (School 

Year 2017-2018) (mg)

Target 3: meet by 

July 1, 2022 (School 

Year 2022-2023) (mg)

K-5 <= 1,230 <= 935 <= 640

6-8 <= 1,360 <= 1,035 <= 710

9-12 <= 1,420 <= 1,080 <= 740

Source: USDA l GAO-15-656.

For breakfast, USDA’s regulations establish three meal components—

fruit, grains, and milk—and require that breakfasts include whole grainrich foods and only fat-free or low-fat milk. (See fig. 2.) Starting in school 

year 2014-2015, schools must offer one cup of fruit with each breakfast 

each day and may offer vegetables in place of fruit.14 If a school chooses 

to offer four or more food items, a child must take at least three, including 

at least one half cup of fruit or vegetable substitute, in order to have a 

 12 In May 2014, in advance of school year 2014-2015, USDA acknowledged that some 

SFAs were struggling with whole grain-rich products, particularly pasta. USDA allowed 

states to approve temporary exemptions for school years 2014-2015 and 2015-2016 from 

the requirement for pasta upon request from SFAs who could demonstrate hardship in 

finding whole grain-rich pasta products that students found acceptable. Subsequently, in 

February 2015, as required by the Consolidated and Further Continuing Appropriations 

Act, 2015, Pub. L. No 113-235, § 751, 128 Stat. 2130, 2171. USDA permitted states to 

approve temporary exemptions to SFAs from the requirement for any grain products for 

school years 2014-2015 and 2015-2016, upon request from SFAs that could demonstrate 

hardship.

13 The Consolidated and Further Continuing Appropriations Act, 2015, Pub. L. No. 113-

235, § 752, 128 Stat. 2130, 2171 provides that USDA cannot use its appropriations to 

implement requirements to reduce sodium below Target 1 until the latest scientific 

research establishes that the reduction is beneficial for children.

14 For breakfast, as well as for lunch, fruit juice may be offered as the fruit component. 

However, total weekly juice offerings may not exceed one-half the total fruits and 

vegetables offered over the week.
Page 8 GAO-15-656 School Nutrition

reimbursable meal.15 In addition, the new nutrition standards include 

minimum and maximum calorie levels for breakfasts and require that 

breakfasts include no trans fat and reduced amounts of sodium and 

saturated fat. Similar to lunch, the whole grain-rich requirement was 

phased in, with exemptions available, and the first sodium target was 

effective in school year 2014-2015, with further reductions in future years. 

(See table 2.)

 15 The offer versus serve policy for breakfast has been optional for schools since 1985. To 

exercise the offer versus serve option at breakfast, an SFA must offer a minimum of four 

food items daily as part of the required components. This policy provides an alternative to 

students being served all components.
Page 9 GAO-15-656 School Nutrition

Figure 2: Examples of Breakfasts Provided Pursuant to New Content and Nutrition Requirements

Note: These are examples of breakfasts selected by students from food items offered. These 

breakfasts all include at least the required minimum of three food items under the offer versus serve 

policy, and some include more.

Table 2: Sodium Targets for Breakfast

Grade Group

Target 1: meet by 

July 1, 2014 (School 

Year 2014-2015) (mg)

Target 2: meet by 

July 1, 2017 (School 

Year 2017-2018) (mg)

Target 3: meet by 

July 1, 2022 (School 

Year 2022-2023) (mg)

K-5 <= 540 <= 485 <= 430

6-8 <= 600 <= 535 <= 470

9-12 <= 640 <= 570 <= 500

Source: USDA l GAO-15-656.
Page 10 GAO-15-656 School Nutrition

For competitive foods, USDA regulations establish nutrition standards for 

foods or beverages, other than school meals, sold to children in schools 

during the school day, by the SFA or school groups. Competitive food 

sales may take place at fundraisers on the school campus, as well as at 

specific venues in schools, such as vending machines, school stores, and 

a la carte lines in the cafeteria, through which the SFA sells individually 

priced food and beverage items.16 The new federal competitive food 

requirements include limits on calories, sugars, total and saturated fat, 

trans fat, and sodium, establish new standards for beverages, and add 

whole grain-rich requirements.17 Competitive foods sold in schools 

generally must meet these requirements during the school day, which the 

regulations define as beginning at midnight and ending 30 minutes after 

the end of the school day. However, USDA has provided flexibility to 

states to grant exemptions from the competitive food requirements for 

infrequent fundraisers held during the school day, allowing states to set 

the number of fundraisers schools can hold in which the food items being 

sold do not have to meet competitive food requirements.18 Outside of the 

school day, food sales also do not have to comply with the requirements. 

Before the Healthy, Hunger-Free Kids Act of 2010, competitive foods 

were largely unregulated at the federal level, with only minimal restrictions 

prohibiting the sale of certain competitive foods, known as foods of 

 16 Side items in meals, when sold a la carte, generally must meet all competitive food 

requirements in addition to those met as part of a school meal. For example, a vegetable 

salad with dressing served as part of a lunch, as well as a la carte, has to meet the 

requirements for the vegetable component of a lunch, be factored into the nutrition 

standards for the lunch as a whole, and meet the nutrition standards for competitive food 

items individually. However, entrée items that make up part of a school meal are 

exempted from competitive food requirements, and can be purchased a la carte on the 

day of or the day immediately following when the menu item is included as part of a 

breakfast or lunch.

17 Beverages can include water or carbonated water with no size limits, as well as 

varieties of milk and 100 percent fruit/vegetable juice (with or without carbonation) less 

than or equal to 8 fluid ounces at elementary schools and up to 12 fluid ounces at middle 

and high schools. In addition, for high schools, other flavored and/or carbonated 

beverages, with or without caffeine, are allowed for beverage sizes up to 12 fluid ounces 

or up to 20 fluid ounces depending on calorie limitations.

18 However, exempted fundraiser food and beverage items may not be sold in competition 

with school meals in the food serving area during the meal service.
Page 11 GAO-15-656 School Nutrition

minimal nutrition value, during meal periods in school cafeterias and other 

food service areas.19

Nationwide, participation in the National School Lunch Program has 

declined in recent years after having increased steadily for more than a 

decade. In our January 2014 report, we found that total student 

participation in the National School Lunch Program—the total number of 

students who ate school lunches—dropped by a cumulative 1.2 million 

students (or 3.7 percent) from school years 2010-2011 through 2012-

2013, with most of the decrease occurring during school year 2012-

2013.20 According to our recent analysis of USDA data, school lunch 

participation continued to decline during school year 2013-2014, reaching 

a cumulative decline of 1.4 million students (or 4.5 percent) since school 

year 2010-2011.21 (See fig. 3.) The participation rate, which measures the 

 19 Foods of minimal nutrition value, as defined by USDA, included soda, chewing gum, 

and hard candy, for example. For more information, see GAO, School Meal Programs: 

Competitive Foods Are Widely Available and Generate Substantial Revenues for Schools, 

GAO-05-563 (Washington, D.C.: August 8, 2005).

20 See GAO-14-104. Each month, states report to USDA the number of lunches served in 

the program and USDA adjusts the data to determine the number of students 

participating. 

21 USDA also provided preliminary data for the first five months of school year 2014-2015. 

According to USDA officials, these data are subject to revision and should not be 

considered final. Although preliminary, these data suggest that participation in the National 

School Lunch Program did not continue to decline in the first five months of the school 

year as compared to the same five months in the prior school year. 

National School 

Lunch Participation 

Continued to Decline 

in School Year 2013-

2014, While Breakfast 

Participation 

Continued to Increase

School Lunch Participation 

Continued to Decline in 

School Year 2013-2014
Page 12 GAO-15-656 School Nutrition

proportion of all students in schools that take part in the National School 

Lunch Program who ate school lunches, also declined during this period, 

falling from 62 percent in school year 2010-2011 to 58 percent in school 

year 2013-2014.

Figure 3: Participation Changes Since School Year (SY) 2000-2001 in the National School Lunch Program for SY 2000-2001 

through 2013-2014

Note: Each month, states report to USDA the number of lunches served in the program and USDA 

adjusts the data to determine the number of students participating. Our analysis of school year data 

represents an average of 9 months—September through May—for each school year.

The decrease in the total number of students eating school lunches 

during the last three school years was driven primarily by a decrease in 

students paying full price for meals. Based on family income, children 

who participate in school meals programs either pay full price or qualify to 
Page 13 GAO-15-656 School Nutrition

receive free or reduced-price meals.22 The number of students paying full 

price for meals declined by two million, a decrease that could be caused 

by students choosing to no longer purchase lunch at school or by 

students becoming eligible for free or reduced-price meals.23 The decline 

in students paying full price for lunch exceeded the increase in the 

number of students eating free lunches during the same time period. (See 

fig. 4.)

Figure 4: Participation in the National School Lunch Program by Category of Student, School Years 2000-2001 through 2013-

2014

 22 SFAs generally determine the prices they charge for school meals, but children are 

eligible for free meals if their families have incomes at or below 130 percent of the federal 

poverty guidelines and reduced-price meals if their families have incomes between 130 

and 185 percent of the federal poverty guidelines. SFAs may charge a maximum of $0.40 

for a reduced-price meal. SFAs receive federal reimbursements for all lunches served to 

eligible students that meet federal lunch component and nutrition requirements, regardless 

of whether children pay for the meals or receive them for free. The amount of federal 

reimbursement that SFAs receive for each meal served to a child is based on the eligibility 

category of the child and the proportion of the SFA’s total lunches that are served to 

children eligible for free and reduced-price meals.

23 Enrollment changes may also affect the number of students who can participate in 

school meal programs, however, enrollment increased over this period.
Page 14 GAO-15-656 School Nutrition

Note: Each month, states report to USDA the number of lunches served in the program by category 

of student and USDA adjusts the data to determine the number of students participating. Our analysis 

of school year data represents an average of 9 months—September through May—for each school 

year.

State and SFA officials told us that several factors likely influenced 

decreases in participation in the school lunch program, though the extent 

to which each factor affected participation is unclear. For example, 

officials from all the SFAs we interviewed during school year 2012-2013 

reported that student acceptance of the lunch content changes was a 

challenge, which we heard again from officials we interviewed during 

school year 2014-2015. Further, officials from seven of the eight states 

we interviewed in school year 2014-2015 reported that the decreases in 

lunch participation were influenced by student acceptance of the changes 

made to comply with the new lunch content and nutrition standards.

According to officials from four states, another factor that may have led to 

lower participation among students paying full price for lunch is the 

federally-required increase in the prices of paid lunches in certain 

districts—also known as paid lunch equity.24 These federally-required 

price increases may have resulted in students who previously purchased 

school lunches deciding not to purchase lunch at the higher price.

The increase in lunch participation by students who qualify for free 

lunches may be influenced by several factors. USDA has reported that 

the introduction of the Community Eligibility Provision, which allows 

qualifying, high-poverty schools to provide free meals to all students, is 

intended to remove the stigma of receiving free meals and reduce 

administrative barriers to student participation.25 Other factors that may 

have influenced the increase in participation by students who receive free 

 24The Healthy, Hunger-Free Kids Act of 2010 contained a new revenue requirement, 

known as paid lunch equity, related to the prices SFAs set for paid lunches. It was 

developed, in part, because of a USDA study that found the average prices charged for 

paid lunches by some SFAs were less than the cost of producing those meals. In 2014, 

we reported that the paid lunch equity requirement caused many SFAs to raise the price 

of their paid lunches beginning in school year 2011-2012. See GAO-14-104. 

25 The Community Eligibility Provision (CEP), authorized as a part of the Healthy, HungerFree Kids Act of 2010, was phased in for an increasing number of states over a period of 

three years, beginning in school year 2011-2012. The program became available 

nationwide in school year 2014-2015. According to USDA, meal counts and participation 

statistics in CEP schools reflect the proportion of a school’s students that are considered 

eligible for free school meals as well as the proportion that would be required to pay for 

their meals in the absence of CEP.
Page 15 GAO-15-656 School Nutrition

school lunch include the economic downturn that began in 200726 and 

adjustments made to how student eligibility for free and reduced-price 

meals is determined.27

As we previously found in our January 2014 report, the impact of other 

factors at the local level on lunch participation may vary.28 Specifically, 

changes to district and school policies that affect school lunch may 

increase or decrease lunch participation. For example, in 2014, officials in 

three of the eight districts we visited noted that the time allotted for lunch 

periods may affect participation. In addition, USDA officials told us that 

school closures, mergers, moves, consolidation due to economic 

conditions, and issues with food service management companies may 

affect school lunch participation.

Participation in the School Breakfast Program continued its upward trend 

during school year 2013-2014, continuing more than a decade of steady 

increases. According to our analysis of USDA data, participation in the 

School Breakfast Program grew by 1.4 million students (or 12 percent) 

from school year 2010-2011 through school year 2013-2014, to a total of 

 26 The recession that began in 2007 ended in 2009. However, according to Census data, 

while the number of children under 18 living in poverty decreased each year since 2011, 

the number of children in poverty remains above pre-recession levels. Additionally, 

participation in programs aimed to reduce food insecurity may lag relative to economic 

recovery. For example, past research into why Supplemental Nutrition Assistance 

Program participation may continue to increase when employment starts to increase 

during the early stages of economic recovery suggests that real wages and job 

opportunities for less-skilled workers did not improve enough to raise people out of 

poverty and the need for food assistance remained high.

27 As we previously reported, there have been various efforts designed to ease the 

administrative burden when certifying children for multiple assistance programs with 

similar eligibility criteria. For example, since school year 2008-2009, all school districts 

have been required to certify as eligible for free meals students in households that receive 

benefits through the Supplemental Nutrition Assistance Program (SNAP), previously 

known as the Food Stamp Program. 42 U.S.C. § 1758(b)(4). Additionally, we previously 

noted that changes to state policies that broaden eligibility criteria for SNAP may have 

resulted in an increase in students eligible for free school meals. For more information, 

see GAO, Supplemental Nutrition Assistance Program: Improved Oversight of State 

Eligibility Expansions Needed, GAO-12-670 (Washington, D.C.: July 26, 2012). 

28 See GAO-14-104.

School Breakfast 

Participation Continued to 

Increase in School Year 

2013-2014
Page 16 GAO-15-656 School Nutrition

13.5 million students.29 (See fig. 5.) The participation rate also increased 

during this period, growing from 26 percent in school year 2010-2011 to 

28 percent in school year 2013-2014. In comparison with school lunch, 

the number of students participating in school breakfast was less than 

half of the number participating in school lunch in school year 2013-2014.

Figure 5: Participation Changes Since School Year (SY) 2000-2001 in the School Breakfast Program for SY 2000-2001 through 

2013-2014

Note: Each month, states report to USDA the number of breakfasts served in the program and USDA 

adjusts the data to determine the number of students participating. Our analysis of school year data 

represents an average of 9 months—September through May—for each school year.

According to USDA data, the increases in School Breakfast Program 

participation can be explained, in part, by program expansion.30

 29 USDA also provided preliminary data for the first five months of school year 2014-2015. 

According to USDA officials, these data are subject to revision and should not be 

considered final. While the data are not final, they suggest that School Breakfast Program 

participation continued to increase in the five first months of the 2014-2015 school year as 

compared to the same months in the prior year.

30 State officials also told us that breakfast participation was likely affected by some of the 

same factors as the school lunch program, including meal pattern changes, economic 

trends, and the introduction of the Community Eligibility Provision.
Page 17 GAO-15-656 School Nutrition

Specifically, since school year 2010-2011, the program has expanded to 

more than 1,500 additional schools, while also increasing the proportion 

of enrolled students eating breakfast. That growth has been driven largely 

by increases in the number of students eating breakfasts that receive free 

meals, which have accounted for 1.3 million of the 1.4 million additional 

average daily breakfasts served from school years 2010-2011 through 

2013-2014.31 (See fig. 6.) Breakfast has also benefitted from efforts 

intended to increase participation using alternative formats, such as 

providing students with breakfast in the classroom and breakfast after the 

school day has started. USDA found in 2009 that the probability of 

student participation in school breakfast increases when breakfast is 

served in the classroom rather than in the cafeteria, and that the more 

time students have to eat breakfast, the more student participation 

increases.32

Figure 6: Participation in the School Breakfast Program by Category of Student, School Years 2000-2001 through 2013-2014

 31 In comparison with school lunch, a greater proportion of free breakfasts were served 

(77 percent) than free lunches (63 percent) in school year 2013-2014. 

32 Bartfeld, Judi. “School Breakfast Program: Participation and Impacts” (2009).
Page 18 GAO-15-656 School Nutrition

Notes: Participation is expressed in average daily breakfasts served, adjusted for attendance using 

USDA’s adjustment factor. Each month, states report to USDA the number of breakfasts served in the 

program by category of student and USDA adjusts the data to determine the number of students 

participating. Our analysis of school year data represents an average of 9 months—September 

through May—for each school year.

SFAs and states reported that some of the challenges they have 

experienced meeting the new school meals requirements have persisted 

since school year 2012-2013, such as increased plate waste. Plate waste 

occurs when students take food required for a school meal, but then 

choose not to eat it. In our January 2014 report, 48 states reported that 

plate waste—particularly for fruits and vegetables—was a challenge for 

their SFAs in school year 2012-2013.33 Further, in 7 of the 17 schools we 

visited in school year 2012-2013, we saw many students throw away 

some or all of their fruits and vegetables at lunch. During school year 

2014-2015, directors and staff from five of the eight SFAs we reviewed 

indicated that this issue has persisted as a challenge, though staff from 

three SFAs reported that plate waste was not a problem at their schools. 

Our lunch observations suggest that plate waste may be beginning to

decrease as students adjust to school meals that meet the new 

requirements. Specifically, the plate waste we observed when visiting 

schools in school year 2014-2015 was generally limited to a small number 

of students throwing away some of their fruits and vegetables in 7 of the 

14 schools.34 SFA food preparation changes and student acceptance of 

 33 See GAO-14-104.

34 We also observed small numbers of students throwing away other types of foods, such 

as students in three schools throwing away some or all of their milk. 

SFAs Continue to 

Report Challenges 

with New School 

Meals Requirements 

and Expressed 

Concern about Future 

Sodium Restrictions

Some Challenges We 

Reported on Previously 

Have Persisted
Page 19 GAO-15-656 School Nutrition

fruits and vegetables may be helping to reduce fruit and vegetable waste 

in some districts. For example, officials from three SFAs noted that it is 

sometimes difficult for students to eat whole fruit during a meal, and one 

SFA has responded by giving pre-cut, rather than whole, fruit to 

elementary and middle school students. In addition, when we asked 

students what they like about school lunch, students we spoke with in 13 

of the 14 schools generally reported liking fruit and vegetable options, and 

those at 5 schools highlighted fruits or vegetables as their favorite 

breakfast or lunch items.

Although there has been some progress, poor student acceptance of 

certain foods is another longstanding challenge that SFAs continued to 

report. For example, in our prior work, we found that SFAs were 

challenged by student acceptance of some whole grain-rich products in 

school year 2012-2013.35 With the requirement increasing from half of 

grains served in meals having to meet the whole grain-rich definition 

beginning in school year 2012-2013, to all grains in school year 2014-

2015, we found that these acceptance challenges have continued for 

most SFAs we reviewed. Specifically, directors and staff from seven of 

eight SFAs told us that students do not like certain whole grain-rich foods, 

so getting them to take and eat them continues to be a challenge.36

Representatives from five of these SFAs highlighted whole grain pasta as 

being particularly challenging to serve, with one noting, for example, that 

whole grain-rich pasta loses structural integrity soon after being served, 

becoming unappealing to students. While none of the SFAs we visited 

had applied for the temporary pasta exemption or grain product 

exemption made available by USDA,37 we found that two had 

nevertheless been serving pasta that was not in compliance with the 

 35 See GAO-13-708T and GAO-14-104.

36 The eighth SFA director indicated that the SFA has not experienced recent challenges 

with student acceptance of whole grain-rich foods.

37 SFA directors provided a range of explanations for this, including not wanting to change 

the menu again when the temporary exemptions expire in the future and not being aware 

of the option to apply for the exemptions. Three of the eight SFA directors indicated their 

interest in pursuing a temporary exemption in the future. According to the state officials we 

spoke with, the number of SFAs that requested pasta exemptions and the number of 

SFAs approved for exemptions ranged across the eight states from 0 to more than 200. 

Also, according to USDA, all eight states in our review have notified USDA of their intent 

to offer the broader exemption from the whole grain requirement to the SFAs in their 

states.
Page 20 GAO-15-656 School Nutrition

whole grain-rich requirement. For example, one SFA director told us that 

she was not serving compliant lasagna noodles because she was unable 

to find whole grain-rich noodles that would work well in the SFA’s recipe.38

In addition, SFA directors and staff mentioned whole grain-rich bread and 

crackers as examples of other items that have been challenging to get 

some students to accept. In our June 2013 testimony, we also found poor 

student acceptance of vegetables in the beans and peas (legumes) and 

red/orange vegetable subgroups,39 and we found during our recent SFA 

visits that this challenge has persisted for five of the eight SFAs. For 

example, two SFA directors reported that they have tried to replace 

regular potatoes with sweet potatoes in fries or tater tots, but students 

have not embraced the change. Also, one SFA director noted that even 

when staff prepare a small amount of legumes, they end up throwing 

some of it away because children do not take it.

Despite their persistence, the challenges around student acceptance that 

we previously reported may be improving over time as students adjust to 

the lunch changes and SFAs find more acceptable products and recipes. 

Specifically, directors and staff from four SFAs we visited reported some 

success in addressing challenges in obtaining student acceptance of 

whole grains, including three that used white whole wheat flour and one 

that mixed whole grains—such as rice—in with other foods rather than 

serving them on their own. Another SFA director indicated that the SFA’s 

early adoption of whole grain-enriched foods helped ease the transition to 

meeting the federal standards, and student acceptance has improved 

over time. The opportunities for SFAs to receive temporary exemptions

from whole grain requirements—both specifically for pasta and generally 

for any grain product—were designed to help ease these challenges in 

some SFAs across the country. Further, food industry representatives we 

spoke with reported that they are taking steps to help schools improve 

preparation of these products, which may also help improve student 

acceptance. For example, representatives of three companies, including 

one that produces pasta, said that they are currently focused on 

educating SFAs and schools on preparation techniques that maximize 

palatability of whole grain-rich products. In addition, directors from two 

SFAs noted that they have found ways to incorporate legumes and 

 38 The SFA director indicated that the SFA would likely continue to use noncompliant 

lasagna noodles until the SFA was scheduled for its next compliance review by the state. 

39 See GAO-13-708T.
Page 21 GAO-15-656 School Nutrition

red/orange vegetables into dishes that students will eat. For example, one 

said the SFA was able to incorporate red/orange vegetables into popular 

harvest cake, pumpkin bars, and a sweet potato and apple side dish on 

the elementary school menus in the fall, and another successfully 

included black and refried beans in tacos.40

In our prior work, we also found that managing food costs was a 

significant challenge in school year 2012-2013.41 During our current 

review, we found that managing food costs has persisted as a challenge 

for several of the SFAs we visited. Specifically, 47 states reported that 

food costs were a challenge for their SFAs in school year 2012-2013, and 

all eight directors of SFAs we visited reported that fruit and vegetable 

expenditures increased substantially from school year 2011-2012 to 

school year 2012-2013. During our recent visits to SFAs, we found that 

four of the eight SFA directors continue to report increased food costs 

due to the new requirements for school meals, which three attributed, in 

part, to increased costs for fruits and vegetables.42 In addition, two SFAs 

reported a net financial loss from school years 2012-2013 to 2013-2014—

a trend they expected to continue for school year 2014-2015—which they 

said reduced their SFAs’ fund balances.43 In addition to increasing food 

costs, several SFA and state officials highlighted increasing employee 

wages and benefits as another major driver of SFAs’ increasing costs.

 40 According to USDA officials, a lack of culinary training may contribute to poor student 

acceptance of school meals. The agency issued professional standards requirements in 

July 2015, which officials said they expect to improve the ability and skills of personnel 

responsible for menu planning.

41 See GAO-13-708T and GAO-14-104.

42 Two SFA directors did not respond to our request for information about factors affecting 

SFA finances. The other two SFA directors did not report that their food costs had 

increased. In addition, according to officials from two states, food that meets the whole 

grain-rich requirement is also more costly than grains that do not meet the whole grainrich definition.

43 These two SFAs were among six that had previously reported a net financial loss from 

school year 2011-2012 to school year 2012-2013. In contrast, officials we spoke with from 

one state said that a greater number of the SFAs in their state are operating at a financial 

surplus exceeding the limit allowed in federal regulations, as compared to past years. 

Federal regulations generally limit SFA net cash resources—the cash SFAs carry in their 

accounts—to 3 months of average operating expenditures. Officials in that state indicated 

that required increases in paid lunch prices may have led to these SFAs’ surpluses.
Page 22 GAO-15-656 School Nutrition

The 2014-2015 school year marked the first school year for which SFAs 

were required to comply with sodium reductions as part of a planned 

phase-in for new sodium limits for breakfast and lunch, and while the 

eight SFAs we reviewed reported meeting the first sodium targets, 

officials reported difficulties in doing so. For example, to meet the first 

sodium target, three SFAs altered popular items to comply with the 

requirements, and three SFAs removed popular items altogether—

including certain cereals, biscuits and gravy, and chili. Staff from another 

SFA said they had replaced all added salt with pepper, which resulted in 

a strong pepper flavor for many foods, and other SFA staff reported 

switching to low-sodium gravy and removing pickles from the condiment 

station. Some students we spoke with in 6 of 14 schools made comments 

about the lack of flavor in school meals that suggested they noticed the 

changes SFAs made to meet the first targets. Further, we found that 

students in two of the SFAs had attempted ways to add sodium to their 

school meals, including bringing salt and pepper shakers to lunch in the 

cafeteria (see fig. 7) and asking school faculty and administrators to 

obtain additional condiment packets for them from the cafeteria. The 

dietitian in the latter SFA noted that under the current sodium restrictions, 

the SFA no longer allows students to take unlimited quantities of 

condiments.

SFAs and States Are 

Concerned about Meeting 

Future Sodium Targets 

Without Industry Help
Page 23 GAO-15-656 School Nutrition

Figure 7: Salt and Pepper Shakers Brought to Lunch by a High School Student

SFA directors, state officials, and industry representatives we interviewed 

expressed concerns about the future sodium targets for school meals. 

Directors and staff from three SFAs indicated that they made changes to 

food that are within their control in order to meet the first sodium 

requirements, and those from two noted that they are doubtful it will be 

feasible to meet the future targets without changes made by the food 

industry. Similarly, officials from three of eight states noted that SFAs’

success with meeting future sodium targets depends on industry’s ability 

to manufacture compliant foods that students will eat. Representatives 

from four of the eight food companies we interviewed said they 

anticipated problems with developing foods that would meet future 

targets. Three of the representatives noted that sodium is a necessary 

component of certain products, including breads, meat, and cheese, so 

reducing sodium content further in those products will be difficult. For 

example, one company representative said that reduced sodium could 

shorten products’ shelf lives. Representatives from two of the companies 

that are already reformulating their food products to meet the future 
Page 24 GAO-15-656 School Nutrition

targets said they have encountered challenges with respect to palatability 

when testing these reformulated foods.

In addition, we found that uncertainty about when and if future targets will 

be implemented may be delaying some industry progress toward 

developing compliant products. For example, a representative from one 

company said that the company is waiting to see if USDA will maintain 

the first target as the ultimate sodium limit, in part because changing 

formulations is expensive and time-intensive.44 Consistent with this, 

officials from two states said they believe some food manufacturers may 

be taking a wait-and-see approach to the sodium targets due to 

uncertainty about the implementation of future targets,45 which could 

impact the availability of low-sodium food products in the future. In April 

2015, USDA officials told us that, consistent with the statutory 

requirements, they have been examining the science around the health 

effects of sodium, and they do not expect to make any policy decisions on 

future sodium targets until the Dietary Guidelines for Americans 

recommendations are released later this year.

In 2010, the National Academies’ Institute of Medicine reported that 

several broad barriers precluded rapid and large reductions in the sodium 

content of school meals, noting that most schoolchildren prefer salty food, 

and that this preference should be expected to persist as long as children 

are exposed to salty foods at home or elsewhere.46 Pointing to studies 

showing that acceptance of diets with lower sodium content is more 

successful if carried out gradually, the Institute of Medicine recommended 

that USDA gradually phase in the sodium reductions in school meals over 

10 years.47 However, the Institute of Medicine said that following a 

 44 Industry representatives discussing product reformulations said that their companies 

need a minimum of one year’s lead time before these products might be ready for the 

market, and another noted that reformulating products to meet future sodium targets 

requires more time for small companies than for larger ones.

45 As discussed earlier in this report, the Consolidated and Further Continuing 

Appropriations Act of 2015 prohibits USDA from implementing future sodium reductions 

until the latest scientific research establishes that they are beneficial to children.

46 Institute of Medicine, School Meals: Building Blocks for Healthy Children (Washington, 

D.C.: The National Academies Press, 2010).

47 The Institute of Medicine report stated that it would be reasonable for USDA to 

determine subsequent sodium targets after the department assesses progress made 

following the implementation of each sodium reduction and the effect of the change on 

student participation rates, food cost, safety, and food service operation.
Page 25 GAO-15-656 School Nutrition

phased-in approach may not remove all related challenges to student 

acceptance, and SFAs will not be able to accomplish these reductions on 

their own. The report noted that the food industry’s partnership is 

essential because the current sodium content of many commercially 

prepared foods available for school meals is moderately high or high, and 

the food industry is responsible for the diversity and quality of these 

foods. It also acknowledged the correlation between palatable foods at 

school and school meals participation and concluded that it is unlikely that 

children will be easily motivated to continue to eat foods they find 

unappealing. Further, the report also noted that any loss of revenue 

based on decreased participation presents a threat to the financial 

stability of SFAs’ programs.

Recognizing the challenges related to implementation of the sodium 

targets, USDA officials told us they have taken steps intended to assist 

SFAs as they modify foods in preparation for the future targets. For 

example, officials told us they began planning an initiative in the summer 

of 2014 called “What’s Shaking? Creative Ways to Boost Flavor with Less 

Sodium” with the goal of developing and sharing strategies for reducing 

sodium levels in school meals. Officials reported that they have 36 

partners in this initiative, including organizations focused on improving 

public health and other federal agencies such as the Department of 

Health and Human Services’ Centers for Disease Control and Prevention, 

who began meeting in April 2015. USDA officials reported that they have 

also held roundtable discussions and are planning future listening 

sessions among districts to discuss and receive feedback on specific 

challenges SFAs are encountering as they try to plan menus with reduced 

sodium. An additional effort that may assist SFAs struggling with the 

sodium reductions in the future is USDA’s training and peer-to-peer 

mentoring program called “Team Up For School Nutrition Success,” which 

aims to leverage successes from some SFAs by sharing best practices 

with others that are struggling with specific aspects of implementing the 

new nutrition requirements.48 The department has also made a number of 

resources on reducing sodium in school meals available for SFAs on the 

department’s website, including recipes, fact sheets, presentations, and 

webinars.

 48 Officials told us that while this initiative provides training and technical support on such 

topics as menu planning and meal presentation, sodium has not yet been a specific topic 

for discussion. However, the initiative offered a June 2015 webinar entitled, “Making 

Sense of the Science of Sodium.”
Page 26 GAO-15-656 School Nutrition

USDA is also beginning to gather information from food producers about 

their progress toward developing school meals that meet the future 

sodium targets. In June 2015, the department requested proposals for a 

study examining the market availability of foods that meet both the current 

and future targets, as well as successes and challenges experienced by 

the food industry and SFAs as they take steps to reduce sodium in school 

meals.49 Among other things, the study aims to identify barriers the food 

industry faces and expects to face in the future in providing schools with 

lower sodium foods, as well as gauge progress made toward future 

sodium targets. In addition, officials reported that they have conducted 

some outreach to food industry representatives on the future sodium 

targets, for example, by visiting a spice manufacturing company to 

discuss alternative food preparation techniques that require little or no 

added salt. USDA officials also said that they are gathering feedback on 

trends related to new technologies and tactics industry is employing to 

lower sodium levels in food. In July 2015, USDA officials noted that food 

industry representatives they have talked to have committed to working 

toward the future targets, but have also emphasized that research and 

development efforts take time, and they do not want to compromise 

quality or taste in producing compliant foods. USDA officials noted that 

while they believe the sodium reductions in school meals can be 

achieved, doing so will take time and energy and will require both industry 

innovation and cooperation among SFAs, the food industry, USDA, and 

other partners that promote good child nutrition.

 49 The request for proposals indicates that the contract for this study will be awarded 

during fiscal year 2015, and the study will be completed within 36 months. 
Page 27 GAO-15-656 School Nutrition

While many states and school districts had pre-existing policies on 

nutrition standards for competitive food sales when the new federal 

requirements were established, SFAs and school groups in seven of the 

eight districts we reviewed reported that they had to make changes to the 

competitive foods they offered for sale in school year 2014-2015 to 

comply. USDA reported that, by 2012, at least half of states had 

competitive food standards for foods sold in schools through a la carte 

sales in the cafeteria, vending machines, school stores, and snack bars, 

and almost half had nutrition standards for foods sold through bake sales. 

Six of the eight school districts we reviewed were in states that had preexisting competitive food policies.50 However, pre-existing policies did not 

eliminate the need for most SFAs to make changes to comply in school 

year 2014-2015, as officials from seven of the eight SFAs we reviewed 

said that they discontinued some products and added other products to 

comply with the new federal standards.51 For example, some products, 

such as candy, were discontinued entirely. Further, two of eight SFA 

 50 According to state officials in six of the eight states that had SFAs we reviewed, their 

states had policies for competitive foods prior to the new federal competitive food 

requirements. In three states, these policies were voluntary, and in the other three states, 

they were mandatory. In addition, officials in three of the SFAs we reviewed in these 

states told us their school districts had previously adopted requirements more restrictive 

than their state policies for competitive foods.

51 Officials from seven of eight SFAs said they had made changes to comply with the new 

federal standards, while one SFA director told us that they had made changes in prior 

years to meet their local policy and therefore were already in compliance with the new 

federal standards. 

SFAs and Schools 

Made Changes to 

Comply with the New 

Federal Competitive 

Food Standards and 

Faced Challenges 

with Procurement, 

Revenue, and 

Oversight

SFAs and School Groups 

Had to Make Product 

Changes and Had 

Procurement Challenges
Page 28 GAO-15-656 School Nutrition

directors said that they stopped selling some items a la carte that were 

served as part of the school lunch, such as a side salad with dressing, 

peach cobbler, and fried potatoes, because the individual items did not 

meet the competitive food requirements.52 At one school, because some 

meal components met the competitive food requirements and others did 

not, the SFA discontinued all meal component a la carte sales to avoid 

confusing students. SFA directors, athletic directors, and a school store 

manager said that non-SFA groups also had to change the products they 

sold, for example, discontinuing sales of candy, donuts, chicken 

sandwiches from a restaurant, and full calorie soda.

SFAs and school groups also added various compliant food products to 

their competitive food sales. For example, some added products that had 

been reformulated to comply with the new requirements, such as flavored 

chips, puffed grain snacks, ice cream, and marshmallow cereal treats.53

Sports drinks continued to be offered at some schools, but in their lower 

calorie or no calorie versions and in small size bottles. Carbonated drinks, 

which were generally previously prohibited by federal regulations from 

being sold in school food service areas at mealtimes, were also added in 

their low-calorie and no calorie forms to competitive food sales in high 

school cafeterias at three of the eight SFAs we contacted.54

Six of eight SFAs told us they had difficulty, particularly during the 

beginning of school year 2014-2015, finding compliant competitive food 

products and obtaining sufficient quantities of the products to meet 

student demand. For example, two SFAs said they had a difficult time 

obtaining products like compliant chips and marshmallow cereal treats. 

 52 When side dishes from school meals are also sold individually, they are required to 

meet the competitive food standards.

53 One SFA director said that she was concerned about providing reformulated products 

as healthy snacks, even if they met the federal competitive food requirements. She said 

that she didn’t want to confuse children with popular snack brands and packaging, when 

they couldn’t get the reformulated version of the product at local stores. She said that this 

is not the way to teach children to eat healthfully. A representative from a national 

association told us that she had been contacted by some parents who were confused and 

concerned about the continued availability of such snacks in schools, now in reformulated 

forms.

54 The federal interim final competitive food regulations allow a variety of carbonated 

drinks to be sold in the school food service area and elsewhere, without meal time 

restrictions. Previously, carbonated beverages could not be sold in food service areas 

during meal times, unless exempted.
Page 29 GAO-15-656 School Nutrition

Food industry representatives we spoke with reported that these 

shortages were the result of initial difficulty estimating demand for the 

new reformulated products. However, SFAs reported that these supply 

challenges diminished as the year progressed.

SFAs reported concerns about revenue losses from switching to sales of 

competitive foods that comply with the new federal nutrition requirements. 

Of the five SFAs that provided us with information on their competitive 

food sales from the beginning of school year 2014-2015 up to the time of 

our visits, four told us that their competitive food sales had decreased in 

comparison to the previous school year, while one SFA reported 

increased competitive food sales. Specifically, reasons the SFAs gave for 

reduced revenues included lost sales from some of the popular, 

discontinued foods, and students not buying as much of the new foods 

offered for sale. SFAs also reported that the cost of compliant items was 

greater than the cost of noncompliant items sold previously, but they did 

not feel that they could increase prices to the same degree, which 

resulted in lower profits. The SFA director that reported increased sales 

said that her a la carte sales were slightly higher part way through the 

2014-2015 school year, possibly because she had not raised prices and 

that she offered a wide variety of snacks and beverages.

We also heard of mixed effects on school group fundraising revenues. 

For example an athletic director in one district we reviewed and a school 

store manager in another said that they had experienced reduced 

revenues from fundraising, which resulted in less money to subsidize 

athletic facilities, equipment, uniforms, field trips, and travel for 

competition at regional and national events.55 However, some groups also 

mentioned that changing from food to non-food sales can sometimes 

increase fundraiser revenues. For example, an athletic director in another 

district and a representative of a national association said that other types 

of fundraising, such as craft fairs or sales of cards that provide discounts 

at local restaurants and other businesses, have raised more money than 

candy sales in some districts.

 55 While we spoke with school officials in all eight districts we reviewed regarding 

competitive food sales in their schools, we did not speak with individual school groups in 

every district regarding competitive food sales, and therefore did not obtain revenue 

information in every district. In 2005, we reported that competitive food revenues were 

often used for these purposes and others. See GAO-05-563.

Some SFAs and Schools 

Reported Reduced 

Revenues from 

Competitive Food Sales
Page 30 GAO-15-656 School Nutrition

The concerns we heard about competitive food revenues are generally 

consistent with those raised by school districts in the past and discussed 

by USDA in its interim final regulations. For example, school districts we 

visited in 2005 that had taken steps to substitute healthy competitive 

foods for less nutritious items expressed strong concerns about potential 

revenue losses. However, at that time, the limited data available on 

competitive foods revenue from the schools and districts we visited 

suggested that districts experienced mixed revenue effects from changes 

made to competitive food sales.56 In USDA’s interim final regulations, the 

department acknowledged that there was considerable variation among 

schools in the share of their revenue from competitive foods, and some 

schools might see substantial reductions in competitive food revenues 

after implementation of the federal requirements, at least in the short 

term.

At the same time, revenue effects and other challenges related to 

implementing the new federal competitive food standards have likely 

been mitigated for school groups that received exemptions from the new 

requirements for certain fundraisers. School groups are subject to the 

same federal competitive food requirements as SFAs, unless exempted; 

USDA permits states to determine the allowed frequency of fundraising 

exemptions without federal review as long as those sales do not take 

place in the food service area during meal times. The eight states we 

reviewed varied in the number of fundraising exemptions allowed in 

school year 2014-2015, with no fundraiser exemptions allowed in four 

states and varied policies on the number exempted and their duration in 

the remaining four. For example, during school year 2014-2015, one state 

allowed 10 exempted fundraisers per year, per school with each lasting 

no longer than 4 consecutive days, while another state allowed unlimited 

fundraisers on 36 designated days during the school year. (See table 3.) 

Fundraiser exemptions remove challenges some school groups may face 

complying with the federal requirements, but they potentially raise other 

challenges as well. For example, in 2013 we found that some SFAs were 

concerned that these exemptions put the SFA at a competitive 

disadvantage relative to other food sales within the school.57 Further, 

some commenters on the interim final regulation raised concerns that 

 56 See GAO-05-563.

57 GAO-13-708T.
Page 31 GAO-15-656 School Nutrition

exempt fundraisers threaten the rule’s public health goals and student 

participation in the meals programs.

Table 3: State Fundraiser Exemptions

State Exemptions

Idaho 10 exempted fundraisers per year, per school. Each fundraiser can be no 

longer than 4 consecutive days. Additional exemptions may be 

requested.

Illinois Year 1: Middle school and high school, 36 exemption days; elementary 9 

exemption days. Number of groups that can fundraise on those days is 

not limited.

Year 2 and beyond: Middle school and high school, 9 exemption days; 

elementary 0 exemption days.

Louisiana No exemptions allowed.

Pennsylvania 10 exempt fundraisers for high school; 5 exempt fundraisers per

elementary school and middle school, per school, per year. Each 

fundraiser can last up to a week. 

Texas No exemptions allowed during school year 2014-2015. Beginning in 

school year 2015-2016, each school is allowed up to 6 exempt fundraiser 

days per school year. 

Virginia No exemptions allowed for school year 2014-2015. For school year 

2015-2016, 30 exempt fundraisers are allowed per school, per school 

year. Duration of the fundraisers is not addressed.

Washington No exemptions allowed.

Wisconsin 2 exempt fundraisers per student group, per year, each lasting up to 2 

weeks.

Source: State officials l GAO-15-656.

Without a fundraiser exemption, school groups may also sell other food 

products that do not comply with the competitive food requirements, on 

the school campus 30 minutes after school or in other non-school 

locations. In three of eight districts we reviewed, some vending machines 

were not turned on until after school. At two schools, we observed sales 

of food and beverage products 30 minutes after the end of the school 

day, when additional products were sold that did not meet the competitive 

food requirements, such as candy, large muffins, pizza, and full-calorie 

carbonated drinks. We were told that school groups also continued to 

have concession stands at after school sporting and other school events 

that sold products that were not subject to the competitive food 

requirements. Groups also continued to sell items like candy bars as 

fundraisers, providing boxes of candy bars to students that were to be 

sold to family, neighbors, and friends outside of school.
Page 32 GAO-15-656 School Nutrition

According to states and SFAs, the involvement of a variety of groups in 

competitive food sales at schools has made oversight of competitive food 

sales challenging. According to USDA, SFAs are responsible for the 

compliance of the sales they operate, and school districts are responsible 

for the compliance of foods sold in areas that are outside the control of 

the SFA. However, while principals at all of the schools we contacted 

were aware of competitive food sales at their schools, our conversations 

with them suggested that their involvement with oversight of these sales 

varied. For example, 6 of 16 principals said that they or the school 

administration must approve fundraisers. Further, 4 school principals told

us that they rely on the SFA director for information about the competitive 

food requirements. This is consistent with our conversations with SFA 

directors, as five of the eight SFA directors said that they provided 

information and assistance regarding the new competitive food 

requirements to school administration or school groups and helped 

determine product compliance. In one school district, competitive foods 

had to be approved by the SFA’s dietitian, and in two other school 

districts, the SFA director provided an approved-list of items that could be 

sold.58 However, at the same time, three of eight SFAs expressed 

concerns that not all school groups were in compliance with the new 

requirements and the consequences for noncompliance were unclear. For 

example, one SFA director said that when she observed noncompliant 

snacks being sold at schools, she reported it to the principal and 

superintendent, but that typically did not result in the noncompliant sales 

being shut down permanently. Beginning in school year 2014-2015,

USDA requires that periodic state reviews of schools identify the entities 

responsible for selling food and beverages and ensure that such food 

meets the competitive food requirements, which should help address 

such situations.

During our visits to schools and discussions with SFAs and students, we 

found that schools in six of the eight SFAs we reviewed had some 

competitive foods for sale during the school day that were not compliant 

with the new federal requirements. In some cases, particular items were 

out of compliance, such as a sports drink sold a la carte by a SFA that 

exceeded the size and calorie requirements, trail mix sold at a school 

store that exceeded the calorie and fat requirements, and pizza slices 

 58 At another school, the SFA director consulted with a fundraising group to help them find 

foods that would meet the requirements for their weekly fundraisers; however, the teacher 

sponsor told her that the group was going to operate as an exempt fundraiser instead.

Oversight of Competitive 

Food Sales has Been 

Challenging
Page 33 GAO-15-656 School Nutrition

sold by a school store during lunch that we were told did not meet whole 

grain-rich requirements.59 In other cases, we observed a bake sale in a 

school cafeteria during the lunch period, and students told us about 

another bake sale held by a teacher in a classroom during the school day 

and sales of candy in the library during the school day.60

All states we contacted indicated there were challenges in local level 

oversight of competitive foods. Officials from three of eight states said 

that there is a lack of clarity at the local level about who is responsible for 

compliance. Officials from two states said that neither the SFAs nor 

school administrators want to be the “food police,” responsible for 

overseeing compliance at the local level. Although officials from three 

states said that ultimately the superintendent is responsible for the 

compliance of school groups’ competitive food sales, not all districts have 

yet to work out how this operates at the local level or defined the role of 

the SFA director and others. In its interim final regulations, USDA foresaw 

issues with ensuring compliance at the local level and said it envisioned 

that a school district designee, such as a local school wellness 

coordinator, may need to take the lead in this area.61 USDA also 

suggested that sorting through who is responsible for monitoring 

competitive foods would initially require planning and cooperation, but if 

all parties (i.e., school wellness coordinator, SFA, and school groups) 

worked together, such as to share information on allowable foods, the 

department believed that implementation in future years would be greatly 

streamlined.

The expansion of state oversight responsibility to include reviews of 

competitive foods could help ensure compliance with the nutrition 

standards, though some states reported that initial oversight of this area 

has been challenging. Specifically, beginning in school year 2014-2015, 

states are now responsible for overseeing local compliance with both 

 59 We reported these instances of non-compliance to USDA.

60 While we did not further investigate these fundraising activities, we did report them to 

USDA. States are responsible for assessing such sales through periodic reviews of 

schools, beginning in school year 2014-2015.

61 In our 2005 report on competitive foods, we concluded that the lack of a single person 

responsible for the presence and sale of competitive foods in schools complicates efforts 

to ensure that new policies will be implemented as intended and maintained over time. 

See GAO-05-563.
Page 34 GAO-15-656 School Nutrition

federal school meals and competitive food requirements, including 

providing technical assistance and developing corrective action plans for 

SFAs and schools when noncompliance is found.62 However, officials 

from two of eight states told us that their initial oversight of this area 

suggests that all school districts do not take competitive food compliance 

seriously, and some try to find ways around the requirements.63 An official 

from another state said that there is sometimes resistance to modifying 

these sales from principals, especially when competitive food sales may 

be the only source of discretionary money for school activities and 

equipment. Officials from three of eight states also expressed concerns 

that they currently do not have enforcement tools for competitive food 

sales, and officials in one state said that they have heard from SFA 

directors who do not think that school groups will take compliance with 

the requirements seriously unless there are financial consequences.64

USDA officials also said that they will be reviewing all aspects of the first 

year’s implementation of the competitive food requirements and will 

consider any necessary changes before finalizing the competitive food 

regulations. When issues of competitive foods noncompliance arise 

during state oversight reviews, USDA has said that it sees technical 

assistance and training as the first step to address them. However, the 

competitive foods interim final regulations also indicate that USDA will 

issue a proposed rule to address a number of integrity issues related to 

administration of the school meal programs and competitive foods, which 

 62 States are required to conduct administrative reviews of SFAs’ school lunch and 

breakfast programs to assess compliance with program requirements at least once during 

each three-year review cycle, provided that each SFA is reviewed at least once every four 

years. In September 2014, USDA added a new section to its Administrative Review 

Manual for states to assess compliance with competitive food requirements. USDA 

recently issued proposed rules that would add competitive foods and other areas to the 

required scope of the administrative review. Administrative Review in the School Nutrition 

Programs, 80 Fed. Reg. 26,846 (proposed May 11, 2015).

63 Officials from one state told us that they were aware of fundraising groups at some 

schools that tried to find ways to get around complying with the requirements and tried to 

hide their activity during state reviews.

64 However, officials from another state said when they previously had a penalty for 

violations of state competitive food requirements, it was ineffective because the value of 

the penalty was far outweighed by the proceeds of the fundraisers.
Page 35 GAO-15-656 School Nutrition

will provide states options for imposing fines against any school or SFA 

failing to comply with program regulations.65

Officials from several states and SFAs that we interviewed during school 

year 2014-2015 indicated that USDA’s assistance on the new school 

meals and competitive food requirements was helpful or has recently 

improved; at the same time, some found the amount of USDA guidance 

to be overwhelming. As part of our January 2014 report, we found that all 

states found USDA’s guidance and training to be useful as the new 

school lunch requirements were implemented during school year 2012-

2013.66 As implementation of the school meals and competitive food 

changes continued during school years 2013-2014 and 2014-2015, 

officials from five states and two SFAs who we interviewed in school year 

2014-2015 similarly noted that USDA assistance has been helpful. For 

example, officials from one state noted that frequent webinars, covering 

such topics as menu planning using USDA foods, have been useful. In 

addition, two SFAs reported that USDA guidance on the changes has 

improved over time; however, a state official also told us that USDA has 

issued too much guidance, and it has overwhelmed SFAs. Officials from 

three SFAs we spoke with also told us that the amount of guidance they 

have received from USDA has been challenging, especially given the 

complex nature of the guidance, and one SFA official noted there is not 

enough time to read all of the guidance. This difficulty keeping up with the 

extensive amount of USDA guidance is consistent with what some states 

and SFAs reported to us during school year 2012-2013. In our 2014 

report, we found that, in the first 33 months after the Healthy, HungerFree Kids Act of 2010 was enacted (from January 2011 through 

September 2013), USDA issued about 90 memos to provide guidance to 

states and SFAs on the new requirements for the content of school 

lunches and paid lunch equity.67 In the 19 months since then (from 

October 2013 through April 2015), we found that USDA issued 51 

 65 USDA officials told us in July 2015 that the proposed rule was under development, but 

they could not provide us with a timeframe for when it will be issued.

66 GAO-14-104.

67 We reported that 85 percent of the memos—including those covering policy and 

providing technical assistance—addressed the new requirements for lunch content and 

nutrition standards, as well as related issues such as food procurement and state review 

of SFA compliance with the lunch requirements. The other 15 percent addressed paid 

lunch equity requirements. See GAO-14-104.

USDA’s Assistance 

Has Included a 

Substantial Amount of 

Guidance and Other 

Efforts
Page 36 GAO-15-656 School Nutrition

additional memos related to these changes. In total, USDA has issued 

nearly 4,700 pages of guidance on the lunch, breakfast, and competitive 

food requirements since the final rule on changes to the lunch and 

breakfast content and nutrition standards was issued in January 2012.68

With the bulk of the changes to school meals and competitive foods 

nutrition standards already required to be implemented, the need for 

USDA to issue additional guidance on these changes should diminish in 

future years, according to officials. In our 2014 report, we found that 

several SFAs reported challenges with the high volume of USDA 

guidance that was issued at the same time that they were implementing 

significant changes to the lunch program. Similarly, during the 2013-2014 

and 2014-2015 school years, SFAs were implementing substantial 

program changes—related to breakfast, competitive foods, and whole 

grains and sodium for lunch—concurrently with USDA’s issuance of 

guidance on those topics. Since the only future planned changes are 

additional sodium reductions for school meals and minor changes to 

competitive foods, it is likely the amount of USDA guidance will decrease.

Some state and SFA officials we spoke with also found USDA’s 

assistance in response to questions about school meals and competitive 

food requirements was not always timely or clear. While several state 

officials we spoke with said they appreciated USDA’s assistance or had 

good working relationships with USDA regional offices, officials from five 

of the eight states we spoke with were frustrated by USDA’s response 

times. Specifically, officials from two of those states said that USDA 

sometimes did not respond to questions for more than a month. Officials 

from two states also expressed frustration with the timing of USDA’s 

release of guidance surrounding state compliance reviews, as changes 

were made after the review cycle began. An official from one of the two 

states told us that as a result of the timing, the state was not able to 

effectively redesign its electronic records system after it had already been 

finalized. In addition, officials from two states and four SFAs also told us 

that some of USDA’s guidance was unclear or inconsistent. For example, 

 68 In our 2014 report, we found that from January 2012 through the end of school year 

2012-2013, USDA issued 1,800 pages of guidance addressing lunch content and nutrition 

standards, state review of SFA compliance with those standards, and related areas, such 

as food procurement. We calculated our new total by adding to this previous total all 

pages from guidance documents issued on these topics from July 2013 through April 

2015.
Page 37 GAO-15-656 School Nutrition

one SFA official said that guidance on whether certain a la carte items 

meet the competitive foods requirements was difficult to interpret.69 Two 

SFA officials also said that the guidance issued on juice—including how 

much can be offered and how frequently it can be offered—has been 

confusing.70 In addition, a state official described frustration with the 

multiple modifications of USDA’s guidance surrounding smoothies, which 

substantially changed how smoothie components were to be credited 

toward the meal pattern.71 However, not all SFAs we spoke with 

highlighted such challenges related to USDA guidance. For example, one 

SFA director noted that while one part of the competitive foods guidance 

was unclear, the competitive foods requirements are new, and she 

expected that USDA would provide clarity. She added that she thought 

USDA provided sufficient communications on the new requirements.

In recognition of the challenges SFAs have faced while implementing the 

new requirements, USDA has provided other types of assistance 

intended to help clarify the regulations and guidance. For example, USDA

partnered with the Institute of Child Nutrition to create the “Team Up For 

School Nutrition Success” training and mentoring program, which is 

designed for SFAs to share best practices. Also under this program, 

experienced SFAs provide targeted technical assistance to those 

struggling with certain aspects of implementation to clear up lingering 

confusion. In addition, the initiative offers monthly webinars for states and 

SFAs on a wide variety of topics—including menu planning and sodium, 

which are also made available online for later viewing.

Although USDA has taken some steps toward addressing three of the 

four recommendations included in our report and testimony on the school 

 69 USDA guidance on competitive foods also includes when entree items must meet the 

nutritional requirements for competitive foods, as well as circumstances when these items 

are exempt from these standards. 

70 In an updated questions and answers memo of August 4, 2014, USDA addresses 

seven questions regarding juice requirements on such issues as whether the limits on 

juice apply on a daily or weekly basis, how the requirements differ among grade groups, 

how frozen juice fluid volume is determined, and how combination vegetable and fruit juice 

blends count against the juice limits. 

71 USDA issued multiple guidance documents on smoothies, which differentiated between 

food and beverage smoothies and between snack and entrée smoothies. USDA also 

changed its guidance to allow schools to credit yogurt in smoothies as a meat/meat 

alternative for lunch beginning January 14, 2015, to be consistent with previous guidance 

which allowed schools to credit yogurt as a meat/meat alternative in breakfast smoothies.
Page 38 GAO-15-656 School Nutrition

lunch nutrition changes,72 the department has not yet acted to address an 

issue we reported in our 2013 testimony that would help SFAs meet the 

school lunch calorie requirements. Specifically, we found that the gap in 

the calorie ranges for the 6-8 and 9-12 grade groups—600-700 and 750-

850, respectively—was problematic for districts we visited that included 

schools with students in both groups. In guidance, USDA acknowledged 

that the lack of overlap in the calorie ranges for the two grade groups can 

be challenging and suggested that districts serve a menu appropriate for 

the lower grade level and add a few additional foods for students in the 

upper grade level. However, as part of that report we also found that this 

may not be a feasible solution for some schools because, for example, 

students in different grade ranges may use the same serving lines during 

a shared lunch period. In such schools, cashiers at the point-of-sale may 

not know each student’s grade level and therefore may not be able to 

accurately identify whether lunches comply with requirements. Thus, in 

that report we recommended that USDA provide flexibility to help SFAs 

with schools that serve students in both grade groups comply with the 

defined calorie ranges. While USDA generally agreed with the 

recommendation, indicating that it recognizes the need to address the 

challenges posed by the lack of overlap in the calorie ranges, the 

department has not yet taken action to address the issue.

In the absence of additional USDA assistance in this area, state and SFA 

officials we spoke with in school year 2014-2015 described varied 

approaches they have taken to address this issue, all of which are 

inconsistent with USDA regulations and guidance. For example, one state 

official told us that for schools serving meals to students in both grade 

ranges, the state recommended serving meals that met the calorie range 

associated with the predominant grade group served at each lunch 

period.73 An SFA from another state took a different approach, planning 

its menus for these schools to offer lunches with maximum calorie counts 

midway between the middle school maximum and the high school 

minimum. Officials from another state said that while USDA requirements 

do not provide flexibility in this area, and schools with both 6-8 and 9-12 

grade groups are supposed to be considered out of compliance if they are 

not meeting both calorie ranges, the state has instead chosen to use 

 72 See GAO-13-708T and GAO-14-104.

73 This approach is consistent with the previous school lunch requirements. 
Page 39 GAO-15-656 School Nutrition

common sense when reviewing the menus in such schools.74 As the 

absence of USDA guidance is leading to states making varied decisions 

about menu compliance in these schools, we continue to believe that our 

June 2013 recommendation to USDA (to provide some flexibility to SFAs 

with such schools) continues to have merit and should be fully 

implemented.75

We provided a draft of this report to the U.S. Department of Agriculture for 

review and comment. On September 1, 2015, the FNS Director for 

Program Monitoring and Operational Support Division, Child Nutrition 

Programs, and other FNS officials provided us with their oral comments. 

The officials stated that they generally agreed with the report findings. 

However, we discussed our previous recommendation that USDA provide 

school districts with flexibility to help them comply with the lack of overlap 

in the calorie ranges for lunches served to students in grades 6-8 and 9-

12 in schools with both grade groups. As stated in this report, we again 

found that some SFAs and states with schools that include students from 

both grade groups were taking varied approaches to address the lack of 

overlap in the calorie ranges for school lunch, which were inconsistent

with USDA requirements. Officials noted that USDA believes it is 

important to maintain the scientifically-based, age-appropriate calorie 

ranges and is unlikely to change the calorie requirements. However, they 

 74 This approach is generally consistent with the Institute of Medicine’s recommendations 

in its report on which the federal requirements are based. The report’s authors suggested 

that, for schools serving students from multiple grade groups on the same serving line, the 

SFA should work with the state agency to find a solution that ensures the basic elements 

of the standards for menu planning will be maintained, including moderate calorie values.

75 In 2014, we reported that national data, as well as our conversations with states and 

visits to schools, suggested that some instances of SFA noncompliance may not have 

been fully documented while the new lunch requirements were being implemented in 

school year 2012-2013. Further, we expressed concern that USDA’s guidance to states 

on assessing SFA compliance with the new requirements moving forward may continue to 

inadvertently lead to states not consistently documenting noncompliance. We noted that 

without such documentation, USDA has limited information on the extent to which SFAs 

are facing similar difficulties complying with the new requirements, which could be the 

focus of future federal technical assistance efforts. See GAO-14-104. 

Agency Comments
Page 40 GAO-15-656 School Nutrition

noted that our findings show an inconsistency in state oversight of 

districts with such schools and indicate a continued need for clarification. 

The officials said that they intend to continue providing menu planning 

guidance and technical assistance to states and districts to help them

comply with these requirements. We continue to believe that additional

flexibility from USDA would assist school district efforts to comply and is

consistent with the Institute of Medicine’s suggestions that USDA and

states should work together to find a solution in these schools, though we 

appreciate that additional technical assistance from USDA may also help 

achieve this goal. FNS also provided technical comments on the draft

report, which we have incorporated as appropriate.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Agriculture, and 

other interested parties. In addition, this report will be available at no 

charge on GAO’s website at http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix II.

Sincerely yours,

Kay E. Brown

Director, Education, Workforce, and Income Security Issues
Appendix I: Scope and Methodology

Page 41 GAO-15-656 School Nutrition

To assess trends in school lunch and breakfast participation, we analyzed 

USDA’s national data on meals served in the National School Lunch and 

School Breakfast Programs from school year 2000-2001 through school 

year 2013-2014.1 We used the same methodology to assess trends in 

participation as we had in our prior report on the initial implementation of 

school lunch changes.2 Each month, states report to USDA on the FNS10 form the number of lunches and breakfasts served by category of 

student—free, reduced-price, and paid—as well as average daily lunches 

and breakfasts served to all students. These data are used to determine 

federal reimbursement payments to states. Additionally, in October of 

each school year, states report to USDA the total number of students 

enrolled in schools with the National School Lunch and School Breakfast 

Programs.

Although USDA does not collect additional data on the number of 

students participating in the programs each month, the department uses 

the lunch and breakfast data it collects to determine the number of 

students participating in the programs. Specifically, USDA adjusts the 

data on average daily lunches and breakfasts served each month upward 

to help account for students who participated in the programs for a 

number of days less than all days in the month. To make this adjustment, 

 1 These data include meals served in public and private schools and residential child care 

institutions in the 50 states, the District of Columbia, Guam, Puerto Rico, the U.S. Virgin 

Islands, and the U.S. Department of Defense’s military bases. USDA also provided 

preliminary data for the first five months of the 2014-2015 school year, which we used to 

describe general trends in school meals participation over the first five months of the 

2014-2015 school year. According to USDA officials, these data are subject to revision 

and should not be considered final.

2 See GAO, School Lunch: Implementing Nutrition Changes Was Challenging and 

Clarification of Oversight Requirements is Needed, GAO-14-104 (Washington, D.C.: 

January 28, 2014).

Appendix I: Scope and Methodology

U.S. Department of 

Agriculture (USDA)

Participation Data
Appendix I: Scope and Methodology

Page 42 GAO-15-656 School Nutrition

USDA uses an estimate of the proportion of students that attend schools 

daily nationwide.3

To analyze participation in the National School Lunch and School 

Breakfast Programs, we reviewed USDA’s data on meals served and 

students enrolled, as well as the department’s methodology for 

determining student participation, and determined these data and the 

method to be sufficiently reliable for the purposes of this report. 

Specifically, we interviewed USDA officials to gather information on the 

processes they use to ensure the completeness and accuracy of the 

school lunch and breakfast data, reviewed related documentation, and 

compared the data we received from the department to its published data. 

To determine school year participation from these data, both overall and 

by free, reduced-price, and paid categories, we relied on 9 months of 

data—September through May—for each year.4

To understand the scale and scope of assistance USDA has provided to 

states and SFAs, we analyzed guidance memos USDA issued from 

October 2013 through May 2015. This period allows for a seamless 

continuation of the analysis we conducted for the previous study on 

implementation of the new nutrition requirements for school lunch, which 

reviewed guidance issued from January 2011 through September 2013.5

Our intent was to continue our longitudinal review of USDA-issued 

guidance addressing implementation of the updated nutrition 

requirements, as well as paid lunch equity, and we used the same 

methodology that we used for the prior study. Specifically, we reviewed all 

guidance memos issued to states during this time period and further 

analyzed those that provided guidance addressing the new requirements 

for the content of school meals and competitive foods, including related 

issues such as food procurement and state review of SFA compliance 

 3 USDA divides the data reported for average daily lunches and breakfasts by an 

attendance factor of 0.927 to estimate monthly meal participation. USDA officials said this 

methodology has been in place for many years and the attendance factor was historically 

derived. We determined that this attendance factor is similar to average daily attendance 

data published annually by the U.S. Department of Education.

4 On its public website, USDA reports annual school lunch participation based on fiscal 

year rather than school year.

5 GAO-14-104. 

Guidance Documents
Appendix I: Scope and Methodology

Page 43 GAO-15-656 School Nutrition

with the requirements, as well as those addressing the paid lunch equity 

requirements. These memos included the department’s policy and 

technical assistance memos, as well as other relevant guidance memos 

that were not designated in one of those categories. For guidance memos 

that were released in multiple versions, we considered each version to be 

a separate piece of guidance. We assessed the number of pages 

included in each document, defined as the number of digital pages for 

each guidance document, including attachments. In the case of 

spreadsheet files, we counted each worksheet within the file as a single 

page. We did not conduct an independent legal analysis of these 

guidance memos.

To gather information from the local level on implementation of the new 

nutrition requirements for school meals and competitive foods, we 

contacted the same eight school districts across the country that we had 

visited as part of our prior study of implementation of the new school 

lunch requirements in school year 2012-2013.6 From December 2014 

through March 2015, we visited Carlisle Area School District (PA), 

Chicago Public Schools (IL), Coeur d’Alene School District (ID), Fairfax 

County Public Schools (VA), Irving Independent School District (TX), 

Mukwonago Area School District (WI), and Spokane Public Schools 

(WA). For the eighth district—Caddo Parish Public Schools (LA)—we 

gathered information over the phone from the SFA director and officials 

from two schools, as our on-site visit to the district was impeded by 

weather-related school closings. We selected these school districts 

because they provided variation across geographic location, district size, 

and certain characteristics of the student population and district food 

services. For example, the proportion of students eligible for free and 

reduced-price lunches and the racial and ethnic characteristics of the 

student population varied across the districts selected. Further, we 

selected districts with different food service approaches, including some 

that generally prepared school meals in one central kitchen before 

delivering them to schools, some that prepared meals in kitchens on-site 

in each school, and others that used alternative approaches for food 

preparation. Six of the school districts we contacted managed their own 

food service operations, while two districts contracted with food service 

management companies. We relied on the U.S. Department of 

 6 GAO-14-104.

Site Visits
Appendix I: Scope and Methodology

Page 44 GAO-15-656 School Nutrition

Education’s Common Core of Data, which provides information on public 

schools,7 to ensure selected districts met several of our criteria. As a 

result, all of the districts we selected for site visits were public, although 

non-profit private elementary and secondary schools, as well as 

residential child care institutions, also participate in the National School 

Lunch Program and the School Breakfast Program.

In each of the districts we visited, to gather information on local level 

implementation of the new nutrition requirements, we interviewed the SFA 

director, as well as other key district-level SFA staff and food service staff 

in two schools. During these interviews, we collected information about 

lunch and breakfast participation trends; challenges, if any, implementing 

the new meal content requirements; challenges, if any, implementing new 

nutrition standards for competitive foods; and USDA and state assistance 

with the changes. To select the schools we visited in each district, we 

worked with the SFA director to ensure the schools included students of 

differing grade levels. This allowed us to observe any relevant differences 

in their reactions to the new meal and competitive food requirements. In 

each school we visited, we observed breakfast and lunch service, as well 

as competitive food sales—including students’ food selections, 

consumption, and plate waste—and, when feasible, interviewed students 

and school staff to obtain their thoughts on the changes. We also 

interviewed the eight state child nutrition program directors overseeing 

these districts to gather information on statewide lunch and breakfast 

participation trends; SFA challenges, if any; and USDA and state 

assistance with implementation of the changes. Contacting these districts 

and states a second time provides a short-term longitudinal perspective 

on challenges related to implementation of the phased-in changes. 

However, we cannot generalize our findings from SFAs, districts, and 

states beyond those that we contacted.

To gather additional information we interviewed various school nutrition 

stakeholder groups, including subject matter experts, professional 

organizations, and industry representatives. We selected groups among 

 7 The Common Core of Data is a program of the U.S. Department of Education’s National 

Center for Education Statistics that annually collects fiscal and non-fiscal data about all 

public schools, public school districts, and state educational agencies in the United States. 

The data are supplied by state educational agency officials and include information that 

describes schools, school districts, students, and staff, as well as fiscal data.

Stakeholder and Industry 

Groups
Appendix I: Scope and Methodology

Page 45 GAO-15-656 School Nutrition

those that were involved with school meals, had an interest in children’s 

nutrition, and/or were involved in competitive food snacks and beverages, 

as well as school fundraisers. This included the School Nutrition 

Association (SNA),8 the National PTA, the Center for Science in the 

Public Interest, and other members of the National Alliance for Nutrition 

and Activity. We also spoke with the American Beverage Association, the 

Snack Food Association, and a group of industry officials who are also 

members of SNA.

 8 The School Nutrition Association (SNA) is a national non-profit organization that 

represents 55,000 members, which include those involved in serving meals to children in 

schools, as well as those that provide support, products or services to school foodservice 

professionals and school nutrition programs. 
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-15-656 School Nutrition

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

In addition to the contact named above, Rachel Frisk (Assistant Director), 

Dan Meyer (Analyst-in-Charge), Luke Baron, Sara Pelton, and Christine 

San made key contributions to this report. Also contributing to this report 

were Divya Bali, James Bennett, Jessica Botsford, David Chrisinger, 

Aimee Elivert, Kathy Leslie, Theresa Lo, Jean McSween, Steve D. Morris, 

Lorin Obler, and Lindsay Read.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100040)
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