Report to Congressional Requesters

United States General Accounting Office 

GAO

April 2004 SCHOOL MEAL 

PROGRAMS 

Competitive Foods 

Are Available in Many 

Schools; Actions 

Taken to Restrict 

Them Differ by State 

and Locality 

GAO-04-673 
Page i GAO-04-673 School Meal Programs 

Letter 1

Appendix I Briefing Slides 4 

Abbreviations 

CDC Centers for Disease Control and Prevention 

FMNV foods of minimal nutritional value 

FNS Food and Nutrition Service 

SHPPS School Health Policies and Programs Study 

SMI School Meals Implementation 

SNDA-II School Nutrition Dietary Assessment Study–II 

USDA United States Department of Agriculture 

Contents 

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Page 1 GAO-04-673 School Meal Programs 

April 23, 2004 

The Honorable Tom Harkin 

Ranking Member 

Committee on Agriculture, Nutrition, and Forestry 

United States Senate 

The Honorable Patrick J. Leahy 

Ranking Member 

Subcommittee on Research, Nutrition, and General Legislation 

Committee on Agriculture, Nutrition, and Forestry 

United States Senate 

The Honorable George Miller 

Ranking Member 

Committee on Education and the Workforce 

House of Representatives 

The Honorable Lynn Woolsey 

Ranking Member 

Subcommittee on Education Reform 

Committee on Education and the Workforce 

House of Representatives 

The nation faces a complex challenge in addressing recent trends in 

children’s health and eating habits. Data from the U.S. Centers for Disease 

Control and Prevention (CDC) have shown that over 15 percent of 

children and adolescents ages 6 to 19 are overweight, a proportion that has 

significantly increased since the 1960s. In addition, CDC has also reported 

an increase in the frequency of type 2 diabetes in U.S. children and 

adolescents over the last two decades. Trends in obesity and a low level of 

physical activity among children and adolescents may be a major 

contributor to this increase. 

To address these trends, in 2001, the U.S. Surgeon General issued a call to 

action to prevent and decrease overweight and obesity among all 

Americans, especially children. In this statement, schools were identified 

as one of the key settings for public health strategies to address these 

issues. Since a large portion of a child’s day is spent in school, providing 

children with healthy food options throughout the school day can be an 

important step toward good child nutrition. The National School Lunch 

United States General Accounting Office 

Washington, DC 20548 
Page 2 GAO-04-673 School Meal Programs 

and School Breakfast Programs provide millions of children with 

nutritious meals each school day. The United States Department of 

Agriculture’s (USDA) Food and Nutrition Service (FNS) administers these 

programs at the federal level, and FNS subsidizes the meals served 

through these programs in local schools as long as the meals meet certain 

nutritional guidelines. In the last decade, these nutritional guidelines were 

amended to require schools to serve meals that adhere to the Dietary 

Guidelines for Americans, which limit total and saturated fat and provide 

specific minimum levels of vitamins and nutrients. Despite these efforts to 

improve the nutritional quality of meals offered through the school meal 

programs, other foods not provided through these programs are often 

available to children at school through a la carte lines in the cafeteria 

where individual foods and beverages can be purchased, snack shops, 

school stores, vending machines, and other venues. The nutritional value 

of these foods, often referred to as competitive foods, is largely 

unregulated by the federal government. 

Because of your concern about the trends in children’s health and eating 

habits and your interest in further understanding issues related to 

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

questions: (1) Which foods and school food practices fall under the term 

competitive foods, and what federal restrictions exist on their sale? (2) 

What is currently known about the types of competitive foods and their 

availability and prevalence in schools? (3) What is currently known about 

additional steps that are being taken on the state and local levels to curtail 

the sale of competitive foods? 

To answer your questions, we reviewed a variety of data sources, 

including legislation, policies, and studies that address competitive foods 

in schools. From these sources, we gathered information on federal and 

state competitive foods laws and regulations. In addition, we analyzed data 

on the availability, prevalence, and types of competitive foods in schools 

provided in three national studies—the School Nutrition Dietary 

Assessment Study-II, the School Health Policies and Programs Study of 

2000, and the Third Year Report of the School Meals Initiative 

Implementation Study. We also reviewed several smaller-scale studies that 

address the association between competitive foods in schools and child 

nutrition. We examined each study to assess the adequacy of the samples 

and measures employed, the reasonableness and rigor of the statistical 

techniques, and the validity of the results that were drawn from the 

analyses. To supplement the information collected from these sources and 

to gather information on steps that have been taken at the local level to 

restrict competitive foods in schools, we conducted interviews with 
Page 3 GAO-04-673 School Meal Programs 

several professional organizations, advocacy groups, and other 

stakeholders. We conducted our review from January through March 2004 

in accordance with generally accepted government auditing standards. 

On April 12, 2004, we briefed interested Senate staff on the results of our 

analysis. This report formally conveys the information provided during 

that briefing. In summary, we reported that 

• Competitive foods include all foods and beverages sold in schools except 

for meals provided through the School Lunch and School Breakfast 

Programs. Current federal regulations restrict only a subset of competitive 

foods, foods of minimal nutritional value, from being sold during 

mealtimes in food service areas. 

• Competitive foods are sold in a variety of locations on a majority of school 

campuses nationwide. The types of competitive foods available often 

differ by location where they are sold, with healthy foods more often sold 

in a la carte lines in the cafeteria and less healthy foods more often sold 

through vending machines, school stores, canteens, and snack bars. 

• Several states, school districts, and individual schools have enacted 

competitive foods policies that are more restrictive than federal 

regulations. These policies differ widely in the types of restrictions they 

apply. 

We provided a draft of this briefing to officials at FNS for their technical 

comments and incorporated their comments where appropriate. 

We are sending copies of this report to relevant congressional committees 

and other interested parties and will make copies available to others upon 

request. In addition, this report will be available on GAO’s Web site at 

http://www.gao.gov. If you or your staff have any questions about this 

report, please contact me at (415) 904-2272 or Kay E. Brown at (202) 512-

3674. Rachel Weber, Kevin Jackson, and Dan Schwimer also made 

significant contributions to this report. 

David D. Bellis 

Director, Education, Workforce, 

 and Income Security Issues 
Appendix I: Briefing Slides 

Page 4 GAO-04-673 School Meal Programs 

Appendix I: Briefing Slides 

School Meal Programs: Competitive 

Foods Are Available in Many Schools; 

Actions Taken to Restrict Them Differ by 

State and Locality

Requested by 

Senator Tom Harkin, Ranking Member

U.S. Senate Committee on Agriculture, Nutrition, and Forestry 

Senator Patrick Leahy, Ranking Member

Subcommittee on Research, Nutrition, and General Legislation

Representative George Miller, Ranking Member

U.S. House Committee on Education and the Workforce

Representative Lynn Woolsey, Ranking Member

Subcommittee on Education Reform

April 12, 2004
Appendix I: Briefing Slides 

Page 5 GAO-04-673 School Meal Programs 

2

Objectives

We were asked to determine:

• Which foods and school food practices fall under the term 

competitive foods, and what federal restrictions exist on their sale?

• What is currently known about the types of competitive foods and

their availability and prevalence in schools?

• What is currently known about additional steps that are being taken 

at the state and local levels to curtail the sale of competitive foods?
Appendix I: Briefing Slides 

Page 6 GAO-04-673 School Meal Programs 

3

Scope and Methodology

• Federal definition and restrictions: We reviewed laws, regulations, 

and court opinions related to USDA’s authority. 

• Availability, prevalence, and types: We reviewed three national 

studies that collected data on these factors.1

We also reviewed 

studies that discuss the association between competitive foods in 

schools and child nutrition. 

• State and local efforts: We reviewed state codes and regulations, 

national databases of proposed state legislation, and recently 

published news articles. We also interviewed several professional 

organizations, trade associations, and advocacy groups.

This review was conducted in accordance with generally accepted 

government auditing standards.

1 We reviewed the Department of Agriculture’s School Meals Implementation Study—Third Year Report (SMI) 

(Washington, D.C.: 2002); the Department of Agriculture’s School Nutrition Dietary Assessment Study—II (SNDA-II) 

(Washington, D.C.: 2001); and the Department of Health and Human Services, Centers for Disease Control and 

Prevention’s School Health Policies and Programs Study (SHPPS) (Washington, D.C.: 2001). 
Appendix I: Briefing Slides 

Page 7 GAO-04-673 School Meal Programs 

4

Summary of Results

• USDA defines competitive foods broadly to include all foods that

are offered for sale at school, with the exception of meals served 

through the federal school meal programs. Current federal 

regulations restrict a small subset of competitive foods in schools 

by prohibiting the sale of foods of minimal nutritional value (FMNV) 

in the food service areas during mealtimes.

• Competitive foods are available from various sources on many 

school campuses. The types of competitive foods in schools differ 

by location where they are sold, with healthy foods more often sold 

in a la carte lines and less healthy foods more often sold in vending 

machines, school stores, canteens, and snack bars.2

• Several states and localities have enacted competitive foods 

policies that are more restrictive than federal regulations. These 

differ widely in the restrictions they apply.

2 Healthy foods are those classified as “low in fat” by SHPPS, while less healthy foods are those classified as 

“high in fat, sodium, or added sugars” by SHPPS.
Appendix I: Briefing Slides 

Page 8 GAO-04-673 School Meal Programs 

5

Background

In recent years, both government and public attention have become 

focused on the increasing incidence of overweight and obesity 

among the US population. 

• Data from the Centers for Disease Control show that the 

percentage of children and adolescents (ages 6 to 19) who are 

overweight has tripled since the 1960s to more than 15 percent 

in 1999-2000. 

• To address this trend, in 2001, the Surgeon General issued a 

call to action to prevent and decrease overweight and obesity. 

In this statement, schools were identified as a key setting for 

public health strategies to address these issues. Specific 

school actions identified included adopting policies that ensure

all foods and beverages available on school campuses 

contribute toward healthy eating patterns. 
Appendix I: Briefing Slides 

Page 9 GAO-04-673 School Meal Programs 

6

Background (cont'd)

Two federal programs provide meals to students—the National School 

Lunch Program (1946) and the School Breakfast Program (1966). 

• These programs provide nutritionally balanced low-cost or free 

meals to schoolchildren. 

• The National School Lunch Program also provides snacks for 

eligible students in after-school-care programs.

• USDA administers the school meal programs at the federal level.

• Schools are required to serve meals that meet the Dietary 

Guidelines for Americans, which include limits on total fat and 

saturated fat. School meals must also meet other nutritional 

standards (e.g., lunches must provide one-third of the 

recommended daily allowances for calories and nutrients).
Appendix I: Briefing Slides 

Page 10 GAO-04-673 School Meal Programs 

7

Federal Definition and Restrictions: Competitive 

Foods Include All Foods Offered in Schools except 

School Meals

USDA defines competitive foods as any foods offered at school, both 

those that are healthy as well as less healthy, other than meals

served through the federal school meal programs. USDA further 

defines two categories of competitive foods—foods of minimal 

nutritional value (FMNV) and all other foods offered for individual 

sale. 

• FMNV are identified as carbonated beverages, water ices, 

chewing gum, hard candy, jellies and gums, marshmallow 

candies, fondant, licorice, spun candy, and candy-coated 

popcorn.

• Other competitive foods offered for sale in schools include any 

foods purchased through a la carte sales in the cafeteria, 

vending machines, school stores, canteens, and snack bars. 

Fund-raisers for various clubs and organizations sometimes 

offer other foods for sale in schools.
Appendix I: Briefing Slides 

Page 11 GAO-04-673 School Meal Programs 

8

Federal Definition and Restrictions: Competitive 

Foods Include All Foods Offered in Schools except 

School Meals (cont'd)
Appendix I: Briefing Slides 

Page 12 GAO-04-673 School Meal Programs 

9

Federal Definition and Restrictions: Federal 

Restrictions on Competitive Foods in Schools Are 

Limited

USDA regulations for the federal school meal programs require that 

states and school food authorities prohibit the sale of FMNV in the 

cafeteria and other food service areas during the school meal 

periods.

• In 1983, the District of Columbia Federal Court of Appeals struck 

down USDA regulations prohibiting the sale of FMNV anywhere 

on school grounds until the last lunch period ends. The court 

interpreted USDA’s regulatory authority as extending only to 

those foods sold in the cafeteria and other food service areas 

during school meal periods.3

According to USDA officials, though the agency cannot regulate 

competitive foods beyond the scope of its authority, it has tried to 

influence school policy on competitive foods by providing 

information on how to create a healthy school nutrition environment. 

3 See National Soft Drink Association v. Block, 721 F.2d 1348 (D.C. Cir. 1983).
Appendix I: Briefing Slides 

Page 13 GAO-04-673 School Meal Programs 

10

Availability, Prevalence, and Types: Competitive 

Foods Are Widely Available through A La Carte Lines 

in Many Schools

According to national studies, competitive foods are available in 

several locations on school campuses, including cafeteria a la carte 

lines. 

• In 2000, 83.4 percent of all schools offered food or beverages 

other than milk a la carte.4

• A la carte sales have increased in many schools, with the 

largest increases reported by middle and secondary schools. 

Over 80 percent of school districts reported offering a la carte

sales in their middle and secondary schools in the 1999-2000 

school year.5

• School food authority officials told us that financial pressures

have led them to serve less healthful a la carte items because 

these items generate needed revenue.6

4 These data were reported in SHPPS. Similar data were reported for the 1998-1999 school year in SNDA-II.

5 These data were reported in SMI. 

6 U.S. General Accounting Office, School Lunch Program: Efforts Needed to Improve Nutrition and Encourage 

Healthy Eating, GAO-03-506 (Washington, D.C.: May 9, 2003).
Appendix I: Briefing Slides 

Page 14 GAO-04-673 School Meal Programs 

11

Availability, Prevalence, and Types: The Types of 

Competitive Foods Provided through A La Carte 

Lines Are Often Healthy Foods

According to SHPPS, in 2000, many of the foods and beverages most 

commonly provided through school a la carte lines were healthy foods.
Appendix I: Briefing Slides 

Page 15 GAO-04-673 School Meal Programs 

12

Availability, Prevalence, and Types: Competitive 

Foods Are Available through Other Locations In a 

Significant Proportion of Schools 

National studies show that competitive foods are available in a variety 

of locations in schools.

• A significant proportion of U.S. schools provided competitive 

foods through either a vending machine or a school store, 

canteen, or snack bar in 2000.7

• Approximately 25 percent of all schools had vending machines 

located in or near the cafeteria in school year 1998/1999.8

7 These data were reported in SHPPS.

8 These data were reported in SNDA-II.
Appendix I: Briefing Slides 

Page 16 GAO-04-673 School Meal Programs 

13

Availability, Prevalence, and Types: The Types of 

Competitive Foods Provided through Other 

Locations Are Often Less Healthy Foods

According to SHPPS, in 2000, many of the foods and beverages most 

commonly provided through school vending machines, school stores, 

canteens, or snack bars were less healthy foods.
Appendix I: Briefing Slides 

Page 17 GAO-04-673 School Meal Programs 

14

Availability, Prevalence, and Types: Officials 

Provided Additional Information on Vending 

Machines in Schools

• Trade associations representing vending operators told us that they 

prefer to focus on per student consumption rather than on the 

number of vending machines available in the schools. 

• Vending association officials told us that they encourage operators 

to work with schools to increase the availability of healthier options 

in vending machines.

• School officials told us that they rely on revenue generated by 

vending and other sales to fund special projects. These funds can 

be used at the discretion of the principal or other school officials.9

• USDA officials believe vending machines found in cafeterias or 

under the control of school food authorities offer healthier foods 

than those sold elsewhere in schools. 

9 See GAO-03-506.
Appendix I: Briefing Slides 

Page 18 GAO-04-673 School Meal Programs 

15

Availability, Prevalence, and Types: Competitive 

Foods Are Also Available through Fund-raising and 

Other Sources

Fund-raising: In 82.4 percent of schools, organizations such as 

student clubs and sports teams sold food at school or in the 

community to raise money.10 The foods most commonly sold 

tended to be less healthy.11

Other sources: In addition, national data show that 6 percent of 

elementary schools, 10.6 percent of middle/junior high schools, and 

26.6 percent of high schools have open-campus policies, which 

allow students to leave the school campus during mealtimes.12

10 These data were reported in SHPPS.

11 Foods characterized as less healthy are those defined as “high in fat, sodium, or added sugars” by SHPPS. 

12 These data were reported in SHPPS.
Appendix I: Briefing Slides 

Page 19 GAO-04-673 School Meal Programs 

16

Availability, Prevalence, and Types: We Found 

Limited Research on the Association between 

Competitive Foods in Schools and Child Nutrition

• We did not find national data on the link between competitive foods 

in schools and child nutrition.

• Limited small-scale studies have examined these issues in various 

localities across the country, and these studies have shown 

evidence of the association between competitive foods and child 

nutrition.
Appendix I: Briefing Slides 

Page 20 GAO-04-673 School Meal Programs 

17

Availability, Prevalence, and Types: Research 

Suggests Competitive Foods Are Associated with a 

Decreased Consumption of Healthy Foods

Preliminary small-scale research suggests that the presence of 

competitive foods in schools is related to a decrease in fruit and 

vegetable consumption and an increase in calories obtained from 

fat.

• In a small study that examined the behaviors of 598 seventh-grade 

students in the St. Paul/Minneapolis, Minnesota, area:13

• On average, students in schools with a la carte programs 

consumed fewer fruits and vegetables than students in schools 

without a la carte programs. 

• Further, students in schools with a la carte programs obtained 

more of their daily calories from total fat and saturated fat than 

did students in schools without a la carte programs. 

13 Martha Y. Kubik, PhD, Leslie A. Lytle, PhD, Peter J. Hannan, MStat, Cheryl L. Perry, PhD, and Mary Story, 

PhD, "The Association of the School Food Environment With Dietary Behaviors of Young Adolescents," 

American Journal of Public Health, vol. 93, no. 7, (July 2003).
Appendix I: Briefing Slides 

Page 21 GAO-04-673 School Meal Programs 

18

• A second study examined the a la carte offerings at 12 suburban 

junior and 7 senior high schools from 6 school districts in the St. 

Paul/Minneapolis, Minnesota, area:14

• A la carte sales were highest for foods in the cookie, nondairy 

drink, vegetable, milk, and entree categories. 

• Overall, 48 percent of a la carte items met the FDA dietary fat 

criteria (for entrees, this requires 3 grams of fat or fewer per

100 grams, for other foods, 3 grams of fat or fewer per serving).

• Less than 10 percent of the items in the cookie and entree 

categories met FDA dietary fat criteria.

• In the vegetable category, mean sales were higher for french 

fries than for all other vegetables, and in the entree category,

sales were highest for hamburgers and pizza. 

Availability, Prevalence, and Types: Research 

Suggests Competitive Foods Are Associated with a 

Decreased Consumption of Healthy Foods (cont’d)

14 Lisa Harnack, PhD, Pat Snyder, MS, Mary Story, PhD, Roseanna Holliday, MPH, Leslie Lytle, PhD, Dianne 

Neumark-Sztainer, PhD, “Availability of A La Carte Food Items in Junior and Senior High Schools: A Needs 

Assessment," Journal of the American Dietetic Association, vol. 100, no. 6 (June 2000).
Appendix I: Briefing Slides 

Page 22 GAO-04-673 School Meal Programs 

19

Availability, Prevalence, and Types: Research 

Suggests Competitive Foods Are Associated with a 

Decreased Consumption of Healthy Foods (cont'd)

• A third study examined changes in food and beverage consumption 

over time for two student cohorts: fourth graders who only had 

access to the school lunch program in year 1 and gained snack bar 

access in year 2, when they transitioned to the fifth grade, and a 

comparison group of fifth- to sixth-graders.15

• For students who moved from fourth to fifth grade, average 

consumption of fruits, regular vegetables, and milk decreased, 

and average consumption of high-fat vegetables and sweetened 

beverages increased.

• Snack bar access may have played a partial role in some of the 

observed changes, but factors other than snack bar access may 

also have been influential. 

• Research would be helpful in understanding how competitive foods

affect overall child health. Both dietary intake and physical activity 

are relevant factors.

15 Karen Weber Cullen and Issa Zakeri, “Fruits, Vegetables, Milk, and Sweetened Beverages Consumption and Access to a la 

Carte/Snack Bar Meals at School,” American Journal of Public Health, vol. 94, no. 3 (March 2004). It is important to note that 

this study used a select sample of students from a single Texas school district, and it did not use a true control group. 
Appendix I: Briefing Slides 

Page 23 GAO-04-673 School Meal Programs 

20

State and Local Efforts: Some States and Localities 

Have Exercised Their Authority to Further Restrict 

Competitive Foods in Schools

• According to USDA regulations for the federal school meal 

programs, state agencies and local school food authorities may 

impose additional restrictions on the sale of all foods sold at any 

time throughout schools participating in the programs.

• In recent years, some states, local school districts, and individual 

schools have implemented competitive foods policies that are more 

restrictive than USDA regulations though they differ in the type and 

extent of restrictions. 
Appendix I: Briefing Slides 

Page 24 GAO-04-673 School Meal Programs 

21

State and Local Efforts: 23 States Have Made Efforts 

to Further Restrict Competitive Foods in Schools as 

of March 2004
Appendix I: Briefing Slides 

Page 25 GAO-04-673 School Meal Programs 

22

State and Local Efforts: States Policies Restrict 

Competitive Foods in Schools in Several Ways 

• Two of the 23 states, Washington and New Mexico, recently 

passed legislation creating committees to develop policies 

concerning competitive foods in schools.16

• In the 21 states that restrict competitive foods in schools beyond 

USDA regulations, policies typically restrict competitive foods by 

limiting the times and types of competitive foods available.

• Times—A majority of these states (14) restrict access to 

competitive foods at times associated with school meal periods. 

Some states (5) restrict access to competitive foods during the 

entire school day, and in the remaining 2 states, time 

restrictions vary by type of school.

• Types—Six of the 21 states restrict access to all competitive 

foods, and 8 states restrict access to FMNV. The remaining 7 

states restrict access to certain competitive foods.

16 In addition, one state, Montana, passed a resolution in 2003 urging school districts to offer nutritious food and 

beverage choices. 
Appendix I: Briefing Slides 

Page 26 GAO-04-673 School Meal Programs 

23

State and Local Efforts: State Policies Restrict 

Competitive Foods in Schools in Several Ways 

(cont'd)

Most state competitive foods policies restrict all competitive foods or 

FMNV at times associated with school meal periods.17

17 For example, some states restrict competitive foods for one half hour before and after each school meal period, 

while others restrict competitive foods from the start of the school day until the end of the last lunch period.
Appendix I: Briefing Slides 

Page 27 GAO-04-673 School Meal Programs 

24

State and Local Efforts: States Policies Restrict 

Competitive Foods in Schools in Several Ways 

(cont'd)

• Most of these states (17) restrict access to competitive foods in 

some way in all schools, including elementary, middle, and high 

schools, though 4 states’ policies only restrict access to competitive 

foods in selected schools. 

• All 21 states restrict access to competitive foods on the entire

school campus rather than only in the food service areas.

• Of the 21 states, policies in 6 states restrict access to certain types 

of beverages differently than access to all other competitive foods. 

For example, West Virginia restricts the sale of competitive foods 

that do not meet specific nutritional criteria in schools during the 

entire school day, though county boards may waive this restriction 

for carbonated drinks in high schools during non-mealtimes.
Appendix I: Briefing Slides 

Page 28 GAO-04-673 School Meal Programs 

25

State and Local Efforts: Since 2002, Many States 

That Had Not Already Made Efforts to Restrict 

Competitive Foods Have Proposed Bills to Do So
Appendix I: Briefing Slides 

Page 29 GAO-04-673 School Meal Programs 

26

State and Local Efforts: Several Large School 

Districts Have Enacted Policies to Restrict 

Competitive Foods

More than half of the 10 largest school districts in the United States 

have policies that restrict competitive foods in schools beyond 

federal and state regulations. 

• The New York City Public School District, the largest school 

district in the country, eliminated candy, soda, and other snack

foods from all vending machines, starting in the fall of 2003. 

Vending machines on school grounds are now limited to selling 

water, low-fat snacks, and 100 percent fruit juices. 

• The Los Angeles Board of Education, representing the second 

largest school district in the country, passed a soda vending 

ban that went into effect January 1, 2004. In addition, the 

board passed a ban on fried chips, candy, and other snack 

foods in school vending machines and school stores that will go 

into effect July 1, 2004.
Appendix I: Briefing Slides 

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27

State and Local Efforts: Some Local Schools Have 

Also Taken Actions to Restrict Competitive Foods 

in Schools

In recent years, several individual schools across the United States 

have taken actions to restrict competitive foods in schools beyond 

federal, state, and school board regulations.

• In Pennsylvania, the Vineland High School South principal 

removed vending machines from schools in January 2004, 

substituting machines that sell only water and juice.

• In Lake County, Illinois, Mundelein High School removed soda 

and candy from vending machines in August 2003 and replaced 

them with juices and cereal bars.

• In Pierre, South Dakota, Riggs High School removed all vending 

machines selling soda and snack food over the 2003-2004 

holiday break.

• In Utah, Syracuse Junior High started removing sodas and other 

FMNV items from vending machines in 2001.
Appendix I: Briefing Slides 

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28

State and Local Efforts: Efforts to Monitor 

Compliance with Competitive Food Policies Are 

Unclear

From a review of laws and policies on competitive foods, it is unclear 

how and to what extent states and localities are monitoring 

compliance with restrictions on competitive foods in schools. 

• Though federal regulations require state agencies and local 

school food authorities to establish rules and regulations that 

control the sale of FMNV during school meal periods, in instances 

of noncompliance, the regulations do not require state agencies 

to take fiscal actions against the school. 

• USDA has encouraged states to take action to enforce these 

requirements.

• In a brief review of state competitive foods policies that are more 

restrictive than federal regulations, for most of these states, it was 

unclear what methods they use to monitor compliance with their 

policies.
Appendix I: Briefing Slides 

Page 32 GAO-04-673 School Meal Programs 

29

Preliminary Observations

• There is growing concern about the nutritional content of 

competitive foods in schools among school districts, states, federal 

officials, and various stakeholder groups.

• Schools are well positioned to positively influence what children eat 

and what they know about good nutrition, and there is growing 

support for actions to restrict the availability and prevalence of 

competitive foods in schools.

• However, restrictions range from minimal, or those that place 

additional restrictions on FMNV, to more extensive, or those that 

place restrictions on all competitive foods for longer periods of time 

during the school day. 

• The challenges in implementing and monitoring state and local 

efforts have yet to be determined.
Related GAO Products 

Page 33 GAO-04-673 School Meal Programs 

School Lunch Program: Efforts Needed to Improve Nutrition and 

Encourage Healthy Eating. GAO-03-506. Washington, D.C.: May 9, 2003. 

School Meal Programs: Revenue and Expense Information from Selected 

States. GAO-03-569. Washington, D.C.: May 9, 2003. 

Public Education: Commercial Activities in Schools. GAO/HEHS-00-156.

Washington, D.C.: September 8, 2000. 

Related GAO Products 

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Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800 

U.S. General Accounting Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Public Affairs