SCHOOL LUNCH

Implementing 

Nutrition Changes 

Was Challenging and 

Clarification of 

Oversight 

Requirements Is 

Needed

Report to Congressional Requesters

January 2014

GAO-14-104

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-104, a report to 

congressional requesters

January 2014

SCHOOL LUNCH

Implementing Nutrition Changes Was Challenging 

and Clarification of Oversight Requirements Is 

Needed

Why GAO Did This Study

The National School Lunch Program 

served more than 31 million children in 

fiscal year 2012, in part through $11.6 

billion in federal supports. The Healthy, 

Hunger-Free Kids Act of 2010 required

USDA to update nutrition standards for 

lunches. USDA issued new 

requirements for lunch components—

fruits, vegetables, grains, meats, and 

milk—and for calories, sodium, and 

fats in meals. USDA oversees state 

administration of the program, and 

states oversee local SFAs, which 

provide the program in schools. The 

changes were generally required to be 

implemented in school year 2012-

2013. GAO was asked to provide 

information on implementation of the 

lunch changes.

GAO assessed (1) lunch participation 

trends, (2) challenges SFAs faced 

implementing the changes, if any, and 

(3) USDA’s assistance with and 

oversight of the changes. To address 

these areas, GAO used several 

methods, including review of federal 

laws, regulations, and guidance; 

analysis of USDA’s lunch participation 

data; a national survey of state child 

nutrition program directors; and site 

visits to eight school districts selected 

to provide variation in geographic 

location and certain school district and 

food service characteristics.

What GAO Recommends

To improve program integrity, GAO 

recommends that USDA clarify the 

need to document noncompliance 

issues found during state reviews of 

SFAs and complete efforts to assess 

states’ assistance needs related to

oversight of financial management.

USDA generally agreed with GAO’s 

recommendations.

What GAO Found

Nationwide, student participation in the National School Lunch Program declined 

by 1.2 million students (or 3.7 percent) from school year 2010-2011 through

school year 2012-2013, after having increased steadily for many years. This 

decrease was driven primarily by a decline of 1.6 million students eating school 

lunch who pay full price for meals, despite increases in students eating school 

lunch who receive free meals. State and local officials reported that the changes 

to lunch content and nutrition requirements, as well as other factors, influenced 

student participation. For example, almost all states reported through GAO’s 

national survey that obtaining student acceptance of lunches that complied with 

the new requirements was challenging during school year 2012-2013, which 

likely affected participation in the program. Federal, state, and local officials

reported that federally-required increases to lunch prices, which affected many

districts, also likely influenced participation.

School food authorities (SFA) faced several challenges implementing the new 

lunch content and nutrition requirements in school year 2012-2013. For example, 

most states reported that SFAs faced challenges with addressing plate waste—

or foods thrown away rather than consumed by students—and managing food 

costs, as well as planning menus and obtaining foods that complied with portion 

size and calorie requirements. SFAs that GAO visited also cited these 

challenges. However, both states and SFAs reported that they expect many of 

these areas will become less challenging over time, with the exceptions of food 

costs, insufficient food storage and kitchen equipment, and the forthcoming limits 

on sodium in lunches. 

The U.S. Department of Agriculture (USDA) provided a substantial amount of 

guidance and training to help with implementation of the lunch changes and 

program oversight, but certain aspects of USDA’s guidance may hinder state 

oversight of compliance. Starting in school year 2012-2013, USDA allowed states 

to focus their oversight of the lunch changes on providing technical assistance to 

SFAs rather than documenting instances of noncompliance and requiring 

corrective actions to address them. This assistance likely helped many SFAs 

move toward compliance with the new lunch requirements and become certified 

to receive increased federal reimbursements for lunches. However, evidence 

suggests this approach may have also resulted in some SFAs that were not fully 

meeting requirements being certified as in compliance. Without documentation of

noncompliance and requirements for corrective actions, SFAs may not have the 

information needed to take actions to address these issues, and USDA may lack 

information on areas that are problematic across SFAs. Moving forward, USDA 

has been developing a new process for conducting program oversight, in part 

because of new statutory requirements. This new process adds requirements for 

reviewing SFA financial management, and many states reported a need for more 

guidance and training in this area. USDA has acknowledged that states’ 

processes for reviewing this area have been inconsistent and sometimes 

inadequate in the past. While USDA has provided some assistance to states on 

the new requirements related to SFA financial management, until USDA has 

collected information from all states on their needs in this area, the department 

will not know if all states are fully prepared to oversee SFA financial 

management.

View GAO-14-104. For more information, 

contact Kay E. Brown at (202) 512-7215 or 

brownke@gao.gov.
Page i GAO-14-104 School Lunch

Letter 1

Background 4

School Lunch Participation Declined by 1 Million Students in 

Recent Years, Likely Due to the Changes to Lunch 

Requirements and Other Factors 14

Nationwide, SFAs Faced Challenges Implementing Lunch 

Changes, Though Some Challenges Will Likely Diminish Over 

Time 25

USDA’s Assistance Efforts Were Substantial, but Certain Aspects 

of USDA’s Guidance May Hinder State Oversight of 

Compliance 36

Conclusions 49

Recommendations for Executive Action 50

Agency Comments 51

Appendix I Scope and Methodology 53

U.S. Department of Agriculture (USDA) 53

Survey of States 55

Site Visits 56

Appendix II Federal Requirements for the Content of School Lunches 59

Appendix III GAO Contact and Staff Acknowledgments 64

Related GAO Products 65

Tables

Table 1: Traditional Food-Based Menu Planning Approach 

Requirements 59

Table 2: Traditional Food-Based Menu Planning Approach 

Nutrient and Calorie Requirements 60

Table 3: Enhanced Food-Based Menu Planning Approach 

Requirements 61

Table 4: Enhanced Food-Based Menu Planning Approach Nutrient 

and Calorie Requirements 62

Contents
Page ii GAO-14-104 School Lunch

Table 5: Food-Based Menu Planning Approach Requirements 

Beginning in School Year 2012-2013 63

Figures

Figure 1: Entities Responsible for Overseeing and Administering 

the National School Lunch Program 5

Figure 2: Previous and Current Federal Requirements for Meal 

Components and Nutrients in School Lunches 8

Figure 3: Examples of Three and Five Component Lunches That 

Comply with the New Content and Nutrition 

Requirements 9

Figure 4: Participation in the National School Lunch Program, 

School Years 2000-2001 through 2012-2013 16

Figure 5: Participation in the National School Lunch Program by 

Category of Student, School Years 2000-2001 through 

2012-2013 17

Figure 6: Number of Students in Each Category, School Years 

2000-2001 through 2012-2013 19

Figure 7: Participation Rate in the National School Lunch 

Program, School Years 2000-2001 through 2012-2013 20

Figure 8: Number of States in Which SFAs Faced Challenges in 

Selected Areas during Implementation of the New Lunch 

Requirements in School Year 2012-2013 26

Figure 9: Examples of the Variety of Fruits and Vegetables 

Offered with Lunches in the Districts We Visited 32

Figure 10: USDA Memos Issued to Provide Guidance on the New 

Requirements for the Content of School Lunches and 

Paid Lunch Equity, Jan. 2011-Sept. 2013 37

Figure 11: USDA Memos that Provided Flexibilities Related to 

Federal Regulations or Changed Previous Guidance on 

the New Requirements for the Content of School 

Lunches and Paid Lunch Equity, Jan. 2011-Sept. 2013 41

Figure 12: SFAs Certified and Validated by States as Complying 

with the New Lunch Requirements in School Year 2012-

2013 46
Page iii GAO-14-104 School Lunch

Abbreviations

FNS Food and Nutrition Service

SFA school food authority

USDA U.S. Department of Agriculture

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

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Page 1 GAO-14-104 School Lunch

441 G St. N.W.

Washington, DC 20548

January 28, 2014

The Honorable John Kline

Chairman

Committee on Education and the Workforce 

House of Representatives

The Honorable David P. Roe

Committee on Education and the Workforce

House of Representatives

The Honorable Kristi Noem

House of Representatives

The National School Lunch Program, which is intended to promote the 

health and well-being of schoolchildren, served an estimated 31.6 million 

children in fiscal year 2012 supported in part through federal subsidies 

and commodities totaling $11.6 billion. Although federal requirements for 

the content of school lunches have existed since the program’s creation, 

the Healthy, Hunger-Free Kids Act of 2010—the law that most recently 

reauthorized school meal programs—required that they be updated in 

order to help reduce childhood obesity and improve children’s diets. The 

Act required the U.S. Department of Agriculture (USDA), which 

administers the National School Lunch Program, to update the 

requirements for the content of school lunches based on 

recommendations from the Institute of Medicine.1

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

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

recommendations issued by the Food and Nutrition Board, which is part of the National 

Academies’ Institute of Medicine, and throughout this report, we refer to these as the 

Institute of Medicine’s recommendations, on which USDA based the new lunch content 

and nutrition requirements. 

USDA issued final 

regulations defining the new requirements in January 2012 and required 

that many of them be implemented beginning in school year 2012-2013. 

USDA’s updated regulations aim to provide lunches high in nutrients and 

low in calories that better meet the dietary needs of schoolchildren and 

protect their health. To that end, the regulations made several changes 

and additions to the previous requirements for the content of school 

lunches, such as requiring that each student’s lunch contain at least one 
Page 2 GAO-14-104 School Lunch

fruit or vegetable. Under agreements with state agencies, local school 

food authorities (SFA), which are generally aligned with school districts, 

serve meals to children in schools and are the entities responsible for 

implementing these requirements.

As school year 2012-2013 progressed, both USDA and the media 

reported that states, SFAs, school officials, parents, and students 

expressed some concerns about the school lunch changes. While the 

changes to school lunch were the primary school food changes required 

to be implemented in school year 2012-2013, the Healthy, Hunger-Free 

Kids Act of 2010 also required similar updates to nutrition standards for 

the School Breakfast Program and other foods sold in schools—known as 

competitive foods—and USDA prescribed that these changes generally 

be implemented in school year 2013-2014 and beyond. In view of both 

the ongoing and future changes to school foods, you asked us to provide 

information on implementation of the changes to school lunch. This report 

assesses: (1) trends in school lunch participation, (2) challenges, if any, 

SFAs faced implementing the lunch changes, and (3) USDA’s efforts to 

assist with implementation of the lunch changes and ensure compliance 

with program requirements. In June 2013, we testified on our initial 

findings on challenges SFAs faced implementing the lunch changes, and 

recommended that USDA make modifications to some of the new lunch 

requirements.2

To answer these questions, we gathered information through several 

methods. At the federal level, we reviewed relevant federal laws, 

regulations, and guidance and interviewed USDA officials. Further, we 

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

Lunch Program and reviewed the department’s method for determining 

lunch participation from these data. To assess their reliability, we 

interviewed USDA officials, reviewed related documentation, and 

compared the data we received from USDA with its published data. We 

determined these data and the participation methodology to be sufficiently 

reliable for the purposes of this report. To assess USDA’s assistance and 

oversight efforts, we relied on federal standards for internal controls.3

 2 See GAO, School Lunch: Modifications Needed to Some of the New Nutrition Standards, 

We 

GAO-13-708T (Washington, D.C.: June 27, 2013).

3 GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).
Page 3 GAO-14-104 School Lunch

also reviewed several key studies on the National School Lunch Program. 

For example, we reviewed USDA’s School Nutrition Dietary Assessment 

Study IV (2012), which provides information on school lunches and other 

foods sold in schools nationwide in school year 2009-2010.4 In addition, 

because it is the basis for USDA’s revised regulations on the content of 

school lunches, we reviewed the Institute of Medicine’s report, School 

Meals: Building Blocks for Healthy Children (2010).5

To gather information from the state level, we conducted a national 

survey of state child nutrition directors that oversee the National School 

Lunch Program in the 50 states and the District of Columbia.

We assessed the 

methodologies and findings of the studies we reviewed and determined 

that they were sufficiently reliable for the purposes of this report.

6 We 

administered our Web-based survey between June and July 2013, and all 

state directors responded. While we did not validate specific information 

that directors reported through our survey, we reviewed their responses, 

and we conducted follow-up, as necessary, to determine that their 

responses were complete, reasonable, and sufficiently reliable for the 

purposes of this report. To gather information directly from those affected 

by the changes in the schools, we conducted site visits to eight school 

districts in eight states across the country between March and May 2013. 

The school districts selected for these visits provide variation across 

geographic location, district size, and certain characteristics of the student 

population and district food services.7

 4 U.S. Department of Agriculture, Food and Nutrition Service, Office of Research and 

Analysis, School Nutrition Dietary Assessment Study IV (Alexandria, VA: November 

2012). 

In each district, we met with SFA 

staff at the district and school levels, school administrators, and students, 

and we observed lunch in at least two schools of different grade levels, 

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

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

6 Because separate agencies oversee the administration of the National School Lunch 

Program in public and private schools in five states, we surveyed both agencies in each of 

these five states. In two of the states, separate state agencies oversee public and private 

schools administering the program, while in the remaining three, private schools 

administering the program are overseen by the relevant USDA regional office. 

7 We conducted site visits to Caddo Parish Public Schools (LA), Carlisle Area School 

District (PA), Chicago Public Schools (IL), Coeur d’Alene School District (ID), Fairfax 

County Public Schools (VA), Irving Independent School District (TX), Mukwonago Area 

School District (WI), and Spokane Public Schools (WA).
Page 4 GAO-14-104 School Lunch

for a total of 17 schools. We also interviewed the eight state child nutrition 

program directors who oversee these districts. We cannot generalize our 

findings from the site visits beyond the school districts we visited.8 To 

gather additional information, we interviewed representatives from several 

stakeholder groups, including a group of eight SFA directors representing 

both their own districts and their regions of the country, and a group of 

eleven relevant industry representatives.9

We conducted this performance audit from February 2013 to January 

2014 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

For additional information on 

the report’s scope and methodology, see appendix I.

The National School Lunch Program was established in 1946 by the 

National School Lunch Act10

 8 We reported on our preliminary findings from these visits in 

and is intended to safeguard the health and 

well-being of the nation’s children. The program provides nutritionally 

balanced low-cost or free lunches to children in public and nonprofit 

private schools and residential child care institutions. In fiscal year 2012, 

the federal government spent $11.6 billion on the National School Lunch 

Program, which served lunches to 31.6 million children on average each 

month.

GAO-13-708T.

9 The School Nutrition Association (SNA), a national non-profit organization representing 

55,000 members involved in serving meals to children in schools, assisted our efforts to 

speak with these groups. The eight SFA directors we spoke with were representatives on 

SNA’s public policy and legislation committee, which includes representatives from each 

region of the country, as well as SNA’s board of directors. None of these SFA directors 

were responsible for administering the National School Lunch Program in districts that we 

selected for site visits, and only one of the SFA directors was from a state in which we 

conducted a site visit. The 11 industry representatives we spoke with were members of 

SNA, and some serve on the Association’s industry advisory board. 

10 The National School Lunch Act was redesignated as the Richard B. Russell National 

School Lunch Act in 1999. Throughout this report we refer to the act as the National 

School Lunch Act.

Background
Page 5 GAO-14-104 School Lunch

The school lunch program is overseen by USDA’s Food and Nutrition 

Service (FNS) through its headquarters and regional offices and is 

administered through state agencies and local SFAs (see fig. 1). FNS 

defines program requirements and provides reimbursements to states for 

lunches served. FNS also provides states with commodities—foods 

produced in the United States that are purchased by USDA and provided 

to SFAs—based on the number of lunches served.11 States have written 

agreements with SFAs to administer the meal programs, and states 

provide federal reimbursements to SFAs and oversee their compliance 

with program requirements. SFAs plan, prepare, and serve meals to 

students in schools.12

Figure 1: Entities Responsible for Overseeing and Administering the National 

School Lunch Program

Although federal requirements for the content of school lunches have 

existed since the National School Lunch Program’s inception in 1946, as 

research has documented changes in the diets of Americans and the 

increasing incidence of overweight and obesity in the United States, the 

federal government has taken steps to improve the nutritional content of 

lunches. Specifically, since 1994, federal law has required SFAs to serve 

school lunches that are consistent with the Dietary Guidelines for 

Americans. In 2004, federal law required USDA to issue rules providing 

SFAs with specific recommendations for lunches consistent with the most 

 11 As authorized in the National School Lunch Act, SFAs are entitled to receive commodity 

foods or, where applicable, cash in lieu of commodity foods. In school year 2013-2014, 

SFAs received commodity foods valued at 23.25 cents for each reimbursable lunch 

served.

12 An SFA is the governing body that is responsible for the administration of the National 

School Lunch Program in one or more schools, which has the legal authority to operate 

the program therein or is otherwise approved by FNS to operate the program. 

Meal Component and 

Nutrition Standards
Page 6 GAO-14-104 School Lunch

recently published version of the Guidelines. As a result of that 

requirement, USDA asked the Institute of Medicine to review the food and 

nutritional needs of school-aged children in the United States using the 

2005 Dietary Guidelines for Americans and provide recommended 

revisions to meal requirements for the National School Lunch Program.

The Healthy, Hunger-Free Kids Act of 2010 required USDA to update 

federal requirements for the content of school lunches based on the 

Institute of Medicine’s recommendations, which were published in 2010. 

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

content and nutrition requirements in January 2012 and required that 

many of the new lunch requirements be implemented beginning in school 

year 2012-2013.13 (See fig. 2.) Regarding the lunch components—fruits, 

vegetables, meats, grains, and milk—lunches must now include fat-free 

or low-fat milk, limited amounts of meats/meat alternates and grains,14

and whole grain-rich foods.15 Further, lunches must now include both fruit 

and vegetable choices, and although students may be allowed to decline 

two of the five lunch components they are offered,16

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

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

they must select at 

least one half cup of fruits or vegetables as part of their meal. (See fig. 3 

for examples of lunches with three and five components.) Regarding the 

nutrition standards, the regulations now include maximum calorie levels 

for lunches, require that lunches include no trans fat, and set future 

14 In January 2014, USDA issued regulations that remove the requirement for SFAs to 

comply with the limits on meats/meat alternates and grains. See Certification of 

Compliance With Meal Requirements for the National School Lunch Program Under the 

Healthy, Hunger-Free Kids Act of 2010, 79 Fed. Reg. 325 (Jan. 3, 2014) (codified at 7 

C.F.R. pt. 210).

15 Regarding the grains component of the lunch, the regulations require that all grain 

products must be made with enriched and whole grain meal or flour, and whole grain-rich 

products must contain at least 51 percent whole grains. 7 C.F.R. § 210.10(c)(2)(iv). 

Beginning July 1, 2012, half of the grain products offered during the school week must 

meet the whole grain-rich criteria, and beginning July 1, 2014, all grain products must 

meet these criteria.

16 The offer versus serve policy has been required for senior high schools and optional for 

all other schools since 1975. This policy allows students to decline two of the five meal 

components offered with the lunch, rather than requiring students to be served all five 

components.
Page 7 GAO-14-104 School Lunch

targets to reduce sodium in lunches.17 In addition to changes to the 

content of lunches, regulations also required that all SFAs use the same 

approach for planning lunch menus—Food-Based Menu Planning.18 This 

approach involves providing specific food components in specific 

quantities, where previously districts could choose from a variety of 

approaches. Further, the new regulations require SFAs to plan menus 

based on one set of student grade groups—grades K-5, grades 6-8 and 

grades 9-12—regardless of whether their schools align with these groups. 

Although regulations have long adjusted lunch content requirements by 

student grade level, previous regulations allowed SFAs a few student 

grade group options from which to choose those that best aligned with 

their schools.19

 17 The final rule requires schools to gradually reduce the sodium content of lunches over a 

specified time period. The first intermediate sodium targets must be met no later than the 

beginning of school year 2014–2015, the second no later than the beginning of school 

year 2017–2018, and the final no later than the beginning of school year 2022–2023. 

However, prior to the implementation of the second and final sodium targets, USDA will 

evaluate relevant studies on sodium intake and human health, as required by the 

Consolidated and Further Continuing Appropriations Act, 2012, Pub. L. No. 112-55, div. A, 

tit. VII, § 743, 125 Stat. 552, 589 (2011).

18 In the preamble to the final rule, USDA noted that over 70 percent of SFAs were 

already using the Food-Based Menu Planning approach to plan their lunch menus. 

19 For more information on the previous and current federal requirements for school 

lunches, see appendix II. 
Page 8 GAO-14-104 School Lunch

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

Notes: Under the previous federal requirements for school lunch, SFAs could choose to use one of 

five approved approaches to plan their menus. Three of these approaches focused on nutrient 

requirements and did not specify portion size requirements. The requirements for portion sizes in the 

two food-based menu planning approaches are shown in the figure. The ranges of portion sizes 

shown reflect the minimum requirements, which vary by grade group and, for the previous 

requirements, by menu planning approach. Under the offer versus serve policy required in high 

schools and optional for other schools, students may decline two of the five lunch components they 

are offered.

a Beginning in school year 2012-2013, lunches offered to students must include both fruit and 

vegetable choices, and students must take at least one half cup of fruits or vegetables with their 

lunches.
Page 9 GAO-14-104 School Lunch

b Over the course of the week, schools must offer all vegetable subgroups established in the 2010 

Dietary Guidelines for Americans: dark green, red/orange, beans/peas (legumes), starchy, and 

“other” vegetables (as defined in the Dietary Guidelines).

c In school years 2012-2013 and 2013-2014, half of the grain products offered in the program must be 

whole grain-rich.

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

In addition to changes to the content and nutrition requirements for school 

lunches, the Healthy, Hunger-Free Kids Act of 2010 required that USDA 

update the requirements for school breakfasts and establish new 

standards for all other foods and beverages sold in schools, which are 

commonly referred to as competitive foods because they compete with 

school meal programs. USDA’s January 2012 final regulations on the new 

lunch requirements also included the new breakfast requirements that are 

to be implemented over several school years, beginning generally in 

school year 2013-2014. The regulations establish three meal components 

for breakfast—fruit or vegetable, grain or meat, and milk—and require 

that breakfasts include whole grain-rich foods and only fat-free or low-fat 

milk. Additional changes to the previous breakfast requirements include 

that breakfasts must now be at or below calorie maximums and comply 
Page 10 GAO-14-104 School Lunch

with limits on sodium and trans fat. Beginning in school year 2014-2015, 

schools must offer one cup of fruit with each breakfast each day, an 

increase from the previous requirement of 1⁄2 cup, though vegetables 

meeting specific requirements may be substituted for fruit. In addition, as 

with lunch, students will be required to take a fruit or vegetable as part of 

their meal. Separate from the lunch and breakfast regulations, USDA 

issued an interim final rule on the new requirements for competitive foods 

in June 2013 and required that they be implemented in school year 2014-

2015.20 Competitive foods are often sold through vending machines, 

school stores, and fundraisers, and also include SFA sales of a la carte 

items in the cafeteria. Prior to the enactment of the Healthy, Hunger-Free 

Kids Act of 2010, USDA’s authority to regulate competitive foods was 

limited to those foods sold in the food service area during meal periods. In 

contrast, the new regulations include nutrition requirements for all foods 

and beverages sold on school campuses during the school day outside of 

the federal school meal programs.

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

some children are eligible to receive free or reduced-price meals. Under 

the National School Lunch Act, children are eligible for free meals if their 

families have incomes at or below 130 percent of the federal poverty 

guidelines and reduced-price meals if their families have incomes 

between 130 and 185 percent of the federal poverty guidelines. SFAs can 

charge a maximum of $0.40 for a reduced-price lunch. Children who are 

not eligible for free or reduced-price meals pay the full price charged by 

the SFA for the meal. However, SFAs receive federal reimbursements for 

all lunches served to eligible students that meet federal lunch component 

and nutrition requirements, regardless of whether children pay for the 

meals or receive them for free. The amount of federal reimbursement that 

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

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

served to children eligible for free and reduced-price meals. For example, 

in school year 2013-2014, federal reimbursements are $2.93 for each free 

lunch, $2.53 for each reduced-price lunch, and $0.28 for each paid lunch 

for SFAs with less than 60 percent of their total lunches served to children 

eligible for free and reduced-price meals. SFAs with a higher proportion of 

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

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

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

SFA Finances
Page 11 GAO-14-104 School Lunch

their total lunches served to children eligible for free and reduced-price 

meals may qualify for a higher per lunch reimbursement rate

SFAs must comply with certain financial requirements when operating the 

National School Lunch Program. Specifically, the National School Lunch 

Act requires that SFAs operate as nonprofit entities. Federal regulations 

further dictate that SFAs must use all revenue for the operation or 

improvement of the program and generally limit their net cash 

resources—the cash SFAs carry in their accounts—to three months of 

average operating expenditures. In the event that an SFA’s resources 

exceed this limit, the state agency may require the SFA to invest the 

excess funds in the program or otherwise reduce the SFA’s account 

balance.

The Healthy, Hunger-Free Kids Act of 2010 contained two new revenue 

requirements related to the prices SFAs set for paid lunches and other 

foods sold outside of the school meal programs. These provisions were 

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

prices charged for paid lunches and for other foods by some SFAs were 

less than the cost of producing those foods.21 While SFAs continue to 

determine the price they charge for school lunches, beginning in school 

year 2011-2012, the Act requires SFAs to provide the same level of 

support for paid lunches as is provided for free lunches.22 If an SFA’s 

average paid lunch price is less than a specified amount—$2.59 for 

school year 2013-2014—the SFA must either increase the price it 

charges for paid lunches or provide non-federal funding to cover the 

difference.23

 21 See USDA, Food and Nutrition Service, Office of Research, Nutrition and Analysis, 

School Lunch and Breakfast Cost Study-II, Final Report (Alexandria, VA: 2008).

Concerning other foods sold by SFAs outside of the school 

meal programs, the Act requires that revenues from the sales of these 

foods generate at least the same proportion of SFA revenues as they 

22 The Act requires that SFAs set paid lunch prices that are no less than the difference 

between the total federal reimbursement for a free lunch and the total federal 

reimbursement for a paid lunch. Pub. L. No. 111-296, § 205, 124 Stat. 3183, 3218 

(codified at 42 U.S.C. § 1760(p)).

23 For SFAs that choose to increase the price charged for paid lunches, the Act limits the 

annual average required price increase to not more than 10 cents. However, SFAs have 

discretion to increase the average price by more than 10 cents. Id., § 205, 124 Stat. 3183, 

3219 (codified at 42 U.S.C. § 1760(p)(2)(B)(iii)).
Page 12 GAO-14-104 School Lunch

contribute to SFA food costs, in effect requiring SFAs to charge prices 

that cover the costs of those foods.24

As required by the National School Lunch Act, USDA policies and 

regulations establish an oversight and monitoring framework for the 

National School Lunch Program to help ensure that meals served meet 

content and nutrition requirements and that SFAs follow required eligibility 

and financial practices and maintain sound financial health. USDA is 

required to review state administration of the program, and states are 

required to review SFA administration of the program.

Although states have been required to regularly review SFA 

administration of the National School Lunch Program for over two 

decades, the Healthy, Hunger-Free Kids Act of 2010 required USDA to 

amend its unified accountability system to ensure SFA compliance with 

requirements for all school meal programs.25 Further, the Act requires 

states to review SFAs on a 3-year cycle, which is a change from the 

previous 5-year cycle. While USDA has not yet issued regulations on the 

new requirements, USDA has developed and provided states with 

guidance on an updated and streamlined administrative review process 

that changes some of the review procedures and required review areas. 

For example, USDA developed risk-based tools to determine the degree 

to which each area must be reviewed and made changes to procedures 

used when SFAs claim or receive federal reimbursements they are not 

entitled to.26

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

Further, USDA modified the extent to which states must 

review certain areas and added review of SFA financial management to

the administrative review process. Specifically, states are now required to 

25 Previously, the National School Lunch Act required states to review the National School 

Lunch Program, which was accomplished through the regular administrative review 

process. The Healthy, Hunger-Free Kids Act of 2010 expanded oversight requirements to 

require that oversight of the National School Lunch Program and School Breakfast 

Program, including nutritional requirements for both programs, be conducted through one 

unified review process. Id., at § 207(1), 124 Stat. 3183, 3220 (codified at 42 U.S.C. § 

1769c(a)(1)).

26 Under USDA regulations, in certain circumstances, a state must take fiscal action 

against an SFA that it finds to be out of compliance with program requirements. For 

example, an SFA found to have served meals not in compliance with requirements is 

potentially subject to fiscal action, such as the recovery of federal reimbursements for 

those meals. 7 C.F.R. § 210.19(c).

Program Oversight and 

Administrative Review 

Process
Page 13 GAO-14-104 School Lunch

review SFAs’ nonprofit food service accounts, use of commodities, 

indirect costs, and compliance with requirements for pricing paid lunches 

and other foods sold outside of the school meal programs. USDA officials 

told us that the new administrative review process was developed with 

extensive input from a workgroup that included state and USDA 

representatives. Although a new 3-year cycle of administrative reviews 

began in school year 2013-2014, because federal regulations have not 

yet been updated to reflect the new administrative review process, USDA 

used its waiver authority to provide states with the flexibility to follow the 

new administrative review requirements or the previous requirements.27

For school year 2012-2013, as SFAs worked to implement the required 

changes to the content of school lunches, USDA established interim 

procedures for program oversight.28 Specifically, to ensure that state 

agencies provided training and technical assistance to help SFAs 

implement the changes to the content of lunches, USDA allowed states to 

postpone administrative reviews until school year 2013-2014.29

The National School Lunch Program’s oversight and monitoring 

requirements are part of the program’s internal controls, which are an 

integral component of management. Internal control is not one event, but 

a series of actions and activities that occur on an ongoing basis. Effective 

Instead, 

during school year 2012-2013, states were required to review 

documentation submitted by SFAs and certify those SFAs determined to 

be in compliance with the new lunch requirements. USDA also required 

states to conduct on-site validation reviews to a sample of at least 25 

percent of certified SFAs to ensure SFA compliance. Once certified, SFAs 

receive an additional six cents for each reimbursable lunch served, as 

provided for in the Healthy, Hunger-Free Kids Act of 2010. 

 27 According to USDA officials, 47 states, Puerto Rico, and the Virgin Islands are using the 

new administrative review process in school year 2013-2014.

28 Certification of Compliance with Meal Requirements for the National School Lunch 

Program Under the Healthy, Hunger-Free Kids Act of 2010, 77 Fed. Reg. 25,024 (April 27, 

2012) (codified at 7 C.F.R. pt. 210).

29 During school year 2012-2013, states had the discretion to conduct administrative 

reviews. Further, states were required to conduct Additional Administrative Reviews, 

which are reviews of those SFAs determined to be at risk for improper payments, and 

planned follow-up administrative reviews that had already been scheduled. In school year 

2013-2014, states are required to review SFAs whose reviews were postponed in school 

year 2012-2013 or omitted during the previous 5-year cycle.
Page 14 GAO-14-104 School Lunch

internal controls include creating an organizational culture that promotes 

accountability and the reduction of errors, analyzing program operations 

to identify areas that present the risk of error, making policy and program 

changes to address the identified risks, and monitoring the results and 

communicating the lessons learned to support further improvement. 

Despite the National School Lunch Program’s oversight and monitoring 

requirements, the program has been found to have a relatively high 

incidence of program errors. For example, USDA’s most recent study of 

program errors found that $248 million in improper payments (3.1 percent 

of federal reimbursements) during school year 2005-2006 resulted from 

school food service staff incorrectly assessing and recording lunches 

eligible for federal reimbursement.

30 At the time of the study, federal 

requirements for the content of lunches had been consistent for 10 years.

 30 These errors included counting meals as eligible for federal reimbursement that did not 

contain the required components or were served to ineligible people such as teachers or 

visitors. They also included failing to count meals for federal reimbursement that met 

nutrition requirements and were provided to eligible students. USDA, FNS, Office of 

Research, Nutrition and Analysis, “NSLP/SBP Access, Participation, Eligibility, and 

Certification Study – Erroneous Payments in the NSLP and SBP, Vol. I: Study Findings”

(Alexandria, VA: 2007). USDA has contracted for a second study that will review school 

meals programs for school year 2012-2013. 

School Lunch 

Participation Declined 

by 1 Million Students 

in Recent Years, 

Likely Due to the 

Changes to Lunch 

Requirements and 

Other Factors
Page 15 GAO-14-104 School Lunch

Nationwide, participation in the National School Lunch Program declined 

in recent years after having increased steadily for more than a decade. 

According to our analysis of USDA’s data, total student participation—the 

total number of students who ate school lunches—dropped from school 

years 2010-2011 through 2012-2013 for a cumulative decline of 1.2 

million students (or 3.7 percent), with the majority of the decrease 

occurring during school year 2012-2013.31 (See fig. 4.) The decrease in 

the total number of students eating school lunches during the last 2 

school years was driven primarily by a decrease of 1.6 million students 

paying full price for meals, despite increases in the number of students 

eating school lunches who receive free meals. While the number of 

students who buy full-price lunches each month has been declining 

gradually since school year 2007-2008, the largest one-year decline—10 

percent—occurred in school year 2012-2013.32 In contrast, the number of 

students participating in the program each month who receive free meals 

has steadily increased over the years, though the increase was much 

smaller in the last year.33

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

USDA adjusts the data to determine the number of students participating. According to the 

data, student participation declined by 84,000 students (0.3 percent) in school year 2011-

2012 and by an additional 1,086,000 students (3.4 percent) in school year 2012-2013. 

See appendix I for more information on USDA’s participation data. 

(See fig. 5.) In addition, some evidence 

suggests that the total number of students eating school lunches declined 

more in schools with older students. For example, in six of the seven 

SFAs we visited that provided participation details by school level, 

participation declined to a greater extent among older students than 

elementary students in school year 2012-2013.

32 Since peaking in school year 2006-2007 with 12.6 million students, participation among 

students paying full price for meals has declined by nearly 5 percent on average each 

year, with a decline of 10 percent in school year 2012-2013. Prior to the decline, the 

number of students paying full price had remained relatively steady. 

33 After increasing for over a decade at an average rate of 3.5 percent per year, 

participation among students receiving free meals increased less than 1 percent in school 

year 2012-2013.

Total School Lunch 

Participation Declined by 1 

Million Students from 

School Years 2010-2011 

through 2012-2013
Page 16 GAO-14-104 School Lunch

Figure 4: Participation in the National School Lunch Program, School Years 2000-

2001 through 2012-2013

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

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

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

year 2012-2013 may contain estimates as the data reporting process was not yet final when we 

received the data from USDA. The decline of 1.2 million does not match the yearly data due to 

rounding.
Page 17 GAO-14-104 School Lunch

Figure 5: Participation in the National School Lunch Program by Category of 

Student, School Years 2000-2001 through 2012-2013

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

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

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

year. Data for school year 2012-2013 may contain estimates as the data reporting process was not 

yet final when we received the data from USDA.

The changes in lunch program participation were likely influenced by 

factors that directly affected students’ eligibility for free and reduced-price 

school meals. Since the recent economic downturn began in late 2007, 

the number of children under age 18 living in poverty nationwide has 

increased substantially, according to data from the U.S. Census Bureau.34

 34 U.S. Bureau of the Census, Current Population Survey, Annual Social and Economic 

Supplements, Table 3. Poverty Status of People, by Age, Race and Hispanic Origin: 1959-

2012.

Consistent with this shift, our analysis of USDA’s data shows that the 

number of students approved for free meals nationally has been 

increasing at a greater rate since school year 2007-2008, and the number 

of students required to pay full price for their lunches has been 

decreasing. (See fig. 6.) This was also true in the districts we visited 
Page 18 GAO-14-104 School Lunch

where two SFA directors noted that the recent economic downturn likely 

contributed to an increase in the number of children approved for free and 

reduced-price meals in their districts. In addition to economic conditions, 

other program changes may have also influenced these trends, such as 

adjustments to the process for determining student eligibility for free and 

reduced-price school meals.35

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

administrative burden when certifying children for multiple assistance programs with 

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

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

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

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

previously noted that changes to state policies that broaden eligibility criteria for SNAP 

may have resulted in an increase in students eligible for free school meals. For more 

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

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

USDA officials reported that other policy changes in selected states may have influenced 

student eligibility during school years 2011-2012 and 2012-2013, including a 

demonstration project to directly certify students based on Medicaid program information 

and use of the community eligibility option.
Page 19 GAO-14-104 School Lunch

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

2012-2013

Note: For October of each school year, states report to USDA the total number of students enrolled in 

schools participating in the National School Lunch Program, as well as the total number of students 

approved for free and reduced-price meals in that month. Paid students in this figure represent 

enrolled students who had not been approved for free or reduced-price meals.

Consistent with declines in the number of students participating in the 

lunch program, our analysis shows that the proportion of all students 

eating school lunches declined in school year 2012-2013. The 

participation rate measures the proportion of all students in schools with 

the National School Lunch Program who ate school lunches in each 

month. In school year 2012-2013, the overall participation rate declined, 

primarily driven by a decline in the participation rate for paid students. 

(See fig. 7.) In that year, the participation rate for paid students declined 

to approximately 38 percent—the lowest rate in over a decade.
Page 20 GAO-14-104 School Lunch

Figure 7: Participation Rate in the National School Lunch Program, School Years 

2000-2001 through 2012-2013

Note: The participation rate measures the proportion of students in each category participating in the 

program in schools that offer the National School Lunch Program. Our analysis of school year data 

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

data for school year 2012-2013 used to develop the participation rate may contain estimates as the 

data reporting process was not yet final when we received the data from USDA.

Several factors likely influenced the recent decreases in lunch 

participation, and while the extent to which each factor affected 

participation is unclear, state and local officials reported that the 

decreases were influenced by changes made to comply with the new 

lunch content and nutrition standards. Almost all states reported that 

student acceptance of the changes was challenging for at least some of 

their SFAs during school year 2012-2013, a factor that likely affected 

participation.36

 36 In our state survey, 48 states identified student acceptance as a challenge and 33 

states noted challenges with palatability—food that tasted good to students—for at least 

some of their SFAs in school year 2012-2013. 

All eight SFAs we visited also noted that students 

Participation Decreases 

Were Likely Influenced by 

Several Factors, Including 

Implementation of the New 

Federal Requirements
Page 21 GAO-14-104 School Lunch

expressed dislike for certain foods that were served to comply with the 

new requirements, such as whole grain-rich products and vegetables in 

the beans and peas (legumes) and red-orange sub-groups, and this may 

have affected participation.37

Federally-required increases in the prices of paid lunches in certain 

districts—also known as paid lunch equity—are another change that state 

and SFA officials believe likely influenced lunch participation. This 

requirement, included in the Healthy, Hunger-Free Kids Act of 2010, 

caused many SFAs to raise the price of their paid lunches beginning in 

school year 2011-2012. Officials from three states and four SFAs we 

spoke with as part of our site visits believe the price increases likely 

contributed to declines in the number of students buying full-price 

lunches. In addition, SFA officials in two districts we visited expressed 

concern that lunch price increases are particularly difficult for families who 

do not receive free or reduced-price lunches but have limited incomes, as 

the new prices may no longer be affordable. Further, SFA officials in two 

districts believed that lunch price increases, combined with the lunch 

content changes, led some students to stop buying school lunches 

because they felt they were being asked to pay more for less food. Some 

middle and high school students we talked to in these districts echoed 

this sentiment and said this combination led them to consider food 

options other than the school lunch program, particularly at the beginning 

of the 2012-2013 school year. SFA officials noted that middle and high 

schools are more likely to have alternatives to school lunches available, 

such as foods sold through vending machines, a la carte lines in the 

Further, some SFAs we visited noted that 

negative student reactions to lunches that complied with the new meat 

and grain portion size limits directly affected program participation in their 

districts. For example, in one district, changes the SFA made to specific

food items, such as sandwiches, contributed to a middle and high school 

boycott of school lunch by students that lasted for 3 weeks at the 

beginning of school year 2012-2013. During this time, participation in 

school lunch significantly declined in those schools.

 37 For more information on student acceptance of lunches served that complied with the 

new requirements in the eight SFAs we visited, see GAO-13-708T.
Page 22 GAO-14-104 School Lunch

cafeteria, and fundraisers, as well as policies that allow students to 

purchase food off of the school campus.38

The reaction to the paid lunch price increases is consistent with USDA’s 

expectations. Prior to implementation, the department estimated that 

nearly all schools would need to increase their lunch prices in response to 

the requirements, and these increases were expected to decrease the 

number of students eating school lunches as they chose not to eat, 

brought their lunches from home, or acquired food from other sources.39

Although the paid lunch equity provisions were included in the Healthy, 

Hunger-Free Kids Act of 2010 in part to help SFAs cover the costs of the 

foods needed to comply with the new lunch requirements, some officials 

we spoke with expressed concern about the potential impact on the 

program if the number of students buying full-price lunches continues to 

decrease. Specifically, several state and SFA officials we spoke with 

expressed concerns that such a trend would hinder the program’s ability 

to improve the diet and overall health of all schoolchildren and potentially 

increase stigma in the cafeteria for low-income students.40

Officials in the SFAs we visited noted other factors that may also have 

affected lunch participation in recent years. SFA directors in three districts 

said that negative national and local media attention regarding changes to 

the lunch content and nutrition standards likely led some students to stop 

participating in school lunch, at least temporarily. SFA directors we visited 

said it is common that they receive feedback from students and parents. 

However, almost all of those we visited noted that they received more 

 38 In recognition of the role that competitive foods play in schools and consistent with the 

Healthy, Hunger-Free Kids Act of 2010’s goal of improving the diets of all schoolchildren, 

USDA has required that all foods sold or offered on the school campus comply with new 

nutritional standards beginning in school year 2014-2015.

39 In the preamble to the interim rule on paid lunch equity requirements, USDA estimated 

that most schools affected by the requirements in school year 2011-2012 would need to 

increase paid lunch prices by only 5 cents in order to comply. National School Lunch 

Program: School Food Service Account Revenue Amendments Related to the Healthy, 

Hunger-Free Kids Act of 2010, 76 Fed. Reg. 35,301, 35,306 (June 17, 2011). USDA’s 

research suggests that a 5 cent increase in paid lunch prices results in a 0.55 percent 

decrease in the student participation rate. See USDA, School Nutrition Dietary 

Assessment Study-III (Alexandria, VA: November 2007). 

40 Previous research has noted that National School Lunch Program participation may be 

inhibited in schools where few students who pay full price for their lunches participate in 

the program, as participation itself may be a visible marker of income status. 
Page 23 GAO-14-104 School Lunch

feedback than normal in school year 2012-2013 with concerns about the 

program, which some believed was in response to negative media 

attention. Another factor that may have affected participation is the time 

allotted for lunch periods, according to officials in three districts we 

visited. SFA officials in one district noted that some of the changes to 

lunches, such as the requirement that students take a fruit or vegetable 

with their lunches, confused staff and students and led to longer lunch 

lines, particularly at the beginning of school year 2012-2013. One district 

we visited also made significant changes to the system students use to 

pay for lunch, which led to longer lunch lines early in school year 2012-

2013. One SFA director noted that if the lunch lines are too long or 

students otherwise do not have enough time to eat, they are more likely 

to look elsewhere for food or not eat at all. Other decisions at the district 

or school level may have also affected school lunch participation in school 

year 2012-2013. For example, one district we visited stopped allowing 

high school students to leave campus during the lunch period, which the 

SFA director believed helped mitigate the lunch participation declines the 

district experienced.41 In addition, states reported through our survey that 

321 SFAs in 42 states stopped participating in the National School Lunch 

Program in school year 2012-2013,42

 41 Prior to the change, the district had an open campus policy for its high schools, which 

allowed students to leave high school campuses during their lunch period. Generally, 

districts may choose to have an open campus policy for various reasons, such as limited 

food service areas on campus or, when the policy is conditional, to incentivize positive 

student behavior or academic performance. With a closed campus policy, students are 

required to stay on the school campus during the lunch period, which increases the 

likelihood that they will participate in the school lunch program.

which directly impacted the number 

of students able to participate in the program nationwide. While districts 

may choose to leave the program for various reasons, such as low 

student participation, twenty-seven of these states reported that the new 

lunch requirements were a factor in some SFAs’ decisions not to 

participate. USDA officials also noted other factors that may have 

influenced lunch participation, including school closures, mergers, moves, 

42 This represents 1.7 percent of the SFAs that participated in the National School Lunch 

Program in school year 2011-2012 nationwide. The percentage of states’ SFAs that 

participated in the program in school year 2011-2012 that chose not to participate in the 

program in school year 2012-2013 varied by state. In 40 of the 42 states with such SFAs, 

this percentage ranged from 0.2 percent to 4.7 percent. In the remaining 2 states, 5.4 

percent and 11.5 percent of SFAs that participated in the program in school year 2011-

2012 chose not to participate in school year 2012-2013. While SFAs provide lunch in one 

or more schools, we did not collect data on the number of schools overseen by SFAs who 

chose not to participate in the program in school year 2012-2013.
Page 24 GAO-14-104 School Lunch

consolidation due to economic conditions, and issues with food service 

management companies.

Although school lunch participation has declined, it is likely that 

participation will improve over time as students adjust to the lunch 

changes. Five of the districts we visited reported that, if the past is an 

indicator, participation will improve over time as students adjust to the 

new food items, and three noted the importance of nutrition education for 

students and parents to help make the transition to healthier school meals 

more successful.43 The SFA director in one district we visited that made 

changes to lunches prior to school year 2012-2013 in anticipation of the 

federal requirements initially experienced a decrease in participation, but 

saw participation recover in the following school year. Similarly, although 

the other seven districts we visited saw decreases in lunch program 

participation in the first months after implementing the new requirements 

in school year 2012-2013, participation increased in the majority of these 

districts as the school year progressed. Nationwide, fewer states 

expected student acceptance of the changes and palatability of foods to 

be challenges for SFAs in school year 2013-2014 than indicated they 

were challenges in school year 2012-2013, although the majority of states 

still expected these areas to be difficult.44

 43 In its report recommending the new school lunch requirements, the Institute of Medicine 

recognized the potential difficulty obtaining student acceptance of the changes and noted 

that various actions, including effective educational, marketing, and food preparation 

strategies, may help improve acceptance over time.

In four districts we visited, SFA 

directors noted that they had begun adding whole grains into their menus 

before the 2012-2013 school year, and they saw student acceptance of 

whole grain products improve over time. One district’s SFA director also 

noted that students’ willingness to eat foods in the beans and peas 

(legumes) sub-group has improved over time. When we talked with 

students in the schools we visited and asked them about the lunches, 

these specific foods were mentioned by some students in four of the eight 

districts we visited. However, at the same time, most of the students we 

spoke with indicated that they like to eat healthy and nutritious foods, and 

they think school lunches generally provide such foods. Further, although 

school year 2012-2013 was the first year that students nationwide were 

44 In our state survey, 36 states reported that they expect student acceptance to be a 

challenge in school year 2013-2014 (down from 48 in school year 2012-2013) and 26 

reported that they expect challenges with palatability in school year 2013-2014 (down from 

33 in school year 2012-2013).
Page 25 GAO-14-104 School Lunch

required to take a fruit or a vegetable with their school lunches, when we

asked students what they liked about school lunch that year, students in 

13 of the 17 schools we visited reported liking certain fruit and vegetable 

options.

As SFAs began implementing the new lunch requirements in school year 

2012-2013, they faced several challenges implementing the lunch 

changes. For example, most states reported that their SFAs faced 

challenges with plate waste—or foods thrown away rather than consumed 

by students—and food costs, as well as planning menus and obtaining 

foods that complied with the new portion size and calorie requirements. 

(See fig. 8.) The majority of states also reported that food service staff 

workload and food storage or kitchen equipment were challenges for their 

SFAs while implementing the new lunch requirements. The eight SFAs 

we visited also experienced these challenges,45

 45 For more information on challenges complying with the new requirements reported by 

the eight SFAs we visited, see 

although at the same 

time, all eight expressed support for the goal of improving the nutritional 

quality of lunches and felt the new requirements were moving in that 

direction.

GAO-13-708T. 

Nationwide, SFAs 

Faced Challenges 

Implementing Lunch 

Changes, Though 

Some Challenges Will 

Likely Diminish Over 

Time

Addressing Plate Waste, 

Managing Food Costs, 

and Planning Menus 

Challenged Many SFAs as 

They Implemented School 

Lunch Changes
Page 26 GAO-14-104 School Lunch

Figure 8: Number of States in Which SFAs Faced Challenges in Selected Areas during Implementation of the New Lunch 

Requirements in School Year 2012-2013

Notes: Figure includes states that reported these areas posed challenges for at least some of their 

SFAs in school year 2012-2013. Areas identified by states that indicated there were “Other”

challenges include: the amount of time provided to implement the changes; parent and public 

perception of the changes, as well as media coverage of the changes; and limited availability of

certain foods, such as whole grain products.

Addressing plate waste has been a longstanding challenge in the school 

lunch program, and officials in six of the districts we visited told us they 

believe plate waste increased in school year 2012-2013 because of the 

new lunch requirements. Specifically, students may take the food 

components they are required to as part of the school lunch but then 

choose not to eat them. Although none of the districts we visited had fully 

analyzed plate waste over the past few years to determine if it changed 

during school year 2012-2013,46 SFAs we visited said that the fruits and 

vegetables students are now required to take sometimes end up thrown 

away.47

 46 One of the districts we visited has been working with a university researcher on a plate 

waste study, but a final report has yet to be issued. 

Consistent with this, in our lunch period observations in 7 of 17 

47 USDA considers the offer versus serve policy, which allows students to decline two of 

the five meal components offered with the lunch, to be a way to minimize plate waste. 

However, under the current regulations for offer versus serve, students must select at 

least one half cup of fruits or vegetables with their lunches.
Page 27 GAO-14-104 School Lunch

schools, we saw many students throw away some or all of their fruits and 

vegetables. However, in the other 10 schools, we saw students take and 

eat sizable quantities of fruits and vegetables and the other lunch 

components, resulting in minimal plate waste. Four of the eight SFAs we 

visited mentioned that plate waste was more of an issue with the 

youngest elementary school students, possibly because of the amount of 

food served with the lunch and the amount of time they have to eat it. The 

Institute of Medicine report that recommended the new lunch 

requirements acknowledged differences in food intake among elementary 

students. The report noted that the amounts of food offered under the 

new recommendations may be too large for some of the younger 

elementary schoolchildren because they are more likely to have lower 

energy needs than older elementary schoolchildren being served the 

same lunches.48

Managing the food costs associated with implementing the new lunch 

requirements was another challenge reported by all of the SFAs we 

visited. In all eight SFAs, fruit and vegetable expenditures increased 

substantially during school year 2012-2013, as compared to school year 

2011-2012, consistent with the new requirements that both fruits and 

vegetables be offered daily with lunches and each student take at least 

one fruit or vegetable with lunch. However, increases varied among the 

SFAs we visited. Several factors likely affected the extent to which these 

costs increased in SFAs nationwide as they implemented the new 

requirements, including the availability of produce suppliers, economies of 

scale, and the amount of fruits and vegetables previously served with 

lunches. Some SFA officials we spoke with also noted that fruit and 

vegetable costs may vary greatly from year to year because of factors 

that are difficult to plan for when budgeting, such as the weather’s impact 

on growing seasons. By the end of school year 2012-2013, increased fruit 

and vegetable costs and other factors had negatively impacted the overall 

financial health of six SFAs we visited.49

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

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

49 In the two other SFAs we visited, officials attributed their resource management efforts 

as enabling them to end school year 2012-2013 with the same or a greater fund balance 

than they had at the end of school year 2011-2012, despite their fruit and vegetable costs 

having increased. 
Page 28 GAO-14-104 School Lunch

The SFAs we visited also cited difficulties planning menus that complied 

with the new requirements, including the portion size and calorie range 

requirements. All eight SFAs modified or eliminated some popular menu 

items because of the new portion size requirements for meats and 

grains.50 For example, two districts stopped serving peanut butter and 

jelly sandwiches as a daily option in elementary schools, and three 

districts reported that they changed the burgers they served. Specifically, 

one district removed cheeseburgers from elementary and middle school 

lunch menus because adding cheese to the district’s burger patties would 

have made it difficult to stay within the weekly meat maximums. Because 

lunch entrees frequently consist of meats and grains and provide the 

majority of calories in meals, the limits on meats and grains made it 

difficult for SFAs to plan lunches that complied with both the portion size 

and calorie range requirements. For example, in order to meet the 

minimum calorie requirements, some SFAs reported that they added 

foods to their menus that generally did not improve the nutritional value of 

lunches, such as pudding or potato chips. Further, students or school 

officials in five districts raised concerns about students being hungry after 

eating lunches that complied with the new requirements, which some of 

the students we spoke with attributed to the smaller entrée sizes. The 

calorie range requirements caused additional difficulties in SFAs whose 

districts included schools with students in both the 6-8 and 9-12 grade 

groups. These SFAs faced challenges planning menus that met the 

requirements for both groups because the calorie ranges for lunches 

served to those groups do not overlap.51

 50 USDA’s regulations specify the minimum and maximum weekly number of ounces of 

meats, cheese, or other meat alternates and the minimum and maximum weekly number 

of ounces of grains to be served with lunch, which differ by grade level. The regulations 

also specify the minimum number of ounces of meats and grains that must be served 

each day but do not specify the maximum number of ounces of meat and grains allowed 

to be served each day. 

One SFA we visited planned its

menus for schools serving students in both groups to generally provide a 

calorie total in-between the two ranges, which is not in compliance with 

requirements and may have left older students feeling hungry after lunch.

51 While the grades K-5 and 6-8 average daily calorie ranges for school lunches overlap at 

550-650 and 600-700, the grades 6-8 and 9-12 ranges, which are 600-700 and 750-850, 

do not. The Institute of Medicine report that recommended these ranges used data-based 

methods to provide a basis for the calculation of appropriate values for mean total daily 

calorie requirements for students in the three grade groups. Specifically, the report 

indicates that calorie range recommendations are based on reference growth chart data 

for healthy weights and heights, objective data on physical activity, and data on how 

calories are distributed among meals and snacks consumed by schoolchildren. 
Page 29 GAO-14-104 School Lunch

USDA temporarily provided SFAs some flexibility to help address these 

challenges, and we recommended in our June 2013 testimony that the 

department take additional steps. Specifically, in response to feedback 

from states and SFAs regarding operational challenges caused by the 

meat and grain maximums, USDA lifted the maximums temporarily—first 

in December 2012 for school year 2012-2013 and then in February 2013 

for school year 2013-2014.52 USDA indicated that they provided these 

flexibilities in response to the challenges they had heard about, and they 

did not see a problem making the temporary changes because the new 

lunch content standards include other requirements that also limit portion 

sizes. In our June 2013 testimony, we recommended that USDA 

permanently remove the weekly meat and grain maximums, and in 

January 2014, USDA issued regulations that remove the requirement for 

SFAs to comply with these maximums.53

SFAs we visited also discussed other challenges they faced planning 

lunch menus that complied with the new requirements in school year 

2012-2013. For example, officials from five SFAs noted that the 

requirements sometimes led them to serve meals they would not 

otherwise have planned because the specific food combinations are 

generally not served together as a meal. For example, one SFA served 

saltine crackers and croutons with certain salads to meet the minimum 

daily grain requirement and a cheese stick with shrimp to meet the 

minimum daily meat requirement. Several SFA directors and school food 

service managers also noted that the new requirements made it very 

difficult to make substitutions if they ran out of a particular menu item, 

because serving alternative food items in one day’s lunch may result in 

the week’s lunches exceeding the meat or grain limits or failing to include 

vegetables from all five sub-groups.

We also recommended in our 

testimony that USDA provide flexibility to help SFAs comply with the lack 

of overlap in the calorie ranges for the 6-8 and 9-12 grade groups. While 

USDA generally agreed with the recommendation, the department has 

not yet taken action to address that issue.

 52 See USDA, “SP 11-2013, FNS Guidance to School Food Authorities: Flexibility in the 

Meat/Meat Alternate and Grain Maximums for School Year 2012-2013” (Alexandria, VA: 

Dec. 7, 2012) and USDA, “SP 26-2013, Extending Flexibility in the Meat/Meat Alternate 

and Grains Maximums for School Year 2013-2014” (Alexandria, VA: Feb. 25, 2013). 

53 Certification of Compliance With Meal Requirements for the National School Lunch 

Program Under the Healthy, Hunger-Free Kids Act of 2010, 79 Fed. Reg. 325 (Jan. 3, 

2014) (codified at 7 C.F.R. pt. 210). 
Page 30 GAO-14-104 School Lunch

Another factor that complicated school year 2012-2013 menu planning in 

the SFAs we visited was food procurement. Three of the SFAs we visited 

noted that because food orders for school year 2012-2013 were placed in 

the initial months of 2012—at the same time that guidance on the new 

requirements was being issued—they procured foods without knowing 

what was required. Consequently, one SFA ordered more meat and 

poultry than was needed for the year, and another SFA inadvertently 

ordered foods that were not in compliance with the new requirements.54

According to SFA staff in all eight districts we visited, the workload for 

food service staff increased because of the new lunch requirements, and 

officials in some of the SFAs also noted that the requirements created 

new food storage and kitchen equipment challenges. School food service 

staff in all eight districts noted that workload increased primarily because 

Several SFA officials in districts we visited also mentioned that it was 

difficult to obtain from vendors certain food products that met the new 

requirements. For example, one SFA had difficulties obtaining the fresh 

produce it wanted to serve with lunches because of the increase in 

volume needed to comply with the new requirements. Further, three SFAs 

had challenges obtaining grain options from vendors that met portion size 

or whole grain requirements and were palatable to students. In three of 

the SFAs we visited, staff were still working with vendors during the 

school year to obtain food products needed to comply with requirements. 

SFA officials in some of the districts we visited and representatives from a 

group of food manufacturers and related industries we spoke with 

indicated that they had too little time between issuance of the final 

regulations and required implementation to reformulate food products to 

comply with the new lunch requirements. Further, after some products 

were reformulated, the temporary flexibilities that USDA provided for the 

meat and grain portion size requirements left industry experiencing 

difficulties forecasting demand, which led to food production, inventory, 

and storage challenges. In one school we visited, food service staff 

experienced related challenges at the end of school year 2012-2013, as 

several items on the school’s lunch menu were no longer being produced 

by vendors who were waiting for more certainty from USDA on the meat 

and grain requirements.

 54 USDA recognized that these types of food procurement issues would likely occur in 

school year 2012-2013, and the department issued guidance in August 2012 that provided 

suggestions for the use of already procured foods, as well as those on order, that may not 

easily fit into the new lunch content and nutrition requirements.
Page 31 GAO-14-104 School Lunch

of the need to prepare more fruits and vegetables each day to meet 

requirements. (See fig. 9.) In two of the smallest districts we visited, the 

increased workload in this area required staff reorganizations in which 

staff previously responsible for baking began helping to prepare fruits and 

vegetables. Staff in one SFA noted that the increased amount of time and 

effort to prepare fruits and vegetables also led to morale issues when 

staff saw students throw the fruits and vegetables in the trash. Further, 

two SFAs that chose to increase their use of fresh produce in lunches, 

rather than relying on canned or frozen products, reported that this 

required more frequent deliveries of these foods because of limited food 

storage capacity on-site in the schools. In one of these SFAs, the more 

frequent deliveries resulted in increased costs from the supplier, and in 

the other, they seemed to increase the likelihood of workplace injuries 

related to unloading and lifting. In addition to the need for more food 

storage space in schools, some SFAs we visited discussed new kitchen 

equipment needs that resulted from the changes to the lunch 

requirements, such as the need for new spoons and ladles to match the 

new portion size requirements, and food choppers and other equipment 

used for preparing fruits and vegetables to be served.55

 55 Similarly, a national survey of SFAs conducted in late 2012 estimated that 31 percent of 

SFAs nationwide needed additional kitchen equipment to comply with the new lunch 

requirements in school year 2012-2013. See The Pew Charitable Trusts and the Robert 

Wood Johnson Foundation, Serving Healthy School Meals: Despite Challenges, Schools 

Meet USDA Meal Requirements (September 2013).
Page 32 GAO-14-104 School Lunch

Figure 9: Examples of the Variety of Fruits and Vegetables Offered with Lunches in the Districts We Visited
Page 33 GAO-14-104 School Lunch

As SFAs, food service staff, and students adjust to the new lunch 

requirements, it is likely that some challenges that arose during 

implementation of the new requirements in school year 2012-2013 will 

become less problematic. For example, fewer states reported that they 

expect menu planning, including the required portion sizes for lunch 

components and calorie ranges for lunches, to challenge their SFAs in 

school year 2013-2014 than reported these areas as challenges in school 

year 2012-2013.56

As more time elapses, food manufacturers expect the availability of foods 

that comply with the new requirements and are palatable to students to 

increase, easing SFA challenges with food procurement and plate waste. 

Food manufacturers we spoke with reported that they spent school year 

2012-2013 focused primarily on reformulating food products to comply 

with the new lunch requirements. They added that because of the short 

timeframes between the issuance of the requirements for lunches and 

implementation, they did not have as much time to focus on food 

palatability, but as time elapses, they may have more time to do so. 

Further, both research and the experiences of some of our site visit 

districts suggest that students will likely adjust to the new lunch menus 

with time, which should result in decreased plate waste. While many 

states expect managing plate waste and food procurement to challenge 

their SFAs in school year 2013-2014, a greater number of states reported 

these areas as challenges for their SFAs in school year 2012-2013.

Although many states expect these areas to continue 

to be challenging, the flexibilities USDA recently made permanent related 

to the meat and grain portion size requirements should help ease menu 

planning moving forward.

57

In contrast, other areas may continue to be challenges in the future, 

including those related to costs and infrastructure. In our survey, a similar 

number of states reported that they expect their SFAs will be challenged 

 56 In our state survey, 39 states reported that they expect menu planning to be a 

challenge in school year 2013-2014 (down from 47 in school year 2012-2013), 35 reported 

that they expect the required portion sizes to be challenges in school year 2013-2014 

(down from 46 in school year 2012-2013), and 34 reported that they expect the calorie 

ranges to be challenges in school year 2013-2014 (down from 43 in school year 2012-

2013).

57 In our state survey, 40 states reported that they expect plate waste to be a challenge in 

school year 2013-2014 (down from 48 in school year 2012-2013) and 34 reported that 

they expect food procurement to be a challenge in school year 2013-2014 (down from 41 

in school year 2012-2013).

Some Areas Are Expected 

to Be Less Challenging for 

SFAs in the Future
Page 34 GAO-14-104 School Lunch

by food costs and food storage or kitchen equipment in school year 2013-

2014 as were challenged by those areas in school year 2012-2013.58

Some of the SFAs we visited also suggested that these areas will likely 

be ongoing challenges. To try to remedy storage challenges, one SFA we 

visited had developed plans to expand coolers and freezers on-site in 

schools, which was not an option in another SFA we visited due to facility 

and resource constraints. A third SFA’s plans to remodel the kitchen and 

serving lines in its largest school were put on hold because of the 

negative financial impact the SFA experienced in part because of the new 

lunch requirements. Overall, future costs were particularly concerning to 

some of the SFAs we visited. For example, officials in four SFAs 

expressed concerns about remaining financially solvent after the new 

requirements for school breakfasts or competitive foods are implemented, 

as some expect the breakfast changes to increase costs and the 

competitive foods changes to decrease revenues.59

Moving forward, states and SFAs also expressed concerns about the 

federally-required sodium limits for school lunches. The first of three 

sodium limits must be met beginning in school year 2014-2015. Many of 

the SFAs we visited noted that these limits will likely present a significant 

menu planning challenge, primarily because many of the foods available 

from manufacturers do not yet comply with these limits and students may 

not accept foods that meet the limits. These concerns were echoed by 

officials we spoke with in four states, with some noting that it will be very 

difficult for food manufacturers to make foods that meet the limits and are 

palatable to students. USDA has acknowledged that complying with the 

new limits will be a significant challenge that will require new technology 

and food products, and they have explained that these issues were 

considered when the department decided to require sodium to be 

reduced gradually over 10 years.

 58 In our state survey, 45 states reported that they expect food costs to be a challenge in 

school year 2013-2014 (compared to 47 in school year 2012-2013) and 27 reported that 

they expect food storage and kitchen equipment to be a challenge in school year 2013-

2014 (compared to 26 in school year 2012-2013).

59 New school breakfast content and nutrition standards were required to be implemented 

by SFAs generally at the beginning of school year 2013-2014, while the new competitive 

foods standards are required to be implemented at the beginning of school year 2014-

2015.
Page 35 GAO-14-104 School Lunch

During our site visits to eight SFAs, many also expressed concerns about 

the future nutrition standards for competitive foods, and these concerns

were not fully addressed in USDA’s interim final rule on the standards. At 

the time of our visits, SFAs expressed concerns that certain aspects of 

USDA’s proposed rule on the standards would be challenging to 

implement, if finalized.60 For example, officials from seven of the eight 

SFAs we visited expressed concerns about what they viewed as a lack of 

clarity regarding how the nutrition standards for competitive food sales 

administered by entities other than the SFA would be enforced. Officials 

from five of the SFAs we visited also expressed concerns about the 

provision that would allow states discretion to exempt certain fundraisers 

from the standards, because such exemptions may result in inequitable 

treatment and put the SFA at a competitive disadvantage relative to other 

food sales within a school. USDA’s interim final rule on the competitive 

food standards, issued in June 2013,61 requires school districts and SFAs 

to maintain records documenting compliance with the competitive food 

standards, and indicates that states and school districts will be 

responsible for ensuring compliance. However, it notes that forthcoming 

rules will describe state oversight requirements and fines for 

noncompliance. In addition, although USDA received many comments 

requesting that the department approve state decisions on fundraiser 

exemptions,62 the interim final rule does not require USDA approval of 

state decisions.

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

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

Fed. Reg. 9530 (proposed Feb. 8, 2013).

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

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

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

competitive food standards included in the interim final rule are generally required to be 

implemented at the beginning of school year 2014-2015. 

62 In the preamble to the interim final rule, USDA reported that approximately 800 

commenters expressed support for USDA approval of states’ decisions regarding the 

frequency of exempted fundraisers, citing that this would better ensure consistent 

application of nutrient standards across all fundraisers. In contrast, USDA reported that 

approximately 85 commenters expressed support for states making these decisions 

without USDA approval.
Page 36 GAO-14-104 School Lunch

USDA provided a substantial amount of guidance and training to assist 

states and SFAs in complying with the required changes to school lunch, 

which states indicated was useful. According to USDA officials, the 

department’s assistance effort has been unprecedented. From January 

2011—the month after the Healthy, Hunger-Free Kids Act of 2010 was 

enacted—through September 2013, USDA issued about 90 memos to 

provide guidance to states and SFAs on the new requirements for the 

content of school lunches and paid lunch equity. (See fig. 10.) Most of the 

memos (85 percent) addressed the new requirements for lunch content 

and nutrition standards, as well as related issues such as food 

procurement and state review of SFA compliance with the lunch 

requirements. The remaining 15 percent of the memos addressed the 

paid lunch equity requirements. Over the past few years, USDA also 

provided training through several venues to help states and SFAs 

implement the changes. For example, USDA officials convened webinars 

and in-person trainings for states, participated in webinars and national 

conferences for SFAs, and worked with the National Food Service 

Management Institute to provide additional training and resources.63

 63 The National Food Service Management Institute was established by law in 1989 and 

funded at the University of Mississippi in 1991 by a grant administered through the USDA. 

The Institute’s mission is to provide information and services that promote the continuous 

improvement of child nutrition programs.

USDA’s regional offices also provided training to states. In addition, as 

the changes were implemented in school year 2012-2013, USDA officials 

reported that they conducted an extensive amount of travel to visit school 

USDA’s Assistance 

Efforts Were 

Substantial, but 

Certain Aspects of 

USDA’s Guidance 

May Hinder State 

Oversight of 

Compliance

USDA Provided a 

Substantial Amount of 

Guidance and Training in 

a Short Time, Which Was 

Both Useful and 

Challenging for States and 

SFAs
Page 37 GAO-14-104 School Lunch

districts around the country to see how their efforts to implement the 

changes were progressing and to obtain feedback on additional 

assistance needed. All states reported that USDA’s guidance and training 

were useful as the new school lunch requirements were implemented. 

Further, over half of the states reported that USDA’s guidance was very 

useful or extremely useful, and officials from seven of the eight states we 

interviewed as part of our site visits expressed appreciation for USDA’s 

efforts to respond to issues that arose as changes were implemented.

Figure 10: USDA Memos Issued to Provide Guidance on the New Requirements for the Content of School Lunches and Paid 

Lunch Equity, Jan. 2011-Sept. 2013

a Paid lunch equity requirements, as well as the milk and water lunch content requirements, were 

required to be implemented by SFAs in school year 2011-2012.

b In order to assist state efforts to certify SFA compliance in school year 2012-2013, USDA issued 

multiple tools through a guidance memo in May 2012 and then made additions and changes to those 

tools several times throughout the school year. Because the figure includes all versions of guidance 

memos by the date they were issued, and these updated tools were not provided with a revised 

guidance memo, these revised tools are not included in the figure.

c “Other” guidance memos include those that address procurement of foods by SFAs for school 

lunches and state administrative funds. USDA provides states with administrative funds annually to 

assist their efforts to administer and oversee the National School Lunch Program, and the Healthy, 

Hunger-Free Kids Act of 2010 provided additional funds for fiscal years 2012 and 2013 intended to 

provide states with additional resources to assist SFAs efforts to improve the quality of school meals 

provided to children and come into compliance with the new requirements.
Page 38 GAO-14-104 School Lunch

In contrast, some states and SFAs noted that the relatively short 

timeframes within which the lunch requirements were implemented made 

it difficult to keep up with the extensive amount of guidance provided by 

USDA. In the 18 months from January 2012—the month in which the final 

rule on the changes to the lunch content and nutrition standards was 

issued—through the end of school year 2012-2013, USDA issued 1,800 

pages of guidance on these changes.64 Several SFAs we visited noted 

that keeping up with the extensive amount of guidance was difficult during 

school year 2012-2013 because they were simultaneously implementing 

the lunch changes. In addition, 32 states reported through our survey that 

the timing of USDA’s guidance on the new lunch requirements was a very 

great challenge or extreme challenge during school year 2012-201365

 64 This is a subset of the guidance that we analyzed. This estimate includes guidance that 

directly addressed the lunch content and nutrition standards, state review of SFA 

compliance with those standards, and related areas, such as food procurement. Because 

USDA has issued multiple manuals and tools to assist state efforts to review SFA 

compliance with the new lunch requirements, almost two-thirds of the total guidance 

pages are related to this area. 

—a 

response echoed by most of the states we spoke with as part of our eight 

site visits. For example, officials in one state reported that the guidance 

providing SFAs with flexibility on the meat and grain maximums was 

provided too late in school year 2012-2013 to be helpful, as SFAs had 

already planned menus and trained food service staff on the new meat 

and grain requirements. Further, because of the fast pace with which 

USDA provided guidance on the new lunch requirements, officials from 

four states said that the department’s regional offices were sometimes 

unable to answer state questions on the guidance. While six of the eight 

states we spoke with as part of our site visits commended the efforts that 

the regional offices took to help states understand the new lunch 

requirements, some noted that regional offices learned about the 

requirements at the same time as states. Because of this, regional office 

staff were not always able to answer state questions on the guidance, 

and states had to instead wait for USDA headquarters’ staff to respond. 

USDA officials told us that while they recognize that the lunch changes 

65 States’ responses to our survey suggest that the timing of USDA’s guidance on the 

School Breakfast Program changes required in school year 2013-2014 may have also 

been challenging. Specifically, states responded to our survey in June and July 2013, 

which coincided with the beginning of school year 2013-2014. At that time, the majority of 

states reported a need for more guidance and training on the School Breakfast Program 

meal patterns and nutrition standards.
Page 39 GAO-14-104 School Lunch

were defined and implemented rather quickly, this was necessary 

because of the importance of improving school meals.

Almost two-thirds of states also reported through our survey that the 

changes USDA made to its guidance on the lunch requirements were a 

very great challenge or extreme challenge during school year 2012-2013. 

According to our analysis, 40 percent of the guidance memos issued by 

USDA on the new requirements for the content of school lunches and 

paid lunch equity from January 2011 through September 2013 contained 

new flexibilities not included in federal regulations or substantive changes 

to previously issued guidance, which were to be enforced either 

temporarily or permanently.66 (See fig. 11.) According to USDA’s general 

counsel, the department felt that it was important to provide such 

flexibilities to help ease the implementation process, although the 

guidance is technically non-binding and does not modify statutory or 

regulatory requirements. For example, USDA issued several guidance 

memos from February through December 2012 that added flexibilities 

related to the fruit, milk, meat, and grain components of lunches, which 

had not been included in the January 2012 final regulations. Further, 

some guidance memos either substantively changed or contradicted 

aspects of previously issued memos. For example, in a February 2012 

guidance memo, USDA indicated that frozen fruit served with lunches 

was not allowed to contain added sugar after school year 2012-2013.67

 66 This includes memos that substantively changed or contradicted previous explanations 

of requirements, and it does not include memos that solely provided additional clarification 

of requirements. Further, because we analyzed guidance memos, the 40 percent does not 

include additions and changes to the tools USDA provided states to assist their efforts to 

certify SFA compliance in school year 2012-2013. While these tools were changed 

multiple times during school year 2012-2013, the updated tools were not provided to 

states with a revised guidance memo. See App. I for more information on our analysis of 

USDA guidance. 

However, in memos issued in September 2012 and June 2013, the 

department indicated that fruit with added sugar would be allowed in 

67 See USDA, “SP 20-2012, Frozen Fruit Products and Nutrition Standards in the National 

School Lunch and School Breakfast Programs” (Alexandria, VA: Feb. 24, 2012).
Page 40 GAO-14-104 School Lunch

school years 2013-2014 and 2014-2015, respectively.68

 68 See USDA, “SP 20-2012-Revised, Frozen Fruit Products and Nutrition Standards in the 

National School Lunch and School Breakfast Programs” (Alexandria, VA: Sept. 11, 2012) 

and USDA, “SP 49-2013, “Frozen Fruit Products in the National School Lunch and School 

Breakfast Programs in School Year 2014-2015” (Alexandria, VA: June 25, 2013). In 

addition, in January 2014, USDA issued regulations that permanently remove the 

requirement for SFAs to serve frozen fruit that does not contain added sugar. Certification 

of Compliance With Meal Requirements for the National School Lunch Program Under the 

Healthy, Hunger-Free Kids Act of 2010, 79 Fed. Reg. 325 (Jan. 3, 2014) (codified at 7 

C.F.R. pt. 210).

While state and 

SFA officials we spoke with noted that some of these changes were likely 

made by USDA to respond to problems SFAs were having implementing 

the new lunch requirements, the guidance changes were difficult to keep 

up with and led to increased confusion about the requirements. Further, 

officials in six of the states we interviewed as part of our site visits 

reported that the changes USDA made to its guidance also frustrated 

SFAs or complicated training on the new lunch requirements. Officials 

from three states we spoke with as part of our site visits also reported that 

changes might have been avoided if USDA had piloted or phased in the 

new requirements more slowly, which suggests that the challenges states 

and SFAs experienced because of the lack of timely and consistent 

guidance from USDA in school year 2012-2013 may become less 

problematic over time. USDA officials told us that their assistance efforts, 

and the changes made to guidance, reflected the department’s 

recognition that the process needed to be iterative, as unexpected issues 

with the requirements would likely arise as the new lunch standards were 

implemented in the schools.
Page 41 GAO-14-104 School Lunch

Figure 11: USDA Memos that Provided Flexibilities Related to Federal Regulations or Changed Previous Guidance on the New 

Requirements for the Content of School Lunches and Paid Lunch Equity, Jan. 2011-Sept. 2013

a Paid lunch equity requirements, as well as the milk and water lunch content requirements, were 

required to be implemented by SFAs in school year 2011-2012.

b In order to assist state efforts to certify SFA compliance in school year 2012-2013, USDA issued 

multiple tools through a guidance memo in May 2012 and then made additions and changes to those 

tools several times throughout the school year. Because the figure includes all versions of guidance 

memos by the date they were issued, and these updated tools were not provided with a revised 

guidance memo, these revised tools are not included in the figure.

c “Other” guidance memos include those that address procurement of foods by SFAs for school 

lunches and state administrative funds. USDA provides states with administrative funds annually to 

assist their efforts to administer and oversee the National School Lunch Program, and the Healthy, 

Hunger-Free Kids Act of 2010 provided additional funds for fiscal years 2012 and 2013 intended to 

provide states with additional resources to assist SFAs efforts to improve the quality of school meals 

provided to children and come into compliance with the new requirements.
Page 42 GAO-14-104 School Lunch

While SFAs transition to the new lunch requirements, USDA has 

emphasized the importance of state assistance in helping SFAs comply. 

According to the Standards for Internal Control in the Federal 

Government,69 federal agencies should have policies and practices in 

place to provide reasonable assurance that programs are operated in 

compliance with applicable laws and regulations. To this end, USDA 

officials told us that they directed states to work with SFAs to achieve 

compliance with the new lunch requirements during school year 2012-

2013. Nationwide, 45 states reported that they used the additional 

administrative funds they received for fiscal year 2013 to conduct training 

for SFAs and provide technical assistance to SFAs.70 In addition, many 

states reported using these funds to certify SFA compliance with the new 

meal requirements and conduct required validation reviews of a sample of 

those certified.71

Although SFAs likely needed and benefited from state assistance as they 

worked to implement the new lunch requirements, USDA’s emphasis on 

assistance, combined with new financial incentives for compliance, may 

have led to incomplete identification and documentation of SFA 

noncompliance. For many years, states have conducted administrative 

reviews of SFAs and observed lunches in schools in order to assess SFA 

compliance with federal requirements. In the past, USDA consistently 

noted the importance of these reviews for ensuring the integrity of the 

National School Lunch Program, as the review process requires that 

noncompliance be addressed. Under this process, instances of SFA 

noncompliance are required to be documented and lead to a corrective 

Officials in all eight of the states we spoke with as part of 

our site visits reported that they provided extensive guidance and 

assistance to SFAs to help them understand and implement the new 

lunch requirements and become certified as in compliance with the 

requirements.

 69 GAO/AIMD-00-21.3.1.

70 While USDA provides states with administrative funds annually to assist their efforts to 

administer and oversee the National School Lunch Program, the Healthy, Hunger-Free 

Kids Act of 2010 provided for states to receive additional administrative funds in fiscal 

years 2012 and 2013. These funds were intended to provide states with additional 

resources to assist SFAs efforts to improve the quality of school meals provided to 

children and come into compliance with the new requirements.

71 The Healthy, Hunger-Free Kids Act of 2010 required USDA to provide additional 

reimbursement for each lunch served in SFAs certified by states as in compliance with the 

new requirements for the content of school lunches beginning October 1, 2012. 

USDA Has Emphasized 

State Assistance to SFAs, 

but USDA Guidance 

Changes and Gaps May 

Hinder State Oversight of 

SFA Compliance
Page 43 GAO-14-104 School Lunch

action plan and follow-up to ensure issues are addressed. In addition, the 

documentation of issues has also provided federal and state officials with 

information on areas for which additional assistance may be needed 

across SFAs. During school year 2012-2013, however, states were 

generally not required to conduct administrative reviews. Rather, states 

were to assist SFA efforts to comply with the new lunch requirements. 

Further, states were required to provide SFAs certified as in compliance 

with the new requirements an extra 6 cents of federal reimbursement for 

each lunch served and conduct on-site validation reviews in a sample of 

the certified SFAs. USDA officials reported that they considered the 

added funds to be an important way to offset the extra costs SFAs 

incurred as they made the required changes to lunches. However, while 

the certification and validation process likely helped SFAs understand the 

new requirements and obtain the additional reimbursement to help with 

compliance, unlike the administrative review process, states were not 

required to fully document issues of noncompliance they identified. For 

example, officials in two states we spoke with noted that USDA instructed 

them to work with SFAs during the certification process and during 

validation reviews of those certified, rather than strictly enforce 

requirements.72 This is consistent with USDA’s guidance, which 

emphasized the provision of assistance during the certification process 

and validation reviews to help SFAs become compliant. However, 

because states were generally not required to document noncompliance 

issues that arose during the certification process or validation reviews, 

SFAs may not have developed or documented corrective action plans 

taken to address them.

73

 72 This emphasis on assisting SFA efforts to comply and become certified appears to have 

been strengthened by at least one USDA regional office, as one state told us it was 

directed not to deny an SFA’s certification without first sending the SFA’s paperwork to the 

regional office for review.

As a result, SFAs may not have adequate 

information on the types of ongoing compliance issues and the need to 

take corrective actions. Moreover, USDA has limited information on the 

extent to which SFAs are facing similar difficulties complying with the new 

73 While documentation of noncompliance issues was not required during the certification 

process or during most validation reviews, USDA’s guidance directed states that found

significant noncompliance in specified areas during a validation review to transition the 

review to a focused administrative review. These reviews include documentation of 

noncompliance issues and require corrective action plans.
Page 44 GAO-14-104 School Lunch

requirements, which could be the focus of future federal technical 

assistance efforts.74

National data, as well as our conversations with states and visits to 

schools, suggest that some instances of SFA noncompliance may not 

have been fully documented while the new lunch requirements were 

being implemented. We and others have reported that SFAs experienced 

significant challenges implementing the new lunch requirements during 

school year 2012-2013, and several state officials we spoke with as part 

of our site visits told us that SFAs often needed a lot of state assistance 

to move forward with the new requirements, also suggesting that SFAs 

faced significant challenges fully complying. However, national data 

suggest that these challenges affected few SFAs’ certifications.75

Specifically, 82 percent of SFAs nationwide applied to be certified as in 

compliance with the new lunch requirements during school year 2012-

2013,76

 74 USDA officials told us that they collected information on challenges SFAs faced 

complying with the new lunch requirements in school year 2012-2013 through the Special 

Nutrition Program Operations Study. One of the goals of this study is to analyze the 

information obtained from a nationally representative sample of SFAs in order to provide 

technical assistance. While this study provides self-reported information on SFA 

challenges, it does not include information on SFA noncompliance.

and states denied 1 percent of SFAs that applied. (See fig. 12.) 

National data on the results of state validation reviews of SFAs show 

similar outcomes, as 1 percent of SFAs had the extra federal 

reimbursement stopped by their states because of noncompliance issues 

found during these reviews. When reviewing the certification and 

validation results by state, we found that 25 states did not deny any SFAs 

that applied for certification and validated all SFAs reviewed. While states 

reported that they were unable to validate compliance in an additional 4 

percent of SFAs reviewed nationwide, states did not stop these SFAs 

from continuing to receive the extra federal reimbursement, possibly 

75 Because the certification and validation process did not require states to document 

issues of noncompliance, the extent to which noncompliance issues occurred in SFAs is 

unknown. 

76 Three of the eight SFAs we visited had not applied to be certified as in compliance with 

the new lunch requirements at the time of our visits in spring 2013. Two of these SFAs 

operated in the smallest school districts we visited, and both had previously used the 

nutrient standard menu planning approach for lunches, rather than the food-based menu 

planning approach—characteristics that created additional challenges for implementation. 

The remaining five SFAs we visited had all been certified by their states as in compliance 

with the new lunch requirements at the time of our visits.
Page 45 GAO-14-104 School Lunch

because of changes in USDA guidance during school year 2012-2013.77

One state told us that it interpreted USDA’s guidance to mean that the 

state should not stop an SFA from receiving the extra federal 

reimbursement even when it was unclear if issues of noncompliance 

found during a validation review would be fully addressed by the SFA.78 In 

another state, we obtained evidence that some of the lunch menus in an 

SFA we visited may not have been fully in compliance with the new 

requirements, though the SFA was certified and validated, and in two 

additional certified SFAs we visited, we observed practices in schools that 

were inconsistent with the new requirements.79

 77 USDA’s guidance on validation reviews and the extra federal reimbursement 

substantively changed during school year 2012-2013. In initial guidance provided in July 

2012, states were instructed to stop the extra federal reimbursement to SFAs not 

validated to be in compliance with the lunch requirements unless the compliance issues 

could be fixed immediately. Later, in January 2013, USDA guidance indicated that states 

could continue to allow an SFA that could not be validated during the review to receive the 

extra federal reimbursement, if immediate corrective action occurred or if the SFA agreed 

to take the appropriate corrective action. The January 2013 guidance added that the extra 

federal reimbursement should only be stopped in cases of “significant noncompliance,”

which were also described as cases “where the problem is severe or intentional.” 

While five of the eight 

SFAs we visited had been certified to be in compliance with the new 

requirements at the time of our site visits, the possible noncompliance 

issues in three of these five SFAs indicate the difficulty of ensuring proper 

implementation of the lunch changes in all of an SFA’s schools, 

particularly during the first year that changes were required.

78 In another state, a state official told us that reviewers found many compliance problems 

during SFA validation reviews; however, that state reported through our survey that all 

SFAs it reviewed were validated.

79 For example, in one school, we observed several students whose lunches were 

counted as eligible for federal reimbursement at the point of sale, but the lunches did not 

include a fruit or vegetable. Federal regulations require all lunches served to include a fruit 

or vegetable, and in order to be eligible for federal reimbursement, lunches need to 

comply with all federal requirements for the content of lunches.
Page 46 GAO-14-104 School Lunch

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

Notes: Figure includes data obtained from state child nutrition directors through our survey in June 

and July 2013. Because school year 2012-2013 ended on June 30, 2013, data provided by states 

who responded to our survey in June may not reflect the full school year. Validation percentages do 

not add to 100 due to rounding.

A new 3-year cycle of state administrative reviews of SFAs began in 

school year 2013-2014, and USDA’s guidance has continued to 

emphasize the need for states to assist SFAs, which may come at the 

expense of program integrity. Consistent with USDA’s guidance issued to 

states in school year 2012-2013 for certification and validation reviews, 

USDA’s guidance on state administrative reviews in school year 2013-

2014 acknowledged that SFAs are in a transition period and set the 

expectation that states continue to work closely with SFAs to support their 

efforts to comply with the new lunch requirements. The guidance also 

indicated that the department believes most SFA noncompliance is likely 

the result of SFA efforts to understand and implement the new 

requirements and, as a result, states should continue to provide technical 
Page 47 GAO-14-104 School Lunch

assistance and training to address issues of noncompliance.80 While 

documenting noncompliance issues and requiring corrective actions to 

address them have long been a required part of the administrative review 

process, because these actions were not required in school year 2012-

2013, it is unclear if states will systematically follow this approach moving 

forward. Further, USDA’s continued emphasis on state assistance to help 

SFAs comply may also inadvertently lead to states not consistently

documenting SFA noncompliance. Without such documentation, issues of 

noncompliance will not be fully addressed through corrective actions, and 

program integrity will be at risk.81

Concerning specific areas assessed by states during administrative 

reviews, states reported through our survey a need for additional USDA 

assistance with oversight of SFA financial management. Specifically, 

nationwide, many states reported a need for additional guidance and 

training on oversight of SFA financial management and the related areas 

of paid lunch equity and revenue from non-program foods.

This has been a long-standing issue for 

USDA. For example, in 2008, incomplete documentation of compliance 

concerned USDA, as some states were found to be conducting practice 

reviews of SFAs to allow them to fix issues of noncompliance before the 

actual reviews were held. At that time, USDA emphasized to states that 

practice reviews undermine the integrity of the review process and should 

be stopped in order to ensure that reviews include full documentation of 

SFA noncompliance and require all corrective actions be taken. By 

allowing states to not consistently document noncompliance during 

school year 2012-2013, and continuing to emphasize assistance in school 

year 2013-2014, USDA may be setting up a similar situation.

82

 80 For the purposes of fiscal action associated with administrative reviews, guidance 

indicates that only for instances of “willful and egregious violations” by SFAs may states 

need to take fiscal action, and only then after states contact their USDA regional offices.

Although 

federal regulations have long required states to generally ensure that 

SFAs manage their resources in accordance with requirements, USDA 

81 According to Standards for Internal Control in the Federal Government, internal control 

monitoring should assess the quality of performance over time and ensure that the 

findings of audits and other reviews are promptly resolved GAO/AIMD-00-21.3.1.

82 In our state survey, 47 and 44 states, respectively, reported that they needed additional 

guidance or training from USDA on overall SFA financial management; 42 and 35 states, 

respectively, reported that they needed additional guidance or training from USDA on 

revenue from non-program foods; and 30 and 24 states, respectively, reported that they 

needed additional guidance or training from USDA on paid lunch equity.
Page 48 GAO-14-104 School Lunch

guidance on state administrative reviews of SFAs previously indicated 

that SFA financial management was not required to be assessed during 

these reviews. In contrast, in part because of new requirements in the 

Healthy, Hunger-Free Kids Act of 2010,83 the new administrative review 

process announced by USDA in 2013 includes oversight of five areas of 

SFA resource management and is intended to ensure effective 

management of school meal programs’ resources.84

Although USDA has provided training for states on SFA financial

management and is currently in the process of talking with some states 

USDA has indicated 

that traditionally, states developed their own processes for reviewing SFA 

finances, but the resulting processes were inconsistent and sometimes 

inadequate. We discussed oversight of this area with six states. The child 

nutrition director from one state indicated that her staff have been trained 

on accounting principles in order to review SFA financial management 

and are therefore ready to implement the new review requirements. 

However, officials from the other five states expressed concerns about 

implementing the new requirements in this area. Officials from two states 

told us that they believe nationwide, states’ approaches for reviewing SFA 

financial management have been very different. For example, in one 

state, past review of this area consisted of ensuring that the SFA’s fund 

balance at the end of one school year matched its starting fund balance 

at the beginning of the next school year, while in another state, officials 

have long employed an outside organization with expertise in this area for 

these reviews. Because state administrative reviews are the key tool used 

to ensure the integrity of the National School Lunch Program, if state 

reviewers are unable to effectively review SFA financial management, the 

federal government will lack assurance that SFAs are complying with 

federal requirements in this area—including those added by the Healthy, 

Hunger-Free Kids Act of 2010.

 83 The Healthy, Hunger-Free Kids Act of 2010 contained two new revenue requirements 

related to the prices SFAs set for paid lunches and other foods sold outside of the school 

meal programs. These provisions were developed, in part, because of a USDA study that 

found the average prices charged for paid lunches and for other foods by some SFAs 

were less than the cost of producing those foods. This led to a concern that some SFAs 

were using federal reimbursements for free and reduced-price meals to subsidize meals 

and other foods for which they were not intended.

84 USDA guidance indicates that these five areas are integral to the financial health of an 

SFA’s school food service. They are: maintenance of the nonprofit school food service 

account, paid lunch equity, revenue from non-program foods, indirect costs, and USDA 

foods (commodities). 
Page 49 GAO-14-104 School Lunch

about oversight of this area, it is unclear if the department has fully 

addressed all states’ information needs. Specifically, USDA provided 

training for all states in spring 2013 on the new administrative review 

requirements, including those for SFA financial management.85 However, 

states reported the need for additional assistance in this area through our 

survey after that training. In late July 2013, USDA provided two additional 

webinars for states on SFA financial management review requirements, 

and in December 2013, officials told us that they have been providing 

ongoing technical assistance in this area to states upon request. Officials 

added that such requests have been relatively frequent during recent 

months, which they acknowledge is likely related to the change in 

requirements for oversight of this area. Further, as part of USDA’s larger 

effort to gather information on states’ experiences with the new 

administrative review process, officials told us in January 2014 that they 

have been talking with individual states in recent months and asking for 

their questions and concerns related to all areas of the administrative 

review process, including SFA financial management. Officials noted that 

they plan to solicit this information from all states implementing the new 

administrative review process this year. However, until the department 

systematically solicits information from all states on their needs related to 

oversight of SFA financial management, including those that are not 

currently implementing the new process, the department will not know if 

all states are fully prepared to oversee this area.

The Healthy, Hunger-Free Kids Act of 2010 required that nutrition 

standards for school lunches be updated to help reduce childhood obesity 

and improve children’s diets, and evidence suggests that lunches served 

are now better designed to meet those goals. Although some decreases 

in student lunch participation and challenges for SFAs occurred in the first 

year that the lunch changes were implemented, these outcomes are likely 

related to the substantial scale of the changes and the short time in which 

they were implemented. As a result, both participation and many of the 

challenges SFAs faced initially are expected to improve with the passage 

of time as students and SFAs adjust to the new lunch requirements.

 85 In addition to the spring 2013 training, USDA officials told us that they have also 

provided training on indirect costs and other SFA financial management areas in recent 

years, both through the department’s headquarters and regional offices. In part, this was 

in response to statutory requirements, as the Healthy, Hunger-Free Kids Act of 2010 

required USDA to provide indirect cost guidance to SFAs. 

Conclusions
Page 50 GAO-14-104 School Lunch

Since the act was passed, USDA has focused on the provision of 

assistance to help SFAs comply with the new requirements. While this 

emphasis may have been needed given the scope of the changes and 

the short timeframe for implementation, it alone will not ensure that 

students nationwide are being served healthier school lunches. Rather, 

only when government assistance is combined with an emphasis on 

program integrity will it be possible to ensure that healthier school lunches 

are served nationwide. The administrative review process has long been 

key to both addressing issues of noncompliance in the National School 

Lunch Program and ensuring that federal and state governments have 

information on areas for which they should target additional assistance to 

SFAs to improve program compliance. However, even with this process in 

place, program errors resulting from lunches that did not comply with

requirements being served to students have been a long-standing issue. 

The substantial changes to the lunch requirements, combined with the 

delays and changes made in federal guidance while the requirements 

were being implemented, as well as temporary changes to the process 

through which states reviewed SFA compliance, increase the likelihood 

that lunches served to students may not meet all of the requirements. In 

addition, while USDA has developed a new administrative review 

process, which includes new requirements related to SFA financial 

management, the review process will not be effective without state 

understanding of all of the requirements they are responsible for 

overseeing. Further, because the Healthy, Hunger-Free Kids Act of 2010 

included two new provisions that relate to SFA financial management—

those addressing paid lunch prices and revenue from foods sold outside 

of the school meals programs—without effective oversight of SFA 

financial management by states, neither states nor the federal 

government will have assurance that SFAs are correctly implementing 

these requirements. As new requirements are added this year and in the 

future for the School Breakfast Program and competitive foods, timely 

and consistent USDA guidance combined with an effective administrative 

review process are all vital to ensuring successful implementation of the 

changes to school food and achieving the laudable goal of improving 

schoolchildren’s diets and health.

To improve program integrity, as USDA moves forward with its new 

administrative review process, we recommend that the Secretary of 

Agriculture direct the Administrator for the Food and Nutrition Service to 

take the following actions:

Recommendations for 

Executive Action
Page 51 GAO-14-104 School Lunch

• clarify to states the importance of documenting compliance issues 

found during administrative reviews and requiring corrective actions to 

address them, and

• continue efforts to systematically assess all states’ needs for 

information to improve their ability to oversee SFA financial 

management and provide assistance to meet identified needs.

We provided a draft of this report to USDA for review and comment. In 

oral comments, the Senior Policy Advisor to the Deputy Administrator for 

Child Nutrition Programs and other USDA officials generally agreed with 

our recommendations. These officials also noted that they consider the 

emphasis on technical assistance associated with school meals 

implementation in school year 2012-2013 appropriate given that the new 

meal patterns represented a major transition for local program operators. 

They also indicated their belief that the level of review associated with the 

6-cent certification process, including detailed review of meal pattern 

documentation and on-site reviews of at least 25 percent of certified 

SFAs, provides a solid foundation for ongoing oversight of compliance 

moving forward. Officials also expressed their belief that the new 

administrative review process, which they developed in collaboration with 

states, is an effective and efficient monitoring process that will improve 

program integrity. Further, they noted that their ongoing efforts to assist 

state efforts to properly implement the new process will help ensure that 

states are able to effectively review all required areas, including SFA 

financial management. We agree that the new administrative review 

process, if properly implemented, could improve program integrity, and as 

we discuss in the report, we agree that the emphasis on technical 

assistance likely benefited SFAs as they transitioned to the new lunch 

requirements. However, we continue to believe that the changes made in 

oversight requirements during school year 2012-2013 may have left 

USDA without key information on compliance issues SFAs faced when 

implementing the changes and may have created confusion among states 

as to the importance of consistently documenting noncompliance for 

program integrity. While we also remain concerned that the change in 

oversight requirements during school year 2012-2013 and the 

department’s continued emphasis on state assistance to SFAs moving 

forward may inadvertently undercut the effectiveness of the new review 

process, we see opportunities for USDA to address these issues. 

Specifically, as USDA continues its efforts to communicate and 

collaborate with states during their implementation of the new review 

Agency Comments
Page 52 GAO-14-104 School Lunch

process, the department is well-positioned to emphasize the importance 

of documenting noncompliance for effective program oversight and to 

provide states with the information they need to effectively review all 

required areas. USDA officials also provided technical comments, which 

we incorporated into the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution of it until 30 days from 

the report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Agriculture, and 

other interested parties. In addition, this report will be available at no 

charge on GAO’s website at http://www.gao.gov.

If you or your staff have any questions concerning this report, please 

contact me at (202) 512-7215 or brownke@gao.gov. Contact points for 

our Offices of Congressional Relations and Public Affairs may be found 

on the last page of this report. GAO staff who made key contributions to 

this report are listed in appendix III.

Kay E. Brown 

Director, Education, Workforce, and Income Security Issues
Appendix I: Scope and Methodology

Page 53 GAO-14-104 School Lunch

To assess trends in school lunch participation, we analyzed USDA’s 

national data on meals served in the National School Lunch Program 

from school year 2000-2001 through school year 2012-2013.1

Although USDA does not collect additional data on the number of 

students participating in the program each month, the department uses 

the lunch data it collects to determine the number of students participating 

in the program. Specifically, USDA adjusts the data on average daily 

lunches served each month upward to help account for students who 

participated in the program for a number of days less than all days in the 

month. To make this adjustment, USDA uses an estimate of the 

proportion of students that attend schools daily nationwide.

Each 

month, states report to USDA on the FNS-10 form the number of lunches 

served by category of student—free, reduced-price, and paid—as well as 

average daily lunches served to all students. These data are used to 

determine federal reimbursement payments to states. Additionally, in 

October of each school year, states report to USDA the total number of 

students enrolled in schools with the National School Lunch Program, as 

well as the total number of students approved for free and reduced-price 

meals in that month. Subtracting these students from the total enrolled 

students provides the number of students required to pay full price for 

their meals, if they choose to buy them, in schools with the National 

School Lunch Program.

2

To analyze participation in the National School Lunch Program, we 

reviewed USDA’s data on meals served and students enrolled, as well as 

the department’s methodology for determining student participation, and 

 1 These data include lunches served in public and private schools and residential child 

care institutions in the 50 states, the District of Columbia, Guam, Puerto Rico, the U.S. 

Virgin Islands, and the U.S. Department of Defense’s military bases. 

2 USDA divides the data reported for average daily lunches by an attendance factor of 

0.927 to estimate monthly lunch participation. USDA officials said this methodology has 

been in place for many years and the attendance factor was historically derived. We 

determined that this attendance factor is similar to average daily attendance data 

published annually by the U.S. Department of Education.

Appendix I: Scope and Methodology

U.S. Department of 

Agriculture (USDA)

Participation Data
Appendix I: Scope and Methodology

Page 54 GAO-14-104 School Lunch

determined these data and the method to be sufficiently reliable for the 

purposes of this report. Specifically, we interviewed USDA officials to 

gather information on the processes they use to ensure the completeness 

and accuracy of the school lunch data, reviewed related documentation, 

and compared the data we received from the department to its published 

data. To determine school year participation from these data, we relied on 

9 months of data—September through May—for each year.3 To 

determine the participation rate, we divided the number of students 

participating per month by the total number of students enrolled in 

schools with the program. We followed the same approach to determine 

the participation rates for students receiving free and reduced-price 

lunches, as well as those who paid full price for their lunches.

To understand the scale and scope of assistance USDA has provided to 

states and SFAs, we analyzed guidance memos USDA issued from 

January 2011—the month after the Healthy, Hunger-Free Kids Act was 

enacted—through September 2013. We reviewed all guidance memos 

issued to states during this time period and further analyzed those that 

provided guidance addressing the new requirements for the content of 

school lunches, including related issues such as food procurement and 

state review of SFA compliance with the lunch content requirements, as 

well as those addressing the paid lunch equity requirements. These 

memos included the department’s policy and technical assistance 

memos, as well as other relevant guidance memos that were not 

designated in one of those categories. For guidance memos that were 

released in multiple versions, we considered each version to be a 

separate piece of guidance.4

 3 On its public website, USDA reports annual school lunch participation based on fiscal 

year rather than school year.

We categorized the guidance memos by 

their primary topic and analyzed their content to determine whether they 

clarified regulations, provided new flexibilities related to requirements 

included in federal regulations, or substantively changed previouslyissued guidance. We also assessed the number of pages included in 

each document, defined as the number of digital pages for each guidance 

4 USDA issued several policy memos with multiple versions during the time period 

assessed. For example, USDA issued seven versions of a key policy memo addressing 

the lunch content and nutrition requirements during this time period. Each version of this 

policy memo made substantial additions to the version previously issued, with the versions 

increasing in length from 11 to 64 pages.

Guidance Documents
Appendix I: Scope and Methodology

Page 55 GAO-14-104 School Lunch

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 obtain information on state efforts related to implementation of the new 

school lunch content and nutrition requirements, we conducted a national 

survey of state child nutrition directors who oversee the National School 

Lunch Program in the 50 states and the District of Columbia.5

Because separate agencies oversee the administration of the National 

School Lunch Program in public and private schools in five states, we 

surveyed both agencies in each of these states. These five states are 

Arkansas, Colorado, Georgia, Oklahoma, and Virginia. In two of these 

states, separate state agencies oversee public and private schools 

administering the program, while in the remaining three, private schools 

administering the program are overseen by the relevant FNS regional 

office. For these five states, when analyzing survey results for questions 

with numerical responses, we combined the answers from entities 

overseeing both public and private schools in order to represent the state 

as a whole. For all other questions, such as those concerning SFA 

challenges with the lunch requirements, we reported responses from the 

agency overseeing the program in public schools because those 

agencies represented the majority of schools with the program in these 

states.

We 

administered our Web-based survey between June and July 2013, and all 

state directors responded. The survey included questions about SFA 

challenges with the new lunch requirements, state use of administrative 

funds, and USDA assistance to states. The survey also requested data 

on SFAs and schools participating in the program, SFAs that left the 

program in school year 2012-2013, and state certification and validation 

of SFAs in compliance with the new requirements.

Because this was not a sample survey, there are no sampling errors. 

However, the practical difficulties of conducting any survey may introduce 

nonsampling errors, such as variations in how respondents interpret 

 5 Although the National School Lunch Program is also provided in schools in Guam, 

Puerto Rico, the U.S. Virgin Islands, and the U.S. Department of Defense’s military bases 

overseas, we did not survey child nutrition program directors overseeing the program in 

those schools.

Survey of States
Appendix I: Scope and Methodology

Page 56 GAO-14-104 School Lunch

questions and their willingness to offer accurate responses. We took 

steps to minimize nonsampling errors, including pretesting draft 

instruments and using a Web-based administration system. Specifically, 

during survey development, we pretested draft instruments with child 

nutrition directors from three states (Louisiana, Texas, and Virginia) in 

May 2013. We selected the pretest states to provide variation in state 

school lunch program characteristics and geographic location. In the 

pretests, we were generally interested in the clarity, precision, and 

objectivity of the questions, as well as the flow and layout of the survey. 

For example, we wanted to ensure definitions used in the surveys were 

clear and known to the respondents, categories provided in closed-ended 

questions were complete and exclusive, and the ordering of survey 

sections and the questions within each section were appropriate. We 

revised the final survey based on pretest results. Another step we took to 

minimize nonsampling errors was using a Web-based survey. Allowing 

respondents to enter their responses directly into an electronic instrument 

created a record for each respondent in a data file and eliminated the 

need for and the errors associated with a manual data entry process. To 

further minimize errors, programs used to analyze the survey data were 

independently verified to ensure the accuracy of this work.

While we did not fully validate specific information that states reported 

through our survey, we took several steps to ensure that the information 

was sufficiently reliable for the purposes of this report. For example, we 

reviewed the responses and identified those that required further 

clarification and, subsequently, solicited follow-up information from those 

respondents via email and phone to ensure the information they provided 

was reasonable and reliable. In our review of the data, we also identified 

and logically fixed skip pattern errors for questions that respondents 

should have skipped but did not. On the basis of these checks, we 

believe our survey data are sufficiently reliable for the purposes of our 

work.

To gather information from the local level on implementation of the new 

lunch content and nutrition requirements, we conducted site visits to eight 

school districts across the country between March and May 2013. The 

school districts we visited were: Caddo Parish Public Schools (LA), 

Carlisle Area School District (PA), Chicago Public Schools (IL), Coeur 

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

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

and Spokane Public Schools (WA). We selected these school districts 

because they provided variation across geographic location, district size, 

Site Visits
Appendix I: Scope and Methodology

Page 57 GAO-14-104 School Lunch

and certain characteristics of the student population and district food 

services. For example, the proportion of students eligible for free and 

reduced-price lunches and the racial and ethnic characteristics of the 

student population varied across the districts selected. Further, we 

selected districts with different food service approaches, including some 

that generally prepared school lunches in one central kitchen before 

delivering them to schools, some that prepared lunches in kitchens onsite in each school, and others that used alternative approaches for lunch 

preparation. Seven of the school districts we visited managed their own 

food service operations, while one district contracted with food service 

management companies. We relied on the U.S. Department of 

Education’s Common Core of Data, which provides information on public 

schools,6

In each district, to gather information on local level implementation of the 

new lunch requirements, we interviewed the SFA director, as well as 

other key district-level SFA staff and food service staff in at least two 

schools. During these interviews, we collected information about lunch 

participation trends; challenges, if any, implementing the new lunch 

requirements; and USDA and state assistance with the changes. To 

select the schools we visited in each district, we worked with the SFA 

director to ensure the schools included students of differing grade levels 

in order to capture any relevant differences in their reactions to the new 

lunch requirements. In each school, we observed lunch—including 

students’ food selections, consumption, and plate waste—and, when 

feasible, interviewed students and school staff to obtain their thoughts on 

the lunch changes. We also interviewed the eight state child nutrition 

program directors overseeing these districts to gather information on 

statewide lunch participation trends; SFA challenges, if any; and USDA 

and state assistance with implementation of the changes. Following the 

site visits, in late summer 2013, we obtained school lunch participation 

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.

 6 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.
Appendix I: Scope and Methodology

Page 58 GAO-14-104 School Lunch

data for school years 2008-2009 through 2012-2013 and information 

about school year 2012-2013 finances from the eight SFA directors. We 

cannot generalize our findings from the site visits beyond the school 

districts we visited.7

 7 We reported on our preliminary findings from these site visits in GAO, School Lunch: 

Modifications Needed to Some of the New Nutrition Standards, GAO-13-708T

(Washington, D.C.: June 27, 2013).
Appendix II: Federal Requirements for the 

Content of School Lunches

Page 59 GAO-14-104 School Lunch

Under the previous federal requirements for the content of school 

lunches, SFAs could choose to use one of five approved approaches to 

plan their menus. Three of these approaches focused on nutrient 

requirements and, aside from milk, did not specify food components or 

portion size requirements. Under the two remaining approaches, 

Traditional and Enhanced Food-Based Menu Planning, schools had to 

comply with specific food component and portion size requirements, as 

well as nutrient requirements. See tables 1 through 4 for details of the 

previous Food-Based Menu Planning approaches.

Table 1: Traditional Food-Based Menu Planning Approach Requirements

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

 Minimum quantities

Recommended 

quantities

Food components and food 

items

Group I

Ages 1-2 

Preschool

Group II

Ages 3-4 

Preschool

Group III

Ages 5-8 

Grades K-3

Group IV

Ages 9 and 

older 

Grades 4-12

Group V

Ages 12 and 

older

Grades

7-12

Milk (as a beverage) 6 fluid ounces 6 fluid ounces 8 fluid ounces 8 fluid ounces 8 fluid ounces 

Meat or Meat Alternate (quantity of 

the edible portion as served):

Lean meat, poultry, or fish 1 ounce 11⁄2 ounces 11⁄2 ounces 2 ounces 3 ounces

Alternate Protein Products 1 ounce a 11⁄2 ounces 11⁄2 ounces 2 ounces 3 ounces

Cheese 1 ounce 11⁄2 ounces 11⁄2 ounces 2 ounces 3 ounces

Large egg 1⁄2 3⁄4 3⁄4 1 11⁄2

Cooked dry beans or peas 1⁄4 cup 3/8 cup 3/8 cup 1⁄2 cup 3⁄4 cup

Peanut butter or other nut or 

seed butters

2 tablespoons 3 tablespoons 3 tablespoons 4 tablespoons 6 tablespoons

Yogurt, plain or flavored, 

unsweetened or sweetened

4 ounces or

1⁄2 cup

6 ounces or 

3⁄4 cup

6 ounces or 

3⁄4 cup

8 ounces or 

1 cup

12 ounces or 

11⁄2 cups

The following may be used to 

meet no more than 50% of the 

requirement and must be used 

in combination with any of the 

above:

Peanuts, soynuts, tree nuts, or 

seeds, as listed in program 

guidance, or an equivalent 

quantity of any combination of 

the above meat/meat alternate 

(1 ounce of nuts/seeds=1 

ounce of cooked lean meat, 

poultry, or fish)

1⁄2 ounce=50% 3⁄4 ounce=50% 3⁄4 ounce=50% 1 ounce=50% 11⁄2 ounces=50%

Appendix II: Federal Requirements for the 

Content of School Lunches

Previous Requirements
Appendix II: Federal Requirements for the 

Content of School Lunches

Page 60 GAO-14-104 School Lunch

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

 Minimum quantities

Recommended 

quantities

Food components and food 

items

Group I

Ages 1-2 

Preschool

Group II

Ages 3-4 

Preschool

Group III

Ages 5-8 

Grades K-3

Group IV

Ages 9 and 

older 

Grades 4-12

Group V

Ages 12 and 

older

Grades

7-12

Vegetable or Fruit: 2 or more 

servings of vegetables, fruits or 

both

1⁄2 cup 1⁄2 cup 1⁄2 cup 3⁄4 cup 3⁄4 cup

Grains/Breads: (servings per 

week): Must be enriched or whole 

grain. A serving is a slice of bread 

or an equivalent serving of biscuits, 

rolls, etc., or 1⁄2 cup of cooked rice, 

macaroni, noodles, other pasta 

products or cereal grains

5 servings per 

weekb

minimum of 1⁄2 

serving per day

—

8 servings per 

weekb

minimum of 1 

serving per day 

—

8 servings per 

weekb

minimum of 1 

serving per day 

—

8 servings per 

weekb

minimum of 1 

serving per day 

—

10 servings per 

weekb

minimum of 1 

serving per day 

—

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

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

b For the purposes of this table, a week equals five days.

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

Minimum Nutrient and Calorie Levels for School Lunches

Traditional Food-Based Menu Planning Approach (School Week Averages)

 Minimum requirements Recommended 

Nutrients and Energy 

Allowances

Group II

Preschool

Ages 3-4 

Group III

Grades K-3

Ages 5-8 

Group IV

Grades 4-12

Ages 9 and older

Group V

Grades 7-12

Ages 12 and older

Energy allowances 

(calories)

517 633 785 825

Total fat (as a 

percentage of actual 

total food energy)

a a,b b

Saturated fat (as a 

percentage of actual 

total food energy)

b

a a,c c

RDA for protein (g)

c

7 9 15 16

RDA for calcium (mg) 267 267 370 400

RDA for iron (mg) 3.3 3.3 4.2 4.5

RDA for Vitamin A (RE) 150 200 285 300

RDA for Vitamin C (mg) 14 15 17 18
Appendix II: Federal Requirements for the 

Content of School Lunches

Page 61 GAO-14-104 School Lunch

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

a The Dietary Guidelines recommend that after 2 years of age “...children should gradually adopt at 

diet that, by about 5 years of age, contains no more than 30 percent of calories from fat.”

b Not to exceed 30 percent over a school week

c Less than 10 percent over a school week

Table 3: Enhanced Food-Based Menu Planning Approach Requirements

Enhanced Food-Based Menu Planning Approach-Meal Pattern for Lunches

 Minimum requirements Option for

Food Components and

Food Items Ages 1-2 Preschool Grades K-6 Grades 7-12 Grades K-3

Milk (as a beverage) 6 fluid ounces 6 fluid ounces 8 fluid ounces 8 fluid ounces 8 fluid ounces

Meat or Meat Alternate (quantity of the edible portion 

as served):

Lean meat, poultry, or fish 1 ounce 11⁄2 ounces 2 ounces 2 ounces 11⁄2 ounces

Alternate protein products 1 ounce a 11⁄2 ounces 2 ounces 2 ounces 11⁄2 ounces

Cheese 1 ounce 11⁄2 ounces 2 ounces 2 ounces 11⁄2 ounces

Large egg 1⁄2 3⁄4 1 1 3⁄4

Cooked dry beans or peas 1⁄4 cup 3/8 cup 1⁄2 cup 1⁄2 cup 3/8 cup

Peanut butter or other nut or seed butters 2 tablespoons 3 tablespoons 4 tablespoons 4 tablespoons 3 tablespoons

Yogurt, plain or flavored, unsweetened or 

sweetened

4 ounces or

1⁄2 cup

6 ounces or 

3⁄4 cup 

8 ounces or 

1 cup

8 ounces or 

1 cup

6 ounces or 

3⁄4 cup

The following may be used to meet no more than 

50% of the requirement and must be used in 

combination with any of the above:

Peanuts, soy nuts, tree nuts, or seeds, as listed 

in program guidance, or an equivalent quantity of 

any combination of the above meat/meat 

alternate (1 ounce of nuts/seeds equals 1 ounce 

of cooked lean meat, poultry or fish).

1⁄2 ounce

=50%

3⁄4 ounce

=50%

1 ounce

=50%

1 ounce

=50%

3⁄4 ounce

=50%

Vegetable or Fruit: 2 or more servings of vegetables, 

fruits or both

1⁄2 cup 1⁄2 cup 3⁄4 cup plus an 

extra 1⁄2 cup 

over a week

1 cup 

b

3⁄4 cup

Grains/Breads (servings per week): Must be enriched 

or whole grain. A serving is a slice of bread or an 

equivalent serving of biscuits, rolls, etc., or 1⁄2 cup of 

cooked rice, macaroni, noodles, other pasta products 

or cereal grains

5 servings per 

weekb 

minimum of 1⁄2 

serving per 

day 

–

8 servings per 

weekb

minimum of 1 

serving per 

day 

–

12 servings 

per weekb 

minimum of 1 

serving per 

day

–

15 servings 

per week

c

b

minimum of 1 

serving per 

day

–

10 servings 

per week

c

b

minimum of 1 

serving per 

day

–

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

c

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

b For the purposes of this table, a week equals five days.

c Up to one grains/breads serving per day may be a dessert.
Appendix II: Federal Requirements for the 

Content of School Lunches

Page 62 GAO-14-104 School Lunch

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

Minimum Nutrient and Calorie Levels for School Lunches

Enhanced Food-Based Menu Planning Approach (School Week Averages) 

 Minimum requirements Optional

Nutrients and Energy Allowances Preschool Grades K-6 Grades 7-12 Grades K-3

Energy allowances (calories) 517 664 825 633

Total fat (as a percentage of actual total 

food energy)

a a,b b

Saturated fat (as a percentage of actual 

total food energy)

a,b

a a,c c

RDA for protein (g)

a,c

7 10 16 9

RDA for calcium (mg) 267 286 400 267

RDA for iron (mg) 3.3 3.5 4.5 3.3

RDA for Vitamin A (RE) 150 224 300 200

RDA for Vitamin C (mg) 14 15 18 15

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

a The Dietary Guidelines recommend that after 2 years of age “...children should gradually adopt at 

diet that, by about 5 years of age, contains no more than 30 percent of calories from fat.”

b Not to exceed 30 percent over a school week

c Less than 10 percent over a school week

Following passage of the Healthy, Hunger-Free Kids Act of 2010, USDA 

updated federal requirements for the content of school lunches and 

required all SFAs to use the same approach for planning lunch menus—

Food-Based Menu Planning. In the January 2012 final rule on these 

changes, USDA noted that over 70 percent of program operators were 

already using the Food-Based Menu Planning approach to plan their 

lunch menus. See table 5 for details of the current lunch content and 

nutrition requirements.

Current Requirements
Appendix II: Federal Requirements for the 

Content of School Lunches

Page 63 GAO-14-104 School Lunch

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

Meal pattern

Lunch Meal Pattern

Grades K-5 Grades 6-8 Grades 9-12

Amount of fooda

(minimum per day)

per week

Fruits (cups) 2 1/2 ( 1/2) b 2 1/2 ( 1/2) 5 (1)

Vegetables (cups) 3 3/4 ( 3/4) b 3 3/4 ( 3/4) 5 (1)

Dark green 1⁄2 c 1⁄2 1⁄2

Red/Orange 3⁄4 c 3⁄4 1 1⁄4

Beans and peas (legumes) 1⁄2 c 1⁄2 1⁄2

Starchy 1⁄2 c 1⁄2 1⁄2

Other 1⁄2 c,d 1⁄2 3⁄4

Additional Veg to Reach Total 1 e 1 e 1 1/2 e

Grains (oz eq)

e

8-9 (1) f 8-10 (1) 10-12 (2)

Meats/Meat Alternates (oz eq) 8-10 (1) 9-10 (1) 10-12 (2)

Fluid milk (cups) 5 (1) g 5 (1) 5 (1)

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

Min-max calories (kcal) 550-650 h 600-700 750-850

Saturated fat (% of total calories) < 10 h < 10 < 10

Sodium (mg) ≤ 640 h,i ≤ 710 ≤ 740

Transfat Nutrition label or manufacturer specifications must indicate zero grams of trans fat

per serving.

h

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

Fed. Reg. 4088 (Jan. 26, 2012).

a Food items included in each group and subgroup and amount equivalents. Minimum creditable 

serving is 1/8 cup.

b One quarter-cup of dried fruit counts as 1/2 cup of fruit; 1 cup of leafy greens counts as 1/2 cup of vegetables. No more than half of the fruit or vegetable offerings may be in the form of juice. All juice 

must be 100% full-strength.

c Larger amounts of these vegetables may be served.

d This category consists of “Other vegetables” as defined in 7 C.F.R. § 210.10(c)(2)(iii)(E). For the purposes of the National School Lunch Program, the “Other vegetables” requirement may be met with 

any additional amounts from the dark green, red/orange, and beans/peas (legumes) vegetable subgroups as defined in 7 C.F.R. § 210.10(c)(2)(iii). e Any vegetable subgroup may be offered to meet the total weekly vegetable requirement.

f

Beginning July 1, 2012 (SY 2012-2013), at least half of grains offered must be whole grain-rich. 

Beginning July 1, 2014 (SY 2014-15), all grains must be whole grain-rich. g

Beginning July 1, 2012 (SY 2012-2013), all fluid milk must be low-fat (1 percent or less, unflavored) or fat-free (unflavored or flavored). h Discretionary sources of calories (solid fats and added sugars) may be added to the meal pattern if 

within the specifications for calories, saturated fat, transfat, and sodium. Foods of minimal nutritional 

value and fluid milk with fat content greater than 1 percent are not allowed. i

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

Acknowledgments

Page 64 GAO-14-104 School Lunch

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

In addition to the contact named above, Rachel Frisk and Kathy Larin 

(Assistant Directors), Robert Campbell, Jean McSween, Dan Meyer, 

Christine San, and Zachary Sivo made key contributions to this report. 

Also contributing to this report were James Bennett, Nora Boretti, Jessica 

Botsford, Sheila McCoy, Paul Schearf, and Almeta Spencer.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 65 GAO-14-104 School Lunch

School Lunch: Modifications Needed to Some of the New Nutrition 

Standards. GAO-13-708T. Washington, D.C.: June 27, 2013.

School Meal Programs: More Systematic Development of Specifications 

Could Improve the Safety of Foods Purchased through USDA’s 

Commodity Program. GAO-11-376. Washington, D.C.: May 3, 2011.

School Meal Programs: Improved Reviews, Federal Guidance, and Data 

Collection Needed to Address Counting and Claiming Errors.

GAO-09-814. Washington, D.C.: September 9, 2009.

School Meal Programs: Changes to Federal Agencies’ Procedures Could 

Reduce Risk of School Children Consuming Recalled Food. GAO-09-649. 

Washington, D.C.: August 20, 2009.

School Meal Programs: Experiences of the States and Districts That 

Eliminated Reduced-price Fees. GAO-09-584. Washington, D.C.: July 17, 

2009.

Meal Counting and Claiming by Food Service Management Companies in 

the School Meal Programs. GAO-09-156R. Washington, D.C.: January 

30, 2009.

School Meals Programs: Competitive Foods Are Widely Available and 

Generate Substantial Revenues for Schools. GAO-05-563. Washington, 

D.C.: August 8, 2005.

Nutrition Education: USDA Provides Services through Multiple Programs, 

but Stronger Linkages among Efforts Are Needed. GAO-04-528. 

Washington, D.C.: April 27, 2004.

School Meals Programs: Competitive Foods Are Available in Many 

Schools; Actions Taken to Restrict Them Differ by State and Locality.

GAO-04-673. Washington, D.C.: April 23, 2004.

School Lunch Program: Efforts Needed to Improve Nutrition and 

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

Related GAO Products

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