Joanne F. Guthrie, Constance Newman, Katherine Ralston, 

Mark Prell, and Michael Ollinger

Nutrition Standards for 

Competitive Foods in Schools

Implications for Foodservice Revenues

Economic

Research

Service

Economic 

Information

Bulletin

Number 114

June 2013

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Guthrie, Joanne F., Constance Newman, Katherine Ralston, Mark Prell, and 

Michael Ollinger. Nutrition Standards for Competitive Foods in Schools: 

Implications for Foodservice Revenues, EIB-114. U.S. Department of Agriculture, 

Economic Research Service, June 2013.

Cover photo credit: USDA.
United States Department of Agriculture

Economic 

Research 

Service

Economic

Information

Bulletin

Number 114

June 2013

Abstract

USDA’s National School Lunch and School Breakfast Programs supply most of the foods 

and beverages obtained by children in U.S. schools. Many schools also sell supplemental 

items, often called “competitive foods.” The Healthy, Hunger-Free Kids Act of 2010 

required USDA to set nutritional requirements for competitive foods served by schools 

that also offer USDA school meals, and this could diminish revenue to local school 

foodservices. This report uses data from two national surveys of schools and School 

Food Authorities to examine competitive food selections and their contribution to school 

foodservice revenues. Most competitive foods selected by students in 2005 were of low 

nutritional value. The amount of revenue obtained from these foods varied widely, but 

most foodservices earned less than 12 percent of revenues from competitive foods. School 

foodservices with high competitive food revenues typically were located in more affluent 

districts and served fewer students receiving free and reduced-price lunches. Secondary 

(middle and high) schools received much more revenue from competitive foods than did 

elementary schools. 

Keywords: National School Lunch Program, competitive foods, child nutrition, diet 

quality, school foodservice revenues

Acknowledgments

The authors thank David Smallwood, Jayachandran Variyam and five anonymous 

reviewers for their comments and suggestions. The authors also thank Mary Kay Fox and 

Anne Gordon of Mathematica Policy Research, Inc., for information and advice regarding 

the use of the SNDA III data set; Ephraim Leibtag for coordination of the report review 

and publication process; Dale Simms for editing the manuscript; and Cynthia A. Ray for 

design and layout.

Joanne F. Guthrie, Constance Newman, 

Katherine Ralston, Mark Prell, and Michael Ollinger

Nutrition Standards for 

Competitive Foods in Schools

Implications for Foodservice Revenues
ii

Nutrition Standards for Competitive Foods in Schools: Implications for Foodservice Revenues, EIB-114

Economic Research Service/USDA

Contents

Summary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii

Congress Mandates Update of Nutrition Standards for Competitive Foods. . . . . . . . . . . . . . . . 1

Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Growth of Competitive Foods in U.S. Schools. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Nutritional Impacts of Competitive Foods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

Policy Actions To Improve Competitive Foods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Competitive Food Revenues. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

USDA’s School Nutrition Dietary Assessment Study (SNDA)-III. . . . . . . . . . . . . . . . . . . . . . . . . 5

School Food Authority Characteristics Survey (SFACS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

Methods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Findings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Most Competitive Foods and Beverages Selected by Students Would Not 

Meet Nutrition Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

Secondary-Level Students Consumed More Competitive Foods. . . . . . . . . . . . . . . . . . . . . . . . . . 8

Competitive Food Revenues Vary Across and Within School Grade Levels. . . . . . . . . . . . . . . . . 8

School Profiles: Characteristics by Food Revenue Quartile. . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

School Food Authorities (SFAs) With Higher Shares of Revenue 

From Competitive Foods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

SFA Profiles: Characteristics Associated With Higher Shares of Revenue 

From Competitive Foods. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

Limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

School Environment Changes Since 2005. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Other Limitations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

Making the Transition to Healthier School Food Choices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Offering Healthier Competitive Foods and Beverages. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

Expanding School Meal Participation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

Appendix A—Characteristics Examined In School-Level (SNDA) and 

SFA-Level (SFACS) Analyses. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30

Appendix B—Categorizing Competitive Food Selections by Ability To Meet Criteria 

Based on Institute of Medicine Nutrition Standards. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

Appendix C—Data Tables for Figures 2-6. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43
www.ers.usda.gov

Across America, meals provided through USDA’s National School Lunch Program (NSLP) and 

School Breakfast Program (SBP) supply most of the foods and beverages obtained by children 

at school. Most schools also sell competitive foods, or “à la carte” items, alongside USDA school 

meals, in vending machines, or in school stores and snack bars, with proceeds going to the school 

foodservice or fundraising school groups. These foods have been widely criticized as being of low 

nutritional value, undercutting public efforts to improve children’s diets and prevent obesity. The 

Healthy, Hunger-Free Kids Act of 2010 requires schools that offer USDA school meals to limit 

competitive foods to those that meet updated nutrition standards, under development by USDA’s 

Food and Nutrition Service (FNS).

What Is the Issue?

Limiting the types of competitive foods available for sale may result in lost revenue for school 

foodservices, which depend to varying degrees on this revenue stream. Because USDA school meal 

programs are a part of the Nation’s nutrition safety net, the contribution that competitive food revenues make to foodservices serving economically vulnerable student populations is of particular 

interest. This report examines how updated nutrition standards for competitive foods might affect 

competitive food availability, and the implications for foodservice revenues. 

What Are the Findings?

Desserts, sweetened beverages, salty snacks, and candy made up more than half of competitive 

items selected by elementary and secondary school students in 2005. Most (80-90 percent) of the 

competitive food and beverage items selected by students would not fully meet updated nutrition 

standards, which would shift purchases from items high in fat, saturated fat, sugars, and sodium to 

foods featuring whole grains, low-fat dairy, fruits, and vegetables. 

One-third of elementary students consumed at least one competitive food on a typical school day 

in 2005, whereas 53 percent of secondary students did. Secondary students also consumed more 

competitive items than did elementary students. Average annual competitive revenues for elementary schools were about one-sixth those of middle schools and one-ninth those of high schools. At 

both the elementary and secondary school levels, school foodservices in more affluent districts 

obtained more revenues from competitive foods on a per-student basis. 

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Joanne F. Guthrie, Constance Newman, Katherine Ralston, 

Mark Prell, and Michael Ollinger

Nutrition Standards for 

Competitive Foods in Schools

Implications for Foodservice Revenues

Economic 

Research 

Service

Economic 

Information 

Bulletin 

Number 114

June 2013

United States Department of Agriculture

Joanne F. Guthrie, Constance Newman, Katherine Ralston, 

Mark Prell, and Michael Ollinger

Nutrition Standards for Competitive 

Foods in Schools: Implications for 

Foodservice Revenues
School Food Authorities (SFAs), the foodservice management units for school districts, reported obtaining, on 

average, 12 percent of revenues from competitive foods in 2002-2003, a period in which there were few nutritional 

restrictions on competitive foods. Ten percent of SFAs received 36 percent or more of their revenues from competitive foods, which was attributable both to higher competitive food revenues and lower revenues from USDA school 

meals. SFAs with higher shares of competitive food revenue typically were located in more affluent districts and 

served fewer low-income students receiving free and reduced-price meals than did schools with low competitive 

food revenues. They also were more common in suburban, rather than urban or rural, districts and in the Northeast, 

Mid-Atlantic, and Midwest.

Establishing nutrition standards for foods sold at school in competition with the USDA meals should provide nutritional benefits, especially to secondary-school students and in the typically suburban, more affluent SFAs that obtain 

large shares of revenue from competitive foods and have low school meal participation. There may be additional 

benefits to lowering the profile of competitive foods in schools. Eliminating less nutritious competitive foods may 

also support efforts to improve the quality of USDA school meals. One study found NSLP lunches to be lower in 

fat in schools with no à la carte and vending. In the competition for student food spending, the absence of unhealthy 

alternatives may leave school foodservices more free to offer healthier meals that meet Federal nutrition standards. 

For school foodservices concerned about covering their expenses, the challenge will be to adapt to new standards 

and develop new strategies for maintaining revenues in a healthier school nutrition environment. The challenge is 

most pronounced in SFAs receiving a large proportion of revenues from competitive foods. Higher school foodservice revenues from competitive foods were associated with lower USDA lunch participation, suggesting that 

competitive food revenues may displace meal participation and associated revenue. In SFAs where competitive food 

revenues make up a larger share of overall revenues, foodservice managers may be apprehensive about nutritionmandated changes in offerings. Such SFAs will be especially interested in strategies for maintaining revenues when 

nutrition standards for competitive foods are implemented.

To offset revenue losses from removal of competitive foods that fail to meet nutrition standards, school foodservices 

can (1) seek out healthier competitive food options to replace those currently sold, or (2) re-emphasize their “core 

business” by expanding participation in school meals. For both strategies, appropriate pricing is key. The Healthy, 

Hunger-Free Kids Act of 2010 addressed pricing of meals and competitive foods, and new regulations based on this act 

may have important effects on revenues obtained both from USDA school meals and from healthier competitive foods.

How Was the Study Conducted?

This study made use of two national surveys conducted on behalf of FNS. Nationally representative school- and 

student-level data collected in 2004-05 were obtained from the School Nutrition Dietary Assessment III (SNDA-III), 

whereas the School Food Authority Characteristics Study (SFACS) provided school foodservice revenue and other 

data at the school district level from 2002-03. The SFACS sample was designed to generate national and regionally 

representative estimates, and although now a decade old, is still the most recent source for such data. At both the 

school and the SFA level, we examine the association of school foodservice competitive revenues with (1) the socioeconomic environment in which schools and SFAs operate; (2) school meal program characteristics like the average 

price charged for a full-price lunch; and (3) State and local characteristics that influence the school environment in 

which the foodservice operates. 

www.ers.usda.gov
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Nutrition Standards for Competitive Foods in Schools: Implications for Foodservice Revenues, EIB-114

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Nutrition Standards for 

Competitive Foods in Schools

Implications for Foodservice Revenues

Joanne F. Guthrie, Constance Newman, 

Katherine Ralston, Mark Prell, and Michael Ollinger

Congress Mandates Update of Nutrition Standards for 

Competitive Foods

Across America, lunches and breakfasts provided through USDA’s National School Lunch Program 

(NSLP) and School Breakfast Program (SBP) supply most of the foods and beverages obtained by 

children at school. The majority of schools also sell “competitive foods,” a general term for foods 

and beverages sold in schools and that are not part of USDA school meals. They are most commonly 

sold in the cafeteria alongside USDA school meals, where they are known as “à la carte” items. They 

are also frequently sold in vending machines and less frequently in other locations such as school 

stores and snack bars, with profits sometimes going to the school foodservice or more often to other 

school groups. Competitive foods are consumed by 40 percent of public school students on a typical 

day (Fox et al., 2009).

USDA school meals are required to meet nutrition standards. These standards were recently 

updated, as part of the Healthy, Hunger-Free Kids Act of 2010 (USDA, 2011), to conform to the most 

up-to-date nutrition guidance and to address concerns about childhood obesity. Meals now include 

more whole fruit, dark green and red/orange vegetables, and whole grains.

While USDA meals are held to nutrition standards, the nutritional content of competitive foods 

is minimally regulated. As concerns about child nutrition and obesity have risen, the nutritional 

content of competitive foods has become an issue (Kids Safe & Healthful Foods Project, 2012a). 

Most of the competitive foods and beverages favored by children are “low-nutrient, energy-dense” 

(LNED) foods, which are high in fat, sugars, or sodium, and deficient in the fruits, vegetables, whole 

grains, fiber, and nutrients that are underconsumed by U.S. children (USDHHS and USDA, 2011). 

Section 208 of the Healthy, Hunger-Free Kids Act of 2010 requires USDA to align nutrition standards for competitive foods with the Dietary Guidelines for Americans. These standards must be 

met by all competitive foods sold at school at any time during the school day (with special exemptions for occasional school-sponsored fundraisers such as bake sales). USDA’s Food and Nutrition 

Service (FNS) published in February 2013 a proposed rule (USDA, FNS, 2013) of nutrition standards based on those developed by the Institute of Medicine (IOM, 2007), allowing 60 days for 

comment. After the final rule is published, schools will be given 1 year to implement the regulations. 

Updated nutrition standards for competitive foods would shift schoolchildren’s purchases from foods 

and beverages high in overconsumed food components such as fat, saturated fat, sugars, and sodium 
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to foods lower in these components and featuring whole grains, lowfat dairy, fruits, and vegetables. 

Implementing these standards may affect the revenues and costs of school foodservices. 

Views on the financial effects of competitive food standards differ. Some maintain that more 

stringent standards for competitive food could jeopardize the financial viability of school foodservices (Rinaldi, 2008; Greves and Rivara, 2006). School foodservices that participate in USDA 

meal programs are required to be nonprofit; however, many localities expect them to cover their 

operational costs. This requires a delicate balancing of revenues and costs, and for a large share of 

schools, revenues fall short of costs (USDA, FNS, 2008). School foodservices must balance nutrition, student participation, and meal cost to achieve nutrition and food security goals while covering 

operational costs (Ralston et al., 2008). Some school foodservices contend that the sale of competitive foods is necessary to maintain financial solvency (U.S. GAO, 2005). Poppendieck (2010) quotes 

one school foodservice director as saying, “We need to sell à la carte to be financially sound.” 

In contrast, others question whether competitive food revenues actually improve the net financial 

status of school foodservices because competitive foods entail their own expenses and can reduce 

NSLP meal participation and the associated revenues (Peterson, 2011). Several school foodservices 

have reduced or discontinued competitive foods while simultaneously promoting NSLP meal participation, with one director saying “I recommend elimination of à la carte for anyone who wants to see 

their program grow—both in participation and revenue” (Kavanaugh, 2010).

The effect of competitive food standards on a school foodservice’s finances can depend, in part, on 

what steps the school foodservice takes to adapt to healthier competitive offerings and/or promote 

the NSLP meal. Student responses to healthier competitive foods—that is, whether they continue to 

buy competitive items, shift to the NSLP meal, or bring food from home or other outside sources—

may vary depending on age, their household economic conditions, or other factors. 

This report examines how updated nutrition standards for competitive foods might affect 

competitive food availability, and the implications for foodservice revenues. It uses nationally 

representative data on school food offerings, student selections, and foodservice revenues to estimate 

the percentage of competitive food items that would or would not meet nutrition standards. It 

examines student and school characteristics associated with higher school foodservice revenues from 

competitive foods.

School-level foodservices are part of a School Food Authority (SFA), usually a district-level unit 

that oversees foodservice operations and manages the overall foodservice budget, consolidating 

revenues and submitting claims for meal reimbursements to USDA. Using a national survey of 

SFAs, this report examines the contribution of competitive food revenues to the SFA as a share of 

SFA total revenues and how those shares relate to SFA characteristics. Results should be useful to 

program and policy officials at Federal, State, and local levels as they implement nutrition standards 

governing competitive foods, allowing them to target and guide school foodservices that are likely to 

be most in need of assistance.
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Background

Growth of Competitive Foods in U.S. Schools

Since the beginning of the National School Lunch Program (NSLP) in 1946, snacks and other food 

items have been sold in many schools (Poppendieck, 2010). At first, the nutritional content of these 

foods was viewed as purely a local issue. Concern about their nutritional quality and detrimental 

effects on school meal consumption led to efforts to regulate sales of competitive foods at the 

Federal level (Poppendieck, 2010; USDA, 2001; U.S. GAO, 2005).

In 1977, the Child Nutrition Act was amended to empower USDA to limit sales of foods that competed 

with USDA school meals. From 1980 to 1983, USDA regulated the sale of foods sold anywhere in 

school until after the last meal period. This blanket prohibition was challenged, and in National Soft 

Drink Association vs. Block (1983), the Court of Appeals for the District of Columbia ruled that 

USDA’s power should be limited to regulation of competitive foods sold in the area where USDA meals 

were being served during mealtimes (U.S. GAO, 2005). Current USDA regulations prohibit sale of 

“foods of minimal nutritional value” in the foodservice area during meal periods. These prohibited 

items are narrowly defined (CFR, 2011) and include sugary items such as soft drinks, chewing gum, 

sugary candies like marshmallows, and popsicles. Under this regulation, many high-energy-density 

snacks and sweets such as fried chips, cakes, and chocolate candy are still allowed.

In 2005, à la carte items were offered in the cafeteria at lunch in 92 percent of secondary schools, 

compared to 76 percent of elementary schools.1 When excluding the schools that offered only milk 

as an à la carte item, the share of elementary schools with à la carte offerings fell to 32 percent. 

Competitive food offerings were more varied in secondary schools. More than half of secondary 

schools offered à la carte entrees, making it easy to substitute competitive foods for the NSLP meal. 

Vending was relatively uncommon in elementary schools (27 percent of schools) and ubiquitous in 

secondary schools (87 percent of middle schools; 98 percent of high schools (USDA, 2007a)).

Availability of specific competitive food items varied from school to school. In 2005, about as many 

schools offered juice and water as sugary or caffeine-containing beverages (USDA, 2007a). Fresh 

fruit was the most widely available healthy choice among à la carte items, obtainable in approximately 40 percent of secondary schools, whereas cookies and chips were available in more than half 

of them. Ice cream and cake-type desserts were also obtainable in one-third or more of secondary 

schools (USDA, 2007a).

Nutritional Impacts of Competitive Foods

Competitive foods could have negative effects on children’s diets either by substituting for a healthier 

lunch, reducing diet quality, or contributing excess calories above the standard lunch. Using nationally representative data from the 2004-05 school year, collected as part of USDA’s School Nutrition 

Dietary Assessment III (SNDA-III), Fox et al. (2009) report that students who ate competitive foods 

1USDA recently released findings from its School Nutrition Dietary Assessment IV (SNDA-IV), including updated 

information on competitive food offerings in school year 2009-10. Because SNDA-IV did not have data on student food 

selections, we did not update our analysis. However, we consider how findings from SNDA-IV add to the interpretation of 

our findings. 
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obtained an average of 277 calories per day from those foods. Low-nutrient, energy-dense (LNED) 

foods and beverages contributed 177—or 64 percent—of those calories. 

Among children who did not eat the NSLP lunch, 45 percent ate competitive foods. Of those who ate 

the NSLP lunch, 36 percent also ate competitive foods, which may crowd out some lunch items if, 

for example, children eat chips or candy instead of the vegetables or fruit provided as side items with 

the meal. Marlette et al. (2005) found that students who purchased competitive foods along with the 

school lunch ate significantly less of their fruit and several other foods, compared to students who 

only bought lunch. If children do eat the complete lunch, the extra calories from LNED competitive 

foods may contribute to obesity, although the link is not definitive (Taber et al., 2012; Van Hook and 

Altman, 2012: Datar and Nicosia, 2012; Anderson and Butcher, 2006). 

Policy Actions To Improve Competitive Foods

As part of the Child Nutrition and WIC Reauthorization Act of 2004 (P.L. 108-265), Congress 

required that school districts participating in the NSLP develop wellness policies that addressed the 

nutritional quality of all foods available in schools, not just USDA meals (USDA, 2005). However, 

the content of the wellness policies was left to local discretion—schools could restrict less nutritious 

competitive foods or not. Similarly, there were no requirements to assess compliance with any policies established.2

Competitive Food Revenues

On average across the country, revenues from competitive foods are far smaller than those from 

USDA-funded school meals. Nationwide, approximately 75 percent of school foodservice revenues 

were obtained from USDA subsidies and student payments for USDA meals in 2005 and 9 percent 

came from State and local funding, according to USDA’s School Lunch and Breakfast Cost Study 

II (USDA, 2008). The remaining 16 percent came from miscellaneous revenue, which included à la 

carte sales in the cafeteria, any vending machines revenues, and all other miscellaneous revenues, 

such as meals sold to adults, catering, etc.

Competitive food sales vary considerably among schools. Approximately one-quarter of elementary 

schools sold no competitive foods in 2005 (Fox et al., 2009). Only 3 percent of middle schools had no 

competitive foods, and virtually all high schools offered them. Competitive foods have been reported 

to be a large portion of foodservice sales and revenues in some schools. Responding to a small study 

conducted by the U.S. General Accountability Office, one school foodservice director said that his 

district generated nearly half its revenue through competitive food sales (U.S. GAO, 2005).

2The Healthy, Hunger-Free Kids Act of 2010 added requirements for monitoring compliance with local wellness 

policies and making findings publicly available.
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Data 

USDA’s School Nutrition Dietary Assessment Study (SNDA)-III

For student and school-level analyses, we use data from the School Nutrition Dietary Assessment 

Study III (SNDA-III). SNDA-III was conducted by Mathematica Policy Research, Inc. 

(Mathematica), under contract with USDA’s Food and Nutrition Service (FNS). It provides nationally representative data on public schools that participate in the National School Lunch Program and 

the students in grades 1-12 who attend those schools (USDA, 2007c). 

Data were collected from 397 schools and 2,314 students in the spring of 2005. Students identified each food/beverage item they selected and where it was obtained (e.g., cafeteria line, vending 

machine, etc.). Mathematica identified foods and beverages as being from USDA school meals 

or competitive sources (see Fox et al., 2009, for details of the methodology). Data on foodservice 

revenues, meal participation, and related variables were obtained from questionnaires administered 

to school foodservice managers. Information on vending by non-school foodservice entities was 

obtained from questionnaires administered to school principals.

School Food Authority Characteristics Survey (SFACS) 

For the SFA-level analysis, we use data from the School Food Authority Characteristics Survey 

(SFACS), a nationally representative survey of SFAs that collected information on SFA revenues 

and costs for school year 2002-03. The survey was conducted by Abt Associates and Mathematica 

on behalf of USDA’s FNS. It provides the most recent SFA financial data from a sample that can 

generate estimates for each of the seven regions defined by FNS (Northeast, Mid-Atlantic, Midwest, 

Mountain, Southeast, Southwest, and West). A subset of 1,432 SFAs participated in the SNDA-III, 

providing information on student enrollment, SFA revenues, and their sources (such as USDA reimbursements for NSLP/SBP meals, student payments for USDA meals, and student payments for 

competitive foods). The SFACS also contains information on school district enrollment and demographic/wealth characteristics drawn from the National Center for Education Statistics Common 

Core of Data and the U.S. Census Bureau. 
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Methods

To illustrate how implementation of nutrition standards for competitive foods might affect school 

foodservice revenues, we assessed the types of competitive foods and beverages most often selected 

by students in 2005 versus those that would be allowed under more stringent nutrition standards. 

Because updated standards have not been finalized, we examined several options, based on the IOM 

report Nutrition Standards for Foods in School: Leading the Way to Healthier Youth (2007) (see 

box, “Foods and Beverages That Meet IOM ‘Tier 1’ Nutrition Standards”). That report is the most 

widely accepted source of expert guidance on the appropriate nutritional content of competitive 

foods and underlies the nutrition standards proposed by FNS. 

One “competitive foods” option estimated foods eligible for sale applying the IOM Tier 1 standards 

as closely as possible, and the other two were less restrictive, incorporating some alternative options 

proposed for consideration (USDA, FNS, 2013). One allows sale of à la carte items also sold as part 

of the reimbursable meal if they meet IOM-based criteria limiting fat and sugars, and the second 

option allows à la carte sales of any foods that are part of the reimbursable meal. Both options 

allow larger sizes of beverages and a wider range of permissible beverages for sale in high schools, 

including flavored waters, caffeinated beverages and low-calorie beverages such as diet sodas (see 

Appendix B). SNDA-III does not provide the purchase price for each selection; however, by examining the share of selected items that would be purchasable versus disallowed, we can estimate the 

potential effects of competitive food standards on student selections and, ultimately, on revenues. 

Using SNDA-III data, we estimate annual school foodservice competitive food revenues on a perschool basis, and on a per-student, per-school basis to adjust for differences in school size. We include 

à la carte revenues and any income the foodservice authority received from vending machines (in most 

schools, vending revenues go to the school or other non-SFA groups, but there are some in which the 

school foodservice obtained revenue from vending).3 À la carte and vending revenues are converted to 

annual revenues based on a 180-day school year. This annual value is divided by the school’s average 

daily attendance to arrive at per-student estimates.

We examine competitive food revenues from elementary and secondary (middle and high) schools 

separately because of differences in student and school characteristics (USDA, 2007a). Older 

students are expected to have more discretionary funds and freedom with which to purchase foods 

and beverages. For each subgroup of schools, we compare school foodservice competitive food revenues on the basis of (a) the socioeconomic environment in which the school foodservice operates, 

since revenue losses could be of particular concern for school foodservices located in low-income 

districts and/or serving primarily low-income children (Kids Safe & Healthful Foods Project, 

2012a), (b) school meal program characteristics like average price for full-price lunch, and (c) State 

and local (district or school-level) characteristics (e.g., reimbursements to SFAs) that influence the 

school environment (see Appendix A). We categorize schools by revenue quartile in order to create 

profiles of schools with lower and higher revenues from competitive foods. The data are weighted 

using school-level sampling weights to obtain nationally representative estimates (StataCorp., 2011).

3A small number of school foodservices may also have received revenues from school stores and snack bars but these 

revenues were not included because of problems identifying either (a) what share of revenues were received by school 

foodservices; (b) for stores, what share of revenues was attributable to food; or (c) for snack bars, whether school foodservice revenues were not already included in à la carte totals. Revenue attributable to snack bars and school stores was quite 

small compared to à la carte and vending.
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The SFA-level analysis investigates competitive food revenues as a share of SFA revenues. This measure is based 

on annual foodservice revenues for school year 2002-03, as reported by the SFA director. Revenues are categorized 

according to source: “student à la carte” and “other food sales, e.g. vending” are combined and used as our measure 

of SFA competitive food revenues. We categorize SFAs by percentage of revenue obtained from competitive foods 

and examine associated socioeconomic and demographic characteristics, meal program characteristics, and State 

characteristics (see Appendix A).

Foods and Beverages That Meet Institute of Medicine “Tier 1” Nutrition Standards1

Foods Beverages

Tier 1 foods are fruits, vegetables, whole grains, and 

related combination products2 and nonfat/low-fat dairy 

that are limited to 200 calories or less per portion as 

packaged and contain:

• No more than 35 percent of total calories from fat.

• Less than 10 percent of total calories from saturated 

fats.

• Zero trans fat (< 0.5 g per serving).

• 35 percent or less of calories from total sugars, 

except for yogurt with no more than 30 g of total 

sugars, per 8-oz portion as packaged.

• Sodium content of 200 mg or less per portion as 

packaged.

Á la carte entrée items that meet fat and sugar limits as 

listed above and:

• Are National School Lunch Program (NSLP) menu 

items.

• Have a sodium content of 480 mg or less.

• Do not exceed calorie content of comparable NSLP 

entrée items (200-calorie limit does not apply to 

entrees).

Tier 1 beverages are:

• Water without flavoring, additives, or carbonation.

• Low-fat (1-percent milk fat) and nonfat milk (in 

8-oz portions):

◊ Lactose-free and soy beverages are included

◊ Flavored milk with no more than 22 g of total 

sugars per 8-oz portion.

• 100-percent fruit juice in 4-oz portion as packaged 

for elementary/middle school and 8-oz (2 portions) 

for high school.

• Caffeine-free, with the exception of trace amounts of 

naturally occurring caffeine substances.

1The Institute of Medicine Committee also developed a list of “Tier 2” foods and beverages that could be made available to high school 

students after the end of the school day. This list is not considered in this study because the Healthy, Hunger-Free Kids Act addresses foods 

and beverages available during the school day only.

2Combination products must contain a total of one or more servings as packaged of fruit, vegetables, or whole-grain products per portion.
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Findings

Most Competitive Foods and Beverages Selected by Students 

Would Not Meet Nutrition Standards 

Our analysis of School Nutrition Dietary Assessment III (SNDA-III) data found that students’ choices 

were even more skewed toward the less healthy options than were product offerings. The overwhelming majority—80-90 percent—of competitive foods and beverages selected by students in SY 

2004-05 would not meet criteria based on Institute of Medicine (IOM) Tier 1 standards, depending 

on the option examined (table 1). The top five competitive food purchases and their respective shares 

were: (1) desserts (20.3 percent), (2) sodas and fruit drinks/drinkades (19.5 percent), (3) salty snacks 

(12.1 percent), (4) pizza and other entrees (11 percent), and (5) candy (11.1 percent). 

The majority of items did not meet the basic criterion of being primarily one of the major food 

groups such as fruit, vegetables, whole grains, or low-fat/nonfat dairy. A larger share of beverages 

than foods met standards; low-fat milks and bottled waters made up the majority of these beverages. 

In the case of some healthier choices, such as fruit juice, overly large portion sizes were frequently a 

problem. Some generally healthy foods, such as yogurts, did not meet a specific standard such as the 

standard for sugars. More detailed information on how competitive foods and beverages compared 

to criteria based on IOM recommended standards is provided in Appendix B.

Secondary-Level Students Consumed More Competitive Foods

One-third (33 percent) of elementary-level students consumed competitive foods on a typical day, 

whereas more than half (53 percent) of secondary-level students did. Secondary-level students also 

consumed twice as many competitive food items as did elementary-level students—on average, 1.2 

items daily compared to 0.6 item. Both differences were statistically significant (p < 0.001). Thus, 

older students likely will benefit most from improvements in dietary intakes at schools that are associated with establishing nutrition standards for competitive foods.

Competitive Food Revenues Vary Across and Within School 

Grade Levels 

Given that most of the competitive items selected by students are low-nutrient, energy-dense foods, 

final nutrition standards are likely to exclude most of the items heavily purchased by students in 

2005. What are the implications for school foodservice revenues?

We expected to see wide variance in revenues obtained from competitive foods based on students’ 

selection patterns. À la carte items make up the bulk of school foodservice competitive food revenues. Although competitive food sales from vending are common in schools, those revenues are 

more likely to go to non-school foodservice sources, with only 20 percent of school foodservices 

reporting vending revenues, based on SNDA-III data. Non-foodservice revenues from competitive 

foods can go to a range of school-related groups (see box, p. 10). However, these revenues are not the 

focus of this study, except as a local characteristic that may influence the competitive food revenues 

of school foodservices, either by competing for student food dollars or by creating an environment 

wherein foodservices feel obliged to sell more competitive foods.
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Table 1

Competitive food/beverage items selected by students, school year 2004-05

BEVERAGES

Total number 

of items 

selected, SY 

2005 (million)

Percent of 

items meeting 

Option 1 

standards1

Percent of 

items meeting 

Option 2 

standards2

Percent of 

items meeting Option 3 

standards3

Dairy Whole or 2% milk—flavored 23 -0- -0- -0- 

Whole or 2% milk—unflavored 77 -0- -0- -0- 

1% of fat free milk—flavored 126 12.6 12.6 12.6

1% of fat free milk—unflavored 121 98.3 98.3 98.3

Milkshakes and other milk drinks 7 -0- -0- -0- 

Fruit juice 100% fruit juice 164 38.5 55.5 55.5

Sodas, fruit 

drinks Carbonated soda (sweetened) 452 -0- -0- -0- 

Non-caloric soda (diet) 26 -0- 69.2 69.2

Fruit drinks, fruitades 864 -0- -0- -0- 

Bottled water Bottled water 403 93.5 98.0 98.0

Coffee or tea Coffee or tea—unsweetened 42 -0- 50.0 50.0

Coffee or tea—sweetened 152 -0- -0- -0- 

Beverage total 2,457

Percent of all beverages meeting standard 23.4 26.9 26.9

FOODS

Fruit 143 47 47 47

Vegetables French fries and similar products 148 -0- -0- 7.4

All other vegetables 128 31.4 31.4 31.4

Salty snacks Potato chips 225 0.7 0.7 46.2

Popcorn 95 -0- -0- 9.5

Corn, tortilla chips 254 -0- -0- 7.9

Crackers and hard pretzels 257 -0- 0.8 0.8

Breads/Grains All except grain-based salty snacks 243 -0- 2.1 7.8

Entrees Pizza or pizza pockets 217 -0- -0- 7.8

All other entrees 540 1.5 4.1 14.8

Desserts Ice cream, baked items, all others 1,399 -0- 0.1 21.5

Candy Candy 763 -0- -0- 6.7

Other Soup, not a veg or entree item 16 -0- 18.8 18.8

Food total 4,428

Percent of all foods meeting standard 2.6 3.2 16.5

Total competitive food/beverage selections 6,885

Percent of total selections meeting IOM standards 10.0 11.6 20.2

1Standards matched to Institute of Medicine (IOM) standards (see box, p. 7) as closely as possible.

2IOM standards adapted to allow à la carte offerings that were also sold as part of the reimbursable USDA meal and met IOM fat and total 

sugar standards, and to allow a wider range of beverages, i.e. (i) up to 8-oz portion sizes of juice in elementary schools and 12-oz portion 

sizes in middle and high schools; and (ii) in high schools up to 20-oz portion sizes of calorie-free beverages and flavored water; and (iii) no 

restrictions on caffeine. 

3IOM standards adapted to allow all à la carte offerings that were also sold as part of the reimbursable USDA meal and allow a wider range of 

beverages, i.e., (i) up to 8-oz portion sizes of juice in elementary schools and 12-oz portion sizes in middle and high schools; and (ii) in high 

schools up to 20-oz portion sizes of calorie-free beverages and flavored water; and (iii) no restrictions on caffeine. 

Total number of items selected on sample school day, weighted to generate an annual, national estimate, assuming 180-day school year.

Source: USDA, Economic Research Service analysis, using data from the School Nutrition Dietary Assessment Study III (SNDA-III), collected in 2004-05.
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Non-Foodservice Revenues From Competitive Foods

In many schools, principals, booster clubs, and other non-school foodservice entities sell competitive foods in vending machines, as fundraisers, etc. They use revenues to augment school funding, 

purchase sports uniforms, fund school trips, or meet other wants and needs. Revenues obtained from 

competitive food sales by school entities other than school foodservices account for only about 5 

percent of competitive food revenues (USDA, FNS, 2013). The legislative requirement for competitive foods to meet nutrition standards will apply to these groups, in general, although it does allow 

for school groups to sell foods that do not meet standards on a limited number of occasions. This 

should help affected school groups to maintain revenues. They may also substitute nonfood sales 

and fundraising activities for sales of less healthy foods. Case studies provide many examples of 

schools that have used these alternative strategies to raise funds previously obtained from vending 

and other competitive food sales (USDA et al., 2005).

Revenues obtained from competitive food sales differ greatly between elementary and secondary 

(middle and high school) levels. Average annual competitive revenues for elementary schools were 

about one-sixth those of middle schools in 2005 and approximately one-ninth those of high schools 

(fig. 1). These differences are consistent with the greater purchasing power and latitude of older 

students. At the middle and high school levels, the difference in revenues appears to be attributable 

to the larger enrollments of high schools. On a per-student basis, elementary school revenues averaged $16 per student per year in 2005, versus $82 for middle school students and $64 for high school 

students. This supports our decision to separate elementary and secondary schools in our analyses.
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School foodservice revenues range widely across elementary and secondary levels. Foodservices in 

most elementary schools obtain negligible revenue from competitive foods and beverages. At the 

median, they received approximately $2,400 annually (fig. 2). This translates to less than $5 per 

student per year. The average foodservice revenue in elementary schools is dramatically skewed by a 

minority of schools. At the 75th percentile, school foodservices obtained almost five times as much 

revenue as at the median, and at the 90th percentile they obtained eight times as much as median 

revenues.

At the secondary level, almost all school foodservices have some competitive food revenues, but again, 

the amounts vary considerably. At the 75th percentile, foodservices obtain 2.5 times as much revenue 

as at the median, and at the 90th percentile they obtain more than 5 times as much (fig. 2). To some 

extent, this may be a function of school size, as at the secondary level enrollments vary considerably. 

On a per-student basis, the pattern is less extreme: per-student revenues at the 75th percentile are 2 

times as high as at the median, while revenues at the 90th percentile are 3.7 times as high.

School Profiles: Characteristics by Food Revenue Quartile

We divided elementary and secondary schools into quartiles based on per-student foodservice revenues 

from competitive foods. Within each quartile, we calculated mean values for each of the characteristics examined (socioeconomic, geographic, demographic, meal program, nutrition environment; see 

Appendix A). The patterns of characteristics associated with each elementary-school quartile are shown 

in figures 3A and 4A, and secondary-level findings are shown in figures 3B and 4B.

4 These patterns allow 

us to create profiles of schools in which foodservices receive more revenues from competitive foods.

4Complete data for all elementary and secondary quartiles can be found in Appendix C.
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Whether elementary or secondary, high competitive-revenue schools shared similar socioeconomic 

and meal program characteristics. Specifically, the high-revenue (4th quartile) elementary and 

secondary schools were: 

• More affluent, with none of the high-revenue elementary and secondary schools located in 

high-poverty districts. The overwhelming majority—84 percent of elementary and 81 percent 

of secondary schools—were located in low-poverty districts, with the remainder in mediumpoverty districts.

• Serving far fewer students that received free or reduced-price meals. In the high-revenue quartile 

elementary schools, 31 percent of students received free or reduced-price lunch, compared to 63 

percent of students in the lowest revenue quartile. At the secondary level, high-revenue quartile 

schools averaged 29 percent of students receiving free or reduced-price lunch, compared to 42 

percent in the lowest revenue quartile.

• Serving the fewest NSLP meals, with elementary schools in the high-revenue quartile averaging 63 percent participation, compared to 80 percent in the low-revenue (first) quartile. At the 

secondary level, where participation is lower, schools in the high-revenue quartile averaged 44 

percent participation, compared to 64 percent participation in the lowest revenue quartile.

• Least likely to offer the School Breakfast Program (SBP), with 75 percent of elementary schools 

in the high-revenue quartile offering the program compared to 100 percent of the schools in the 

lowest revenue quartile. At the secondary level, 75 percent of schools in the high-revenue quartile 

offered the SBP, compared to 84 percent of schools in the lowest revenue quartile.

Findings on ethnicity differed by school level. Elementary schools in the high-revenue quartile 

served a smaller percentage of non-White students—26 percent compared to 50 percent in the lowest 

revenue quartile. At the secondary level, however, competitive food revenues were unassociated with 

race/ethnicity. 

High-revenue elementary and secondary schools both charged more for full-price meals to students. 

The average meal price for elementary schools in the high-revenue quartile was $1.56 in 2005, 

compared to $1.03 for the low-revenue quartile. For secondary schools in the high-revenue quartile, 

the average meal price was $1.89, compared to $1.32 for the low-revenue quartile. Yet, while they 

charged higher standard prices than other schools, the revenue obtained from such meals would still 

be lower than the free meal reimbursement. Full-price meals receive a small Federal reimbursement—$0.21 in the study year. So an elementary school foodservice that charged a full-price student 

$1.56 would have had a combined student and Federal payment of $1.77, and a secondary school 

charging $1.89 would have a combined payment of $2.10. Both amounts are lower than the Federal 

free meal reimbursement of $2.24 for that year. 

Given that higher competitive-revenue schools serve a larger share of full-price students, they would 

tend to obtain less revenue from school meals, possibly leading them to seek additional revenues 

from competitive foods. SNDA-III data do not provide school-level information on meal revenues, 

but the relationship between competitive food revenues and meal revenues is explored further in the 

SFA-level analysis.
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School nutrition environment characteristics

Schools in higher and lower competitive revenue quartiles did not differ as much in nutrition environment characteristics (figs. 4A-4B) as in socioeconomic and meal program characteristics. Nor 

did elementary and secondary levels vary in similar ways. The high-revenue elementary quartile, 

compared to the lowest revenue quartile, had higher percentages of schools that had non-foodservice 

vending (15 percent versus 4 percent) and fundraisers selling sweet or salty snacks (43 percent versus 

26 percent). 

At the secondary level, however, foodservices with the highest competitive revenues least often 

co-existed with non-foodservice vending and fundraisers selling sweet or salty snacks. This lack 

of internal competition may have allowed school foodservices to capture student food spending 

that would otherwise have gone to these outlets. Vulnerability to outside competition, as measured 

by having an open campus, did not seem to follow a consistent pattern of association with revenue 

levels. This may be because relatively few schools allowed students to leave and return during the 

school day. The pattern of association between State wellness policies and competitive food revenues 

was inconsistent—the low-revenue category had the lowest percentage of schools covered by a State 

or district wellness policy, followed by the high-revenue category (fig. 4B). 

In summary, the prototypical high competitive-revenue elementary school foodservice can be found 

in a school located in a low-poverty district, serving primarily nonpoor, White children. It tends to 

have lower NSLP participation and is less likely to offer the SBP. It charged higher full prices for 

NSLP meals than other districts, but prices were still well below what the foodservice would have 

received for a free meal. Competitive foods were more likely to be available from non-foodservice 

vendors, perhaps pressuring foodservices to offer similar items.

At the secondary level, the prototypical high competitive-revenue foodservice was also found in 

more affluent districts serving primarily nonpoor students, had lower NSLP participation, was less 

likely to offer the SBP, and charged a higher standard price for a full-price NSLP lunch. Unlike 

high-revenue elementary school foodservices, they were less likely to face competition from nonfoodservice vending, although in all revenue quartiles, the majority of secondary schools included 

non-foodservice vending. 

School Food Authorities (SFAs) With Higher Shares of Revenue 

From Competitive Foods

Using SFA-level data from the School Food Authority Characteristics Survey (SFACS), we examine 

competitive food revenues as a share of overall revenues. At the national level, SFAs averaged 12 percent 

of revenues from competitive foods in 2002-03. This is lower than the 16-percent figure reported in 

the 2005 School Lunch and Breakfast Cost Study (SLBCS) II. The difference may be attributable to 

measure—the SLBCS II included “miscellaneous” revenues that may have added to the estimate; to 

sampling differences; or to a trend to higher competitive revenues across the 2002-05 period. Our analysis 

found the distribution of competitive food revenue shares at the SFA level to be less skewed than at the 

school level. Nevertheless, 54 percent of SFAs had revenues below the mean in 2005 (fig. 5).

The differences in the competitive food share of revenues across SFAs could be attributed to 

either higher competitive food revenues, lower USDA meal revenues, or—as turned out to be the 

case—both. SFAs with higher shares of revenues from competitive foods received larger amounts 

of competitive food revenues in absolute terms, $1.25 per student per day at the highest percentile 
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(fig. 6). They also had lower revenues from USDA meals, both from USDA reimbursements for 

meals served and from meal payments made by students. 

SFA Profiles: Characteristics Associated With Higher Shares of 

Revenue From Competitive Foods

To better understand what types of SFAs derived more revenue from competitive foods, we grouped 

SFAs into quartiles based on share of revenue from competitive foods. Analysis of SFA-level socioeconomic characteristics revealed associations consistent with our school-level analysis. SFAs in 

the higher competitive food revenue quartiles were in more affluent districts, with below-average 

poverty levels and fewer students receiving free and reduced-price meals (fig. 7A).

Consistent with meal revenue patterns shown in figure 6, USDA meal participation was lower in 

the high-competitive food revenue SFAs (fig. 7B). Breakfast participation was especially low in 

the highest competitive revenue quartile, where breakfasts made up only 13 percent of all USDA 

meals served in 2005, compared to 24 percent in the lowest quartile. SFAs in the highest competitive revenue quartile charged higher average lunch and breakfast prices to full-price students than 

did other SFAs, with breakfast charges averaging $1.01 per meal compared to the national average of 

$0.94 per meal, and lunch prices averaging $1.73 per meal compared to a national average of $1.56. 

Nevertheless, meal revenues from student payments dropped off as the share of competitive food 

revenue increased (fig. 6), probably because of very low participation.
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The SFACS was designed to be representative of FNS regions, allowing examination of geographic 

differences. SFAs with higher competitive food revenues as a share of total revenues were more 

heavily concentrated in suburban districts (fig. 8A). They were also much more commonly found in 

the Midwest, Northeast, and Mid-Atlantic regions (fig. 8B). 

The SFACS data lack information on school-level factors such as presence of non-foodservice 

competitive food sales or existence of wellness policies. The survey does have information on the 

extent of State financial support to the school meal programs. SFAs in the highest competitive food 

revenue quartile had the lowest level of State support as a percent of revenue—2 percent, compared 

to 2.7 percent in the lowest quartile and the overall average of 2.4 percent. State support may be 

tied to either meal participation or the financial status of the district. However, these differences are 

small, and may be associated with other State differences.

In summary, we find that SFAs with high shares of revenues coming from competitive food sales 

tend to serve more affluent, suburban districts; are most common in the Midwest, Northeast, and 

Mid-Atlantic regions; and typically serve more nonpoor students. They serve fewer USDA meals per 

student (consistent with the lower participation found at schools with high competitive food revenues), 

serve fewer breakfasts as a share of meals, and charge higher meal prices to full-price students. 
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Limitations 

School Environment Changes Since 2005

Foremost among this study’s limitations is the fact that these data were collected some 8 years ago. 

Since then, State and local competitive food policies have changed considerably, potentially influencing 

offerings, selections, and revenues. By 2010, 39 States had policies concerning the nutritional quality 

of competitive foods, although policies varied considerably and they tended to be weaker in secondary 

schools. None fully met IOM standards (CDC, 2012). A recent, nationally representative survey of 

school district policies conducted through the Bridging the Gap Program found that a majority of 

school districts with policies limiting competitive foods and beverages were generally not as strict as 

ones based on the Dietary Guidelines for Americans would be (Schneider et al., 2012). 

Still, these State policies appear to have had some effects on competitive food offerings. The Kids’ 

Safe & Healthful Food Project (2012b) found that many secondary schools reduced availability of 

less healthy snack foods between 2002 and 2008, although the decline slowed between 2008 and 

2010. Another study by the Bridging the Gap Program found that availability of some less healthy 

items, such as soft drinks, decreased significantly in secondary schools while healthier beverages 

like bottled water became ubiquitous (Johnston et al., 2012). USDA’s SNDA-IV provides updated 

information on competitive food offerings for school year 2009-10, although it lacks the information on student behavior included in SNDA-III (USDA, FNS, 2012). As with SNDA-III, competitive 

foods and beverages were more limited at the elementary level. Many healthier items were more 

widely available in 2009-2010 than they had been in 2005—for example, fresh fruit was available à 

la carte in 66.5 percent of high schools in 2009-10, compared to 39 percent in 2005. 

Taken together, these updated findings indicate that many schools have already expanded healthier 

offerings and limited at least some less healthy items. Although most students continue to have 

access to less healthy competitive options (Kids Safe & Healthful Foods Project, 2012b; Johnston 

et al., 2012, Turner et al., 2010), these changes likely have reduced the challenge schools face in 

adapting to updated Federal nutrition standards for competitive foods. 

Other Limitations

The sample is limited to public schools. Private schools also participate in USDA school meal 

programs and will need to implement nutrition standards for competitive foods. However, no comparable data on these schools were available. Published findings from other sources suggest that private 

schools tend to sell a mix of competitive foods and beverages similar to that found in public schools 

(Turner et al., 2010). Therefore, the same changes in food offerings and purchase behavior have 

likely taken place in private schools that participate in USDA school meal programs, with similar 

effects on school foodservice revenues.

The financial data used in this study are based on questionnaire responses and may be less accurate 

than what would be obtained through a more detailed review of foodservice financial data. We do 

not have actual prices paid for specific competitive food and beverage items, requiring us to assume 

that competitive items meeting and not meeting proposed Federal standards contribute equally to 

revenues on a per-selection basis. It may be possible that healthier items are priced higher or lower 

than items not meeting the standards; if so, that will affect the extent to which implementation of 

nutrition standards would influence revenues. 
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Making the Transition to Healthier School Food Choices

Establishing nutrition standards for foods sold at school in competition with the USDA School Meal 

Programs should provide nutritional benefits, especially to secondary-school students who are the 

largest consumers of competitive foods. Those benefits should be especially pronounced in the typically suburban, more affluent SFAs that obtain large shares of revenue from competitive foods and 

have relatively low school meal participation. Nutritional benefits could be either better quality diets, 

fewer excess calories, or both. 

There may be additional benefits to lowering the profile of competitive foods in schools. Eliminating 

less nutritious competitive foods may support efforts to improve the quality of USDA school meals. 

Newman et al. (2009) found NSLP lunches to be lower in fat in schools with no à la carte and 

vending. In the competition for student food spending, the absence of unhealthy alternatives may 

leave school foodservices more free to offer healthy meals that meet Federal nutrition standards.

Another potential benefit of restricting competitive foods may be reducing or eliminating any stigma 

associated with USDA school meal participation. Some argue that the presence of competitive foods 

creates a climate in which those purchasing competitive foods at lunchtime are perceived as being 

nonpoor, while those who eat the school lunch are more likely to be perceived as low-income, freelunch recipients (Poppendieck, 2010; Kavanaugh, 2010). Some students who qualify for free lunch 

reportedly do not eat it because of the associated stigma. 

For school foodservices concerned about covering their expenses, the challenge will be to adapt to 

new standards and develop new strategies for maintaining revenues in a healthier school nutrition 

environment. The challenge is most pronounced to the subset of SFAs receiving a large proportion 

of revenues from competitive foods. School foodservices serving low-income student populations 

are not at higher financial risk from pending introduction of nutrition standards. On the contrary, 

competitive food revenues are highest in more affluent districts and in schools serving nonpoor children, where many students are ineligible for free or reduced-price meals. 

Higher school foodservice revenues from competitive foods were associated with lower USDA lunch 

participation, suggesting that competitive food revenues may displace meal participation and associated revenue. In SFAs where competitive food revenues make up a larger share of overall revenues, 

foodservice managers may be apprehensive about nutrition-mandated changes in offerings. Such 

SFAs will be especially interested in strategies for maintaining revenues when nutrition standards 

for competitive foods are implemented.

To offset revenue losses from removal of competitive foods that fail to meet nutrition standards, 

school foodservices can (1) seek out healthier competitive food options to replace those currently 

sold or (2) re-emphasize their “core business” by expanding participation in school meals. For both 

strategies, appropriate pricing is key. The Healthy, Hunger-Free Kids Act of 2010 addressed pricing 

of meals and competitive foods, and new regulations based on this act may have important effects on 

revenues obtained both from USDA school meals and from healthier competitive foods.

Offering Healthier Competitive Foods and Beverages

One strategy for offsetting revenue losses from removal of popular but unhealthy competitive foods 

would be to seek out healthier products that meet nutrition standards. Case studies at the State and 
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local level found that school foodservices respond to new standards by offering healthier competitive 

items, and student behavior adapts to the changed environment. 

In Texas, establishment of State nutrition standards in 2004 resulted in considerable substitution 

of new or reformulated products for previously allowed products, and students increasingly bought 

these products (Cullen and Watson, 2009). Although this partially compensated for the loss of sales 

from less healthy options, overall school food purchases declined 6 percent. Because we do not 

have revenue information or specific pricing for each item, we cannot draw firm conclusions about 

revenue effects, but assuming each purchase contributes about the same, the substitution of offerings 

would suggest a 6-percent decline in foodservice revenue.

A study of several school districts in California found that, following the establishment of State 

nutrition standards in 2007, purchases of compliant products such as bottled water increased, 

partially offsetting the drop in purchases of soda, candy, and other foods not meeting standards.

 In 

addition, meal sales increased. Nevertheless, there was a decline in net revenue, apparently due to 

higher food costs (Woodward-Lopez et al., 2010).

Among early adopters of competitive food standards, limited availability and higher costs of healthier 

options have been cited as barriers to success (Woodward-Lopez et al., 2005b). Establishing nationwide standards is likely to reduce this problem by spurring product development and increasing 

demand. In some cases, changes are relatively simple. For example, to meet IOM standards, juices 

could be repackaged in smaller containers. In other cases, reformulation of products may be necessary, 

but advocacy groups such as Alliance for a Healthier Generation have already lobbied food manufacturers to develop new products for competitive food sales. Examples include such items as 4-ounce 

fruit bowls; nonfat, no-sugar- added frozen yogurt; 4-ounce frozen fruit bars; and reduced-fat/sodium 

pizza with whole-grain crust (Alliance for a Healthier Generation, 2010).

Other case studies report changes in competitive food offerings that did not have significant effects 

on revenues (Treviño et al., 2012; USDA et al., 2005). These typically combined changes in competitive food offerings with other health promotion activities, which may have contributed to their 

success. For example, school meal menus and competitive food offerings in 24 middle schools were 

modified as part of a health promotion project that also included physical activity, health education, 

and social marketing. After 3 years (2006-09), revenues and expenses of health project schools and 

matched control schools were not significantly different (Treviño et al., 2012). 

Success in maintaining fiscal stability may hinge on appropriate pricing of competitive foods. 

Ironically, the competitive foods that school foodservices feel compelled to sell may not be helping 

their overall financial situation. The SLBCS-II (USDA, FNS, 2008) indicates that in school year 

2005-06, school foodservice competitive food revenues covered, on average, only 71 percent of 

costs. Some of the costs associated with competitive food sales, such as labor, may not be fully 

considered by school foodservices, leading them to underestimate the appropriate price for covering 

costs. Supporting this possibility, in a study of 344 Minnesota public school districts, Peterson (2011) 

found a small but statistically significant negative relationship between competitive food sales and 

overall foodservice profit. 

To address concerns about underpriced competitive foods, the Healthy, Hunger-Free Kids Act of 

2010 (section 206) requires that beginning in the 2012 school year, competitive foods sold by the 

school foodservice must generate revenues appropriate to costs. More appropriate pricing of compet-
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itive foods should result in higher revenues (USDA, 2011b)—and an improved net financial status of 

school foodservices.

Expanding School Meal Participation

Expanding meal participation is an especially appealing option for generating revenues to offset any 

losses from eliminating sales of less nutritious competitive foods. USDA meals are designed specifically to meet nutritional needs of children and reflect the most current nutrition guidance. Given 

the relatively low levels of school meal participation in high-competitive-food-revenue schools and 

SFAs, there is considerable opportunity for expanding meal participation. Previous research suggests 

that if the supply of competitive foods is removed or greatly reduced, school lunch participation is 

likely to increase. An analysis of SNDA-III (USDA, 2007b) found that the NSLP participation rate 

was 4.6 percentage points higher in schools that did not offer competitive food than in those that 

did. School foodservices with low initial participation rates—such as schools with higher competitive food revenues—may raise participation higher than the average rate. However, they tend to have 

more students who are not receiving free or reduced-price meals and may more easily opt to bring 

food from home. Therefore, expanding meal participation may be challenging, and may require 

school foodservices to intensify their efforts to promote USDA school meal purchases. 

Some school foodservices that wanted to de-emphasize competitive foods as a part of the food environment have launched efforts to improve school meal participation that result in above-average 

increases. Kavanaugh (2010) reports that efforts such as adding new, attractive, healthy items; 

speeding service; and making the service area more appealing were successful in generating large 

increases in NSLP participation in several school districts that eliminated or dramatically reduced 

competitive foods. Given that school meal participation is particularly low in secondary schools, 

where competitive food revenues are highest, efforts to attract secondary students are especially 

important. More marketing-style research to identify approaches that appeal to older students could 

be useful. For example, a recent study highlighted the effectiveness of a “healthy express” line that 

could make a school meal as quick to pick up as a snack bar item (Hanks et al., 2012). 

Breakfasts provided through USDA’s SBP may offer another opportunity to increase foodservice 

revenue. However, this strategy can be problematic. USDA’s School Lunch and Breakfast Cost Study 

II (SLBCS-II, 2008) reports that in school year 2005-06, the reported cost of producing reimbursable breakfasts exceeded reimbursement rates. Other studies have found that breakfast costs are 

strongly influenced by participation, which tends to be much lower than for lunches (Hilleren, 2007; 

Ollinger et al., 2011a; Ollinger et al., 2011b). Increasing participation may offer economies of scale, 

reducing costs in relationship to revenues. In a pilot study of nutrition improvements in California 

schools, offering the SBP in schools not currently participating and increasing participation where 

it was already offered were helpful in offsetting competitive food revenue losses in several schools 

(Woodward-Lopez et al., 2005a). This was most effective in schools with more free and reducedprice students, the group that most typically participates in SBP. In schools with more full-price 

students, this strategy may be less successful.

For schools with higher levels of nonpoor students, the success of strategies that rely on increasing 

meal participation hinges on the adequacy of the price charged to full-price students. The SLBC-II 

found that most schools underprice the full-price meal charged to their students by 32 percent 

(USDA, 2008; Kavanaugh, 2010). The Healthy, Hunger-Free Kids Act of 2010 addressed the issue, 

requiring school foodservices to gradually adjust the full price upward if the full price is less than 

the difference between the total Federal reimbursements for a free lunch and a full-price lunch (or 
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provide additional non-Federal support for these meals such as State or local funding). Affected 

school foodservices are allowed to gradually phase in higher prices, with meal price increases 

capped at $0.10 per year. As prices rise to meet costs, schools with larger percentages of nonpoor 

students should feel less pressure to sell competitive foods, assuming they are able to maintain or 

increase participation.

However, school foodservices may be unable to maintain or increase participation in the face of 

required price increases. Previous research indicates that higher meal prices are associated with 

lower participation (USDA, 2007b). School foodservices seeking to move from reliance on competitive food revenues to increased meal revenues may also need assistance with marketing efforts 

to increase the perceived value of the meal and to instill the willingness to pay a higher price. 

Alternatively, advocates may seek to gain State or local support for meals. 
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Conclusions

Most competitive food and beverage items selected by students in 2005 would not meet nutrition 

standards based on Institute of Medicine guidelines. Implementation of nutrition standards for 

competitive foods promises benefits by improving dietary quality and reducing excess calories from 

low-nutrient foods. Although there has been concern that the loss of revenue would hurt poorer 

schools most, school foodservices with high competitive food revenues typically are located in more 

affluent districts and serve fewer low-income students receiving free and reduced-price lunch than 

do schools with low competitive food revenues.

These school foodservices may particularly benefit from guidance in making the transition to 

new competitive food standards. Typically, they tend to couple higher competitive food revenues 

with low school meal participation, so increasing meal participation is a plausible strategy to 

offset revenue losses. In addition, these school foodservices could be assisted in selecting new 

competitive food products that meet nutrition standards. Such products are becoming more widely 

available, and national nutrition standards for competitive foods will likely spur further product 

development. Changes in Federal regulations that should result in more appropriate pricing of fullprice USDA meals and competitive foods could enhance the revenue-generating effects of these 

nutrition-based strategies.
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Appendix A—Characteristics Examined in School-Level 

(SNDA) and SFA-Level (SFACS) Analyses 

School-Level Analysis (SNDA III data)

 Categories Specific Items Information sources

School level Elementary, middle, high National Center for Educational Statistics 

(NCES) Common Core Database (CCD), 

2004-05

Socioeconomic Child poverty level of district reported 

on SNDA data file as falling into one of 

the following categories, based on the 

percentage of schoolchildren in families 

with incomes less than 100 percent of 

poverty:

--low (<20 percent)

--medium (20 to <30 percent)

--high (30 percent or more)

U.S. Census, 2000

Percentage of students receiving free or 

reduced-price meals

National Center for Educational Statistics 

(NCES) Common Core Database (CCD), 

2004-05

Demographic Percentage of non-White students National Center for Educational Statistics 

(NCES) Common Core Database (CCD), 

2004-05

Meal Program 

Characteristics

Weekly lunch (National School Lunch 

Program) participation

Calculated by Mathematica researchers 

using data collected during a target week in 

which school menus and meal participation 

were recorded by school foodservice managers following standardized protocols

Average standard price for full-price 

lunch

Reported by school foodservice managers

School offers USDA School Breakfast 

Program (SBP)

Schools coded as offering SBP if School 

Food Authority director reported that they did 

and menu survey reported serving breakfast 

menu

School Nutrition 

Environment

Has State, district, or school wellness 

policy

School principal’s response to question 

asking whether there was a wellness policy 

addressing student nutrition and physical activity, with options of (1) school, (2) district, 

(3) State, or (0) no policy

Has vending that is not operated by 

school foodservice (non-foodservice 

vending)

Computed from questionnaire response 

variables indicating that there are vending 

machines present at the school, but the 

foodservice does not receive revenues from 

them

Has fundraisers selling sweet or salty 

snacks

Variable created by Mathematica on basis of 

questionnaire responses indicating whether 

the school had any fundraising activities selling sweet or salty snacks

Open campus (for secondary schools) Variable created by Mathematica on basis of 

questionnaire responses indicating whether 

the school had a policy allowing students to 

leave and return to school during the school 

day (open campus)
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Characteristics Examined in SFA-Level (SFACS) Analysis

Characteristics SFA-level (SFACS) analysis of competitive food revenue as a share of total 

foodservice revenue

Information sources

School type Elementary, middle, high National Center for Educational Statistics (NCES) Common Core Database 

(CCD), 2002-03

Socioeconomic Poverty level 

--Percent of school-age children in district 

in poverty

U.S. Census, 2000

Shares of students receiving free or 

reduced-price meals

Calculated from questionnaire data

Geographic USDA Food and Nutrition Service region

--Mid-Atlantic (includes Delaware, District 

of Columbia, Maryland, New Jersey, Pennsylvania, Virginia, West Virginia)

--Midwest (includes Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin)

--Mountain (includes Colorado, Iowa, Kansas, Missouri, Montana, Nebraska, North 

Dakota, South Dakota, Utah, Wyoming)

--Northeast (includes Connecticut, Maine, 

Massachusetts, New Hampshire, New 

York, Rhode Island, Vermont)

--Southeast (includes Alabama, Florida, 

Georgia, Kentucky, Mississippi, North 

Carolina, South Carolina, Tennessee)

--Southwest (includes Arkansas, Louisiana, 

New Mexico, Oklahoma, Texas)

--West (includes Arizona, California, Idaho, 

Nevada, Oregon, Washington)

Regions defined by FNS for administrative purposes; some of these regions 

also included States or territories outside of the 48 coterminous States, but 

these were not included in the sampling 

frame of this study and are therefore 

not listed here.

Urbanicity

--Rural

--Suburban

--Urban

Defined on the basis of the Metropolitan Statistical Area (MSA) in which the 

SFA is located

Meal Program 

Characteristics

Lunch (NSLP) meals per student Questionnaire response provided by 

SFA

Average price for full-price lunch Questionnaire response provided by 

SFA

Breakfast as share of meals Computed on the basis of questionnaire responses provided by SFA

State 

Characteristics

State reimbursement to SFA National Center for Educational

Statistics (NCES) Common Core 

(CCD), 2002-03
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Appendix B—Categorizing Competitive Food Selections 

by Ability To Meet Criteria Based on Institute of Medicine 

Nutrition Standards

This analysis was first conducted as part of an effort to assess the possible effects on students and 

school foodservices of implementing national nutrition standards for competitive foods. The analysis 

examines the extent to which the mix of competitive foods and beverages selected by students in 

2005 would meet national nutrition standards for competitive foods. In the absence of established 

national nutrition standards, we use criteria based on model nutrition standards developed by the 

Institute of Medicine (IOM, 2007) as our guideline (see box, p. 7). Given uncertainty about final 

standards, we examined how foods would be categorized under three different options: 

(a) Standards that matched those described in the box as closely as possible. 

(b) Standards that allowed all à la carte offerings that were also sold as part of the reimbursable USDA meal and met IOM fat and total sugar standards, and that allowed a wider 

range of beverages, i.e., (i) up to 8-oz portion sizes of juice in elementary schools and 12-oz 

portion sizes in middle and high schools; and (ii) in high schools, up to 20-oz portion sizes 

of calorie-free beverages and flavored water; and (iii) no restrictions on caffeine. 

(c) Standards that allowed all à la carte offerings that were also sold as part of the reimbursable 

USDA meals, and also allowed the beverages described under option (b). 

Data and Methods

Our data source is the School Nutrition Dietary Assessment Study III (SNDA-III), conducted in the 

2004-05 school year. This provides the most recent nationally representative data on foods consumed 

at school, their sources, and their nutrient composition. SNDA-III was conducted for the Food and 

Nutrition Service of the U.S. Department of Agriculture by Mathematica Policy Research, Inc. 

(Mathematica). Its staff collected information on all foods selected and consumed by students within 

a given 24-hour period that included a school day. Mathematica researchers classified foods obtained 

at school as being part of the USDA school meal or as competitive items using methods described by 

Fox et al. (2009). Survey weights that could be used to generate nationally representative findings were 

developed by Mathematica and included in the public-access data file used in this analysis.

SNDA-III does not identify foods by purchase occasion, but rather by eating occasion. Therefore, we 

assessed frequency of item selection as a proxy for purchase frequency. For each item selected, we 

compared its nutritional composition to standards based on the three options described above. Each 

item was identified as meeting or not meeting standards on this basis of its specific composition. 

As a result, within a given type of food or beverage, some might meet nutrition standards, others 

not. For example, some low-fat flavored milks might not meet the standard for sugar content, while 

others made with less sugar might meet the sugar content.

After each item was classified as meeting or not meeting the standards, items were grouped by 

major beverage or food categories. The total number of selections of each item was generated using 

SNDA-III data, which were annualized assuming a 180-day school year. Results were weighted to 

provide nationally representative findings.
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Findings

Tables B1-B6 provide detailed information on beverages and foods selected by students and the 

share of selections that met standards, as well as the specific standards not met. More beverage than 

food items met standards—23-27 percent, depending on the option examined. Low-fat milk, juice, 

and especially bottled water were the beverages that most often met standards. However, even within 

these categories, not all choices completely met the standards. The majority of flavored lowfat milks 

exceeded the sugars standard. Many fruit juice selections (our proxy for purchase size) were of overlarge portion size, even under options that allowed larger sizes. Even some bottled waters did not 

meet criteria regarding flavors and sweeteners. 

Under every option, a smaller proportion of foods than beverages selected by students met the Tier 

1 standards. Fewer than 3 percent met all IOM standards, but allowing any NSLP item to be sold à 

la carte raised the share of saleable items to 16.5 percent. Generally, competitive foods are criticized 

as being high in fat, sodium, or sugars. Large numbers of food items failed to meet standards for 

those nutrients, but the biggest single reason for not meeting standards was the failure to provide 

meaningful amounts of healthful, underconsumed food groups like low-fat dairy, whole grains, 

vegetables, fruits. Again, there were some categories in which some items met standards, and others 

did not. For example, some potato chips met all standards, perhaps because they were baked rather 

than fried, made with less sodium, and/or sold in smaller packages. Because updated USDA school 

meal standards have likely resulted in items that are also sold as part of the NSLP being lower in fat, 

sodium, and sugars, the nutritional quality of à la carte items also sold as part of the NSLP has likely 

improved since 2005.

Limitations

The model IOM standards provided the guiding principles for our analysis. However, using them to 

classify food items required us to make some operational decisions, as described in the footnotes to 

our tables. For example, portion size was an important criterion for fruit juices, but we did not have 

direct information on purchase size. Instead we estimate purchase size based on amount consumed, 

and we also based our cutoffs on slightly larger amounts consumed (e.g., 4.5 oz. rather than 4 oz. of 

juice) to allow for reporting error. 

Since these data were collected in 2005, some States and/or school districts have developed policies limiting sales of less nutritious competitive foods and beverages. Therefore, the composition of 

competitive foods may have changed since 2005. However, we lack more recent national data with 

the level of detail necessary for these estimates. Given changes in school policies, these should be 

considered upper-bound estimates of the shares of competitive food and beverage selections that 

would not meet IOM model standards.

Most importantly, these are model standards developed by an independent organization, not actual 

national nutrition standards. The Food and Nutrition Service (FNS) of USDA has not yet issued final 

standards; those standards may be quite different from any of the options examined here. Therefore, 

findings provide only a general guide to how food items might be affected by national nutrition 

standards. Nevertheless, these data provide insights into how products commonly selected by U.S. 

students compare to model nutrition standards and suggest potential areas for improvement, for 

example by decreasing portion sizes of some items, such as juice, or developing lower-sugar versions 

of some items, such as yogurts.
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Table B1Competitive beverage items selected by students - Option 1; Tier One Institute of Medicine (IOM) Standards

Tier 1 IOM standards

Competitive beverages

Beverage standards

Total 

number of 

items selected “Baseline 

2005”

Meets all 

Tier 1 IOM 

standards

Meets lowfat 

or nonfat milk 

standard

Meets 

flavored milk 

sugar standard

Meets portion 

size standard 

of 4 oz (elem/

mid) or 8 oz 

(high) for 

100% fruit 

juice

Meets 

caffeine free 

standard

Meets noncarbonated, 

non-flavored, 

unsweetened 

standard for 

water

BEVERAGESDairy Whole or 2% milk--flavored 23 - - - - 23 - 

Whole or 2% milk--unflavored 77 - - 77 - 77 - 

1% of fat free milk--flavored 126 16 126 16 - 126 - 

1% of fat free milk--unflavored 121 119 121 119 - 121 - Milkshakes and other milk drinks 7 - - 7 - 7 - 

Fruit juice 100% fruit juice 164 63 - - 63 164 - Soda Caloric soda (sweetened) 452 - - - - 99 - 

Non-caloric soda (diet) 26 - - - - 1 - 

Fruit drinks, fruitades 864 - - - - 864 - 

Bottled water Bottled water 403 376 - - - 403 376 

Coffee or tea Coffee or tea--unsweetened 42 - - - - - - 

Coffee or tea--sweetened 152 - - - - - - 

Beverage baseline total 2,457 574 - - - - - 

Percent of 2005 beverage baseline total 23.4 - - - - - 

Note: Total number of items selected on sample school day, weighted to generate an annual, national estimate.Selections are considered proxies for purchases.Source: Economic Research Service analysis of School Nutrition Dietary Assessment Study-III 2005 student recall dietary data.
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Table B2Competitive food items selected by students - Option 1; Tier 1 Institute of Medicine (IOM) Standards

Total 

number 

of items 

selected 

“Baseline 

2005”

 Food sub-standards

Competitive food

Meets 

all Tier 

1 IOM 

standards

Meets 

all Tier 

1 IOM 

except 

Food 

Type 

Standards

Meets 

IOM 

food type 

standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets total sugars 

standard

Meets 

200 

sodium 

standard

Meets 

calorie 

limits

FOODVegetables French fries and similar products 148 - 1 33 1 79 148 124 123 

All vegetables other than french fries 128 40 81 83 114 118 120 85 118 

Breads/grains Other bread (biscuits, croissants, bread) 17 - 7 - 11 17 17 7 9 

Breads, rolls, bagets, etc. 79 - 43 - 79 79 79 43 52 

Cold cereal 44 - - 9 44 44 18 26 37 

Corn, tortilla chips 254 - 1 - 8 144 254 147 202 

Crackers and hard pretzels 257 - 42 4 132 168 257 106 209 

Pastries 63 - - - 4 35 36 28 8 

Rice 5 - 3 - 5 5 5 3 5 

Pasta 4 - 4 - 4 4 4 4 4 

Muffins, quickbreads, not english muffins 31 - - 4 28 27 31 - - 

Fruit Whole fruit, fresh, canned, or frozen 143 67 92 94 143 143 92 143 129 

Entrees Pizza or pizza pockets, etc. 217 - - 114 34 - 217 39 94 

Beef, burgers, pork, lamb, veal, sandwich 31 - - 23 5 - 31 18 23 Sandwich with meat, poultry, fish, may 77 7 7 70 24 51 77 42 60 

Breakfast sandwich 20 - - 20 8 - 20 - 4 

Other entree mix with meat, grain, vegetable 11 - - 11 - - 11 - 11 Chicken and turkey 104 1 1 99 2 20 104 61 74 Fish and shellfish 12 - - 12 12 12 12 - 12 Mexican-style entrees 119 - - 79 16 12 119 42 91 

Hotdogs and sausage 32 - 2 31 2 2 32 2 29 

Yogurt 15 - - - 15 15 - 15 15 Noodles or pasta mixture 7 - - 4 6 3 7 - 3 

Peanut butter sandwich 18 - - 18 - 18 18 - - Nuts, nutbutters, sunflower seeds, trail mix 21 - - 14 6 11 21 21 21 

continued—
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Table B2Competitive food items selected by students - Option 1;Tier One Institute of Medicine (IOM) Standards—continued

Total 

number 

of items 

selected 

“Baseline 

2005”

 Food substandards

Competitive food

Meets 

all Tier 

1 IOM 

standards

Meets 

all Tier 

1 IOM 

except 

Food 

Type 

Standards

Meets 

IOM 

food type 

standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets total sugars 

standard

Meets 

200 

sodium 

standard

Meets 

calorie 

limits

Other protein-cheese, eggs 73 - - - - - 73 49 68 

Desserts Ice cream and other frozen dairy dessert 283 - - - 60 20 31 280 254 

Pudding and other non-frozen dairy dessert 22 - - 1 22 10 - 19 21 

Fruit or fruit juice dessert 31 - - 2 31 31 - 31 31 

Sweet baked desserts 246 - - - 133 220 49 142 138 Cookies 550 - 25 - 60 131 514 522 481 Granola or grain fruit bar 87 - 1 9 37 34 68 87 69 

Other dessert, non-fruit gelatin 180 - - - 180 180 - 180 149 

Candy Candy 763 - - 21 475 458 27 753 525 

Salty snacks

Popcorn 95 - - 43 3 38 91 30 55 

Potato chips 225 1 1 164 4 61 225 161 193 

Soup that is not a veg or entree item 16 - - - 3 3 16 8 11 

Food baseline total 4,428 116 311 962 1,711 2,193 2,824 3,218 3,328 

Percent of 2005 food baseline total 2.6 7.0 - - - - - - 

Total baseline 6,885 690 - - - - - - - Percent of 2005 total baseline 10.0 12.9 - - - - - -

Note: Total number of items selected on sample school day, by commodity-based groups, weighted to generate an annual, national estimate.Selections are considered proxies for purchases.Source: Economic Research Service analysis of School Nutrition Dietary Assessment Study-III 2005 student recall dietary data.
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Appendix table B3Competitive beverage items selected by students - Option 2, modified Institute of Medicine (IOM) standards

Estimates using Option 2 Modified IOM standards

Beverage standards

Competitive beverages

Total 

number 

of items 

selected 

“Baseline 

2005”

Meets all

Option 2 

beverage 

standards

Meets 

lowfat or 

nonfat 

milk standard

Meets 

flavored 

milk sugar 

standard

Meets 

portion 

size standard of 8 

oz (elem/

mid) or 12 

oz (high) 

for 100% 

Fruit Juice

Meets caffeine free 

standard 

for elem/

mid and 

up to 20 

oz for high

Meets 

bottled 

water 

limits of 

unsweetened for 

elem/mid 

and up to 

20 oz for 

high

Meets diet 

soda limit 

of up to 20 

oz for high 

school 

students

BEVERAGESDairy Whole or 2% milk--flavored 23 - - - - 23 - - 

Whole or 2% milk--unflavored 77 - - 77 - 77 - - 1% of fat free milk--flavored 126 16 126 16 - 126 - - 1% of fat free milk--unflavored 121 119 121 119 - 121 - - Milkshakes and other milk drinks 7 - - 7 - 7 - - 

Fruit juice 100% fruit juice 164 91 - - 91 164 - - 

Soda Caloric soda (sweetened) 452 - - - - 35 - - 

Non-caloric soda (diet) 26 18 - - - 1 - 18 

Fruit drinks, fruitades 864 - - - - 437 - - 

Bottled water Bottled water 403 395 - - - 89 395 - 

Coffee or tea Coffee or tea--unsweetened 42 21 - - - 21 - - 

Coffee or tea--sweetened 152 - - - - - - - 

Beverage baseline total 2,457 660 - - - - - - 

Percent of 2005 beverage baseline total 26.9 - - - - - - 

Note: Total number of items selected on sample school day, weighted to generate an annual, national estimate.Selections are considered proxies for purchases.Source: Economic Research Service analysis of School Nutrition Dietary Assessment-III 2005 student recall dietary data.
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Appendix table B4Competitive food items selected by students - Option 2, modified Institute of Medicine (IOM) standards

Estimates using Option 2 modified IOM standards

Food standards

Competitive food

Total 

number 

of items 

selected 

“Baseline 

2005”

Meets all 

Option 2 

standards

Meets 

reimbursable food 

standards 

subject 

to fat and 

sugar 

standards

Meets 

USDA 

food type 

standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets total sugars 

standard

Meets 200 

sodium 

standard

Meets 

calorie 

limits

FOODVegetables French fries and similar products 148 - - 44 1 79 148 124 123 

All vegetables other than french fries 128 40 - 83 114 118 120 85 118 

Breads/Grains Other bread (biscuits, croissants, bread) 17 - - - 11 17 17 7 9 

Breads, rolls, bagets, etc. 79 - - - 79 79 79 43 52 

Cold cereal 44 - - 15 44 44 18 26 37 

Corn, tortilla chips 254 - - 20 8 144 254 151 203 

Crackers and hard pretzels 257 2 2 6 132 168 257 107 209 

Pastries 63 - - 14 4 35 36 30 22 

Rice 5 - - - 5 5 5 3 5 

Pasta 4 - - - 4 4 4 4 4 

Muffins, quickbreads, not english muffins 31 5 5 9 28 27 31 5 5 

Fruit Whole fruit, fresh, canned, or frozen 143 67 5 94 143 143 92 143 129 

Entrees Pizza or pizza pockets, etc. 217 - - 125 34 - 217 54 109 

Beef, burgers, pork, lamb, veal, sandwich 31 - - 23 5 - 31 19 25 Sandwich with meat, poultry, fish, may 77 7 - 70 24 51 77 42 60 

Breakfast sandwich 20 - - 20 8 - 20 - 4 

Other entree mix with meat, grain, vegs 11 - - 11 - - 11 - 11 

Chicken and turkey 104 1 - 99 2 20 104 73 86 

Fish and shellfish 12 - - 12 12 12 12 - 12 

Mexican-style entrees 119 - - 80 16 12 119 44 93 Hot dogs and sausage 32 - - 31 2 2 32 2 29 

continued—
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Appendix table B4Competitive food items selected by students - Option 2, modified Institute of Medicine (IOM) standards—continued

Estimates using Option 2 modified IOM standards

Food standards

Competitive food

Total number of 

items 

selected 

“Baseline 

2005”

Meets all 

Option 2 

standards

Meets 

reimbursable food 

standards 

subject 

to fat and 

sugar 

standards

Meets 

USDA 

food type 

standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets 

total 

sugars 

standard

Meets 200 

sodium 

standard

Meets 

calorie 

limits

Yogurt 15 - - - 15 15 - 15 15 

Noodles or pasta mixture 7 - - 4 6 3 7 - 3 

Peanut butter sandwich 18 - - 18 - 18 18 18 18 

Nuts, nutbutters, sunflower seeds, trail mix 21 14 - 14 6 11 21 21 21 

Other protein-cheese, eggs 73 - - 25 - - 73 61 68 

Desserts Ice cream/other frozen dairy desserts 283 - - 130 60 20 31 283 270 

Pudding/other nonfrozen dairy desserts 22 - - 20 22 10 - 20 22 Fruit or fruit juice desserts 31 - - 5 31 31 - 31 31 

Sweet baked desserts 246 - - - 133 220 49 142 138 

Cookies 550 - - - 60 131 514 522 481 

Granola or grain fruit bar 87 1 1 39 37 34 68 87 70 Other dessert, non-fruit gelatin 180 - - 115 180 180 - 180 171 

Candy Candy 763 - - 68 475 458 27 753 547 

Salty snacks Popcorn 95 - - 52 3 38 91 38 55 

Potato chips 225 1 - 189 4 61 225 190 206 

Soup that is not a veg or entree item 16 3 3 3 3 3 16 11 11 

Food baseline total 4,428 141 16 1,438 1,711 2,193 2,824 3,334 3,472 

Percent of 2005 food baseline total 3.2 - - - - - - -

Total baseline 6,885 801 - - - - - - - 

Percent of 2005 total baseline 11.6 - - - - - - -

Source: Economic Research Service analysis of School Nutrition Dietary Assessment-III 2005 student recall dietary data.Note: Total number of items selected on sample school day, by commodity-based groups, weighted to generate an annual, national estimateSelections are considered proxies for purchases.
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Table B5Competitive beverage items selected by students - Option 3, Modified Institute of Medicine (IOM) standards

 Estimates of USDA proposed standards

Beverage standards

Competitive beverages

Total 

Number 

of Items 

Selected 

"Baseline 

2005"

Meets 

All USDA 

Proposed 

Beverage 

Standards

Meets 

lowfat or 

nonfat milk 

standard

Meets 

flavored 

milk sugar 

standard

Meets portion size 

standard 

of 8 oz 

(elem/mid) 

or 12 oz 

(high) for 

100% Fruit 

Juice

Meets caffeine free 

standard 

for elem/

mid and 

up to 20 oz 

for high

Meets 

bottled 

water 

limits of 

unsweetened for 

elem/mid 

and up to 

20 oz for 

high

Meets diet 

soda limit 

of up to 20 

oz for high 

school 

students

BEVERAGESDairy Whole or 2% milk--flavored 23 - - - - 23 - -

Whole or 2% milk--unflavored 77 - - 77 - 77 - -

1% of fat free milk--flavored 126 16 126 16 - 126 - - 1% of fat free milk--unflavored 121 119 121 119 - 121 - - 

Milkshakes and other milk drinks 7 - - 7 - 7 - - 

Fruit juice 100% fruit juice 164 91 - - 91 164 - - 

Soda Caloric soda (sweetened) 452 - - - - 35 - - 

Non-caloric soda (diet) 26 18 - - - 1 - - 

Fruit drinks, fruitades 864 - - - - 437 - -

Bottled water Bottled water 403 395 - - - 89 - - 

Coffee or tea Coffee or tea--unsweetened 42 21 - - - 21 - - 

Coffee or tea--sweetened 152 - - - - - - -

Beverage baseline total 2,457 660 - - - - - - 

Percent of 2005 beverage baseline total 26.9 - - - - - - 

Note: Total number of items selected on sample school day, by commodity-based groups, weighted to generate an annual, national estimate.Selections are considered proxies for purchases. Source: Economic Research Service analysis of School Nutrition Dietary Assessment-III 2005 student recall dietary data.
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continued—

Table B6Competitive food items selected bystudents - Option 3, Modified Institute of Medicine (IOM) standards—continued

Food standards 

Competitive food

Total Number of Items 

Selected 

“Baseline 

2005”

Meets All 

USDA 

Proposed 

Standards 

- Alternative 2

Is a reimburseable 

food

Meets 

USDA 

Food Type 

Standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets total 

sugars 

standard

Meets 200 

sodium 

standard

Meets 

calorie 

limits

FOODVegetables French fries and similar products 148 11 11 44 12 79 148 124 123 

All vegetables other than french fries 128 40 - 83 114 118 120 85 118 

Breads/Grains

Other bread (biscuits, croissants, brea 17 - - - 11 17 17 7 9 

Breads, rolls, bagets, etc. 79 - - - 79 79 79 43 52 Cold cereal 44 6 6 15 44 44 24 26 37 Corn, tortilla chips 254 20 20 20 28 155 254 151 203 Crackers and hard pretzels 257 2 2 6 132 168 257 107 209 Pastries 63 14 14 14 18 47 38 30 22 

Rice 5 - - - 5 5 5 3 5 Pasta 4 - - - 4 4 4 4 4 Muffins, quickbreads, not english muffi 31 5 5 9 28 27 31 5 5 

Fruit Whole fruit, fresh, canned, or frozen 143 67 5 94 143 143 92 143 129 Entrees Pizza or pizza pockets, etc. 217 17 17 125 45 17 217 54 109 

Beef, burgers, pork, lamb, veal, sandwi 31 1 1 23 6 1 31 19 25 Sandwich with meat, poultry, fish, may 77 7 - 70 24 51 77 42 60 Breakfast sandwich 20 - - 20 8 - 20 - 4 Other entree mix with meat, grain, vege 11 - - 11 - - 11 - 11 

Chicken and turkey 104 13 12 99 14 32 104 73 86 Fish and shellfish 12 - - 12 12 12 12 - 12 

Mexican-style entrees 119 2 2 80 17 13 119 44 93 
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Table B6Competitive food items selected bystudents - Option 3, Modified Institute of Medicine (IOM) standards—continued

Food standards 

Competitive food

Total Number of Items 

Selected 

“Baseline 

2005”

Meets All 

USDA 

Proposed 

Standards 

- Alternative 2

Is a reimburseable 

food

Meets 

USDA 

Food Type 

Standards

Meets 

total fat 

standard

Meets 

saturated 

fat standard

Meets total 

sugars 

standard

Meets 200 

sodium 

standard

Meets 

calorie 

limits

Hotdogs and sausage 32 - - 31 2 2 32 2 29 Yogurt 15 - - - 15 15 - 15 15 

Noodles or pasta mixture 7 - - 4 6 3 7 - 3 Peanut butter sandwich 18 18 18 18 18 18 18 18 18 

Nuts, nutbutters, sunflower seeds, trai 21 14 - 14 6 11 21 21 21 

Other protein-cheese, eggs 73 25 25 25 25 25 73 61 68 

Desserts

Ice cream and other frozen dairy desser 283 130 130 130 160 140 144 283 270 

Pudding and other non-frozen dairy dess 22 20 20 20 22 22 20 20 22 

Fruit or fruit juice dessert 31 3 3 5 31 31 3 31 31 

Sweet baked desserts 246 - - - 133 220 49 142 138 

Cookies 550 - - - 60 131 514 522 481 

Granola or grain fruit bar 87 33 33 39 68 66 70 87 70 

Other dessert, non-fruit gelatin 180 115 115 115 180 180 115 180 171 

Candy Candy 763 51 51 68 493 476 71 753 547 

Salty snacks Popcorn 95 9 9 52 12 38 91 38 55 

Potato chips 225 104 102 189 106 140 225 190 206 

Soup that is not a veg or entree item 16 3 3 3 3 3 16 11 11 

Food baseline total 4,428 730 604 1,438 2,084 2,533 3,129 3,334 3,472 

Percent of 2005 food baseline total 16.5 - - - - - - - 

Total baseline 6,885 1,390 - - - - - - - 

Percent of 2005 total baseline 20.2 - - - - - - -

Note: Total number of items selected on sample school day, by commodity-based groups, weighted to generate an annual, national estimateSelections are considered proxies for purchases.Source: Economic Research Service analysis of School Nutrition Dietary Assessment-III 2005 student recall dietary data.
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Appendix C—Data Tables for Figures 2-6

Table C.1

Distribution of annual school foodservice competitive food revenues, at elementary and 

secondary levels (data for Figure 2)

Percentile Elementary school competitive food revenues Secondary school competitive food revenues

1 $0 $0

10 $0 $0

25 $18 $3,928

50 $2,395 $27,803

75 $11,394 $69,339

90 $19,048 $148,275

95 $32,975 $203,812

99 $81,594 $414,317

Source: USDA, Economic Research Service analysis, using data from the School Nutrition Dietary Assessment Study III 

(SNDA-III), collected in 2004-2005.

Table C.2 

Characteristics of elementary schools in differing school foodservice competitive food revenue 

quartiles (data for Figures 3A and 4A)

Elementary schools

School foodservice competitive food revenue quartiles

(school foodservice competitive food revenues per student per year)

Overall 

mean

<=25th %tile

0

>25th - <=50th 

%tile

(>0 - <=$4.82)

>50th - <=75th 

%tile

>$4.82 - 

<=23.41

>75th %tile

>$23.34

% Low poverty (More affluent districts) 64.5% 37.8% 60.8% 60.9% 83.9%

% Medium poverty 28.6% 39.9% 37.8% 29.8% 16.1%

% High poverty 7.0% 22.3% 1.4% 9.5% 0.0%

% Students receiving free/reduced price 

meals 46.2% 63.1% 50.5% 52.9% 30.6%

% Non-white students 35.8% 50.2% 40.1% 38.7% 25.6%

Weekly lunch participation 69.8% 80.1% 70.3% 69.9% 63.1%

Average price of full-price meal $1.44 $1.03 $1.50 $1.49 $1.56

Offer school breakfast program 79.3% 100.0% 67.2% 80.3% 75.0%

Have non-foodservice vending 11.3% 4.3% 9.7% 17.0% 14.7%

Have fundraisers selling sweet or salty 

snacks 36.9% 25.6% 39.6% 36.0% 43.4%

Have State or District level wellness policy 34.4% 41.6% 29.0% 38.0% 37.1%

Source: USDA, Economic Research Service analysis, using data from the School Nutrition Dietary Assessment Study III (SNDA-III), collected 

in 2004-2005
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Table C.4

School Foodservice Authority (SFA) competitive food revenue as percent of total revenue 

(data for Figure 5)

Percentile of SFAs Competitive food revenue as a percent of total SFA revenue

0 0%

10 0%

20 0%

30 3%

40 6%

50 11%

60 15%

70 21%

80 27%

90 36%

95 44%

99 70%

Source: USDA, Economic Research Service analysis, using data from the School Food Authorities Characteristics Study 

(SFACS), 2002-03.

Table C.3 

Characteristics of secondary schools in differing schoolfoodservice competitive 

food revenue quartiles (data for Figures 3B and 4B)

Secondary schools

School foodservice competitive food revenue quartiles

(school foodservice competitive food revenues per student per year)

Overall 

mean

 <=25th %tile

<=$5.79

>25th-<=50th 

% tile

>$5.79-

<=$46.91

>50th - <=75th 

%tile

>$46.91-

<=$99.21

>75th %

>$99.21

% Low poverty (More affluent districts) 68.2% 56.2% 63.1% 70.5% 80.9%

% Medium poverty 26.0% 32.1% 32.8% 24.2% 19.1%

% High poverty 5.9% 11.7% 4.1% 5.2% 0.0%

% Students receiving free/reduced price 

meals 39.3% 42.4% 46.1% 39.2% 29.0%

% Non-white students 30.7% 29.4% 28.4% 37.8% 27.8%

Weekly lunch participation 53.5% 64.3% 56.4% 48.3% 44.3%

Average price of full-price meal $1.62 $1.32 $1.66 $1.65 $1.89

Offer school breakfast program 83.0% 83.9% 85.3% 85.1% 75.1%

Have non-foodservice vending 69.4% 64.5% 69.0% 77.8% 60.2%

Have open campus 15.7% 22.0% 13.4% 23.7% 6.5%

Have fundraisers selling sweet or salty 

snacks 52.3% 50.7% 56.9% 58.8% 35.0%

Have State or District level wellness policy 24.1% 12.5% 40.1% 28.5% 18.1%

Source: USDA, Economic Research Service analysis, using data from the School Nutrition Dietary Assessment Study III (SNDA-III), collected 

in 2004-2005
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Table C.5 

Composition of School Foodservice Authority revenues in SFAs with higher shares of 

revenue from competitive foods (data for Figure 6)

Composition of SFA Revenues on a Per-Student, Per-Day Basis

Percentiles of SFAs

USDA meal 

reimbursements 

Student payments 

for USDA meals

Competitive food 

sale revenues

0 $1.15 $0.38 $0.00

20 $1.11 $0.64 $0.01

30 $1.40 $0.46 $0.06

40 $1.36 $0.54 $0.13

50 $1.05 $0.54 $0.20

60 $0.71 $0.56 $0.25

70 $0.54 $0.64 $0.34

80 $0.58 $0.47 $0.42

90 $0.50 $0.45 $0.58

95 $0.33 $0.53 $0.78

99 $0.20 $0.30 $1.25

Source: USDA, Economic Research Service analysis, using data from the School Food Authorities Characteristics Study 

(SFACS), 2002-03.
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Table C.6

Characteristics of School Foodservice Authorities in differing quartiles defined by share of revenues from 

competitive foods

School foodservice competitive food revenue quartiles

National 

mean 1 2 3 4

 <=25th 

%tile

>25th-

<=50th % 

tile

>50th - 

<=75th %tile >75th %

School Type

Percent Elementary Schools 63.4 62.2 64.5 63.6 63.0

Percent Middle Schools 17.6 16.7 16.9 18.3 18.5

Percent High Schools 19.0 21.1 18.5 18.1 18.5

Socioeconomic

 Average Poverty Level of District 15.4 18.2 17.5 13.5 9.5

Percent Students Receiving Free Meals 31.2 38.1 34.8 27.8 17.4

Percent Students Receiving Reduced-Price Meals 9.3 10.5 10 9.2 6.4

Geographic

Percent Rural 50.7 56 63.8 49.0 26.0

Percent Suburban 41 31.3 30.3 44.1 69.4

Percent Urban 8.3 12.7 5.9 6.9 4.6

Percent Mid-Atlantic 10.0 8.6 5.6 10.0 18.5

Percent Midwest 24.6 17.9 19.8 36.1 30.8

Percent Mountain 16.0 20.0 24.2 9.2 4.9

Percent Northeast 11.7 4.2 9.3 14 26.6

Percent Southeast 8.3 2.7 14.9 14.3 3.8

Percent Southwest 15.3 23.7 15.9 9.2 5.4

Percent West 14.1 22.9 10.3 7.2 10

State

State reimbursement as percent of revenue 2.4 2.7 2.5 2.4 2.0

Meal Characteristics

Average breakfast price 0.94 0.94 0.89 0.9 1.01

Breakfasts as percent of USDA meals 20.4 24.0 21.8 18.6 13.2

Average lunch price 1.56 1.56 1.43 1.55 1.73

National School Lunch Program lunches per student 

(annual) 113.9 115.0 124.9 122.1 88.9

USDA breakfasts per student (annual) 34.0 44.6 37.9 27.5 16.6

Source: USDA, Economic Research Service analysis, using data from the School Food Authorities Characteristics Study (SFACS), 2002-03.